20190288 Ver 1_WRC Comments_20190307

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
March 7, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Request to Modify 404 Permit, Buckeye Reservoir, Town of Beech Mountain
Buckeye Creek, Watauga County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to modify the existing 404 permit for the Town of Beech Mountain's water supply
reservoir, Buckeye Lake, in Watauga County. NCWRC staff have been to the site multiple
times. 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).
The Town of Beech Mountain (Town) is operating under a 1984 permit for installing the dam and
associated fill material. Two minimum flow conditions are required as part of this permit: (1) a
minimum flow release of 1.5-1.6 cfs maintained at all times and (2) a minimum flow release of
2.8 cfs during October -December to protect Brook Trout. The Town has been unable to maintain
these flows due to water withdrawals, inefficient water supply infrastructure, and drought.
The Town has requested the following new flow conditions: (1) Inflow to the reservoir be
continuously measured using a stream flow gauge station upstream of the reservoir, (2) during
low -flow conditions, outflows will be matched to incoming flows in Buckeye Creek by adjusting
the outflow gate valve, and (3) during high-flow conditions, outflows will be >1.0 cfs. Low -flow
conditions are considered the estimated 7Q10 value of 1.0 cfs. They also offer the following
permit modification conditions: (1) install and maintain gauge stations upstream and downstream
of the reservoir and (2) upfit the dam gate and valve with a mechanized valve and gate.
We offer the following comments and recommendations:
1. The proposal would require the town to release the 7Q10 value when upstream flows are at
or greater than 7Q 10 and require that inflows equal outflows when upstream flows are lower
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Buckeye Reservoir — 404 modification Page 2 March 7, 2019
Buckeye Creek, Watauga County
than 7Q10. Thus, the Town would only be required to release 7Q10 or lesser flows. The
7Q 10 was never meant to be an instream flow standard, and it is inadequate to protect aquatic
ecosystems. We recommend that flow requirements be based on Mean Annual Flow and
follow a 3 -tiered system like that recommended by NC Division of Water Resources
(NCDWR) at the on-site meeting held on October 15, 2018 and described in their February 1,
2016 letter regarding the Buckeye Creek Reservoir required minimum release reevaluation.
This 3 -tiered system allows for varied minimum releases based on the Mean Annual Flow
and Water Shortage Response Plan tiers.
2. The proposal notes that the 7Q10 value may be modified based on three years of hydrologic
data from the downstream and upstream gauging stations, which were installed in December
2018 and February 2019. USGS generally bases 7Q 10 values on at least 10 years of data,
and we recommend that any 7Q 10 modification adhere to this protocol.
3. We request that the applicant explain how they will maintain outflows that equal inflows.
Information should be provided on the protocols used to adjust flows, including how the
frequency of adjustment, whether the adjustments will be automated or manual, and how
records on flows will be maintained. We also request details on the outflow structure,
including at what elevation it will be set in relation to the lake bottom or normal pool
elevation.
4. Any permit modification should be contingent on the upfitting of the dam gate and valve
with a mechanized valve and gate. What is the progress on this effort?
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: Clement Riddle, Clearwater Environmental
Sue Homewood and Fred Tarver, NC Division of Water Resources
Chris Goudreau, NCWRC