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HomeMy WebLinkAbout20130412 Ver 1_Public Notice Comments_20140722WILDLANDS ENGINEERING July 21, 2014 Mr. Andrew Williams U.S. Army Corps of Engineers Raleigh Regulatory Field Office 3331 Heritage Trade Drive, Suite 105 Wake Forest, NC 27587 Subject: Response to Public Notice Comments Hoosier Dam Mitigation Bank Wildlands Engineering Project No. 005 -14005 Dear Mr. Williams, JUL 2014 We have reviewed the comments from the public notice period for the Hoosier Dam Mitigation Bank dated June 5, 2014. Below are the responses to each of the regulatory agency comments. For your convenience, the comments are reprinted with our responses in italics. Comments by Karen Higgins, NCDENR April 15, 2014 I. The majority of the proposed mitigation units (Table 3) are based on improving the water quality of the Rocky River and its tributaries. Monitoring (both pre- and post - removal) should be performed to assess water quality and aquatic function of the impounded reaches and their post- impoundment condition. Physicochemical monitoring should follow up on temperature and nutrient data collected and presented in the Prospectus. Extensive baseline and post -dam removal monitoring programs have been developed for the Hoosier Dam Mitigation Bank based on previous dam removal projects and input from the US Fish and Wildlife Service. A supplemental monitoring document has been attached, which will be included in the Final Mitigation Plan. Water quality monitoring protocol and associated success criteria are located in Sections 2.1.2 and 2.2.4. Monitoring will be done seasonally each monitoring year at seven stations and include sampling of temperature and dissolved oxygen, as the goals of the project is to ameliorate temperature and dissolved oxygen stratification within the previously impounded sections of the Rocky River. Biological monitoring should focus on improvement of water quality through conversion from a lentic to a lotic system. Parameters for monitoring should include macrobenthos and fish. Performance standards should be crafted to document improvements in physicochemical parameters and to the biotic community. Meeting each individual performance standard over the course of the monitoring period should have an associated percentage of the total water quality improvement credit. Aquatic biological community sampling protocol and success criteria are described in Sections 2.1.4 and 2.2.2 in the attached supplemental monitoring document. Sampling will include macroin vertebrates, snails, mussels and fish surveys along with habitat evaluations at each sampling station. Wildlands Engineering, Inc. • phone 919- 851 -9986 • fax 919 -851 -9987 • 312 W Millbrook St Suite 225 • Raleigh, NC 27609 DWR recommends consulting the Milburnie Dam Draft Mitigation Plan dated March, 2014 for an example of performance standards and associated credit yield. While the performance standards and credit yield presented in this plan may not be appropriate for the Hoosier Dam project, the concepts may provide useful in development the Hoosier Dam mitigation plan As the M►Iburn►e Dam Draft Mitigation Plan is not an approved document it could not legally be made available to .Wildlands. To mitigate this, W►Idlands ►s consulting with the IRT agencies on aspects of the M►Iburnie plan they wish to include on ,this project 2. The total proposed potential credit for the project raises a concern that has been the topic of discussions among the IRT in the past Specifically,, if it is appropriate for the DE to allow for more credit to be generated by a dam removal project than the amount of the mitigation that would be required if the dam was constructed now , The mitigation plan (Table 3) indicates the total maximum potential credit'for the project is 24,105 LF (24,105 credits) The impounded reach of the river and associated tributaries has been calculated to be 22,425 LF If the project were proposed today, based on DE requirements on other impoundment projects, the mitigation required would likely be as follows- Impact Type Impact Amt (LF) DA Multiplier Mitigation Requirement Fill (Dam Footprint) 200 Lf* 2 1 400 LF Inundation 22,225 LF 1 1 22,225 LF Total Mitigation, Required 22,625 LF *Approximate based on aerial photography According to the proposed maximum potential credit from the mitigation plan, the Sponsor would potentially be awarded 1,480 more Jinear,feet of credit (24,105- 22,625) than the mitigation that would potentially be required to permit the construction of the dam and impoundment of 22,425 LF of river and tributaries As this issue has not.been resolved, this should be discussed by the IRT at the next regularly scheduled meeting. The additional credits requested by the Bank Sponsor reflect the proposal for the establishment of riparian buffer conservation easements along Rocky River,and its tributaries as discussed in Sectiom3 2 4 of the Prospectus The easements, on lands already purchased by the Sponsor, will protect over 35% of the riparian buffer along the Rocky River within the bank limits, 100% ofithe riparian buffer along Tributaries 3 and 4, and 33% along Tributary 2 (tributary credit will be requested only in cases where an easement can be recorded on both sides) Wildlands and the Bank Sponsor agree that the easements are ►mportant'in protecting this water resource during its conversion from .a lotic to lentic system and in perpetuity to protect Cape Fear shiner habitat. The Bank Sponsorvntends to protect the riparian buffers along their properties during their ownership,of the lands, however, only a conservation easement will ensure permanent,protect►on. The Sponsorrequests compensation for easements in the form of Mitigation Credits If no credits are awarded, easements will not be recorded on the Rocky River as proposed and the credit request will be altered 3. Monitoring'activities should also include stability monitoring of all formerly - impounded tributaries proposed for credit Lowering of the water level after dam removal has the potential to expose unvegetated streambanks, which could result in streambank erosion /headcutting As described in the attached supplemental monitoring plan (Sections 2 1 1 and 2 2 1), geomorphic monitoring stations will be established on all tributaries where credits are requested, spaced 25 bankfull widths apart These stations will be monitored directly after�dewotering and then annually during the monitoring period. 4 The standard service area for mitigation banks in North Carolina is the eight -digit HUC in which the bank is located The location of the bank site at the southeastern end of 0303003 and its close proximity to 0303004 makes the proposed service area feasibly DWR would support the primary service area for this bank to include all of 03030003 and the Piedmont portion of 0303004 T,he,proposal is to include only the Piedmont portion, of 0303004 in the bank service area This will be made clearer in the text and figures of the Mitigation Plan Figure 3 from the Prospectus will be altered to highlight this distinction 5 We strongly encourage the bank,'Sponsor to Continue to acquire property along,the Rocky,River,and associated bank tributaries, and inclusion of such lands within the bank conservation easement The Bank Sponsor continues to pursue the purchase of land along the impoundment of Reeves Lake They have recently purchased two parcels along the right bank of the impoundment approximately 2;500 linear feet upstream of the dam and adjacent to previously purchased parcels. As long as mitigation credits will be awarded for conservation easements, as discussed in the response to above Question 2, they will be Included in the Hoosier Dam Mitigation Bank Comments from Shari Bryant, NCWRC April 10, 2014 1 Section 1.0 Introduction (p 1) "The dam impounds approximately 22,425 feet of Rocky River and six perennial tributaries" This sentence is confusing because it can be read that the dam impounds'22,425 feet of Rocky River We suggest this sentence is changed to reflect that the dam impounds 16,060 linear feet of Rocky River and 6,365 linear feet of perennial tributaries This language will be clarified in the Mitigation Plan ,2 Section 13, Bank Objectives (p 2 -3): Table 1 describes the bank goals and methods of achievement Six goals are listed forthe bank, however, several of these goals,,are, restatements. For example, goals 2, 3, and 6 all refer to restoring natural flow regime, managing sediment, and or /improving habitat In comments from the USACE on the Draft Prospectus, they requested that we "reword and restructure [our] bank,objectives to match those deemed applicable within the, 2008 [Dam Removal],Guidance because those objectives reflect successful targets identified years ago by the resource agencies" For that reason, the Bank Objectives Section is presented in the format seen in the Final Prospectus 3 Section 2.2, Assurance of Sufficient Water'Rights (p.4). Indicated'the hydro faality,was bought by the Bank Sponsor The FERC library does not show any records of transfer of the exemption. Please provide additional information regarding the transfer of the FERC exemption between the previous owner and the Bank Sponsor A letter notifying FERC,of the change in ownership was submitted by Timothy Sweeny on May 14, 2014 Mr Sweeny has since received notification that it was accepted by FERC and should now show up in the library 4 Section 2 3, Proposed Service Area (p 5) The bank Sponsor is requesting the proposed service area for this mitigation bank include Cape Fear HU 03030003, and the urban growth areas,of Cape Fear HU 03030004 The Bank Sponsor indicates these two HUs have the same physiographic characteristics and the HU boundary is arbitrary Generally, we believe the service area should be designated based on the location of the mitigation bank (i a Cape Fear HU 03030003), and using credits outside of the service area should be determined on a case -by -case basis However, if additional information is included that documents the physiographic and ecological similarities between the original HU and the urban growth areas of Cape, Fear.HU 03030004, then it can, be considered The draft mitigation plan will Include a section that describes the similarities be HU 03030003 and the urban growth areas within the piedmont of HU 03030004 in order to-supplement our request for,the applicability of the mitigation bank to both service areas 5 Section 2 4 2, Feasibility (p,7) Under Phase III it indicates removal of the remaining portions of the dam Although it,appears'to be indicated in previous sections (e g Section 10), we recommend the entire powerhouse is removed as well as the dam The entire powerhouse will be removed with the dam This will be explained clearly In the demolition plan within the Mitigation Plan 6 Section 2.4.2, Feasibility (p 7) Under Phase III it-indicates removal of the remnant rock dam upstream of Hoosier Dam The boulders from this dam would be incorporated into habitat enhancement measures on Rocky River We recommend the boulders are placed to mimic natural stream conditions and appropriate instream habitat rather than randomly placing the boulders in the stream channel Care will be taken to place remnant rock,material throughout the drained impoundment region /n such a way that it mimics naturally occurring rock features on other portions of Rocky River. 7 Section 3.2, Baseline Site Conditions (p.8): A discussion of the baseline site conditions'is included for water quality and'threatened and endangered species However, there is no discussion of the existing aquatic community (i e, benthic- macroinvertebrates, fish, and freshwater mussels) Baseline (i e , pre - removal) data for the aquatic community should be collected to develop success criteria and document the specific changes that occur in the aquatic community following dam removal The pre--removal (baseline) and post - removal survey designs should be coordinated with the IRT prior to data collection to ensure appropriate data is collected to document success criteria have been met. Pre - removal and post - removal data should be collected in Rocky River and any tributaries where mitigation credit' is sought All surveys should be conducted by biologists with both state and federal endangered species'permrts Also, exotic aquatic or terrestrial plant or animal species ('e g., flathead catfish) that may be present within the mitigation bank, or that may be introduced to the mitigation bank by removal of the dam should be identified An extensive biological monitoring plan Including baseline and post -dam removal has been developed based on previous dam removal projects -and Input from the US FWS Wlldlands has attached this plan that discusses each of these concerns Including monitoring protocol, success criteria, and the handling of endangered species by companies with state and federal endangered species permits This discussion can,be found in Sections 2.1.4, 222and22.3 8_ Section 3 2 4, Existing Riparian Buffer Vegetation (p 8 -9) The, Bank „Sponsor Indicates approximately 35% of the riparian buffer along Rocky River within the bank limits has been purchased or protected In addition, 100% of the, buffer along Tributaries 3 and 4, and approximately 33% of the buffer along Trubutary 2 has been purchased and protected. Information regarded how these riparian buffers are protected (e g. permanent conservation easement) should be included. Please refer -to the response to the NCDENR comment #2 The land has been purchased by the Bank Sponsor If mitigation credits are awarded for the establishment of conservation easements, then the Bank Sponsor will place conservation easements along the,Rocky River according to the percentages described above Conservation easements will be recorded on both sides of any tributaries for which credit is requested Final copies of these easements will be provided in the final mitigation plan 9 Section 3 2 5, Water Quality (p 9): Baseline water quality data was collected in the summer of 2013 within the reservoir, upstream of the reservoir, and downstream of'the,dam It is likely additional water,quality sampling will be needed to establish an adequate baseline. In addition, specific water quality improvements that will be achieved by removal of the dam (i e , success criteria) should be defined The pre - removal (baseline) and post - removal survey designs should be coordinated with the IRT prior to data collection to ensure appropriate data is collected to document success criteria have been met Also, in addition to collecting water quality data in'Rocky River; pre- and post - removal water quality data should be collected in any tributaries where mitigation credit is sought The baseline and annual monitoring protocol and success criteria for water quality are discussed in Sections 21 2 and 2.2 4 of the attached supplemental monitoring guidelines. They include collecting water quality data along the tributaries where mitigation credit is sought These protocols will be discussed with the IR,T prior to implementation to establish a final agreed upon monitoring plan 10. Section 3.2 6; Sediment Characterization and Management (p 13) Indicates a bathymetric,survey, Tier 1, and possibly Tier 2 analysis of sediment will be performed, and a Sediment Management Plan will be developed We are concerned about sediment and its impact on downstream aquatic resources In addition to -the Cape Fear shiner, there are several state listed freshwater mussel species downstream The volume, level of contamination, and potential risks to downstream aquatic resources will determine how the sediment should be managed However, in the past, sediments,were required to be removed (dredged) prior to dam removal in a watershed that supported federally listed species downstream of the project On July 16, 2014 Wildlands met with USFWS staff to discuss the sediment wedge upstream of the Hoosier dam and the possible impacts it may have on downstream a4uat'ic wildlife, populations including the endangered'Cape Fear shiner It was determined that.Wildlands will perform a Tier 1 evaluation, which investigates potential sources of contamination within the contributing drainage area, the physical characteristics of the sediment behind the dam and a bathymetric study to determine the volume -of the wedge This evaluation will then be submitted to.the USACE with a determination cf,whether a Tier 1 evaluation is sufficient or a Tier 2 evaluation should be completed in order to further rule out contamination. The USACE will then provide the document to the USFWS'who will do their own evaluation to determine if the dam removabis likely to have a,positive or negative effect on fish populations including the cape fear shiner This evaluation will determine whether sediment will be dredged from behind the dam. 11 Section 3 2 7, FERC License (p.13) It states the Bank Sponsor will surrender the Exemption #3586 to the FERC License in Compliance with the FERC Regulation 4 102. According to the FERC regulations, the exemption holder must consult with the fish and wildlife agencies on the plans for disposition of facilities and site restoration Also, the exemption holder must fulfill any obligations imposed by FERC and the fish and wildlife agencies for disposition of faalities,and site restoration It is our understanding,the application to be filed with FERC is essentially the same as a relicensing application, and includes an environmental assessment of the dam removal and restoration Yes, the above process description is the one that will be followed by the Bank Sponsor 12 Section 4'0, Mitigation Work Plan (p.15). Under Dam Demolition and Dewatering Work Plan it indicates the initial dewatering of`Reeves Lake would occur in a manner that minimizes Water quality and ecological impacts to downstream water bodies and aquatic communities while maintaining instream flows. Also, in Section 2.4.2, Feasibility (p 6), under Phase I it indicates reservoir draining would occur in late fall through early winter through the existing powerhouse Detailed information regarding the proposed dewatering of Reeves Lake should be included We support dewatering the impoundment during late fall through early winter Dewatering should occur in a slow controlled manner that will not result in the scouring or erosion of downstream habitat, and will not result'in the downstream flushing of sediment from within the reservoir In addition, details describing, how the impoundment will be drawn down, the proposed drawdown schedule that includes the release flow (CFS) for the impounded waters, and how minimum flows downstream of the dam will be maintained during the entire dam removal process to minimize impacts to aquatic resources should be included. Also, we request the Bank Sponsor notify NCWRC regarding'the date and time of dewatering of Reeves Lake is initiated. We would like the opportunity to relocate any freshwater mussels that may be stranded during the dewatering There will be a section of the Mitigation Plan dedicated to demolition and dewatenng that will explain the process in detail Per your request, NCWRC,wlll be notified regarding the date and time of dewo,terrng of Reeves Lake providing enough time for relocation procedures. 13 Section 4 0, Mitigation Work Plan (p.15) Under Wooded Buffer Restoration Plans it indicates planting lists and details will be included We recommend re- vegetation -of riparian buffers with native trees and shrubs A reference site located within, near „,or adjacent to the bank should be used to develop the plant list for re- vegetating riparian buffers within the bank In addition, if it is determined these riparian buffers will be used for mitigation credit, then success criteria will need to be developed Wildlands will follow the methods used in their previous riparian buffer restoration projects for the design and establishment of riparian ,buffers along Rocky River and its tributaries. It should be noted that the majorityrof the riparian buffer along Reeves Lake and its tributaries is currently vegetated with mature bottomland hardwood species Adjacent native vegetative communities will be used as a guideline for, the plant list along with species with high survivability noted on previous riparian buffer restoration projects The mitigation plan will outline the success criteria for these buffers 14 Section 4 0, Mitigation Work Plan (p 15). Under Monitoring Plan it indicates pre- and post- removal monitoring will include geomorphic surveys If the�success criteria for the tributaries will include channel stability, then stream geomorphology data should be collected immediately after the reservoir is drawn down for use as pre - removal (baseline) data Wildlands will follow the above procedure as part of the baseline data collection This is described in Section 2 2 1 of the attached supplemental monitoring plan 15. Section 5.0 Determination of Mitigation Credit (p 15) It states "The upstream limits of the impounding effect of the Hoosier Dam on Rocky River and six perennial tributaries were initially estimated based on the water level of Reeves Lake,and LIDAR data for the tributaries The upper limits of these inundated areas were visited, photographed„ and field verified using hand -held global positioning system equipment The final lengths for the Rocky River and each of the six tributaries will be confirmed by,topographic survey of the limits of the impounded area " In the past, determining, impoundment,limits has been problematic particularly on short tributaries Detailed information describing how the impoundment limits were determined should be included This will be included in the 'Mitigation plan 16. Section 5 0, Determination of Mitigation Credit (p 16) Table 3 shows mitigation criteria for improving water quality, rare, endangered, and threatened species, and protecting wooded buffers The table does not show "establishing an appropriate aquatic community" as part,of,the mitigation criteria Establishing an appropriate aquatic community is listed as a,goal in Table,l, and is an important component in determining the success of a dam removal project Also, the aquatic community was not discussed under baseline site conditions Please provide additional information regarding how "establishing an appropriate aquatic.community" will be determined and how it fits the mitigation criteria This criteria will be evaluated with biological surveys conducted pre- and post- dam removal to determine if the species composition has shifted in representation from len tic to lotic The protocol for aquatic community sampling is discussed in Sections 2.1 4, 2 2.2, and 2.2 3 of the attached supplemental monitoring pldn. 17 Section 5.0, Determination of Mitigation Credit (p.16): Table 3 shows credit for Rare, Endangered, and Threatened Species for the Rocky River and each of the six`tributaries We question, whether all of these tributaries will provide suitable habitat for rare, threatened, or endangered species Generally, restoration of the tributaries following dam removal is not as effective as restoration of the main channel where the dam was located. If credit is sought for each of the tributaries, then pre - removal and post - removal data will need to be collected in each of the tributaries to document success criteria were met in each tributary Collection of data in the tributaries is discussed in the attachedsupplemental monitoring plan We will not claim credit if success criteria are not met within the tributaries 18. Section 5 0, Determination of Mitigation Credit (p 16)• It states' "Based on initial comments from the IRT, generation of stream mitigation credits for water quality improvements „and restoration of rare, threatened, and endangered species for the Rocky River and the six perennial tributaries wilknot exceed a ratio of 1.1 The Bank Sponsor proposes to preserve riparian buffers along a significant portion of the ma`instem of Rocky River and its tributaries. This approach to preserving buffers along the mainstem has not been undertaken on any previously approved dam removal mitigation projects. For this reason, we propose to,generate credit above the based 1 ratio following-the methodology in the rescinded dam removal guidance ” This was a possibility in the rescinded dam removal guidance (i e., Determining Appropriate Compensatory Mitigation Credit for Dam Removal Projects in North Carolina, June 19, 2008) However, it wasianticipated the buffer cred its, generated would compensate for tributaries,that most likely would not meet all three success criteria (i.e., water quality, aquatic community, rare, threatened and endangered species) and therefore would not qualify for the 1:1 ratio. Tributaries are more easily impacted and wooded buffers provide additional protection to the tributaries. We question whether mitigation credit should be given for any of the tributaries unless they have protected wooded buffers. Review of previous dam removal mitigation banks has shown tributaries without protected wooded buffers often have significant degradation of aquatic habitat. We believe further discussion with the IRT is needed regarding mitigation credit for tributaries and /or wooded buffers. Also, there appears to be some discrepancy between the percentages of buffer protected on each of the tributaries as described in Section 3.2.4 (p. 8 -9) and Table 3 (p. 16). The Bank Sponsor is not claiming credit on any tributaries without a proposed riparian buffer and easement. Any discrepancies between Section 3.2.4 and Table 3 will be reconciled in the draft mitigation plan. As mentioned in the response to NCDENR question #2 and NCWRC question #8, conservation easements will be recorded on the Rocky River if the Bank Sponsor is compensated with mitigation credit. Comments from Pete Benjamin, USFWS April 10, 2014 1. During the draft prospectus review meeting, Emily Jernigan expressed the Service's concerns with removing the sizeable dam in such a sensitive area for the Cape Fear shiner and numerous other Federally At Risk and State rare species. The concerns primarily stem from the lack of available scientific data in regards to the exact quantity and quality of sediments and nutrients the dam is holding back (NPDES discharges, runoff, etc.); and how the release of the impounded water and sediments could potentially negatively affect the downstream ecosystem as a whole. Specific concerns are for the potential impacts to the Cape Fear shiner and its designated downstream Critical Habitat associated with the dam removal. In addition to the Cape Fear shiner, there are several Federal At Risk species that live downstream of the Hoosier Dam including: Atlantic pigtoe (Fusconaia mosoni); brook floater (Alasmidonta voricoso); and the Septima's club tail (Gomphus septima). North Carolina rare species found downstream of the dam include: the panhandle pebblesnail (Somatogyrus virginicus); notched rainbow (Villosa constricta); triangle floater (Alasmidonta undulata); Carolina creekshell (Villosa voughaniona); eastern creekshell (Villosa delumbis); and the creeper (Strophitus undulatus). As discussed during our May 13, 2013 meeting, the Service recommends the Corps request to begin the consultation process, as the proposed activities may affect the Cape Fear shiner, and may adversely modify the designated Critical Habitat downstream of the dam location depending on the actions taken. This process will be the most appropriate avenue to adequately address all of the potential concerns in addition to the desired species benefits associated with this proposed project. Wildlands and the Bank Sponsor have begun the consultation process with Emily Jernigan as requested. The first meeting took place July 16, 2014 to discuss the Tier 1 evaluation for sediment behind the dam as well as potential impact the sediment and dam removal itself may have on aquatic life including the Cape Fear shiner. Wildlands and the Bank Sponsor will continue the consultation process throughout the project to ensure all concerns regarding aquatic life are addressed. 2. The Service is pleased to know the prospectus states that a sediment management plan will be established in the Mitigation Plan, and will be developed such that the risk of short -term impacts to sensitive aquatic communities downstream is minimized, and long -term impacts are avoided altogether. A sediment management plan should be based on site - specific assessment of sediment quantity and quality. It should discuss how sediment is to be managed before and during the removal and include the anticipated impacts of sediment movement post - removal (on upstream and downstream sediment loading, bank stability, and sediment and water quality), particularly as related to Cape Fear shiner habitat. Any proposed mitigative measures and monitoring should also be included. Wildlands will follow the suggestions above in developing the sediment management plan to be included in the draft mitigation plan 3 The - Service applauds the Bank Sponsor's initial efforts to acquire the majority of the Rocky River mainstem and associated tributary buffers, and encourages these efforts to continue to incorporate additional buffers along the entire project reach;' as it will benefit the Cape Fear shiner's habitat and additional aquatic;land terrestrial species as -a whole Wildlands Engineering has indicated that more conservation easements are in the process of being acquired along the project reach, and the,Service supports these conservation efforts The Service recommends that in order to receive credit for the approximately 6,365 linear feet of tributaries proposed,'the.tributaries should be protected with conservation easements which include a buffer on each side of the channel, preferably a 300 -foot forested buffer wherever this is possible We also encourage the establishment of 300 -foot forested buffers and conservation easements on as much of the Rocky River mainstem 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, or observed to be lacking in desired,natural aquatic functions We look forward to viewing,the impounded areas, reviewing the total property easement acquisitions, and discussing potential credit ratios As mentioned in the response to NCDENR question #2 and NCWRC question #8 and #18, conservation easements will be recorded on the,Rocky River if the Bank Sponsor is compensated with mitigation credit The bank sponsor has not yet decided on the width of buffer to be protected but will take the USFWS comment under advisement Geomorphic surveys will be conducted on the tributaries and Wildlands will coordinate with the IRT regarding the suitability of these systems for credit generation 4 In general, the Service does not have concerns with structuring available credits around goals of "the project (reestablishment of flow, endangered species habitat improvement, water quality improvement, fish passage, etc ) However, we caution that all goalsand 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 in an effort to retain consistency with other proposed dam removal projects Success criteria have been outlined in regards to aquatic communities, water quality, geomorphology and the re- colonization of "rare, threatened and endangered species In the attached supplemental monitoring °document Success criteria in the monitoring document are quantifiable, based on monitoring data and have, been modeled after previous dam removal projects. Wildlands intends to discuss this document at the IRT meeting on July 22, 2014 before Inclusion of these criteria Into the draft mitigation plan 5 The Service anticipates that the Mitigation Plan will include, at a minimum, proposals for monitoring of fish passage and habitat quality for the Cape Fear shiner and other rare native aquatic species, water quality, sediment quantity, quality, and movement, vegetation recruitment and invasive plants, and shoreline stability We recommend using appropriate native vegetative species that would benefit the Cape Fear shiner and the Rocky River °system, such,as American water willow (Just1aa americano), when preparing the replanting component,of,the mitigation plan In addition, remedial plans should be included, should the provider fail to meet stated goals The mitigation plan will address the topics listed above Includmg,plantrng of native vegetation, success criteria and long term management plans Comments by Renee Gledhill - Early, SHPO, March 17, 2014 I There are no recorded archeological sites in -the project vicinity, but the document states that a Phase I cultural resources investigation is anticipated to be undertaken We concurwith.this recommendation and look forward to review of the document. The investigations should include background research documenting the history of the dam and'the power generating facilities, as well as a pedestrian survey of the project area of potential effect (APE) The aerial photograph noted,Henley's Mill If a milkexists,,background research should be conducted and the structure or remains investigated Potential project effects to this mill should be assessed. We would suggest that the applicant, or their archaeological contractor, meet with staff of the Office of State Archaeology, prior to undertaking the Phase I investigation to ensure that all expectation concerning'the investigation are anticipated Two copies of the resulting cultural resource report, as well as one copy of the appropriate site forms, should be forwarded to us for review and comment as soon as they are available and well in advance of project implementation Wildlands and Unique Places will continue to coordinate with SHPO throughout the Phase 1 cultural resources investigation and provide the requisite copies of the resulting cultural resource report the SHPO office and the ,IRT Comments by Jean Gibby, USACE June 5, 2014 I, In an.electronic correspondence dated July 3, 2013 regarding this project, the Corps of Engineers requested that a jurisdictional determination be conducted for this project and included in the prospectus To date, a Jurisdictional determination for this site has not been conducted You must identify and quantify all jurisdictional waters within the project area and include the source of hydrology for each. As part of your Jurisdictional determination, you should complete USACE and North Carolina Division of Water Resources (NCDWR) stream forms, upstream of the impounded areas, in order to describe the antic return of functions You will also need to assess the potential impacts to all wetlands from the proposed dam removal Any wetland impacts that cannot be avoided may require a separate compensatory mitigation plan Furthermore, depending upon the amount of loss of wetland resources, and /or adverse impacts to other aquatic resources, and individual DA permit may be required for this project Please be aware that even if a Mitigation Banking Instrument (MBI) and mitigation plan for this proposed project is approved, the DA individual permit authorization would be issued or denied based upon criteria as determined by our Section 404(b)(1) guidelines and public interest review A wetland and stream delineation is currently being conducted for this site and ajurisdictional determination will be requested (estimated completion date August 1, 2014). The corresponding forms mentioned above will be Included III the draft mitigation plan Discussion and analysis of wetland impacts will also be included in the mitigation plan 2. Additional information regarding'impacts of the proposed work on the six (6) tributaries will need to be addressed in the draft mitigation plan As impact to the tributaries has not yet been addressed, the amount of credit, if any, to be provided by these tributaries will need to be determined after review of the draft plan. As mentioned by the North Carolina Wildlife Resources Commission (NCWRC) in their April 10, 2014 letter, Y additional information regarding the establishment of the impoundment limits of the tributaries, establishment of appropriate aquatic communities, determination of habitat for threatened and endangered species within the tributaries and the use of wooded buffers will be necessary regarding,the final establishment of potential credits (see also number 5 below) The draft mitigation plan will address impacts and proposed worked on the six tributaries As you mentioned, some IRT'members voiced concerns over the tributaries Those regarding b►olog►calcommunity, water quality, endangered species, and geomorphic,stability monitoring and success criteria are addressed in the attached supplemental monitoring document. Wildlands will gather input from the IRT regarding the monitoring document before the completion of our baseline monitoring and include that input into the draft mitigation plan Also as previously discussed, credit will only be sought for tributaries that include riparian buffers In conservation easements 3 Please be aware that the credit release schedule -and service area have not been determined These items still need to be resolved and will depend, in part, on much of the information that will be included in the draft mitigation plan and draft mitigation banking instrument This is noted, and we will continue to communicate with the IRT throughout this process 4 Based on comments received from the US Fish and Wildlife Service (USFWS), we have initiated informal consultation regarding the Cape Fear Shiner by letter dated June 5, 2014. Please consider all information provided during this process and incorporate it into your draft mitigation plan and draft MBI Wildlands hasbegun to consult with USFWS and had a,meeting regarding the Cape Fear, Shiner on July 16, 2014 Discussions in this meeting led to the development of the attached monitoring document Wildlands will continue to work closely with USFWS throughout the project and will incorporate methods for protecting the Cape Fear shiner pre, during, and post dam removal ►n the draft mitigation' plan 5. As indicated in your prospectus and ,the April 15 letter from the NCDWR and the April 10, 2014 letter from NCWRC, additional water quality monitoring, aquatic community data and geomorphic data (both pre and post removal) will be necessary to aid in the development of performance standards and credit determination. This data collection should be coordinatedmith the IRT as the draft mitigation plan and draft MBI are developed. Wildlands has provided the attached supplemental monitoring doument in order to get a consensus from the IRT moving forward on acceptable monitoring protocols and success criteria. The draft mitigation plan will include the monitonng,protocol as agreed upon by the IRT 6 As indicated in your prospectus, a more detailed evaluation of sediment quantity and quality above the Hoosier Dam must be completed and a more detailed sediment management plan must be developed As indicated by the USFWS and ,the NCWRC in their April 10, 20141etters, the plan should discuss how much sediment is to be managed before,and during the removal,and include the anticipated impacts of sediment movement post - removal. You should also include any proposed mitigation and monitoring associated with sediment removal. The subjects mentioned above w►llbe,included,in the draft mitigation plan. WIldlands is currently performing a bathometric study of the impounded sediment and is starting a Tier 1 evaluation of the Impoundment, which, along with consultation from the USFWS, will drive the development of the sediment management plan 7 Please continue to coordinate with the State Historic Preservation Office regarding potential impacts to cultural resources Coordination will continue with the SHPO and information regarding correspondence will be provided to the IRT 8 Please consider and address the recreational uses of the existing resource by the adjacent property owners /citizens expressed in the attached letters. The concerns regarding the recreational uses of the existing resources and other comments from adjacent property owners /atizens is being addressed in a separate comment re "sponse ,letter, which will be provided to, the USACE at a later date. Please contact me at 919 - 851 -9986 x 102 if you have any questions Sincerely, S John Hutton Title 'Enclosure Monitoring Document 1.0 Introduction The Bank Sponsor, 130 of Chatham, LLC, proposes to establish the Hoosier Dam Umbrella Mitigation Bank (Bank) to provide compensatory stream mitigation credits to offset unavoidable impacts to jurisdictional streams authorized under Sections 401 and 404 of the Clean Water Act and Section 10 of the Rivers and Harbor Act. The proposed Bank site is located on the Rocky River in Chatham County approximately 5 miles upstream of its confluence with the Deep River in Hydrologic Unit 03030003 (Figure 1). The Bank shall be planned and designed by Wildlands Engineering, Inc. (Wildlands) and Unique Places, LLC as an umbrella bank, with the initial bank site encompassing the area of the Hoosier Dam and a significant length of'Rocky River and several tributaries upstream of the currentdam The Hoosier Dam impounds approximately 1'6,060 feet of Rocky River (also known as Reeves Lake) and portions of six perennial tributary streams The U S Fish & Wildlife Service (FWS) has designated sections of the ,Rocky River upstream and downstream from Hoosier Dam, as well as a section of Bear Creek dust below the dam, as Critical Habitat for the Cape Fear shiner ('Notropis mekistocholas), a federally listed endangered species (FWS, 1988) The free - flowing /unimpounded sections of the Rocky River and Bear Creek exhibit very 'high quality riverine habitat that supports 'a diverse collection of aquatic species including the Cape Fear shiner and other species of concern, such as the Eastern creekshell (Villoso delumbis) and the Carolina creekshell (Villosa vaughaniana) The dam represents a significant blockage 'to aquatic species' migration and as a result, FWS has documented declines in the,disconnected Cape Fear shiner population upstream of the dam (FWS, 1988). 'Rem'oval ,of the blockage created by the dam to provide access to these high - quality reaches would be of substantial long -term benefit to aquatic communities including the Cape Fear °shiner The overall objectives of the removal of the Hoosier Dam and`restoration of Rocky River and'its tributaries are to (1) Restore the Hoosier Dam /Reeves Lake impoundment-to a lotic ecosystem, providing habitat that supports an appropriate aquatic community. (2) Facilitate restoration activities that promote re- colonization of the currently impounded section of the Rocky River by rare, threatened and endangered species, specifically the Cape Fear'shirier (3) Improve water quality in the Rocky River by reducing thermal stratification and increasing dissolved oxygen levels 2.0 Monitoring Plan The monitoring plan has been designed to evaluate the success ofithe Hoosier Dam removal in meeting the project objectives It includes baseline monitoring and post - removal monitoring to be conducted annually for five years or until success criteria are met, whichever occurs first Monitoring reports:will be submitted to USACE by December 15Y of each monitoring year and made available to other members of the Interagency Review Team (IRT) The monitoring plan structure is based on previous dam removal projects '(Carbonton Dam, Lowell Dam, and Milbur,nie Dam) and the 2008 guidelines for achieving compensatory mitigation credit from dam removals published by the NC IRT (2008). The monitoring plan will be finalized in coordination with the'IRT priorlto submission ofthe Mitigation Plan The primary objectives of the monitoring plan are to- (1) Determine if an appropriate lotic aquatic community has been re- established'in the Lake Reaves impoundment; (2) Determine if rare, threatened and endangered species have recolonized the impoundment, specifically the Cape Fear shiner; and ` (3) Determine if thermal stratification is reduced and dissolved oxygen levels have'improved 2 1 Baseline Monitoring 211 Geomorphology In order to establish baseline geomorphic conditions and the extent of the impoundment upstream of Hoosier Dam, 20 cross - sections (spaced 600 -1,000 ft apart) have been surveyed along the ,Rocky River These include one section above the impoundment and three sections below Hoosier Dam to be used as reference conditions Cross - sections were taken at existing FEMA modeling locations so they could be utilized to, model pre - removal conditions in HEC -RAS Of the 20 cross - sections, seven will become permanent sections to be monitored annually post -dam removal Cross - sections will also be surveyed on Tributaries 2, 3, 4, and 6 where restoration credits are requested These will be placed approximately 25 bankfull widths apart and,will be used as permanent cross - sections for monitoring post -dam removal The baseline cross sections will serve as a basis for comparison to post restoration cross sections to verify geomorphic stability Velocity measurements have been taken at reference cross - sections upstream of the impoundment and below the Hoosier Dam using a digital water velocity meter Measurements were taken at two ft increments at the cross - sections upstream of the impoundment and four ft increments at wide cross - sections downstream of dam At each increment, a velocity measurement was taken at 60% of the water depth. The reference velocity measurements will serve as a basis for comparison to post restoration measurements within the currently impounded sections of the Rocky River to verify a return to lotic conditions. 2 12 Water Quality Local water quality data within the project reach of the Rocky River is not available from federal or state agencies Therefore, Wildlands performed an assessment of water quality in Reeves Lake and in the Rocky River upstream and downstream of the Hoosier Dam between July 15th 2013 and,September 6, 2013 This assessment of water quality was focused on establishing a better understanding of (1) the baseline water quality in the Rocky River and Reeves Lake, (2) the extent that Reeves Lake may be acting as a source or sink for pollutants (primarily sediment and nutrients), and (3) the extent to which temperature and dissolved oxygen (DO) stratification occurs in the impoundment To develop a better understanding of the effect Reeves Lake may have on the water quality of the Rocky River and downstream water - bodies, two ISCO Brand water samplers were installed. (1) the Upstream Station was located upstream of the impoundment approximately 350 feet °east of the bridge at'Pittsboro Goldston Rd, and (2) the Downstream�Station was located approximately 350 ft downstream of'Hoosier Dam: The two'ISCO samplers collected a water sample every.four hours, four days a week between July 15, 2013 and September 6, 2013' A total of 72 water quality samples collected at each - station were tested for Total Suspended Solids (TSS), Nitrate ( NO3 -), Ammonium (NH4 +), Total Kjeldahl Nit "rogen (TKN), Phosphate (P042-), Total Phosphorus (TP) and Total Dissolved Nitrogen (TDN) All data from samples were separated into two groups by station (Upstream or Downstream) for analysis, The data populations were then analyzed using a 2- tailed T -test to determine if they were significantly different from one another (p < 0 05, n =72). On six dates during the summer of 2013 (7/11/2013, 7/25/2013, 8/,2/2013, 8/15/2013, 8/30/2013, 9/6/2013) temperature and DO profiles were measured in Reeves Lake Each variable was measured for every foot of depth at a location approximately 100 feet upstream of the Hoosier Dam Such profiles give an indication of the extent of thermal stratification in Reeves Lake, a condition known to negatively affect river- adapted aquatic life Results of baseline water quality monitoring have been presented in the Mitigation Bank Prospectus and will be included in the Mitigation Plan 2 13 Sediment Characterization Wildlands performed an initial survey of sediment quantity'in July 2013 Water depths over 22 feet were found along the historic alignment of the Rocky River in Reeves Lake for a distance of approximately 1500 feet upstream of the Hoosier Dam. Depths ranging from 15 feet to less than 3 feet were found across the historic floodplain of the river within the existing impoundment The crest elevation of the dam is 25 ft above the thalweg elevation of the stream A comparison of this preliminary data to the dam height appears to indicate that extensive sedimentation above Hoosier Dam has not occurred To further evaluate sediment Wildlands will perform a detailed bathymetric survey of,the impoundment to determine the extent, character, and depths of sediment upstream of the d'am This will be used to determine the total quantity of impounded sediment as well as the portion of this that is likely to be mobilized upon dam removal Wildlands will perform a sediment characterization to estimate the portion offines-vs coarse - grained sediment on a subset of seven of the existing cross - sections surveyed At cross - sections where the water is safely wadeable, a Wolman pebble count or sieve analysis will be completed (depending on the coarseness of substrate,) At cross - sections where the water is deep, substrate will be sampled using a petite -Ponar dredge: Samples will then be classified using a Wolman pebble count or sieve analysis as appropriate- Wildlands will also engage staff with the FWS to develop a Tier 1 sediment quality assessment, which includes =a review of impounded sediment character and extent (as described above) and potential sources of contamination in the contributing watershed. If the Tier 1 review finds that there is potential for contaminated sediment within the impoundment, a Tier 2 analysis (toxicity testing) will be performed This information (mobile sediment load, sediment characterization, estimates of background sediment load, and findings of the Tier 1 and 2 if conducted), and the, sensitivity of downstream aquatic communities, will inform the Draft Sediment Management Plan that will be submitted to the IRT for approval The Sediment Management Plan will be developed such that the risk of short -term impacts to sensitive aquatic communities downstream is minimized, and long -term impacts are avoided altogether. 2 1 4 Aquatic Community Sampling Aquatic community biologic sampling will be completed at four lotic stations located outside of the impoundment (two upstream of the impoundment and two downstream of Hoosier Dam) and seven sections within the impoundment The data collected from these stations will be used to establish local reference conditions to evaluate the project success post dam - removal Biologic sampling will consist of fish community sampling, mussel and snail sampling, macroinvertebrate sampling, and habitat assessment Fish community sampling will be conducted in the, fall of 2014 by The Catena Group or Alderman Environmental Services Fish sampling reaches will be located around two cross - sections upstream of the impoundment, two cross - sections downstream of the impoundment, and two cross - sections within the impoundment Sampling reaches will be between 200 and 400 meters and will be completed using a combination of Seine nets and dip nets in shallow riffle areas and electrofishing in deep pool areas in order to sample various habitats This will establish baseline data on the lotic fish community surrounding the impoundment Mussel /snail and macroinvertebrate sampling will be completed in` the fall of 2014 at 11 of the 20 cross - sections surveyed in the existing conditions assessment Two sections will be located above the impoundment and two below Hoosier Dam This sampling will establish a baseline condition from which to map the departure of species from lentic to lotic within the impoundment Habitat evaluation will be performed at the'seven cross sections located within the impoundmerit;in order to characterize habitat availability for rare, threatened and endangered species This will be done using the NCDWR Habitat Assessment protocol 2 2 Annual Monitoring Post -Dam Removal 2 2 1 Geomorphologic Monitoring The geomorphology of Rocky River and its tributaries_ will transform post -dam removal as the river transitions from a lentic to a lotic system. Geomorphic monitoring will be conducted annually to characterize that transformation and highlight the development of lotic habitat within the previously impounded reach Monitoring activities�will include geomorphic feature classification (e.g riffle, pool, run, glide), a total station survey (or appropriate survey technique for the water level post- dam removal), stream velocity measurements, sediment characterization, and NCDWR Habitat Assessment protocol Permanent cross - sections will be established along the length of Rocky River and tributaries where mitigation credits are requested Cross- sections will be spaced approximately 25 bankfull widths apart and will be permanently marked with rebar on each bank. The bank pins will be georeferenced with a handheld GPS unit to aid in location each monitoring year, Cross - sections locations will be selected after dewatering of the impoundment in order to include an array of geomorphic features (e g riffle, pool, run, glide). if possible, cross - sections will be located at sections used for baseline monitoring Cross - sections will serve as a permanent geomorphic and biologic monitoring station Stream Reach # Geomorphic Monitoring Stations Rocky River 7 Tributary 2 4 Tributary 3 4 Tributary 4 5 Tributary 6 1 2 A geomorphic survey will be completed at each monitoring station annually on the tributaries and in monitoring years one and five on the mainstem using an appropriate survey technique based on the depth of mater Each station will be referenced by its location and geomorphic feature (e g riffle, run, pool, and glide). Results will be used to track the stability of each cross - section and the development of habitat features across the width of the channel (e g micropools, riffles, undercut banks) post- dam removal Stream velocity measurements will be taken in coo rdination�with geomorphic,surveys at each monitoring station to evaluate aquatic habitat suitability for lotic species as well as sediment transport Inasmuch as possible, measurements will be taken at comparable discharges at each cross - section each year A digital water velocity meter will be used to record velocity measurements at evenly spaced intervals. For water depths less than 2 5 ft, measurement will be taken at 609,/o of the water depth For water depths greater than 2 5 ft, measurements will be taken at 20% and 60% of the water depth Substrate in the Rocky River and its tributaries is expected to coarsen post- dam removal as the alteration in hydraulics will facilitate flushing of fines This coarsened material will provide enhanced habitat for a lotic aquatic community Substrate monitoring will be�conducted annually at monitoring stations to track the coarsening of substrate over time At cross - sections where the water is safely wadeable, a Wolman pebble count or sieve analysis will be completed ('depending on the coarseness of substrate) At cross - sections where the water is deep, substrate will be sampled using a petite -Ponar dredge Samples will then be classified using a Wolman pebble count or sieve, analysis In addition to the survey, velocity measurements, and substrate analysis a NCDWQ Habitat Assessment will be performed at each cross - section This will be used in conjunction with the aquatic community sampling to determine if an environment suitable for lotic aquatic organisms is developing post -dam removal Success criteria for geomorphic monitoring along restoration reaches of Rocky River and its tributaries includes the following (a) Progression from a homogenous lentic waterway towards a geomorphically heterogeneous lotic system including the establishment of riffle, pools, runs and glides (b) Demonstration of stable channel geometry (c) Coarsening of the stream substrate in the previously impounded reaches as indication of the establishment of lotic habitat (d) Increase in NCDWR stream habitat scores. 22.2 Aquatic Biological Community Sampling Aquatic biological community sampling will betcompleted to track the establishment of lotic species within the previously impounded reaches cif Rocky River and its tributaries It will also be completed to track the re- colonization of rare, threatened and endangered species, specifically the Cape Fear shiner Sampling will be conducted at permanent biological monitoring stations located within the previously impounded reaches of Rocky River and its tributaries as well as at two reference stations upstream of the impoundment and two downstream of the Hoosier Dam All stations will be located on riffles /runs, however surveys will be conducted an adequate distance up- `and down - stream from the station to capture a variety of habitat types Biological monitoring stations may be re- located during the monitoring years if geomorphic shifts occur and the previous years' sampling station is no longer located on a riffle /run Of the seven potential monitoring stations within the impoundment of the Rocky River, the ones with the best ,potential for the ,redevelopment of Cape Fear shiner habitat will be chosen for sampling Stream Reach # Biological Monitoring Stations Rocky River 11 Total 2 upstream of previous impoundment, 2 downstream of Hoosier Dam, potentially 7 within restoration reach Tributary 2 1 Tributary 3 1 Tributary,4 1 Tributary 6 1 Macroinvertebrates sampling will be conducted annually at each biological monitoring station by the Catena Group or Alderman Environmental Services and will follow the NCDWR's Standard Qualitative method'. Results will be analyzed for relative abundance of Ephemeroptera, Plecoptera and Trichoptera taxa (EPT) as well as total benthic taxa. Mussel and snail community sampling will be completed in years four and five, as it has been shown that the re- colonization process takes longer for these communities post -dam removal Fish surveys will be conducted annually by the Catena Group or Alderman Environmental Services at each biological monitoring station following dam-removal Survey reaches will extend up to 200m on either side of the monitoring station in order to assess,a variety of habitat niches from an array of geomorphic features. A combination of electrofishing and seine netting /dip netting will be used as appropriate to sample various ,habitat features along the reach NCIBI methods may be used in certain conditions. Inasmuch as is possible, surveys will be completed under similar conditions (time of year, flow rate, turbidity) at the biological monitoring stations,in order to generate species - specific "Catch Per Unit Effort" (CPUE) data sets. Biological sampling from the reference monitoring stations will be used to evaluate success A sampling station will be considered successful if monitoring values for that station converge with or exceed reference station values Success criteria for Aquatic Biologrical Community Sampling along restoration reaches of Rocky River and its tributaries includes the following- (a) Establishment of a range of lotic- adapted fish, mussels, snails and macroin "vertebrates (b) Increases in class size distribution (from juvenile to adult post -dam remova_I), relative abundance as indicated by CPUE, distribution and occupancy of available habitat, and species diversity of freshwater fish. (c) An increase in relative abundance and species diversity of macroinvertebrates, snails,and mussels. 22.3 Rare, Threatened and Endangered Species Re- colonization Cape Fear shiner and additional rare, threatened and endangered species identified during baseline aquatic biological community monitoring will be monitored for re- colonization. This monitoring will be conducted annually by The Catena Group or Alderman Environmental Services during the aquatic biological community sampling Both companies hold appropriate permits to conduct population surveys for sensitive and protected species Success criteria for rare, threatened and,endangered species re- colonization along restoration reaches of Rocky River and its tributaries includes the following. (a) Increase in appropriate habitat for Cape Fear shiner or other species identified during baseline monitoring (b) Increase in presence /abundance of known associate species of the Cape Fear shiner or other species identified during baseline monitoring (c) Increase in presence /abundance of Cape Fear shiner or other species identified in the baseline monitoring. 2 2 4 Water Quality Monitoring Water quality improvement in the restoration reach of Rocky River is expected post -dam removal Dewatering the impoundment and removing Hoosier Dam should reduce thermal stratification and increase dissolved oxygen levels in the water column The improvement in water quality is expected to facilitate the re- colonization of lotic aquatic species within the previously impounded reaches Water quality monitoring will include temperature and dissolved oxygen Wildlands will use a YSI meter to sample temperature and dissolved oxygen along the mainstem at the seven previously mentioned permanent sampling ,stations within the currently impounded reach. Wildlands will use, the same sampling�protocol at the monitoring stations upstream of the impoundment and downstream of the dam for comparison Temperature and dissolved oxygen at the sampling stations within the tributaries as well Samples will be taken seasonally during each monitoring year to account for variations in temperature and dissolved oxygen as well as to thoroughly,document the progressive alteration in water quality post - dam removal Inasmuch as possible, samples will be taken under similar conditions (e.g temperature and, discharge). Macroinvertebrate sampling, as discussed in the Aquatic Biological Community Sampling, will be used as an indicator for water quality in addition to the water temperature and chemistry sampling Success criteria for Water Quality Sampling along restoration reaches of Rocky River and its tributaries includes the following (a) Reduction in thermal and dissolved oxygen stratification along the previously impounded reaches of Rocky River and its tributaries (b) Improvement in benthic biotic indices scores (decrease = improvement) LAND OWNED BY 1130 OF CHATHAM / POTENTIAL POST - REMOVAL / BIOLOGICAL MONITORING STATION PRE AND POST - REMOVAL BIOLOGICAL MONITORING STATION +� ISCO SAMPLING LOCATIONS (BASELINE) Tributary 1 Tributary 4 ributary 5 Tributary 2 Tributary,3 Tributary 6 o 45 . 0 1000 2000 3000 INO cUiAL) WILDLANDS ENGINEER `NG 312 W Nhllb�rook Road, Suite 225 NC- 27609 Tel3h�9198519986 \ Firm Llcense`No F -0831 Date 07-17-20M REMOVAL Job Number 005 -14005 Project Engineer ANA BIOLOGICAL MONITORING ]LOCATIONS Drawn By ANA Checked By JH