20180142 Ver 1_WRC Comments_20180227

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
February 27, 2018
Mr. William Elliott
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: CC Hays Stream Restoration
UTs to Purlear Creek, Wilkes County
Dear Mr. Elliott:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 1,421 feet of two unnamed tributaries (UTs) to Purlear Creek in Wilkes
County. I corresponded with Derek Goddard and Justin Church about the project. 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 the installation of a large number of in -stream structures (log j -hooks, rock
cross vanes) and planting. According to Derek Goddard, the width of the new riparian buffer
will be 10 feet, sometimes wider. They have also agreed to construct the project in the dry, using
a pump -around setup. They will use Rye or Millet as temporary seed in the riparian area.
We are concerned about the potential 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. In addition, a buffer width of 10 feet is very narrow, leaving
the long-term success of the project at risk.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

CC Hays Stream Restoration
UTs Purlear Cr, Wilkes County
February 27, 2018
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.
2. The design should be reevaluated to determine if the number of structures can be reduced.
3. 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.
4. We recommend that a woody buffer of at least 30 feet be planted on both sides of the stream
as infrastructure allows to ensure project success. A wide forested buffer can ensure greater
bank stability, filter overland pollutants, and provide habitat for birds and other wildlife.
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, Blue Ridge Environmental Consultants
Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service