20230774 Ver 1_WRC Comments_20230620

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
June 20, 2023
Mr. Mitchell Anderson
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: NCNG North Wilkesboro Readiness Center Renovation
UT to Yadkin River, Wilkes County
Dear Mr. Anderson:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 477 ft of an unnamed tributary (UT) to the Yadkin River in Wilkes
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.
The application proposes to stabilize an eroding reach of stream by installing constructed riffles,
rock toe, sloping stream banks, and planting a buffer. Work will be done 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 should be stabilized at the end of each work day.
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. The "rock toe" appears to be riprap piled on the stream banks. We recommend against using
riprap as bank stabilization. Instead, we recommend a bioengineering approach, such as
geolifts.
4. The planted buffer width appears to be 5-20 ft. 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
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

NCNG N Wilkesboro Readiness Center Page 2 June 20, 2023
UT Yadkin R, Wilkes Co
ensure project success. A wide forested buffer can ensure greater bank stability, filter
overland pollutants, and provide habitat for birds and other wildlife.
5. The stream runs through a narrow forested buffer. Live tree clearing should be minimized as
much as possible.
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: Kate Heftier, Timmons Group
Seren Homer, NC Division of Water Resources