20240160 Ver 1_WRC Comments_20240223

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
February 23, 2024
Mr. Shannon Healy
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: River Stone Business Park — Sites 4 and 5
UTs Floyd Creek, Rutherford County
Dear Ms. Healy:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 81 ft of unnamed tributaries (UTs) to Floyd Creek and 0.063
acre of wetland, as well as temporarily impact 32 ft of UTs and 0.009 acre of wetland in
Rutherford 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. Floyd Creek supports the Seagreen Darter (Etheostoma thalassinum), which is NC
Significantly Rare. Excellent erosion and sediment control are needed to minimize impacts to
this sensitive species.
Impacts are associated with a development that would require substantial cut and fill. The plan
set is not easy to read, but it appears that high density polyethelyne (HDPE) pipes will be used
for two culverts.
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]

River Stone Business Park Page 2 February 23, 2024
UTs Floyd Cr & Wetlands, Rutherford Co
3. The application proposes using HDPE culverts. We recommend against using smooth -walled
RCP or 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. The plan set specifies the planting of Tall Fescue for permanent stabilization. Tall Fescue
should be avoided, as it is invasive and has minimal wildlife benefits. Instead, a quick
growing seed such as Wheat, Rye Grain or Oats is recommended. Perennial native grasses
and wildflowers can be added to the seed mix in order to provide a more permanent
herbaceous cover. Native trees and shrubs should be planted to provide permanent and
natural bank stabilization.
7. 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,
�U'P4�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: Alex Lowdermilk, McGill & Associates
Tyler Hickman, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service