Comment on Proposed Changes to NHCP (Aug 2011)

Folks- I have reviewed the proposed NRCS Conservation Standards for dam and pond removal and stream crossings (Docket #NRCS-2011-0018), and in general have found it to be a good document. However, I would make the following recommendations: In regard to Culvert and Bridge crossings, 578-2, 5th paragraph “Size culverts to convey flow….” etc.: Stronger language to maintain the cross sectional shape of out-of-bank flows should be included. As the paragraph is currently written, it sounds like the typical single culvert with rock protection downstream would be acceptable. Flow terrace culverts or openings are presented as only a possible option. Secondly, the use of ‘bottomless’ or ‘natural bottom’ culverts should be encouraged or mandated in new bridges. These culverts provide an uninterrupted substrate in the streambed, and provide a continuity in depth and habitat that allows for passage for macroinvertebrates and small fish. Thank you for this opportunity to comment on the proposed standards.