20201968 Ver 1_WRC Comments_20211026

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
October 25, 2021

Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Broad River Paddle Access – 221 Site
Broad River, Rutherford County

Dear Ms. Boggs:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to construct a kayak access on the Broad River, impacting 47 ft of the river. 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).

This project should not affect trout and the activities do not need to be avoided during the trout
spawning moratorium. However, a rare species is found in the river in the vicinity of the project
– Seagreen Darter (Etheostoma thalassinum, NC Significantly Rare). Due to the sensitivity of
this species to fine sediments, it is important that excellent erosion and sediment control be
maintained during the project.

The project involves the construction of a parking area, trail, riprap/vegetated swale, and kayak
launch. The launch would be a set of stairs to the river and a concrete slab that would run 41 ft
along the river bank and jut out 13 ft into the river from bankfull. An infiltration swale would be
used to treat stormwater from the parking and turn-around areas. According to the plans,
disturbed areas would be stabilized at the end of each day.

We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
Disturbed areas should be seeded, mulched and/or matted as soon as possible, and we
appreciate that disturbed areas will be stabilized at the end of each day.
Broad River Paddle Access – 221 Site Page 2 October 25, 2021
Broad River, Rutherford Co.
2. 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.
3. We assume that the concrete slab will be formed and pushed into place. The contractor must
assure that the concrete is adequately cured in the dry and reinforced so that it can be pushed
without damage to its final location.
4. If woody vegetation is cleared in the riparian area, we recommend replanting the disturbed
buffer area with native trees and shrubs where possible.
5. Avoid the use of Tall Fescue and Sericea Lespedeza in the temporary or permanent seed mix.
Plant a permanent native riparian seed mix on the disturbed banks.

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: Josselyn Lucas, Brushy Fork Engineering
Mitchell Anderson, NC Division of Water Resources