20231319 Ver 1_WRC Comments_20231030

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
October 30, 2023
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Ashe County Middle School
UTs to Cole Branch, Wetlands, AsheCounty
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to impact 0.498 acre of wetland and 455 ft of unnamed tributaries to Cole Branch in
Ashe County. I attended a site visit on October 27, 2023. Our comments on this application are
offered for your consideration under provisions of the Clean Water Act of 1977 (33 U.S.C. 466
et. seq.) and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-
667d).
Wild Brown Trout are found in the vicinity of the project, and in -stream activities should be
avoided between October 15 and April 15 to minimize impacts to trout reproduction. The site is
adjacent to the Mount Jefferson State Natural Area, which is recognized by the NC Natural
Heritage Program and Exceptional for the richness of rare species it contains and the ecological
importance of the site. There are Bog Turtle [Glyptemys muhlenbergii, US Threatened (T) due to
Similarity of Appearance, NC T] records in other nearby wetland sites, and it is possible that
wetlands on the site do support bog turtles, so work around the main southern wetland should be
done carefully to avoid unnecessary compaction and access to non -impact areas.
The application proposes to construct a new school on a 67-acre tract. Wetlands will be filled
and culverts and French drains installed, involving stream impacts. Mitigation will be needed for
wetland and stream impacts. We recommend that mitigation be provided at a 2:1 ratio.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Work should be accomplished as quickly as possible and vigilance used in sediment and
erosion control during site preparation, construction, and clean up. Disturbed areas should be
seeded, mulched and/or matted as soon as possible, preferably at the end of each workday.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Ashe County Middle School Page 2 October 30, 2023
Wetlands and UTs Cole Br, Ashe Co.
2. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
3. In -stream impacts should be avoided October 15 to April 15 to minimize impacts to trout
reproduction.
4. The application proposes using a high density polyethylene (HDPE) culvert for one of the
impacts. We recommend against using HDPE material, as this slick material is less likely to
hold stream substrate and provide for movement of aquatic organisms like fish and
salamanders.
5. If heavy equipment is used for temporary wetland impacts, work should be done from high
ground or from mud mats. Non -impact wetlands should be flagged off so that equipment is
kept out of them.
6. Limit impervious surface to less than 10% or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%.
7. Use non-invasive native species and Low Impact Development (LID) technology in
landscaping. Using native species instead of ornamentals should reduce the need for water,
fertilizers and pesticides. Using LID technology in landscaping will not only help maintain
the predevelopment hydrologic regime, but also enhance the aesthetic and habitat value of
the site.
8. Protect riparian buffers on the site and set aside the non -developed forested areas on the
upper slopes as forested green space. Maintain open space areas with native vegetation.
9. We recommend working with the NC Wildlife Resources Commission to manage and
maintain the main wetland area as an outdoor classroom. Please reach out to Andrea Leslie at
andrea.lesliegncwildlife if interested.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: McKenzie Beyer, C1earWater Environmental
Rebecca Chandler, NC Division of Water Resources
Gabrielle Graeter, NCWRC
Sue Cameron, US Fish and Wildlife Service