HomeMy WebLinkAbout20070833 Ver 1_USACE Correspondence_20100514REPLY TO
ATTENTION OF:
Regulatory Division
Action ID. 2000-0985
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Mr. David Ashcraft
N.C. State Natural Resources Foundation, Inc.
Campus Box 8010
Room 3060, Biltmore Hall
Raleigh, North Carolina 27695
Dear Mr. Ashcraft:
This letter serves to confirm our evaluation, through coordination with the Interagency
Review Team (IRT), of your March 2, 2010 monitoring report (Year 4) for the Hofmann Forest
Wetland Mitigation Bank (Hofmann Bank) in the Hofmann State Forest, adjacent to the White
Oak Pocosin, north of Jacksonville, Onslow County, North Carolina. Please reference our May
22, 2009 letter concerning the 3rd year monitoring report.
As discussed in the May 22"d letter, our office shared concerns relating to the hydrologic and
vegetation success criteria being satisfied for certain portions of the bank site. Specifically, the
vegetative plots 1_1, 1_4, & 1_12 in Block 1 and plots 2_5 and 2_7 in Block 2 were on target for
failing, or have failed, to meet the required 260 planted trees per acre at the end of the 5-year
monitoring period. The Year 4 report shows that all of these plots, with the addition of 1_10 in
Block 1, have exhibited a survival rate less than the required amount of 260 trees/acre. In Blocks
1 & 2, the trees were planted in 1999 and the initial hydrology modifications were in place in
2004, with additional plugs installed in 2007. Supplemental plantings in Block 3 and the initial
plantings for Block 4 & 5 took place in early spring of 2005, which completed the initial
construction phase for the entire bank and secured the 2006 growing season as the first
monitoring year. In summary, the planted tree stems for Blocks 1 & 2 have been in place and
monitored for approximately 10 years, with hydrology restoration for these two blocks in place
for 5-6 years. Upon acknowledging the shortfalls of the identified vegetative plots, our overall
position, after reviewing previous reports and conducting several onsite observations, is that
Blocks 1 & 2 are moving toward reaching the established success criteria for the targeted plant
community. Therefore, no remedial or contingency action is necessary at this time. Monitoring
of the planted stems and volunteer species will continue for the 2010 growing season, and no
modifications to the sampling method and/or presentation of data in the reports are required at
this time.
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
May 12, 2010
11
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For the hydrology component, the water level trends for (4) wells, Block 1 North, Block 2
North, Block 4 North, and Block 4 South, raise greater concerns in meeting the success criteria.
Specifically, Block 2 North has not met the requirement in the last 3 seasons. Although this well
is meeting wetland jurisdictional status by definition, it fails to meet the established threshold of
12.5% of the growing season set forth in the restoration plan. The summary table in the Year 4
monitoring report shows that this well cumulatively shows saturated/inundated conditions for
just over 9.0% of the growing season. In my discussions with Mr. Glen Catts of your office, it
has been decided that an additional well will be placed near Well Block 2 North location for
calibration, and to determine if the installation and/or location is a factor for this shortfall. For
Block 1 North and both wells in Block 4, their water level readings exhibit success only during
periods of above normal rainfall conditions. Hydrograph results show quicker and deeper than
expected draw downs after most rainfall events. It has been determined that an additional well
will also be installed, at a depth less than 20 inches from the surface, near Block 4 North
location. This is expected to help determine if the present wells in this block are installed too
deep and have intercepted the sand lens, or if the block is being affected by existing ditches.
Reference our previous responses to years 1-3 for our concerns on the well data.
Pursuant to the May 20, 2008 letter detailing the modified credit release schedule, 15% of
the total credits are eligible for release after year 4 monitoring. At this time, our office has
determined that 6 of the 10 hydrology wells have conclusively met the success criteria, with
Block 2 North solidly falling short and Block 1 North and all of Block 4 remaining in question
for long-term success. It has been concluded that, with the continuing uncertainty of the above
mentioned wells, only 8% (or 31 credits) of the 15% eligible credits will be released. To date,
this brings the cumulative amount of credits released from Hofmann Bank to 282 credits. Please
be reminded, as stated in the May 22nd letter, that 5% (or 20 credits) of the credits were withheld
for similar reasons. These 20 credits, coupled with the 27 credits (or 7%) above, will continue to
be ineligible for release until further assessments conclusively demonstrate hydrologic success
for the questionable wells. Our intentions of withholding credits are to ensure the long-term
sustainability of the site meeting its goals and objections as a compensatory mitigation bank.
Please be reminded of your obligations pursuant to the 24 May 2004 Mitigation Banking
Instrument (MBI); and to continue maintenance inspections of the check dams and culverts
throughout the bank in order to evaluate the condition and stability of each structure in
perpetuity. Should you have any questions, please contact me at (910) 251-4811.
Sincerely,
Mickey Sugg, Project Manager
Wilmington Regulatory Field Office
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Copies Furnished:
Mr. Glenn Catts
Hofmann Forest Liaison
College of Natural Resources
North Carolina State University
2023 Biltmore Hall
Raleigh, North Carolina 27695
Mr. Pete Benjamin
U.S. Fish and Wildlife Service
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh North Carolina 27636-3726
Ms. Maria Dunn
N.C. Wildlife Resources Commission
943 Washington Square Mall
Washington, North Carolina 27889
Ms. Molly Ellwood
N.C. Wildlife Resources Commission
127 Cardinal Drive Extension
Wilmington North Carolina 28405-3845
r. Tammy Hill
ivision of Water Quality
N.C. Department of Environment
and Natural Resources
2321 Crabtree Boulevard
Raleigh, North Carolina 27604-2260
Mr. Ron Sechler
National Marine Fisheries Service
Pivers Island
Beaufort, North Carolina 28516
Mr. Howard Hall
U.S. Fish and Wildlife Service
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh North Carolina 27636-3726
Ms. Becky Fox
U.S. Environmental Protection Agency
Wetlands Regulatory Section- Region IV
1349 Firefly Road
Whittier, North Carolina 28789
Mr. Stephen Everhart
N.C. Division of Coastal Management
127 Cardinal Drive Extension
Wilmington North Carolina 28405-3845
Ms. Tere Barrett
N.C. Division of Coastal Management
400 Commerce Avenue
Morehead City, North Carolina 28557-3421
Mr. John Domey
N.C. Division of Water Quality
2321 Crabtree Boulevard
Raleigh, North Carolina 27604-2260
Mr. Steve Sollod
N.C. Division of Coastal Management
1638 Mail Service Center
Raleigh North Carolina 27699-1638