SAW2023-00552_CarolinaRVSales_BoringMillBr&Wetland_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]
April 2, 2024

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

SUBJECT: SAW-2023-00552, Carolina RV Sales
Boring Branch and UT, Wetlands, Buncombe County

Dear Mr. Anderson:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 43 ft of Boring Mill Branch and temporarily impact 67 ft of an
unnamed tributary (UT) and permanently impact 0.095 acre and temporarily impact 0.01 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 trout reproduction should not be impacted by project activities, and a trout moratorium is
not needed.

The application proposes to construct an RV sales commercial site, impacting wetlands and
streams. Wetland work would be done from wetland mats.

We offer the following recommendations to minimize impacts to the aquatic community:
1. In-channel 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 stabilized at the end of each work day.
2. Any erosion control matting used should be free of nylon or plastic 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 seeding specifications include Tall Fescue and Bermudagrass, which are invasive and
should not be planted within the wetland and riparian areas. We recommend reseeding these
areas with native wetland and riparian seed.
SAW-2023-00552 Carolina RV Sales Page 2 April 2, 2024
Boring Mill Br, UT & Wetlands, Buncombe Co
4. Flag off wetland areas that are outside the impact area so that heavy equipment stays within
the impact area footprint.
5. It appears that the culvert material is high density polyethylene (HDPE). We recommend
against using HDPE or reinforced concrete material, as these smooth materials are less likely
to hold stream substrate and provide for movement of aquatic organisms like fish and
salamanders.
6. Culvert installation must be done in the dry.

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: Alan Moore, Nutter & Associates
Joey Winston, NC Division of Water Resources