20210865 Ver 1_WRC Comments_20210928

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
September 28, 2021
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Ledford Cane Creek Bank Restoration
Cane Creek and UT, Buncombe County
Dear Ms. Fuemmeler,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 741 ft of Cane Creek and an unnamed tributary (UT) 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).
Work in the Cane Creek should not impact trout reproduction, and project activities do not need
to be avoided during the trout spawning moratorium. However, Cane Creek supports Eastern
Hellbender (Cryptobranchus alleganiensis, US Federal Species of Concern, NC Special
Concern) and Blotched Chub (Erimystax insignis, NC Significantly Rare) in the vicinity of the
project. Excellent sediment and erosion control are essential to minimize impacts to these
important species.
The project involves bank stabilization on 351 ft of Cane Creek with rock toe, toewood
revetment, and a log vane. The UT will be relocated, with 390 of the channel constructed in the
dry and stabilized with constructed riffles and toewood with soil lift. Banks will be graded and a
riparian buffer of 30 ft planted on both reaches. In -stream machinery will be used in Cane Creek
where needed, with flows diverted around work areas with a cobble berm constructed from mid -
channel bar material.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
Disturbed areas be `storm -ready' at the end of each day.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Ledford Cane Cr Bank Restoration Page 2 September 28, 2021
Cane Cr & UT, Buncombe Co
2. Bank stabilization work should be staged so that any risk of loss of sediment into the river is
extremely low.
3. Any erosion control matting used should be free of nylon or plastic 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 modifying the plans so it is clear that stream cobble used to construct
diversion barriers is sourced from da mid -channel bars.
5. Due to the potential for Eastern Hellbender, we recommend avoiding the disturbance of large
flat rocks and watching for any hellbenders during construction. If animals are disturbed
during construction, they should be captured in a bucket and moved away from the area of
disturbance. Please notify Andrea Leslie([e-mail]) and Lori Williams
(lori.williams&ncwildlife.org ) if hellbenders are found.
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,
za�"&4�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Andrew Moore, NC Division of Water Resources
Lori Williams, NCWRC
Zan Price, Jennings Environmental