20181430 Ver 1_WRC Comments_20181128

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
November 28, 2018
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Margaret Pierce Stream Bank Stabilization
South Toe River, Yancey County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 74 feet of the South Toe River in Yancey County. I visited the site on
November 20, 2018. 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).
The application proposes to rebuild a rock wall on the left bank of the river. This wall is isolated
from the river at normal flows. An excavator would operate from a dry cobble point bar adjacent
to the bank. The excavator would cross approximately 40 fe of the wetted channel within a
backwater pool in order to access the point bar, and a coir log would be placed downstream of
this crossing area. Stream banks would be stabilized with a rock wall and the disturbed areas
planted with native herbaceous vegetation immediately after grading work is complete.
The South Toe River supports wild populations of Brown Trout and Rainbow Trout; however, as
this project involves stabilizing a bank adjacent to a home and minimal in -channel disturbance, a
moratorium will not be required. This portion of the South Toe River is part of the South Toe
River Aquatic Habitat, a natural area designated by the NC Natural Heritage Program and rated
Exceptional due to the richness of rare species it contains. In the vicinity of the project, the
South Toe River supports one of the best breeding populations of the Eastern Hellbender
(Cryptobranchus alleganiensis, US Federal Species of Concern, NC Special Concern) in the
state. Further downstream, the South Toe contains a diversity of rare and listed species,
including the federally endangered Appalachian Elktoe. Wild trout and these rare species are
especially sensitive to sediment, and special care should be taken to minimize sediment loss from
the project.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Margaret Pierce Stabilization Page 2 November 28, 2018
S Toe River, Yancey County
We offer the following recommendations to minimize impacts to the aquatic community:
1. Minimize equipment crossing in the wetted channel.
2. 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.
3. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
4. Work should be accomplished during low flows.
5. We recommend that native woody vegetation be incorporated into the planting plan. Trees
and shrubs 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: John Vilas, McGill Engineers
Andrew Moore, NC Division of Water Resources
David Goodfred, NCWRC
Allen Ratzlaff, US Fish and Wildlife Service