20080164 Ver 1_WRC Comments_20080124

® North Carolina Wildlife Resources Commission
January 24, 2008
Ms. Lori Beckwith
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Mr. Ian McMillan
NCDENR, Division of Water Quality, 401 Unit
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
SUBJECT: Mr. Greg Crawford, Highlands Country Club Nationwide Permit Application
Club Lake dredging and dam repair -Monger Creek, Macon County
DWQ No.
Dear Ms. Beckwith and Mr. McMillan:
Mr. Greg Crawford of Highlands Country Club requested a letter of concurrence from the North Carolina
Wildlife Resources Commission (Commission) fora 404 Permit from the U.S. Army Corps of Engineers
(ACOE). Comments from the Commission are provided under provisions of the Clean Water Act of 1977
(33 U.S.C. 466 et. seq.) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C.
661-667d).
The project involves dam repair and removal of sediment from 0.4 acre of Highlands Country Club's Club
Lake on Monger Creek (WS III-CA). A half pipe would be placed around the gate valve inlet to reduce
sediment losses during draining. To reduce losses after the draw-down, a 20 foot wide area in front of the
valve would be excavated to allow construction of a rock dike or sediment trap. In addition, the lake bed may
be seeded if the draw-down duration exceeds 30 days.
Monger Creek likely supports trout like other streams in the region. The project may harm trout, particularly
if it caused sedimentation during the spawning season.
The Commission is concerned about sedimentation from this project and its potential effects on aquatic
habitat in Monger Creek. Sediment loss should happen during excavation of the dike area. However, there
may be additional and more appreciable losses from the exposed lake bed. As demonstrated by similar, recent
dredging projects, exposed sediments easily erode, particularly during storm events, and transport
downstream unless stream flow is isolated in pipe. The aggregate in the 3-4 foot tall dike would clog by
suspended sediment and the dike would likely be overtopped and thus rendered ineffective during high stream
flow events. Seeding, if pursued, would reduce erosion from rainfall within the lake bed itself, but prove
ineffective at preventing scour caused by Monger Creek inflow. Moreover, seeding may cause dissolved
oxygen declines in the lake once it is refilled and grass, if established, begins to decay. For these reasons,
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721
Telephone: [phone] Fax: [phone]

Crawford, Highlands Country Club Page 2 January 24, 2007
Macon County
stream flow should be isolated in pipe with this project as it is the most effective way to minimize the erosion
and sedimentation from the dredging of dewatered lakes on streams.
Stream temperatures in the Cullasaja River watershed are already excessive in the summer largely because of
in-line impoundments like Club Lake. Therefore, the Commission supports retrofitting the dam with a cool
water" release structure as depicted in the plans, but requests that the draw pipe extend closer to the lake
bottom in order to be most effective (only about a 5 foot depth is shown versus anticipated lake depth of about
10 -12 feet). This would help reduce the temperature increase the lake causes in the stream during the
summer.
Since the project could harm aquatic habitat in Monger Creek, the Commission recommends that the
following conditions be attached to the permit and used to help conserve fish and wildlife resources:
1. Draw down, dredging, and refilling does not occur from October 15 to April 15 to avoid possible
harm to trout spawning downstream of the lake.
2. Sediment and erosion control measures are used before construction and maintained until all
disturbed soils are permanently stabilized. Any bare soils excluding the dredging area are seeded as
soon as possible following disturbance. Erosion control matting that is anchored with staples, stakes,
or, wherever possible, live stakes of native trees is used with seeding on disturbed stream banks. Tall
fescue is not used along streams.
3. The lake is drawn-down gradually by siphoning or pumping. Turbidity is monitored downstream of
the lake during drawdown and excavation to ensure compliance with the water quality standards.
4. Any concrete work is isolated from stream flow because uncured concrete can kill aquatic life.
5. Excavated materials are disposed of and stabilized in a suitable upland location.
6. Rock, sand, or other materials are not excavated from stream channels except in immediate permitted
areas. Instream dredging has severe, adverse effects on aquatic life and disturbance of the natural
form of the channel can cause erosion.
7. Excavation and fill is avoided in flowing water. Stream flow is routed in pipe around the lake or
through the lake bed during excavation.
8. All heavy equipment operated near streams is inspected and maintained regularly to prevent
contamination by fuels, lubricants, or hydraulic fluids.
9. Hydroseed mixtures and wash-waters do not reach streams.
10. Disturbance of vegetation, particularly trees and shrubs, is minimized wherever lake or creek access
by heavy equipment is required. Roots are left in the ground (e.g. no grubbing) to resprout in
temporary access areas. Native woody vegetation (e.g., rhododendron, dog hobble, silky dogwood,
sycamore, river birch, red maple) is replanted where vegetation is permanently removed in order to
provide bank or shoreline stability and shading.
11. A sleeved standpipe or similar structure is constructed to withdraw water from near the bottom of the
lake. Cold water intakes should be within 1-2 feet of the bottom, but not on the bottom. This design
will improve water quality in impoundments. The easiest way to accomplish anear-bottom outflow
is to place a larger pipe (i.e. shroud or sleeve) over the standpipe so that water flows up through the
bottom of the larger pipe (see inset).
pond surface
outflo~- ~ water inflow
pond bottom

Crawford, Highlands Country Club Page 3 January 24, 2007
Macon County
12. Flow in the creek below the dam is maintained during lake refilling to protect aquatic life. This can be
accomplished by partially opening the gate valve during refilling. However, turbid water is not
discharged. Until the water in the pond is clear, bypass measures are used to maintain downstream flow.
The Commission appreciates the opportunity to assist the U.S. Army Corps of Engineers and the N.C.
Division of Water Quality in their evaluation of the project. Commission staff may inspect the project
area during and after construction. If there are any questions regarding these comments, please contact
me at [phone] extension 24.
Sincerely,
Dave McHenry
Mountain Region Coordinator
Habitat Conservation Program
cc: C1earWater Environmental Consultants
Mr. Kevin Barnett, NC Division of Water Quality