20220897 Ver 1_WRC Comments_20220725

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]
July 25, 2022

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

SUBJECT: Beaver Dam Analog Restoration of an Unnamed Tributary to Canoe Creek
UT Canoe Creek, Burke County

Dear Ms. Boggs:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to impact 324 ft of an unnamed tributary (UT) to Canoe Creek in Burke 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 reproduction should not be impacted by project activities and a trout moratorium is
not needed. Carolina Foothills Crayfish (Cambarus johni, NC Significantly Rare) is found in
Canoe Creek in the vicinity of the project.

The application proposes to place 2 sets of 2-4 beaver dam analog (BDA) structures along an
incised reach of stream. The BDAs would be constructed with hand tools of pine posts woven
with branches and raise the water level enough to allow the stream to better access the
floodplain. The BDAs would be maintained for up to 1-2 years, with the ultimate objective
being to attract beavers that will maintain natural beaver dams at the site. The goals of this
project are to reconnect the stream to its floodplain, minimize further incision, and monitor the
impacts if the BDAs on stream and riparian animals, hydrology, sediment dynamics, and
geomorphology. We appreciate the intention to use this project as a test of BDAs in the NC
piedmont; a robust monitoring effort will help the larger stream restoration community
understand the applicability and usefulness of this restoration method.

We offer the following recommendations to minimize impacts to the aquatic community:
BDA Restoration UT Canoe Cr Page 2 July 25, 2022
UT Canoe Cr, Burke Co
1. 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 stabilized at the end of each work day.
2. Please keep NCWRC staff informed of construction plans and monitoring results.

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: Grant Buckner, Catawba Riverkeeper
Mitchell Anderson, NC Division of Water Resources