20051354 Ver 2_Staff Comments_20120601

Strickland, Bev
From: Kulz, Eric
Sent: Friday, June 01, 2012 9:57 AM
To: Tugwell, Todd SAW
Cc: Adams, Amy; Strickland, Bev; Montgomery, Lori
Subject: Watts Property - Perquimans Co. (20051354 v2)
Attachments: Watts Property LIDAR.pdf
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I just reviewed the Watts Property "revised" mitigation plan. I remain to have a lot of real problems with this site. This
appears to be a site they bought a long time ago (2003) and are determined to shoehorn a stream project into it.
They pretty much ignored all of your comments in your February 16, 2012 letter.
My issues are as follows:
1) 1 strongly oppose approving a Priority 2 CP headwater stream project. It is not clear how much they are
excavating (no plans showing existing and proposed elevations), but they are excavating a valley (where one
already appears to exist on the topo map and LIDAR — see attached) and using the excavated material to fill
ditches. BTW they are also retaining a "permanent spoil pile" on a portion of the property, so it sounds like they
may be excavating a LOT. Perhaps another DOT project a la Clayhill, where they plan to use the spoil pile? I
don't believe this excavation was ever the intent of the CP HW Guidance document, which they cite (just
changed the reference from 2005 to 2007). Dave Lekson killed a project like this that EBX proposed two or
three years ago.
2) They totally ignored the recommendations regarding seven years of monitoring and tree performance standards
(I know they were just recommendations, but the plan should have been revised to current standards) .
3) They are still showing that goofy figure with a 10 -foot wide channel flowing through a 120 to 140 -foot wide
band of "upland species ". This does not in the least resemble their reference sites, nor does it resemble what is
described in the CP guidance. They talks about creating a Coastal Plain HW forest, which is a riparian wetland,
but this is the area on the plan which shows upland species planting. All of the wetlands shown on their plans
are non - riparian.
4) They indicate they are going to use a crest gauge to "document stream flow" along with visual observation.
Crest gauges measure the vertical rise and fall of water, they do not provide any evidence of down - valley flow.
5) On page 42, there is a discussion under 8.2 Wetlands that talks about the hydrology performance standard as
12.5 %, but then goes on to say that areas between 5% and 12.5% will be classified as wetlands when
hydrophytic veg and hydric soils are present. I think I know where that is going.
There appear to be a number of constrains due to surrounding land usage, requiring perimeter ditches to remain in
place and a berm to remain in place along the NE side of the site.
Overall, I think this is a bad site and is not going to result in the quality of mitigation credit we are expecting to see on
projects submitted in 2012. As stated above, I think they ended up stuck with this property and are trying wedge a
project into it.
Give me a call if you would like to discuss.

Eric
Eric W. Kulz
Environmental Senior Specialist
N.C. Division of Water Quality
Program Development Unit
1650 MSC
Raleigh, NC 27699 -1650
Phone: [phone] Please note this is a new phone number effective May 10, 2012
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

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