20211637 Ver 1_WRC Comments_20220222

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]
February 22, 2022

Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Clevon Woods OSWW Plant
Watauga River and wetland, Watauga County

Dear Ms. Fuemmeler:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to fill 0.094 acre of wetland in the Watauga River floodplain in Watauga 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).

Activities should not impact wild trout reproduction, and a trout moratorium is not needed.
However, there are wild Rainbow Trout and Brown trout in the Watauga River. In addition, the
project is upstream of a reach of the Watauga River that is part of the Watauga River Aquatic
Habitat, a NC Natural Heritage Program natural area rated Very High due to its ecological
significance. The Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species of
Concern, NC Special Concern) is found downstream of the project. Notably, the Watauga River
is classified as a High Quality Water, as well.

The application proposes to fill a wetland in order to construct a wastewater treatment plant
(WWTP) on the 0.576-acre site. Practically the entire site would be filled to raise the elevation
for the WWTP. A part of the proposed fill would be in the floodway, and the majority of the
WWTP would be in the 100-year floodplain. The NCWRC does not support commercial or
residential development within the floodway or 100-year floodplain. The filling of floodplains
increases the potential for flooding and degrades in-stream habitats for fish and other aquatic
organisms. Placing a WWTP in the 100-year floodplain poses a distinct risk to water quality in
the Watauga River; flooding of the WWTP is possible, resulting in loss of untreated and partially
treated wastewater into the Watauga River, impacting its important biological community.

Clevon Woods WWTP Page 2 February 22, 2022
Watauga River and wetland, Watauga Co
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 workday.
2. Disturbed wetland areas should be reseeded with a native wetland seed mix.
3. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
4. Wetlands should be clearly marked and areas outside of the work area flagged or fenced in
order to exclude machinery from them.
5. Any equipment that is used in wetlands resulting in temporary impacts should be set on
timber mats.
6. We strongly recommend that the WWTP be sited outside of the floodway and 100-year
floodplain in order to protect the Watauga River and its important biological community.

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: Sue Homewood, NC Division of Water Resources
Michael Brame, Pilot Environmental
Kin Hodges and TJ Johnson, NCWRC