20030832 Ver 3_WRC Comments_20180831

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
August 31, 2018
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Biltmore Forest Country Club Stream Enhancement
Brown Branch, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 1,920 feet of Brown Branch in Buncombe County. Staff visited the site
on August 27, 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).
Project activities should not impact wild trout reproduction, and work does not need to be
avoided during a trout moratorium.
The project would entail stabilizing a section of Brown Branch in place that is eroding and
incised and has little to no woody riparian vegetation along much of its length. Much of the
existing boulder armoring and rock walls would remain, although some of the boulder material
would be incorporated into instream structures. Geolifts, coir fiber blocks, instream vanes and
bank sloping will be used throughout the design. The design involves planting a narrow native
woody buffer with livestakes from the stream edge to the top of bank. Woody vegetation would
be maintained at a maximum height of 3-4 ft.
A forested riparian buffer is essential in maintaining long-term stability of the project. A wide
forested buffer can ensure greater bank stability, filter overland pollutants, and provide habitat
for birds and other wildlife. The uppermost portion of the project does not involve any riparian
planting; the right bank is currently grassed, and we recommend planting a woody buffer as wide
as infrastructure allows to maintain stability. We also recommend extending the width of the
planted buffer as far as possible throughout the project. Maintenance of the buffer should be
done carefully, ensuring that it is not cut lower than 2 ft and allowed to grow up to 3-4 ft.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Biltmore Forest Country Club Page 2 August 31, 2018
Brown Br, Buncombe County
Additional woody plants that could be incorporated into the planting plan include Tag Alder,
Winter Berry, Spicebush, and Ninebark, among others.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
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. 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.
3. As described above, we recommend expanding the planted woody riparian buffer as much as
infrastructure allows throughout the site. Maintenance of the buffer should be done
carefully, cutting vegetation to a height no less than 2 ft.
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 Streambanks
ec: Zan Price, NC Division of Water Resources
Ronnie Dilbeck, Creekstone