20200305 Ver 1_WRC Comments_20200317

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
March 17, 2020
Mr. Andrew Moore
NC Division of Water Resources
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
SUBJECT: White Oak Reservoir Drag Rake Extension
White Oak Creek, Macon County
Dear Mr. Moore:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to extend an existing water intake/drag rake structure in White Oak Reservoir on
Whiteoak Creek, impacting 0.01 acre of open water in Macon 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 Rainbow Trout are found downstream of the project area, and project activities should be
avoided between January 1 and April 15 to minimize impacts to trout reproduction.
To access the work area, lake levels will be lowered and maintained through the sand gate.
Downstream flows will be maintained during the project. Best management practices will be
used to isolate the work area from the exposed stream channel. The work area will be dry, and a
vacuum truck will be used to remove built-up sediment from the work area. Sediment will be
disposed off -site. A new concrete foundation will be poured in place, and a new drag and trolley
system installed.
We offer the following recommendations to minimize impacts to fish and wildlife:
1. Project activities should be avoided during the Rainbow Trout moratorium of January 1 to
April 15.
2. Rack spacing is currently 1 inch, and it is our understanding that the design does not
accommodate smaller rack spacing. If possible, rack spacing should be adjusted so that it
does not exceed 0.4 inch (1 centimeter), while maintaining a maximum intake velocity of 0.5
feet per second.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

White Oak Drag Rake Extn Page 2 March 17, 2020
Whiteoak Creek, Macon County
3. Excavated materials should not be stockpiled where sediment will erode to surface waters.
4. Wet concrete is toxic to aquatic organisms. Construction procedures which prevent uncured
concrete from contacting surface waters should be used, even during unanticipated flow
spikes.
5. Project activities 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. 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. Provisions of the Nantahala Minimum Flow and Flow Monitoring Plan (submitted August 8,
2013; approved September 25, 2013), the Whiteoak Sediment Management Plan (submitted
August 9, 2013; approved September 18, 2013), and the Whiteoak Woody Debris and Trash
Management Plan (submitted July 17, 2012) should be followed at all times. The license -
required minimum flow of 8 cfs or inflow to Whiteoak Reservoir, whichever is less, should
be maintained, even during pond refill, unless provisions of the Low Inflow Protocol or
Emergency Protocol are invoked.
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: Alan Stuart, Duke Energy
Chris Goudreau, NCWRC