20200437 Ver 1_WRC Comments_20200414

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
April 14, 2020
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Ray Alvarez Stream Restoration
Holley Branch, Mitchell County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 800 ft of Holley Branch in Mitchell County. In addition, temporary
impacts to 20 ft of Holley Branch for a pump around are proposed. 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).
Wild trout reproduction should not be impacted by the project, and a trout moratorium is not
needed. However, the site is immediately upstream of the North Toe/Nolichucky River Aquatic
Habitat, a natural area identified by the NC Natural Heritage Program and rated as Very High due
to the richness of rare species it supports. In the vicinity of the project, both Sharphead Darter
[Etheostoma acuticeps, US Federal Species of Concern (FSC) NC Threatened] and Eastern
Hellbender (Cryptobranchus alleganiensis, US FSC, NC Special Concern) are found. Effective
erosion and sediment control on this project is essential in conserving these species.
The application proposes to stabilize an eroding and straightened reach of Holley Branch with a
dense set of rock and log cross vanes, j-hooks and constructed riffles. Banks will be graded, a
floodplain bench constructed, and a native riparian buffer of 10-25 ft will be planted on the
stream banks. Work will be done in the dry.
There is virtually no woody riparian vegetation on the North Toe River, and we strongly
recommend planting native trees and shrubs on the river bank.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Ray Alvarez Stream Restoration Page 2 April 14, 2020
Holley Br, Mitchell County
We offer the following recommendations to minimize impacts to the aquatic community:
1. 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.
2. 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.
3. We recommend that a woody buffer of at least 30 feet be planted on both sides of the stream
as infrastructure allows in order to ensure project success. The North Toe River should be
planted with a woody buffer as well. A wide forested buffer can ensure greater bank
stability, filter overland pollutants, and provide habitat for birds and other wildlife.
4. 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,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Derek Goddard, BREC
Andrew Moore, NC Division of Water Resources