20121081 Ver 2_WRC comments_20190611

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
June 11, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Middle Fork Greenway Phase 4
Middle Fork South Fork New River and unnamed tributaries, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 157 feet of the Middle Fork South Fork New River, culvert 43 ft of an
unnamed tributary (UT) to Elrod Br and UT to Middle Fork South Fork New River, and
temporarily impact another 60 ft of stream to construct a greenway 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 and Rainbow Trout in the vicinity of the project, and in -stream activities
should be avoided between October 15 and April 15 in order to minimize impacts to trout
reproduction. The site is within the South Fork New River Aquatic Habitat, a natural area
designated by the NC Natural Heritage Program and rated Exceptional due to the rich aquatic
community it supports, which includes the following rare species in the vicinity of the project:
Tonguetied Minnow [Exoglossum laurae, NC Significantly Rare (SR)], Kanawha Darter
(Etheostoma kanawhae, NC SR), and Kanawha Minnow (Phenacobius teretulus, NC SR).
Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species of Concern, NC Special
Concern) is likely present just downstream of the project area, as well. These rare species are
especially sensitive to sediment, and excellent erosion and sediment control is essential to
minimize impacts to these species.
Impacts are associated with the construction of a 4,275 -ft long 10 -ft wide gravel trail that runs
along the Middle Fork South Fork New River. The greenway is at least 25 ft away from the river
for approximately two-thirds of its length; in other areas, it is closer due to slope and ADA -
accessibility constraints. Five permanent stream crossings on tributaries to the Middle Fork are
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Middle Fk Greenway Phase 4 Page 2 June 11, 2019
Middle Fork SF New River, Watauga County
proposed, with 3 out of 5 being bridges and the remaining 2 being arch reinforced concrete pipe
culverts. A 157 -ft section of the Middle Fork would be stabilized using 2 j -hooks, boulder toe,
toe wood, bank sloping, and native planting. A temporary crossing on the Middle Fork is
proposed to carry construction materials for the stabilization. The thalweg will be diverted away
from work areas (toe wood, j -hook tie-in, and boulder toe areas) with a coffer dam.
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. Disturbed areas as a result of greenway construction should be stabilized as soon as possible
with straw and temporary seed; plans note that a native perennial seed mix will be applied as
well.
3. 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.
4. In -stream work should be avoided between October 15 and April 15 to minimize impacts to
wild trout.
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: Joe Furman, Watauga County Planning and Inspections
Carrie Caviness, Interface Environmental Consulting
Sue Homewood, NC Division of Water Resources
Kin Hodges and TJ Johnson, NCWRC
Byron Hamstead, US Fish and Wildlife Service