20190729 Ver 1_WRC Comments_20190517

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
May 17, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: 214 Blue Ridge Road — Rollins Bank Stablization
Swannanoa River, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 145 feet of streambank on the Swannanoa River in Buncombe County. I
visited the site with the contractor and other agency staff on March 18, 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 the vicinity of the project, and project activities should be
avoided between January 1 and April 15 to minimize impact to trout reproduction. In addition,
the Swannanoa River supports a population of the Eastern Hellbender (Cryptobranchus
alleganiensis, US Federal Species of Concern, NC Special Concern). These species are
especially sensitive to excess sediment and effective erosion and sediment control is essential to
minimize impacts to them.
The applicant proposes to rebuild an eroding bank 20 ft streamwards, armor the toe of the bank
with large rock, and tie the bank into the existing upsteam and downstream banks. The
contractor may also excavate a cobble bar on the opposite side of the stream. Given how close
the stream is to the house, we understand the urgency of the situation; however, we are
concerned that this solution may only be a short-term fix, and that the bank will continue to
erode with future storm events. We encourage the applicant to implement a design that will
consider stream hydrodynamics and direct flows away from the bank with instream structures.
In addition, we strongly recommend the use of native shrubs and trees to further stabilize the
bank and provide shade for the Swannanoa River.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

214 Blue Ridge Rd — Rollins Stabilization Page 2 May 2, 2019
Swannanoa River, Buncombe County
We offer the following recommendations to minimize impacts to the aquatic community:
1. Work should be avoided during the trout moratorium of January 1 to April 15.
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. Work should be performed from the top of the bank during low flows.
4. Stream flows should be diverted away from the work area so that work is done in as dry an
area as possible.
5. 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.
6. We recommend that the project incorporate as many native trees and shrubs as possible for
the project. For planting recommendations, please see NC Cooperative Extension's guide on
small-scale solutions to eroding stream banks, attached.
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: Linda Rollins, landowner
Zan Price, NC Division of Water Resources