20200956 Ver 1_WRC Comments_20200824

A
� North Carolina Wildlife Resources Commission IQ
Cameron Ingram, Executive Director
August 24, 2020
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Phillips Stream Restoration
East Fork Grassy Creek and UT, Mitchell County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 1,738 ft of East Fork Grassy Creek and an unnamed tributary (UT) in
Mitchell County. In addition, temporary impacts to 60 ft of stream for pump around diversions
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 within 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, the Eastern Hellbender (Cryptobranchus
alleganiensis, US Federal Species of Concern, NC Special Concern) is found. Effective erosion
and sediment control on this project is essential in conserving these species.
The application proposes to stabilize an eroding and rather straight reach of East Fork Grassy
Creek with a dense set of rock and log cross vanes and j-hooks. 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 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: [phone] • Fax: [phone]

Phillips Stream Restoration Page 2 August 24, 2020
E Fk Grassy Cr, Mitchell Co
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. wide forested buffer can ensure
greater bank stability, filter overland pollutants, and provide habitat for birds and other
wildlife.
4. Eastern Hemlock and Green Ash are included in the planting plan; we recommend removing
these species due to pests that are causing widespread mortality of these species.
5. We recommend softening the project design, using fewer structures, more wood and less
rock, and making the distribution of structures less regular.
6. 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 and Amy Annino, NC Division of Water Resources