Loading...
HomeMy WebLinkAbout20130411 Ver 1_USFWS Comments_20130531United States Department of the Interior FISH AND WILDLIFE SERVICE Raleigh Field Office Post Office Box 33726 Raleigh, North Carolina 27636 -3726 May 16, 2013 Mr. Andrew Williams, Project Manager Wilmington Regulatory Division U. S. Army Corps of Engineers 3331 Heritage Trade Drive, Suite 105 Wake Forest, NC 27587 13-d�q 17, _., MA Y 2013 i�tlan d � W/' Subject: Wildlands Engineering, Inc.: Lower Swepsonville Dam Mitigation Bank Draft Prospectus Dear Mr. Williams: This responds to Monte Matthews' email of April 17, 2013, requesting comments on the draft prospectus for Wildlands Engineering Inc.'s Lower Swepsonville Dam Mitigation Bank. The U.S. Fish and Wildlife Service (Service) has reviewed the draft prospectus, and attended a meeting to discuss the project at the Corps office on May 13, 2013. Kathy Matthews will be the Interagency Review Team (IRT) member for this mitigation bank. At the May 13, 2013 meeting, Kathy provided copies of the Service's "Haw River Sediment Quality Assessment" (July 2011), and a "Preliminary Sediment Survey" (August 28, 2008), which was prepared for the Service by Restoration Systems. At this time, the Service does not have any concerns for impacts to federally- listed species from this project. Our concerns relate to consistency with other proposed dam removal projects, and potential impacts to downstream habitat and fisheries from contaminated sediment. 1. The South Burlington Wastewater Treatment Plant (WWTP) is located within the impoundment of the dam in Big Alamance Creek. The Service is concerned about potential ramifications to the WWTP's NPDES permit limits, as well as potential water quality and sediment impacts from the WWTP. We recommend that the facility's NPDES permit be examined to determine whether the permit limits were formulated assuming impoundment of Big Alamance Creek, or low flow of the stream. The Service's 2011 sediment quality assessment indicated acutely -toxic contamination downstream of the WWTP. The sediment removal management plan for the mitigation bank should include sediment testing within the impoundment and consultation with the resource agencies to determine whether sediment should be removed. 2. At the May 13, 2013 meeting, the sponsor indicated that more conservation easements may be purchased along the impoundment. The Service recommends that in order to receive credit for the approximately 2,570 linear feet of tributaries proposed, the tributaries should be protected with conservation easements and a 50 -foot forested buffer on each side of the channel. We also encourage the establishment of 50 -foot forested buffers and conservation easements on as much 2 of the Haw mamstem and Big Alamance Creek as possible Even with forested buffers and conservation easements, the Service would be concerned about allowing 1 1 credit ratios for tributary reaches that are deeply incised We look forward to viewing the impounded areas and discussing potential credit ratios at that time 3 In general, the Service does not have concerns with structuring available credits around goals of the project (reestablishment of flow, water quality improvement, fish passage, etc ) However, we caution that all goals and success criteria should be quantifiable and reasonable, and the amount of credits offered for reaching the goals should be appropriate for the level of effort and measured level of improvement We look forward to discussing potential goals, success criteria, and available credits 4 The Service anticipates that the mitigation plan will include, at a minimum, proposals for monitoring of water quality, sediment quantity, quality, and movement, vegetation recruitment and invasive plants, shoreline stability, fish passage, and habitat quality In addition, remedial plans should be included, should the provider fail to meet stated goals and success criteria, or if adverse impacts are discovered Thank you for the opportunity to comment on this project We look forward to the field visit and future opportunities for input If you have any questions concerning these comments, please contact Kathy Matthews at (919) 856 -4520, Ext 27, or by e -mail at <kathryn_matthews @fws gov> Sm Dl�, �r , Pete B amm Field Supervisor cc Todd Bowers, USEPA Rosemary Hall, USEPA "Sue Homewood, NCDWQ Eric Kulz, NCDWQ -Dolores Hall, NC Office of State Archaeology Shari Bryant, NCWRC 13 March 2013 Swepsonville Dam Site Removal Project Pre - application Meeting I/ i�_ Ozq [ � - -Much of the information that was discussed and determined to be necessary for the Hoosier Dam will apply to the Lower Swepsonville Dam. Swepsonville- intercepted level was less on this project than Hoosier; - -upper Swepsonville dam may be removed this summer as a separate project. - -Lower Swepsonville —8 feet high Powerhouse is located offline and was closed in 1970. - -Will most likely use existing drop gates to dewater. -- Impoundment extent was determined by LIDAR and existing FEMA cross sections. - -dam was constructed between 1880 and 1900. - -Shari mentioned that available records indicate that there are currently no state or federally listed T &E species within footprint of the proposed bank or up or downstream for a considerable distance. - -group discussed current low water quality within this section of the Haw /Big Alamance due to current land use and existing WWTP. - -group discussed even if habitat for T &E were re- established within footprint of bank, would or could the species actually re- establish within footprint of bank. - -John stated that they would conduct surveys for site and upstream and downstream. -- Travis stated that the IRT needs to establish if there is a reasonable expectation for the targeted species to return. - -The goals of bank need to be revised to reflect the dam removal guidance (rescinded). - -Group discussed WWTP located on Big Alamance and need to coordinate with them regarding the discharge, NPDES permit, receiving waters, etc. - -Kathy mentioned there were some contaminated sediments below the WWTP. Also mentioned existing report on sediments located behind Lower Swepsonville Dam. - -group discussed existing Golf Course near dam. John stated they have an intake for water withdrawal but does not have the amount they use at this time.