20060200 Ver 2_Staff Comments_20100708

FW: Five Mile Branch - Iredell County (#2006O2OOv2)
FW: Five Mile Branch - Iredell County (#2006O200v2)
Kulz, Eric
Sent: Thursday, July 08, 2010 7:39 AM
To: Johnson, Alan
Cc: Dennison, Laurie; Strickland, Bev; Mcmillan, Ian
Attachments: Five Mile Branch Stream (4).pdf (197 KB)
Page 1 of 3
Alan: __...??.._,?._._.__..?.-..__._._?_...?._...,_?__?,.?...a...__._?.?__.._._......._._....?..._ .,..__
This was a Design-Bid-Build project that was to be issued out of Central Office (per the Director's Office). Any
time EEP is the applicant, the RO's should forward comments to me as soon as practical, as we only have a 30-
day clock for EEP DBB projects (per the Director's Office). Since EEP does not pay a fee, we do not issue a 401
cert for DBB Projects. For EEP Full-Delivery Projects (where a designer or bank is the applicant, but it is being
done for EEP), those are issued by the appropriate ROs.
I think Bev is currently sending out a form with EEP projects that describes who is issuing. This one went out
before we modified the form.
Unfortunately, we had some issues with this project, as noted below.
Please let us know what needs to be done to clarify this process further.
Eric
From: Dennison, Laurie
Sent: Tuesday, July 06, 2010 8:08 AM
To: Kulz, Eric
Subject: RE: Five Mile Branch - Iredell County (#2006O200v2)
See attached L -
From: Kulz, Eric
Sent: Thursday, July 01, 2010 1:43 PM
To: Dennison, Laurie
Subject: FW: Five Mile Branch - Iredell County (#2006O200v2)
Forgot to include you on this one. Project is on hold.
From: Kulz, Eric
Sent: Thursday, July 01, 2010 1:00 PM
To: Xu, Lin
Cc: Hill, Tammy; Tugwell, Todd SAW'; Johnson, Alan; '[e-mail]'; Dorney, John
Subject: Five Mile Branch - Iredell County (#2006O200v2)
Lin:
DWQ has reviewed the above-referenced project documents and have a number of issues which require
clarification and/or possible discussion by the IRT. The majority of the issues are related to the proposed
https://mail.nc. gov/owa/?ae=Item&t=IPM.Note&id=RgAAAAAAOgPoLNIPQZ06vHVRO... 7/8/2010
FW: Five Mile Branch - Iredell County (#2006O2OOv2) Page 2 of 3
wetland restoration.
Vegetation
Sweetgum and red maple should be removed from the planting list for the project. Although these species are
common in Piedmont/Mountain Bottomland Hardwood communities, they tend to be very competitive in early
successional systems (such as recently-planted mitigation sites) and will likely colonize on their own.
Proposed Wetland Restoration Area Delineation
It is unclear how the extent of restored wetland was estimated. The boundaries of the proposed wetland
restoration in the design plan sheets do not appear to follow topographic contours or hydric soil lines. Please
provide further explanation and additional maps, if necessary, to clarify how the total proposed wetland
restoration area was calculated and mapped.
Vernal Pools
While we support the inclusion of a small number of vernal pools on a wetland restoration site, the mitigation
plan does not provide details regarding the number and total area of constructed pools. These factors are
significant since the plan proposes that they be included in the area receiving wetland mitigation credit.
Soil
While the site does appear to have hydric (Wehadkee) soil inclusions, we are concerned about the extent of
wetland restoration (58.6 acres) proposed on an area that contains primarily Chewacla soils. We echo the
concerns expressed in the original DA permit (May 9, 2006) as well as the suggestion that EEP not use any of the
proposed wetland credits to offset permitted impacts until such time as success of wetland restoration begins to
be demonstrated.
Hydrology Success Criteria
The proposed performance criteria for hydrology are "saturation within 12 inches of the soil surface for the
hydroperiod dictated by the project reference or 5% of the growing season, whichever is less." DWQ believes
that a hydroperiod reaching the minimum of these criteria will be inadequate to support the wetland system
targeted for restoration. Table 5 in the Corps' 1987 Wetland Delineation Manual shows that areas with
continual saturation or inundation for less than 5 percent of the growing season in most years are not wetlands,
and DWQ does not support wetland mitigation credit for such areas. As Bottomland Hardwood Forests are
expected to be "intermittently to seasonally inundated for long duration" (NC Wetland Assessment Method, ver.
1, April 2008), and based on results of reference hydrology monitoring in 2005 (Mitigation Plan, Dec 2009, p. 6-
2), we expect that the targeted hydroperiod is significantly greater than 5 percent, and varies depending upon
landscape position (elevation, proximity to streams and surface runoff sources, etc.).
In addition, although the mitigation plan indicates that monitoring will be representative, it does not include
details regarding the placement of monitoring plots for vegetation and hydrology. Please provide a map and
description of how monitoring will be structured to capture conditions across the site, including the hydrology
gradient from the ditches that will remain open adjacent to 1-40.
Monitoring Duration
Please note that the federal Mitigation Rule states that monitoring periods should be extended for forested
https://mail.nc.gov/owa/?ae=Item&t=IPM.Note&id=RgAAAAAAOgPoLNIPQZ06vHV RO... 7/8/2010
FW: Five Mile Branch - Iredell County (#2006O2OOv2)
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wetlands. This policy has been adopted by the IRT in NC. Considering the concerns regarding restoration on
Chewacla soils, an extended monitoring timeframe for both vegetation and hydrology may be warranted.
Please note we have copied pertinent USACE representatives and request input from them in resolving these
issues.
Please feel free to contact Tammy Hill at [phone] or me if you have any questions regarding these
comments.
Eric
Eric W. Kulz
Environmental Senior Specialist
N.C. Division of Water Quality
401 Oversight and Express Permitting Unit
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties
https://mail.nc. gov/owa/?ae=Item&t=IPM.Note&id=RgAAAAAAOgPoLNIPQZ06vH V RO... 7/8/2010