20080299 Ver 1_WRC Comments_20080225

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f North Carolina Wildlife Resources Commission 9
MEMORANDUM
TO: Amanda Jones, USACOE
Asheville Regulatory Field Office
FROM: Ron Linville, Regional Coordinator FES 2 J 2008
Habitat Conservation Program DENR - WADER OUAUTY
DATE: February 22, 2008 WETLANDS AND STORMWATER BRA.NCFI
SUBJECT: Linville Land Harbor Dam Rehabilitation, Linville River, DWQ20080299, Avery County
The applicant proposes to repair the Linville Land Harbor dam Biologists with the North Carolina Wildlife
Resources Commission (NCWRC) are familiar with habitat values in the area. These comments are provided in
accordance with the provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-
667d) and the North Carolina Environmental Policy Act (G.S. 113A-1 through 113A-10; NCAC 25).
The project includes removal and replacement of an aerial sewer line, a temporary access road, drawdown of the
lake, diversion channel and cofferdam construction, and earth dam improvements and stabilization. Brown and
Rainbow trout are known for the Linville River.
Based on our review of the submittal, we will not object to the project as proposed providing the following non-
prioritized conditions are implemented:
1. Below the dam, any in stream work and land disturbance within the 25-foot wide trout buffer zone
should be prohibited during the brown and brook trout spawning season of October 15 through April
15 to protect the egg and fry stages of trout from direct impacts and sedimentation. Work in the lake
or above the dam can be accomplished during this period providing it does not violate NC Division of
Water Quality sediment and turbidity (10 NTU) standards in the river.
A coldwater release(s) and aerated discharge(s) must be provided below the dam to maintain
temperature and oxygen levels needed for trout.
3. Minimum flow regimes as established by the NC Division of Water Resources, the US Army Corps of
Engineers and NCWRC biologists should be determined and ensured by structure design.
4. Sediment and erosion control measures should adhere to the design standards for sensitive watersheds
(15A NCAC 4B .01.24). Current eroding banks below the dam should be stabilized as part of the dam
rehabilitation project. Similar erosion issues should be prevented from occurring.
5. If any concrete will be used, work must be accomplished so that wet concrete does not contact stream
water.
Mailing Address: Division of Inland Fisheries - 1721 Mail Service Center - Raleigh, NC 27699-1721
Telephone: [phone] - Fax: [phone]
Linville Land Harbor Dam R&R -Page 2 -
February 22, 2008
6. Any equipment used in waters should be new or low-hour, clean and well maintained. Emergency
petroleum spill containment equipment should be readily available during the project.
7. Heavy equipment should be operated from the bank rather than in the stream channel in order to
minimize sedimentation and reduce the likelihood of introducing other pollutants into the stream.
Where this is not possible, equipment should be new or clean, low-hour and well maintained.
Petroleum spill containment equipment should be readily available and accessible at all times during
the project and until heavy equipment is removed from the work area.
8. Temporary or permanent native herbaceous vegetation should be established on all bare soil within
five (5) days of ground disturbing activities in the twenty-five (25) foot trout buffer to provide long-
term erosion control. Only autochthonous (native) plants should be used for the project. Natural fiber
matting is recommended instead of plastic matting that can entrap small animals. Onsite vegetation
and materials may be used for stream bank stabilization when practicable.
9. Flow elevations in the river should not be of a duration or extent that river banks and bank vegetation
is destabilized. In the event that damage occurs in the riparian zone, these areas should be immediately
restored using state-of-the-art natural channel design methodologies.
10. Remaining jurisdictional waters and wetlands should be buffered, either through protection or
provision of undisturbed forested buffer zones. These buffers should be permanently preserved as
common contiguous forest areas instead of being subdivided into portions of lots. For streams that do
not support federally listed threatened or endangered aquatic species, we recommend 50' intermittent
and 100' perennial stream buffers. Maximum available buffers should be provided; however, the
twenty-five (25) foot trout buffer should remain undisturbed to the maximum extent practicable.
Although not recommended, a walking trail may be placed in the buffer zone providing it is kept away
from streams to the maximum extent practicable, it is pervious, and its width does not exceed
minimum width requirements specified in the Americans with Disabilities Act (ADA).
11. Local officials should consider and evaluate the provision of stormwater management for all new and
retrofit development. Where imperviousness exceeds ten (10) percent, stormwater management
strategies that maintain pre development hydrograph conditions are recommended. Information on
Low Impact Development (LID) practices can be found at
litlp:iwWw_._c_ic?v_c«c»r;!n hcilidn:ftlxlf and l?ttp '?i,?r_?4 st?rn??? itcxcm?t_i?ct Information on
Secondary and Cumulative Impacts may be found at our NCWRC website:
4ViU1-_-- tipc?i?SC' m t> 'c ?izl?lzact .??c)f.
Although not an integral part of this application, any wastewater discharges under the control of Linville Land
Harbor should avoid using chemical disinfection processes and convert to ozone or ultra-violet if this has not been
done already. If practicable, any golf course or similar land use activities should consider incorporation of naturally
vegetated bio-retention measures to reduce potential chemical issues into waters. The National Wildlife Federation
at littp:ilwww.nw1'.orgi or Audubon International at l?itT 'IN??r>?.,tu? utK?ni_?ltl one j?ro rani ?acssi. li.hr n offer
guidance and certification programs for enviromnentally sound land use practices.
Thank you for the opportunity to review and comment on this project during the early planning stages. If you have
any questions regarding these comments, please contact me at 336-769-9453.
Cc: Cyndi Karoly, DWQ 401 Certification Unit
E-copy: Kevin Barnett, DWQ-ARO
Allan Ratzlaff, USFWS-ARO