20120774 Ver 1_Comment Memo Mit Plan Review_20120824

REPLY TO
.ATTENTION OF
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403 -1343
CESAW- RG /Crumbley August 24, 2012
SUBJECT: NCIRT Comments During 30 -day Mitigation Plan Review
Purpose: The comments listed below were posted to the NCEEP Mitigation Plan Review Portal
during the 30 -day comment period in accordance with Section 332.8(8) of the 2008 Mitigation
Rule.
NCEEP Project Name: Jacobs Ladder Stream Mitigation Site (EEP -IMS# 95023), Rowan County,
NC
USACE AID #: SAW 2012 -01007
30 -Day Comment Deadline: August 23, 2012
1. 8/22/2012- N.C. Division of Water Quality; Eric Kulz:
No comments or concerns regarding this property, pending a site visit by DWQ (Alan
Johnson - MRO), along with a visit to Jacob's Landing.
2. 8/23/2012- U.S. Environmental Protection Agency; Jeffrey Garnett:
I would like to reiterate comments that I made on the Jacob's Landing bank: The plan
calls for some reconstructed culverted crossings. I request that the Provider submit
detailed plans of culvert installations that adequately ensure that passage for aquatic
life is achievable. Additionally, one of the goals of the project is to "reduce the sediment
supply entering Irish Buffalo Creek." Monitoring channel forms over the first five years
of the bank only serves as a surrogate that sediment loads are decreasing. The
assumption is being made that improving the channel will reduce sediment loads, but
no quantifiable way to test this is being presented. The Provider should develop a
quantifiable plan to directly measure success of the project goal. For example, simple
turbidity measurements could be taken on a regular basis (during base flows and bank
full events) both upstream and downstream of the site. These measurements should be
taken before restoration, during restoration, and for a minimum of five years post -
restoration in order to document achievement of the goal.

3. 8/23/2012 -U.S. Army Corps of Engineers; Tyler Crumbley and Todd Tugwell:
a. Please ensure that the performance standards for channel dimension [(as described
in Sections 9 and 10 of the document (pgs. 35 -38)], are in accordance with the 2003
Stream Mitigation Guidelines (1 cross - section per 20 bankfull width lengths) and that
the performance standard for Bed Materials is instituted to show a change to a pre-
determined desired composition, rather than purely an evaluation of sediment
transport.
b. Section 9.0, pg. 35 reads: "The purpose of monitoring..." please change to "The
purpose of geomorphological monitoring ..."
c. Section 9.0, pg. 36, vegetation: Please add "planted, living stems per acre." Also,
please remove the year 4 performance standard of 288 stems per acre.
d. Site Plan and Profile, (sheet 11 of 23), Sta. 119 +25: A 50' crossing is proposed.
Please ensure that all crossings on the project are wide enough to allow for future
planned uses on the property, including any municipal or DOT mandated road
widths, if anticipated.