20180310 Ver 1_WRC Comments_20180322

❑ North Carolina Wildlife Resources Commission ❑
Gordon Myers, Executive Director
March 22, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Platt French Broad River Bank Stabilization
French Broad River, Transylvania County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 300 feet of streambank on 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).
Project activities should not impact wild trout and do not need to be avoided during a trout
moratorium. The French Broad River supports a number of listed and rare aquatic species in the
vicinity of the project, including the Appalachian Elktoe [Alasmidonta raveneliana, US
Endangered (E), NC E], Creeper (Strophitus undulatus, NC Threatened), and French Broad River
Crayfish (Cambarus reburrus, US FSC, NC Significantly Rare). These rare species are
especially sensitive to sediment, and special care should be taken to minimize sediment loss from
the project.
The application proposes to stabilize an eroding section of the French Broad River by installing
boulder and wood toe revetments, installing a short boulder vane, sloping the bank back, and
planting a 30 -ft wide buffer with native trees and shrubs. We are supportive of this project, as it
should address an eroding section of channel.
Due to the sensitivity of rare species described above to sedimentation, we request that all efforts
be used to reduce the risk of sediment loss from the site. In -channel work should be performed
quickly, and flows should be diverted around the work area. Since work will not be done in the
dry, we strongly recommend that work be done during a period of low flow. All efforts to
minimize sediment loss from project activities should be implemented. Disturbed areas should
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Platt French Broad Stabilization Page 2 March 22, 2018
French Broad River, Transylvania County
be stabilized at the close of each construction day.
We recommend planting as wide a forested buffer as possible, as native woody vegetation will
provide long-term bank stabilization, keep water temperatures cool, and provide wildlife habitat.
NCWRC recommends protecting a forested buffer of 200 feet on both sides of a river to protect
federally listed species such as Appalachian Elktoe; we recognize that this width can be difficult
to achieve on working lands and recommend that a buffer as wide as possible be planted.
As discussed with Greg Jennings, the designer for this project, NCWRC and US Fish and
Wildlife biologists will conduct mussel surveys so that any animals found in the project footprint
can be relocated before the work in the French Broad River begins. Please notify NCWRC staff
as soon as possible (preferably providing a 1 -month lead time before instream activities) about
the project timeline. Contact Andrea Leslie and Luke Etchison, NCWRC Aquatic Wildlife
Diversity biologist (luke.etchison&ncwildlik,.M, 828-558-6016).
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -stream activities should be performed during a period of low flows to minimize the risk of
sediment loss from the project.
2. 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.
3. 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.
4. We recommend that a woody buffer as wide as possible be planted to ensure project success.
A wide forested buffer can ensure greater bank stability, filter overland pollutants, provide
cooler water temperatures needed by rare species in the French Broad River, and provide
habitat for birds and other wildlife.
5. Coordinate with NCWRC to ensure that mussel surveys are completed before construction
begins.
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: Parker Platt, landowner
Greg Jennings, Jennings Environmental
Kevin Mitchell, NC Division of Water Resources
Luke Etchison, NCWRC
Byron Hamstead, US Fish and Wildlife Service