20200420 Ver 1_WRC Comments_20200414

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
April 14, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: N. Pacolet River Bank Stabilization (Strickland)
North Pacolet River, Polk County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 700 feet of streambank with riprap on the North Pacolet River in Polk
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).
Project activities should not impact wild trout, and a trout moratorium is not needed. However,
this part of the North Pacolet River supports the Broad River Spiny Crayfish (Cambarus
spicatus, NC Special Concern) and the Seagreen Darter (Etheostoma thalassinum, NC
Significantly Rare).
The application proposes to stabilize an eroding streambank with riprap. Buttonbush or
comparable plantings would be planted above the riprap on the bank slope, and native trees
would be protected or planted on top of the bank. We reviewed similar permit applications in
2016, 2018, and 2019 to stabilize other sections of the North Pacolet River on the same property
with riprap.
We support the landowner's intention to establish a native woody buffer. However, we
recommend against using riprap for such a long area of bank; riprap is not likely to provide a
long-term solution to erosion. Instead, we recommend that bioengineering and natural channel
design methods, such as in -stream structures, geolifts, bank sloping, and planting, be used to
stabilize the banks.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

N Pacolet Stabilization - Strickland
N Pacolet R, Polk County
March 7, 2019
Due to the systemic instability of the river channel, it is likely that a bigger picture restoration
project is needed, involving in -stream structures, bank sloping, and riparian planting; we
recommend that the landowner consult with the Polk County Soil and Water Conservation
District to develop a longer -term solution.
We offer the following recommendations to minimize impacts to the aquatic community:
1. Bioengineering and natural channel design methods, such as in -stream structures, geolifts,
bank sloping, and native vegetation should be used instead of rock to stabilize the bank if at
all possible.
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. We appreciate the landowner's intention to eradicate non-native kudzu and establish a native
buffer. We encourage the landowner to establish a buffer as wide as possible; 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: Cynthia Strickland, landowner
Andrew Moore, NC Division of Water Resources