20230992 Ver 1_NesbitetAlCaneCrGravellyCrRestoration_CaneCrGravellyCr_Buncombe_NCWRCComments

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
August 28, 2023
Mr. Mitchell Anderson
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Nesbit et al. Tract Cane Creek - Gravelly Creek Restoration
Cane Creek and Gravelly Creek, Buncombe County
Dear Mr. Anderson:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to restore 7,375 ft of Cane Creek and Gravelly Creek in Buncombe County. I visited
the site on August 25, 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).
Project activities should not impact wild trout, and a trout moratorium is not needed for the
project. However, there are records of Eastern Hellbender (Cryptobranchus alleganiensis, US
Federal Species of Concern, NC Special Concern) and Blotched Chub (Erimystax insignis, NC
Significantly Rare) in the vicinity of the project. In order to minimize impacts to these species, it
is especially important to use excellent erosion and sediment control techniques and limit the
amount of in -channel disturbance.
The project proposes to stabilize eroding reaches of stream by installing log vanes, boulder j-
hooks, and toewood, grading stream banks, and planting a native riparian buffer of at least 25 ft
in width. Work will be done in the wet, with equipment in -stream in Cane Creek; coffer dams of
gravel and cobble harvested from the stream would be used to isolate flows from work areas.
Work on Gravelly Creek will be done in the dry.
The plans propose to harvest boulders in Cane Creek to install habitat structures. Due to the
possibility of hellbenders in the reach, we recommend leaving large rock (at least 1 ft long or
wide) at the bank toe and within the channel undisturbed. We also recommend using hellbender
shelter specifications for the habitat structures to increase in -stream habitat for these animals.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Cane Cr — Gravelly Cr Restoration Page 2 August 28, 2023
Cane Cr & Gravelly Cr, Buncombe Co
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 disturbing large rocks as much as possible, as hellbenders can use them for shelters.
Do not harvest in -stream boulders to create habitat structures, as these boulders may already
provide hellbender habitat. There is one area on the left bank at the downstream end of the
project where boulders at the toe can be harvested, as discussed with David Brown during the
8/25/23 field visit.
4. We recommend using hellbender shelter specifications for the habitat structures to be
installed.
5. Avoid heavy equipment access in the channel as much as possible. This is especially
important where larger rock is present that could harbor hellbenders.
6. Work should be performed during low flows.
7. The design proposes to isolate flows from instream work areas on Cane Creek 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.
8. As River Cane is on site, we recommend that the contractor save as much cane as possible
and replant it within the buffer.
9. During construction, staff should watch for hellbenders. If hellbenders are seen, they should
be captured in a bucket with water and placed upstream of the project location.
10. If hellbenders are seen, contact Lori Williams (lori.williamsgncwildlife.org) with this
information.
11. We request that NCWRC staff be involved in the pre -construction meeting.
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: David Brown, Jennings Environmental
Tyler Hickman, NC Division of Water Resources