20190560 Ver 1_WRC Comments_20190522

C 1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
May 23, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Bradley Creek Reservoir Dredging
Bradley Creek, Henderson County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to temporarily dewater 290 ft of Bradley Creek and 0.012 acre of an online reservoir on
Bradley Creek, as well as dredge 0.03 acre of the same reservoir in Henderson 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).
There are wild Brook Trout, Brown Trout, and Rainbow Trout in the vicinity of the project, and
project activities should be avoided between October 15 and April 15 to minimize impact to trout
reproduction. In addition, the Eastern Hellbender (Cryptobranchus alleganiensis, US Federal
Species of Concern, NC Special Concern) is found downstream in the South Mills River. These
species are especially sensitive to excess sediment and effective erosion and sediment control is
essential to minimize impacts to them.
The Bradley Creek Reservoir serves as a water supply source for the City of Hendersonville, who
proposes to dredge the impoundment in order to maintain intake infrastructure in good working
order. Dredging was last performed about 25 years ago, and similar methods are proposed for this
project. The applicant proposes to divert stream flows around the reservoir through what is assumed
to be the original channel. This channel meets the current wetted channel about 290 ft downstream
of the dam; thus this 290 ft reach will be dewatered during the project, which will take 2-4 weeks.
The reservoir itself would be dewatered by means of a mechanical pump, which would pump the
water into a geotextile filter bag to capture sediments. Isolated animals within the pond would be
rescued and moved upstream. Dredging will be performed with an excavator to a depth of 4-8 ft,
pulling out approximately 150 cyd of sediment, which will be hauled off to Hendersonville. Once
dredging is complete, water will be rediverted back into the channel and reservoir.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Bradley Creek Reservoir Dredging Page 2 May 23, 2019
Bradley Cr, Henderson County
As 290 ft of Bradley Cr will be dewatered, the applicant must rescue any stranded animals in the
stream reach as well in order to lessen impacts on aquatic life within the channel. This should be
done immediately and quickly after flows have been diverted, and we recommend moving the
animals via buckets with water into downstream Bradley Creek. Pond animals should be rescued as
well, and if any turtles or salamanders are found in the pond, they should be moved to a very large,
slow pool within Bradley Creek that has `ponded' character. After all flows are redirected back into
the main channel and reservoir, the diversion channel should be quickly surveyed and any stranded
animals relocated downstream into the flowing channel.
When flows are redirected back into the channel and reservoir, some flow must be maintained in the
downstream reach (that which is 290 ft downstream of the reservoir) during reservoir refill. We
recommend that only 50% of flows be redirected back into the channel and reservoir until the
reservoir is full. According to our calculations, refill should take less than 2 hours with 50% of the
flow.
We offer the following recommendations to minimize impacts to the aquatic community:
1. Work should be avoided during the trout moratorium of October 15 to April 15.
2. 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.
3. Any erosion control matting used should be free of plastic or nylon mesh, as this type of mesh
netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last for
years.
4. Animals (including fish, salamanders, turtles, and crayfish) must be rescued and moved from
within the dewatered stream reach, the pond, and the diversion channel once it is dewatered. We
ask the applicant to develop an animal rescue plan, which should be sent to NCWRC and US
Fish and Wildlife Service for review.
5. Ensure that 50% of incoming flows are maintained in Bradley Creek downstream of the project
footprint during pond refill.
6. Please notify Andrea Leslie (andrea.lesliekncwildlife.org), Luke Etchison
(luke.etchison(kncwildlife.ora), and Byron Hamstead (byron_hamsteadkfws.gov) at least 2
weeks before mobilization.
Thank you for the opportunity to review and comment on this project. Please contact me at (828)
803-6054 if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Anna Priest, Clearwater Environmental
Andrew Moore, NC Division of Water Resources
Luke Etchison, Chris Goudreau, Powell Wheeler, and Lori Williams, NCWRC
Byron Hamstead, US Fish and Wildlife Service