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HomeMy WebLinkAbout20040325 Ver 1_EPA Comments_20030225 ~. #~'<J) SrAr~oS' . ^ . ~~~ ~ & \.~ ....~~'< A{ PAO~c. UNITED STATES ENVIRONMENTAL PROTECTIONAG.ENCY REGION 4 f ,,,'1 ;JL& II n Sam Nunn Atlanta Federal Center 61 Forsyth Street, S,W. Atlanta, Georgia 30303 -8960 FEB 2 5 2003 WET~ '- "WAl!~ OUAlity st~ - Colonel Charles R, Alexander, Jr. District Engineer A TTN: Mr, Mickey Sugg Regulatory Division Wilmington District, Corps of Engineers P,O, Box 1890 Wilmington, North Carolina 28402-1890 m,,~~~ SUBJ: Barra Farms Cape Fear Regional Mitigation Bank; Phase II Mitigation Plan February 5, 2003 Dear Colonel Alexander: The U.S, Environmental Protection Agency (EPA), Region 4, Wetlands Regulatory Section has reviewed the February 5, 2003 draft Mitigation Plan, submitted by ECOBANK for Phase II of the Barra Farms Cape Fear Regional Mitigation Banle As we stated with the September 2002 draft, EP A remains pleased with the mitigation plan, and has no significant concerns with the technical proposal for restoration, enhancement, and preservation of wetlands on the site. However, we do have comments relating to the regulatory provisions of the plan, particularly the geographic service area (GSA), credit ratios, and credit release schedule, 1, EP A recommends that the GSA for Barra II remain the same as the GSA for Barra I. At this time, we do not believe it is appropriate to extend the GSA to other areas. We note that the GSA for Barra Farms is larger than most approved banks in North Carolina, which are generally limited to the 8-digit cataloguing unit in which they are located, 2. On Page 22 under Item V(1), the success c;riteria states that the "density'ofplanted species should meet or exceed 320 trees per acre at the end of3 years (post-planting) and/or 260 trees per acre at the end of 5 years (post-planting)," We believe the "or" should be deleted from the sentence, as 260 5-year-old trees per acre is an accepted standard success criteria for mitigation banks in North Carolina, Also, the 260 'trees should be five-year-old trees. 3, In our previous letter, EP A recommended that the method for generating mitigation credits, agreed upon by the MBRT at our June 1,2000 meeting, be used to determine the number of available credits for each Phase (1: 1 for restoration, 2: 1 for enhancement, 3: 1 for creation, and 5: 1 for preservation). In this most recent draft, the sponsor recommends 1 : 1 for restoration, 3: 1 for enhancement, and 10: 1 for preservation. We are unsure from where the proposed credit ratios were derived, The proposed credit ratios are not the ~I l!J1 I ~~ 2 same as those of Barra I, nor are they the same as those for other mitigation banks in North Carolina, We again recommend that the method for generating credits outlined in David Lekson's June 27, 2000 letter to the MBRT, be used to generate credits for Barra II, This method also stipulates that in general, two credits will be debited from the bank for each acre of impact. 4, EP A is pleased that the request for credits from upland buffers has been removed from the mitigation plan, 5, EP A now accepts the proposed credit release schedule, which is the same as the credit release schedule for Barra I. . Thank you for the opportunity to comment on this project. If you have any questions concerning our comments, please contact Kathy Matthews at (706) 355-8780. Sincerely, Ronald, ikulak, Chief Wetlan s Regulatory Section cc: USACE, Wilmington USFWS, Raleigh DWQ/NCDENR, Raleigh NCWRC, Raleigh /'