20180727 Ver 1_WRC Comments_20180625

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
June 25, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Multi -area Streambank Restoration Projects, Henderson County
Cherry Branch Site, Comet Drive Site, Meadowbrook Terrace Site, Oaks and
Haywood Townes Sites, Patton Park Site, Allen Branch at Lakewood Road Site,
Allen Branch at Highway 64 Site, Spartanburg Highway Site,
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed
applications to stabilize 7,383 feet stream, including Allen Branch and unnamed tributaries
(UTs), Britton Creek and UTs, Cherry Branch and a UT to King Creek, which will involve
temporary impacts to 0.03 acre of wetland, in Henderson County. Our comments on these
applications 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 spawning, and no trout moratorium is required.
However, there are some rare species that could be impacted by project activities. The projects
that occur on in the Britton Creek watershed (Comet Drive Site, Meadowbrook Terrace Site, The
Oaks/Haywood Townes Site, and Patton Park Site) drain to Mud Creek, which hosts the
Southern Blotched Chub [Erimystax insignis eristigma, US Federal Species of Concern, NC
Significantly Rare (SR)] and a rare mayfly (Macdunnoa brunnea, NC SR). The projects that
occur in the Allen Branch watershed (Allen Branch at Hwy 64 Site, Allen Branch at Lakewood
Road Site) drain to Clear Creek, which contains the Southern Blotched Chub, the Creeper
(Strophitus undulatus, NC T), and another rare mayfly (Tsalia berneri, NC SR). The Spartanburg
Highway Site is in the vicinity of the Southern Blotched Chub habitat, as well. These rare
species are sensitive to sediment, and special care should be taken to minimize sediment loss
from the projects.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Multi -site Stabilization Page 2 June 25, 2018
Hendersonville, Henderson County
The projects are meant to stabilize stream reaches that are unstable and threatening sanitary
sewer infrastructure and adjacent property. NCWRC supports the approach to these projects, as
the designs generally use natural channel design elements as opposed to bank hardening, such as
bank grading, stream profile grading, in -stream structures (constructed riffles, vanes), geolifts,
brush mattresses, invasive species removal, and native species planting. Work will be performed
in the dry.
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. Areas that will be treated for Japanese Knotweed should have follow-up treatment for several
years to eliminate this invasive species.
3. Little information is provided on planted buffer width. We recommend that a woody buffer
as wide as possible as infrastructure allows be planted to ensure project success. A wide
forested buffer can ensure greater bank stability, filter overland pollutants, and provide
habitat for birds and other wildlife.
4. Remove as few native trees and shrubs as possible when constructing each project. This is
especially important where a healthy buffer is present, such as at the Allen Brach at
Lakewood Road Site.
5. Given the urban nature of these watersheds, designs should take into consideration watershed
build -out hydrology and the erosive and flashy nature of stormflows.
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: Scott Gregory, Wildlands Engineering
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service