20191191 Ver 1_WRC Comments_20190927

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
September 27, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Western North Carolina Stream Initiative — Beasley Site
Elk River and UT - Avery County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 1,704 ft of the Elk River and 106 ft of an unnamed tributary (UT) to the
Elk River, as well as temporarily impact 0.006 acre of wetland 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).
Brown Trout and Rainbow Trout may be impacted by the project, and in -stream activities should
be avoided between October 15 and April 15 to minimize impacts to trout reproduction.
The application proposes to stabilize an eroding reach of the Elk River and an UT with in -stream
structures, slight adjustments to pattern and profile, and bank grading. In -stream structures
include brush toes with geolifts, constructed riffles, log sills, rocks sills, j -hooks, and cross
vanes. A native riparian buffer of 10-35 ft in width will be planted, achieving an average width
of 25 ft. Work will be done in the wet. According to Ian Eckhart, work will be performed from
the bank as much as possible, and when feasible, on -site materials (rock, logs, etc.) will be used
to create temporary diversion structures immediately above areas of active in -stream work to
divert flow.
The impacted wetland should be reseeded with a native wetland mix. We recommend that
wetland impacts be avoided wherever possible and timber mats be used where equipment will
access wetlands to minimize soil compaction. Efforts should be made to preserve as many
existing trees as possible, especially on left bank of the lower third of the project.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Beasley Site Page 2 September 27, 2019
Elk River, Avery County
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -stream activities should be avoided between October 15 and April 15 to minimize impacts
to Brown Trout and Rainbow Trout reproduction.
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. Disturbed
areas should be seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day.
3. We recommend diverting flows around in -channel work areas especially at the bank tie in
locations to reduce the risk of fine sediment liberation and loss.
4. 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.
5. Wetland impacts should be minimized by avoiding them wherever possible. Where crossing
wetlands with equipment is necessary, it should be done with the use of mud mats to
minimize soil compaction. Disturbed wetlands should be planted with a native riparian seed
mix.
6. Efforts should be made to retain as many native trees on site as possible.
7. We request that we be informed of project construction start and end dates so that we can
visit the site when it is underway.
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,
o„ d"e a
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Ian Eckhart, Wildlands Engineering
Sue Homewood, NC Division of Water Resources
David Goodfred and Chris Wood, NCWRC