20221449 Ver 1_WRC Comments_20221117

North Carolina Wildlife Resources Commission 0
Cameron Ingram, Executive Director
November 17, 2022
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Brown WNCSI Restoration
Cove Creek, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 1,725 ft of Cove Creek 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).
Wild trout should not be impacted by project activities, and a trout moratorium is not required for
the project. However, Cove Creek is recognized by the NC Natural Heritage Program as part of
the Watauga River Aquatic Habitat, rated Very High for the richness of rare species it contains.
The Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species of Concern, NC
Special Concern) is found in Cove Creek, and in order to avoid detrimental impacts to this
species it is important to use excellent erosion and sediment control on the project.
The application proposes to address unstable reaches of channel by installing a bankfull bench
and a series of in -stream structures including j-hooks, cross vanes, constructed riffles, boulder
sills/steps, rootwad and toe revetments, and boulder revetments. A woody buffer of native plants
of 15-25 ft in width will be established. We strongly recommend that a native riparian buffer of
at least 30 ft in width be established and maintained.
Because hellbenders have been found in Cove Creek, NCWRC staff will conduct surveys of the
project area before construction.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Brown WNCSI Restoration Page 2 November 17, 2022
Cove Creek, Watauga Co.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Be vigilant with sediment and erosion control during site staging, construction,
Disturbed
areas
should
be
stabilized
at
the
end
of
each
day.
and cleanup.
2. Work should be done at low flows, and flows diverted around in -stream work areas to
minimize fine sediment loss to the stream. Work should be performed from the banks as
much as possible, and instream equipment use be minimized.
3. Any erosion control matting used should be free of nylon or plastic 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. The project manager should reach out to Lori Williams([e-mail] ) and
Andrea Leslie([e-mail]) at least three weeks before construction begins
so that hellbender surveys can be conducted.
5. Native rocks potentially used by hellbenders should be left undisturbed during construction
activities. These rocks are typically large flat rocks at least a foot in diameter.
6. Project staff should be on site during in -stream activities to watch for hellbenders. If large
rocks, especially those in the constructed vanes to be repurposed, are disturbed, the rocks
should be lifted carefully and the area observed for hellbenders. 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 if hellbenders are found.
7. We recommend that a woody buffer as wide as possible (we recommend at least 30 feet) be
planted on the stream as infrastructure allows in order to ensure project success. A wide
forested buffer can ensure greater bank stability, filter overland pollutants, and provide
habitat for birds and other wildlife.
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: Adam Williams, Brushy Fork Environmental
Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Lori Williams, NCWRC