LinvilleStreamCrossing_UTLinvilleR_Avery_NCWRCComments

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 6, 2023

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

SUBJECT: Linville Stream Crossing
UT to Linville River, Avery County

Dear Ms. Fuemmeler:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 20 ft and temporarily impact 40 ft of an unnamed tributary
(UT) to the Linville River in Avery 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 Brown Trout are found just downstream of the project vicinity, and instream work should
be avoided between October 15 and April 15 to minimize impacts to trout reproduction.

We offer the following recommendations to minimize impacts to fish and wildlife resources:
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 seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day.
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. In-stream activities should be avoided between October 15 and April 15 in order to minimize
impacts to wild trout reproduction.
4. Culvert material is not specified. We recommend against using high density polyethylene
(HDPE) or reinforced concrete pipe (RCP) material, as this smooth material is less likely to
hold stream substrate and provide for movement of aquatic organisms like fish and
salamanders.

Linville Stream Crossing Page 2 July 6, 2023
UT Linville River, Avery Co
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: Sarah Kilby, Interface Environmental Consulting
Joey Winston, NC Division of Water Resources