20220416 Ver 1_WRC Comments_20220411

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
April 11, 2022
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Rapoport Stream Restoration
UT to Hunting Creek, Wilkes County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 305 ft of an unnamed tributary (UT) to Hunting Creek in Wilkes County.
In addition, temporary impacts to 20 ft of stream for a pump around diversion are proposed. 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 project activities and a trout moratorium is
not needed.
The application proposes to stabilize an eroding reach of stream by sloping stream banks and
planting a buffer of 15 ft in width. The site will be stabilized at the end of each work day.
A pump -around is proposed for the project. As no instream work is proposed, we recommend
against a pump -around to avoid drying out the streambed. Instead, we recommend carefully
grading the stream bank, and placing a barrier at the toe of the bank, such as silt fence, to ensure
that soil isn't lost to the stream.
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. We
appreciate that disturbed areas will be stabilized at the end of each work day.
2. We recommend against using a pump -around for the project, instead insuring that sediment
loss to the stream is minimized with a barrier placed at the toe of the bank, as needed.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Rapoport Stream Restoration Page 2 April 11, 2022
UT Hunting Cr, Wilkes Co
3. 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.
4. The planted buffer is proposed to be an average of 15 ft in width. We strongly recommend
that a woody buffer of at least 30 feet be planted on both sides of 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.
5. Minimize any live tree clearing.
6. Eastern Hemlock is included in the planting plan; we recommend removing this species due
to pests that are causing widespread mortality of this species and replacing it with additional
species. In addition, Black Gum is included, which is an upland species — it is appropriate if
planted in an upland setting only.
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: Derek Goddard, BREC
Sue Homewood, NC Division of Water Resources