20181448 Ver 1_WRCComments_20181130

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
November 14, 2018
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Reece Bank Stabilization
Watauga River, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 75 ft of the Watauga River in Watauga 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 should not be impacted by project activities and a trout moratorium is not needed for
this project. However, Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species
of Concern, NC Special Concern) is found in the project vicinity.
The application proposes to stabilize an eroding reach of stream by bank sloping at 2:1, placing
boulders on the bank, and planting livestakes. From the plan set provided, it appears that the
boulders will be placed the bank, on top of compacted fill and geotextile. We recommend that
the boulders be keyed into the bank to ensure more stability. In order to minimize sediment loss
from the project area, we recommend that stream flows will be diverted around the work area.
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 seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day.
2. The work area should be isolated from stream flows with the use of a coffer dam or other
diversion device.
3. The boulders should be keyed into the bank.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Reece Bank Stabilization Page 2 November 14, 2018
Watauga R, Watauga County
4. 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.
5. We recommend that a woody buffer of at least 30 feet be planted on the Watauga River 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,
zo"�J' d�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Derek Goddard, BREC
Sue Homewood, NC Division of Water Resources