20150839 Ver 1_WRC Comments_20150916

_ North Carolina Wildlife Resources Commission _
Gordon Myers, Executive Director
September 16, 2015
Ms. Tasha Alexander
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801 -5006
SUBJECT: Comments on Maple Trace
Reems Creek and UT, Buncombe County
Dear Ms. Alexander:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 130 feet of an unnamed tributary (UT) to Reems Creek and 0.005 acre of
wetland and install a water line crossing, impacting 20 ft of Reems Creek 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).
Reems Creek is stocked with trout, but most spawning likely occurs in its upper reaches. The
project should not impact trout. Therefore, this work does not need to be avoided during the
spawning season.
The application proposes to culvert 130 feet of UT to Reems Creek with twin 48 -inch HDPE
culverts placed at identical elevations. This culvert length seems excessive, and we recommend
shortening this length if at all possible. Installation of twin culverts often result in one culvert
filling with sediment and the one functioning as the dominant route. We recommend against this
design and suggest that the applicant use one larger structure, such as a bridge, arched culvert, or
elliptical pipe. Given the density of housing proposed for this development, the magnitude of
stormflows may increase; it is essential that the structure installed can carry stormflows without
causing downstream or upstream erosion, maintain stream substrate on the structure bottom, and
enable passage of aquatic organisms.
We offer the following recommendations to minimize impacts to fish and wildlife:
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

Maple Trace Page 2 September 16, 2015
Reems Cr and UT, Buncombe Co
1. We recommend against using smooth - walled HDPE, as this slick material is less likely to
hold stream substrate and provide for movement of aquatic organisms like fish and
salamanders.
2. We recommend using a bridge, arched culvert, or elliptical culvert instead of dual circular
culverts.
3. Effective sediment and erosion control measures must be used and maintained to stabilize the
stream banks quickly after the culvert and utility line are installed. In order to stabilize the
stream banks, we recommend using matting over straw and a quick growing temporary seed
mix without Tall Fescue. We recommend planting native trees and shrubs to provide
permanent and natural bank stabilization.
4. Matting used for bank stabilization should be free of nylon mesh; nylon mesh netting
frequently entangles wildlife and is slow to degrade resulting in a hazard that may last for
years.
5. Culvert and utility line installation should be constructed in the dry. If this is not possible for
the Reems Creek utility crossing, installation should be performed so that the work area is
isolated from flows in some manner, such as with a coffer dam.
6. The stream channel at the utility crossing 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.
7. The streams should not be excavated except in the immediate vicinity of the culvert and
utility locations.
8. Removal of riparian vegetation along streams should be avoided as much as possible outside
of the impact areas.
Thank you for the opportunity to review and comment on this project. Please contact me at
(828) 400 -4223 if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator
Habitat Conservation Program
ec: Kaylie Yankura, C1earWater Environmental
Zan Price, NC Division of Water Resources