20170782 Ver 1_WRC Comments_20171120

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
November 20, 2017
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Pisgah Forest Base Camp
North Glade Prong and UTs, Transylvania County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to impact 100 ft of North Glade Prong and unnamed tributaries and 0.009 acre of
wetland by extending existing culverts and placing new culverts in Transylvania 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).
Project activities should not impact wild trout and activities do not need to be avoided during the
trout moratorium.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
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 matted as soon as possible, preferably at the end of each work day.
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. Culvert material for Impact 1 is either HDPE or corrugated metal pipe. We recommend
against using smooth-walled HDPE material for culverts, as this slick material is less likely
to hold stream substrate and provide for movement of aquatic organisms like fish and
salamanders.
4. Removal of riparian vegetation along streams should be avoided as much as possible outside
of the impact areas. Streamside woody vegetation is limited on the property, and we
recommend that a native woody buffer of at least 30 ft be established. A wide forested buffer
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Pisgah Forest Base Camp Page 2 November 20, 2017
North Glade Prong &UTs, Transylvania
can ensure greater bank stability, filter overland pollutants, and provide habitat for birds and
other wildlife.
5. The planting specifications include Tall Fescue for temporary seeding. They also specify
Tall Fescue and Sericea Lespedeza for permanent seeding specifications but note that they
should not be used in riparian areas; however, specifications are not provided for riparian
areas. Both Tall Fescue and Sericea Lespedeza are highly invasive and should be avoided.
For temporary seeding, NCWRC recommends an alternative mix of Red Clover, Creeping
Red Fescue, and a grain, such as Oats, Wheat, or Rye. For permanent seeding in riparian
areas, we recommend a mix of native trees, shrubs, forbs, and grasses.
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,
XaA�J,�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Derek Goddard, Blue Ridge Environmental Consultants
Kevin Mitchell, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service