GrandfatherGCCStreamEnhancement_LinvilleR&tribs_Avery_NCWRCComments

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
July 11, 2023

Ms. Alexi Archer
U.S. Army Corps of Engineers
100 W Oglethorpe Ave
Savannah, GA 31401-3604

SUBJECT: Grandfather Golf and Country Club Stream Enhancement
Linville River, Big Grassy Creek, Little Grassy Creek, and UTs, Avery County

Dear Ms. Archer:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to impact 1,964 ft of the Linville River, Big Grassy Creek, Little Grassy Creek, and
unnamed tributaries (UTs) in Avery 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 entails stabilizing eroding reaches of stream that run through a golf course as
follows:
 Work on the upper reach of the Linville River (reaches 1A and 1B), Big Grassy Creek,
Little Grassy Creek, and unnamed tributaries to the Linville River and Big Grassy Creek
would entail bank sloping, bankfull bench construction, matting, and/or installing rock on
the banks and/or toe. Sod would be planted along these streams. According to Ian
Eckardt, this work should involve no equipment in the streams with the exception of
some tie-in areas.
 The middle reach of the Linville River (Reach 2) would involve in-stream work (rock
sills and vanes), bank sloping, a stone wall, rock on the banks, and sod planting. The
lowest reach of Reach 2 would involve bank sloping, rock, and planting a native riparian
buffer.
 Work on Hole 10 Tributary, a stream that feeds to the lake, would involve pond removal,
stream channel construction, bank sloping, and planting a native riparian buffer.

A robust population of wild Brown Trout are found in the project vicinity, and instream work
should be avoided between October 15 and April 15 to minimize impacts to trout reproduction
for the more involved work on Reach 2 of the Linville River. Work on other reaches of stream
Grandfather GCC Stream Enhancement Page 2 July 11, 2023
Linville River & tributaries, Avery Co
can proceed during the trout moratorium period as long as excellent erosion and sediment control
practices are used to minimize release of fine sediments to streams.

The eroding stream reaches have been stabilized in the past with rock. We doubt that the
proposed stabilization plan will provide a long-term solution to chronic instability on-site; we
strongly recommend that a bioengineering solution such as geolifts and a woody riparian buffer
be incorporated into the restoration plan to ensure a greater bank stability, filter overland
pollutants, and provide habitat for birds and other wildlife. Other golf courses in western NC
have planted narrow woody buffers as part of their stream stabilization plans, periodically
maintaining the buffer to achieve a maximum height of 3-4 ft.

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
areas should be seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day.
2. Work on Hole 10 Tributary should be done in the dry to minimize loss of sediment from the
project. In-stream work on Reach 2 of the Linville River should be done in a way that
minimizes loss of sediment; we recommend using structures to divert stream flows away
from work areas more prone to sediment loss, such as bank tie-in areas.
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. As described above, we recommend incorporating bioengineering solutions instead of or in
addition to bank hardening for streambank stabilization. We strongly suggest incorporating a
native woody riparian buffer as wide as infrastructure allows throughout the site. Any
maintenance of a planted buffer should be done carefully, cutting vegetation to a height no
less than 2 ft.
5. In-stream activities should be avoided between October 15 and April 15 in order to minimize
impacts to wild trout reproduction for work on the Linville River Reach 2.

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: Ian Eckardt, Wildlands Engineering
Joey Winston, NC Division of Water Resources
David Goodfred, NCWRC