20180292 Ver 1_WRC Comments_20180319

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
March 19, 2018
Mr. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Private Driveway — Jason Green
UT Winkler Creek, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to impact 40 ft of an unnamed tributary (UT) to Winkler Creek and 0.07 acre of
wetland with culverts and fill associated with the construction of a driveway 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).
There are Brown Trout in the vicinity of the project, and any instream activities much be avoided
during the trout moratorium of October 15 to April 15. Wild trout are especially sensitive to
excess sediment, and it is extremely important to practice good sediment and erosion control
during project construction.
The project will involve the construction of a driveway that will cross three wetlands and the UT
to Winkler Creek. Culvert design for UT to Winkler Creek includes a 4 -ft diameter culvert for
baseflows and an additional 3 -ft diameter culvert for higher flows, set at a higher elevation. We
support the use of higher elevation culverts as `floodplain' culverts, such as this one.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
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 matted as soon as possible, preferably at the end of each work day.
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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Jason Green Private Driveway Page 2 March 19, 2018
UT Winkler Cr, Watauga Co
3. Instream work should be avoided between October 15 and April 15 to minimize impacts to
Rainbow Trout spawning.
4. The application does not specify culvert material. We recommend against using smooth-
walled HDPE material for culverts, as this slick material is less likely to hold stream
substrate and provide for movement of aquatic organisms like fish and salamanders.
5. The culverts should be buried at least 20% to allow stream and wetland substrate to be
maintained in the culverts and assist in free movement of aquatic and wetland animals, such
as fish and salamanders.
6. Removal of riparian vegetation along streams should be avoided as much as possible outside
of the impact areas. Plant native trees, shrubs, grasses, and wildlflowers wherever possible to
achieve a forested riparian buffer. Please refer to NC State's "Small-scale Solutions to
Eroding Stream Banks" (attached) for planting recommendations.
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
Attachment: Small-scale Solutions to Eroding Stream Banks
ec: Jason Green, landowner
Sue Homewood, NC Division of Water Resources