20231648 Ver 1_WRC Comments_20240102

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
January 2, 2024
Mr. Mitchell Anderson
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: EAT Storm Fred Buncombe County — Israel -Haley Site
South Hominy Creek, Buncombe County
Dear Mr. Anderson:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 250 ft of South Hominy 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).
There are wild Rainbow Trout in the vicinity of the project site, and in -stream activities should
be avoided between January 1 and April 15 to minimize impacts to trout reproduction. In
addition, Eastern Hellbender [Cryptobranchus alleganiensis, US Federal Species of Concern
(FSC), NC Special Concern] and French Broad River Crayfish (Cambarus reburrus, US FSC,
NC Significantly Rare) have been found in the project vicinity. Excellent erosion and sediment
control are needed to minimize impacts to these sensitive species.
The project proposes to stabilize an eroding reach of stream with stacked boulders, geolifts, and
native plantings. Work would be done in the wet. Cobble/gravel berms would be used to isolate
instream work areas from flows. 4,000 ft of channel will be subjected to debris removal.
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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

EWP Storm Fred — Israel -Haley Site Page 2 January 2, 2024
S Hominy Cr, Buncombe Co
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. In -stream work should be avoided between January 1 and April 15 to minimize impacts to
Rainbow Trout reproduction.
4. 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.
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. 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. Please notify
Lori Williams (Lori.williamskncwildlife.org) if any hellbenders are observed.
8. We recommend that the riparian buffer that is planted be as wide as possible, preferably at
least 30 ft in width.
9. 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
Andrew Moore, NC Division of Water Resources
Lori Williams, NCWRC