20161060 Ver 1_WRC Comments_20161128

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
November 28, 2016
Mr. William Elliott
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Goddard Family Farm Stream Restoration
UTs to Little Cub Creek, Wilkes County
Dear Mr. Elliott:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 3100 feet of two unnamed tributaries (UTs) to Little Cub Creek in Wilkes
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).
Project activities should not impact trout reproduction and do not need to be avoided during the
trout moratorium.
The project involves bank sloping, instream structures (log riffles, log j -hooks, rock cross vanes,
and rock riffles), and planting. Livestock will be excluded from the stream channel. A new
riparian buffer will be planted, ranging in width from 10 to 40 ft on either side of the streams.
Most of the work will be done in the wet, and much of it will be performed from the top of the
bank.
We are concerned about the overuse of instream structures in the design; log riffles and rock
riffles are extremely dense in many reaches of the project and may hinder the stream from self-
adjusting, possibly causing instability over time. These structures may have unintended negative
impacts to native species.
We offer the following recommendations to minimize impacts to fish and wildlife:
1. Work should be accomplished as quickly as possible and vigilance used in sediment and
erosion control during site preparation, construction, and clean up. Disturbed areas should be
seeded, mulched and/or matted as soon as possible, preferably at the end of each work day.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Goddard Family Farm Stream Restoration
UTs to Little Cub Cr, Wilkes County
November 28, 2016
2. Measures to reduce the risk of fine sediment liberation and loss should be employed. This is
especially important, as work will be performed in the wet. We recommend diverting the
thalweg around the work area if at all possible.
3. The design should be reevaluated to determine if the number of structures can be reduced.
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. Minimize the removal of existing native vegetation within the riparian area.
6. We recommend that a woody buffer of at least 30 feet 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, and provide habitat for birds and other
wildlife.
7. The plan does not include temporary seed specifications for the riparian area within 25 feet
of the stream. Fast-growing temporary seed using non-invasive species should be established
within the riparian area, such as Wheat, Rye Grain or Oats.
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: Derek Goddard, Landowner
Sue Homewood, NC Division of Water Resources