20211821 Ver 1_WRC Comments_20220105

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]
January 5, 2022

Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Slope Stabilization at Cullowhee Dam
Tuckasegee River, Jackson County

Dear Mr. Brown:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 43 ft of stream for bank stabilization and structure repair and
temporarily impact 46 ft of stream to install a coffer dam for the work in the Tuckasegee River
Jackson 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).

This project should not affect trout and the activities do not need to be avoided during the trout
spawning moratorium. However, this part of the Tuckasegee River is in the Tuckasegee River
Aquatic Habitat, a NC Natural Heritage Program natural area rated Exceptional due to the
richness of rare species it supports. Appalachian Elktoe (Alasmidonta raveneliana, US and NC
Endangered), Wounded Darter [Etheostoma vulneratum, US Federal Species of Concern (FSC),
NC Special Concern (SC)], Eastern Hellbender (Cryptobranchus alleganiensis, US FSC, NC
SC), and Little Tennessee Crayfish (Cambarus georgiae, US FSC, NC SC) are found in the
Tuckasegee River in the vicinity of the project. Hellbenders have been found at the impact site.
Sicklefin Redhorse (Moxostoma sp., NC Threatened) is also found in the river downstream of the
dam. Due to the sensitivity of these species to fine sediments, it is essential that excellent
erosion and sediment control be maintained during the project.

The project involves the placement of riprap and gabion baskets along 60 ft of the right bank,
just downstream of the dam. This work would be performed in the dry through the installation of
a coffer dam around the area. In addition, a sand filter will be established and concrete poured
on a sluice gate on the left bank to address leakage from the dam.

Slope Stabilization at Cullowhee Dam Page 2 January 5, 2022
Tuckasegee R, Jackson County
NCWRC is aware of past discussions regarding the removal of Cullowhee Dam. The present
project is presented as an alternative to dam removal to address continuing instability of the dam.
We strongly recommend that the dam be removed to address the long-term instability issues ;
dam removal would greatly expand available habitat for the state threatened Sicklefin Redhorse,
whose upriver movement is blocked by the dam. Removal would also allow free movement by
other aquatic species, including those rare and listed species noted above.

We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. 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. Work should be performed during low flows.
3. Any erosion control matting used be free of plastic or nylon mesh, as this type of mesh
netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that may
last for years.
4. Due to the presence of Eastern Hellbender and Appalachian Elktoe in the project vicinity, the
applicant must contact Lori Williams ([e-mail]), Luke Etchison
([e-mail]), and Andrea Leslie ([e-mail]) at least 3
weeks before construction begins, so that the area of impact may be surveyed for these
animals.
5. Shelter rocks potentially used by hellbenders should be left undisturbed during construction
activities. Shelter rocks are typically large flat rocks at least a foot in diameter. If animals
are disturbed during construction, they should be captured in a bucket and moved away from
the area of disturbance. Please notify Lori Williams ([e-mail]) if
hellbenders are found.
6. Concrete should be poured and cured away from water to avoid toxic pH levels in contact
water.

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: Jon Swaim, McGill Associates
Kaylie Yankura, NC Division of Water Resources
Rebekah Reid, US Fish and Wildlife Service
Luke Etchison and Lori Williams, NCWRC