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HomeMy WebLinkAbout20160299 Ver 1_Email_20170428Strickland, Bev From: Baker, Virginia Sent: Friday, April 28, 2017 5:36 PM To: Andy Williams (andrew.e.williams2@usace.army.mil) Cc: amy.chapman@ncdenr.gov Subject: Asheboro Bypass Attachments: Mitigation Update PN with Document_FINAL public posted 10-24-2016.pdf Andy, Thanks for talking earlier. I will be interested to hear what Beth says about available credits from DMS for this project. I did check my notes and have that I was told DMS had said "they could not find" wetland mitigation credits in this HUC. I asked Mac about this and he thought that once DMS provides DOT with a letter that they will provide credits through the In Lieu Fee program they then will go out and seek RFPs in those HUCs for mitigation. It is unlikely they had that much mitigation in the ground already which might be why DOT said DMS did not have the wetland mitigation credits. Although this was confusing, as I thought they were saying DMS was unable to find the credits. I do know there are times DMS does struggle to find the needed mitigation for DOT. We just went through this for the Neuse 01 and 02 required mitigation for impacts associated with I-540. This resulted in some "creative" alternative forms of mitigation being proposed. Ultimately it turned out DOT did not need as much stream mitigation. I have in our Approval that DMS has agreed to provide the mitigation credits. Attached is the 2016 Monitoring Guidance. For DMS this would be required for sites instituted after the Oct 24, 2016 date. Here is some of the things we talked about — Project impacts would be 2.48 ac in the Yadkin 03, 4.42 in the Yadkin 04 and 5.96 in CPF 03 equaling 6.43 ac impacts. The ACOE requires a 2:1 mitigation ratio. DWR also required 2:1. The mitigation site is in CPF 03 so 6.90 ac would be out of service area which would result in a credit adjustment (I don't recall off hand what out of Huc requirements are, 1.5 or 2 to 1?). DOT had historically asked about banking credits on this project but was told they could not do that. We both had concerns about this site not really needing stream restoration though out. Some areas would be better suited with E1 and EII. This approach would end up being restoration throughout. I was particularly concerned about restoring the streams and creating wetlands on the other properties, Lunsford and Farlow, that had mature forested buffers already. It was not clear if the existing tribs east of the proposed right of way would be turned into wetland. It appeared from the conceptual plan there would be some sections on the east side of the right-of-way that would have buffers <50 ft. Credits should be adjusted for the utility crossing. For streams, DOT has been given 50% or 100% depending on the age of the project and the agency review. I would say with past DOT projects there has been inconsistency in this regard. DMS and Bank sites were getting 50% for utility crossings and currently are getting 0%, I don't remember the date of that change (2013?). You would have to ask Todd about this. I'm not sure about the credit reduction for wetlands under utilities, I think it is 50%. We talked about using the new 2016 guidance for monitoring. This guidance has a methodology to determine credit reductions for narrow buffers and also credit additions for wider buffers (which I did not mention) Both reductions and additions would be applicable for the Asheboro Bypass mitigation project if the 2016 guidance was applied. There is draft guidance for out for buffer width credit adjustments that was put out in 2010 that has also been used on other DOT and DMS projects. Existing pocket wetlands should be removed from the wetland credit areas after a JD is done. Our guidance is for forested wetlands and these wetlands would be primarily shrub covered. Although, personally I think for some types of wetlands (e.g. pocosins) should not be planted with trees. The proposed wetland type does seem to be the type of wetland that would have scrub shrub. It would be helpful to know in the mitigation plan what type of wetland this system is suppose to be mimicking. The NHP wetland classification (third or fourth approximation) could be used as I think NCWAM is too coarse. This would aid in the justification for a shrub covered as opposed to a forest covered wetland. Distict stream channels have received centerline stream footage credit. Braided stream channels that do not have a distinct single thread may receive valley length credit would could affect he site crediting. This would be considered wetland creation, not restoration, to be consistent with what has been allowed for other NC mitigation projects restoration would only be applicable for this approach when considering the pre-colonial era, if not earlier. Up to 12" of fill (some times more, but not three feet) has been used for restoration. If this project does move forward I would recommend hydrology monitoring with wells. Georgeville is not a soil type listed in the 2016 guidance, but typically a minimum of 7.5%-8% has been required for riparian wetlands. Additional soils cores and other baseline information would be needed for the mit. Plan. Crediting would need to be adjusted for creation. I've seen 3:1, I would confer with Todd on this one. I see in the meeting min for Aug 5, 2015 that NCDOT and agencies concurred that creation could be 2:1/3:1. I could look back in our database and see what has been allowed in the past. 2:1 is typically use for enhancement. The stream design proposed, "2D-Hydrodynamic Modeling" has been used in MD and PA with success and clearly was carefully planned and implemented. This approach has not been used on a project in NC where stream designers typically use the Rosgen Design approach in the Piedmont with reference streams. It could be helpful to get some feedback from the some academics who have substantial stream design experience like Barbara Doll or Greg Jennings on using this approach in NC. Have a good weekend! Ginny Bake� T��nspo�t�tion Pe�mitting l/nit iVCDEQ-Division ofW�te� Resou�ces �650 M�ilSe�vice Cente� R�leigh, /VC27699-�650 Phone-<9�9I707-8788, F�x-(9�9I733-�290