20070896 Ver 1_Staff Comments_20070523

NC Division of Water Quality
401 Oversight and Express Permitting Unit
May 23, 2007
Memorandum
To: File
Cyndi Karoly
From: Eric Kulz
Subject: Comments on Restoration Plan
Wolf Pond Stream Restoration Site -Union County (20070896)
Kimley-Horn and Associates/EBX -Full-Delivery Project to EEP
They are proposing to restore two UTs to Adams Branch. The site is located on an agricultural
property in Union County. The proposed plan involves a combination of priority 1 and priority 2
restoration of the two tributaries. Neither restoration includes the headwaters of the streams. I
have a number of issues with this plan.
The plan states "It is proposed that UT1 and UT2 be relocated to a more natural position in the
center of both the valley and the historic floodplain of the streams". Based on aerial photography
and topographic plans provided, it is not obvious to me that the streams have been relocated or
are not in a "natural position".
Also, the Restoration Plan includes a Reference Site Vegetative Communities Map, but does not
include such a map for the proposed site. Both the Upper UT2 and Lower UT2 channels appear
to be located within an existing vegetated riparian zone, measured from the aerial photograph to
be from 70 to over 150 feet wide total. Limited site photographs were taken. According to Page
12 of the plan, areas classified as Piedmont Alluvial forest and Piedmont Bottomland Forest were
"observed within the project area".
If these streams are currently located within existing riparian corridors with reasonably mature
vegetation, the project would violate guidance that is currently being revised but has been being
used by DWQ and USACE for the past several years.
The aerial photograph shows what appear to be channels or ditches in a dendritic pattern located
outside of the project area, within farm fields, and draining to the proposed restoration reaches.
These appear to correspond with topographic crenulations on the USGS map. The plan states,
on Page 8, that the "landowner expects to continue to cultivate that land adjacent to the project
site".
The plan does not address how the discharge from the streams/ditches will be handled, nor even
that such discharge is occurring. I measured over 5,000 linear feet of channels draining the farm
fields to the restoration reaches.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterq ual ity. org/wetlands

NC Division of Water Quality
401 Oversight and Express Permitting Unit
I cannot see how "Benefits will include improved water quality by reducing sediment load through
stabilization and by reducing nutrient and other pollutant input by the addition of forested buffer"
(Page 14) will occur when all that ag land is draining to the channels/ditches and discharging
directly to the stream.
Finally, on a more minor note, the plan proposes Rhododendron maximum as a component of ate
understory. Schafale and Weakley (1990) do not list this species as a component of either
Piedmont Alluvial Forests or Piedmont Bottomland Forests, which the plan says are the targeted
riparian communities. Neither the USDA Plants Database
(http://plants.usda.gov/about plants.html) or Radford, Ahles and Bell (1968) identify R. maximuum
as occurring in Union County.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Senaice Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
ht tp://~ncwaterq ual ity. org/wetlands