AppleValleyGolfCourseStreamStabilization_BillsCr_Rutherford_NCWRCComments

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]
September 23, 2022

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

SUBJECT: Apple Valley Golf Course Stream Stabilization
Bills Creek, Rutherford County

Dear Ms. Boggs:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 296 ft of Bills Creek in Rutherford 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 reproduction should not be impacted by the project, and a trout moratorium is not
required. However, two rare crayfish are found in Bills Creek – Broad River Stream Crayfish
[Cambarus lenati, NC Significantly Rare (SR)] and Carolina Foothills Crayfish (Cambarus
johni, NC SR). Effective erosion and sediment control are needed on this project to minimize
impacts to these species.

The application proposes to stabilize an eroding reach of stream by regrading the stream banks
and armoring them with riprap. Erosion control matting would be placed behind the riprap, and
we recommend replacing that with filter cloth, keeping biodegradable matting on the slope above
the riprap.

It appears that vegetation along the stream banks has been heavily maintained in the project
reach and throughout the property. The lack of woody riparian vegetation is likely a major driver
for the stream bank instability on Bills Creek. The proposed stabilization scheme does not
involve the planting of a shrubs or trees; armoring banks as proposed will likely only provide a
short-term solution to bank erosion. We strongly recommend that the applicant use
bioengineering methods, such as geolifts and native woody plantings, to ensure the long-term
stability of the project and benefit both aquatic and terrestrial wildlife. Incorporating live
Apple Valley Golf Course Stabilization Page 2 September 23, 2022
Bills Cr, Rutherford Co
stakes/woody vegetation will provide much more insurance against erosion and benefits to the
stream such as shading and habitat. We strongly recommend that the landowners plant a woody
buffer on the entire reach – even 10 ft outward from the top of bank, maintained at a height of 3-
5 ft would provide more protection.

We offer the following recommendations for the project to minimize impacts to fish and wildlife
resources:
1. 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 matted as soon as possible, preferably at the end of each work day.
2. Instream work should be performed during low flows. Work should be done from the top of
the bank, and flows should be diverted around the work area, as described.
3. 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.
4. We recommend modifying the design to incorporate bioengineering methods instead of bank
armoring. Native woody plantings should be incorporated to achieve a buffer as wide as
infrastructure and existing land uses allow in order to ensure project success. Native trees,
shrubs, grasses, and wildlflowers should be planted.

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: McKenzie Beyer, ClearWater
Mitchell Anderson, NC Division of Water Resources