20221671 Ver 1_WRC Comments_20230104

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
January 4, 2023
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Woodfin Riverside Park and Wave
French Broad River and UT, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 258 ft and an additional 0.79 acre of the French Broad River
and an unnamed tributary (UT) and temporarily impact 75 ft and an additional 2.19 acres of the
French Broad River and UT in Buncombe County. NCWRC staff have visited the site multiple
times. 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 should not be impacted by project activities, and a trout moratorium is not needed.
However, this site is in a very popular reach of the river for angling and boating. Communication
with the general public and recreational users, in particular, is essential in order to ensure public
safety.
The project proposes to expand an existing park along the east side of the French Broad River,
constructing parking, trails, viewing areas, and two river access sites. In addition, it proposes to
construct a whitewater and low flow bypass feature in the river itself. Elements of the on -land
part of the project include the installation of a culvert on a UT, boulder toe stabilization along the
riverbank, and construction of an upstream river access area as well as a downstream take-out
access using a push -in concrete boat ramp. The in -river work will involve the construction of a
whitewater feature in the center of the channel and a low flow bypass on the west side. Some
bedrock will be cut and artificial features constructed.
The in -stream structures will be built in stages, with the central area constructed first, then the
east area constructed, and finally the west area constructed. The central area structure will be
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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French Broad R, Buncombe Co
accessed in the following way - a low water access consisting of culverts placed topped by stone
between the old railroad piers will be constructed, then a coffer dam will be constructed around
the central work area, the water within that area allowed to settle and then pumped down, and a
sump placed in a low corner. Then the structure will be constructed in the dry, ensuring that no
cementitious material enters the water way and grout is cured in the dry for 3 days. The east
work area will be accessed with the same low water access and isolated from flows in the same
way. The west work area would be accessed from the railroad on the west bank; a work area will
be isolated with a coffer dam and an in -river access road built and in -river structure constructed
within the dry area.
NCWRC does not support the manipulation of the river bed to create an artificial whitewater
feature. There is a natural set of whitewater ledges approximately 5 river miles downstream,
which supports recreational use.
We offer the following recommendations and requests for additional information:
• The plans describe three different methods to isolate in -river work areas. It is unlikely that a
sandbag coffer dam will stay in place at high flows, and we recommend against using this
method.
• Contingency plans for high flow events should be developed. These should include cleaning
up debris from coffer dams and temporary roads in the channel. Any bags used for coffer
dams should be filled with clean material (e.g., sand) and not soil.
• The weather forecast should be monitored closely; it is essential that concrete pours be done
during low flows and followed by several days of low flows to ensure dry conditions.
• Sump pits should be deep enough so that there is reasonable settling of suspended material.
• The plans do not include specifications on the in -river structures nor the manipulation of
existing in -river features, planting specifications, or specifications for river bank stabilization
or river access sites. Please provide these details.
• This project will involve an increase in impervious surface on the east side of the river.
Please describe the stormwater measures that will be used to minimize the hydrologic
impacts of increased stormwater from site development.
• 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.
• Tree clearing should be accomplished outside of summer bat roosting season, during the
period recommended by the US Fish and Wildlife Service (USFWS).
• To compensate for the loss of habitat that will occur with the installation of the in -stream
structures, we recommend several habitat measures:
o Although a recent mussel survey did not find any rare mussels, survey work has
demonstrated that the riffle associated with the old railroad footprint provides some of the
best bed habitat in the vicinity. It is unclear if the removal of the railroad piers will
destroy this habitat feature. We recommend removing only the portion of the piers needed
to ensure safety but maintaining that which will preserve the riffle habitat, if at all
possible.
o If possible, plant native aquatic vegetation, such a Water Willow, to create a backwater
refugium in the shallow area on the west side of the river.

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French Broad R, Buncombe Co
o Install educational kiosks that provide information on the native fauna of the river and the
importance of aquatic organism passage, riparian vegetation, and large woody debris.
• We recommend that the applicant meet with agency representatives to discuss concerns
raised during application review.
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: Owen Carson, Equinox Environmental
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Doug Besler, Amanda Bushon, Luke Etchison, Scott Loftis, & Powell Wheeler, NCWRC