20081090 Ver 1_Restoration Plan Review_20081030

Peeler Creek Restoration Project

Subject: Peeler Creek Restoration Project
From: "Tammy.L.Hill" <[e-mail]>
Date: Thu, 30 Oct 2008 12:58:20 -0500
To: [e-mail]
CC: Eric Kulz <[e-mail]>, Sue Homewood <[e-mail]>,
matt. m atthews@ncmai 1. net, Cyndi Karoly <cyndi. karoly@ncmail. net>
Hello, Toni.
We have received your 10/21/2008 response to our 8/4/2008 comments regarding the
Restoration Plan for the Peeler Creek Restoration Project, Davie County, DWQ #
20081090, EEP Project ID # 92469. We appreciate you taking the time to address all
of our concerns. We have no further questions regarding the project at this time,
and will consider the 401 Certification deemed issued.
Please feel free to contact Tammy Hill or Eric Kulz at [phone] if you have
any questions about the project as it moves ahead. We look forward to working with
you toward a successful restoration project over the coming years.
Warm regards,
Tammy
Tammy Hill
Environmental Senior Specialist
NC Division of Water Quality (401/Wetlands)
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604
919-715-9052 (voice)
919-733-6893 (fax)
Tammy.L.Hill@ncmail..net
1 of 1 10/30/2008 12:59 PM
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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H Sullins, Director
Division of Water Quality
August 4, 2008
Mr. Edward Hajnos
N.C. Ecosystem Enhancement Program.
1619 Mail Service Center
Raleigh, NC 27699-1619
Re: Peeler Creek Restoration Site
Davie County
DWQ #08-1090
Dear. Mr. Hajnos:
The Division of Water Quality (DWQ) 401 Oversight and Express Review Permitting Unit has reviewed
the above-referenced application and restoration plan.
We have several questions/comments regarding the proposed project. Our comments are as follows:
• The soils in the proposed wetland restoration area are mapped Chewacla. Section 5.7 of the
restoration plan references Figure 6, which is to show Soil Units 1 and 2 determined during a soil
characterization study. These units are not shown on Figure 6; therefore, this figure should be
resubmitted with the available soils data.
Since there are issues involved with wetland restoration in Chewacla soils, the availability of
wetland mitigation credits at the project site will not be finalized until the commenting agency
members of the PACG-TC have an opportunity to consider the soil characterization information.
If the restoration is pursued in the meantime, it is at the risk of receiving a reduced amount of
wetland credit.
• Based on topography and soils data provided in the restoration plan, it is expected that wetland
restoration may occur well beyond the easement boundaries. Please verify that if the restored
wetlands extend into privately-owned land adjacent to the conservation easement, the
landowners will not seek to drain those wetlands. Ideally, the entire extent of restored wetlands
feasible at this site would be put into a conservation easement.
Again, we need to see the extent of Soil Units 1 and 2, but it appears that hydrologic success
criteria are probably appropriate. They should be clarified to read that the targeted percentages
are based on consecutive days of saturation or inundation during the growing season. Vegetation
criteria are appropriate. The status of volunteers, including invasive species, should be included
in the annual monitoring reports. In addition, Section 8.4, 1St sentence, should be revised to say
NQ `ftticarol(na
AWArra«y
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / Fax [phone]
Intemet:. http://h2o.enr.state,nc.us/ncwetiands
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Mr. Hajnos
N.C. Ecosystem Enhancement Program
Peeler Creek Restoration Project
Page 2 of 2
that all success criteria (not just vegetation) must be met in order for the project to be deemed
successful.
• The reference wetland is a linear ditch in the historic flowpath of Peeler Creek. It may be an
acceptable hydrology reference, but since it is located in a fallow field with no canopy layer, it is
obviously not an appropriate wetland vegetation reference.
The fact that one of the landowners (Concord United Methodist Church) has not yet agreed to
allow a conservation easement on their property is a concern. Another concern is the presence of
a cypress plantation immediately adjacent to the conservation easement. I would recommend
fencing the easement to prevent encroachment on the restored wetlands.
• Based on the description of the tributary and the DWQ stream form completed by the consultant,
Tributary 1 may be an intermittent stream. DWQ does not currently require mitigation for
intermittent streams. Credit generated through the restoration of intermittent streams can only be
used as compensatory mitigation for impacts to intermittent streams.
DWQ is awaiting scheduling on a N.C. Environmental Management Commission (EMC), Water
Quality Committee's session docket to present research on the importance of intermittent streams
and the need to require mitigation for intermittent stream impacts. Should the EMC pass DWQ's
requested requirement for intermittent stream mitigation, demand for intermittent stream credits
should increase in the future.
We look forward to your response to the comments listed above. Please feel free to contact Eric Kulz or
Tammy Hill at [phone] if you have any questions regarding this project or our comments.
Since y,
Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
cc: File Copy (Eric Kulz)
Central Files
Sue Homewood - DWQ WSRO
John Thomas - USACE Raleigh Regulatory Field Office
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / Fax [phone]
Internet: httk://h2o.enr.state.ne.us/ncwetlands
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