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HomeMy WebLinkAbout1.20 CWA404_Request_RydenNo2_and_BensonPiersonNelson_DiversionsFloodplain Development Report for Middle Colorado Agriculture Collaborative Fish Passage Design in New Castle, Colorado 211-020.020 Wright Water Engineers, Inc. Attachments July 2024 E.2 CWA 404 Permit Documentation Project 2 (WWE has not yet received cultural survey from the BoR or approval from the USACE. When cultural survey documentation and approval documentation arrives, WWE will submit the documentation to Garfield County) DENVER DURANGO (303) 480-1700 TEL (303) 480-1020 FAX (970) 259-7411 TEL (970) 259-8758 FAX Wright Water Engineers, Inc. 818 Colorado Ave., Ste. 307 www.wrightwater.com Glenwood Springs, CO 81601 ngreenberg@wrightwater.com (970) 945-7755 TEL (970) 945-9210 FAX June 24, 2024 Via Email: SPA-RD-CO@usace.army.mil U.S. Army Corps of Engineers, Northwestern Colorado Branch Re: Clean Water Act Section 404 Request-Removal of Benson Pierson Nelson Ditch Diversion Structure, Replacement of Existing Ryden No. 2 Ditch Diversion Structure, and Associated Ditch Reconfiguration (Project 2), Garfield County, Colorado Dear U.S. Army Corps of Engineers Project Manager: Wright Water Engineers, Inc. (WWE) is sending you this letter request regarding planned irrigation diversion structure and ditch work in the Elk Creek drainage basin in Garfield County, Colorado (see Figure 1). The planned work (Project) is intended to replace two agricultural irrigation points of diversion with a single diversion structure that requires minimal maintenance and which allows fish passage up- and downstream through this reach of Elk Creek. The existing diversion structures are aging, require regular maintenance (and associated adverse effects to the creek) and do not facilitate fish movement. To allow the removal and abandonment of the Benson Pierson Nelson Ditch diversion structure without losing the ability to deliver water to that ditch, the Project includes conversion of roughly 1,925 feet of non-wetland open ditch (with a corresponding area of less than 0.15 acre) to a piped ditch and construction of a splitter and pipe from the Ryden No. 2 Ditch that would convey flows to the Benson Pierson Nelson Ditch. Project design drawings are attached to this letter. AQUATIC RESOURCES AT PROJECT SITE Methods WWE delineated aquatic resources at the Project location on October 10 and 11, 2023 and May 20, 2024. Wetlands were delineated using the methodology provided by the United States Army Corps of Engineers (USACE) in the 1987 Corps of Engineers Wetland Delineation Manual (Manual) and the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Regional Supplement). Aquatic resources were located and mapped using a sub-meter accurate global positioning system (GPS). Wetland determination data points were located within and outside unique wetland areas. These data are available upon your request or for inclusion in future submittals to your office (either Approved Jurisdictional Determination [AJD] requests or Preconstruction Notification [PCN]). Non-wetland water ordinary high water marks (OHWM) were mapped using A Guide to the Ordinary High Water Mark (OHWM) Delineation for Non-Perennial Streams in the Western Mountains, Valleys, and Coat Region of the United States (OHWM Manual) and USACE Regulatory Guidance Letter No. 05-05 titled Ordinary High Water Mark Identification (RGL 05-05). USACE Northwestern Colorado Regulatory Branch June 24, 2024 Page 2 Please note that for the purposes of Clean Water Act Section 404 authorization, WWE considers all delineated aquatic resources as waters of the United States until USACE has issued an Approved Jurisdictional Determination (AJD) for those features. Results The results of WWE’s aquatic resources delineation are depicted in Figure 2, which includes representative photographs. The delineated aquatic resources are summarized as follows: 1) Elk Creek: Elk Creek is a perennial tributary of the Colorado River. At the Project site, the river’s OHWM is roughly 30-to-40-feet wide. 2) Elk Creek Floodplain Wetlands: WWE delineated floodplain wetlands that have a direct surface connection with Elk Creek and which appear to have hydrology driven by naturally high groundwater and periodic flooding. There is a significant wetland bench along the east side of the creek in the vicinity of the Ryden No. 2 Ditch diversion structure. There are minimal fringe wetlands along the creek in the vicinity of the Benson Pierson Nelson Ditch diversion structure. Dominant vegetation in these areas include willow (Salix spp.), redtop (Agrostis gigantea), and red osier dogwood (Cornus sericea). 3) Ryden No. 2 Ditch: WWE delineated a reach of the Ryden No. 2 Ditch in the vicinity of the planned conversion to a pipeline and splitter box. The ditch appears to have only ephemeral flows based on the lack of hydrophytic vegetation and hydric soils within the ditch. 4) Benson Pierson Nelson Ditch: WWE delineated a reach of the Benson Pierson Nelson Ditch in the vicinity of the planned outfall for diverted flows from the Ryden No. 2 Ditch. The ditch appears to have intermittent flows based on the presence of hydrophytic vegetation and hydric soils within and surrounding the ditch. Additionally, WWE delineated wetland areas in the immediate vicinity of the ditch. These wetlands are irrigation dependent and in WWE’s opinion, would revert to upland if flows in the ditch were terminated. PROJECT IMPACTS TO AQUATIC RESOURCES AND CWA 404 REGULATORY CONSIDERATIONS The Project will include the discharge of fill material within delineated aquatic resources, including Elk Creek and the Ryden No. 2 Ditch and the Benson Pierson Nelson Ditch. As stated above, in lieu of a USACE AJD, WWE considers all aquatic resources as waters of the United States for the purposes of CWA 404 compliance. Based on the Project design, delineated aquatic resources, knowledge of CWA 404 (including 404f exemptions and Regional General Permit 5 [RGP 5]) it appears that: USACE Northwestern Colorado Regulatory Branch June 24, 2024 Page 3 1)Diversion structure replacement for the Ryden No. 2 Ditch will occur within the existing structure footprint, does not appear to be subject to the Recapture Provision 1, and appears to be eligible for an agricultural exemption under CWA 404(f). There will be no permanent losses of waters of the United States associated with this action and there will be a net- benefit to aquatic resources achieved as a result of the decreased maintenance needs and incorporation of fish passage into the new structure. 2)Removal of the Benson Pierson Nelson Diversion also appears to be eligible for an agricultural exemption as the activity will remove an existing diversion structure and restore the channel consistent with up- and downstream ecological conditions. There will be no permanent loss of waters of the United States at this location and the project will result in a net-increase in aquatic resource function (e.g., creating in-stream habitat where a cross-channel diversion structure is presently located). 3)A roughly 1,925 foot long reach of the Ryden No. 2 Ditch will be impacted with the conversion from open ditch to piped ditch and installation of a flow splitter that will direct flows, in a new pipeline, to the Benson Pierson Nelson Ditch. The total area of non-wetland ditch that will be lost as a result of this conversion is less than 0.15 acre. Less than 0.05 acre of the Benson Pierson Nelson Ditch (including associated wetlands) will be impacted as a result of the installation of an engineered flow outfall energy dissipator. In lieu of a USACE AJD for the ditches, the conversion to a piped feature, installation of the flow splitter, and installation of the energy dissipater result in a total loss of potential waters of the United States that is less than the thresholds for preconstruction notification (PCN) requirements under RGP 5 2. The Bureau of Reclamation (BoR) is funding the Project and is functioning as the lead federal agency for National Environmental Policy Act (NEPA) review. BoR’s NEPA review of the Project included inventory and consultation as required under Section 106 of the National Historic Preservation Act (Section 106) and Section 7 of the Endangered Species Act (Section 7). Documentation of BoR’s compliance with Sections 106 and Section 7 is attached for USACE’s review. Based on the BoR’s role as the lead federal agency for NEPA review and the attached documentation of its compliance with Sections 106 and 7, RGP 5 PCN requirements associated with Sections 106 and 7 do not apply to the Project. 1 Although the Recapture Provision application is somewhat variable between USACE offices, replacement projects which remain within the footprint of the existing structure are generally not susceptible for being recaptured as CWA 404 regulated activities. 2 Under RGP 5, PCN is not required for projects resulting in the loss of less than 0.1 acre jurisdictional wetland or less than 1 acre of non-wetland waters. USACE Northwestern Colorado Regulatory Branch June 24, 2024 Page 4 CONCLUSION AND REQUEST FOR USACE CONFIRMATION Based on WWE’s analysis, the Project consists of: 1)CWA 404f exempt activities (replacement of Ryden No. 2 Diversion and removal of Benson Pierson Nelson Diversion); and 2)CWA 404 RGP 5 authorized activities, including the conversion of less than 0.15 acre of non-wetland open ditch to a piped conveyance and installation of an energy dissipator in a ditch with less than 0.05 acre loss of wetlands. Because BoR is serving as the lead federal agency and has satisfied obligations under Sections 106 and 7, and the losses of aquatic resources are significantly below the PCN thresholds which apply to RGP 5, the non- exempt portions of the Project appear to be authorized under RGP 5 without notification. Thank you for your review of this submitted information. If your office agrees with WWE’s assessment of the Project’s CWA 404 regulated impacts being authorized under RGP 5 without PCN, we would appreciate your written letter of concurrence. If additional information is needed, please contact me at (303) 480-1700 or ngreenberg@wrightwater.com. Sincerely, WRIGHT WATER ENGINEERS, INC. By ______________________________ Noah Greenberg, PWS Senior Water Resources Scientist Attachments: Figures 1 and 2, Select Construction Drawings cc: Scott Schreiber, P.E. (WWE), \\WWE-GWS\project files\WWE\211-020\020\Engr\404_and_ESA\USACE_Submittals_2024_February\Project_2\CWA404_Request_RydenNo2_and_BensonPiersonNelson_Diversions_ PROJECT COORDINATOR: TROUT UNLIMITED 115 NORTH 5TH STREET GRAND JUNCTION, CO 81501 ENGINEER: WRIGHT WATER ENGINEERS, INC. 818 COLORADO AVENUE SUITE 307 GLENWOOD SPRINGS, CO 81601 SURVEYOR: BOOKCLIFF SURVEY SERVICES, INC. 163 EAST 3RD STREET RIFLE, CO 81650 STRUCTURAL ENGINEER: GEI CONSULTANTS 2750 S. WADSWORTH BLVD SUITE D-200 DENVER, CO 80227 FISHERIES BIOLOGIST: GEI CONSULTANTS 2750 S. WADSWORTH BLVD SUITE D-200 DENVER, CO 80227 TELEMETRY CONSULTANT: HYDROLOGIK, LLC 10790 W. 50TH AVENUE UNIT 700 WHEAT RIDGE, CO 80033 CONTACT: RICHARD VAN GYTENBEEK 307-690-1267 CONTACT: SCOTT SCHREIBER, P.E., CFM 970-945-7755 (OFFICE) 423-943-7500 (CELL) CONTACT: WAYNE KIRKPATRICK 970-625-1330 (OFFICE) CONTACT: MARGARET PROVENCHER, P.E. 303-264-1038 (OFFICE) 970-895-7692 (CELL) CONTACT: ASHLEY FICKE, PHD 303-625-9502 (OFFICE) 970-290-4374 (CELL) CONTACT: BRUCE BACON 720-799-2828 (OFFICE) 720-480-6639 (CELL) COVER SHEET 211-020.020 ---- GN01 GARFIELD COUNTY, COLORADO MIDDLE COLORADO AG COLLABORATIVECOMBINE RYDEN NO. 2 AND BENSON PIERSON NELSON DIVERSIONS(PROJECT 2) JBH/DTL JBH/DTL SDS 4/12/2024 SHOWN MEMBER UTILITIES FOR THE MARKING OF UNDERGROUND BEFORE YOU DIG, GRADE, OR EXCAVATE CALL 3-BUSINESS DAYS IN ADVANCE CENTER OF COLORADO OR CALL UTILITY NOTIFICATION 1-800-922-1987 811CALL COLORADO NO. BY DATE COMMENTS SCALE DETAIL CHECK DESIGN Pl o t D a t e / T i m e : 0 4 / 1 2 / 2 0 2 4 , 0 1 : 2 6 : 1 1 P M ; G : \ W W E \ 2 1 1 - 0 2 0 \ 0 2 0 \ C A D \ 0 2 _ D W G S \ G N X X - C O V E R A N D N O T E S . D W G - G N 0 1 P R O J 2 C O V E R S H E E T SHEET NO. JOB NO. REVISION NO. DATE DESCRIPTIONWRIGHT WATER ENGINEERS, INC. GLENWOOD SPRINGS, CO 81602 (970)945-7755 FAX(970)945-9210 818 COLORADO AVE. P.O. BOX 219 DRAFT NOT FOR CONSTRUCTION BID SET 4/12/2024 4/12/2024 VICINITY MAP PROJECT LOCATION COUNTY ROAD 243 ELK CREEK NORTH 1000 2000 FT10000 MAP SOURCE: GOOGLE EARTH SHEET NUMBER SHEET TITLE GN01 COVER SHEET GN02 GENERAL NOTES OV01 OVERALL PLAN DM01 BENSON PIERSON NELSON DITCH ABANDONMENT HZ01 HORIZONTAL CONTROL PLAN HZ02 HORIZONTAL CONTROL PLAN PP01 FISH PASSAGE PLAN & PROFILE PP02 DIVERSION AND RETURN FLOW PLAN & PROFILE PP03 RYDEN NO. 2 DITCH PLAN AND PROFILE PP04 RYDEN NO. 2 DITCH PLAN AND PROFILE PP05 RYDEN NO. 2 DITCH PLAN AND PROFILE PP06 BENSON PIERSON NELSON DITCH PLAN AND PROFILE PP07 BENSON PIERSON NELSON DITCH PLAN AND PROFILE XS01 SECTIONS XS02 SECTIONS TS01 TYPICAL SECTIONS TS02 TYPICAL SECTIONS DT01 PROJECT PERSPECTIVE DETAILS DT02 TYPICAL DETAILS TE01 OVERALL TELEMETRY PLAN COMBINE RYDEN NO. 2 AND BENSON PIERSON NELSON DIVERSIONS SHEET INDEX CONTACTS1. THE GOAL OF THIS PROJECT IS TO REMOVE IN-STREAM BARRIERS TO FISH PASSAGE BY UPGRADING THE DIVERSION STRUCTURE. THIS PROJECT COMPLEMENTS AND FURTHERS THE OBJECTIVES, GOALS, AND ACTIONS IDENTIFIED IN THE COLORADO WATER PLAN, AS WELL AS THE THEMES, GOALS, AND STRATEGIES RECENTLY STATED IN THE COLORADO BASIN ROUNDTABLE'S UPDATED BASIN IMPLEMENTATION PLAN. 2. DIVERSION INFRASTRUCTURE UPGRADES INCLUDE BUT ARE NOT LIMITED TO MODIFICATIONS TO THE DIVERSION CREST ELEVATION, CONCRETE DIVERSION STRUCTURE, TRASH RACKS, FISH SCREEN, HEADGATES, AUTOMATION, TELEMETRY, FLOW MEASUREMENT, DITCH ENHANCEMENTS AND DITCH SPLITTER STRUCTURE. 3. FISH PASSAGE IS ENHANCED VIA MINOR ADJUSTMENTS TO THE EXISTING STREAMBED AND DIVERSION DAM CREST. INSTREAM WORK IS DESIGNED TO CAUSE MINIMAL DISTURBANCE TO THE EXISTING CONDITIONS AND IS LIMITED TO IMPROVEMENTS TO THE DIVERSION CREST AND FORMALIZING THE OFFLINE DIVERSION CHANNEL. 4. THE CONTRACTOR SHALL ASSUME SOME FIELD FITTING WILL BE REQUIRED IN COORDINATION WITH THE ENGINEER TO PROVIDE A SUCCESSFUL PROJECT. MOST FIELD FITTING WILL BE ASSOCIATED WITH THE FISH PASSAGE ELEMENTS. 5. THIS PROJECT CAN BE CONSTRUCTED INDIVIDUALLY OR BE LUMPED TOGETHER WITH THE OTHER MIDDLE COLORADO AGRICULTURE COLLABORATIVE (MCAC) PROJECTS. 6. THE PROJECT WILL BE CONSTRUCTED DURING THE NON-IRRIGATION SEASON. PROJECT DESCRIPTION LOCATION MAP NORTH 5000 10000 FT50000 MAP SOURCE: GOOGLE EARTH PROJECT LOCATION NEW CASTLE 1-70 1-70 CR 2 4 5 CR 2 4 3 CR 2 4 1 O E O E O E O E O E O E O E O E O E O E O E O E w w w w w w w ww w ww w w w O E O E O E O E O E ^ ^ ^ ^ ^ ^ ^ 5905 2+63 1+0 0 2+00 3+33 1 + 0 0 2+0 0 3+00 1 + 0 0 1 + 4 8 OFFLINE DIVERSION CHANNEL TO HEADGATE DEBRIS DEFLECTOR BOULDERS, SEE SHEET DT02 STREAM SUBSTRATE (D50 = 18") BOULDERS SEE SHEET DT02 CONCRETE WALL EXISTING 24-INCH CMP TO BE REMOVED REMOVABLE TRASH RACK AND FISH SCREEN FLOW EL K C R E E K ELK CREEK FL O W CO U N T Y R O A D 2 4 3 REMOVE PILE OF ROCKS IN COORDINATION WITH ENGINEER CONCRETE DIVERSION STRUCTURE RYDEN NO. 2 - FISH PASSAGE, SEE SHEET PP01 RYDEN NO. 2 - DIVERSION, SEE SHEET PP02 RYDEN NO. 2 - SEDIMENT SLUICE, SEE SHEET PP02 MAINTAIN EXISTING ACCESS AREA FOR PROPOSED DIVERSION STRUCTURE 30" HDPE PIPE REVEGETATION: WILLOW STAKES REVEGETATION: UPLAND SEED APPROXIMATE LOCATION OF SPOT TREATMENT BOULDERS, SEE SHEET DT01 CONTRACTOR TO COORDINATE WITH ENGINEER ON RESTORATION OF AREA DEPENDING ON CONTRACTOR MEANS AND METHODS FOR CONSTRUCTION REVEGETATION: WILLOW STAKES REVEGETATION: UPLAND SEED 5 9 0 5 590 5 5905 59 0 5 59 0 6 59 0 7 59 0 8 59 0 9 5905 5910 5 9 0 0 59 2 0 591 5 5920 5 9 0 0 5 9 0 0 5 9 0 5 5910 COORDINATE WITH ENGINEER TO PRESERVE AND/OR CREATE BACKWATER HABITAT O E O E O E ^ ^ ^ ^ ^ ^ ^^ ^ ^ ^ ^ ^ ^ ^ ^ ^ x x x ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ x x x ^ ^ ^ ^ x ^ EL K C R E E K 30-INCH HDPE PIPE 24-INCH PARSHALL FLUME CONCRETE FLOW SPLITTER STRUCTURE DAYLIGHT TO EXISTING DITCH BENSON PIERSON NELSON DITCH EXISTING PIPELINE TO REMAIN IN PLACE EXISTING BENSON PIERSON NELSON DIVERSION TO BE ABANDONED, SEE SHEET DM01 RYDEN NO. 2 DITCH LOCATION OF PROPOSED COMBINED DIVERSION (RYDEN NO. 2 POINT OF DIVERSION) PROPOSED PROJECT DESIGNED UNDER SEPARATE COVER, SEE COMBINE RYDEN NO. 1 AND CO & CP PIERSON DIVERSIONS PLAN SET 30" HDPE PIPE 24-INCH PARSHALL FLUME SEDIMENTATION BASIN EXISTING 24-INCH CMP CULVERT BENEATH CR243 TO BE REMOVED AND REPLACED WITH 30-INCH HDPE 30" HDPE PIPE 24-INCH PARSHALL FLUME DRAINAGE CROSSING 1, SEE SHEET PP08 CO U N T Y R O A D 2 4 3 DRAINAGE CROSSING 2, SEE SHEET PP09 DRAINAGE CROSSING 3, SEE SHEET PP10 RYDEN NO. 2 DITCH 30-INCH HDPE INSTALLED ACROSS CR243 JBH/DTL JBH/DTL SDS 4/12/2024 SHOWN MEMBER UTILITIES FOR THE MARKING OF UNDERGROUND BEFORE YOU DIG, GRADE, OR EXCAVATE CALL 3-BUSINESS DAYS IN ADVANCE CENTER OF COLORADO OR CALL UTILITY NOTIFICATION 1-800-922-1987 811CALL COLORADO NO. BY DATE COMMENTS SCALE DETAIL CHECK DESIGN Pl o t D a t e / T i m e : 0 4 / 1 2 / 2 0 2 4 , 0 1 : 3 1 : 2 7 P M ; G : \ W W E \ 2 1 1 - 0 2 0 \ 0 2 0 \ C A D \ 0 2 _ D W G S \ O V X X - P R O J E C T O V E R A L L P L A N S . D W G - O V 0 2 - P R O J 2 O V E R A L L SHEET NO. JOB NO. REVISION NO. DATE DESCRIPTIONWRIGHT WATER ENGINEERS, INC. GLENWOOD SPRINGS, CO 81602 (970)945-7755 FAX(970)945-9210 818 COLORADO AVE. P.O. BOX 219 DRAFT NOT FOR CONSTRUCTION BID SET 4/12/2024 4/12/2024 OVERALL PLAN 211-020.020 ---- OV01 NORTH 10 10 20 FT0 DETAILED PLAN NORTH 200 400 FT2000 OVERALL PLAN COMBINE RYDEN NO. 2 AND BENSON PIERSON NELSON DIVERSIONS