20180648 Ver 1_WRC Comments_20180522

0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
May 22, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Benito Horse Farm
UT Foster Creek, Henderson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 60 ft of an unnamed tributary (UT) to Foster Creek for access to two
homesites in Henderson 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).
This project should not affect wild trout reproduction and the activities do not need to be avoided
during the trout spawning moratorium. The site is just upstream of a reach of the Mills River
that is recognized by the NC Natural Heritage Program as the Mills River Aquatic Habitat, rated
High for the richness of rare species it contains. Aquatic species found in the vicinity of the
project include four mussels—Appalachian Elktoe [Alasmidonta raveneliana, US Endangered
(E), NC E], Slippershell (Alasmidonta viridis, NC E), Tennessee Heelsplitter [Lasmigona
holstonia, NC E, US Federal Species of Concern (FSC)] and Creeper (Strophitus undulatus, NC
Threatened); a rare fish—Southern Blotched Chub (Erimystax insignis eristigma, NC
Significantly Rare); and a rare salamander—the Eastern Hellbender (Cryptobranchus
alleganiensis, US Federal Species of Concern, NC Special Concern). We are particularly
concerned about potential sediment impacts to these rare and listed species, and proper sediment
and erosion control is essential to protect this aquatic community.
The project will involve the construction of a driveway that will cross the UT to Foster Creek
with a 60 -in smooth-walled HDPE culvert that is 60 ft long. 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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Benito Horse Farm Page 2 May 22, 2018
UT Foster Cr, Henderson Co
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. 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. The stream has virtually no woody riparian buffer. We recommend that a woody buffer
composed of native trees, shrubs, grasses, and wildflowers of at least 30 feet be planted on
both sides of the stream as infrastructure allows in order to ensure project success. A wide
forested buffer can ensure greater bank stability, filter overland pollutants, and provide
habitat for birds and other wildlife. Please refer to NC State's "Small-scale Solutions to
Eroding Stream Banks" (attached) for planting recommendations.
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
Attachment: Small-scale Solutions to Eroding Stream Banks
ec: Shawn Anderson, Anderson Construction
Annabel Benito, landowner
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service