20071980 Ver 1_WRC Comments_20071204

~ North Carolina Wildlife Resources Commission ~
Richard B. Hamilton, Executive Director
December 4, 2007
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. William McKee, High Hampton Incorporated Nationwide Permit Application
Lake Jewel dredging and dam repair -Fowler Creek
Jackson County DWQ No. 07-1980
Dear Ms. Beckwith and Mr. McMillan:
Clearwater Environmental Consultants, on behalf of Mr. William McKee of High Hampton Incorporated,
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 construction of a 0.2 acre haul road to remove sediment from Lake Jewel on Fowler
Creek in the High Hampton Golf Course near Cashiers. The lake would be drained with a mechanical pump
and all outflow filtered through a silt bag.
Fowler Creek (C Tr) supports wild rainbow trout downstream of lake and the lake that was recently dredged
or that will be dredged on Wade Hampton. Fowler Creek flows to the Chattooga River, which is classified
ORW. The project may harm trout, particularly if construction occurred during the spawning season.
Lake dredging can harm aquatic habitat unless sedimentation is controlled and adequate stream flow
maintained downstream of the dam. The pump inlet would need to be elevated off the pond bottom to avoid
entraining sediment and to comply with the 10 NTU turbidity standards for trout waters (15A NCAC
023.0211). Exposed sediments in drained lake beds can easily erode during storm events and transport
downstream unless stream flow is isolated in pipe and run-off detained before discharge. In addition, partial
flow needs td be maintained below drained lakes during their refilling to avoid stream dewatering.
Since the lake impounds trout waters and the dam and water control structure will be reworked, the
Commission requests that the outlet structure be retrofitted to draw water from near the bottom the
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721
Telephone: [phone] Fax: [phone]

McKee, High Hampton Page 2 December 4, 2007
Jackson County
impoundment. This should help reduce the temperature increase the lake causes in the stream during the
summer. The temperatures of Fowler Creek are already excessive in the summer largely because of in-line
impoundments. The dredging project will increase the retention time of water in Jewel Lake and probably
add further to this seasonal warming. Therefore, it would be appropriate to retrofit a cool water release to
help minimizes changes in water quality conditions.
Since the project could harm aquatic habitat in Fowler Creek, the Commission recommends that the following
conditions be attached to the permit and used to help conserve fish and wildlife resources:
1. Pond draw down, dredging, and refilling occurs between April 16 and December 31 of any year to
avoid possible harm to rainbow 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 pond is drawn-down gradually by siphoning or pumping. Turbidity is monitored downstream of
the lake during drawdown and excavation to ensure compliance with the standard for trout waters.
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 pond or
through the pondbed 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. 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.
12. If not already installed and operational on the lake outlet, a sleeved standpipe or similar structure is
constructed to withdraw water from near the bottom of the pond. Cold water intakes should be within
1-2 feet of the bottom of the lake or pond bed, 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

McKee, High Hampton Page 3 December 4, 2007
Jackson County
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: Clearwater Environmental Consultants