20211499 Ver 1_WRC Comments_20210924

0 North Carolina Wildlife Resources Commission 0
Cameron Ingram, Executive Director
September 24, 2021
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Kennedy NRCS-EQIP Stream Restoration Project
UTs to Double Creek, Wilkes County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 1,590 ft of unnamed tributaries (UTs) to Double Creek in Wilkes 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 should not be impacted by the project, and a trout moratorium is not recommended.
The application proposes to restore unstable reaches of stream that run through agricultural land.
The stream will be stabilized by grading banks, planting a native riparian buffer, and installing
multiple in -stream structures including log and rock vanes, boulder steps, and boulder riffles. It
appears that work will be done in the dry, with flows pumped around work areas.
We offer the following recommendations to minimize impacts to the aquatic community:
I . 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.
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.
3. Work should be performed at low flows. Flows should be pumped around in -stream work
areas.
Mailing Address: Habitat Conservation - 1721 Mail Service Center - Raleigh, NC 27699-1721
Telephone: [phone] - Fax: [phone]

Kennedy NRCS-EQIP Restoration Page 2 September 24, 2021
UTs Double Cr, Wilkes Co
4. It is unclear how wide the planted riparian buffer will be. We 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.
Thank you for the opportunity to review and comment on this project. Please contact meat
[phone] if you have any questions about these comments.
Sincerely,
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Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Jeff Bellflower, designer
Sue Homewood, NC Division of Water Resources