BufordRainesMiddleForkFrenchBroadRRestoration_Transylvania_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]
March 25, 2024

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

SUBJECT: Buford-Raines Tract Middle Fork French Broad River
Middle Fork French Broad River, Transylvania County

Dear Ms. Healy:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 1,250 ft of the Middle Fork French Broad River in Transylvania 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, and in-stream activities should be
avoided between October 15 and April 15 to minimize impacts to wild trout reproduction. In
addition, the Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species of Concern,
NC Special Concern), French Broad River Crayfish [Cambarus reburrus, NC Significantly Rare
(SR)], and Blotched Chub (Erimystax insignis, NC SR) are found in the project vicinity. These
species are especially sensitive to sedimentation, and effective erosion and sediment control
measures for this project are essential to protect these species.

The design features constructed riffles, log vanes, toewood, and habitat boulders. A new river
channel will be constructed for a substantial part of the reach, involving shifting the flows from
the existing channel into the new one. Where in-stream work is required, a gravel/cobble berm
will be used to shift flows around the work areas. Due to the possibility of hellbenders within the
reach, gravel/cobble should be harvested from dry bars for use as berms.

Due to the possibility of hellbenders in the project reach, NCWRC biologists may survey the site
before in-stream work begins. The project manager should inform Andrea Leslie
([e-mail]) and Lori Williams ([e-mail] of the
construction start date at least 3 weeks before construction.
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Middle Fork French Broad R, Transylvania Co
We offer the following recommendations to minimize impacts to the aquatic community:
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 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. Avoid in-channel work between October 15 to April 15 to minimize impacts to wild trout
reproduction.
4. Avoid disturbing large rocks as much as possible, as hellbenders can use them for shelters.
5. Work should be performed during low flows.
6. Cobble/gravel berm material should be harvested from dry bars, not from within the wetted
channel.
7. The project manager should inform Andrea Leslie ([e-mail]) and Lori
Williams ([e-mail] of the construction start date at least 3 weeks before
construction.
8. During construction, staff should watch for hellbenders. This is especially important in
reaches of the river that will be realigned. Construction in these reaches should be performed
so that animals can move with flows to the new channel. Staff should be staged to watch for
animals within the abandoned channel reaches. If hellbenders are seen in the impact areas,
they should be captured in a bucket with water and placed well upstream at a location to be
determined by NCWRC staff.
9. If hellbenders are seen, contact Lori Williams ([e-mail]) with this
information.
10. The planted buffer will be at least 25 ft in width; we recommend expanding this to at least 30
30 ft in width 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.
11. The planting plan includes River Birch, which should only be planted if this is found on site
or nearby.

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: David Brown, Jennings Environmental
Joey Winston, NC Division of Water Resources
Lori Williams, NCWRC

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Middle Fork French Broad R, Transylvania Co