20060385 Ver 1_More Info Received_20060719

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WN;t
Wetland and Natural Resource
Consultants, Inc.
July 13, 2006
Mr. Kevin Barnett
NC Division of Water Quality
2090 US Highway 70
Swannanoa, North Carolina 28778
RE: Forge Cove
Transylvania County, North Carolina
DWQ Project # 06-0385
Mr. Barnett:
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DENR - WATER QUALITY
WETLANDS AND STORMWATER BRANCH
Please reference the Request for More Information" dated June 26, 2006 sent by the
North Carolina Division of Water Quality (DWQ) in response to the June 15, 2006 letter
from Wetland and Natural Resource Consultants (WNR) providing additional information
and a response to comments received as a result of the Forge Cove Public Notice. DWQ
has requested additional information regarding impacts to brook trout associated with the
above referenced project.
Due to the July 4t" holiday weekend, WNR did not receive the "Request for More
Information" until July 5,, 2006. Upon receipt of DWQ's letter, WNR noticed a potential
typo in the additional requested information. The letter indicated that Fletcher
Management Group and WNR have "yet to provide compelling data which shows that this
impounding activity will adversely impact the existing brook trout population". The
afternoon of July 5, 2006, WNR contacted DWQ to insure our understanding of the
request. As indicated verbally by DWQ the request should read, "will notadversely impact
the existing brook trout population". On July 10, 2006, WNR requested additional time to
compile information needed to address the verbally revised request. Additional time was
granted, extending the deadline to July 14, 2006.
The trout survey done by Western Carolina University indicated that the brook trout
range extends approximately 500 linear feet beyond the footprint of the 27-acre lake.
With a reduction in the size of the lake to 15.67 acres, there will be an additional 715
linear feet of Osborne Branch avoided; totaling approximately 1215 linear feet of Osborne
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Branch beyond the footprint of the lake which can be utilized for trout spawning. WNR
has contacted Blue Ridge Ecological (a company formed by the WCU students that
conducted the previous survey) to discuss habitat suitability upstream and the possibility
of conducting additional field studies to determine the limits of suitable habitat on
Osborne Branch and its tributaries. Mike LaVoie of Blue Ridge Ecological is currently
studying brook trout within the Waynesville Reservoir, which impounds Allen's Creek and
its tributaries. Research indicates that brook trout do, in fact, live in the reservoir.
During a telephone conversation on July 12, 2006, Mr. LaVoie indicated that based on his
findings at Allen's Creek, brook trout can make use of a lake habitat if there is suitable
spawning areas upstream. WNR will provide the agencies with habitat suitability survey
results as they become available. We have tentatively scheduled the additional fieldwork
for the week of July 24tH
According to the April 27, 2006 letter from the NC Wildlife Resources Commission
(WRC), brook trout are found in lakes but "it is highly unlikely that they reproduce there
and are probably only present because of source populations in tributary streams". It is
also stated that "most if not all of the lakes cited (in the application] have tributaries that
support wild trout". Because Fletcher Management Group has reduced the size of the lake
allowing for additional spawning area, Forge Cove Lake would fall into the same category as
the other lakes cited. -A lake itself usually does not allow for a viable population of brook
trout; but, a sustainable population does live within the lake because of the population's
ability to spawn upstream.
It is indicated in the WRC letter that in March of 2006, WRC biologist found rainbow
trout in Boylston Creek. It is known that brook trout are sensitive to species introduction
and introduced species can cause range reduction. It is also stated that introduction of
species, mainly rainbow trout, results in slow growing brook trout populations that are less
abundant. Even with this knowledge, lakes and streams managed by the WRC are stocked
with brook, rainbow, and brown trout at a 40:40:20 ratio, respectively.
As stated in the WRC letter, "brook trout populations in streams and lakes decline when
some fish species, usually rainbow trout, are introduced or migrate into the watershed".
The Forge Cove Lake dam will be a barrier between the rainbow trout in Bolyston Creek
and native brook trout in Osborne Branch. The WRC affords no designation to Osborne
Branch or Boylston Creek and does not manage either tributary for trout. Fletcher
Management Company (FMC) will afford protection to the brook trout and is dedicated to
the management of the lake as a brook trout lake and understands the importance of the
tributaries leading to the impoundment. Forge Cove Lake is the main attraction at this
development. It is in the developer's best interest to keep this attraction appealing by
insuring that the lake and brook trout thrive. Wide buffers and extensive stormwater and
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Canton, NC 28716 Newton, NC 28658
828-648-8801 828-465-3035
828-648-8802 Fax [phone] Fax
lake management plans will ensure that upstream tributaries remain in a condition that is
suitable for spawning.
Information provided by Blue Ridge Ecological and the WRC leads Fletcher Management
Company and WNR to the conclusion that a viable wild brook trout population can utilize
the lake and upstream tributaries; therefore the Forge Cove Lake will not adversely
effect the brook trout population.
Fletcher Management Group and WNR have now presented compelling data that the wild
brook trout population will not be adversely impacted with the proposed action and request
that NC DWQ issue the 401 certification. WNR will provide the results of the additional
fieldwork to DWQ when it becomes available but this additional information should not be
necessary for the issuance of the certification. Should you require any further
information associated with the Forge Cove development, please do not hesitate to contact
me at 828-712-9205.
Best regards, ? 4t? (4/?,
Jennifer Robertson
Cc: Mrs. Cyndi Karoly, 401 Permitting Unit, 1650 Mail Service Center
Raleigh, North Carolina 27699
Mr. Roger Edwards, Surface Water Protection Section, 2090 US Hwy 70,
Swannanoa, North Carolina 28778
Mr. David Baker, US Army Corps of Engineers, 151 Patton Ave., Room 208,
Asheville, North Carolina 28806
Canton Office Newton Office
PO Box 882 wnrinc.com PO Box 224
Canton, NC 28716 Newton, NC 28658
828-648-8801 828-465-3035
828-648-8802 Fax [phone] Fax