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HomeMy WebLinkAbout20221635 Ver 1_WRC Comments_202212074 North Carolina Wildlife Resources Commission Cameron Ingram, Executive Director December 7, 2022 Ms. Brooke Davis U.S. Army Corps of Engineers, Regulatory Branch 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 SUBJECT: Boylston Creek Restoration — FBPLLC Property Boylston Creek, Henderson County Dear Ms. Davis, Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an application to restore 3,658 ft of Boylston 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). The project should not impact trout reproduction, and project activities do not need to be avoided during the trout spawning moratorium. However, Appalachian Elktoe (Alasmidonta raveneliana, US and NC Endangered) is found in the French Broad River downstream of the project. In order to minimize impacts to this species, excellent erosion and sediment control are necessary on the project. The project involves restoration of Boylston Creek with construction of flood benches, instream structures such as constructed riffles, boulder/log steps, and boulder/log vanes, and toewood, and a native riparian buffer. Berms will be removed. The planted buffer width will range from 15-35 ft in width. Flows will be diverted around work areas with coffer dams. The planting list includes River Birch, which is a species typically found in floodplains of large stream systems. Unless this tree is found on Boylston Creek nearby, we recommend eliminating this species in favor of others more typical of smaller streams, such as Sweet Birch or Yellow Buckeye. In addition, we recommend removing Water Oak from the planting list, as it is not native to the area. We offer the following recommendations to minimize impacts to fish and wildlife resources: 1. In -channel work should be accomplished as quickly as possible and vigilance used in sediment and erosion control during site preparation, construction, and clean up. Disturbed Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Boylston Cr Restoration Page 2 December 7, 2022 Boylston Cr, Henderson Co areas should be seeded, mulched and/or matted as soon as possible, preferably at the end of each workday. 2. 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. 3. We recommend eliminating River Birch (if not found nearby) and Water Oak from the planting list in favor of species more typical of the area. 4. 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 (828) 400-4223 if you have any questions about these comments. Sincerely, Andrea Leslie Mountain Region Coordinator, Habitat Conservation Program ec: Andrew Moore, NC Division of Water Resources David Brown, Jennings Environmental