20190323 Ver 1_WRC Comments_20190412

❑ North Carolina Wildlife Resources Commission ❑
Gordon Myers, Executive Director
April 9, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: North Fork New River and Brush Fork Stabilization — Wilson Property
North Fork New River and Brush Fork, Ashe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 2,312 ft of the North Fork New River and 805 ft of Brush Fork in Ashe
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).
Brown Trout and possibly Brook Trout are in the vicinity of the project, and in -channel activities
should be avoided between April 15 and October 15 to minimize impacts to wild trout
reproduction. The North Fork of the New River is part of the North Fork New River Aquatic
Habitat, a NC Natural Heritage Program designated natural area, rated Very High due to the
richness of rare species it supports, including three fishes endemic to the New River basin —
Kanawha Rosyface Shiner [Notropis sp., NC Significantly Rare (SR)], Tongetied Minnow
(Exoglossum laurae, NC SR), and Kanawha Darter (Etheostoma kanawhae, NC SR). Brook
Trout and these rare species are especially sensitive to sedimentation, and effective erosion and
sediment management is very important on this project.
The application proposes to stabilize these stream reaches with in -stream structures including
cross vanes, j -hooks, and toe wood, creating a bankfull bench, bank sloping, and planting native
woody and herbaceous vegetation. Cattle will be fenced out of the streams. Most work will be
done from the bank, except where in -stream access is necessary to install instream structures.
Stream flows will be temporarily diverted from in -channel work areas. Work areas will be
stabilized each day. According to Adam Williams, the width of the planted buffer in areas where
there is not an existing forested riparian area will be a minimum of 15-20 ft. We support this
project, as it should address bank erosion and reduce instream sediment.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

N Fk New & Brush Fk - Wilson Page 2 April 9, 2019
N Fk New R & Brush Fk, Ashe County
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -stream project work should be avoided between October 15 and April 15 to minimize
impacts to Brown Trout and Brook Trout reproduction.
2. The application notes that disturbed areas will be matted at the end of each work day. 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.
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. 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: Adam Williams, Brushy Fork Environmental Consulting
Sue Homewood, NC Division of Water Resources
Thomas Johnson, NCWRC