20081199 Ver 1_More Info Letter_20090331

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
Governor Director Secretary
March 31, 2009
Iredell County
DWQ Project# 08-1199
CERTIFIED MAIL: RETURN RECEIPT REQUESTED
Mr. Scott Jones,Field Chief
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville,NC 28801-5006
Subject Property: Girl Scouts Environmental Academy—Proposed Lake
Dear Mr. Jones:
On behalf of the NC DWQ 410/Wetlands Permitting Unit, and in light of the most recent correspondence
from the applicant for the proposed project dated February 27, 2009,we respectfully request that you
consider the following comments within your review of the 404 Individual Permit request for the above
referenced property:
1. DWQ disagrees with the applicant's agent's assertion that there will be no algal blooms in the
proposed impoundment during summer months since the land use within the watershed of the
proposed impoundment is primarily agricultural. Furthermore, this Office may provide data that
impounding of a piedmont stream will lead to algal blooms within the impoundment.
2. It is not clear how the applicant will be handling releases from the three different levels. Will
they be releasing from all three simultaneously or alternating between them? It is the opinion of
this Office that if they alternate between the three it will be very destructive to downstream
aquatic communities.
3. Since primary recreation will be occurring(see page 4 under"Response to the Purpose and Need
Statement"), this Office will request.fecal coliform sampling post construction.
4. In response to comments contained within section Known Effects to Aquatic Resources from
your February 27, 2009, correspondence, DWQ offers the following:
o Ecological systems and native faunal/floral communities within the impounded stream
reach are negatively impacted due to water quality deterioration, habitat destruction, and
effects on migration. For instance, sedimentation may cover existing rock and gravel
substrate, including riffles and breaks. This is especially detrimental to gravel-riffle
spawners, such as channel catfish and smallmouth bass,that only deposit eggs where the
water depth, current, temperature, clarity, dissolved oxygen content, and bottom types are
suitable. Also, according to Higgs(2007), dams disrupt river connectivity and create
physical and thermal barriers that prevent migrating fish and other wildlife from moving
up-or downstream in a river system. He emphasizes that this is problematic for sea-run
401 Oversight/Express Review Permitting Unit One 1650 Mail Service Center,Raleigh,North Carolina 27699-1650 NOIthCarolina
Location:2321 Crabtree Blvd.,Raleigh,North Carolina 27604
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Page 2 of 4
March 31,2009
(anadromous and catadromous)fish as well as for residential fish that migrate up and
down a river system. These physical and thermal barriers affect fish spawning, rearing,
and foraging migrations, and also prevent re-colonization of other species following
floods, droughts, or human disturbances. For instance, during the larval stage, mussels
can attach to fish temporarily and move up-or downstream to re-colonize stream
segments.
o The Tennessee Department of Environment and Conservation(TDEC) sampled 75
streams below small impoundments and published a report in September 2006(Arnwine,
Sparks, and James, 2006). Benthic macroinvertebrate communities were adversely
affected in most of the streams sampled as only four passed biological criteria guidelines
or were comparable to first order stream references. In fact, 96%of the streams sampled
failed to meet reference guidelines for the number of distinct Ephemeroptera, Plecoptera,
and Trichoptera(EPT)taxa, and 86%had low EPT density. They also found that 39% of
the dams with year-round(low-flow)discharge provided insufficient flow to supply
adequate habitat for aquatic life during at least one season. Only about half of streams
studied appeared to have relatively stable channel structures, and approximately 80%
failed to meet regional expectations for sediment deposition.
o According to Mammoliti (2002), "a substantial body of literature indicates that
construction of dams has a negative impact on native stream fishes. In general, an
impoundment can reduce the quantity and quality of stream habitat, alter reproductive
and feeding behavior or fishes, and increase the number and sizes of predatory fish within
a stream system. These impacts suggest a negative relationship between impoundments
and obligate stream species."
5. Should this Water Quality Certification is issued,the DWQ will require a minimum flow release
to maintain current downstream flows, regardless of the set proposed impoundment normal pool,
and five years of May—October upstream, downstream, and comprehensive within the
impoundment water quality sampling.
6. The claim that"The biodiversity within the riparian area is limited."within section Flora and
Fauna, on page 3, should be supported with onsite collected data.
Thank you for your attention. If you have any questions, please contact Ian McMillan or me in our Central
Office in Raleigh at(919) 733-1786.
Sin ly,
ndi Karoly, Supervisor
XyC)
r
1 Oversight/Express Permitting Unit
CBK/ijm
cc: Amanda Jones,U.S. Army Corps of Engineers-Asheville Regulatory Field Office
Alan Johnson,DWQ Mooresville Regional Office
File Copy
Michael T. Brame, ECS, LLP,4811 Koger Boulevard, Greensboro,NC 27455
Filename: 081199GirlScoutsEnvironmentalAcademyProposedLake(Iredell)_IP_Comment_Letter3

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USACE—Asheville Office
Mr Scott Jones, Field Chief
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