20180770 Ver 1_WRC Comments_20180703

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
June 30, 2018

Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Farmer Site Stream Restoration Project
Scott Creek, Jackson County

Dear Mr. Brown:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 3,351 ft of Scott Creek 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).

There is a robust population of wild Rainbow Trout in Scott Creek, and in-stream work should
be avoided during the trout moratorium of January 1 to April 15 to minimize impacts to trout
spawning.

We support this project, as it should address bank erosion and reduce instream sediment. The
application proposes to stabilize streambanks and improve habitat and bedform diversity with a
combination of bank sloping, in-stream structures, geolifts, boulder toes, and planting native
woody and herbaceous vegetation. Work areas will be stabilized each day. Work will be done
from the bank and within the channel, and it will be performed in the wet due to the size of the
stream. To reduce sediment loss during structure placement (e.g., vanes, geolifts), we strongly
recommend that streamflows be diverted around work areas.

We offer the following recommendations to minimize impacts to the aquatic community:
1. In-stream activities should be avoided during the Rainbow trout moratorium of January 1 to
April 15.
2. 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
Farmer Site Page 2 June 30, 2018
Scott Creek, Jackson County
areas should be seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day.
3. 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.
4. Streamflows should be diverted around work areas for instream structure placement. Work
should also be performed during a period of low flows.
5. Riparian planting width is limited to 10 ft in many areas. 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,

Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program

ec: Jake Byers, Michael Baker Engineering
Kevin Mitchell, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Powell Wheeler, NCWRC