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HomeMy WebLinkAbout20190905 Ver 1_WRC Comments_201908139 North Carolina Wildlife Resources Commission 0 Gordon Myers, Executive Director August 13, 2019 Ms. Amanda Fuemmeler U.S. Army Corps of Engineers, Regulatory Branch 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 SUBJECT: Sam Storey Stream Restoration Skalley Branch, Avery County Dear Ms. Fuemmeler: Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an application to restore 1010 ft of Skalley Branch in Watauga County. In addition, temporary impacts to 0.08 acre of wetland for equipment access and 20 ft of Skalley Branch for a pump around are proposed. I attended an agency site visit on August 12, 2019. 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). Rainbow Trout may be impacted by the project, and in -stream activities should be avoided between January 1 and April 15 to minimize impacts to trout reproduction. Effective erosion and sediment control on this project is essential in conserving this species. The application proposes to stabilize an eroding reach of Skalley Branch by removing existing in -stream meanders and installing a dense set (approximately 1 structure every 40 ft) of rock cross vanes and rock j -hooks. According to Derek Goddard, log structures may also be used. Banks will be graded and a native riparian buffer of 10-25 ft will be planted on the left bank. The restored channel will run close to the existing road, and the riparian buffer width on the right bank (the road side) will be less than 10-25 ft in width. Work will be done in the dry. We recommend that the design pull the stream further away from the road wherever possible in order to allow a wider riparian buffer on the right bank. In addition, we recommend a less invasive project design so that fewer in -stream structures are needed and some meander is maintained. Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Sam Storey Stream Restoration Page 2 August 13, 2019 Skalley Br, Watauga County 0.08 acre of wetland would be impacted 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 January 1 and April 15 to minimize impacts to Rainbow 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. 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. Soften the project design so that fewer in -stream structures are needed, more meanders are maintained, and the stream channel is farther away from the road. 5. Efforts should be made to retain as many existing trees within the riparian area as possible. 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 (828) 803-6054 if you have any questions about these comments. Sincerely, Andrea Leslie Mountain Region Coordinator, Habitat Conservation Program ec: Derek Goddard, BREC Andrew Moore, NC Division of Water Resources