20170406 Ver 1_WRC Comments_20170404

Strickland, Bev
From: Leslie, Andrea J
Sent: Tuesday, April 04, 2017 1:00 PM
To: Brown, David W SAW
Cc: Mitchell, Robert K; Byron Hamstead ([e-mail]); Fraley, Stephen J;
Williams, Lori A; Wheeler, A. Powell; Chris Whitmire; Young, Jeff; Jeff Parker
Subject: Chris Whitmire Stream Stabilization - NCWRC comments
Attachments: ChrisWhitmireStreamban kStabilization_FrenchBroad R_Transylvania_WRCComments.pd
f
Hi David,
Please see the attached comments from NCWRC on the Chris Whitmire Stream Stabilization project.
Andrea
Andrea Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Commission
20830 Great Smoky Mountain Expressway
Waynesville, NC 28786
828-558-6011; 828-400-4223 (cell)
www.ncwildlife.org
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1

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
April 4, 2017
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Chris Whitmire Streambank Stabilization
French Broad River, Transylvania County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 598 feet of streambank on the French Broad River in Transylvania
County. I attended a site visit with the landowner, designer, and agency representatives on
March 28, 2017. 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 Brown Trout in the project vicinity, and we prefer that in -stream activities be
avoided between October 15 and April 15 to avoid impacts to trout spawning. The French
Broad River supports a number of listed and rare aquatic species in the vicinity of the project,
including the Appalachian Elktoe [Alasmidonta raveneliana, US Endangered (E), NC E],
Creeper (Strophitus undulatus, NC Threatened), Eastern Hellbender [Cryptobranchus
alleganiensis, US Federal Species of Concern (FSC), NC Special Concern], and French Broad
River Crayfish (Cambarus reburrus, US FSC, NC Significantly Rare). Wild trout and these rare
species are especially sensitive to sediment, and special care should be taken to minimize
sediment loss from the project.
The application proposes to stabilize three eroding sections of the French Broad River by
creating a bankfull bench with riprap topped with soil, sloping the bank back to a 2:1 slope, and
planting the area with woody vegetation. Work will be performed from the bank. We are
supportive of this project, as it should address eroding sections of channel.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Chris Whitmire Streambank Stabilization Page 2 April 4, 2017
French Broad River, Transylvania County
Due to the sensitivity of trout and rare species described above to sedimentation, we request that
all efforts be used to reduce the risk of sediment loss from the site. In -channel work should be
performed quickly. Since work will not be done in the dry, we strongly recommend that work be
done during a period of low flow. All efforts to minimize sediment loss from project activities
should be implemented. Disturbed areas should be stabilized at the close of each construction
day.
According to discussions during the site visit, the planted riparian area will be at least 20 feet in
width from top of bank. We recommend planting as wide a forested buffer as possible, as native
woody vegetation will provide long-term bank stabilization, keep water temperatures cool, and
provide wildlife habitat. NCWRC recommends protecting a forested buffer of 200 feet on both
sides of a river to protect federally listed species such as Appalachian Elktoe; we recognize that
this width can be difficult to achieve on working lands and strongly recommend that at least 30
feet of area from the top of bank be planted in shrubs and trees.
As discussed, NCWRC and US Fish and Wildlife biologists will conduct mussel surveys so that
any animals found in the project footprint can be relocated before the work in the French Broad
River begins. Steve Fraley, NCWRC's Western Aquatic Wildlife Diversity Coordinator, will
take the lead for NCWRC and his contact information is stephen.fraleygncwildlife.org; 828-
550-0064.
We offer the following recommendations to minimize impacts to the aquatic community:
1. If possible, in -stream activities should be avoided between October 15 and April 15 to avoid
impacts to trout spawning. However, due to the presence of Appalachian Elktoe and other
rare species, it is most important to time this project to coincide with a period of low flows to
minimize the risk of sediment loss from the project.
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. 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. The planting mixture includes Tall Fescue which should be avoided in the riparian area, as it
is invasive and has minimal wildlife benefits. Instead, we recommend that perennial native
grasses and wildflowers be added to the seed mix to provide native herbaceous cover.
5. We recommend that a woody buffer as wide as possible be planted on both sides of the
stream as infrastructure allows to ensure project success. A wide forested buffer can ensure
greater bank stability, filter overland pollutants, provide cooler water temperatures needed by
Brown Trout and the rare species in the French Broad River, and provide habitat for birds
and other wildlife.
6. Coordinate with NCWRC to ensure that mussel surveys are completed before construction
begins.

Chris Whitmire Streambank Stabilization Page 3 April 4, 2017
French Broad River, Transylvania County
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
cc: Chris Whitmire, landowner
Jeff Young, NC Division of Soil and Water
Jeff Parker, Transylvania County Soil and Water Conservation District
Kevin Mitchell, NC Division of Water Resources
Steve Fraley, Powell Wheeler, Lori Williams, NCWRC
Byron Hamstead, US Fish and Wildlife Service