20211202 Ver 1_WRC Comments_20210825

® North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
August 25, 2021
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Seventh Day Adventist Church Bank Stabilization
North Pacolet River, Polk County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 300 feet of streambank with quarried boulders 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 rock backed by filter fabric.
Trees washed into the river as well as those leaning and in danger of falling in will be cleared.
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 methods, such as
geolifts, bank sloping, and planting, be used to stabilize the banks. However, due to the systemic
instability of the river channel, it is likely that a bigger picture restoration project is needed,
involving instream structures, bank sloping, and riparian planting; we recommend that the
landowner consult with the Polk County Soil and Water Conservation District or a qualified
stream restoration designer to develop a longer -term solution.
Aerial photographs demonstrate that there is very little woody riparian vegetation along the river
on this property; the lack of woody riparian vegetation only exacerbates streambank erosion. We
recommend that the landowner plant a wide woody buffer along the entire reach of the North
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

7' Day Adventist Church Stabilization Page 2 August 25.2021
N. Pacolet River, Polk County
Pacolet River on the property. We recommend incorporating as many native shrubs and trees as
possible into the project, as native woody vegetation will help provide long-term bank
stabilization, keep water temperatures cool, and provide wildlife habitat.
We offer the following recommendations to minimize impacts to the aquatic community:
1. Bioengineering methods, such as geolifts, bank sloping, and native vegetation should be used
instead of rock to stabilize the bank if at all possible. We recommend that the landowners
consult with a qualified stream restoration designer and/or the Soil and Water Conservation
District for ideas to address systemic instability.
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 recommend that the project incorporate as many native trees and shrubs as possible for
the project and recommend planting a woody buffer along the entire reach of the North
Pacolet River. For planting recommendations, please see NC Cooperative Extension's guide
on small-scale solutions to eroding stream banks, attached.
Thank you for the opportunity to review and comment on this project. Please contact meat
[phone] if you have any questions about these comments.
Sincerely,
( v, ,dA"--�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
Attachment: Small-scale Solutions to Eroding Stream Banks
ec: Roger Peden, Seventh Day Adventist Church
Kaylie Yankura, NC Division of Water Resources