20240062 Ver 1_WRC Comments_20240208

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
February 8, 2024
Mr. Mitchell Anderson
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Mills Gap Road — Landing at Meadowview
UTs Cane Creek and Wetlands, Henderson County
Dear Mr. Anderson:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 89 ft of unnamed tributaries (UTs) to Cane Creek and 0.0861
acre of wetland, as well as temporarily impact 116 ft of UTs in Henderson 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. Cane Creek supports the Creeper mussel [Strophitus undulatus, NC Threatened (T)],
Blotched Chub (Erimystax insignis, NC T), and Ohio Lamprey (Icthyomyzon bdellium, NC
Special Concern). Excellent erosion and sediment control are needed to minimize impacts to
these sensitive species.
The project involves the establishment of a large residential development in the 100-year
floodplain. The NCWRC does not support commercial or residential development within the
100-year floodplain. The filling of floodplains increases the potential for flooding and degrades
in -stream habitats for fish and other aquatic organisms.
Two reinforced concrete pipe (RCP) culverts are proposed along with riprap within the channel
beds upstream and downstream of these pipes. Four wetland areas would be filled.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Mills Gap Road — Landing at Meadowview Page 2 February 8, 2024
UTs Cane Cr & Wetlands, Henderson Co
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.
3. The application proposes using RCP culverts. We recommend against using smooth -walled
RCP or high density polyethylene (HDPE) material, as these smooth materials are 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 and plant native riparian buffers on the site and set aside non -developed areas as
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,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: Michael Brame, Pilot Environmental
Andrew Moore, NC Division of Water Resources