EagleRockCove_UTsSpruceFork_Buncombe_NCWRCComments

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
March 19, 2024

Mr. Mitchell Anderson
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Eagle Rock Cove
UTs to Spruce Fork, Buncombe County

Dear Mr. Anderson

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 100 ft and temporarily impact 22 ft of unnamed tributaries to
Spruce Fork 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 project activities, and a trout moratorium is
not required. Impacts involve the replacement of one culvert and the installation of two other
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.
3. The application does not note what culvert material will be used. We recommend against
using smooth-walled high density polyethylene or reinforced concrete pipe material, as these
materials are less likely to hold stream substrate and provide for movement of aquatic
organisms like fish and salamanders.

Eagle Rock Cove Page 2 March 19, 2024
UTs Spruce Fork, Buncombe County
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

ec: Tyson Kurtz, ClearWater Environmental
Joey Winston, NC Division of Water Resources