20171099 Ver 1_WRC Comments_20171023

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
October 23, 2017
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Linville River Restoration
Linville River, Avery County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 2,989 feet of the Linville River in Avery County. I attended a site visit
with Andrew Moore, the NC Forest Service, and Greg Jennings on October 13, 2017. 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).
There are wild Brown Trout in the vicinity of the project, and in -channel work should be avoided
between October 15 and April 15 in order to minimize impacts to trout spawning. In addition,
the rare Grandfather Mountain Crayfish (Cambarus eeseehoensis, US Federal Species of
Concern, NC Significantly Rare), endemic to the Linville River system, is found throughout the
project reach.
The project involves the installation of in -stream structures (log and boulder j -hooks, rock cross
vanes), the removal of a long mid -channel island, and planting. The project would be
constructed in the wet. During site visit discussions, Mr. Jennings agreed to remove three of the
in -stream structures downstream of the island and upstream of the bottom of the project reach.
We are generally supportive of stream restoration and instream and riparian habitat enhancement.
This reach of the Linville River is overly wide in some areas (e.g., the reach upstream of the low
water bridge), and instream structures should aid in narrowing the channel and create pool
habitat. In the vicinity of the island, the river is divided into two channels, both of which are
relatively stable and are characterized by good instream habitat. We support a lighter touch in
this reach of the channel and are concerned about the removal of the island and construction of a
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Linville River Restoration
Linville River, Avery County
October 23, 2017
new single -thread channel. This strategy, which will marginally improve instream habitat, will
involve a large amount of earth moving and require an unknown amount of time to stabilize,
disturbing habitat for native aquatic fauna such as the Grandfather Mountain Crayfish and
serving as a source of sediment.
The Linville River is constrained by berms, not allowing the river to flood into its natural
floodplain. If the NC Forest Service nursery facility on the right side of the river is closed in the
future, we recommend removing this berm in some areas, allowing the river to spread into its
floodplain.
We offer the following recommendations to minimize impacts to fish and wildlife:
1. In -channel work should be avoided between October 15 and April 15 to minimize impacts to
trout reproduction.
2. Vigilance should be 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.
3. In -channel work should be accomplished as quickly as possible.
4. The design should be reevaluated to determine if a lighter touch alternative to island removal
is feasible.
5. In order to minimize sediment release during the project, flows should be diverted around
structure installation areas and channel construction areas at the island.
6. Work should be done during a period of low flows.
7. In -channel construction activities, especially those involved in island removal and channel
construction, should be overseen by the stream designer or his alternate.
8. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that may
last for years.
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: Greg Jennings, Jennings Environmental
Bill Swartley, NC Forest Service
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Chris Wood, TR Russ, David Cox, NCWRC