20211609 Ver 1_WRC Comments_20211123

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
November 23, 2021
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Springs of North Asheville
UT to Wagner Branch, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to remove a dam on an unnamed tributary (UT) to Wagner Branch in Buncombe
County, which would involve impacts to 0.153 acre of wetland and loss of 0.424 acre of open
water. 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).
The project should not impact wild trout, and project activities do not need to be avoided during
a trout moratorium.
The work would involve dewatering of the existing pond by setting a culvert 3 ft below the pond
bed and surrounding the culvert with rock pipe inlet protection to capture sediments before they
are delivered downstream. The dam will be removed, and once the pond is sufficiently dried out,
a new channel will be constructed in the dry through the pond footprint, which will involve
wetland impacts. Stream flow will be turned into the new channel once it has been stabilized
with matting, seed, and mulch. According to Andrew Bick, a native riparian buffer 50 ft wide
will be planted on either side of the restored stream.
We are concerned about the effectiveness of the rock pipe inlet protection in ensuring that pond
sediments are not lost downstream, and we recommend designer oversight of this effort. It is
important that this project be monitored daily to ensure that it is not resulting in downstream
turbidity or sediment impacts.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Springs of North Asheville Page 2 November 23, 2021
UT Wagner Br, Buncombe County
We offer the following additional recommendations to minimize impacts to fish and wildlife
resources:
1. We recommend that project oversight be provided by the designer or environmental
consultant during pond draining, dam removal, and channel restoration.
2. Daily visual monitoring should be performed to ensure that project activities are not resulting
in downstream turbidity or sediment deposition.
3. 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.
4. 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.
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: Britten Yant, ClearWater Environmental
Andrew Bick, Headwaters Engineering
Andrew Moore, NC Division of Water Resources