20230867 Ver 1_WRC Comments_20230717

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
July 17, 2023
Mr. Andrew Moore
NC Division of Water Resources
2090 US Highway 70
Swannanoa, NC 28778
SUBJECT: Rankin Farm Stream Stabilization Project
Garren Creek, Buncombe County
Dear Mr. Moore:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 310 ft of Garren Creek 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).
Wild trout reproduction should not be impacted by this project, and a trout moratorium is not
needed.
The project entails stabilizing eroding reaches of stream with a stacked rock toe. Flows will be
diverted from in -stream work areas. A riparian buffer of unknown width will also be planted.
Instead of bank hardening, we recommend that a bioengineering solution such as geolifts be used
to ensure a greater bank stability, filter overland pollutants, and provide habitat for birds and
other wildlife.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
I . 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. 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.
3. The planting list include Black Walnut, which is alleleopathic. We recommend eliminating
this species from the planting list.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Rankin Farm Stabilization Page 2 July 17, 2023
Garren Creek, Buncombe Co
4. 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.
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
cc: Mike Knoerr, Conservation Management Institute