20180896 Ver 1_WRC Comments_20180605

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
June 5, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Cheoah River RM 5.1 River Access
Cheoah River, Graham County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to construct a parking lot and boat launch access ramp on the Cheoah River,
impacting 50 ft of river in Graham 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).
This project should not affect trout and the activities do not need to be avoided during the trout
spawning moratorium. However, numerous rare and listed species are found in this portion of
the Cheoah River, including Appalachian Elktoe (Alasmidonta raveneliana, US and NC
Endangered), Spotfin Chub [Erimonax monachus, US and NC Threatened (T)], Virginia Spiraea
(Spiraea virginiana, US and NC T), Junaluska Salamander (Eurycea junaluska, US Federal
Species of Concern (FSC), NC T), Wavyrayed Lampmussel [Lampsilis fasciola, NC Special
Concern (SC)], and Wounded Darter (Etheostoma vulneratum, US FSC, NC SC]. The project is
within two NC Natural Heritage Program natural areas—the Cheoah River Floodplain (rated
Exceptional) and the Cheoah River Aquatic Habitat (rated Very High).
The project involves the construction of a parking area of up to 9 spaces, a hardened area for
toilets, and a concrete access launch with a retaining wall. The concrete slab will be poured in
place. The launch will be placed above the baseflow water level and will not come in contact
with the stream bottom. Two rain gardens will treat stormwater from the site, which will be
discharged to the Cheoah River over a Class B riprap apron.
There are multiple older records of Junaluska Salamander in the vicinity of the project, and we
are concerned about direct impacts to this rare species. We recommend that both visual night
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Cheoah R RM 5.1 Access Page 2 June 5, 2018
Cheoah R, Graham Co
surveys and snorkel surveys be conducted in the project area before any tree clearing and ground
disturbance occurs. Please coordinate with NCWRC biologist Lori Williams
(lori.williamskncwildlife.org) about these surveys. In addition, the site should be surveyed for
Virginia Spiraea before the project begins; these surveys should be conducted in coordination
with the US Fish and Wildlife Service.
We offer the following recommendations to minimize impacts to aquatic and terrestrial wildlife
resources:
I. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
Disturbed areas should be seeded, mulched and/or matted as soon as possible, at least at the
end of each work day.
2. Any erosion control matting used should be free of nylon or polypropylene mesh, as this
frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last for
years.
3. Concrete must be poured in the dry and allowed to cure at least 24 hours in order to avoid
toxic pH levels in the contact water.
4. Minimize the footprint of disturbance within the riparian area, avoiding the removal of
riparian vegetation as much as possible when mobilizing equipment and during construction.
If needed, replant the disturbed area with native riparian trees, shrubs, forbs, and grasses.
5. Surveys for Junaluska Salamander and Virginia Spiraea should be conducted before the
project commences.
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: Barry Jones, USFS
Kevin Mitchell, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Lori Williams, NCWRC