20231440 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: Mountain Springs RVC
South Hominy Creek and UT, Wetland, Buncombe County
Dear Mr. Anderson:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to temporarily impact 30 ft of South Hominy Creek and permanently impact 8 ft of a
UT (unnamed tributary) and 0.004 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 Rainbow Trout are present in the vicinity of the project, and in -stream activities should be
avoided from January 1 to April 15 to minimize impacts to trout reproduction. In addition, South
Hominy Creek supports Eastern Hellbender (Cryptobrancus alleganiensis, US Federal Species
of Concern, NC Special Concern) and French Broad River Crayfish (Cambarus reburrus, NC
Significantly Rare). Excellent erosion and sediment control are needed to minimize impacts to
these sensitive species.
The project involves the establishment of a large RV park and a septic system. Impacts include
an open trench cut of South Hominy Creek for sewer line, a culvert on a UT, and wetland fill for
an access road.
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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Mountain Springs RWC Page 2 November 14, 2023
Hominy Cr & UT & Wetland, Buncombe Co
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.
3. In -stream work should be avoided between January 1 and April 15 to minimize impacts to
Rainbow Trout reproduction.
4. The application proposes using a HDPE culvert. 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.
5. Project specifications include using a ford on South Hominy Creek and stabilizing the stream
banks with rock. We recommend sloping the banks and planting native woody vegetation
instead.
6. Stream channels at utility crossings should be restored to near pre -disturbance conditions.
Channel dimensions should mimic the existing dimensions, and the stream bed should set be
at the pre-existing elevation. At least 6-8 inches of natural bed material should be placed on
top of the restored stream channel bed; this bed material should mimic that which is found in
the stream bed. Banks should be stabilized with a seed mix that includes a quick -growing
temporary seed and native riparian vegetation. Native woody vegetation should also be
planted.
7. The application notes that disturbed parts of the riparian areas will be replanted with native
perennial seed and containerized plants. We support this approach, but recommend
eliminating Silver Maple from the planting list, as this tree is not typical in the mountains
except for in very large floodplain areas. In addition, if River Birch is not found on site, we
recommend eliminating this in favor of a more typical species, such as Ironwood (Carpinus
caroliniana) or Sweet Birch (Betula lenta).
8. As a large forested area will be cleared for a septic field, we recommend replanting this with
native herbaceous seed to benefit native pollinators. Please contact NCWRC for seed
recommendations, if needed.
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
cc: Emily Tarsa, C1earWater Environmental
Andrew Moore, NC Division of Water Resources