20160075 Ver 1_WRC Comments_20160223

� North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
February 23, 2016
Mr. William Elliott
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Lansing Creeper Trail Project
Big Horse Creek, Ashe County
Dear Mr. Elliott:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize and improve habitat on approximately 1,900 feet of Big Horse 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).
This project should not negatively impact wild trout and the activities do not need to be avoided
during the trout spawning moratorium. This portion of the river is recognized by the NC Natural
Heritage Program as the North Fork New River Aquatic Habitat, rated High for the richness of
rare species it contains. Four rare fish are found in Big Horse Creek in the vicinity of the
project—Kanawha Minnow [Phenacobius teretelus, US Federal Species of Concern (FSC), NC
Special Concern (SC)], Kanawha Rosyface Shiner [Notropis sp., NC Significantly Rare (SR)],
Kanawha Darter (Etheostoma kanawhae, NC SR), and Tonguetied Minnow (Exoglossum laurae,
NC SR), as well as Seep Mudalia (Leptoxis dilatata, NC Threatened) and Eastern Hellbender
(Cryptobranchus alleganiensis, US FSC, NC SC).
We are supportive of the project's objectives, which are to address bank instability and improve
in -stream habitat on a reach of Big Horse Creek that runs through the Town of Lansing. The
project design includes rock vanes, cross vanes, root wads, and boulder clusters, as well as bank
grading, and riparian planting. Many of the instream structures are intended to provide habitat
for stocked trout, as Big Horse Creek is a Delayed Harvest Trout Water.
Our review of the design does raise some concerns, as we believe that the approach may be
overly intensive for this stretch of Big Horse Creek and have unintended impacts to native
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Lansing Creeper Trail Project Page 2 February 23, 2016
Big Horse Creek, Ashe County
species. We suggest that the number of structures be reduced and that the placement of some
structures be modified. For example, several rootwads appear to be on the inside of bends and
may have little habitat value in these depositional areas. The number of cross vanes may be
excessive, given the low slope of the reach. We also recommend modifying the cross vane
design to achieve longer, lower sloped arms and a more "U" shaped structure, as this should lead
to less scour and a more stable structure.
We appreciate the design team's interest in modifying the design to benefit the Eastern
Hellbender. Rock structures, including vanes and boulder clusters, can provide cover. We
recommend incorporating large (at least 2 x 3 ft) flat rocks, oriented with an opening on the
downstream side if possible.
In coordination with the Town of Lansing, NCWRC has designed a fishing pier within the
project's footprint. It appears that the fishing pier location is incorrect on the project plans, and
that coordination is needed between the two projects. Please contact Jeff Ferguson of NCWRC
at 828-231-3517 to coordinate.
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. Efforts
should be made to isolate the work area from the thalweg wherever possible. Disturbed areas
should be seeded, mulched and/or matted as soon as possible, preferably at the end of each
work day; at a minimum, disturbed areas should be stabilized within five working days or
seven calendar days, whichever is shorter.
2. Any erosion control matting used be free of nylon mesh; nylon mesh netting frequently
entangles wildlife and is slow to degrade resulting in a hazard that may last for years.
3. We request that shelter rocks potentially used by Hellbenders be left in place during
construction activities. Shelter rocks are typically large (at least 2 x 3 ft) flat rocks.
4. We recommend that a woody buffer as wide as possible be planted on both sides of the
stream to ensure project success. A wide forested buffer will ensure greater bank stability,
filter overland pollutants, provide cooler water temperatures needed by rare and common
native aquatic species as well as trout, and provide habitat for birds and other wildlife.
5. We recommend that the design be reevaluated to reduce the number of cross vanes, modify
structure placement, and modify cross vane design.

Lansing Creeper Trail Project Page 3 February 23, 2016
Big Horse 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.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Glen Sullivan, Foggy Mountain Nursery
Sue Homewood, NC Division of Water Resources
Jeff Ferguson, Kin Hodges, Lori Williams, Scott Loftis, NCWRC