20210005 Ver 1_WRC Comments_20210226

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]
February 26, 2021

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

SUBJECT: Aganad Project
South Fork New River, Ashe County

Dear Ms. Fuemmeler:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 122 ft of the South Fork New River in Ashe County. 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 recognized by the NC Natural Heritage
Program as the South Fork New River Aquatic Habitat, rated Exceptional for the richness of rare
species it contains. Rare and listed species found in the river in the vicinity of the project include
Green Floater [Lasmigona subviridis, US Federal Species of Concern (FSC), NC Endangered],
Eastern Hellbender (Cryptobranchus alleganiensis, US FSC, NC Special Concern), Spike
(Elliptio dilatata, NC SC), Seep Mudalia (Leptoxis dilatata, NC SC), Kanawha Minnow
(Phenacobius teretulus, NC SC), Kanawha Darter [Etheostoma kanawhae, NC Significantly
Rare (SR)]. Hellbenders have been documented from very near this location. Due to the
sensitivity of these species to fine sediments, it is essential that excellent erosion and sediment
control be maintained during the project.

The application proposes to stabilize an eroding reach of bank on the South Fork New River
through sloping the bank, planting native woody and herbaceous vegetation, and installing one
in-stream rock vane. Most work will be done from the bank, but some instream access may be
necessary for proper installation of the rock vane.

Aganad Project Page 2 February 26, 2021
S. Fork New R, Ashe County
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. For the rock vane installation, we recommend diverting flows around the work area in order
to reduce the risk of fine sediment liberation and loss.
4. Depending on the construction timeframe, NCWRC staff may come out to survey the site
before or after the project construction for rare animals. We ask that the project manager
coordinate with Andrea Leslie ([e-mail]) and Luke Etchison
([e-mail]) to ensure access to the site.
5. Shelter rocks potentially used by hellbenders should be left undisturbed during construction
activities. Shelter rocks are typically large flat rocks at least a foot in diameter. If animals
are disturbed during construction, they should be captured in a bucket and moved away from
the area of disturbance. Please notify Lori Williams ([e-mail]) if
hellbenders are found.
6. We recommend that a woody buffer as wide as possible (we recommend at least 30 feet) be
planted on 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: Glen Sullivan, Foggy Mountain Nursery
Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Lori Williams & Luke Etchison, NCWRC