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Home My WebLink About20180785 Ver 1_More Info Received_20200424Strickland, Bev From: Tim Morris <Tim.Morris@kci.com> Sent: Friday, April 24, 2020 3:15 PM To: Davis, Erin B Cc: Haupt, Mac; Kim Browning; Tugwell, Todd J CIV USARMY CESAW (US); Dow, Jeremiah J; Xu, Lin Subject: [External] RE: Hip Bone Restoration Site - Request for Additional Information Attachments: KCI Planting Addendum for Hip Bone 2020.04.24.pdf Follow Up Flag: Follow up Flag Status: Completed External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Erin — Attached is our response to your comments. Let me know if you have any questions. From: Davis, Erin B [mailto:erin.davis@ncdenr.gov] Sent: Thursday, April 23, 2020 2:14 PM To: Tim Morris <Tim.Morris@kci.com> Cc: Haupt, Mac <mac.haupt@ncdenr.gov>; Kim Browning <Kimberly.D.Browning@usace.army.mil>; Tugwell, Todd J CIV USARMY CESAW (US) <Todd.J.Tugwell@usace.army.mil>; Dow, Jeremiah J <jeremiah.dow@ncdenr.gov>; Xu, Lin <lin.xu@ncdenr.gov> Subject: Hip Bone Restoration Site - Request for Additional Information Ti m, In reviewing your letter response to agency comments for the Hip Bone Restoration Site, DWR is concerned with your answers to comments 12b and 13 and the precedent that they could set. DWR is requesting additional information in order to issue the 401 permit approval. Please provide a brief addendum to be attached to the previously submitted final mitigation plan that addresses the following: 1. Please provide at least one target community type for the proposed planting areas. Identifying a target community is a common practice to aid in the selection of appropriate plant species for a restoration planting plan. Additionally, observing whether a mitigation site is trending towards a target community is a consideration in evaluating site success. 'Target community' is referenced in the 2016 NCIRT Mitigation Guidance Update (IV.A. pg.4; V.A.6. pg.5; XII.C. pg.26). 2. Please provide an updated planting list that includes all desirable species that you are requesting to count towards stem density and vigor success. The 2016 NCIRT Mitigation Guidance Update states that: "For any tree stem to count toward success for standard 1 or 2, it may be either planted or volunteer, but it must be a species from the approved planting list included in the Mitigation Plan. Other species not included on the planting list may be considered by the IRT on a case -by -case basis." Please note that since black walnut is a allelopathic species and could have a negative impact on establishment of planted stems and site diversity, we would not consider it a desirable restoration species. Please email the addendum to me and cc Mac, Kim and Todd. Once received we will continue processing the 401 permit application. Note that we are not requesting re -submittal of the final mitigation plan. Please let me know if you have any questions. Many thanks, Erin Erin B. Davis, PWS Stream & Wetland Mitigation Specialist 401 & Buffer Permitting Branch Division of Water Resources Department of Environmental Quality 919-707-3684 office erin.davisa-ncdenr.gov KCI ASSOCIATES OF NC ISO 9001:201 S CERTIFIED ENGINEERS • PLANNERS • SCIENTISTS • CONSTRUCTION MANAGERS 4505 Falls of Neuse Rd., Suite 400 • Raleigh, NC 27609 • Phone 919-783-9214 • Fax 919-783-9266 Date: April 24, 2020 To: Erin Davis, NCDWR CC: Kim Browning, USACE Jeremiah Dow, NCDMS Mac Haupt, NCDMS Todd Tugwell, USACE Lin Xu, NCDMS From: Tim Morris, Project Manager KCI Associates of North Carolina, P.A. Subject: Hip Bone Creek Restoration Site Planting Addendum — Response to NCDWR 401 Permit Comments Cape Fear River Basin - 03030003 Chatham County, North Carolina DEQ Contract No. #7528 DMS Project #100059 USACE AID #: SAW-2018-01160 We received your follow-up questions about the Hip Bone Creek Restoration Site Mitigation Plan in relation to the 401 permit application and our previous response to IRT comments from 3/17/2020. Please see our most current responses below. Mac Haupt and Erin Davis, NCDWR: 12. Page 26, Section 6.8 b. Please identify target communities. KCI Response 311712020 In general, we prefer not to designate a specified community type since a site can generally not be converted to that community within the timeframe of monitoring. We do select trees that are in line with the surrounding community types, though. DWR Response 4/23/2020 Please provide at least one target community type for the proposed planting areas. Identifying a target community is a common practice to aid in the selection of appropriate plant species for a restoration planting plan. Additionally, observing whether a mitigation site is trending towards a target community is a consideration in evaluating site success. "Target community' is referenced in the 2016 NCIRT Mitigation Guidance Update (IV.A. pg.4; V.A.6. pg.5; XII.C. pg.26). Employee -Owned Since 1988 RISE TO THE CHALLENGE WWW.KC.COM KCI Amended Response 412412020 We propose to restore a Piedmont Alluvial Forest as described in Schafale 2012. This community type will cover the riparian and floodplain zones of the project streams with a mixture of alluvial and upland species, with distribution varying from the drier, upper ranges of the site to lower, broader floodplains. 13. Page 30, Vegetation Performance — Note that only volunteer species that are included on the approved mitigation plan plant list may count toward the vegetation performance standard. KCI Response 311712020 We added: "Volunteers that are included on the approved mitigation plan plant list must be present for a minimum of two growing seasons before being included in performance standards in Year 5 and Year 7." Additionally we added an extra list of native trees that could be used for substitutes or seen as desirable volunteers. This text reads, "Other native desirable species that have the potential to volunteer at the site or be used for planting substitutions towards the performance standard include other native oaks (Quercus sp.), native Celtis species (Celtis sp.), tulip poplar (Liriodendron tulipifera), native hickories (Carya sp.), native dogwoods (Cornus sp.), native elms (Ulmus sp.), black walnut (Juglans nigra), native Nyssa species (Nyssa sp.), and cottonwood (Populus deltoides)." DWR Response 4/23/2020 Please provide an updated planting list that includes all desirable species that you are requesting to count towards stem density and vigor success. The 2016 NCIRT Mitigation Guidance Update states that: "For any tree stem to count toward success for standard 1 or 2, it may be either planted or volunteer, but it must be a species from the approved planting list included in the Mitigation Plan. Other species not included on the planting list may be considered by the IRT on a case -by -case basis." Please note that since black walnut is a allelopathic species and could have a negative impact on establishment of planted stems and site diversity, we would not consider it a desirable restoration species. KCI Amended Response 412412020 Updated Tree List (Planted plus anticipated volunteers) Buckeye Aesculus sylvatica FAC River Birch Betula nigra FACW American Hornbeam Carpinus caroliniana FAC Pignut Hickory Carya glabra FACU Shagbark Hickory Carya ovata FACU Sugarberry Celtis laevigata FACW Silky Dogwood Cornus amomum FACW Flowering Dogwood Cornus florida FACU American Persimmon Diospyros virginiana FAC Tulip Poplar Liriodendron tulipifera FACU Blackgum Nyssa sylvatica FAC American Sycamore Platanus occidentalis FACW Cottonwood Populus deltoides FAC White Oak Quercus alba FACU Southern Red Oak Quercus falcata FACU Employee -Owned Since 1988 RISE TO THE CHALLENGE WWw.KCI.COM Swamp Chestnut Oak Quercus michauxii FACW Pin Oak Quercus palustris FACW Willow Oak Quercus phellos FAC Northern Red Oak Quercus rubra FACU Winged Elm Ulmus alata FACU American Elm Ulmus americana FACW Slippery Elm Ulmus rubra FAC Sincerely, Tim Morris Project Manager Employee -Owned Since 1988 RISE TO THE CHALLENGE WWW.KCI.COM