20120773 Ver 1_Comment Memo Mit Plan Review_20120823

REPLY TO
.ATTENTION OF
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403 -1343
CESAW- RG /Crumbley August 24, 2012
SUBJECT: NCIRT Comments During 30 -day Mitigation Plan Review
Purpose: The comments listed below were posted to the NCEEP Mitigation Plan Review Portal
during the 30 -day comment period in accordance with Section 332.8(8) of the 2008 Mitigation
Rule.
NCEEP Project Name: Jacobs Landing Stream Mitigation Site (EEP -IMS# 95024)
USACE AID #: SAW 2012 -01006
30 -Day Comment Deadline: August 23, 2012
1. 8/22/2012- N.C. Division of Water Quality; Eric Kulz: This project consists of a significant
amount of Priority 2 Restoration. Our mitigation study revealed a lot of problems with
P2 sites in the Piedmont, specifically related to vegetation survival and growth. The
Provider needs to provide more details on topsoil management and addressing
potential compaction and fertility /organic matter issues. 2) The plan shows a number of
drainage ditches entering the easement from pasture areas. The plan proposes to
stabilize with riprap and discharge directly to the stream. These discharges may include
cattle waste and have the potential to compromise water quality and reduce the
potential for the project to provide uplift. Routing of this runoff to floodplain wetland
pools for retention /infiltration should be considered, as NCEEP has been using these on
projects for a number of years.
2. 8/22/2012- U.S. Environmental Protection Agency; Jeffrey Garnett: I agree with both
points made by Eric Kulz. With the amount of excavation involved with Priority 2
restoration, the Provider should present a soil management plan. This should primarily
include the stockpiling of topsoil and redistribution of it on top of other fill. The mixing
of soil layers could prove detrimental to vegetative success. Additionally, the plan calls
for at least four reconstructed culverted crossings. I request that the Provider submit
detailed plans of culvert installations that adequately ensure that passage for aquatic
life is achievable. Finally, one of the goals of the project is to "reduce the sediment
supply entering Irish Buffalo Creek." Monitoring channel forms over the first five years
of the bank only serves as a surrogate that sediment loads are decreasing. The

assumption is being made that improving the channel will reduce sediment loads, but
no quantifiable way to test this is being presented. The Provider should develop a
quantifiable plan to directly measure success of the project goal. For example, simple
turbidity measurements could be taken on a regular basis (during base flows and bank
full events) both upstream and downstream of the site. These measurements should be
taken before restoration, during restoration, and for a minimum of five years post-
restoration in order to document achievement of the goal.
3. 8/23/2012 -U.S. Army Corps of Engineers; Tyler Crumbley and Todd Tugwell:
a. Please ensure that the performance standards for channel dimension [(as described
in Sections 9 and 10 of the document (pgs. 34 -37)], are in accordance with the 2003
Stream Mitigation Guidelines (1 cross - section per 20 bankfull width lengths) and that
the performance standard for Bed Materials is instituted to show a change to a pre-
determined desired composition, rather than purely an evaluation of sediment
transport.
b. Where possible, easement crossings should be made at a perpendicular angle.
Exception 1 on easement B could be modified to reduce loss of the buffer.
Additionally, it appears that the dirt path crosses through the conservation
easement (Sheet 1 of 1, Final Plat).