20181589 Ver 1_WRCComments_20190130

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
January 30, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Biltmore French Broad River and Swannanoa River Bank Stabilization
French Broad River and Swannanoa River, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 1,235 ft of the French Broad River and Swannanoa River in Buncombe
County. NCWRC staff attended a site visit with the applicant, consultants, and agency staff on
December 17, 2018. 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 no trout moratorium is
needed. However, the French Broad River provides habitat for the Appalachian Elktoe
(Alasmidonta raveneliana, US and NC Endangered) and both the French Broad River and
Swannanoa River host the Blotched Chub (Erimystax insignis, US Federal Species of Concern,
NC Special Concern).
The application proposes to stabilize a total of 310 ft on three sites on the Swannanoa River,
stabilize a total of 800 ft on four sites on the French Broad River, impact 70 ft of the French
Broad River for an emergency portage, and impact 10 ft of the French Broad River for outlet
protection. NCWRC supports the plan to use bioengineering and natural channel design methods
for stabilization, such as log and boulder vanes, geolifts, brush mattresses, and bank grading.
Live stakes will be planted on upper slopes of repairs. Work will be performed during low flows
and boulders will be used to divert flows from work areas. The application proposes to access
site S5 on the Swannanoa River (which involves construction of a 80 ft boulder vane) from a
staging area near site S6, necessitating movement of equipment and material downstream for 350
ft through the channel.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Biltmore French Broad/Swannanoa Stabilization Page 2 January 30, 2019
Buncombe County
Before project construction, the applicant must perform surveys for and relocations of
Appalachian Elktoe at the French Broad River impact sites. This work should be done in
coordination with Luke Etchison of NCWRC(luke.etchison(a�,ncwildlife.org) and US Fish and
Wildlife Service (USFWS) staff. NCWRC and USFWS will survey the Swannanoa River sites
and in -stream construction corridor before project construction; we ask that the applicant notify
both agencies of the project schedule at least one month before the start of construction.
We offer the following additional 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 nylon or 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. Avoid the removal of existing woody vegetation as much as possible and plant a woody
riparian buffer as wide as infrastructure allows. A wide forested buffer can ensure greater
bank stability, filter overland pollutants, and provide habitat for birds and other wildlife.
4. Work from the bank and avoid setting equipment in -channel as much as possible. Minimize
the number of in -channel trips between the staging area and site S5.
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: Clement Riddle, Clearwater Environmental
Andrew Bick, Headwaters Engineering
Zan Price, NC Division of Water Resources
Mark Endries, US Fish and Wildlife Service
Luke Etchison and Dylan Owensby, NCWRC