20181349 Ver 1_KCI Response to IRT Comments MP final_20200901

Strickland, Bev
From:
Reid, Matthew
Sent:
Tuesday, September 1, 2020 4:23 PM
To:
Davis, Erin B
Subject:
RE: Mill Dam Creek
Attachments:
KCI Response to IRT Comments Mill Dam MP final.pdf
Follow Up Flag:
Follow up
Flag Status:
Flagged
Here you go.
Sorry if it wasn't included in the permitting mit plan copies. We always ask the providers to include them at the very
front, but these copies usually go straight to Raleigh and bypass PM's. I'll be sure to reiterate the importance of putting
the response letter at the front of the document in the future.
Have a great Labor Day Weekend!
Matthew Reid
Project Manager —Western Region
North Carolina Department of Environmental Quality
Division of Mitigation Services
828-231-7912 Mobile
matthew.reida-ncdenr.gov
Western DMS Field Office
5 Ravenscroft Dr
Suite 102
Asheville, NC 28801
t ing Compare
Sim
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Davis, Erin B
Sent: Tuesday, September 1, 2020 4:01 PM
To: Reid, Matthew <[e-mail]>
Subject: Mill Dam Creek
Hi Matthew,
Sorry to bother you. I don't have a copy of KCI's responses to IRT draft mit plan comments letter (it wasn't included in
the final mitigation plan or 401 application that was uploaded in Dec. 2018). Do you mind sending me a copy of the
letter please?
Many thanks,
1

Erin B. Davis, PWS
Stream & Wetland Mitigation Specialist
401 & Buffer Permitting Branch
Division of Water Resources
Department of Environmental Quality
919-817-0360 cell
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 [phone] • Fax [phone]
Date: December 7, 2018
To: Kim Browning, USACE
From: Tim Morris, Project Manager
KCI Associates of North Carolina, P.A.
Subject: Mill Dam Creek Restoration Site
Mitigation Plan Review — Response to IRT Comments
Yadkin River Basin - 03040101
Yadkin County, North Carolina
DEQ Contract No. #6898
DMS Project #97136
USACE AID #: SAW-2016-01335
Below are our responses to comments received on the mitigation plan for the Mill Creek Dam Restoration
Site. All of the following changes have been completed in the revised mitigation plan. Please contact me
if you have any questions or would like clarification concerning these responses.
Mac Haupt, NCDWR:
1. Section 3.1.1- Landscape Characteristics - states in second paragraph that Fairview soils are "hydric
interfluvial soils". The Fairview series is a non-hydric soil (Typic Kanhapludult).
- We have removed the hydric reference.
2. DWR believes Section 4.0 - Functional Uplift Potential should have mentioned more about the
existing wetlands on site and their potential to be enhanced. For example, it is possible some of the
existing wetlands may be enhanced while other portions of filled relic stream channel may develop
into wetlands, this will be important to show a net positive functional gain to the wetlands on site
for permit purposes.
We have updated the text in the second paragraph of Section 4.0 to read:
"..... The site will also provide the ancillary benefit of protecting and enhancing 0.43 acre of existing
wetlands (shown in the jurisdictional wetlands in Section 12.8 and Figure 7). These riparian wetlands
will be improved by increased overbank flooding and elevated groundwater levels in proximity to the
restored stream profiles. Additional riparian wetlands may form alongside the restored channels as
well. In particular, the former pond bed along T6 has the potential to develop new wetlands."
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3. Section 6.4 for Tributary 3 does mention that "the stream restoration will serve to improve wetland
hydrology". DWR would prefer that that a gauge be installed to document this statement.
We will install two groundwater gauges within existing wetlands WA (along T7) and WH (along
T8) to characterize benefits from restored streams to wetland hydroperiods.
4. One negative aspect about this project is the number of crossings (10). In the future, DWR requests
that the number of crossings be minimized.
We realize the number of crossings is not ideal, but unfortunately they were necessary to
accommodate the number of landowners (8) involved in this project. We typically try to minimize
the number of crossings as much as we can.
5. There are several tables that note project reaches with very small drainage areas:
a. Trib T3 - 7 acres
b. Trib T4 - 3 acres
c. Trib T6A-2 - 9 acres
d. Trib 8A — 7 acres
Please be aware that the IRT will be paying close attention to the reaches to ensure that the
tributaries maintain an appropriate flow regime. DWR noted that a couple of submitted (DWR)
Stream Forms showed two reaches with low intermittent scores, Tribs 5A and the top of 8A. KCI may
want to consider installing stream gauges in these features.
- We have added stream gauge and/or camera monitoring to TSA and T8A in both the mitigation
plan text and on Figure 10.
6. Section 7.0 Performance Standards- states that "project streams must also show a minimum of 30
days of continuous flow..." Please realize this standard was developed initially for coastal headwater
systems. The standard is currently being applied to intermittent streams statewide. While the IRT is
currently reviewing this standard for intermittent streams outside the coastal plain, the 30-day flow
metric does not apply to perennial streams.
- Noted. We will monitor these streams throughout the year to determine the duration of
continuous flow. We anticipate that the streams classified as perennial on -site will have a greater
period than the 30-day standard.
7. The design sheets need to show the location of the jurisdictional wetlands. This will be a
requirement for PCN review. Tributaries with wetlands adjacent are T7, T8, the top of T3 and UTHC2.
In addition, DWR prefers that the stream plan view and profile view appear on the same page.
We have added the jurisdictional wetlands to the plans. We have made that note about plan and
profile for future plansets.
8. DWR likes that fact that KCI intends to install a stream gauge on Tributary 1A, DWR suggests the
installation occur at Sta 154+25.
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We have moved the stream gauge to this location. As a result, we have also changed the
monitoring cross-section to this location in order to keep monitored dimensional data with the
gauge results.
9. DWR likes the fact that this is a large, mostly contiguous (a lot of crossings) project. Moreover,
DWR likes the proposed Regenerative Stormwater Conveyances that are planned to be installed.
Kim Browning, USACE:
1. Section 4.0: 1 agree with DWR's comment #2, and would add that while I agree that the wetlands on -
site will likely see a functional uplift, and even though there are no wetland credits being sought,
it is recommended that wetland gauges be installed and monitored in order to demonstrate no
functional loss and/or acreage loss of wetlands with this project, especially for the wetlands along
T7. We cannot authorize impacts, even for restoration, if we are not able to demonstrate that projects
won't impact/degrade existing wetlands (or other aquatic resources) without at least ensuring that
those wetlands will be replaced elsewhere. And the best way to do this is through groundwater
gauges.
- We will install two groundwater gauges within existing wetlands WA (along T7) and WH (along
T8) to characterize benefits from restored streams to wetland hydroperiods.
a. It might also be beneficial to include the data collection sheets associated with documenting
existing conditions. NC WAM/SAM forms would be beneficial to document existing
conditions, and to compare to in the event that there's a perceived functional loss associated
with the restoration project.
- We will complete NC WAM forms for the wetlands near T3, T7, and T8 prior to construction
and then again at project close-out.
2. USACE agrees that 10 culverts and two utility crossings seems excessive for this project, especially
the culvert on reach T8 where such a small sections of stream is planned for restoration before the
easement ends.
- We realize the number of crossings is not ideal, but unfortunately they were necessary to
accommodate the number of landowners(8) involved in this project. We typically try to minimize
the number of crossings as much as we can.
3. Section 7.0: Table 4 indicates that both C and B channels are proposed for this project. If that's the
case, please update the Stream Geomorphology Performance standard to include "The
Entrenchment Ratio (ER) shall be no less than 1.4 for all measured riffle cross -sections on a given
reach (for B channels)."
- This has been added to Section 7.0.
4. Please include the location of existing wetlands on the Plan Sheets.
- We have added the jurisdictional wetlands to the plans.
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5. Section 6.7: Please include a description of the planned pond dam removal, as well as the proposed
pond bed sediment removal.
- We have added further description of the removal in Section 6.7 — please see the revised
mitigation plan.
6. Section 8.0: Vegetation Monitoring—Veg plots should be added to the areas with existing
wetlands, particularly along T7 and in the area where the pond bed currently is.
- We have converted three of the planned randomly placed plots to permanent plots within former
pond along T6, Wetland WA along T7, and Wetland WH along T8. See revised Figure 10. Proposed
Monitoring Map.
Sincerely,
Tim Morris
Project Manager
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