20100952 Ver 1_Staff Comments_20101207

Kulz, Eric
From: Kulz, Eric
Sent: Tuesday, December 07, 2010 8:59 AM
To: 'Tugwell, Todd SAW'
Cc: Wiggs, Linda; Johnson, Alan; Turlington, Chad
Subject: Mitigation Site Applications
Todd
Here are comments/issues with EEP projects currently in review:
DWQ #10-0952 UT to Martin Creek - Cherokee Co. (EEP DBB)
As we briefly discussed last week, this is a large project involving a lot of preservation. Most of the project looks good,
and I have no issues with the proposed mitigation activities. The concern lies with the E2 of the main stem of Martin
Creek. This reach lies within a overhead power line easement (the stream runs more or less parallel to the long axis of
the transmission line), and a road also converges to within <10' of the stream channel. I'm not sure where we are
headed regarding the policy on utility easements, but as we discussed, it is likely that this entire reach will not meet the
default veg criterion (260 spa, wooded buffer).
DWQ #10-0982 Branson Creek - Cumberland Co. (EEP DBB)
We also discussed this one last week. This project has a lot of constraints, and If we were brought out here early on in
the process, we might tell them that this is not a good site to provide mitigation.
Specific issue include; only 650 If of restoration, the remainder is E2 (involving privet removal, which will unlikely be
successful in the long run). However, they want 2,360 If of stream credit (1:1). 1 don't see how we can approve that. By
my calculation, using 2.5:1 to calculate enhancement credit, the best potential yield would be 261 If + 388 If +1,384/2.5
= 1,202.60 stream credits. However, easement/buffer width would be an issue.
Section 2.8.2 describes some potential easement and site access issues, and it appears that these have not even been
worked out yet.
Section 2.8.5 describes a gap in the easement that they apparently weren't aware of when the project was instituted.
Section 4.0 indicates the reference stream is in Polk County (Mountains). Not appropriate for a stream restoration
project in the Sandhills/CP.
Section 6.1 shows a discrepancy in the requested credits; they calculated 2,033 SMUs, whereas earlier in the report they
calculated 2,360 SMUs.
Table 1: By my calculation, using 2.5:1 to calculate enhancement credit, the best potential yield would be 261 If + 388 If
+1,384/2.5 = 1,202.60 stream credits. However, easement/buffer width would be an issue.
DWQ #10-0994 North Fork Mountain Creek - Catawba Co. (EBX/EEP Full-Delivery).
No restoration plan sheets included with the report. We are putting on hold for that.
The project is proposing 3.44 acres of riparian wetland restoration; however, the restoration areas are mapped
Chewacla soils, and limited soil borings (Section 2.3) hydric soil indicators are present between 20 and 30 inches below
the land surface. Not sure if these areas were ever wetlands
Todd, I assume we are going to discuss at least some of these issues at the IRT this week. Maybe you and I can discuss
the others, as I need to take some kind of action (e.g. issue or put on hold) for the DBB sites this week.
Eric
Eric W. Kulz
Environmental Senior Specialist
N.C. Division of Water Quality
401 Oversight and Express Permitting Unit
1650 MSC
Raleigh, NC 27699-1650
Phone: [phone]
Fax: [phone]
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