20171022 Ver 1_WRC Comments_20170905

El North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
September 5, 2017
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Blue Ridge EMC's Rutherwood Substation Site
UT to Brown Branch, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 92 feet of an unnamed tributary (UT) to Brown Branch and fill 0.24 acre of
wetland in order to fill a site for the construction of an electrical substation 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).
Project activities should not impact wild trout, and activities do not need to be avoided during a
trout moratorium. However, the site is upstream of the South Fork New River and 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 Kanawha Minnow [Phenacobius teretulus, US Federal
Species of Concern (FSC), NC Special Concern (SC)], Tonguetied Minnow [Exoglossum laurae,
NC Significantly Rare (SR)], Kanawha Rosyface Shiner (Notropis sp., NC SR), and Kanawha
Darter (Etheostoma kanawhae, NC SR).
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.
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.
3. The seeding specifications include Tall Fescue and Sericea Lespedeza, both of which are
highly invasive and should be avoided. NCWRC recommends an alternative mix of Red
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Blue Ridge EMC Rutherwood Substation Page 2 September 5, 2017
UT Brown Br, Watauga County
Clover, Creeping Red Fescue, and a grain, such as Oats, Wheat, or Rye. Perennial native
grasses and wildflowers can be added to the seed mix to provide a more permanent
herbaceous cover.
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: Carson Dellinger, Environmental Resources of the Carolinas, Inc.
Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service