20221614 Ver 2_NPS_BRP_DWR 20221614v2_NWP Application_Watauga Caldwell Avery_NCWRC Comments_20230901

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
September 1, 2023
Amanda Jones
U.S. Army Corps of Engineers, Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801
Dave Wanucha
NCDEQ, DWR
450 Hanes Mill Road, Suite 300
Winston Salem, NC 27105
SUBJECT: Comments on NWP/WQC Application for NPS BRP Pavement and Drainage
Maintenance from US 321 to US 221, Watauga, Caldwell, and Avery Counties.
DWR 20221614 ver.2 (BLRI2B13-2H17)
Dear Amanda and Dave,
Contractors for the National Park Service Blue Ridge Parkway (NPS BRP) applied for a Nationwide 404
Permit and 401 Certification for the subject project. I am familiar with the wildlife resources in the area
but did not visit the project sites. Comments on the application from the North Carolina Wildlife
Resources Commission (NCWRC) are offered to conserve wildlife resources affected by the project and
to promote wildlife -based recreation in accordance with applicable provisions of the state and federal
Environmental Policy Acts (G.S. 113A-1through 113-10; 1 NCAC 25 and 42 U.S.C. 4332(2)(c),
respectively), the Clean Water Act of 1977 (33 U.S.C. 466 et seq.), and the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).
The project will impact Sims Creek, Boone Fork, and Dixon creeks, or their unnamed tributaries, and
unnamed tributaries to Cold Prong and Hill (Anthony) Branch in Watauga, Caldwell, and Avery counties.
Most of the work will involve channel dewatering and excavation of accumulated sediments in the
vicinity of culverts that pass under the parkway or connecting roadways.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

DWR 20221614 VER.2 Page 2 September 1, 2023
Watauga, Caldwell, Avery
The potential effects of the project on federally listed species have already been addressed in consultation
with the US Fish and Wildlife Service. The NCWRC supports the conservation measures outlined in the
consultation information that was included with the application.
Most of the affected streams are small, first order tributaries that are likely fishless. However, others may
support wild trout populations at or short distances downstream of the impact sites. The NCWRC
requests that the October 15 to April 15 moratorium for work in all streams and buffers be adhered to
because there are naturally reproducing trout at or downstream of all project sites. Ground stabilization
would be challenging at high elevation in the winter as well. Adherence to the moratorium was proposed
in previous applications for culvert work on the parkway.
In addition to the moratorium, effective sediment and erosion controls will be needed and work should be
performed steadily within jurisdictional areas to minimize the potential for downstream sedimentation.
Sedimentation, if it occurred, could be extensive because the sites are situated near the headwaters of
these stream systems.
The NCWRC emphasizes that overly widening or deepening of channels and the elevating of culvert
outlets (aka perching) should be avoided. While the intent of the work is to restore hydraulic capacities of
drainage structures, it is nonetheless important to balance that objective with the natural functions of these
systems, including aquatic life support and sediment transport. Therefore, to the extent possible,
excavation should mimic stable or reference channel dimensions that are expected for the size of the
streams.
Thank you for the opportunity to review and provide recommendations on this project. Please contact me
at david.mchenrykncwildlife.org or [phone] if you have any questions about these comments.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
cc: John Thomas, Gannett Fleming