20201231 Ver 1_WRC Comments_20201123

0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
November 23, 2020
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Pebble Creek Restoration
Dingle Creek, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 291 ft of Dingle Creek in Buncombe 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).
Wild trout reproduction should not be impacted by project activities, and a trout moratorium is
not required for this project.
The project involves stabilizing erosion on Dingle Creek, much of which was previously
armored with gabion baskets, which are now failing. The design proposes to remove the gabion
baskets and replace them with gravity retaining walls (essentially concrete blocks), install a
boulder cross vane, harden the channel, and clean sediment out of existing culverts. Work will
be done in the dry. It appears that Dingle Creek is highly constrained by a sewer line and
infrastructure, with roads and building 10-40 ft from the stream. Although a limited set of
instream structures may be appropriate, we recommend against hardening the channel as
designed. In addition, we recommend alternative options to using concrete blocks to stabilize the
channel, such as geolifts.
We offer the following recommendations to minimize impacts to the aquatic community:
1. 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 workday.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Pebble Creek Restoration
Dingle Cr, Buncombe County
November 23, 2020
2. 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.
3. We recommend against hardening the channel and banks with rock and concrete. We
recommend limiting the amount of in -stream structures to those only needed for channel
stability and exploring bioengineering alternatives to gravity retaining walls.
4. Channel work should ensure that stream channel elevation allows substrate retention within
the culverts to ensure aquatic organism passage.
5. We support the permanent riparian seed mix. In addition, we recommend planting as many
native woody shrubs and trees as possible to provide bank stability, shade Dingle Creek, treat
stormwater driven pollutants, and benefit 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: Amy Bloom, McAdams Company
Andrew Moore, NC Division of Water Resources