WoodfinRetirementResidence_UTsBeaverdamCr_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 30, 2024

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

SUBJECT: Woodfin Retirement Residence
UTs Beaverdam Creek, Buncombe County

Dear Mr. Anderson:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 281 ft and temporarily impact 36 ft of unnamed tributaries
(UTs) to Beaverdam 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).

Wild trout reproduction should not be impacted by project activities, and a trout moratorium is
not needed.

The application proposes to construct a residential development on forested land, impacting
streams. A vast majority of the land will be cleared and developed. Streams would be culverted
under a road and building, and a utility crossing will be constructed.

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. Culvert material is not specified. We recommend against using high density polyethylene
(HDPE) or reinforced concrete pipe (RCP), as these smooth materials are less likely to hold
stream substrate and provide for movement of aquatic organisms like fish and salamanders.

Woodfin Retirement Residence Page 2 April 30, 2024
UTs Beaverdam Cr, Buncombe Co
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: McKenzie Beyer, ClearWater Environmental
Joey Winston, NC Division of Water Resources