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HomeMy WebLinkAbout20200675 Ver 1_WRC Comments_202006309 North Carolina Wildlife Resources Commission 9 Gordon Myers, Executive Director June 30, 2020 Ms. Brandee Boggs U.S. Army Corps of Engineers, Regulatory Branch 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 SUBJECT: Frank Busic Stream Restoration UTs to Rock Creek, Alleghany County Dear Ms. Boggs: Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an application to restore 2,968 ft of unnamed tributaries (UTs) to Rock Creek in Alleghany County. In addition, temporary impacts to 80 ft of stream for a pump around and temporary impacts to 0.295 acre of wetland 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 upstream of the South Fork New and New River Aquatic Habitat, a natural area identified by the NC Natural Heritage Program and rated as Exceptional due to the richness of rare species it supports. Rare and listed species found in the river in the vicinity of the project include Spike [Eurynia dilatata, US Federal Species of Concern (FSC), NC Special Concern (SC)], Seep Mudalia (Leptoxis dilatata, US FSC, NC SC), Kanawha Darter [Etheostoma kanawhae, NC Significantly Rare (SR)], Appalachia Darter (Percina gymnocephela, NC SR), Mimic Shiner (Notropis volucellus, NC Threatened), Common Mudpuppy (Necturus maculosus, NC SC), and Eastern Hellbender (Cryptobranchus alleganiensis, NC SC, US FSC). These species are especially sensitive to sedimentation, and good erosion and sediment control measure for this project are essential to protect these species. The application proposes to stabilize eroding and reaches of stream 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. We recommend softening the project design, using fewer structures, more wood and less rock, and making the distribution of structures less regular. Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Frank Busic Stream Restoration Page 2 June 30, 2020 UTs to Rock Cr, Alleghany 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. 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. 5. Wetland impacts should be minimized, and where feasible, equipment placed on mud mats. 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: Derek Goddard, BREC Sue Homewood, NC Division of Water Resources