20190545 Ver 1_WRC Comments_20190426

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
April 26, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Scudder Project
South Fork New River, Alleghany County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 101 ft of the South Fork New River in Alleghany 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 wild trout and do not need to be avoided during the trout
moratorium. However, the South Fork New River is recognized by the NC Natural Heritage
Program as the South Fork New River Aquatic Habitat, rated Exceptional for the richness of rare
species it contains. Rare and listed species found in the river in the vicinity of the project include
two mussels—Green Floater [Lasmigona subviridis, US Federal Species of Concern (FSC), NC
Endangered] and Spike [Elliptio dilatata, US FSC, NC Special Concern (SC)]; a snail—Seep
Mudalia (Leptoxis dilatata, US FSC, NC SC); three fishes—Kanawha Minnow (Phenacobius
teretulus, NC SC), Kanawha Rosyface Shiner [Notropis sp., NC Significantly Rare (SR)], and
Mimic Shiner (Notropis volucellus, NC Threatened); and two large salamanders—the Common
Mudpuppy (Necturus maculosus, NC SC) and the Eastern Hellbender (Cryptobranchus
alleganiensis, NC SC, US FSC). Hellbenders are found throughout this reach of the South Fork
of the New River. These species are especially sensitive to sedimentation, and good erosion and
sediment control measure for this project are essential to protect these species.
The application proposes to stabilize an eroding reach of bank on the South Fork New River
through sloping the bank, planting native woody and herbaceous vegetation, and installing one
in -stream rock vane. Most work will be done from the bank, but some instream access may be
necessary for proper installation of the rock vane.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Scudder Project Page 2 April 26, 2019
South Fork New River, Alleghany County
NCWRC staff may survey for mussels and hellbenders in the project footprint before project
construction. We request that the applicant coordinate with Andrea Leslie
(andrea.leslie(d),ncwildlife.org) about the construction timeline, informing them of the
construction start date at least one month in advance.
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -channel 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. Any erosion control matting used should be free of nylon or plastic mesh, as this type of
mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that
may last for years.
3. For the rock vane installation, we recommend diverting flows around the work area
especially at the bank tie in locations to reduce the risk of fine sediment liberation and loss.
4. We request that project construction activities be avoided from September 1 to November 30
to avoid impacts to Eastern Hellbender breeding, nesting, and hatchling development.
5. Shelter rocks potentially used by Hellbenders should be left undisturbed during construction
activities. Shelter rocks are typically large flat rocks at least a foot in diameter. If animals
are disturbed during construction, they should be captured in a bucket and moved away from
the area of disturbance. Please notify Lori Williams (lori.williams(ancwildlife.org ) if
hellbenders are found.
6. We recommend that a woody buffer of at least 30 feet be planted on the stream banks as
infrastructure allows in order to ensure project success.
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: Glen Sullivan, Foggy Mountain Nursery
Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Luke Etchison and Lori Williams, NCWRC