20191716 Ver 1_WRC Comments_20200819

A
� North Carolina Wildlife Resources Commission IQ
Cameron Ingram, Executive Director
August 19, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: New Seawall at Greystone Inn
Lake Toxaway, Transylvania County
Dear Mr. Brown,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to install 600 feet of new seawall on Lake Toxaway in Transylvania County. I
visited the site on December 19, 2019. 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).
The project should not harm trout and construction does not need to be avoided during the trout
moratorium.
The site is on a peninsula that at the time of my site visit had a fringe of native vegetation. No
erosion was observed except for a small area near the wooded dock. Rhododendron had been
recently removed from the small existing buffer, presumably in preparation for the seawall. We
strongly recommend that any stabilization be limited to the small existing area of erosion, and we
prefer that bioengineering techniques such as bank sloping and native vegetation be used. If a
hard stabilization structures are needed, we recommend the use of dry -stack boulders with a rip
rap lining the base. These measures provide some physical shoreline complexity for fish and
invertebrates that is not afforded by vertical seawalls alone.
Natural cover such as boulders and fallen trees provide spawning and rearing habitats for
sunfish, black bass, and other fishes in the lake, but these features are sparse along the perimeter
of the lake due to extensive development. The shoreline trees and shrubs that not only stabilize
banks but also serve as habitat for wildlife such as song birds.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Greystone Inn Seawall Page 2 August 18, 2020
L Toxaway, Transylvania Co
We offer the following recommendations to minimize impacts to terrestrial and aquatic wildlife:
1. Any shoreline stabilization/seawall should be limited to the area of appreciable erosion.
2. Large woody debris should be left in place or moved temporarily and replaced after
stabilization work is complete.
3. We recommend that the landowner retain existing shoreline shrubs and trees.
4. We recommend the use of bioengineering techniques over hardening. Regardless of the
method used to stabilize the bank, we recommend that native trees and shrubs be planted
within the project footprint.
Thank you for the opportunity to review and comment on this regulatory action. 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
ec: Terry Allen
Kaylie Yankura, NC Division of Water Resources