20180661 Ver 1_WRC Comments_20180507

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
May 7, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Mud Creek Sewer Line
Henderson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application for impacts associated with the Mud Creek Sewer Line, which include 120 ft of
temporary impact for eight stream crossings, as well as 1.82 acres of wetland impact in
Henderson County. I visited the site with the US Fish and Wildlife Service and C1earWater
Environmental staff on April 27, 2018. 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).
Henderson County intends to construct a new sewer line on 13 acres to connect Fletcher
Academy to the Cane Creek/Henderson County municipal sewer line; Fletcher Academy is
currently operating under a Special Order of Consent due to noncompliance with effluent limits
for BOD and NH3-N. The proposed line would cross 19 wetland areas and 6 unnamed tributaries
to Mud Creek. Wild trout would not be impacted by project activities, and a trout moratorium is
not needed. Mud Creek hosts the Southern Blotched Chub (Erimystax insignis eristigma, US
Federal Species of Concern, NC Significantly Rare).
The sewer line will be installed in the dry via trench cut through wetlands and streams.
Wetlands, stream channels, and stream banks will be restored to original contours and stabilized
with matting and seed. Based on conversations with C1earWater Environmental staff, our
understanding is that the construction corridor would be a 25 -ft wide swath, expanding to 40 ft in
W 1 and S 1. A 10 -ft wide right-of-way (ROW) would be maintained after construction.
Much of the project area is within the 100 -year floodplain of Mud Creek. Wetland impacts
include 1.47 acres of forested wetland and 0.34 acre of herbaceous wetland. We describe the
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Polk, Rutherford, Cleveland Counties
wetlands with the largest proposed impacts here. W1, for which 0.52 acre of impact are
proposed, is a forested wetland with a red maple canopy and rich understory, threaded through
with several sinuous streams. W4, which is forested, is proposed for 0.27 acre of impact, and
much of what was observed during the site visit was inundated. W13, in which 0.35 acre of
impact is proposed, appears to be primarily forested, with a canopy of box elder, ash, and other
species, transected by ditches likely dug to drain the wetland when it was farmed in the past.
NCWRC is concerned about the extensive wetland impact proposed by this project. In
particular, we are concerned about the possibility of hydrologic impacts to wetlands due to the
trench cut installation of the sewer lines. We question the feasibility of trench cut installation in
wetlands that are deeply inundated, such as W4. We strongly recommend that the applicant
examine alternatives to the proposed project, such as installing a force main that could be
constructed in road ROWs or constructing a line that would be suspended above the wetland
areas on pillars. We are particularly concerned about the section of line that would run through
W 1 and W 13, and we recommend that these wetlands be avoided.
We offer recommendations to minimize impacts to terrestrial and aquatic wildlife below and will
provide additional comments once a mitigation proposal is received and if any project route
revisions are proposed:
1. Alternatives to minimize the impacts to wetlands and streams should be explored.
2. Avoid equipment maintenance in the immediate vicinity of streams and wetlands, make
stream crossings as narrow as possible, minimize stream bank disturbance, avoid
spraying of herbicides, and where woody vegetation is cleared, cut so that stumps can
resprout.
3. Sediment and erosion controls measures should be installed prior to any land clearing or
construction. These measures should be routinely inspected and properly maintained.
Excessive silt and sediment loads can have numerous detrimental effects on aquatic
resources including destruction of spawning habitat, suffocation of eggs, and clogging of
gills of aquatic species.
4. Work performed in wetlands should be done from wetland mats to minimize compaction.
5. Wetland topsoil should be set aside during trenching for replacement afterwards and the
wetland and be replanted with a native wetland seed mix. For forested wetlands, any area
outside the 10 -ft maintenance ROW should be replanted with native woody species.
6. The top 6-12 inches of stream substrate should be stockpiled and kept saturated during
pipe installation, and replaced once the pipe is installed.
7. Stream banks should be stabilized with matting, temporary seed, and a native riparian
mix. We recommend that the native riparian mix also be applied 50 ft landward from the
stream.
8. Matting used for stabilization should be free of nylon or plastic mesh, as this type of
netting frequently entangles wildlife and is slow to degrade resulting in a hazard that may
last for years.
9. ROW maintenance on stream banks should be performed by hand, cutting woody
vegetation to allow resprouting. ROW maintenance through wetlands should also be
done by hand, avoiding the use of heavy machinery.
10. Re -seed all disturbed areas with seed mixtures that are beneficial to wildlife; avoid fescue
based mixtures because fescue is invasive and provides little benefit to wildlife. Native

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Polk, Rutherford, Cleveland Counties
mixes of grasses and herbaceous plants that emphasize pollinator species are
recommended. Allowing the corridor area to re -vegetate into a brush/scrub habitat would
maximize benefits to wildlife. For areas adjacent to residential areas, a native shrub/grass
option may be beneficial.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions.
Sincerely,
�A'��
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: Byron Hamstead, US Fish and Wildlife Service
Andrew Moore, NC Division of Water Resources
Clement Riddle, C1earWater Environmental Consultants