20051354 Ver 2_Staff Comments_20120614

Strickland, Bev
From: Kulz, Eric
Sent: Thursday, June 14, 2012 2:41 PM
To: Tugwell, Todd SAW; Crumbley, Tyler SAW
Cc: Adams, Amy; Strickland, Bev; Montgomery, Lori
Subject: RE: Watts Property - Perquimans Co. (20051354 v2) (UNCLASSIFIED)
Sounds good to me. I need to pull the old file; as you can see by our project number, Nwe had activity on this site in 2005. I
need to look at -what might have been "agreed upon" back then.
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 ne,,w 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 La-w and may be disclosed
to third parties
- - - -- Original Message---- -
From: Tugwell, Todd SAW [ mailto: Todd. Tug« -ell a usace.armw.mil]
Sent: Thursday, June 14, 2012 2:30 PM
To: Kulz, Eric; Crumblev, Tesler SAW
Cc: Adams, Amy; Strickland, Bev; Montgomery Lori
Subject: RE: Watts Property - Perquimans Co. (20051354 w2) (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
I agree. I've taken a look at the "revised" plan and I still have major issues. At this point, I think -we need to have a meeting
-with EEP and the designer of the site, and having newer been to the property (that I know of), I think it makes sense to go ahead
a schedule a site meeting to discuss the proposal before Nwe approve the permit. This sound good to you?
Todd
- - - -- Original Message---- -
From: Kulz, Eric [mailto:eria.kulz cc ncdenr.QoiI
Sent: Friday, June 01, 2012 9:57 AM
To: Tug-well, Todd SAW
Cc: Adams, Amy; Strickland, Bev; Montgomery, Lori
Subject: Watts Property - Perquimans Co. (20051354 w2)
Todd
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) I strongly oppose approving a Priority 2 CP head-water stream project. It is not clear ho-w much they are excavating (no
plans shoeing 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 ,, as ever the intent of the CP HW Guidance
document, -which they cite (just changed the reference from 2005 to 2007). Dare Lekson killed a project like this that EBX
proposed O o or three years ago.
2) They totally ignored the recommendations regarding seven years of monitoring and tree performance standards (I kno-
they -were just recommendations, but the plan should have been revised to current standards) .
3) They are still shoeing that goofy figure -with a 10 -foot -,vide channel flowing through a 120 to 140 -foot -,vide 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 sho- ws upland species planting. All of the -wetlands sho- wn on their plans are non - riparian.
4) They indicate they are going to use a crest gauge to "document stream floe-" along -with visual observation. Crest gauges
measure the vertical rise and fall of Nvater, they do not provide any evidence of do- n- -alley floe-.
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 Nve are expecting to see on projects
submitted in 2012. As stated above, I think they ended up stuck Nvith 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 Qualit -v
Program Development Unit
1650 MSC
Raleigh, NC 27699 -1650
Phone: [phone] Please note this is a ne-w 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 La-'v and may be disclosed
to third parties
Classification: UNCLASSIFIED
Caveats: NONE