20191240 Ver 1_WRC Comments_20191001

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
October 1, 2019
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Maple Street/Merrill Street Improvements
UTs to Lovill Creek, Surry County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to temporarily impact 20 ft of unnamed tributaries (UTs) to Lovill Creek in Surry
County to replace a sewer line. 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).
Project activities should not impact wild trout and do not need to be avoided during the trout
moratorium.
The plans propose to cross streams via trench -cut. Streams would be restored to original
contours and the stream banks stabilized with riprap. We recommend against using riprap to
stabilize the banks and recommend that a native riparian seed mix and live stakes be used to
stabilize the banks. At least 6-8 inches of natural bed material should be placed on top of the
restored stream channel bed; this bed material should mimic that which is found in the stream
bed.
We offer the following recommendations to minimize impacts to fish and wildlife:
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. At least 6-8 inches of natural bed material should be placed on top of the restored stream
channel bed; this bed material should mimic that which is found in the stream bed.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Maple St/Merritt St Improvements Page 2 October 1, 2019
Surry County
3. A native riparian seed mix and live stakes should be used to permanently stabilize disturbed
stream areas instead of riprap.
4. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
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: Mitch Williams, Town of Mount Airy
Sue Homewood, NC Division of Water Resources