HomeMy WebLinkAbout20170998 Ver 1_WRC Comments_20170905El 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: Eric Green Stream Restoration
Stoney Fork, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 1235 feet of Stoney Fork 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 trout reproduction and do not need to be avoided during the
trout moratorium.
The project involves in -stream structures (log j -hooks, rock cross vanes) and planting. A new
riparian buffer will be planted. The application requests to construct the project in the wet. We
are concerned about the overuse of instream structures in the design; rock cross vanes and log j -
hooks are extremely dense across 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.
The drainage area at the location is less than one square mile, and as the number of in -stream
structures is so high, this project will likely cause a considerable amount of in -stream
sedimentation. We recommend that this project proceed in the dry.
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: (919) 707-0220 • Fax: (919) 707-0028
Eric Green Stream Restoration
Stoney Fork, Watauga County
September 5, 2017
2. The project should be constructed in the dry. If not, measures to reduce the risk of fine
sediment liberation and loss should be employed, such as diverting the thalweg around the
work areas.
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. 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.
6. 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
(828) 558-6011 if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Derek Goddard, Blue Ridge Environmental Consultants
Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service