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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