20140802 Ver 2_WRC Comments_20180402

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
April 2, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: North Pacolet River Reach 4
North Pacolet River, Polk County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 3,616 ft of the North Pacolet River in Polk County. A previous
application for this project was reviewed in 2014. 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, and a trout moratorium is not needed. However,
this part of the North Pacolet River supports the Seagreen Darter (Etheostoma thalassinum, NC
Significantly Rare) and Broad River Spiny Crayfish (Cambarus spicatus, US Federal Species of
Concern, NC Special Concern).
The application proposes to stabilize an eroding reach of river with bank sloping, establishment
of a bankfull bench, geolifts/toewood, stone stream barbs, and riparian planting. We are
concerned about the use of stream barbs in the design, as these structures may not stay stable
over the long-term in a sandy system like the North Pacolet River. In addition, they can cause
local scour and accelerate downstream bank erosion. We recommend the incorporation of more
wood, geolifts, and a wide riparian buffer in the design.
We offer the following recommendations to minimize impacts to the aquatic community:
1. We recommend avoiding the use of stream barbs and suggest using natural channel design
alternatives, such as more geolifts and wood structures.
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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

N Pacolet River Reach 4 April 2, 2018
N Pacolet R, Polk County
3. Bank work should be performed during low flows, and instream work areas should be
isolated from flows.
4. 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.
5. We recommend that a woody buffer of at least 30 feet be planted on both sides of the stream
as infrastructure allows 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.
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: Wyatt Edsel, Anchor QEA
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service