20020122 Ver 1_More Info Received_20020404

EC:NL=rGIC
March 28, 2002
John T. Thomas, Jr.
Acting Chief
USACE - Raleigh Regulatory Field Office
6508 Falls of Neuse Road, Suite 120
Raleigh, North Carolina 27615
RE: Victory Junction Gang Camp
Level Cross, Randolph County, North Carolina
Action ID No. 200220199
Dear John:
Ecologic Associates, P.C.
218-4 Swing Rd. • Greensboro, NC 27409
[phone] • Fax [phone]
www.ecollogic-nc.com

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On behalf of Victory Junction Gang Camp, Inc., the following information is submitted
in response to your letters (2) dated March 18, 2002 regarding comments received from
the US Fish and Wildlife Service (FWS) and the NC Wildlife Resources Commission
(WRC) on the public notice of the above referenced Individual Permit application.
Please distribute the enclosed copies of this letter with attachments, including the
mitigation plan, to the FWS and the WRC.
The responses below are labeled alphabetically to correspond to the concerns listed in
your letters.
a. There is currently no data to support a statistically-derived "natural, instream flow
volume", or minimum flow, for the subject stream, as the stream is much too small to
support a USGS gage station for data collection. In fact, it is our firm belief that the
subject stream at the dam location is an intermittent stream, not a perennial stream as
classified by the USACE. Our Principal Biologist, Ken Bridle, PhD, performed a stream
classification survey at the property prior to stream channel disturbances using NCDWQ
criteria and professional judgment and found the stream to be intermittent to a point
below the proposed dam and adjacent to a hillside seep wetland. A copy of his
classification report dated October 11, 2001 is enclosed.
As such, we believe that no meaningful minimum flow is calculable for the stream. The
inflow to the proposed pond is so sporadic that the owner proposes to make supplemental
water available via groundwater wells in order to keep the pond full. No continuous
flowing water has been observed in the stream above the hillside seep during any of our
site visits beginning in September, 2001, even immediately following a significant
rainfall event (subterranean flow was evident). Pond overflow during significant runoff
events should simulate the periodic pre-dam flows that occur. If necessary, the pond's
primary spillway could be fitted with a valve to allow releases during periods of drought.
+ M• Printed on recycled paper.
Victory Junction Gang Camp - Action ID No. 200220199
b. Copies of the compensatory mitigation plan submitted with the. IP application are
enclosed for forwarding to the FWS and the WRC. Forested riparian buffers at least 50
feet wide are proposed as part of the stream restoration plan.
Regarding the WRC's request that "the applicant be required to fully mitigate for total
stream impacts", we refer to the aforementioned stream classification performed by
EcoLogic and our understanding of current USACE policy concerning mitigation.
Specifically, the 1,270 linear feet of proposed impact to the declared perennial stream is
not disputed, as we believe that reach to be an "important" intermittent stream. The
1,160 linear feet of proposed impact to the declared intermittent stream is not believed to
warrant mitigation, however. The FWS either agrees or has "discounted" this reach..
Dr. Bridle classified the disputed reach as ephemeral rather than intermittent due to its
lack of significant aquatic biological activity and lack of influence on the watershed (Dr.
Bridle is also a Level 4, Rosgen-trained stream consultant and a published expert on
Piedmont and Mountain wetland hydrology - see enclosed resume). Todd Tugwell of the
USACE, upon his inspection of the reach, stated that he believed it to be an
"unimportant" intermittent stream. It is our understanding that unimportant intermittent
streams do not normally warrant mitigation. As such, we believe that the proposed 1,600
feet of restoration is adequate compensation for the aforementioned impacts.
Regarding the FWS's request for "evidence that this stream reach (the proposed
restoration reach) requires restoration", the enclosed mitigation plan includes. stream
mitigation data that supports the need for restoration. The banks are bare and exhibit
signs of active erosion along almost the entire length of the reach. Roots from trees
located atop the banks are exposed. The lower portion of the riparian corridor is heavily
dominated by Chinese Privet, an invasive exotic shrub, and other invasive exotic species.
The lower portion of the proposed restoration reach is moderately entrenched due to head
cutting. In the middle of the reach, a culverted road crossing has created multiple
problems. Below the culvert, a scour hole has formed, and due to the height of the
culvert above the water surface, fish passage in the upstream direction is prohibited.
Upstream of the culvert is an excessively long backwater pool (200+ feet). This pool is
straight. The straightened (channelized) section extends upstream beyond the pool.
Above the straightened reach, there are several eroding meander bends. Above the
meanders is a significant bedrock outcrop (knick point), which is the proposed upper
limit of the restoration reach.
The preliminary restoration plan proposes to lay back the banks in the lower portion of
the reach to create stable growing surfaces and bankfull benches. The existing culvert
will be removed to improve stream hydraulics and so that fish may access upstream
destinations. (Foot bridges are proposed for future stream crossings.)' Sinuosity will be
restored to the straightened reach upstream of the existing culvert, and eroding bends will
be reshaped and stabilized. The restored stream will be a stable, bedrock-controlled C4
channel upstream of the existing culvert and a B4c channel downstream (Rosgen
classification). Invasive exotic vegetation will be removed and replaced with native tree
3/28/02 2 EcoLogic Associates, P.C.

Victory Junction Gang Camp - Action ID No. 200220199
and shrub species. Revegetation of disturbed or created bankfull benches will be with a
native herbaceous mix, and coir matting with live staking will be used to stabilize banks.
c. Both agencies have requested a forested buffer around the lake 50 to 100 feet in
width. Such a buffer is proposed and desired by the camp to maximize natural area and
to discourage campers from accessing the lake at other than the designated area (boat
dock/fishing pier) for safety reasons. The enclosed Proposed Pond Design Plan (Drawing
1) shows the proposed pond highlighted in blue and proposed forested areas highlighted
in yellow. The proposed forest buffer is at almost all locations greater than 50 feet in
width and exceeds 100 feet along most of the west shore. Much of the forest buffer is
undisturbed woodland that has not been altered during preliminary site work. Lakeside
areas disturbed during pond construction or that were previously unvegetated will be
reforested after pond construction is completed.
d. A comprehensive stormwater management plan for the site has yet to be completed,
so the WRC's suggestions (items 6 and 7) can be thoughtfully considered during its
development. The use of impervious surfaces will be optimized to balance
environmental concerns with economic, utility and safety concerns. Since many of the
campers will be in wheelchairs or will need other aids to walk, hard surfaces will be
necessary on primary walks and trails for mobility and safety (trip hazard minimization).
The use of curb and gutter is not planned for drives and parking lots.
Also enclosed for your information is a letter from the NC Department of Cultural
Resources dated March 18, 2002 requesting additional site information relative to the
potential for significant archeological sites. We will be responding to that request soon
and will mail a copy to you.
If you have questions or need further information, please call our office.
Respectfully,
EcoLogic Associates, P.C.
Mark A. Taylor, PE
Project Manager
Enclosures
C: Brian Collier, CEO, Victory Junction Gang Camp, Inc. (w/ new enclosures only)
Dean Spinks, AIA, Victory Junction Gang Camp, Inc. (w/ new enclosures only)
v1 John Dorney, NCDENR - Division of Water Quality (w/o enclosures)
3/28/02 3 EcoLogic Associates, P.C.