20140038 Ver 1_WRC Comments_20140124

IQ North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
January 24, 2014
Sue Homewood
NC DENR Winston -Salem Regional Office
Division of Water Resources — Water Quality Programs
585 Waughtown Street
Winston- Salem, NC 27107
SUBJECT: 401 Water Quality Certification for U.S. Army Corps of Engineers, Huntington District
Watauga Restoration Project, South Fork New River, Watauga County
Dear Ms. Homewood:
We reviewed the information about the proposed stabilization of 4,000 feet of the South Fork New River
on Appalachian State University property in Boone. Comments from the North Carolina Wildlife
Resources Commission on the application are offered for your consideration under provisions of the
Clean Water Act of 1977 (33 U.S.C. 466 et seq.) and the Fish and Wildlife Coordination Act (48 Stat. 401,
as amended; 16 U.S.C. 661- 667d).
Despite extensive stormwater impacts, the South Fork New River at the project site supports populations
of wild brown and rainbow trout. The project proponents asked that the trout spawning moratorium
(Nationwide Permit Regional Condition 1.2) be waived to facilitate project scheduling. Our biologists
concurred with that largely because the work could have long -term benefits for trout.
Based on the incomplete plans that we received, it appears that the work will not involve channel pattern
changes and only include profile modifications for three riffle structure /equipment access points.
Dimensional changes will include bank sloping with rock and /or log "dikes" or smaller toes constructed
along one or both channel margins through much of the project reach. Boulder clusters will be added to
enhance fish habitat diversity.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

USACOE
Watauga
Page 2 January 24, 2014
The overall project should reduce sources of sedimentation in the river and complement the stabilization
work done immediately upstream several years ago. Preservation of existing large trees and riparian
planting should promote long -term channel stability. We are pleased that fish habitat needs are considered
in the project. A few digger logs, root wads, bunkers, and similar structures in addition to the boulders
would provide better fish habitat diversity than that found in the upstream stabilization reach. We
recommend incorporating those features wherever possible and appropriate.
Though the project should be beneficial overall, it may degrade trout habitat, particularly during
construction, without minor modifications and stipulations. We recommend including the following
conditions in the certification to help conserve trout habitat in the stream during and after construction:
1. Materials placed in the river must be anchored or otherwise massive enough to resist typical flood
forces. Materials must not be placed in the river channels in a manner that overly constricts flow or
that impedes aquatic life during low water. Vertical drops over structures should be no higher than
conditions on other undisturbed parts of the river.
2. Rock, sand, or other materials must not be excavated from the river channel except where necessary
to construct the bank protecting structures or in isolated mid - channel locations for habitat
improvement structures. Channel modifications often lead to instability, particularly when done
without plans that are based on reference conditions. And, the project reach has some pool -riffle
sequences that should be maintained to the extent possible.
3. Only existing and actively eroding areas can be stabilized. Some portions of river banks in the
project reach are stable and should remain undisturbed.
4. Bank armoring should be minimized, particularly on inside meander bends as shown and where it is
usually not necessary.
5. All bare soil shall be seeded and stabilized as soon as possible after ground disturbance. Disturbed
river banks below bankfull must be covered with secured heavy fiber coir matting after seed and
straw are applied. Heavy coir matting, instead of straw mulch or burlap as specified in the plans,
should be used because the reach is prone to high shear velocities and the project will not be restoring
much floodprone area with benching. Wheat, winter rye grain, millet, or other annual cover
appropriate for the season should be used for rapid soil stabilization.
6. All heavy equipment operated near streams must be inspected and maintained regularly. Equipment
should usually be operated from the top of the river banks since mostly bank sloping and toe of slope
work will be conducted.
7. Disturbance of riparian vegetation shall be kept to a minimum. Additional tree and shrub planting is
recommended to augment the stabilization work. Most streams in the mountains of North Carolina
need deep- rooting trees and shrubs on their banks in order to remain stable, even those that are
temporarily stabilized with rock and rock structures such as vanes.

USACOE
Watauga
Page 3 January 24, 2014
Thank you for the opportunity to review and comment on this project. Please contact me at (828) 400-
4223 if you have any questions about these comments or need further assistance.
Sincerely,
Dave McHenry
Mountain Region Coordinator, Habitat Conservation Program
ec: Ms. Tasha McCormick, USACOE, Asheville
Mr. Kin Hodges and Mr. Kevin Hining, NCWRC