20120776 Ver 2_WRC Comments_20150508

1 North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
May 7, 2015
Ms. Tasha Alexander
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801 -5006
SUBJECT: Town of Boone Water System Improvements
South Fork New River and tributaries, Watauga County
Dear Ms. Alexander:
Biologists with the North Carolina Wildlife Resources Commission ( NCWRC) reviewed an
application for stream and wetland impacts associated with the installation of a water intake
structure on the South Fork New River and installation of a new water line and associated pump
stations in Watauga County. NCWRC submitted comments on an earlier application on
September 10, 2012; we have updated these comments based on the present permit application
and additional biological data and analyses. 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).
Most of the water line crossings and culverts are on streams that either support wild trout
populations or are a short distance upstream of waters where trout spawning occurs. Recent surveys
have documented wild Brook and Brown Trout in Meadow Creek, so streams in this watershed have
been added to the list of streams where a trout moratorium should be observed. This list includes
the UT South Fork New River in Boone (S 1), Hardin Creek (S2), an unnamed tributary (UT) to Gap
Creek (S5 /S6), Meadow Creek (S7, 510, 511, S12 /S13), and UTs to Meadow Creek (S8, S9). Work
in and near these streams should not be undertaken between October 15 and April 15 (trout
spawning moratorium) to avoid harm to Brown, Rainbow, and/or Brook Trout spawning in the South
Fork New River, Meadow Creek, and Gap Creek.
The South Fork New River at the intake location is part of the South Fork New River Aquatic
Habitat, rated Very High by the NC Natural Heritage Program due to the richness of rare species it
contains. Rare or listed species found in the vicinity of the intake include Spike [NC Special
Concern (SC)], Seep Mudalia (NC Threatened), Kanawha Minnow [US Federal Species of Concern
(FSC), NC SC], Eastern Hellbender (US FSC, NC SC), Kanawha Darter [NC Significantly Rare
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

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Watauga County
(SR)], and Kanawha Rosyface Shiner (NC SR). There are older records of the Green Floater (US
FSC, NC SC) from the project vicinity, and this mussel has been recently found at an upstream
location in the South Fork New River; it is possible that it occurs in the project vicinity.
The application states that Spike mussels will be relocated from the intake location before any
construction work is undertaken. Due to the possibility that the Green Floater could exist at the
project site, we recommend that all mussels be relocated from the intake construction site.
The box culverts in UT to Gap Creek and Meadow Creek must be constructed so that fish passage is
minimally impeded. We appreciate the inclusion of baffles in the box culverts to help retain
bedload. Constructed riffles are proposed downstream of the culverts; these should not be used
unless they are necessary to backwater the culverts, help retain upstream bedload, or ensure that
outlet perching does not develop. Typically, these issues should not be encountered if the culvert
invert is recessed well below the natural stream grade, though the steep grade (6 % +) on the UT to
Gap Creek site may be problematic.
We have no major concerns with the project provided it is completed as described in the application
and consistent with measures articulated in the EA. These include doing the majority of stream
work, particularly the intake work in the river, in the dry. Also, it is particularly important that
effective erosion controls be used consistently with this project.
In addition to considering the preceding comments, we offer the following recommendations to
minimize impacts to fish and wildlife habitats, particularly during construction:
1. Work in and near UT South Fork New River in Boone (S1), Hardin Creek (S2), UT to Gap
Creek (S5 /S6), Meadow Creek (S7, 510, 511, S12 /S13), and UTs to Meadow Creek (S8, S9)
should not be undertaken between October 15 and April 15 (trout spawning moratorium) to
avoid harm to Brown, Rainbow, and/or Brook trout spawning in the South Fork New River,
Gap Creek, and Meadow Creek.
2. All mussels should be relocated from the intake construction area.
3. The culverts must be installed with their base barrel /s recessed about 1 foot below the natural
grades of the streams. Baffles must be used in the culverts to help retain bedload.
Backfilling with stockpiled stream gravel and cobble is recommended.
4. Sediment and erosion control measures for sensitive watersheds (15A NCAC 4B .0124) must
be used and maintained until all disturbed soils are permanently stabilized. All bare soil shall
be seeded as soon as possible after ground disturbance and erosion control matting used with
seeding on disturbed stream banks.
5. Coir matting used for bank stabilization should be free of nylon mesh; nylon mesh netting
frequently entangles wildlife and is slow to degrade resulting in a hazard that may last for
years.
6. Stream and river channel excavation shall be conducted in the dry using sandbags or other
temporary diversion structures.
7. Clearing of riparian vegetation should be avoided as much as possible by routing utility line
corridors outside of streamside buffer areas. Trees and shrubs should be cut with their
stumps left in the ground (e.g. no grubbing) where temporary access is needed.
8. Rock, sand, or other materials must not be excavated from stream channels except in the
immediate permitted areas.

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Watauga County
9. The stream channels must be restored to stable and near natural conditions after completing
the pipe installations. The stream bottoms should not be covered with rip rap and any rock
used for bank stabilization should be limited to below the normal high water level.
Vegetation should be used for stabilization above the ordinary high water level.
10. Any concrete work must be isolated from water to avoid toxic pH levels in contact water.
Thank you for the opportunity to review and comment on this project. Please contact me at
(828) 400 -4223 if you have any questions about these comments or need further assistance.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Ward Marotti, WK Dickson
Sue Homewood, NC Division of Water Resources
Steve Fraley, Kevin Hining, Kin Hodges, and Lori Williams, NCWRC