20180119 Ver 1_WRC Comments_20180302

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
March 2, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: 339 Cold Springs Creek Road Trout Farm
Cold Springs Creek, Macon County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to install an intake for a future trout farm, impacting 20 ft of Cold Springs Creek in
Macon County. I attended a pre -application site visit on May 5, 2017. 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).
There are Rainbow Trout in Cold Springs Creek, and the instream work proposed should be
avoided between January 1 and April 15 to avoid impacts to trout spawning.
The application proposes to place a 6 x 12 -inch steel I-beam in the stream, set perpendicular to
stream flow and flush with the stream bottom. In addition, a 3 x 10 -ft intake box fitted with a
screen would be installed on the left side of the stream, flush with the stream bank; this would
feed a 12 -inch pipe that would run 150 ft to a weir box to measure flow rate. Water would then
be piped back to the stream. This set-up will allow the applicant to determine the feasibility of a
trout farm at this location.
We are supportive of Mr. Brown's innovative design, which is intended to use less water and
avoid installing an intake device that would be a barrier to aquatic organisms. The project
proposes to withdraw 25% of the low flow with the design. We recommend a two-tiered
withdrawal limit in order to be protective at extremely low flows. We estimate that the 7Q 10
flow (which represents the lowest 7 -day average flow that occurs on average once every 10
years) is 1.7 cfs at this location on Cold Springs Creek. We recommend that the withdrawal be
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

339 Cold Springs Cr Trout Farm
Cold Springs Cr, Macon County
March 2, 2018
limited to 20% of instream flows when flows are < 1.7 cfs, and no more than 25% of instream
flows when flows are > 1.7 cfs.
To accomplish this, it is necessary to measure both instream flows and withdrawn flows.
Instream flows can be directly measured at the intake location or at a preestablished downstream
weir on Cold Springs Cr. If the downstream weir is used, flows at the new intake location can be
estimated by back calculating using the proportion of the drainage area at the intake location vs.
that at the weir.
We provide the following recommendations to minimize impacts to aquatic wildlife:
I. 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.
2. Divert flows around the work area as much as possible; for instance, while installing the
intake box, place large rocks or sand bags upstream of the area so that work is not performed
in direct flows.
3. Instream work should be avoided during the trout moratorium of January 1 to April 15 to
minimize impacts to Rainbow Trout spawning.
4. Withdrawn flows should be limited to 20% of the instream flows when they are <1.7 cfs and
limited to 25% of instream flows when they are >1.7 cfs.
5. Flows must be monitored at two locations — within Cold Springs Creek and within the intake
flow system in order to determine percent flows.
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: Howard Brown, applicant
Kevin Mitchell, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Chris Goudreau and Powell Wheeler, NCWRC