20210394 Ver 1_WRC Comments_20210604

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
June 4, 2021

Ms. Kaylie Yankura
NC Division of Water Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778

SUBJECT: Big Bradley Falls Overlook and Trail Improvements
Cove Creek and UT, Polk County

Dear Ms. Yankura:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize a small section of stream bank, remove a log culvert, and install a ford,
temporarily impacting 36 ft and permanently impacting 71 ft of Cove Creek and an unnamed
tributary (UT) in Polk County. I have visited the site multiple times and provided advice to
minimize impacts to stream and riparian resources. 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 are present in Cove Creek, and in-stream activities should be avoided
between January 1 and April 15 to minimize impacts to trout reproduction.

The application proposes to install rock cribbing along the bank of Cove Creek, remove an
unsustainable section of trail and log culvert on a UT to Cove Creek, reroute the trail to a more
sustainable route, cross the UT with a new rock ford, and harvest cobble for the ford from an
adjacent reach of the UT.

We offer the following recommendations to minimize impacts to fish and wildlife:
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 workday.
Big Bradley Trail Page 2 June 4, 2021
Cove Creek and UT, Polk Co
2. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
3. Disturbed stream banks be planted with native vegetation to better ensure bank stability.
4. In-stream activities should be avoided between January 1 and April 15 to minimize impacts
to Rainbow Trout reproduction.

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: Jeff Ferguson, NCWRC