20170842 Ver 1_WRC Comments_20170731

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
July 31, 2017
Mr. William Elliott
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Fleetwood Fire and Rescue Facility
UT to Old Field Creek, Ashe County
Dear Mr. Elliott:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an application to
place a culvert on an unnamed tributary (UT) to Old Field Creek, temporarily impacting 10 feet and
permanently impacting 140 feet of stream in Ashe 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).
There are wild Brook Trout and Brown Trout in the project vicinity, and project activities should be
avoided between October 15 and April 15 to minimize impacts to trout spawning. The site is just
upstream of the South Fork New River, recognized by the NC Natural Heritage Program as the South
Fork New River Aquatic Habitat, rated Exceptional for the richness of rare species it contains. The
following rare species are found in Old Field Creek and/or the South Fork New River in the vicinity of
the project: two mollusks—Spike [Elliptio dilatata, NC Special Concern (SC)] and Seep Mudalia
(Leptoxis dilatata, NC Threatened); two fishes endemic to the New River basin—Kanawha Minnow
[Phenacobius teretulus, US Federal Species of Concern (FSC), NC SC], and Kanawha Darter
(Etheostoma kanawhae, NC Significantly Rare); and five NC Significantly Rare dragonflies --Splendid
Clubtail (Gomphus lineatifrons), Mustached Clubtail (Gomphus adelphus), Green -faced Clubtail
(Gomphus viridifrons), Pygmy Snaketail (Ophiogomphus howeii, US FSC), and Brook Snaketail
(Ophiogomphus asperus). Both trout and these rare species are especially sensitive to sedimentation.
The application proposes to culvert 140 of UT to Old Field Creek in order to provide parking, turn around
space, and a heliopad for a new multi -modal rescue facility. Impervious cover at the site will be 24%, and
it appears that stormwater will be managed with the use of six swales that will send stormwater off-site to
a road, presumably ending up in Old Field Creek.
Because the site will drain to nearby habitat occupied by Brook Trout and numerous listed and rare
species, we are especially concerned about the potential for impacts from stormwater from the site. We
strongly recommend that the design incorporate on-site stormwater control measures that together mimic
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Fleetwood Fire & Rescue Page 2 July 31, 2017
UT Old Field Cr, Ashe County
a hydrograph consistent with an impervious coverage of less than 10% and remove stormwater pollutants.
We recommend using Low Impact Development (LID) techniques in site design to lessen the impact of
the development on the natural hydrologic cycle by using native vegetation and natural drainage patterns,
optimizing water infiltration, and implementing smaller localized best management practices. As the site
drains to a cool water mountain stream, stormwater management practices should be designed to release
cooler water.
We offer the following recommendations for the project to minimize impacts to fish and wildlife
resources:
1. In -channel work should be avoided between October 15 and April 15 in order to minimize impacts to
wild trout.
2. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
Disturbed areas should be seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day; at a minimum, disturbed areas should be stabilized within five working days or seven
calendar days, whichever is shorter.
3. In addition, we request the use of sediment and erosion control practices outlined in the Design
Standards in Sensitive Watersheds (15A NCAC 4B .0124).
4. Effective sediment and erosion control measures must be used and maintained to stabilize stream
banks quickly after the stream crossing and utility crossing are installed. Heavy fiber matting such as
coir over straw, and a mix of quick growing seed such as rye grain or oats, red clover, and creeping
red fescue is recommended wherever there are exposed soils near the stream. Tall fescue should be
avoided. Native vegetation, especially shrubs and trees, should planted.
5. Manage stormwater from the site in order to mimic a hydrograph consistent with an impervious
coverage of less than 10%. Incorporate Low Impact Development (LID) techniques in site design.
Ensure that stormwater management controls temperature, releasing cool water downstream.
6. Use non-invasive native species and 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.
Thank you for the opportunity to review and comment on this project. Please contact me at (828) 558-
6011 if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Derek Goddard, BREC
Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Kin Hodges, NCWRC