20221001 Ver 1_Staff Report Annino, Amy M_20220802

® North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
August 18, 2022
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Metcalf Bank Stabilization
Tuckasegee River Jackson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application stabilize 119 ft of the Tuckasegee River in Jackson 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).
This project should not affect trout and the activities do not need to be avoided during the trout
spawning moratorium. However, this part of the Tuckasegee River is in the Tuckasegee River
Aquatic Habitat, a NC Natural Heritage Program natural area rated Exceptional due to the
richness of rare species it supports. 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)],
Eastern Hellbender (Cryptobranchus alleganiensis, US FSC, NC SC), Smoky Dace
(Chnostomus sp., NC SC), and French Broad River Crayfish (Cambarus reburrus, US FSC, NC
Significantly Rare) are found in the Tuckasegee River in the vicinity of the project. 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 project involves the placement of a stacked stone wall to stabilize the stream bank. Boulders
would be placed with a machine working from the bank. Flows should be diverted around the
work area with sand bags or other structures, and native trees and shrubs should be planted to
achieve a streamside buffer as wide as possible.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Metcalf Bank Stabilization Page 2 August 18, 2022
Tuckasegee R, Jackson Co
We strongly recommend a much more wildlife -friendly and less costly method of ensuring long-
term bank stability — sloping the banks and planting native shrubs and trees to achieve a forested
streamside zone.
We ask that the applicant reach out to Lori Williams (lori.williamskncwildlife.org) at least 3
weeks before construction begins, so that the area of impact may be surveyed for hellbenders.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
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. If rocks are used, bank work should be performed during low flows. Where work is
performed in the river, flows should be diverted around the work area with sand bags or other
coffer dam material.
3. Any erosion control matting used must 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. Protect as many trees and shrubs as possible.
5. We recommend that the project incorporate as many native trees and shrubs as possible,
whether the stone wall is placed or not. 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.
6. Contact Lori Williams (lori.williamsgncwildlife.org) at least 3 weeks before construction
begins.
Thank you for the opportunity to review and comment on this project. Please contact meat
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
Attachment: Small-scale Solutions to Eroding Streambanks
ec: Steve Metcalf, landowner
Amy Annino, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Lori Williams, NCWRC