20160871 Ver 1_Other Agency Comments_20160912

Homewood, Sue
From: Leslie, Andrea J
Sent: Monday, September 12, 2016 4:35 PM
To: Elliott, William A SAW
Cc: Homewood, Sue; Derek Goddard
Subject: FW: Boone Mall Culvert Maintenance - NCWRC comments
Attachments: BooneMallCulvertMaintenance_BooneCr_Watauga_WRCComments.pdf;
BackyardStreamRepairGuide.pdf
William and Sue,
Our comments remain the same on the revised PCN for. the Boone Mall. Culvert Maintenance project.
Andrea
Andrea Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Commission
20830 Great Smoky Mountain Expressway
Waynesville, NC 28786
828-558-6011; 828-400-4223 (cell)
www.ncwildlife.org
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From: Leslie, Andrea J
Sent: Friday, July 29, 2016 1:39 PM
To:'Elliott, William A SAW' <[e-mail]>
Cc: Homewood, Sue<sue. homewood @ ncdenr.gov>; 'Derek Goddard' <[e-mail]>; Hodges, Kinnon B
<[e-mail]>; Byron Hamstead ([e-mail]) <[e-mail]>
Subject: Boone Mall Culvert Maintenance - NCWRC comments
Hi William,
Attached are NCWRC's comments on the Boone Mall Culvert Maintenance project.
Andrea
Andrea. Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Coln..mission

20830 Great S>n.oky Mountain Expressway
Waynesville, NC 28786
828-558-6011; 828-400-4223 (cell)
www.ncwildlife.org
Get NC Wildlife Update delivered to your in.box from the N.C. Wildlife Resources Commission.
Email correspondence to and from. this sender is subject to the N.C. Public. Records Law and may be disclosed to third parties.

® North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
July 29, 2016
Mr. William Elliott
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Boone Mall Culvert Maintenance
Boone Creek, Watauga County
Dear Mr. Elliott:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to dredge sediment from a quadruple box culvert and the stream channel both upstream
and downstream of the culvert, impacting 125 feet of Boone Creek in Watauga 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).
There are wild Brown Trout in the project vicinity, and in -stream activities should be avoided
between October 15 and April 15 to avoid impacts to trout spawning. In addition, the site is just
upstream of the South Fork New River, which is part of the South Fork New River Aquatic Habitat, a
natural area rated Exceptional by the NC Natural Heritage Program due to the extraordinary diversity
of rare species it contains. Rare and listed species within the vicinity of the project include the
Eastern Hellbender [Cryptobranchus alleganiensis, US Federal Species of Concern (FSC), NC
Special Concern (SC)], Kanawha Minnow (Phenacobius teretulus, US FSC, NC SC), Tonguetied
Minnow [Exoglossum laurae, NC Significantly Rare (SR)], and Kanawha Darter (Etheostoma
kanawhae, NC SR). Wild trout and these rare species are especially sensitive to sediment, and
special care should be taken to minimize sediment loss from the project.
The application proposes to dig out sediment that has accumulated in the box culvert and upstream
and downstream sediment bars with a front-end loader. Sediment would be removed from all four
boxes in the culvert and that in the channel would be removed to achieve the same elevation as the
culvert bottom. Sediment would be deposited on the stream bank, surrounded by a silt fence while
stockpiled, and hauled offsite once work is completed. Although the application is for repeated
culvert and channel dredging for up to two times per year, it is our understanding that Nationwide
Permit 3 can only be applied to a one-time event.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Boone Mall Culvert Maintenance Page 2 July 29, 2016
Boone Creek, Watauga County
Some of the work would be performed from the bank, but other work will be done in the wet with the
front-end loader. Straw bales and a sediment curtain would be placed downstream of the work area.
Due to the sensitivity of trout and the rare species to sedimentation noted above, we are concerned
about the potential for loss of sediment from the in -stream work described in this application.
We commented on a similar permit application for the Boone Mall culvert maintenance on December
12, 2008, and our concerns remain the same. As in 2008, we do not believe that culvert and channel
dredging is a long-term or effective solution to flooding, and we recommend that other measures be
considered such as replacing the culvert with a bridge, increasing flood storage capacity at the site,
and coordinating with adjacent landowners to increase channel and flood storage capacity.
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -stream activities should be avoided between October 15 and April 15 in order to avoid impacts
to Brown Trout spawning.
2. Work should be accomplished as quickly as possible and vigilance used in sediment and erosion
control during site preparation, construction, and clean up. In -stream work should be done at low
flows. Disturbed areas should be seeded, mulched and/or matted as soon as possible, preferably
at the end of each work day.
3. In the vicinity of the culvert, the base flow channel's natural dimension, pattern and profile
should be retained so that the channel continues to flow through one of the culvert boxes. This
can be accomplished through the placement of an upstream sill on the three `stormflow' boxes or
by leaving a portion of the sediment deposits in those boxes so that baseflows continue to flow
through a single barrel. Soils inside the culverts should not be removed below the natural
floodplain bench elevation to preclude exasperated sedimentation below the culvert during storm
events.
4. Any erosion control matting used be free of plastic or nylon mesh, as this type of mesh netting
frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last for years.
5. We recommend that a woody buffer as wide as possible be planted on both sides of the stream as
infrastructure allows in order to ensure project success. A wide forested buffer can ensure
greater bank stability, filter overland pollutants, provide cooler water temperatures needed by
Brown Trout and the rare species in the South Fork New River, and provide habitat for birds and
other wildlife.
Thank you for the opportunity to review and comment on this project. Please contact me at (828)
558-6011 if you have any questions about these comments.
Sincerely,
'0�dA"�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Derek Goddard, Blue Ridge Environmental Consultants
Sue Homewood, NC Division of Water Resources
Kin Hodges, NCWRC
Byron Hamstead, US Fish and Wildlife Service