20230109 Ver 1_WRC Comments_20230207

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
February 7, 2023
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Terry Floyd Stream Restoration
Roan Creek, Ashe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 946 ft, install a ford on 12 ft, and temporarily impact 20 ft of Roan Creek
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).
Wild trout reproduction should not be impacted by project activities, and a trout moratorium is
not needed. However, the site is part of the South Fork New and New River Aquatic Habitat, a
NCNHP natural area rated Exceptional due to the richness and importance of rare species it
supports. These species include the Kanawha Shiner (Phenacobius teretulus, NC Special
Concern), Kanawha Darter (Etheostoma kanawhae, NC SR), Appalachia Darter (Percina
gymnocephala, NC SR), and Kanawha Rosyface Shiner (Notropis sp., NC SR). Excellent
sediment and erosion control are necessary to minimize impacts to this river and the rare species
it supports.
The application proposes to stabilize an eroding reach of stream by installing j-hooks and cross
vanes, sloping the stream bank, and planting a native riparian buffer of 10-25 ft in width. The in -
stream work will be performed in the dry.
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 will be stabilized at the end of each work day.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Terry Floyd Stream Restoration Page 2 February 7, 2023
Roan Cr, Ashe Co
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. It appears that an intact riparian buffer exists on the right bank, and disturbance and removal
of native vegetation should be minimized as much as possible.
4. The proposed planted buffer is only 10-25 ft in width. We 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.
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,
p
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Derek Goddard, BREC
Sue Homewood, NC Division of Water Resources