SetzerHatcheryRenovations_DavidsonR&GroganCr_Transylvania_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]
February 9, 2024

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

SUBJECT: Bobby N. Setzer State Fish Hatchery Renovations
Davidson River and Grogan Creek, Transylvania County

Dear Ms. Healy,

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an application to
permanently impact 35 ft and temporarily impact 332 ft of the Davidson River and Grogran Creek in
Transylvania 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 Rainbow Trout and Brown Trout are found in the vicinity of the project. Both Eastern Hellbender
[Cryptobranchus alleganiensis, US Federal Species of Concern (FSC), NC Special Concern] and French
Broad River Crayfish (Cambarus reburrus, US FSC, NC Significantly Rare) are also found in the
Davidson River in the project vicinity. The hellbender population in the Davidson River is particularly
robust, and we request that in-stream construction activities be avoided from August 15 to November 30
to avoid impacts to Eastern Hellbender breeding, nesting, and hatchling development. As in-stream work
is limited and will be performed in the dry, we are not requesting a trout moratorium; however, we ask
that work areas in the riparian corridor be stabilized at the end of each work day to minimize sediment
loss into the Davidson River and Grogan Creek.

The project involves impacts associated with major renovations at the Setzer fish hatchery, including
replacement of the raceways and hatchery building. Water is supplied to the hatchery via existing dam-
associated intakes on Grogan Creek and the Davidson River, which will remain. The increase in
impervious area from this renovation will be treated through stormwater best management practices.
Stormwater from the hatchery and trail parking lot to the east will be directed to the Davidson River or to
a new stormwater wetland that drains to Grogan Creek. Renovations will involve numerous elements that
will improve water use efficiency and waste treatment.

In-stream impacts include temporary dewatering via aqua dams, coir logs, concrete barriers, or other
structures at three sites on the Davidson River and one site on Grogan Creek. At two of the dewatered
sites on the Davidson River, discharge pipes and concrete headwalls will be installed. At the remaining
Setzer Hatchery Renovations Page 2 February 9, 2024
Davidson R & Grogan Cr, Transylvania Co
Davidson River site and the Grogan Creek site, outfall pipes will be installed, but no concrete headwalls
will be used.

The US Forest Service is committed to improving water quality and maintaining habitat that supports a
diversity of aquatic species, such as the Eastern Hellbender. Hatchery upgrades are expected to greatly
improve water efficiency, requiring less water from the Davidson River. A pump-back system has been
incorporated into the design, which will allow for water to be pumped back to the base of the dam in the
Davidson River to benefit aquatic species and associated habitats; this could be incorporated into an
operation protocol. NCWRC has begun collecting and compiling information to inform triggers to use
this pump-back system in order to maintain in-stream flows that would support the biodiversity in the
Davidson River. Since water efficiencies are expected with the hatchery renovations, a final operating
protocol with instream flow specifications would not be finalized and implemented until after
construction is complete and adjustments made with actual withdrawal needs.

We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Be vigilant with sediment and erosion control (SEC) during site staging, construction, and cleanup.
Disturbed areas in the stream or riparian area should be stabilized at the end of each day. SEC in both
riparian and upland areas is extremely important to minimize impacts to the Davidson River and
Grogan Creek.
2. Work should be done at low flows.
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. The
matting that is included in the plans has polypropylene netting; this type of matting should not be
used.
4. A moratorium of August 15 to November 30 should be applied to the in-stream work on this project
in order to protect trout and hellbender reproduction.
5. The site should be surveyed for the Eastern Hellbender just before the project begins; animals should
be relocated well outside of the project area. 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 NCWRC can coordinate these efforts.
6. Shelter rocks potentially used by hellbenders should be left undisturbed as much as possible during
construction activities. Shelter rocks are typically large flat rocks at least a foot in diameter.
7. Specifications are not provided for temporary seeding. Invasive species such as Tall Fescue,
Kentucky Bluegrass, and Sericea Lespedeza should not be used; we recommend a mix of Red Clover,
Creeping Red Fescue, and a grain, such as Oats, Wheat, or Rye.

Thank you for the opportunity to review and comment on this project. Please contact me at (828) 400-
4223 if you have any questions about these comments.

Sincerely,

Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program

ec: Jon Swaim and Alex Lowdermilk, McGill Associates
Lorie Stroup, US Forest Service
David Deaton, Shannon Deaton, Brad Kleinmaier, Powell Wheeler and Lori Williams, NCWRC
Joey Winston, NC Division of Water Resources