20240575 Ver 1_WRC Comments_20240521

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
May 21, 2024
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Big Laurel Creek Stabilization
Big Laurel Creek and Wetland, Ashe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 2,665 ft of Big Laurel Creek and impact 0.06 acre of wetland in Ashe County. I
visited the site on April 26, 2024. 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).
Although there are Rainbow Trout and Brown Trout in the project vicinity, a trout moratorium is not
required for this project. The project reach is recognized by the NC Natural Heritage Program as part
of the North Fork New River Aquatic Habitat, rated Exceptional for its ecological importance and the
richness of rare species it contains. Rare and listed species found in the river in the vicinity of the
project include Seep Mudalia [Leptoxis dilatata, US Federal Species of Concern (FSC), NC Special
Concern (SC)], Eastern Hellbender (Cryptobranchus alleganiensis, US FSC, NC SC), Kanawha
Minnow (Phenacobius teretulus, NC SC), Kanawha Darter [Etheostoma kanawhae, NC Significantly
Rare (SR)], Tongue-tied Minnow (Exoglossum laurae, NC SR), Appalachia Darter (Percina
gymnocephala, NC SR), and Kanawha Rosyface Shiner (Notropis sp., NC SR). It is very possible
that hellbenders are found within the project reach. These species are especially sensitive to
sedimentation, and good erosion and sediment control measures for this project are essential to
protect these species.
The application proposes to restore unstable reaches of stream by enhancing the channel in -place
with constructed riffles, rock sills, rock vanes, j-hooks, and boulder and toewood revetments.
Hellbender shelters will be constructed. Construction will be performed in the wet, but flows will be
diverted around work areas. It is unknown how wide the planted woody buffer will be, but an
assortment of native riparian and nut/fruit species will be planted.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Big Laurel Cr Stabilization Page 2 May 21, 2024
Big Laurel Cr, Ashe Co
We offer the following recommendations to minimize impacts to the aquatic community:
1. Based on our site visit, we ask for the following modifications to the design plan:
a. At the bend at 1900-2000', we recommend eliminating the toewood at the bedrock
feature which may provide good hellbender habitat. Instead, we recommend planting
only. Toewood may be useful at 1000-1300' on the right bank.
b. Avoid running over or otherwise disturbing existing boulders on the bank or within the
channel; these features could provide valuable existing habitat for hellbenders.
c. Avoid or greatly minimize any grading associated with the boulder toe at the large
sycamore on the left bank at 1000' in order to avoid disturbing the root system.
d. There is a constructed riffle designed for 700'; it is unclear why this is here, as there is an
existing cobble riffle in this location. We recommend re-evaluating this design feature.
2. 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. We appreciate that
disturbed areas will be stabilized at the end of each work day.
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. We recommend that a woody buffer of at least 30 feet be planted on both sides of the streams as
infrastructure allows in order to ensure project success. A wide forested buffer can ensure
greater bank stability, filter overland pollutants, and provide habitat for birds and other wildlife.
5. As hellbenders may be present on site, hellbender surveys should be conducted during the
hellbender breeding season this year. Natural Resources Conservation Service (MRCS) staff
(Morgan Harris) and NCWRC staff will coordinate on these surveys. Results from these surveys
should be used to inform design and construction.
6. Construction staff should watch for hellbenders during construction. If animals are disturbed
during construction, they should be captured in a bucket and moved away from the area of
disturbance. Please notify Lori Williams if hellbenders are found.
7. It is our understanding that construction will take place in January 2025. If this timeframe is
shifted (especially into the fall), please coordinate with NCWRC staff to minimize impacts to
hellbenders.
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.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Adam Williams, Brushy Fork Environmental
Morgan Harris, NRCS
Seren Homer, NC Division of Water Resources
Lori Williams, NCWRC