20230657 Ver 1_WRC Comments_20230614

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
June 14, 2023
Mr. Andrew Moore
NC Division of Water Resources
2090 US Highway 70
Swannanoa, NC 28778
SUBJECT: Platt-Wickwire-Whitmire-Ganner East Fork French Broad River Restoration
East Fork French Broad River, Transylvania County
Dear Mr. Moore:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 2,696 ft of the East Fork French Broad River in Transylvania County. I
visited the site on June 12, 2023. 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).
There are wild Rainbow Trout and Brown Trout in the East Fork French Broad River, and a trout
moratorium applies to this project. In addition, the river supports the Eastern Hellbender
(Cryptobranchus alleganiensis, US Federal Species of Concern, NC Special Concern), French
Broad River Crayfish [Cambarus reburrus, NC Significantly Rare (SR)], and Blotched Chub
(Erimystax insignis, NC SR). These species are especially sensitive to sedimentation, and
effective erosion and sediment control measures for this project are essential to protect these
species.
We recommend a modified hellbender moratorium on this project, avoiding in -stream activities
during the reproductive window of August 1 and September 15. The project is to be constructed
in 2 phases, with the upstream Phase 1 to be completed before the end of this year due to funding
constraints. Therefore, to enable Phase 1 to be completed this year, we will allow a modification
of the full trout moratorium, with the moratorium applying between December 1 and April 15;
this will allow a construction window between September 15 and November 30 to construct
Phase 1. Phase 2 must be constructed with consideration of both the modified hellbender
moratorium and the full trout moratorium of October 15 to April 15; this allows a construction
window between April 15 and August 1 and September 15 to October 15.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

East Fork French Broad River Restoration Page 2 June 14, 2023
East Fork French Broad R, Transylvania Co
The design features constructed riffles, instream boulder/log steps and vanes, brush toe
stabilization, bank grading, berm removal, and riparian planting of at least 25 ft in width. The
river channel will be shifted in one location and will be taken entirely off-line into an alternative
channel location at another.
Phase 1 of the project is planned for a reach that has good in -stream habitat and a healthy and
mature riparian buffer in many areas; this buffer is planned to be removed in order to grade back
the banks, tighten the channel width, remove tires used for stabilization, and replant. We are
concerned about negative impacts to hellbenders from the proposed design. Due to the quality
habitat within the channel, along the edges of the stream, and within the riparian buffer, we
recommend a much lighter touch for Phase I, with details below:
• The straight forested reach between 4+00 and 6+00 should be left alone, with no work within
the channel or riparian buffer. Instream habitat is good, banks are primarily stable, and edge
habitat is valuable. Very few tires are apparent.
• The brush toe on the right bank at approximately 12+00 should be eliminated or shortened to
the minimum length needed to protect the log vane structure. Edge habitat is good and the
banks are primarily stable with good rooted vegetation.
• The constructed riffles at 10+00 and 13+00 are sited where there is existing bedrock and
larger rock features. We recommend eliminating both of these structures, as the existing
channel bed provides good habitat.
• The 2 large sycamores on the left bank at 20+00 that anchor a pool should be preserved; the
bend should be left alone and not filled.
Phase 2 of the project is on a section of the channel that has a less robust buffer, has much worse
erosion, and a very silty bed. We generally support the work that is proposed for this reach.
Due to the likelihood of hellbenders in the project reach, we request that NCWRC biologists be
allowed on site to perform hellbenders as early as July. In addition, the project manager should
inform Andrea Leslie (andrea.leslie&ncwildlife.org) and Lori Williams
(lori.williamsgncwildlife.org of the construction start date at least 3 weeks before construction.
A pre -construction meeting should be held that involves the permitting agencies and NCWRC
staff. The designer should coordinate with NCWRC during construction so that staff can be
present during construction, especially during times of channel shift and abandonment.
We offer the following recommendations to minimize impacts to the aquatic community:
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. Any erosion control matting used should be free of 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. Avoid in -channel work for Phase 1 between August 1 and September 15 and December 1 to
April 15 to minimize impacts to hellbender and trout reproduction. Avoid in -channel work
for Phase 2 between August 1 and September 15 and October 15 to April 15.
4. We recommend that construction oversight be provided by the designer.

East Fork French Broad River Restoration Page 3 June 14, 2023
East Fork French Broad R, Transylvania Co
5. The project manager should inform Andrea Leslie (andrea.lesliekncwildlife.org) and Lori
Williams (lori.williamsgncwildlife.org of the construction start date at least 3 weeks before
construction.
6. Avoid disturbing large rocks as much as possible, as hellbenders can use them for shelters.
7. Avoid heavy equipment access in the channel as much as possible.
8. Work should be performed during low flows.
9. Due to the size of the channel, work will not be performed in the dry except for that on the
new channel. The design proposes to isolate flows from instream work areas with a
gravel/cobble berm. As juvenile hellbenders use cobble beds as habitat, materials from the
wetted channel should not be used to form in -stream berms.
10. During construction, staff should watch for hellbenders. This is especially important in
reaches of the river that will be realigned. Construction in these reaches should be performed
so that animals can move with flows to the new channel. Staff should be staged to watch for
animals within the abandoned channel reaches. If hellbenders are seen in the impact areas,
they should be captured in a bucket with water and placed well upstream at a location to be
determined by NCWRC staff.
11. If hellbenders are seen, contact Lori Williams (lori.williamskncwildlife.org) with this
information.
12. The planting plan includes River Birch, which I did not observe on site. We recommend
using alternative species found on site, such as Yellow Buckeye, Basswood, American
Beech, and Carolina Silverbell.
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,
�A4-�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: David Brown, Jennings Environmental
Shannon Healy, US Army Corps of Engineers
Lori Williams and Powell Wheeler, NCWRC
Byron Hamstead, US Fish and Wildlife Service