20091249 Ver 1_WRC Comments_20091207

DEC ^ 7 2009
0?? R BRANCH
? North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: Cyndi B. Karoly, Supervisor, 401 Oversight and Express Permits Unit
NCDWQ Wetlands and Stormwater Branch
FROM: Ron Linville, Regional Coordinator
Habitat Conservation Program
DATE: December 3, 2009
SUBJECT: Rod C. Chaney Stabilization, Moss Lake, DWQ No. 09-1249, Cleveland County
The NC Division of Water Quality is requesting letters of concurrence from the North Carolina
Wildlife Resources Commission (NCWRC) for the Clean Water Act Section 401 Certification
referenced above. The NCWRC has reviewed information provided by the applicant and our
biologists are familiar with habitat values in the project area. These comments are provided in
accordance with provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and the Fish
and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).
It appears that the applicant proposes to install a hard rock (vertical) wall along the shoreline to
replace an existing riprap and cement seawall. No listed species are indicated for the project area.
The lake supports a warm water fishery.
Based on the information provided, we will not object to the project. However, vertical walls on
shorelines diminish habitat values and should be avoided when it is practicable to provide gentler
sloped banks. The following habitat recommendations for shoreline stabilization should be
considered for the project:
1. Preferably, stabilization should be done by barge using minimum class I (class II
preferred) riprap or rock on a gradual slope instead of a vertical wall. This size
rock improves aquatic habitat through the provision of void spaces. We do not
support the use of river rock as mining river rock causes direct impacts to aquatic
species and affects aquatic environments with unnatural geomorphic
modifications. River rock is also prone to slippage. Fabric matting may be used
beneath the stone to reduce erosion and turbidity. Natural fiber matting is
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
Rod C. Chaney, Moss Lake Page 2
December 3, 2009
recommended over plastic matting that can impinge and entrap small animals. To
the extent practicable, rock or stone should be placed just above the high water
mark and into the lake five (5) to six (6) feet to provide continuous aquatic edge
habitat. Bare banks should be temporarily planted with annual wheat or oats
within five (5) to ten (10) days of ground disturbing activities.
2. As noted above, work should occur from the water instead of on the interior of the
shore to minimize buffer impacts.. Existing wooded buffers should be preserved.
Any Large Woody Debris (LWD) should be maintained to the maximum extent
practicable to provide aquatic habitat. If relocated, the LWD must be securely
anchored so that it will remain where installed.
3. Stringent erosion control measures should be installed where soil is disturbed and
maintained until project completion.
4. Wide undisturbed shoreline buffers and natural vegetation should be maintained
when practicable. Disturbed banks should be revegetated with silky dogwood
(Corpus amonum), silky willow (Salix sericea), tag alder (Alnus serrulata), black
willow (Salix nigra), and sycamore (Platanus occidentalis) or other native plants
to provide long term bank stability and shoreline shade. Note that silky
dogwood, silky willow and black willow can be planted as live stakes collected
during the dormant growing season. Cuttings should be randomly planted and
done on four (4) foot centers from the waters edge to the top of the bank. Trees
should be planted on ten (10) to twelve (12) foot centers.
5. The applicant should contact state and local planning and environmental
authorities to determine if permits are needed for buffer infringements or impacts.
Thank you for the opportunity to review and comment on this project. If you have any questions
regarding these comments, please contact me at 336-769-9453.
E-copy: Alan Johnson, DWQ-MRO
Steve Chapin, USACOE-ARO