20071556 Ver 2_Other Agency Comments_20141017

9 North Carolina Wildlife Resources Commission P
Gordon Myers, Executive Director
September 19, 2014
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801 -5006
SUBJECT: Comments on Big Ridge After the Fact PCN
Jackson County
Dear Mr. Brown,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an application
for an After - the -Fact (ATF) permit for unauthorized activities associated with road construction to
provide access to lots within a subdivision formerly known as Mount Wilderness in Jackson County.
These activities resulted in a Notice of Violation in 2007 to the former landowner; the current landowner
seeks to address these violations. On September 12, I visited the site with Chuck Cranford of the NC
Division of Water Resources and Rebekah Newton, consulting biologist with C1earWater Environmental
Consultants. 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).
The ATF application states that unpermitted activities resulted in the installation of eleven culverts that
impact 512 ft of stream. The applicant proposes to remove four of these culverts, reduce the length of
two others, and restore a stream that was moved at the development's entrance. The streams on this
property drain to the West Fork of the Tuckasegee River which contains wild Rainbow Trout. We request
a trout moratorium for this project, and work should be avoided between January 1 and April 15.
We are supportive of the proposed activities to reduce the original stream impacts. The application
offered little detail on how culvert removal and channel restoration would be implemented. We offer the
following recommendations to minimize impacts to on -site and downstream resources:
1. Culvert removal (culverts Cl, C9, C10, Cl l) and culvert shortening (culvert C2) should take
place in the dry by temporarily diverting stream flow around excavation areas. Stream channels
should be constructed to ensure stability, banks seeded and covered with heavy fiber matting,
and native woody vegetation planted.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

Big Ridge ATF Page 2 September 19, 2014
Jackson
2. According to the proposal, culverts C3, C4, C5, and C7 will remain in place. The outlets of these
culverts are perched and overhang the downstream slope. Where possible, culvert outlet
overhang should be reduced by cutting the culvert back to the side slope. Large splash rocks
should be installed to dissipate energy and reduce potential for downstream erosion.
3. The proposed channel restoration should take place in the dry. The stream channel should be
constructed to mimic stable upstream dimensions. Banks should be seeded and covered with
heavy fiber matting, and native woody vegetation should be planted within the disturbed riparian
corridor.
4. Matting used for bank stabilization should be free of nylon mesh. Nylon mesh netting frequently
entangles wildlife and is slow to degrade resulting in a hazard that may last for years.
5. For all stream work, particular care should be used with sediment and erosion control measures
during site preparation, construction, and clean up.
6. Stormwater impacts from the site should be evaluated and minimized. In particular, steep eroding
sections of road should be stabilized, best management practices should be installed to capture
sediment from roads, and bare eroding slopes along roads should be seeded and stabilized.
7. If road sections are abandoned, they should be seeded and stabilized.
Thank you for the opportunity to review and comment on this project. Please contact me at (828) 296-
4720 if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator
Habitat Conservation Program
ec: Rebekah Newton, C1earWater Environmental Consultants
Chuck Cranford, NC Division of Water Resources