KaterinaRichterWhitmer_EagleFOrkCreek_Clay_NCWRCComments

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]
February 2, 2024

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

SUBJECT: Katerina Richter-Whitmer
Eagle Fork Creek, Clay County

Dear Ms. Healy:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
after-the-fact application accounting for riprap stabilization of 180 ft of Eagle Fork Creek in Clay
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 Rainbow Trout in Eagle Fork Creek, and activities should have been avoided
between January 1 and April 15 to avoid impacts to trout spawning.

The application describes using riprap to stabilize an eroding stream bank. Some scattered trees
have been left along the bank. We recommend against using riprap to stabilize a bank, as it is a
poor long-term solution to bank erosion, and a natural alternative such as bank grading and
planting as many native shrubs and trees as possible on the slope as well as the top of the bank
can provide long-term bank stabilization, keep water temperatures cool, and provide wildlife
habitat.

We recommend that the landowners supplement the limited riparian buffer with as many native
trees and shrubs as possible; we recommend planting at least a 30 ft wide buffer on both sides of
the stream. 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.

Katerina Richter-Whitmer Page 2 February 1, 2024
Eagle Fork Creek, Clay Co
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

Attachments: Small-scale Solutions to Eroding Stream Banks
NCSU mountain riparian species list

ec: Kathy Richter, landowner
Joey Winston, NC Division of Water Resources