20031409 Ver 3_WRC Comments_20200710

� North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
July 10, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Little Brasstown Creek - Lewis
Little Brasstown Creek, Cherokee County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 1,275 ft of Little Brasstown Creek in Cherokee 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 the project, and a trout moratorium is not
needed. However, the site is less than one mile upstream of Brasstown Creek, which is part of
the Upper Hiwassee River Aquatic Habitat, a natural area rated as Exceptional by the NC Natural
Heritage Program due to the richness of rare aquatic species it supports. Species in the
immediate vicinity of the confluence of Little Brasstown Creek with Brasstown Creek include
Sicklefin Redhorse [Moxostoma sp., NC Threatened (T)], Rainbow (Villosa iris, NC T), Eastern
Hellbender [Cryptobranchus alleganiensis, US Federal Species of Concern (FSC), NC Special
Concern (SC)], Banded Sculpin (Cottus carolinae, NC SC), Highland Shiner [Notropis
micropteryx, NC Significantly Rare (SR)], and Blotched Chub (Erimystax insignis, NC SR).
Knotty Burrowing Crayfish (Cambarus nodosus, NC SR) has been found in tributaries to Little
Brasstown Creek near the site.
We are particularly concerned about potential sediment impacts to rare and listed species in
Brasstown Creek. Sicklefin Redhorse spawn in Brasstown Creek in the late spring; we
recommend that project activities be avoided between April 1 and June 30 in order to avoid
sediment impacts to spawning and egg and early juvenile development.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

L Brasstown Creek - Lewis Page 2 July 10, 2020
L Brasstown,Cherokee County
The application proposes to stabilize eroding and reaches of stream with a various instream
structures, including constructed riffles and j-hooks. Banks will be graded and a native riparian
buffer of approximately 30 ft will be planted. Work will not be done in the dry, but work on new
reaches of channel will be done off-line.
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -channel 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/or matted as soon as possible, preferably at the end of
each work day. At a minimum, disturbed areas should be stabilized within five working days
or seven calendar days, whichever is shorter.
2. Special care should be used to to reduce the potential for sediment loss from the site.
3. Any erosion control matting used should be free of nylon or plastic mesh, as this type of
mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that
may last for years.
4. As soon as a stream reach is taken off-line, any stranded animals (e.g., fish, salamanders,
crayfish, aquatic insects) should be captured and relocated into the flowing stream.
5. Avoid in -stream work between April 1 and June 30 to minimize impacts to Sicklefln
Redhorse reproduction.
6. Replace River Birch with another species (e.g., Sweet Birch), as River Birch is typically only
found in large river floodplains.
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: Zan Price, Jennings Environmental
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Luke Etchison, NCWRC