20071108 Ver 1_Other Agency Comments_20070702

~ North Carolina Wildlife Resources Commission ~
Richard B. Hamilton, Executive Director
MEMORANDUM
TO: Amanda Jones, USACOE
Asheville Regulatory Field Office
Cyndi Karoly, 401 Certification Unit
NC Division of Water Quality
FROM: Ron Linville, Re ~onal Coordinator /'~
Habitat Conservation Program
DATE: June 29, 2007
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SUBJECT: Brookshire Park Stream StabilizationlEnhancement, South Fork New River, DWQ No.
20(171108, Watauga County
The applicant proposes repair severe erosion along Brookshire Park along the South fork New River.
Biologists with the North Cazolina Wildlife Resources Commission are familiar with habitat values in the
area. These comments are provided in accordance with the provisions of the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d) and the North Carolina Environmental
Policy Act (G.S. 113A-1 through 113A-10; NCAC 25).
The project is indicated to stabilize and enhance river banks previously disturbed by Hurricanes Frances
and Ivan (2004). The park site is adjacent to the South Fork New River. Total bank
stabilizationlenhancement will be about 7001ineaz feet for both banks. Brown trout and Smallmouth bass
are known for this area. Kanawha minnow, Phenacobius teretudus (NCSC, FSC); Kanawha darter,
Etheostoma kanawhae (NCSR); Seep mudalia, Leptoxis dilatata, (NCT); green floater, Lasmigona
subviridis (NCE, FSC); tonguetied minnow, Exoglossum laurae (NCSR); sharpnose darter, Percina
oxyrhynchus (NCSC); spike, Elliptio dilatata (NCSC), and crayfish on the NC Watch List, New River
crayfish, Cambarus chasmodactylus; and Orconectes cristavarius, no common name. These occur in the
South Fork New River system from the Boone vicinity and downstream. Kanawha minnow, Phenacobius
teretulus (NCSC, FSC); Kanawha darter, Etheostoma kanawhae (NCSR); tonguetied minnow,
Exoglossum laurae (NCSR); and New River crayfish, Cambarus chasmodactylus (NC Watch List) are
kno~m to inhabit smaller headwater streams as well as the larger main stem portions of the river system.
Based on our review of the application, we will not object to the project as proposed providing the
following non prioritized conditions are implemented:
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721
Telephone: [phone] Faz: [phone]

Brookshire Park Stabilization -Page 2 -
June 29, 2007
1. In stream work and land disturbance within the twenty-five (25) foot wide buffer zone are
prohibited during the brown and brook trout spawning season of October 15 through April 1 ~
to protect the egg and fry stages of trout from off-site sedimentation during construction.
2. The natural dimension, pattern and profile of the stream should be restored to the extent
practicable. This should include restoration and stabilization of active floodplain benches.
3. Repairs to eroded banks should be conducted in a dry work area where possible. Sandbags,
flexible pipes or other clean diversion structures should be used to minimize excavation in
flowing water.
4. River rock, sand or other materials should not be dredged from the stream channel except, if
necessary, in the immediate vicinity of the eroding banks for the explicit purpose of
anchoring, installing, or stabilizing bank or flow diversion structures.
5. Instead of toe edging extensively with rock, more dependence should be placed on properly
designed, located and installed natural channel design structures such as j-hooks, root wads,
and/or rock weirs to aggrade bank materials and maintain the thalweg and natural channel
flow. The use toe edging may be more appropriate for restored floodplain benches.
6. Fiber matting or geotextile fabric materials used for the project should be biodegradable
natural fibers that do not entrap wildlife species. Plastic stabilization blankets are known to
entrap small species like snakes, turtles and birds.
7. Only autochthonous (native) plants should be used for the project. Annual non-native
agricultural grains may be used for temporary ground cover. Restored banks and floodplains
should be planted with autochthonous plants like silky dogwood, rhododendron, dog hobble,
red maple, silky willow, tag alder, black willow, sycamore, river birch, or other native woody
species. Shrubs and trees should be planted at rate equivalent to six (6) feet centers. On
average, cuttings should be randomly planted on four (4) foot centers from the waters edge to
the top of the bank. Trees should be planted on ten (10) to twelve (12) foot centers. Site
conditions may determine plant locations.
8. Temporary or permanent native herbaceous vegetation should be established on all bare soil
within five (5) days of ground disturbing activities in the twenty-five (25) foot trout buffer to
provide long-term erosion control. A phased stabilization or "seed as you go" process is
recommended. We encourage the use of fiber matting. Onsite vegetation and materials may
be used for stream bank stabilization when clean and practicable.
9. Remaining jurisdictional waters and wetlands should be naturally buffered, either through
protection or provision of undisturbed forested buffer zones. Buffers should be permanently
preserved as common contiguous forest areas. As appropriate to protect buffer zones, river
access should be limited to a few preferred points of entry. Aesthetically pleasing fencing
may be useful for directing park visitors. For streams that do not support federally listed
threatened or endangered aquatic species, we recommend 50' intermittent and 100' perennial
stream buffers. Maximum available buffers should be provided; however, the twenty-five
(25) foot trout buffer should remain undisturbed to the maximum extent practicable. For park
settings, aesthetically pleasing fencing should be used to protect buffers by directing park
users to prescribed access points. Walking trails in the buffer are not recommended;
however, if a walking trail is placed in the buffer zone, it should be located away from the
river to the maximum extent practicable, it should be pervious, and its width should not

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Brookshire Park Stabilization -Page 3 -
June 29, 2007
exceed minimum width requirements specified in the Americans with Disabilities Act
(ADA).
10. Sediment and erosion control measures should adhere to the design standards for sensitive
watersheds (15A NCAC 4B .0124).
11. If any concrete will be used, work must be accomplished so that wet concrete does not
contact stream water.
12. To the extent practicable, heavy equipment should be operated from the bank rather than in
the stream channel in order to minimize sedimentation and reduce the likelihood of
introducing petroleum pollutants into the river. Petroleum spill containment equipment
should be readily available while work is being done in or along the river.
Thank you for the opportunity to review and comment on this project during the early planning stages. If
you have any questions regarding these comments, please contact me at 336/769-9453.
E-copy: Daryl Lamb, DWQ-WSRO