20151275 Ver 1_WRC Comments_20151207

II North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
December 7, 2015
Ms. Tasha Alexander
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Jefferson Landing Pond
Little Naked Creek, Ashe County
Dear Ms. Alexander:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to drain and dredge accumulated sediments from a 4 -acre pond on Little Naked
Creek in Ashe 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).
The project should not impact wild trout populations, so project activities do not need to be
avoided during the trout moratorium period. However, the site is just upstream of the South Fork
New River Aquatic Habitat, a NC Natural Heritage Program natural area rated Very High for the
richness of rare species it contains. The following rare and/or listed species are found in the
South Fork New River in the vicinity of the project: two mussels --Spike [Elliptio dilatata, NC
Special Concern (SC)] and Seep Mudalia (Leptoxis dilatata, NC Threatened); three fishes
endemic to the New River basin—Kanawha Minnow [Phenacobius teretulus, US Federal
Species of Concern (FSC), NC SC], Kanawha Darter [Etheostoma kanawhae, NC Significantly
Rare (SR)], and Kanawha Rosyface Shiner (Notropis sp., NC SR); and two other rare fishes—
Sharpnose Darter (Percina oxyrhynchus, NC SC) and Tonguetied Minnow (Exoglossum laurae,
NC SR).
The application proposes to drain the lake slowly with a bottom gate valve, which is above the
bottom of the pond, is operated regularly, and was used to lower the pond completely in 2014.
The stream will run through the pond bed and silt fence installed along it to isolate it from the
pond dredging area. Sediments will be allowed to dry or freeze and then be dredged with a long
reach excavator. Sediments will be spoiled on a site at least 25 feet from the stream upstream of
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Jefferson Landing Pond Page 2 December 8, 2015
Little Naked Creek, Ashe County
the dam and stabilized with sediment and erosion control measures. Turbidity will be monitored
daily during excavation and during storm events.
Due to the rich community of rare and listed species in the South Fork New River, NCWRC is
very concerned about the potential for sediment loss from the project. We recommend that the
pond be drained as quickly as possible without releasing sediment or causing erosion in the
downstream channel. If this method of lake lowering does result in more than minimal sediment
loss, then the pond level should be lowered with surface pumps or a siphon. We appreciate the
efforts to monitor turbidity. We recommend that turbidity be monitored daily with a real-time
method (e.g., turbidity meter) during drawdown.
We were just made aware that the lake is currently being drawn down in preparation for
excavation work; there is no 401 or 404 permit in hand and it is unknown when and if these will
be granted. If the lake is drawn down completely, the channel will be vulnerable to
sedimentation from exposed in -pond sediment during storm events. We recommend waiting to
draw down the pond until permits are in hand. If the pond does sit in a drawn down state, we ask
that sufficient erosion control measures be installed to ensure that sediment is not lost to the
channel.
In addition, we are concerned about the risk of sediment loss into the channel during excavation,
and we recommend that the excavation work be performed in the dry and the stream pumped
around the work area.
We offer the following recommendations to minimize impacts to fish and wildlife:
1. If pond draining results in more than de minimus sediment release, pond lowering should be
shifted to a surface pump or siphon draining method.
2. We recommend that the stream not be drawn down until permits are issued. If the pond is
drained and rests in a drawn down state, sufficient erosion control measures be installed to
ensure that sediment is not lost to the channel.
3. Dredging should be conducted in the dry and the stream pumped around the area to be
dredged.
4. Vigilant sediment and erosion control is essential in order to minimize sediment impacts to
downstream waters. Particular care should be used with sediment and erosion control during
site preparation, construction, and clean up.
5. Spoiled excavated sediments must be stabilized with temporary seed and straw and/or
matting. We recommend that measures be implemented to treat any drainage water from the
spoiled dredge material prior to being directed to surface waters, such as a grassed swale
draining to a settling basin.

Jefferson Landing Pond Page 3 December 8, 2015
Little Naked Creek, Ashe County
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 or need further assistance.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Derek Goddard, BREC
Sue Homewood, NC Division of Water Resources
Kin Hodges, NC Wildlife Resources Commission