20200566 Ver 1_WRC Comments_20200501

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
May 1, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: UT Foster Creek Stream Restoration and Bank Stabilization
UTs to Foster Creek, Henderson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize and restore 1,895 ft of two unnamed tributaries (UTs) to Foster Creek in
Henderson 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).
This project should not affect wild trout reproduction and the activities do not need to be avoided
during the trout spawning moratorium. The site is upstream of a reach of the Mills River that is
recognized by the NC Natural Heritage Program as the Mills River Aquatic Habitat, rated Very
High for the richness of rare species it contains. Aquatic species found in the vicinity of the
project include three mussels —Appalachian Elktoe [Alasmidonta raveneliana, US Endangered
(E), NC E], Slippershell (Alasmidonta viridis, NC E), and Creeper (Strophitus undulatus, NC
Threatened); a rare fish —Blotched Chub (Erimystax insignis, NC Significantly Rare); and a rare
salamander —the Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species of
Concern, NC Special Concern). We are particularly concerned about potential sediment impacts
to these rare and listed species, and proper sediment and erosion control is essential to protect
this aquatic community.
The project would involve stabilization of three stream reaches with log boulder j-hooks,
constructed riffles, boulder cross vanes, bank sloping, and planting of a 20-30 ft native buffer.
According to Zan Price with Jennings Environmental, flows would be pumped around work
areas and disturbed areas would be made `storm ready' at the end of each work day.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

UT Foster Creek Restoration Page 2 May 1, 2020
UTs Foster Cr, Henderson County
We offer the following recommendations to minimize impacts to the aquatic community:
1. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
Due to the presence of listed and rare species downstream, disturbed areas should be seeded,
mulched and/or matted as soon as possible, preferably at the end of each work day; at a
minimum, disturbed areas should be stabilized within five working days or seven calendar
days, whichever is shorter.
2. Efforts should be made to retain as many existing native trees and shrubs as possible. 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 or need further assistance.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: Zan Price, Jennings Environmental
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service