20200689 Ver 1_WRC Comments_20200619

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
June 19, 2020
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Ward Mill Dam Removal
Watauga River, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to remove a private hydropower dam on the Watauga River in Watauga County.
NCWRC staff have visited the site multiple times over the past years. 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).
Ward Mill Dam impounds a section of the Watauga River that is part of the Watauga River Aquatic
Habitat, a natural area rated High by the NC Natural Heritage Program due to the richness of rare
species it supports. In the project vicinity, Eastern Hellbender [Cryptobranchus alleganiensis, US
Federal Species of Concern (FSC), NC Special Concern (SC)] and Green Floater (Lasmigona
subviridis, US FSC, NC Endangered) have been found in the river. The project should not impact
wild trout, and project activities do not need to be avoided during a trout moratorium.
NCWRC has been a part of a technical oversight team for this project, and we support its
implementation, as it will remove a barrier and restore a natural hydrologic and sediment regime.
The application proposes to remove a 20-ft high rock and concrete dam, direct the channel away
from the left bank that houses a mill and associated structures, and stabilize the formerly impounded
area.
The channel work will be accomplished in two phases, and project oversight will be performed by
Wildlands Engineering. Phase 1 consists of dam removal and bank stabilization immediately
upstream of the dam to protect the mill structures. The project team intends on lowering the
impoundment water level in stages for 3-6 weeks before the dam is removed. Dam removal will take
2-3 weeks and is intended to start in July or August. It would be performed from top down, from a
riprap pad placed on the left river bank and in the channel; this will be removed upon project
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Ward Mill Dam Removal Page 2 June 19, 2020
Watauga County
completion. Metal will be removed from dam debris, and the remaining rock and concrete will be
mixed with native sediments and used to armor the left bank near the mill structures. A new channel
will be diverted away from the left side with floodplain sills and a rock vane.
Phase 2 would occur several or more months later after stream flows have moved a significant
proportion of sediments behind the dam through the former impounded area, and it involves
stabilization of stream banks throughout the impounded reach with bank sloping, benching, matting
and bioengineering in the form of vegetated lifts and/ or brush mattress or live wattle installations.
Additional rock structure may be needed as well.
Although we are concerned about loss of sediment from behind the dam, sediment modeling
performed by the design team has shown that sediment loss from the impounded section of the river
will likely be only a portion of annual sediment volume transported by the river. In addition, there is
evidence that the area behind the dam has been scoured out numerous times in the past.
A minimum of 2 years of inspection and monitoring will be implemented after dam demolition.
Hellbender surveys and relocations would be performed by Appalachian State University staff before
dam removal. We ask the applicant to reach out to Lori Williams (lori.williamsAncwildlife.org)
to inform her of monitoring plans so that she may participate if possible.
We offer the following additional recommendations to minimize impacts to fish and wildlife
resources:
1. 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 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. Hellbender surveys and relocations should be performed just before the project begins, before
sediments from behind the dam are allowed to move downstream.
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: Jake McLean, Wildlands Engineering
Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Luke Etchison, Chris Goudreau, Kin Hodges, & Lori Williams, NCWRC