20040325 Ver 1_Staff Comments_20030413

Michael F, Easley, Governor

William G, Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources

Alan W. Klimek, P,E., Director
Division of Water Quality

April 13, 2003

Mickey Suggs
Wilmington Corps of Engineers
Regulatory Branch
P.O, Box 1890
Wilmington, NC 28402-1890

Dear Mr, Suggs:

RE: Comments on Barra Farms II Mitigation Plan
Cumberland County

DWQ staff have reviewed the Wetland Mitigation Plan dated February 2003 prepared by Land
Management Group for Barra Farms, Phase II project in Cumberland County. DWQ staff also made a site visit
to the bank on February 27,2003

We have the following suggestions with respect to this plan:

1, Wetland restoration credit should be available on this site for the removal and replanting of forestry
roads when the parallel ditches are filled or plugged.
2. We support the broadening of the service area for this bank to include the Middle Atlantic Coastal
Plain Ecoregion within the Cape Fear River basin. We acknowledge that specific wetland types
within this Ecoregion (including cypress-dominated depresssional wetlands) should be excluded
from this service area but note that Carolina bays and wet flats are common, non-riparian wetland
types throughout this Ecoregion,
3, In accordance with DWQs' rules and the EPNCOE no-net-Ioss policy, each credit from the bank
must have at least one unit of restoration or creation, Since there are 907 acres of restoration on
this site, we,believe that credits from this bank should reflect this design,
4. We slJpp()r1 the aCgeler~t~d cr~~m rE3IE3i=is~~2Q,edul~ aspr9pc>sed for this b,~nkdue to .its p~st,
success.

Please call me at 919-733-9646 if you have any questions.

Cc: Ken Averitte, DWQ Fayetteville Regio
File copy
Rob Moul, :Land Management Group
John Hennessy, DWQ

N, C. Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd" Raleigh, NC 27604-2260 (Location)
[phone] (phone), 919-733-6893 (fax), (http://h2o,enr,state,nc,uslncwetlands