20071250 Ver 5_WRC Comments_20241001

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
October 1, 2024
Ms. Brooke Davis
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Hawkins Mine Expansion, SAW-2008-01254
UTs to North Toe River and Wetlands, Mitchell County
Dear Ms. Davis:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 2,113 ft of unnamed tributaries (UTs) to the North Toe River
and 0.116 acre of wetland in Mitchell County. I visited the site on May 23, 2024. 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 should not be impacted by project activities, and a trout moratorium is not needed.
The site drains to the North Toe River, which is recognized by the NC Natural Heritage Program
as the North Toe River/Nolichucky River Aquatic Habitat, a natural area rated Very High for the
richness and ecological importance of rare species it contains. In the vicinity of the project,
Sharphead Darter [Etheostoma acuticeps, US Federal Species of Concern (FSC), NC Threatened
(T)] and Eastern Hellbender [Cryptobranchus alleganiensis, US FSC, NC Special Concern (SC)]
are found. Further downstream, Appalachian Elktoe [Alasmidonta raveneliana, US Endangered
(E), NC E], Mimic Shiner [Notropis volucellus, NC T), Wavyrayed Lampmussel (Lampsilis
fasciola, NC SC), and Highland Shiner [Notropis micropteryx, NC Significantly Rare (SR)] are
found. Anglers use this resource in the spring and summer. It is essential to employ effective
sediment and erosion control and stormwater management at the site to minimize impacts to
these species.
The project proposes to expand an existing waste rock disposal area by 54 acres. An existing
diversion channel would be realigned and streams and wetlands piped and diverted to the
diversion channel. The 54-acre area was forested but was cleared in the past year; riparian
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Hawkins Mine Expansion Page 2 October 1, 2024
UTs North Toe R, Mitchell Co
buffers are very narrow and streams appeared to have excess fine sediments from the logging
event.
Plans for these impacts were not provided. Mitigation is proposed to compensate for these
impacts via Division of Mitigation Services. Streams would be mitigated at a 2:1 ratio, and
wetlands would be mitigated at a 1:1, 1.5:1, or 2:1 ratio, depending on the NCWAM rating.
However, it is unclear how the ratios were determined, as wetlands rated High are proposed for a
1.5:1 ratio and some wetlands rated Medium are proposed for a 2:1 or 1.5:1 ratio. Based on our
observations, wetlands and streams have likely been impacted by the logging that has just
occurred; we recommend that all mitigation be provided at a 2:1 ratio.
We offer the following recommendations and requests for additional information:
• Please provide plans for impacts to streams and wetlands, including locations and types of
culverts and diversions.
• We recommend mitigating for all stream and wetland impacts with a 2:1 ratio.
• 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.
• Effective erosion and sediment control must be used in sediment and erosion control during
site preparation, construction, and clean up.
• We recommend planting native woody vegetation to achieve a buffer of 30 ft in width as
infrastructure allows along the diversion ditch throughout the site to cool water temperatures,
keep stream banks stable, and control overland pollutants.
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, EnviroScience
Sue Homewood and Tyler Hickman, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service