20190446 Ver 2_WRC Comments_20210903

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]
September 3, 2021

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

SUBJECT: Hyman Riverbank Stabilization #2
Elk River, Avery County

Dear Ms. Fuemmeler:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 170 feet of streambank on the Elk River in Avery 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).

There are wild Rainbow Trout and Brown Trout in the vicinity of the project, and project
activities should be avoided between October 15 and April 15 to minimize impact to trout
reproduction.

The applicant proposes to place a boulder two on the eroding section of bank, slope the bank at a
3:1 slope, and mat and seed the bank with native vegetation. We appreciate the use of native
seed and a natural fiber matting. However, without the backup of native woody vegetation on
the slopes and top of the bank, this section of bank will be more vulnerable to erosion in the
future. We encourage the applicant to use native shrubs and trees to further stabilize the bank
and provide shade for the Elk River.

We offer the following recommendations to minimize impacts to the aquatic community:
1. Work should be avoided during the trout moratorium of October 15 to April 15.
2. 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.
3. Work should be performed from the top of the bank during low flows. Stream flows should
be diverted away from the work area.
Hyman Riverbank Stabilization #2 Page 2 September 3, 2021
Elk R, Avery Co.
4. We recommend that the project incorporate as many native trees and shrubs as possible for
the project. For planting recommendations, please see NC Cooperative Extension’s guide on
small-scale solutions to eroding stream banks, 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

Attachment: Small-scale Solutions to Eroding Stream Banks

ec: Jonathan Hyman, landowner
Mitchell Anderson, NC Division of Water Resources
Chris Wood, NCWRC