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HomeMy WebLinkAbout20200543 Ver 1_WRC Comments_20200423ltl North Carolina Wildlife Resources Commission 0 Gordon Myers, Executive Director April 23, 2020 Ms. Amanda Fuemmeler U.S. Army Corps of Engineers, Regulatory Branch 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 SUBJECT: Thompson Project Flannery Fork, Watauga County Dear Ms. Fuemmeler: Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an application to stabilize 166 ft of Flannery Fork in Watauga 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). Wild Brown Trout are found in the project vicinity, and in -channel work should be avoided between October 15 and April 15 to minimize impacts to trout reproduction. In addition, Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species of Concern, NC Special Concern), Kanawha Minnow (Phenacobius teretulus, NC SC), and Tongue-tied Minnow (Exoglossum laurae, NC SR) are found in the vicinity of the project. Excellent erosion and sediment control on this project is especially important to minimize impacts to these animals. The application proposes to stabilize an eroding reach of bank on Flannery Fork through sloping the bank, planting native woody and herbaceous vegetation, and installing two in -stream rock vanes. Most work will be done from the bank, but some instream access may be necessary for proper installation of the rock vane. 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. Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Thompson Project Page 2 April 23, 2020 Flannery Fork, Watauga County 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. For the rock vane installation, we recommend diverting flows around the work area at the bank tie-in locations only, balancing the risk of sediment loss and direct impacts to hellbender habitat, in order to reduce the risk of fine sediment liberation and loss. 4. The project manager should reach out to Lori Williams (lori.williams(&ncwildlife.org ) and Andrea Leslie(andrea.leslie(d),ncwildlife.org) at least three weeks before construction begins so that the area of impact can be surveyed for hellbenders, and animals relocated if found. 5. Shelter rocks potentially used by hellbenders should be left undisturbed during construction activities. Shelter rocks are typically large flat rocks at least a foot in diameter. If animals are disturbed during construction, they should be captured in a bucket and moved away from the area of disturbance. Please notify Lori Williams if hellbenders are found. 6. We recommend that a woody buffer as wide as possible (we recommend at least 30 feet) be planted on the stream as infrastructure allows in order to ensure project success. A wide forested buffer can ensure greater bank stability, filter overland pollutants, and provide habitat for birds and other wildlife. Thank you for the opportunity to review and comment on this project. Please contact me at (828) 400-4223 if you have any questions about these comments. Sincerely, Andrea Leslie Mountain Region Coordinator, Habitat Conservation Program ec: Glen Sullivan, Foggy Mountain Nursery Sue Homewood, NC Division of Water Resources Byron Hamstead, US Fish and Wildlife Service Lori Williams, NCWRC