WNCSICedarCrJonesSite_CedarTaylorUTs_Rutherford_NCWRCComments (002)

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]
October 28, 2022

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

SUBJECT: WNCSI Cedar Creek (Jones Sites)
Cedar Creek, Taylor Creek, and UTs, Rutherford County

Dear Ms. Boggs:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 3,332 ft of Cedar Creek, Taylor Creek, and unnamed tributaries (UTs) to
Cedar Creek in Rutherford 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 the project, and a trout moratorium is not
needed. However, Seagreen Darter (Etheostoma thalassinum, NC Significantly Rare) is found in
the project vicinity, and effective erosion and sediment control on this project are especially
important to minimize its impacts to this rare species.

The impacts involve restoring profile and dimension in all streams; on Cedar Creek, pattern will
be addressed as well. The streams will be restored with a bankfull bench, in-stream structures
including constructed riffles, log vanes, j-jooks, and brush toe, and a riparian buffer of 10-35 ft in
width. Where feasible, the channel will be constructed off-line.

Plan sheets 3.1 and 3.2 note that stream banks should be stabilized within 7 days in Note 2, but
that all disturbance within 25 ft of the top of bank should be stabilized by the end of day in Note
9; we recommend that Note 2 be deleted.

We offer the following recommendations to minimize impacts to fish and wildlife:
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
WNCSI Cedar Creek Page 2 October 28, 2022
Cedar Cr, Taylor Cr, UTs, Rutherford Co.
areas should be seeded, mulched and/or matted as soon as possible, preferably at the end of
each workday.
2. 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.
3. A considerable length of stream will only be planted within 10 ft of top of bank. We
recommend that a woody buffer of at least 30 feet be planted on both sides of 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.
4. In-stream work should be performed in the dry in the smaller streams (UTs). In Cedar Creek
and Taylor Creek, work should be done at low flows, and flows diverted around in-stream
work areas to minimize fine sediment loss to the stream, especially where there is more risk
of sediment loss, such as bank tie-in areas. Work should be performed from the banks as
much as possible, and instream equipment use be minimized.

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: Ian Eckardt, Wildlands Engineering
Joey Winston, NC Division of Water Resources