20201400 Ver 1_WRC Comments_20210621

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
June 21, 2021
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Hodges Stream Restoration
Linville Creek and UT, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 1,179 ft of Linville Creek and an unnamed tributary (UT) in Watauga
County. In addition, temporary impacts to 40 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).
There are wild Brown Trout in the project vicinity, and in -stream activities should be avoided
between October 15 and April 15 to minimize impacts to trout reproduction. Effective erosion
and sediment control on this project is essential to protect this species.
The application proposes to restore an eroding reach of Linville Creek and a tributary with a
dense set of rock and/or log cross vanes and j-hooks and constructed riffles. Banks will be
graded, 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.
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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Hodges Stream Restoration Page 2 June 21, 2021
Linville Cr & UT, Watauga Co
3. In -stream activities should be avoided between October 15 and April 15 to minimize impacts
to wild trout reproduction.
4. We recommend softening the project design, using fewer structures, more wood and less
rock, and making the distribution of structures less regular.
5. The planted buffer is proposed to be 10-25 ft in width. A buffer of 10 ft will do little to
maintain bank stability over time. We strongly 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. A wide forested buffer can ensure greater bank stability, filter overland pollutants,
and provide habitat for birds and other wildlife.
6. 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 and
replacing them with additional species. In addition, Black Gum is included, which is an
upland species — it is appropriate if planted in an upland setting only.
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
Sue Homewood, NC Division of Water Resources