20170359 Ver 2_WRC Comments_20191016

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
October 16, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Loch Dornie Dredging, Island Enhancements, and Linville River Stabilization Project
Linville River, Avery County
Action ID#: SAW-2019-01616
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
individual permit application for Grandfather Golf and Country Club (GGCC) to permanently impact
279 ft of the Linville River and 8.1 acres of Loch Dornie (an in -line impoundment on the Linville
River), and in addition temporarily impact 71 ft of the Linville River and 4.6 acres of Loch Dorney in
Avery County. This project was proposed in 2017 but has been modified substantially in the present
application. I attended an agency site visit on October 9, 2019. 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 Brown Trout and Rainbow Trout in the Linville River downstream of the project. To allow
the applicant to achieve this work during their off-season, we will allow work to proceed during the
second half of the Brown Trout moratorium. Project activities should be avoided between October
15 and December 31. The Linville River also supports the endemic and rare Grandfather Mountain
Crayfish (Cambarus eeseeohensis, US Federal Species of Concern, NC Significantly Rare).
The application proposes to mechanically dredge sediment from 5.9 acres of Loch Dornie,
remove/modify 6 islands and create 2 larger islands, and stabilize 262 feet of the Linville River
stream bank and 1.1 acres of shoreline on Loch Dornie. The lake will be lowered 8 ft with a siphon
over the dam to dewater the upper area of Loch Dornie that is to be dredged. The river will be
alternately routed to the western and eastern sides of the upper lake area to allow the other side of the
lake to dry out. This dewatered side of the lake will be mechanically dredged and the spoil used to
build the new islands and stabilize the lake shoreline.
A set of three rock sills is proposed for the free -flowing portion of the Linville River upstream of the
lake. This section of the river is natural and is characterized by cobble, boulder, and some bedrock.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Loch Dornie Dredging 2 October 16, 2019
Linville River, Avery County
We strongly recommend against placing these structures in the river, as they could result in barriers
to aquatic animals.
Turbidity curtains will be set up in the lake at two locations downstream of the work areas to
minimize turbidity loss from the work areas to the lake. According to the applicant, equipment will
be pulled out of the project footprint before big storms hit the area. As dredging activity is so
extensive and will be implemented during the trout moratorium, we request that the applicant
monitor turbidity at the lake outfall during lake drawdown, dredging, and refill. We recommend that
the applicant work with the NC Division of Water Resources and NCWRC to develop turbidity
monitoring methods, turbidity benchmarks, and actions to be taken if excessive turbidity does occur.
Flows must be maintained within the Linville River at all times per discussions between McGill
Associates and NCWRC in the fall of 2015 regarding GGCC dam maintenance activities and our
comments on the 2017 Individual Permit. NCWRC stipulated that a minimum flow of 2 cfs is to be
maintained at all times, including during pond refill. However, it is our understanding that the NC
GGCC must maintain 1.9 cfs below Loch Dornie per a 1998 NC Department of Natural Resources
letter, and NCWRC supports this slightly lower minimum flow limit for the project.
We offer the following additional 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. We recommend that
areas be surrounded by silt fence and/or other measures used to retain sediment at the dredge site.
2. Disturbed areas at the lake and stream bank stabilization areas should be seeded, mulched and/or
matted as soon as possible. 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. Polyacrylimide and coir log rolls are proposed for placement within the environmental release
channel; these structures should not be placed in flowing streams.
4. The planting list provided in the plans is specifies native wildflowers, shrubs, and trees. All
stream bank and lakeshore stabilization areas should be planted with native herbaceous and
woody plants.
5. A planting list should be provided for wetlands that will be created as part of this project.
Thank you for the opportunity to review and comment on this project. Please contact me at (828)
803-6054 if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: Keven Arrance, Hazen and Sawyer
Andrew Moore, Fred Tarver, and Sue Homewood, NC Division of Water Resources
David Goodfred, Chris Wood, and TR Russ, NCWRC