20010963 Ver 1_Other Agency Comments_20000713

July 13, 2000
Regulatory Division
Action ID No. 199403552, Wilmington Bypass TIP R-2633C
Mr. William D. Gilmore, P.E., Manager
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Dear Mr. Gilmore:
Please reference the revised mitigation plans that have been provided to our office by your
contractor, Ecobank, Inc. Also reference our letter dated December 17, 1999 in which we
provided comments to you regarding these plans. We also provided, by letter dated
April 10, 2000, comments regarding design aspects of the subject project. We are aware that in
order to meet your current let date you must have the required Department of the Army (DA)
permit by August 1, 2000. I have reviewed the revised mitigation plans and still fmd them to be
deficient in addressing several of our previous comments. As we are being asked to review and
approve the plans in their entirety, all of our concerns must be addressed before we can accept
them as being complete.
With the exception of item (1) below, the following comments pertain to the revised
mitigation plans:
1. A final corrected wetland impact table must be provided.
2. The North Carolina Department of Transportation must demonstrate that it either
owns the entire mitigation tract described in the plan or that the property has been
preserved to our satisfaction prior to permit issuance.
3. Based on our review of the project and our knowledge of the flatwood restoration
sites, we anticipate that the entire Eagle-Brunswick tract will be used for this project.
4. A proposal for the measurement of success of the enhancement areas must be
provided. The information provided on page 11 and page 13 of the Eagle Brunswick
Plan does not provide any information on what will be measured.
5. On page 12 of this plan it states that a 2:1 mitigation ratio was accepted by the
agencies for this project. This statement should be removed from the plan as it is
incorrect.
6. The proposed restoration success criteria are not acceptable. As we have absolutely
no information regarding hydroperiods at the reference site we cannot accept that the
restoration site will exhibit "soil saturation within 12" of the soil surface for at least
50% of the hydroperiod exhibited by the reference site."
7. Vegetative monitoring criteria provided on page 14 does not provide any information
on what species must be present as determined from the reference site. In addition,
you provide no information on plant community composition that currently exists in
the restoration and enhancement areas. This assessment should have been completed
prior to submittal with a plan to provide or augment those species that should be
found in the restoration areas.
8. The center of the Eagle Brunswick tract is not 1.9 miles from the proposed bypass.
This statement must be deleted from the plan.
9. The revised plan for the McIntyre site remains deficient in several areas. The plan
must provide specific and measurable hydrologic and vegetative success criteria as it
relates to the removal of spoil from tidal marsh areas. Overall, the plan indicates that
restoration and enhancement areas will exhibit "similar" tidal amplitudes once the
work is completed on the site. The use of "similar" as a success criterion does not
provide for a measurable goal.
10. The revised plan for the McIntyre Site shows the location of several "tidal creeks". It
is unclear at what frequency these creeks will flood and if they are connected to the
river. It would be beneficial if these creeks would flood over a large portion of the
tidal cycle to allow for the movement of aquatic species into the restored marsh area
as well as providing for some drainage of the site.
11. Success criteria relative to the frequency and duration of flooding on the McIntyre site
still lacks sufficient detail. For example, on page 11 of the revised plan, hydrologic
success criteria are defined as: "Success criteria for these gauges will be the
establishment of a similar hydroperiod with tidal amplitudes at least equal to that of
the reference gauges." As we have discussed on numerous occasions, simple
benchmark elevations of the reference sites with tide data can be used to generate
proposed elevations of the restored sites as well as frequency and duration of tidal
flood events. The proposed success criteria, as described in the plan, do not provide
enough detail to know what the frequency and duration of flooding will be on the site.
We are reluctant to leave this issue unresolved, as it is not a specific goal for which
you can provide quantitative data.
12. Adequate documentation does not exist in the plan to justify why the proposed 25.2-
acre tidal freshwater marsh is classified as restoration. To generate "restoration
credit" for this area, you should document existing conditions relative to plant
community composition and flood frequency and duration to provide specific and
measurable target goals to document the restoration.
13. Measurement of the herbaceous vegetation at the McIntyre site should be performed
as detailed in the attached methodology.
2
Finally, I have attached comments from the National Marine Fisheries Service on the
revised mitigation plan for the McIntyre tract.
Questions or comments may be addressed to Scott McLendon, Wilmington Field Office,
Regulatory Division, telephone [phone].
Sincerely,
FIELNAME:65D7
CESAW-RG-L/M
CESAW- G/F4
MAIL )
CESA =R L
E. David Franklin
Chief, NCDOT Team
Enclosures
Copies Furnished (without enclosure):
Mr. John Hennessy
Water Quality Section
North Carolina Department of Environment,
Health, and Natural Resources.
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Mr. Rob Moul
Land Management Group
Post Office Box 2522
Wilmington, North Carolina 28402
Mr. Alan G. Fickett
Ecobank, Inc
1555 Howell Branch Road
Suite C-200
Winter Park, Florida 32789
Mr. Tom McCartney
United States Fish & Wildlife Service
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh, North Carolina 27636-3726

3
Mr. Ron Sechler
National Marine Fisheries Service
Pivers Island
Beaufort, North Carolina 28516
Mrs. Kathy Matthews
Wetlands Section, Region IV
Water Management Division
United States Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303
Mr. David Cox
Highway Coordinator
North Carolina Wildlife Resources Commission
11411-85 Service Road
Creedmoor, North Carolina 27522
Mrs. Kelly Williams
North Carolina Division of
Coastal Management
1638 Mail Service Center
Raleigh, North Carolina 27699-1638
BCF:
CESAW-RG-L/MCLENDON
CESAW-RG-L/HARRIS
CESAW-RG/FRAANRtIl
4
07!13%2000 T$U 11:07 FAX [phone] NXFS,HCD,BEAUFORT,NC 14001
g UNITED STATES DEPARTMENT OF COMMERCE
< National Oceanic and Atmaapheric A*niniatration
NATIONAL MARINE FGHERIES SERVICE
Southeast Regional Office
9721 Executive Center Drive N
St. Petersburg, Florida 33702
July 13, 2000
Colonel James W. DeLony
District Engineer, Wilmington District
Department of the Army, Corps of Engineers
P. O. Box 1890
Wilmington, North Carolina 28402-1890
Attention Scott McLendon
Dear Colonel DeLony:
Please reference yourJuly 10, 2000, request for the National Marine Fisheries Service's comments
on the North Carolina Department ofTransportation,s (NCDOT) Revised Compensatory Mitigation
Plan for the Mcl ntyre Tract dated June 8, 2000. This mitigation plan is proposed by the NCDOT
to offset unavoidable loss of tidal brackish and freshwater marsh and tidal wooded wetlands
associated with the construction of the Wilmington Bypass (Action ID No. 200001312, TIP No. R-
2633C). We have reviewed the subject plan and offer the following comments for your
consideration.
MITIGATION
Page 129MUaph 1. The statement that all areas will be transplanted with "appropriate vegetation"
is not acceptable. The mitigation plan should be more specific and include a list of all species to be
planted in each area, the percentage of each species to be planted, the source of the transplants, the
season when planting will occur, and the planting strategy. Based on coordination with the Center
for Coast Fisheries and Habitat Research, Beaufort Laboratory, we recommend dense plantings (1-
foot centers) to discourage Phragmites communis from out competing the transplanted target
species.
RESTORATION MITIGATION
Spoil Removal
?age 9• Para arg___nh 2. -,according to the plan, the mixed marsh/cypress/gum mitigation areas will be
6-12 inches higher than the adjacent marsh areas and it is unclear whether they are intertidal.
Because ofthis difference in elevation, we recommend that they be monitored separately from the
tidal marsh components. Also, the plan is not clear whether the mixed marsh/cyprms/gurn
mitigation areas is proposed to offset losses of tidal marsh.
a p
07%13%2000 THU 11:07 F.A% 252 728 8728 NMFS,HCD,BEAUFORT,NC x]002
Berm Breaching
paize 9. paragraph 3. The bottom elevation of the proposed 20-foot-wide breaches should be
specified. We recommend that the breach be excavated to the same elevation as the adjacent marsh.
Vegetation Restoration
Pa e 10 ara h 2. We recommend against planting Typha spp. In addition to the other marsh
species identified in Table 2 for the Tidal Marsh/Scrub Shrub area, we recommend the use ofSeirpus
spp. at the upper elevations and Spartzna alternfflora at the lower elevations. Also, see our
comments on Page 9, paragraph 1 above.
MONITORING PLAN
RESTORATION AND ENHANCEMENT HYDROLOGICAL TIDAL MONITORING
Pie L1• n=agtraph 3. Establishing a "similar" hydroperiod is not an acceptable success criteria-
We recommend the following: Tidal inundation will be established at a frequency and duration
within ten percent of the range of the reference marsh. We further recommend that the location of
the reference marsh be identified in the mitigation plan.
TIDAL MARSH/SCRUB SHRUB VEGETATION MONITORING
Page 12, t)arag h 4, The method to be used to randomly locate sample plots should be identified.
TIDAL FRESHWATER MARSH AND TIDAL MARSH/SCRUB SHRUB ENHANCEMENT
MONITORING
Page 13, paragraph 3. Establishing a "similar" hydroperiod is not an acceptable success criteria,
We recommend the following: Tidal inundation will be established at a fequency and duration
within tern percent of the range of the reference marsh. We further recommend that the location of
the reference marsh be identified in the mitigation plan.
CONTINGENCY PLAN
Pa :c 14 par- ?h 2, The mitigation plan includes a contingency plan, however, no details
regarding the measures to be considered under the plan are included. We recommend that the
mitigation plan include a list ofpossible responses including regrading the site as needed, replacing
lost transplants as needed, the control of invasive species, and measures to improving tidal flushing
if the hydrological success criteria are not met.
07!13/2000 THU 11:08 FAX [phone] NHFS,HCD,BEAUFORT,NC 01003
FINAL PROPERTY DISPENSATION
?a a 15 ara h 15. The amount, activities covered, and holder of the bond must be id
m the mitigation plan and be approved by the Corps Of Engineers before the plan entified
complete. is considered
FIGURES AND TABLES
Table 2
We recommend that this table be revised to delete the use of Typha spp, in the marsh restoration
areas,
We appreciate the opportunity to provide these comments.
Sincerely,
?:
;?r-e'as Mager,
stant Regional Administrator
Habitat Conservation Division
cc: F W-5, ATLA, GA
FWS, Raleigh., NC
EPA, ATZA, GA
NCDENR, Raleigh, NC
NCDENR, Morehead City, NC
F/SER4
Attachment I
DRAFT
4-3-2000
Site Monitoring Surveys for Emergent Marsh Mitigation
Projects Proposed by the North Carolina Department of Transportation
Using Random Sampling with Geographical Information Systems ((3IS),
Geographical Positioning Systems (GPS) and the Braun-Blanquet Method to
Estimate Frequency(Survival) and Percent Cover
The National Marine Fisheries Service and the US Army Corps of Engineers (COE) collaborated
to collect and analyze data from the COE's Reserve Lerner Marsh Mitigation Site (size = 2,6
acres) located in the Newport giver, just north of the North Carolina State Port. The objective
was to develop a scientifically valid vegetative sampling procedure for marsh mitigation sites,
High variability in the vegetative cover often characterizes newly constructed marsh mitigation
sites. The number of samples and sample plot size to provide a statistically valid sampling
procedure was determined using a Monte Carlo Simulation Model. Moreover, the use of GIS
software and GPS technology was determined to be a practical and efficient method of mapping
the site and locating the sample plots with a reasonable amount of effort by the monitoring team.
]Based on this study our recommendations are as follows:
1- Sample plot size is one square meter. We recommend constricting the sampling apparatus
with PVC pipe.
2- Forty (44) sample plots are examined for each 2.6-acres of project area or.15.4sample plots
per acre. Pending additional data collection, a simple ratio can be used. to determine the number
of sample for sites larger than 2,6-acres. For example, an 8-acre site will require 123 sample plots
3. Pending additional data collection, we recommend a minimum
less than 2.6-acres regardless of the size area sampled of 34 sample plots for projects
4. A GIS data base may be used to map the coordinates for the perimeter of the area to be
sampled.
5. GIS software may be used to generate coordinates for the centers of a meter square grid
overlay of the project area.
6. GIS software may be used to randomly select the required number of sample plots
(coordinates) within the project area_

07%0 ' 6•'000 THL 09:25 F_A13 252 728 8723 \HFS,HCD,BEAUFORT,tiC
? 003
7. Monitoring of the marsh mitigation should be completed on an annual basis for a period of five
years. Because a new set of random sample plots is required for each sampling effort, we
recommend that four additional sets of sample plot coordinates be generated for future use.
Vegetative monitoring will occur at the end of the growing season. (August-September) each year.
8. Selected sample plot coordinates may fall outside of the staked limits of the project area.
Therefore, extra sample plot coordinates should be included with each set. If a sample plot is
determined to be outside of the project area then the next available extra sample plot coordinates
should be substituted to provide the required number.
9. GPS software can arrange the sample plot coordinates sequentially throughout the site to
minimize search time and this data sct can be downloaded into GPS instrumentation.
10. A two man crew consisting of a surveyor/GPS technician and a biologist can accomplish the
required sampling. The surveyorhechnician navigates to the coordinates for each site. Precise
accuracy in identifying the center ofthe sample plot is not required for this technique.
Accordingly, when the plot location is determined plus or minus one foot (0,30 meter) the spot
should be marked and sampled without further effort.
11. The one meter square quadrat is centered on each sample plot and the Braun-Blanquet (B B),
Attachment A method is used to estimate frequency (survival), density and/or percent cover.
12. The B -B method is a quick visual estimate of frequency (survival), density and percent
cover within each one meter square sample plot and the entire site. See Attachment II and the
Murdoch Visual Estimation Percentage Chart (MVEPC), Attachment III, for additional
information on this vegetative sampling technique. prior to conducting the sampling, the observer
should familiarize him/herseif with the MVEPC, and practice observing the range of coverage:.
conditions (e.g. 0.100%) that may be-encountered in the field. Also, those conducting. field
surveys should practice together to develop a common search image.
13. Monitoring is required at the end of each growing season for a period of five years or until
the survival and success criteria are met.
14. Visual Percentage Estimates are determined for each square meter sample plot by using the
MVIIPC and sampling strategy outlined above.
15. Estimations of frequency of occurrence (survival), abundance and density shall use the
procedures specified in Attachment If and III.
16. This guidance deals exclusively with evaluating the success of the vegetative component of a
marsh mitigation site. Other success criteria such as hydrology and fauna reestablishment may be
added as needed to determine the .overall success of a specific site-
`0
7 2
Frequency of Occurrence (Survival) of the transplants must be at least 700/a at the end of the first
and each subsequent growing season. If survival is less than 70%, replanting is required to
reestablish the transplants. Alternative survival requirements can be identified in the mitigation
plan on a site by site basis.
Survival = number of occupied quadrats/total number of quadrats x 100
VEGETATIVE CE4R CRITERIA
A For sites where a reference marsh is not used as a comparative measure of success, the
establishment of vegetation will be considered successful when the sum of the B-B values divided
by the total number of quadrats is equal to 5.0 (7554 cover) on the B -B scale provided in
Attachment H at the end of the fifth growing season.
Vegetative success estimate = sum of the B-B values / the total number of quadrats
This calculated value must be equal to or greater than 5.0 which is equivalent to 75% coverage on
the B B scale at the end of the fifth growing season.
13- For sites where a reference marsh is used as a comparative measure of success, the
establishment of vegetation in the mitigation sites will be considered successful if the calculated
value for density at the transplant site is equal to or greater than 7S% of that calculated value for
density at the reference site at the end of the fifth growing season.
Vegetative Success is calculated as follows:
Site A (Mi igation Site)
Density = sum of B-B scale values / total number of quadrats
Site B (Reference Marsh Site)
Density = sum of B-B scale values / total number of quadrats
Density for Site A / Density for Site B x 100
To be considered a vegetative sings this value must be equal to or greater than 75% at the end
of the fifth growing season.

" C -
?ENCY

Il; at the end of the monitoring program, success criteria have not been met for either the
vegetative or hydrological component (if one exist), the applicant will consult with the US Army
Corps of Engineers and other appropriate state and federal agencies to determine specific causes
and appropriate remedial actions.
s

ti
Attachment II

DRAFT
4-3-2000
Synopsis of Braun-Blanquet Technique (Braun-Blanquet,1 1965. Plant
Sociology: The study of plant communities: translated, revised and edited by C.D.
Fuller and H.S. Conrad. Hafaer, London.)
The Braun-Blanquet (B-B) coverage abundance scale is computed by placing a one meter squared
quadrat centered on the randomly selected sample sites within the mitigation area. (Pending
additional data collection, we recommend 40 samples per 2.6-acres and a minimum of 30 samples
regardless of the size of the site.
Each quadrat is visually inspected (Attachment p and a cover-abundance scale value is assigned
to the marsh coverage within the quadrat.
The scale values are:
0 = none
0.1 = solitary stem with small cover
0.5 - few stems with small cover
1.0 - numerous stems but with less than 5% cover
2.0 = any number of stems but with 5-25% cover
3.0 = any number of stems but with 25-50•/ cover
4.0 = any number of stems but with 50-75% cover
5.0 = any number of stems but with > 75% cover
From the random survey of quadrats, frequency of occurrence, abundance and density of marsh
can be computed as follows:
Frequency of Occurrence = number of occupied quadrats / total number of quadrats
Abundance = sum of B-B values / number of occupied quadrats
Density ?- sum of B -B scale values / total number of quadrats
The above values can be used as follows:
1. As a means of assessing survival, post-planting
2. As a means of documenting compliance, after specified time periods, with previously
established performance criteria
3. As a comparative basis among sites.
4
Oe 2c,
o r ercer«gge Ch
F ?
Marine and Freshwater Murdoch University
Research Lgbot'atOry. Enyk'On(tlentel6clenC4
Mufd6ch, Weatem Auatram 6 160
Produccd by tfic S2 group (Segrass Rehabilitation)? S WO soato v{auaiParccrtaoeEatImatfortCMft6
(Ment)
A try K B
¦
I
C D
6%
A Ig? B A B A $ kAl
C
D C D C
1096 t5? b
A fft? 909
B A $ AfIr-gOOM B
3:25-50%
C
A
4: 54-75%
C
A
{
S
C
f __ 4
a-=--1 D C
8096
A
;0%

80%
90,1110
DI
B
D
B A
D C
D
•60%
B
D
1QQ%