20201053 Ver 1_WRC Comments_20200901

A
� North Carolina Wildlife Resources Commission IQ
Cameron Ingram, Executive Director
September 1, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Culvert Removal and Creek Bank Restoration
Plott Creek, Haywood County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to remove a culvert and restore stream bank dimensions, impacting 75 ft of Plott
Creek in Haywood 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 Rainbow Trout and Brook Trout may be impacted by the project, and in -stream activities
should be avoided between October 15 and April 15 to minimize impacts to trout reproduction.
Details are not provided about how culvert removal and bank restoration will be accomplished;
the plan drawing states "creek bank to be widened to match adjacent cross section". In -stream
work should be done in the dry, with flows pumped around the work area. We strongly suggest
planting native woody vegetation on both sides of the stream 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.
We offer the following recommendations to minimize impacts to the aquatic community:
1. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
Due to the presence of Brook Trout in the watershed, disturbed areas should be seeded,
mulched and/or matted as soon as possible, preferably at the end of each work day.
2. In -stream activities should be avoided between October 15 and April 15 to minimize impacts
to Brook Trout and Rainbow Trout reproduction.
3. Work should be performed in the dry, with flows pumped around the in -stream work area.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Culvert Removal & Bank Restoration Page 2 September 1, 2020
Plott Cr, Haywood Co
4. We recommend that a woody buffer as wide as possible be planted on both sides of the
stream as infrastructure allows in order to ensure project success.
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: Bruce Ganger, landowner
Amy Annino, NC Division of Water Resources