20210774 Ver 1_WRC Comments_20210916

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
September 16, 2021
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Ponderosa Creek Stabilization
UT to Bill Moore Cr/Enka Lake, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 1,173 ft of an unnamed tributary to Bill Moore Creek/Enka Lake in
Buncombe County. 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 the project, and a trout moratorium is not
required for the project.
The project involves the stabilization of an unstable reach of stream. A number of features
would be installed to arrest headcuts and reduce erosive flows, including two rock ramps at
active headcuts, one rock sill, four woody checks, and six permeable large woody debris
structures. On 9/15/2021, NCWRC staff attended a site visit with the project design team at
Givens Estate, where a similar strategy was used. For the current project, we strongly
recommend using much less riprap and more wood in the structures.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
Disturbed areas should be stabilized at the end of each day.
2. Work should be done at low flows.
3. 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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Ponderosa Creek Stabilization Page 2 September 16, 2021
UT Bill Moore Cr, Buncombe Co
4. We recommend minimizing the amount of riprap and increasing the amount of wood used in
the structures.
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: Chris Grose, Robinson Design Engineers
Andrew Moore, NC Division of Water Resources