HomeMy WebLinkAbout20180866 Ver 1_eApproval Letter SAW-2018-01169_20191202Strickland, Bev
From:
Browning, Kimberly D CIV USARMY CESAW (USA)
<Kimberly.D.Browning@usace.army.mil>
Sent:
Monday, December 2, 2019 3:47 PM
To:
Baumgartner, Tim
Cc:
Tugwell, Todd J CIV USARMY CESAW (US); Haupt, Mac; Davis, Erin B; Wilson, Travis W.;
kathryn_matthews@fws.gov; Merritt, Katie; Wells, Emily N; McLendon, C S CIV
USARMY CESAW (USA); Crumbley, Tyler A CIV USARMY CESAW (USA); Mickey Sugg;
Jessop, Jordan E CIV USARMY CESAW (USA); Bowers, Todd; Crocker, Lindsay; Ray
Holz; John Hamby
Subject:
[External] eApproval Letter NCDMS Shaw's Run Mitigation Site/ Columbus County/
SAW-2018-01169
Attachments:
Draft Mit Plan Comment Memo_Shaws Run_SAW-2018-01169.pdf, eApproval
Letter_Shaws Run_SAW-2018-01169.pdf
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Mr. Baumgartner,
Attached is the Shaw's Run Draft Mitigation Plan approval letter and copies of all comments generated during the
project review. Please note that this letter approves the Draft Mitigation Plan provided that the Final Mitigation Plan
adequately addresses all comments on the attached memo. Please provide a copy of the Final Mitigation Plan when you
submit the Pre -Construction Notice for the NWP 27. If no permit is required to construct the project, please submit a
copy of the Final Mitigation Plan to our office at least 30 days prior to beginning construction. Also, please ensure that a
copy of the Final Mitigation Plan is posted to the NCDMS project documents so that all members of the IRT have access
to the Final plan.
Please let me know if you have any questions about the process or the attached letter.
Thanks,
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers
3331 Heritage Trade Dr, Ste. 105 1 Wake Forest, NC 27587 1 919.554.4884 x60
BUILDING STRONG (r)
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
REPLY TO
ATTENTION OF:
CESAW-RG/Browning
MEMORANDUM FOR RECORD
November 13, 2019
SUBJECT: Shaw's Run Stream and Wetland Mitigation Site - NCIRT Comments during 30-day Mitigation
Plan Review
PURPOSE: The comments listed below were received during 30-day comment period in accordance with
Section 332.8(g) of the 2008 Mitigation Rule in response to the Notice of NCDMS Mitigation Plan Review.
NCDMS Project Name: Shaw's Run Stream and Wetland Site, Columbus County, NC
USACE AID#: SAW-2018-01169
NCDMS #: 100055
30-Day Comment Deadline: October 31, 2019
DWR Comments, Mac Haupt:
1. Table 4- DWR believes that the upper reaches of UT1 and UT2 are at risk for losing flow. The DWR
stream score provides evidence that these reaches are at risk. Thanks to DMS for recommending another
flow gauge for the upper reach of UT1. In addition, DWR questions the design for these reaches
maintaining a single thread channel.
2. Table 5.- thanks for including the taxonomic subgroup for the mapped soil series names.
3. Table 7.- Is the Angola site an appropriate reference for this stream restoration site?
4. Section 3.5.2- DWR will require more soil profiles for this site before final approval of this mitigation
plan. One soil boring with a profile is not adequate.
5. Section 8.1.1- the verbiage states all the stream restoration will be priority I type work. DWR believes
the upper reaches of UT 1 and UT2 should include more headwater type restoration work. It appears there
is more slope associated with the upper UT2 reach, however, the drainage area is small, or right at the
minimum to maintain an intermittent channel from published research (25 acres).
a. Other verbiage suggests the designer may substitute rock as necessary. DWR believes very little
rock needs to be placed in the proposed restoration features.
b. Outfall Structures- DWR does not believe use of a Terracell is warranted. Why not utilize log
cross vanes as shown on the design sheets?
6. Section 8.2- what is the drainage area at the top of UT I?
7. Table 15- DWR recommends limiting Green Ash planting to no more than 5% due to the ash borer.
8. Table 17- DWR would like the proposed growing season stated/written into the Table. We realize Axiom
will monitor the soil temperature, however; we will need to know the proposed season, the location of the
soil probes and the pairing of the soil temperature with the appropriate vegetative bud burst (not red maple,
since they usually show early bud burst).
9. Table 18- the 30 day flow criteria is only for intermittent streams. DWR expects near continuous flow for
perennial streams.
10. DWR accepts and appreciates DMS's comment regarding the wetland performance criteria.
11. Appendix A- Figures, in the future, for projects with proposed stream reaches high in the watershed, please
include a LiDAR figure.
12. In addition, it is also helpful to have pictures showing representative reaches, particularly when there has
been at least a year since the site visit.
13. Figure 6- typical riffle cross section- DWR is assuming the designer will not line the channel and up the
stream bank with rock.
14. Figure 9- DWR likes the placement of the flow gauges, however; either some of the wetland gauges may
need to be moved or other gauges added to monitor wetlands located in upper topo gradients.
15. Design sheet 2D- what is floodplain interceptor made out of and does the designer intend to install this
feature?
16. Design sheet 4- what is the line that borders the stream between the wetted perimeter line and limits of
disturbance line? Also, please put a scale on all design sheets with stream planforms.
17. Design sheet 5- DWR believes the single thread channel should start at approximately station 7+00.
Summary: before final approval of this mitigation plan, DWR would like the following:
a. Information on number and location of soil profiles, including areas in upper topo gradients,
b. Better explanation or case for starting with single thread channels at the top of the project,
Site pictures, particularly of the upper reach features.
WRC Comments, Travis Wilson:
Significant portions of the watershed shown for UT 1 and UT 2 are located north of a road and railroad
bed making it unclear how or if that area drains into those watersheds. The mitigation plan states UT 1
starts at a culvert under the roadbed but appears to still be interconnected with the roadside ditches and
drainage. With a Priority 1 approach will the drainage coming under the road access the channel or be
pushed further down the roadside ditch? There also does not appear to be any cross pipes connecting flow
from the UT 2 watershed delineated on the north side of the road to UT 2 south of the road making that
watershed significantly smaller.
2. On paper this site looks like a better wetland restoration site with some amount of headwater stream
restoration.
3. The amount of Greene ash proposed for planting should be reduced to reflect our latest guidance of <5%
USACE Comments, Kim Browning:
1. The correct USACE Action ID is SAW-2018-01169. Please correct the cover page.
2. Section 8.3- Wetland Restoration — The inclusion of ephemeral/vernal pools is acceptable, and should be
8-14" depressions that dry up yearly so that predatory species cannot colonize.
3. It would be beneficial to add some coarse woody debris to the depressional areas in the buffers and
throughout the adjacent wetlands for habitat, and to help store sediment, increase water
storage/infiltration, and absorb water energy during overbank events.
4. Table 17 Success CriteriaStreams, please add a statement (regarding UT3) at least 30-days continuous
surface water flow for intermittent streams.
5. Table 18Success Criteria: Please add a section on Photo Documentation or Digital Monitoring. An
example would be that photographs should illustrate the site's vegetative and morphological stability on
an annual basis, in fixed locations, depicted on the monitoring maps or at all cross -sections. Cross-section
photos should demonstrate no excessive erosion or degradation of the banks. Longitudinal photos should
indicate the absence of mid -channel bars or vertical incision. Grade control structures should remain
stable.
6. The upper end of UT 1 will likely be intermittent and develop into more of a headwater system rather than
a single thread. Photo documentation showing defined channel features will be important.
7. When submitting the PCN, please include an estimate of the number of trees, or acres, to be cleared for
the NLEB 4(d) Rule.
8. Maintenance Plan: Will the marsh treatment area within the easement require maintenance? If so, please
discuss.
9. Please include Lidar maps.
BROWNING.KIMBE
RLY.DANIELLE.152
7683510
Digitally signed by
BROWN INGAMBERLY.DANIELL
E.1527683510
Date: 2019.11.13 15:5 7:40
-05'00'
Kim Browning
Mitigation Project Manager
Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
December 2, 2019
Regulatory Division
Re: NCIRT Review and USACE Approval of the NCDMS Shaw's Run Mitigation Site / Columbus Co./
SAW-2018-01169/ NCDMS Project # 100055
Mr. Tim Baumgartner
North Carolina Division of Mitigation Services
1652 Mail Service Center
Raleigh, NC 27699-1652
Dear Mr. Baumgartner:
The purpose of this letter is to provide the North Carolina Division of Mitigation Services
(NCDMS) with all comments generated by the North Carolina Interagency Review Team (NCIRT) during
the 30-day comment period for the Shaw's Run Draft Mitigation Plan, which closed on October 31, 2019.
These comments are attached for your review.
Based on our review of these comments, we have determined that no major concerns have been
identified with the Draft Mitigation Plan, which is considered approved with this correspondence.
However, several minor issues were identified, as described in the attached comment memo, which must
be addressed in the Final Mitigation Plan.
The Final Mitigation Plan is to be submitted with the Preconstruction Notification (PCN)
Application for Nationwide permit approval of the project along with a copy of this letter. Issues identified
above must be addressed in the Final Mitigation Plan. All changes made to the Final Mitigation Plan
should be summarized in an errata sheet included at the beginning of the document. If it is determined
that the project does not require a Department of the Army permit, you must still provide a copy of the
Final Mitigation Plan, along with a copy of this letter, to the appropriate USACE field office at least 30
days in advance of beginning construction of the project. Please note that this approval does not preclude
the inclusion of permit conditions in the permit authorization for the project, particularly if issues
mentioned above are not satisfactorily addressed. Additionally, this letter provides initial approval for the
Mitigation Plan, but this does not guarantee that the project will generate the requested amount of
mitigation credit. As you are aware, unforeseen issues may arise during construction or monitoring of the
project that may require maintenance or reconstruction that may lead to reduced credit.
Thank you for your prompt attention to this matter, and if you have any questions regarding this
letter, the mitigation plan review process, or the requirements of the Mitigation Rule, please call me at
919-554-4884, ext 60.
Sincerely,
Digitally signed by
BROWN ING•KIMBERLY• BROWNING.KIMBERLY.DANIELLE.
DA N I E LLE.1527683510 1527683510
Date: 2019.12.02 15:39:48-05'00'
Kim Browning
Mitigation Project Manager
for Tyler Crumbley
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
Lindsay Crocker— NCDMS
Raymond Holz, John Hamby—RS