20231412 Ver 1_WRC Comments_20231114

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
November 14, 2023
Mr. Mitchell Anderson
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Old Charlotte Highway
UTs Gashes Creek and Wetlands, Buncombe County
Dear Mr. Anderson:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 172 ft of unnamed tributaries (UTs) to Gashes Creek and
0.029 acre of wetland in Buncombe County. 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 trout reproduction should not be impacted by the project, and a trout moratorium is not
needed. The northern forested part of the property is part of the Cedar Cliff/Little Cedar
Mountain Natural Area, rated Very High due to the ecological importance and richness of rare
species found in the area. This area should be avoided as much as possible, set aside as forested
green space.
The project involves the establishment of a large development of apartment buildings an 306
townhomes on a primarily forested 99-acre parcel. Three HDPE culverts are proposed, and
multiple wetlands would be filled.
We offer the following recommendations to minimize impacts to the aquatic community:
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.
2. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that
may last for years.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Old Charlotte Highway Page 2 November 14, 2023
UTs Gashes Cr & Wetland, Buncombe Co
3. The application proposes using HDPE culverts. We recommend against using smooth -walled
HDPE material, as this slick material is less likely to hold stream substrate and provide for
movement of aquatic organisms like fish and salamanders.
4. 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%.
5. 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.
6. 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.
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,
# a�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: Emily Tarsa, C1earWater Environmental
Andrew Moore, NC Division of Water Resources