20200958 Ver 1_WRC Comments_20200824

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
August 24, 2020

Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: South Fork New River Streambank Stabilization Project
South Fork New River, Watauga County

Dear Ms. Fuemmeler:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 1,950 ft of the South Fork of the New River in Watauga County. This
project is the second phase of a restoration project that was permitted in 2018 on the Teddy
Mackeroll soccer fields. 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. However, the South Fork New River is part of the South Fork New River Aquatic
Habitat, a natural area rated Exceptional by the NC Natural Heritage Program due to the
extraordinary diversity of rare species it supports. Rare and listed species within the vicinity of
the project include the Kanawha Minnow [Phenacobius teretulus, US Federal Species of
Concern (FSC), NC Special Concern (SC)], Tonguetied Minnow [Exoglossum laurae, NC
Significantly Rare (SR)], Kanawha Rosyface Shiner (Notropis sp., NC SR), and Kanawha Darter
(Etheostoma kanawhae, NC SR).

The application proposes to stabilize an eroding reach of bank through sloping the bank, creating
a bankfull bench, installing instream structures, and planting native woody and herbaceous
vegetation of generally 50 ft in width. Work will be done from the bank, except where instream
access is necessary to install instream structures. According to Josselyn Lucas, deflection rocks
will be used to divert direct flows from instream work areas. Work areas will be stabilized each
day. We support this project, as it should address bank erosion and reduce instream sediment.

S Fork New River Restoration Page 2 August 24, 2020
S Fork New R, Watauga Co
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. 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.
3. Sambucus nigra is on the planting list. This is European elderberry, and this should be
replaced with the native elderberry, Sambucus canadensis.

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
Byron Hamstead, US Fish and Wildlife Service
Kin Hodges, NCWRC