20201356 Ver 1_WRC Comments_20201015

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� North Carolina Wildlife Resources Commission IQ
Cameron Ingram, Executive Director
October 15, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Tuckasegee River Erosion Control Project
Tuckasegee River, Swain County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 200 feet of streambank on the Tuckasegee River in Swain County. I
visited the site in 2015, and I spoke with Dale Nolan on October 15, 2020 about the project. 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).
Wild trout reproduction should not be impacted by the project, and a trout moratorium is not
needed. However, the Tuckasegee River is part of the Tuckasegee 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 in the river in the project vicinity include
Appalachian Elktoe (Alasmidonta raveneliana, US and NC Endangered), Sicklefin Redhorse
(Moxostoma sp., NC Threatened), Wounded Darter [Etheostoma vulneratum, US Federal Species
of Concern (FSC), NC Special Concern (SC)], Olive Darter (Percina squamata, US FSC, NC
SC), Little Tennessee Crayfish (Cambarus georgiae, US FSC, NC SC), Highland Shiner
[Notropis micropteryx, NC Significantly Rare (SR)], Smallmouth Redhorse (Moxostoma
breviceps, NC SR), and Tuckasegee Stream Crayfish (Cambarus tuckasegee, US FSC, NC SR).
Effective sediment and erosion control are extremely important on this project to minimize
impacts to this aquatic community.
The application proposes to stabilize the left descending bank of the Tuckasegee River by
placing large stacked rock at the toe up to the top of the stream bank, backing the rock with a
semi -permeable liner. Work will be done from the bank and at low flows.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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To minimize sediment loss from the project, the work area should be isolated from flows with
sand bags or other coffer dam material; silt fences could also be installed at the toe of the bank if
this would effectively retain sediment lost from the bank.
According to Dale Nolan, the landowner has allowed vegetation to grow on the bank for several
years. We recommend incorporating as many native shrubs and trees as possible on the slope as
well as the top of the bank, as native woody vegetation will provide long-term bank stabilization,
keep water temperatures cool, and provide wildlife habitat.
We offer the following recommendations to minimize impacts to the aquatic community:
1. 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. Bank work should be performed during low flows, and the work area should be isolated from
the main channel with the use of sand bags, other coffer dam material, and/or silt fence.
3. Any erosion control matting used should be free of plastic or nylon 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. Since the endangered Appalachian Elktoe mussel is found in the Tuckasegee River, the
landowner/contractor should notify Luke Etchison (luke.etchisonkncwildlife.or and
Andrea Leslie(andrea.leslie(kncwildlife.org) at least 3 weeks before the project begins so
that mussel surveys and relocations can be performed if needed.
5. We recommend that the project incorporate as many native trees and shrubs as possible.
Incorporating native wildflowers and grasses is also recommended to provide better habitat
for wildlife such as birds and butterflies. For planting recommendations, please see NC
Cooperative Extension's guide on small-scale solutions to eroding stream banks and NC
State University's list of mountain riparian species, attached.
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
Attachments: Small-scale Solutions to Eroding Stream Banks
NCSU mountain riparian species list
ec: Beth Rose Miratsky, landowner
Dale Nolan, Rocks to Roses
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Luke Etchison, NCWRC

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