20170204 Ver 3_WRC Comments_20170317

Strickland, Bev
From: Leslie, Andrea J
Sent: Friday, March 17, 2017 9:17 AM
To: Brown, David W SAW
Cc: john vilas [e-mail]); Mitchell, Robert K
Subject: Project Bluebird FRC - NCWRC comments
Attachments: ProjectBluebird FRC-UT2nd Broad R-Rutherford-WRCComments.pdf
Hi David,
Attached are NCWRC's comments on Project Bluebird FRC.
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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1

� North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
March 17, 2017
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Project Bluebird FRC
UTs to Second Broad River, Rutherford County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert two unnamed tributaries (UTs) to the Second Broad River in Rutherford
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 wild trout, and activities do not need to be avoided during the
trout moratorium.
The project will involve the placement of a 51 -ft culvert and riprap protection within 24 ft of the
bed on a perennial stream, as well as a 42 -ft culvert and riprap protection within 20 ft of the bed
on an intermittent stream. Work will be performed in the dry and the culverts buried to allow
passage of organisms and stream sediments.
Former impacts at the project site in addition to present project impacts exceed mitigation
thresholds, and 1:1 mitigation is proposed for 148 ft of past and 93 ft of present impacts,
resulting in a proposed 241 ft of stream mitigation. Mitigation is only proposed for the culverted
areas of the streams. We argue that riprap placement within the stream bed of 44 ft of stream
constitutes negative long-lasting stream impact, and we recommend that this length of impact
also be mitigated, adding 44 ft to the 241 ft of proposed mitigation. In addition, we recommend
that impacts to the intermittent stream, which is rated through the NC Stream Assessment
Method as High, be mitigated with a 2:1 mitigation ratio.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Project Bluebird FRC Page 2 March 17, 2017
UT 2nd Broad River, Rutherford Co
We offer the following recommendations to minimize impacts to the aquatic and terrestrial
resources:
1. Work 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. We recommend planting a permanent seed mix
of native grasses and wildflowers as well as native trees and shrubs to provide permanent and
natural bank stabilization.
2. Any erosion control matting used should 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.
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: John Vilas, McGill Associates
Kevin Mitchell, NC Division of Water Resources