20180418 Ver 1_WRC Comments_20190510

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
May 10, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Lady Marion Dam Dewatering
UT Catawba River, McDowell County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to drain Lady Marion Lake and assess the reservoir drain, temporarily impacting 0.56
acre of wetland in McDowell County. This work is associated with an order by NC Department
of Environmental Quality to address concerns over this high hazard dam. 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).
The stream into which the lake drains is an unnamed tributary to the Catawba River which is
culverted for an unknown long reach. Wild trout should not be impacted by project activities and
a moratorium is not needed. The stream drains to a reach of the Catawba River that supports a
number of rare and listed species, including the Brook Floater [Alasmidonta varicosa, US
Federal Species of Concern (FSC), NC Endangered], Notched Rainbow (Villosa constricta, US
FSC, NC Threatened), Seagreen Darter [Etheostoma thalassinum, NC Significantly Rare (SR)],
and Carolina Foothills Crayfish (Cambarus johni, NC SR). To protect these species, it is
especially important to use good erosion and sediment control on the project.
We offer the following recommendations to minimize impacts to fish and wildlife:
1. Project activities should be accomplished as quickly as possible and vigilance used in
sediment and erosion control during site preparation, construction, and clean up.
2. Disturbed areas should be seeded, mulched and/or matted as soon as possible. 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]

Lady Marion Dam Dewatering Page 2 May 10, 2019
UT to Catawba R, McDowell County
3. If any concrete is used for repairs, concrete should be poured and allowed to cure away from
water at least 24 hours in order to avoid dangerous pH levels in streams.
4. Efforts should be made to minimize turbidity in outflows from the lake. We recommend that
the applicant work with the NC Division of Water Resources to develop measures to achieve
low turbidity in outflows.
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: Joey Lawler, S&ME
Amy Annino, NC Division of Water Resources