20201154 Ver 1_WRC Comments_20200909

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IQ North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
September 9, 2020
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Shroup Driveway
UT to West Fork Pond Creek, Avery County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to replace a culvert and stabilize an eroding reach of stream, impacting 100 ft of an
unnamed tributary (UT) to West Fork Pond Creek 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 trout reproduction should not be impacted by project activities and a trout moratorium is
not needed.
The application proposes to replace a failing culvert with a new one. A reach of the left stream
bank downstream of the culvert is eroding, and the applicant proposes to remove fallen/slumped
tree roots and place large rock on the bank, mostly above water.
We offer the following recommendations to minimize impacts to the aquatic community:
I . Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
Disturbed areas should be seeded, mulched and/or matted as soon as possible, preferably at
the end of each work day.
2. Work should be performed in the dry, with flows pumped around the in -stream work area.
3. We recommend disturbing existing trees and shrubs as little as possible, including roots.
Existing root structure on the bank is important in maintaining bank stability and preserving
the health of live trees.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Shroup Driveway Page 2 September 9, 2020
UT W Fk Pond Cr, Avery Co
4. The culvert material to be used was not noted. We recommend against using HDPE (high
density polyethylene) material, as this slick material is less likely to hold stream substrate
and provide for movement of aquatic organisms like fish and salamanders.
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 or need further assistance.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Sue Homewood, NC Division of Water Resources