20170511 Ver 1_WRC Comments_20170508

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
May 8, 2017
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: George Belflower Stream Stabilization
UTs to Roberson Creek, Rutherford County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 650 feet of two unnamed tributaries (UTs) to Roberson Creek in
Rutherford 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).
Project activities will not impact wild trout, and observance of a trout moratorium is not
required.
The project involves the stabilization of two UTs to Roberson Creek using natural channel
design techniques, including bankfull benches, in -stream structures, bank sloping, and planting.
According to Renee Ray with the Natural Resources Conservation Service, the planted buffer
width will be 35 feet from the stream's center on each side of the stream. Most of the in -channel
work will be performed in the wet, with equipment operated from the top of the bank.
We are supportive of the stream stabilization work, as it should address channel instability and
improve in -stream habitat. However, the stabilization work will occur after the construction of
an on-line pond just upstream of one of the stream stabilization locations. Construction of this
pond does not require US Army Corps of Engineers authorization, as it is to be used as a farm
pond to provide water for irrigation and to water livestock. On-line impoundments are
detrimental to stream integrity, as they can change downstream water temperature (which is
especially detrimental in the warm months, when they can significantly heat up water
temperature), provide a barrier to aquatic movement, alter water chemistry, and change aquatic
food web dynamics. The benefits of aquatic habitat restoration in the downstream reach will
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

George Belflower Stream Stabilization
UTs to Robeson Creek, Rutherford County
May 8, 2017
likely be limited by the pond's impacts on the stream. These negative impacts can be lessened
by constructing an off-line pond, diverting a portion of the stream's flow to the pond.
We offer the following recommendations to minimize impacts to terrestrial and aquatic resources
from the project:
1. Project activities should be accomplished as quickly as possible and vigilance used in
sediment and erosion control during site preparation, construction, and clean up.
2. Disturbed areas should be seeded, mulched and/or matted as soon as possible, preferably at
the end of each work day. 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 -stream construction should be performed during low flow periods.
4. For pond construction, we recommend an off-line design. Regardless of whether it is off or
on-line, stream flow should be routed around excavation areas and the work completed
during a period of forecasted dry weather. Some flow downstream of the pond should be
maintained during pond filling.
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: Buddy Belflower, landowner
Renee Ray, Natural Resources Conservation Service
Amy Anino, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service