20190802 Ver 1_WRC Comments_20190712

n North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
July 12, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Ed Liddle Stream Restoration
Roan Creek - Ashe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 906 ft of Roan Creek in Ashe County. In addition, a 20 -ft wide ford will
be constructed in the restoration reach, and temporary impacts to 0.09 acre of wetland,
presumably for equipment access, are proposed as well. 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).
Brown Trout may be impacted by the project, and in -stream activities should be avoided between
October 15 and April 15 to minimize impacts to trout reproduction. The project site is upstream
of the South Fork New River Aquatic Habitat, a natural area rated Exceptional by the NC Natural
Heritage Program due to the richness of rare species it supports. Rare and listed species found in
the vicinity of the project include three fishes endemic to the New River basin—Kanawha
Minnow (Phenacobius teretulus, NC SC, US FSC), Kanawha Rosyface Shiner [Notropis sp., NC
Significantly Rare (SR)], and Kanawha Darter (Etheostoma kanawhae, NC SR). Effective
erosion and sediment control on this project is essential to conserving these species.
The application proposes to stabilize an eroding reach of Roan Creek by restoring the dimension,
pattern, and profile to the channels. Restoration generally involves bank grading, in -stream
structures (rock cross vanes and rock j -hooks), and native riparian planting of a buffer of at least
10 ft in width. According to Derek Goddard, work will be done in the wet. In addition, trees on
the right bank of the downstream end of the project will be trimmed.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Ed Liddle Stream Restoration Page 2 July 12, 2019
Roan Creek, Ashe County
0.09 acre of wetland would be impacted, presumably for equipment access. These wetlands will
be reseeded with a native wetland mix. We recommend that wetland impacts be avoided
wherever possible and timber mats be used where equipment will access wetlands to minimize
soil compaction.
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -stream activities should be avoided between October 15 and April 15 to minimize impacts
to Brown Trout reproduction.
2. 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.
3. We recommend diverting flows around the work areas especially at the bank tie in locations
to reduce the risk of fine sediment liberation and loss.
4. 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.
5. Efforts should be made to retain as many existing trees within the riparian area as possible,
and trimming of existing trees kept to a minimum.
6. We recommend that a woody buffer of at least 30 feet be planted on both sides of the stream
as infrastructure allows in order to ensure project success. A wide forested buffer can ensure
greater bank stability, filter overland pollutants, and provide habitat for birds and other
wildlife.
7. Wetland impacts should be minimized by avoiding them wherever possible. Where crossing
wetlands with equipment is necessary, it should be done with the use of mud mats to
minimize soil compaction.
8. We request that we be informed of project construction start and end dates so that we can
visit the site when it is underway.
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: Derek Goddard, BREC
Sue Homewood, NC Division of Water Resources