20221271 Ver 1_WRC Comments_20221018

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]
October 18, 2022

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

SUBJECT: Sugar Mountain #1 Restoration Project
North Toe River, Avery County

Dear Ms. Fuemmeler:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 2,007 ft of the North Toe River and temporarily impact 0.018 acre of
wetland 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 Brook Trout, Brown Trout, and Rainbow Trout in the project vicinity, and in-
stream work should be avoided during the October 15 to April 15 reproduction season to
minimize impacts to these species. These species are especially sensitive to excess sediment,
and it is important to use excellent erosion and sediment control on the project.

The application proposes to address unstable reaches of channel by installing a bankfull bench
and a series of in-stream structures including j-hooks, cross vanes, root wads, toewood, rock
steps, and boulder revetments. Work will be done in the dry. It is unknown how wide the
planted woody buffer will be or what species will be planted. We strongly recommend that a
native riparian buffer of at least 30 ft in width be established and maintained.

We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
We appreciate that disturbed areas will be stabilized at the end of each day.
2. In-stream work should be avoided between October 15 and April 15 to minimize impacts to
wild trout.
3. Given that the North Toe River on the project site has a robust wild trout population, we
recommend that the construction crew rescue stranded animals with nets and buckets when
Sugar Mountain #1 Project Page 2 October 18, 2022
N. Toe R, Avery Co.
flows are diverted around work areas. Animals should be captured and relocated downstream
of the work area.
4. 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.
5. We ask the designer to provide a planting list for the project. The plans include a list of
species that may be used, which includes both Black Walnut and River Birch, which should
not be planted on this site. Black Walnut has allelopathic properties and can set back growth
and survival of other species, and River Birch is typically only found on lower elevation
rivers associated with large floodplains in the mountains.
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.
7. The streams run through a forested riparian buffer; minimize disturbance to native trees and
shrubs.
8. Any heavy equipment that accesses wetland areas should be placed on temporary mud mats.
Disturbed wetland areas should be reseeded with native wetland seed.

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: Susan Cragg and Adam Williams, Brushy Fork Environmental
Joey Winston, NC Division of Water Resources
David Goodfred, NCWRC