20190293 Ver 1_WRC Comments_20190416

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
April 16, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Robert Lake Park
Flat Creek and Puncheon Branch, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize portions of channel and rebuild footbridges within a park, impacting 336
ft of Flat Creek and Puncheon Branch in Buncombe County. I attended a site visit with the
applicant, NC Division of Water Resources staff, and others on March 21, 2019. 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 Flat Creek, and in -stream work should be avoided between
January 1 and April 15 in order to minimize impacts to reproduction. In addition, Flat Creek
supports the Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species of Concern,
NC Special Concern). These species are especially sensitive to sedimentation, and good erosion
and sediment control measure for this project are essential to protect these species.
The application proposes repair damage from 2018 floods to the park by rebuilding foot bridges,
stabilizing stream banks, and reshaping the channel in limited locations. Most work will be
performed from banks, but machinery will access the streams in limited locations. Some
boulders that have moved recently will be moved and used to stabilize banks and structures. A
stacked rock wall will be built against a vertical eroding bank, and an existing masonry wall will
be repaired.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Robert Lake Park Page 2 April 16, 2019
Flat Cr & Puncheon Br, Buncombe County
We appreciate the willingness of the Montreat Retreat Association to modify their plans to
minimize impacts to stream habitat. We offer the following recommendations to minimize
impacts to the aquatic community:
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 in -channel work between January 1 and April 15 to minimize impacts to Rainbow
Trout reproduction.
4. Perform work from the banks wherever possible and minimize the amount of time machinery
is in the channel.
5. If possible, use pre -cast concrete footers. Any concrete must be poured and set away from
water, allowed to cure at least 24 hours in the dry.
6. Avoid disturbing large rocks as much as possible, as hellbenders can use them for shelters.
7. Perform in -stream work during low flows and divert flows around work areas.
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 Newton, Davis Civil Solutions
John Quinzi, Montreat Retreat Assocation
Zan Price, NC Division of Water Resources
Lori Williams, NCWRC
Josh Holbrook, Montreat College