20231153 Ver 2_WRC Comments_20240209 (2)

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
February 9, 2024
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Shulls Mill Dam Removal
Watauga River, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to impact 445 ft of the Watauga River and 62 ft of an unnamed tributary (UT) for the
purpose of removing the Shulls Mill dam on the Watauga River in Watauga County. We have
visited the site multiple times and attended numerous meetings with the design team. These
comments are based on both the permitting package and meetings with Jake McLean, the lead
designer for Wildlands Engineering. 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).
Project activities should not impact wild trout, and a trout moratorium is not needed for the
project. However, the Watauga River is part of the Watauga River Aquatic Habitat, a NC Natural
Heritage Program natural area rated Very High due to the richness and ecological importance of
the aquatic community. Most importantly, the Eastern Hellbender (Cryptobranchus
alleganiensis, US Federal Species of Concern, NC Special Concern) is present just downstream
of the dam. We request that in -stream activities be avoided between August 15 and November 30
to minimize impacts to the Eastern Hellbender during its reproduction and nesting season.
Effective erosion and sediment control on the project is extremely important to protect habitat for
this species.
The project proposes to remove Shulls Mill dam and restore a stretch of channel upstream of the
dam in order to minimize sediment release downstream. Activities will include stabilizing the
vertical and unstable left bank, excavating the channel upstream of the dam by approximately 3
ft to match what appears to be the former bed level. Rock will be harvested from a boulder area
on river right at the dam, and this rock will be used to stabilize the left bank. Spoil will be used
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Shulls Mill Dam Removal Page 2 February 9, 2024
Watauga River, Watauga Co
for left bank restoration, and it is likely that more will need to be taken off site. The river will be
accessed with heavy machinery, but most of this will be done in the dry; a wood mat bridge will
be constructed over the live channel, travel up and down the channel will mostly be done from
dry rocky bars, and where the river channel will be excavated, flows will be diverted away from
work areas. The dam will be removed in stages, with river flows diverted around these work
areas.
The permitting plans propose to place some spoil in the pool just downstream of the dam on river
left. We recommend that this pool be left alone, as hellbenders are present here. The design team
has agreed to avoid filling this area.
As there is an important hellbender population just downstream of the dam, surveys and animal
relocations will be performed before construction by Appalachian State University and NCWRC
biologists. We ask that the design -construction team continue to communicate closely with this
group during the project.
We offer the following recommendations to minimize impacts to the aquatic community:
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 mesh, as this type of mesh netting
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 August 15 and November 30 to minimize
impacts to the Eastern Hellbender during its reproduction and nesting season.
4. NCWRC staff would like to be kept abreast of progress during construction. Please
coordinate with Andrea Leslie on progress.
5. The applicant should notify Lori Williams(lori.williams(d),ncwildlife.org), Andrea Leslie
(andrea.leslie&ncwildlife.org), and Mike Gangloff (gangloffminkenstate.edu) at least 3
weeks before project construction is to begin so the affected reach can be surveyed for
hellbenders and found animals relocated.
6. Work should be done at low flows.
7. Avoid heavy equipment access in the wetted channel as much as possible. This is especially
important where larger rock is present that could harbor hellbenders.
8. If Eastern Hellbenders are seen during construction, they should be captured in a bucket and
moved away from the area of disturbance. Contact Lori Williams
(lori.williams(ancwildlife.org) if animals are seen.
9. The pool downstream of the dam on river left should not be used as a spoil deposition area
due to the presence of hellbenders there.

Shulls Mill Dam Removal Page 2 February 9, 2024
Watauga River, Watauga 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: Mimi Caddell and Jake McLean, Wildlands Engineering
Andy Hill, MountainTrue
Sue Homewood and Seren Homer, NC Division of Water Resources
Dr. Mike Gangloff, Appalachian State University
Lori Williams, NCWRC