20171630 Ver 1_WRC Comments_20180629

0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
June 29, 2018
Mr. William Elliott
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: North Wilkesboro Sewer Improvements
UTs to Fishing Creek and wetlands, Wilkes County
Dear Mr. Elliott:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed a revised
application to impact 12 wetlands, entailing 0.25 acre of permanent and 0.48 acre of temporary
impacts, as impact 12 stream sites, entailing 239 ft of temporary impact, all for a sewer extension
project in Wilkes 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 will not impact wild trout, and project activities do not need to be avoided during a
trout moratorium. However, the project area is near known locations of Bog Turtle (Glyptemis
muhlenbergii, US Threatened due to Similarity of Appearance, NC Threatened), and efforts should be
taken to minimize impacts to habitat for this species.
The sewer line will be installed with a combination of trench cut, jack and bore, and aerial crossings.
Trench cuts through streams will be performed in the dry, and design plans show the use of riprap on
the banks. We encourage bank sloping and the use of matting and native vegetation as an alternative
to riprap if at all possible.
Wetland W5 appears to contain suitable habitat for Bog Turtle, especially within its muddy ruts, and
Carolina Ecosystems, Inc. staff will be on site during sewer line placement at the site to ensure no
turtles are harmed during installation. NCWRC recommends the following practices within Wetland
W5: (1) mark the construction corridor clearly in the wetland, fencing/taping the non -impact area and
ensuring construction equipment will be kept out of this area, all other parts of the wetland out so that
the construction crew will stay out of it, (2) use mud mats for equipment in the wetland (and all other
wetlands to be impacted), and (3) if work is done in the muddy ruts, a qualified biologist should
survey the muddy ruts for turtles; this person should be on-site while the crew digs through the ruts,
so that s/he can sort through the spoil for animals.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

N Wilkesboro Sewer Improvements Page 2 June 29, 2018
UTs Fishing Cr, Wilkes Co
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Avoid equipment maintenance in the immediate vicinity of streams and wetlands, make stream
crossings as narrow as possible, minimize stream bank disturbance, avoid spraying of herbicides,
and where woody vegetation is cleared, cut so that stumps can resprout.
2. Sediment and erosion controls measures should be installed prior to any land clearing or
construction. These measures should be routinely inspected and properly maintained. Excessive
silt and sediment loads can have numerous detrimental effects on aquatic resources including
destruction of spawning habitat, suffocation of eggs, and clogging of gills of aquatic species.
3. Work performed in wetlands should be done from wetland mats to minimize compaction.
4. Wetland topsoil should be set aside during trenching for replacement afterwards and the wetland
and be replanted with a native wetland seed mix. For forested wetlands, any area outside the
maintenance right-of-way (ROW) should be replanted with native woody species.
5. The top 6-12 inches of stream substrate should be stockpiled, kept saturated during pipe
installation, and replaced once the pipe is installed.
6. Minimize the use of riprap on the stream banks and instead stabilize banks with matting,
temporary seed, and a native riparian mix. We recommend that the native riparian mix also be
applied 50 ft landward from the stream.
7. Matting used for stabilization should be free of nylon or plastic mesh, as this type of netting
frequently entangles wildlife and is slow to degrade resulting in a hazard that may last for years.
8. The temporary planting specifications include Lespedeza, which is highly invasive and should be
avoided. For temporary seeding, NCWRC recommends an alternative mix of Red Clover,
Creeping Red Fescue, and a grain, such as Oats, Wheat, or Rye.
9. For permanent seeding of disturbed areas, a native riparian seed mix should be used for
streamside areas and a native wetland seed mix should be used for wetland areas. For permanent
seeding in riparian areas, we recommend a mix of native trees, shrubs, forbs, and grasses.
10. ROW maintenance on stream banks should be performed by hand, cutting woody vegetation to
allow resprouting. ROW maintenance through wetlands should also be done by hand, avoiding
the use of heavy machinery.
Thank you for the opportunity to review and comment on this project. Please contact me at (828)
803-6054 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: Chris Hopper, Carolina Ecosystems, Inc.
Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Gabrielle Graeter, NCWRC