20190167 Ver 1_WRC Comments_20190307

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
March 7, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Cheshire Streambank Stabilization
Camp Branch, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 300 ft of streambank on Camp Branch in Buncombe County. NCWRC
staff visited the site in 2014 when the applicant had applied for a 404 permit which has since
expired. 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).
Rainbow Trout are found downstream of the project, and if the applicant performs in -stream
work, activities should be avoided between January I and April 15 to minimize impacts to torut
reproduction. In addition, the Eastern Hellbender (Cryptobranchus alleganiensis, NC Special
Concern) is found downstream of the project, and it is especially important that effective
sediment and erosion control be used on the project to protect this species.
The project is intended to stabilize a section of Camp Branch that is unstable and has little
woody riparian vegetation. According to the application, the project will involve "centering the
flow back to its original historic bed", grading the streambanks to a 2:1 slope or less, and seeding
and straw application. Native riparian/wetland vegetation will be planted. Little information is
provided on design; however, it appears that the channel will be relocated in some areas.
As we noted in our 2014 comments, we recommend that any work in the stream channel itself be
avoided; if in -channel work is to be done, additional design information is needed for review,
including a plan view of the work to be done. We do support laying the banks back where they
are eroding and/or vertical and extensive planting of native woody vegetation. A combination of
Mailing Address: Habitat Conservation - 1721 Mail Service Center - Raleigh, NC 27699-1721
Telephone: [phone] - Fax: [phone]

Cheshire Streambank Stabilization Page 2 March 7, 2019
Camp Br, Buncombe County
live stakes and containerized shrubs and trees can be used to reestablish a riparian zone that will
stabilize the stream and create shade.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
I . 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, preferably at the end of each work day.
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. If in -channel work is to be done, the work should be avoided between January I and April 15
to minimize impacts to Rainbow Trout spawning. If the project is limited to bank sloping
and planting, a moratorium is not required.
4. We recommend using a combination of native wildflowers and grasses, shrubs, and trees to
establish a riparian buffer at least 30 ft in width to ensure project success. A wide forested
buffer can ensure greater bank stability, filter overland pollutants, and provide habitat for
birds and other wildlife. Planting recommendations and streambank stabilization guidance is
provided in the attached NC Cooperative Extension's guide on small-scale solutions to
eroding stream banks.
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
Attachment: Small-scale Solutions to Eroding Stream Banks
ec: Ken Curren, Cheshire
Zan Price, NC Division of Water Resources