StormFredEWPStRAPHeadwatersTrout&AtTheRidge_NFkFrenchBroad_Transylvania_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]
November 7, 2023

Ms. Shannon Healy
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Transylvania County Storm Fred EWP/StRAP – Headwaters Trout Farm and At
the Ridge Campground
North Fork French Broad River, Transylvania County

Dear Ms. Healy:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 2,795 ft of the North Fork of the French Broad River in Transylvania
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).

There are wild Brown Trout in the vicinity of the two project sites, and in-stream activities
should be avoided between October 15 and April 15 to minimize impacts to trout reproduction.

The project proposes to stabilize eroding reaches of stream at two different sites with stacked
boulders, rock toe with geolifts, and native plantings. Work would be done in the wet, with
machinery working from the bank where possible. Cobble/gravel berms would be used to isolate
instream work areas from flows.

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.
Headwaters Trout Farm & At the Ridge Camp Page 2 November 7, 2023
N Fork French Broad R, Transylvania Co
3. In-stream work should be avoided between October 15 and April 15 to minimize impacts to
Brown Trout reproduction
4. We recommend that the riparian buffer that is planted be as wide as possible, preferably at
least 30 ft in width.
5. Unless Sycamore and River Birch are found on the site or nearby on the river, they should be
removed from the planting plan, as they are typically associated with lower elevation streams
and larger floodplains. We suggest substituting these with Yellow Birch, Sweet Birch, and/or
Yellow Buckeye.

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
Joey Winston, NC Division of Water Resources