20190860 Ver 1_WRC comments_20190628

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
June 28, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Thompson's Branch
Mitchell River, Surry County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 200 feet of streambank on the Mitchell River (aka Thompsons Branch) in
Surry 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 and Brown Trout in the vicinity of the project, and project
activities should be avoided between October 15 and April 15 to minimize impact to trout
reproduction.
The applicant proposes to rebuild an eroding bank by installing toewood and root wads, and
building a bankfull bench that will be held in place with coir matting. The bank will be seeded
and planted with riparian vegetation. We appreciate the use of bioengineering to address bank
erosion; however, we are concerned that this solution may only be a short-term fix, and that the
bank will continue to erode with future storm events. We encourage the applicant to implement a
design that will consider stream hydrodynamics and direct flows away from the bank with
instream structures.
We offer the following recommendations to minimize impacts to the aquatic community:
1. Work should be avoided during the trout moratorium of October 15 to April 15.
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. Work should be performed during low flows.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Thompson's Branch Page 2 June 28, 2019
Mitchell River, Surry County
4. Work should be performed from the top of the bank if at all possible. Stream flows should
be diverted away from the work area so that work is done in as dry an area as possible.
5. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that
may last for years.
6. We recommend that the project incorporate as many native trees and shrubs as possible for
the project. For planting recommendations, please see NC Cooperative Extension's guide on
small-scale solutions to eroding stream banks, attached.
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
Attachment: Small-scale Solutions to Eroding Stream Banks
ec: Danny Layell, ACE Grading & Environmental
Sue Homewood, NC Division of Water Resources