20081090 Ver 1_Restoration Plan Review_20080803

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NC Division of Water Quality
401 Oversight and Express Permitting Unit
August 3, 2008
Memorandum
To: Eric Kulz
From: Tammy Hill
Subject: Comments on Peeler Creek Restoration Plan (20081090)
Repositioning Peeler Creek in its historic location in the middle of the floodplain with riparian
wetlands appears to be an appropriate goal at this site. However, based on topography and soils
data provided in the restoration plan, it is expected that wetland restoration may occur well
beyond the easement boundaries. The applicant should verify that if the restored wetlands
extend into privately-owned land adjacent to the CE, 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.
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 visible in 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.
References: The Beaverdam Creek reference site has a shrub layer "dominated by Chinese
privet, with pockets of Japanese honeysuckle and Japanese stiltgrass" (p. 21). While the
community contains some desirable species, this is not exactly what we're looking for in the
subcanopy of a reference ecosystem. 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 planting plan (Section 10, Table 8) looks like it compares with the reference communities
they discuss, but some of the species are a little different than we usually see in restoration plans.
This is not necessarily a bad thing, but I'd like to look at it side by side with the Schafale &
Weakley lists to determine if there's anything that should/should not be included in the plan.
Success criteria: 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 standard 320 surviving preferred woody stems/acre at
Year 3, 260 at Year 5. The status of volunteers, including invasive species, should be included in
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterquality.org/wetlands
VC,
NC Division of Water Quality
401 Oversight and Express Permitting Unit
the annual monitoring reports. Section 8.4, 1s` sentence, should be revised to say that all
success criteria (not just vegetation) must be met in order for the project to be deemed
successful.
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.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterquality.org/wetlands