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HomeMy WebLinkAbout20051354 Ver 2_Staff Comments_20121001Kulz, Eric From Smith, Heather Sent Monday, October 01, 2012 1 01 PM To Jurek, Jeff, Tugwell, Todd SAW Cc Kulz, Eric, Wilson, Travis W, Wheeler, Tracey L SAW Subject RE Watts discussion (UNCLASSIFIED) Todd, Also, Ecological Engineering reviewed the hydro data again and they came up with an 8% hydrology for the wetland success criteria Sincerely, Heather Smith Eastern Project Manager Ecosystem Enhancement Program 919 - 715 -5590 heather c smith @ncdenr gov Please note that the Ecosystem Enhancement Program's Raleigh office has moved and is physically located in the N C Dept of Administration building at 116 West Jones St , # G111, Raleigh, N C 27603 The mailing address remains 1652 Mail Service Center, Raleigh, N C 27699 -1652 Parking and visitor access information is available on the EEP website - - - -- Original Message---- - From Jurek, Jeff Sent Friday, September 21, 2012 11 37 AM To Tugwell, Todd SAW Cc Smith, Heather, Kulz, Eric, Wilson, Travis W , Wheeler, Tracey L SAW Subject RE Watts discussion (UNCLASSIFIED) Todd, Below I have updated what we will agree to Keep in mind that there is a lot of history (push /pull) on this site and we have tried to make the site meet most people's expectations (sometimes decisions made in 1999 don't equate logically to feelings today) -We agreed on the 1 5 1 ration for stream enhancement -We agreed to five years of monitoring (seven was not the back - breaker, but seven was not in place historically) Two more years if project is unacceptable in five -We agreed on vegetation plot on the slope -We also agree to stem growth of 8 feet at year 5 monitoring period -We said we would put two pressure transducers out to measure surface flow but would not use for success criteria This was the "back- breaker" on project viability that was discussed -We agreed that a 5% hydroperiod was not good enough, we will provide a proper one -We will use the success criteria you mentioned as below Evidence of channel formation within the valley or crenulation must be documented through the identification of field indicators on an annual basis in accordance with the following schedule a During monitoring years 1 through 4, the preponderance of documented field indicators must demonstrate the accumulation of flow within the topographic low -point of the valley or crenulation. Documented indicators may include any of the following indicators or any of the indicators listed in part b i Presence of litter and debris (wracking) indicating a surface water flow, ii Leaf litter disturbed or washed away, ill Matted, bent or absence of vegetation (herbaceous or otherwise) indicative of surface flow, iv Sediment 1 deposition and /or scour indicating sediment transport by flowing water, v Water staining due to continual presence of water, b. During monitoring years 5 through 7, the preponderance of documented field indicators must demonstrate the accumulation of flow within the topographic low -point of the valley or crenulation (documented by the field indicators listed in Part A) and the development of a primary path of flow, stream channel, or ordinary high water mark Documented indicators may include any of the following 1 Formation of channel bed and banks, ii Sediment sorting indicated by grain -size distribution within the primary path of flow, ill Sediment shelving or a natural line impressed on the banks, iv Change in plant community (absence or destruction of terrestrial vegetation and /or transition to species adapted for flow or inundation for a long duration, including hydrophytes) v Development of channel pattern (meander bends and /or channel braiding) at natural topographic breaks, woody debris piles, or plant root systems, vi Exposure of woody plant roots within the primary path of flow, vii Changes in soil characteristics (when compared to the soils abutting the primary path of flow) Let me know if you all can live with this, if not we can discuss further - - - -- Original Message---- - From Tugwell, Todd SAW [mailto Todd Tugwell@usace Sent Tuesday, September 18, 2012 11 43 AM To Jurek, Jeff Cc Smith, Heather, Kulz, Eric, Wilson, Travis W , Subject RE Watts discussion (UNCLASSIFIED) Classification UNCLASSIFIED Caveats NONE army mil] Wheeler, Tracey L SAW, Recktenwald, Marc Jeff, I can't remember who else was at the meeting on site, but I wanted to include them for comment as well - please forward to the providers or others than may have an interest I have taken a look at the responses Please note that we did not agree at the meeting on all these points I have a couple comments listed below When we met on the 28th, I believe you indicated that if 7 years of monitoring were required, the project would not be viable. While I still think that 7 years would be best given the circumstances, I can agree to 5 years, but if we determine that the data is not conclusive after 5 years, we will require additional monitoring You stated that you will place gauges (pressure transducers) across the valley, but that these will not be linked to performance standards I think the intent of the gauges is to document stream flow, which we have stated is a mayor concern for us in this project So we will have to consider the data from the gauges in determining success, even if we don't establish a particular threshold for success I think what you are stating is that you do not agree to the 30 -day consecutive flow standard, correct? If this is the case, then what is the minimum consecutive days of flow that you propose? You have suggested modifications to the performance standards that were proposed in my letter of February 16th (see attached), but you have eliminated Standard 1 (which documented flow - see comment above) and Standard 2, Part b, which I think is critical to demonstrate the formation of a channel Standard 2, Part a really only gets to the movement of water across a site, which is what we expect in the first few years I think this standard would be met in most wetlands regardless of channel formation, so I think it's important to include the Part b as well, which gets to development of a channel I suggest that we shift the timeframes so that Standard 2, Part a runs from monitoring years 1 through 3, and Part b runs from years 4 through 5 Obviously, this is compressed from the original, but if you only z want a 5 year monitoring cycle, we (the IRT) need to have some assurances that the site is developing appropriately, to include the formation of a stream channel That is, after all, the type of credit that will be generated Lastly, my letter also requested that a performance standard for tree vigor be included Given the extent of excavation and earthwork on this project, I strongly feel that this standard needs to be included in the final mitigation plan To account for the shorter monitoring period, it can be adjusted to 7 feet at year 5 instead of 10 feet at year 7 Thanks, Todd Tugwell Special Projects Manager Regulatory Division Wilmington District U S Army Corps of Engineers 11405 Falls of Neuse Road Wake Forest, NC 27587 (919) 846 -2564 We would appreciate your feedback on how we are performing our duties Our automated Customer Service Survey is located at http / /per2 nwp usace army mil /survey html Thank you for taking the time to visit this site and complete the survey - - - -- Original Message---- - From Jurek, Jeff [mailto Jeff jurek@ncdenr gov] Sent Wednesday, September 05, 2012 3 49 PM To Tugwell, Todd SAW Cc Smith, Heather Subject Watts discussion Todd, we appreciate you meeting with us the other day to discuss Watts Below is the summary of what we discussed and what EEP would submit per your comments In response to our discussion on 8/28/12 EEP agrees with the 1 5 1 ratio for enhancement for the project length EEP agrees to monitor for five years, if at the end of the five year monitoring period, the IRT can make the determination, based on inconclusive monitoring data, to have EEP monitor two more years EEP agrees to place a vegetation plot on the slope of the headwater stream EEP will place pressure transducers across a portion of the headwater valley and will monitor /report the results but they will not be used as success criteria EEP will submit a more realistic targeted wetland hydroperiod (to be determined) EEP will use the success criteria suggested by the USACE as listed below 3 Evidence of channel formation within the valley or crenulation must be documented through the identification of field indicators on an annual basis in accordance with the following schedule a During monitoring years 1 through 4, the preponderance of documented field indicators must demonstrate the accumulation of flow within the topographic low -point of the valley or crenulation Documented indicators may include any of the following indicators or any of the indicators listed in part b 1 Presence of litter and debris (wracking) indicating a surface water flow, ii Leaf litter disturbed or washed away, iii Matted, bent or absence of vegetation (herbaceous or otherwise) indicative of surface flow, iv Sediment deposition and /or scour indicating sediment transport by flowing water, v Water staining due to continual presence of water, Jeff Jurek Project Management Manager NC Ecosystem Enhancement Program 1652 Mail Service Center Raleigh, NC 27699 -1652 (919) 715 -1157 phone (919) 715 -2219 fax Jeff Jurek@ncdenr gov <mailto Jeff jurek@ncmail net> E -mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation Classification UNCLASSIFIED Caveats NONE 4