ABTechRestoration_UTsFrenchBroadR_Buncombe_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]
February 7, 2024

Mr. Mitchell Anderson
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: AB Tech Stream Restoration Project
UTs to French Broad River, Buncombe County

Dear Mr. Anderson:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application proposing to stabilize 1983 ft of Haith Branch and unnamed tributaries (UTs) (all
UTs to the French Broad River) and temporarily impact 0.004 acre and permanently impact 0.01
acre of wetland 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 project activities and a trout moratorium is
not needed. The French Broad River does support Appalachian Elktoe [Alasmidonta raveneliana,
US Endangered (E), NC E] and the Mustached Clubtail (Hylogomphus adelphus, NC
Significantly Rare) just downstream of the project, and excellent erosion and sediment control
are needed to minimize impacts to these species.

The application proposes to stabilize 1,983 ft of stream with log sills, rock toe, rock drops, brush
toe, and various constructed riffle types. A wide native riparian buffer would be planted.

We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. 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 matted as soon as possible.
2. 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.
3. Work should be performed in the dry.
AB Tech Restoration Page 2 February 7, 2024
UTs French Broad R, Buncombe Co

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: Renee Fortner, RiverLink
Joey Winston, NC Division of Water Resources