20170359 Ver 3_WRC Comments_20241017

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
September 26, 2024
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Grandfather Golf and Country Club Loch Dornie Maintenance Dredging Plan
Linville River, Avery County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to impact 3.4 acres of Loch Dornie (Linville River) in Avery 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).
The project entails dredging 11 areas in the lake, totaling 3.4 acres. The lake would not be
lowered and the dredging done hydraulically. The subject areas would be dredged routinely on a
3-5 year rotation. The dredge material would be pumped into filter bags on land, and the bags
would be allowed to drain to Loch Dornie. Once somewhat dry, the sediments would be hauled
off site. The dredge areas would be surrounded by 1-2 sets of turbidity curtains. The applicant
developed a turbidity management plan and response protocol that was reviewed and approved
by the NC Division of Water Resources and NCWRC.
A robust population of wild Brown Trout are found in the project vicinity. In addition, the
Linville River also supports the endemic and rare Grandfather Mountain Crayfish (Cambarus
eeseeohensis, US Federal Species of Concern, NC Significantly Rare). The applicant has
requested that they be allowed to work within the January 2 — March 31 period of the Brown
Trout moratorium; as they have worked diligently to satisfy agency concerns about downstream
sediment risks and have an acceptable turbidity management plan and response protocol,
NCWRC will allow work during that time period. Therefore, the trout moratorium that will apply
to this work will be October 15- January 1.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Grandfather GCC Dredging Page 2 September 26, 2024
Linville River, Avery Co
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. In -lake 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.
2. 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.
3. In -lake activities should be avoided between October 15 and January 1 in order to minimize
impacts to wild trout reproduction.
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: Keven Duerr, Hazen and Sawyer
Sue Homewood and Tyler Hickman, NC Division of Water Resources
David Goodfred, NCWRC