20191109 Ver 1_WRC Comments_20190823

❑ North Carolina Wildlife Resources Commission ❑
Gordon Myers, Executive Director
August 23, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Linville Creek Stabilization — Shipley Site
Linville Creek and UT, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 3,130 ft of Linville Creek and an unnamed tributary (UT) in Watauga
County. Temporary impacts to 0.006 acre of wetland are proposed for equipment access, 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 are in the vicinity of the project, and in -channel activities should be avoided
between October 15 and April 15 to minimize impacts to trout reproduction.
The application proposes to stabilize the streams with in -stream structures including cross vanes,
j -hooks, rock steps, and toe wads, creating a bankfull bench, bank sloping, and planting native
woody and herbaceous vegetation. According to Adam Williams, the width of the planted buffer
in areas where there is not an existing forested riparian area will be 10-15 ft. Cattle will be
fenced out of the streams. Two undersized culverts will be replaced with larger culverts, three
fords will be repaired or replaced, and another ford will be installed. Work will be done in the
wet, with most work done from the bank, except where in -stream access is necessary to install
instream structures. Stream flows will be temporarily diverted from in -channel work areas.
Work areas will be stabilized each day. We support this project, as it should address bank erosion
and reduce instream sediment.
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -stream project work should be avoided between October 15 and April 15 to minimize
impacts to Brown Trout reproduction.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Linville Cr - Shipley Page 2 August 23, 2019
Linville Cr & UT, Watauga County
2. The application notes that disturbed areas will be matted at the end of each work day. 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.
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. 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.
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: Adam Williams, Brushy Fork Environmental Consulting
Sue Homewood, NC Division of Water Resources