20180847 Ver 1 _WRCComments _20180720

� North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
July 20, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: White Oak Phase 5
UT to Clear Creek and wetlands, Henderson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 149.5 ft of an unnamed tributary (UT) to Clear Creek and 0.09 acre of
wetland 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).
Project activities should not impact wild trout and do not need to be avoided during the trout
moratorium. However, several rare species are present downstream of the project, including the
Creeper (Strophitus undulatus, NC Threatened), Southern Blotched Chub [Erimystax insignis
eristigma, US Federal Species of Concern, NC Significantly Rare (SR)], and a mayfly (Tsalia
berneri, NC SR). These species are sensitive to sediment, and excellent erosion and sediment
control is important to minimize impacts to these species.
It is unclear if a stormwater management plan will be developed for the project. Unmanaged
stormwater from the site could destabilize stream channels, negatively impact instream habitat,
and harm aquatic biota. Stormwater control measures should mimic the hydrograph consistent
with an impervious coverage of less than 10%. We recommend the use of Low Impact Design
techniques, such as grassed swales and pervious pavement; curb and gutter, catch basins, and
underground piping of stormwater should be avoided. As stormwater runoff from pavement can
cause short-term temperature spikes in downstream waters, mechanisms to lower stormwater
temperature should be incorporated into the stormwater management design.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

White Oak Phase 5 Page 2 July 20, 2018
UT Clear Cr & wetlands, Henderson County
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.
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. The application proposes using a 48 -inch HDPE culvert. We recommend against using slick -
bottomed HDPE material, as this material is less likely to hold stream substrate and provide
for movement of aquatic organisms like fish and salamanders.
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: Alea Tuttle, C1earWater Environmental Consultants
Andrew Moore, NC Division of Water Resources