20180530 Ver 1_WRC Comments_20180507

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
May 7, 2018
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Penzenstadler Fire Suppression Pond
Little Piney Creek, Ashe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to impact 35 ft for a stream intake and water return for an offline pond and culvert 40
ft of Little Piney Creek in Ashe 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).
Project activities should not impact trout reproduction and do not need to be avoided during the
trout moratorium.
The application proposes constructing an off-line pond, which will withdraw up to 10% of the
flow of Little Piney Creek. It will have a coldwater release structure. Where ponds are
necessary, NCWRC supports the construction of off-line ponds with coldwater releases in
western North Carolina.
In addition, the project proposes to install a double-barreled culvert with two 48 -inch HDPE
culverts. We recommend against using slick -walled HDPE material, as this material is less likely
to hold stream substrate and provide for movement of aquatic organisms like fish and
salamanders. Double culverts set at the same elevation often result in one culvert carrying most
or all of the flows over time; this can cause channel instability and problems with aquatic
organism passage. We recommend replacing the double culverts with a spanning structure such
as a bridge or bottomless arch instead. If a culvert must be used, we recommend using a single
larger squash pipe capable of carrying base and stormflows.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Penzenstadler Pond Page 2 May 7, 2018
Little Piney Creek, Ashe County
We offer the following recommendations to minimize impacts to fish and wildlife:
1. Avoid using slick -walled HDPE culvert material.
2. We recommend replacing the double culverts with a spanning structure such as a bridge or
bottomless arch instead. If a culvert must be used, we recommend using a single larger
squash pipe capable of carrying base and stormflows.
3. Culvert replacement should be performed in the dry. The culvert should be buried in order to
allow free movement of sediment and aquatic organisms.
4. In -channel 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.
5. Construction of the pond will require significant earth work near Little Piney Creek. It is
extremely important to use effective sediment and erosion control on site to protect Little
Piney Creek from sedimentation.
6. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
7. It appears that little riparian vegetation is present on Little Piney Creek at the project site.
We recommend that a woody buffer of at least 30 feet be planted on both sides of the stream
as infrastructure allows. A wide forested buffer can ensure greater bank stability, filter
overland pollutants, and provide habitat for birds and other wildlife.
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: Derek Goddard, Blue Ridge Environmental Consultants
Sue Homewood, NC Division of Water Resources