20190189 Ver 1_WRC Comments_20190307

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
March 7, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Lance Road Subdivision
UTs to Avery Creek, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to replace a 50 -ft culvert, install new 49 -ft and 11 -ft culverts, and install stormwater
management practices, resulting in 99 ft of impacts to unnamed tributaries (UTs) to Avery
Creek, permanent impacts to 0.094 acre of wetland, and temporary impacts to 0.005 acre of
wetland in Buncombe 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).
Wild trout reproduction should not be impacted by this project and a trout moratorium is not
needed. However, French Broad River Crayfish (Cambarus reburrus, NC Significantly Rare) is
found in Avery Creek.
The proposed impacts are associated with a subdivision development. It appears that part of the
project area is within the 100 -year floodplain. The NCWRC does not support commercial or
residential development within the 100 -year floodplain. The filling of floodplains increases the
potential for flooding and degrades in -stream habitats for fish and other aquatic organisms.
The project proposes to replace an existing culvert at on a UT to Avery Creek with a triple
barreled culvert of 24 -in HDPE. We recommend against using a triple -barreled culvert, as
culverts set at the same elevation often result in one culvert carrying most or all of the flows over
time; this can cause channel instability and problems with aquatic organism passage. We also
recommend against the use of HDPE material, 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]

Lance Road Subdivision Page 2 March 7, 2019
UTs Avery Cr, Buncombe 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. Disturbed areas should be
seeded, mulched and matted as soon as possible, preferably at the end of each work day.
2. We recommend using an alternative material to smooth-walled HDPE for culverts.
3. We recommend replacing the triple -barreled culvert with a spanning structure such as a
bridge or bottomless arch instead. If a culvert must be used, we recommend using a single
larger squash pipe capable of carrying base and stormflows.
4. 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.
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: Mike Lovoy, Advantage Civil Engineering
Zan Price, NC Division of Water Resources