20081296 Ver 1_Mitigation Bank Proposal Review_20080905

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
September 5, 2008
Ms. Loretta Beckwith
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
Re: Ratcliffe Cove Mitigation Bank
Haywood County
Mitigation Bank Prospectus Comments
Dear. Ms. Beckwith:
Coleen H. Sullins, Director
Division of Water Quality
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We have reviewed the Prospectus for the above-referenced site. Based on the information presented in
the Prospectus, the site appears to be a good candidate for a mitigation site. Our comments address the
proposed monitoring and success criteria for the project, as follows:
The stream monitoring should include installation of staff/crest gauges to document bankfull
events. Success criteria should include the occurrence off two bankfull events (in non-
consecutive years) over the proposed five-year monitoring period. This is referenced in the
credit release section of the Mitigation Plan (Section 6.2) but is not discussed in the sections on
monitoring or success criteria.
The target hydrological success criterion proposed for the project is inundation or saturation for 5
to 12.5% of the growing season (consecutive days). DWQ does not believe this is a suitable
hydrology criterion for riparian wetlands. Recent research conducted by DWQ has shown that
natural riparian wetlands are inundated or saturated for significant periods during the year.
DWQ feels that 12.5% should be the minimum acceptable hydrology target for riparian
wetlands, unless the reference wetland for the site shows drier conditions during an atypical year.
DWQ does not agree with the proposed practice of performing a jurisdictional determination to
document success if wetland parameters are marginal based on monitoring. Compensatory
mitigation is intended to replace the lost functions and values of a particular type of wetland. The
monitoring data should reflect a trend toward the target wetland type in order to be considered
successful and generate mitigation credits.
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / Fax [phone]
Internet: http://h2o.enr.state.nc.us/ncwetlands
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N hCarolina
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An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper
Ms. Beckwith
U.S. Army Corps of Engineers.
Bass Mountain Mitigation Bank - Prospectus Comments
Page 2 of 2
Again, we feel that the site as proposed appears to be a good candidate for a mitigation bank. Please
note that DWQ reserves the right to provide additional comments based on the site visit and review of
more detailed design plans.
Please feel free to contact Eric Kulz or Tammy Hill at [phone] if you have any questions
regarding this project.
Sincerely,
1 L7
Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
cc: File Copy (Eric Kulz)
Central Files
Roger Edwards - ARO
Noe Carolina
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401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / Fax [phone]
Internet: htto://h2o enr state.nc.us/ncwetlands
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper