20120396 Ver 1_401 Application_20121206

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PROGRAM
December 4, 2012
Ian McMillan, 401 Coordinator
Division of Water Quality
401 Wetlands Unit
1650 Mail Service Center
Raleigh, NC 27699 -1650
Re: Permit Application- Moores Fork Stream Restoration Project, Surry County (EEP
Design- Bid -Build Project)
Dear Mr. McMillan
Attached for your review are two sets of copies of 401/404 permit application package and
mitigation plans for Moores Fork stream restoration project in Surry County. A memo for the
permit application fee is also included in the package. Please feel free to contact me with any
questions regarding this plan (919- 707 - 8319).
Thank you very much for your assistance.
Sincerely
Lin Xu
Attachment: 404/401 Permit Application Package (2 originals)
Final Mitigation Plan (2 originals)
Permit Application Fee Memo
CD containing all electronic files
E ... Prot". Oar Stag � A
North Carolina Ecosystem Enhancement Program, 1652 Mail Service Center, Raleigh, N[ 11699 -1652 / 919 -115 -0416 / www.nceep.net

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MEMORANDUM:
TO: Cindy Perry
FROM: Lin Xu V
SUBJECT: Payment of Permit Fee
401 Permit Application
DATE: December 4, 2012
The Ecosystem Enhancement Program is implementing a stream restoration and
enhancement project for Moores Fork site in Surry County. The activities associated
with this restoration project involve stream restoration related temporary stream impact.
To conduct these activities the EEP must submit a Pre - construction Notification (PCN)
Form to the Division of Water Quality (DWQ) for review and approval. The DWQ
assesses a fee of $570.00 for this review.
Please transfer $570.00 from Fund # 2981, Account # 535120 to DWQ as
payment for this review. If you have any questions concerning this matter I can be
reached at 707 -8319. Thanks for your assistance.
cc: Ian McMillan, 401 Coordinator, DWQ
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North (arolina Ecosystem Enhancement Program, 1652 Mail Service (enter, Raleigh, NC 21699 -1652 / 919 -115 -0416 / www.nceep.net

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Office Use Only:
Corps action ID no.
DWQ project no.
Form Version 1.3 Dec 10 2008
Pre - Construction Notification C Form
A. Applicant Information
1. Processing
1 a. Type(s) of approval sought from the
Corps:
® Section 404 Permit ❑Section 10 Permit
1 b. Specify Nationwide Permit (NWP) number. 27 or General Permit (GP) number:
1c. Has the NWP or GP number been verified by the Corps?
❑ Yes ® No
1d. Type(s) of approval sought from the DWQ (check all that apply):
® 401 Water Quality Certification — Regular ❑ Non -404 Jurisdictional General Permit
❑ 401 Water Quality Certification — Express ❑ Riparian Buffer Authorization
le. Is this notification solely for the record
because written approval is not required?
For the record only for DWQ 401
Certification:
❑ Yes ® No
For the record only for Corps Permit:
❑ Yes ® No
1f. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation
of impacts? If so, attach the acceptance letter from mitigation bank or in -lieu
fee program.
❑ Yes ® No
1g. Is the project located in any of NC's twenty coastal counties. If yes, answer 1h
below.
❑ Yes ® No
1 h. Is the project located within a NC DCM Area of Environmental Concern (AEC)?
❑ Yes ® No
2. Project Information
2a. Name of project:
Moores Fork Stream Restoration Project
2b. County:
Sur y County ^,
2c. Nearest municipality / town:
Mount Airy
2d. Subdivision name:
I
2e. NCDOT only, T.I.P. or state
project no:
3. Owner Information tes Brand,
3a. Name(s) on Recorded Deed:
NCEEP
3b. Deed Book and Page No.
DB504, PG1127; DB504, PG1134; DB426, PG1017; DB325, PG461.
3c. Responsible Party (for LLC if
applicable):
3d. Street address:
2728 Capital Blvd, Suite 1 H 103
3e. City, state, zip:
Raleigh, NC27604
3f. Telephone no.:
919 - 707 -8319
3g. Fax no.:
919 - 715 -2219
3h. Email address:
[e-mail]
Page 1 of 11
PCN Form —Version 1.3 December 10, 2008 Version

4. Applicant Information (if different from owner)
4a. Applicant is:
❑ Agent ❑ Other, specify:
4b. Name:
4c. Business name
(if applicable):
4d. Street address:
4e. City, state, zip:
4f. Telephone no.:
4g. Fax no.:
4h. Email address:
5. Agent/Consultant Information (if applicable)
5a. Name:
5b. Business name
(if applicable):
5c. Street address:
5d. City, state, zip:
5e. Telephone no.:
5f. Fax no.:
5g. Email address:
Page 2 of 11
PCN Form —Version 1.3 December 10, 2008 Version

B. Project Information and Prior Project History
1. Property Identification
1a. Property identification no. (tax PIN or parcel ID):
4090 -57 -5440; 4090 -39 -0783; 4090 -49 -7679; 4090 -39-
0783.
Latitude: 36.506671 Longitude: -
1 b. Site coordinates (in decimal degrees):
80.704115
(DD.DDDDDD) (- DD.DDDDDD)
1c. Property size:
134.33 acres
2. Surface Waters
2a. Name of nearest body of water (stream, river, etc.) to
proposed project:
Moores Fork
2b. Water Quality Classification of nearest receiving water.
Class C
2c. River basin:
Yadkin -Pee Dee (CU 03040101)
3. Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
Forest Land, pastureland and agricultural
3b. List the total estimated acreage of all existing wetlands on the property:
0.83
3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property:
19370
3d. Explain the purpose of the proposed project:
EEP is proposing the Moores Folk stream restoration project to fulfill stream mitigation requirements accepted by this
program for Upper Yadkin River Basin (CU 03040101).
3e. Describe the overall project in detail, including the type of equipment to be used:
Through this project, EEP is proposed to restore, enhance and preserve approximately 19,370 linear feet of Moores Fork
and thirteen previously unnamed tributaries (UTs), provide livestock fencing and alternative water sources to keep
livestock out of the streams, remove invasive plant species, and establish native riparian buffers.
4. Jurisdictional Determinations
4a. Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /
project (including all prior phases) in the past?
❑ Yes ®No ❑ Unknown
Comments:
4b. If the Corps made the jurisdictional determination, what type
❑ Preliminary ❑ Final
of determination was made?
4c. If yes, who delineated the jurisdictional areas?
Agency /Consultant Company:
Name (if known):
Other.
4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation.
5. Project History
5a. Have permits or certifications been requested or obtained for
this project (including all prior phases) in the past?
❑ Yes ®No El unknown
5b. If yes, explain in detail according to "help file" instructions.
Page 3 of 11
PCN Form — Version 1.3 December 10, 2008 Version

j
6. Future Project Plans
6a. Is this a phased project? ❑ Yes ® No
6b. If yes, explain.
Page 4 of 11
PCN Form — Version 1.3 December 10, 2008 Version

C. Proposed Impacts Inventory
1. Impacts Summary
1 a. Which sections were completed below for your project (check all that apply):
® Wetlands ® Streams - tributaries ❑ Buffers
❑ Open Waters ❑ Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a.
2b.
2c.
2d.
2e.
2f.
Wetland impact
Type of jurisdiction
number —
Type of impact
Type of wetland
Forested
(Corps - 404, 10
Area of impact
Permanent (P)
(if known)
DWQ — non -404, other)
(acres)
or Temporary
W1 ❑ P ®T
Grading (Wetland 2)
Riparian
Non - riverine
® Yes
❑ No
® Corps
❑ DWQ
0.009
W2 ❑ P ®T
Grading
g (Wetland 3)
iparian
Non - riverine
® Yes
❑ No
® Corps
❑ DWQ
0.011
W3 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W4 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W5 ❑ P ❑ T
❑ Yes
❑ Corps
[] No
❑ DWQ
W6 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
2g. Total wetland impacts
0.02
2h. Comments:
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a.
3b.
3c.
3d.
3e.
3f.
3g.
Stream impact
Type of impact
Stream name
Perennial
Type of jurisdiction
Average
Impact
number -
(PER) or
(Corps - 404, 10
stream
length
Permanent (P)
intermittent
DWQ — non -404,
width
(linear
or Temporary
(INT)?
other)
(feet)
feet)
M
S1 SPOT
Restoration/Enhancement
Moores Reach
® PER
❑ INT
® Corps
® DWQ
5253
S2 ®P ❑ T
Enhancement I
Silage Reach
❑ PER
® INT
® Corps
® DWQ
3348
S3 ®P ❑ T
Enhancement II
Cow
❑ PER
® INT
® Corps
® DWQ
934
S4 ®P ®T
Restoration
Pond
❑ PER
® INT
® Corps
® DWQ
194
S5 ®P ❑ T
Enhancement
Sam Reach
® PER
❑ INT
® Corps
® DWQ
3434
S6 ❑ P ❑ T
Enhancement
Com Reach /
❑ PER
❑ Corps
1928
UT1
® INT
❑ DWQ
3h. Total stream and tributary impacts
15091
3i. Comments:
Page 5 of 11
PCN Form —Version 1.3 December 10, 2008 Version

4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U.S. then individually list all open water impacts below.
4a.
Open water
impact
number —
Permanent (P)
or Temporary
4b.
Name of waterbody
(if applicable)
4c.
Type of impact
4d.
Waterbody type
4e.
Area of impact (acres)
01 ❑P [IT
02 []POT
03 ❑P ❑T
04 ❑P ❑T
4E Total open water impacts
4g. Comments:
5. Pond or Lake Construction
If Pond or lake construction proposed, then com lete the chart below.
5a.
Pond ID
number
5b.
Proposed use or purpose of
pond
5c.
Wetland Impacts (acres)
5d.
Stream Impacts (feet)
5e.
Upland
(acres)
Flooded
Filled
Excavated
Flooded
Filled
Excavated
Flooded
P1
P2
R Total
5g. Comments:
5h. Is a dam high hazard permit required?
❑ Yes ❑ No If yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
Page 6 of 11
PCN Form — Version 1.3 December 10, 2008 Version

6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If any impacts require mitigation, then you MUST fill out Section D of this form.
6a.
❑ Neuse ❑ Tar - Pamlico ❑ Other:
Project is in which protected basin?
❑ Catawba ❑ Randleman
6b.
6c.
6d.
6e.
6f.
6g.
Buffer impact
number —
Reason
Buffer
Zone 1 impact
Zone 2 impact
Permanent (P)
for impact
Stream name
mitigation
(square feet)
(square feet)
or Temporary
required?
B1 ❑P ❑T
❑Yes
❑ No
B2 ❑ PEI T
❑Yes
❑ No
B3 ❑P ❑T
El Yes
❑ No
6h. Total buffer impacts
6i. Comments:
D. Impact Justification and Mitigation
1. Avoidance and Minimization
la. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
Limit the grading activities within the limit of disturbance area.
1b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
Follow the approved sediment control plan , seed mulch and plant.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for
❑ Yes ® No
impacts to Waters of the U.S. or Waters of the State?
2b. If yes, mitigation is required by (check all that apply):
❑ DWQ ❑ Corps
❑ Mitigation bank
2c. If yes, which mitigation option will be used for this project?
❑ Payment to in -lieu fee program
❑ Permittee Responsible Mitigation
3. Complete If Using a Mitigation Bank
3a. Name of Mitigation Bank:
3b. Credits Purchased (attach receipt and letter)
Type
Quantity
Page 7 of 11
PCN Form —Version 1.3 December 10, 2008 Version

,s
3c. Comments:
4. Complete if Making a Payment to In -lieu Fee Program
4a. Approval letter from in -lieu fee program is attached.
❑ Yes
4b. Stream mitigation requested:
linear feet
4c. If using stream mitigation, stream temperature:
❑ warm ❑ cool []cold
4d. Buffer mitigation requested (DWQ only):
square feet
4e. Riparian wetland mitigation requested:
acres
4f. Non - riparian wetland mitigation requested:
acres
4g. Coastal (tidal) wetland mitigation requested:
acres
4h. Comments:
5. Complete if Using a Permittee Responsible Mitigation Plan
5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
6. Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWQ
6a. Will the project result in an impact within a protected riparian buffer that requires
buffer mitigation?
❑ Yes ® No
6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.
Zone
6c.
Reason for impact
6d.
Total impact
(square feet)
Multiplier
6e.
Required mitigation
(square feet)
Zone 1
3 (2 for Catawba)
Zone 2
1.5
6f. Total buffer mitigation required:
6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in -lieu fee fund).
6h. Comments:
Page 8 of 11
PCN Form — Version 1.3 December 10, 2008 Version

11 . 'f
E. Stormwater Management and Diffuse Flow Plan (required by DWQ)
1. Diffuse Flow Plan
1a. Does the project include or is it adjacent to protected riparian buffers identified
❑ Yes ® No
within one of the NC Riparian Buffer Protection Rules?
1 b. If yes, then is a diffuse flow plan included? If no, explain why.
Comments:
Yes ❑ No
2. Stormwater Management Plan
2a. What is the overall percent imperviousness of this project?
%,
2b. Does this project require a Stormwater Management Plan?
❑ Yes ® No
2c. If this project DOES NOT require a Stormwater Management Plan, explain why:
2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan:
❑ Certified Local Government
2e. Who will be responsible for the review of the Stormwater Management Plan?
❑ DWQ Stormwater Program
❑ DWQ 401 Unit
3. Certified Local Government Stormwater Review
3a. In which local governments jurisdiction is this project?
❑ Phase II
3b. Which of the following locally- implemented stormwater management programs
❑ NSW
apply (check all that apply):
❑ USMP
❑ Water Supply Watershed
❑ Other:
3c. Has the approved Stormwater Management Plan with proof of approval been
❑ Yes ❑ No
attached?
4. DWQ Stormwater Program Review
❑ Coastal counties
4a. Which of the following state - implemented stormwater management programs apply
[I HQW
❑ ORW
(check all that apply):
❑ Session Law 2006 -246
❑ Other.
4b. Has the approved Stormwater Management Plan with proof of approval been
attached?
❑ Yes ❑ No
5. DWQ 401 Unit Stormwater Review
5a. Does the Stormwater Management Plan meet the appropriate requirements? -
❑ Yes ❑ No
5b. Have all of the 401 Unit submittal requirements been met?
❑ Yes ❑ No
Page 9 of 11
PCN Form —Version 1.3 December 10, 2008 Version

V- . %&
F. Supplementary Information
I. Environmental Documentation (DWQ Requirement)
1a. Does the project involve an expenditure of public (federal/state/local) funds or the
® Yes ❑ No
use of public (federal/state) land?
lb. If you answered °yes° to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State
® Yes ❑ No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1c. If you answered *yes* to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
letter.)
® Yes ❑ No
Comments: see mitigation plan
2. Violations (DWQ Requirement)
2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards,
❑ Yes ® No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b. Is this an after - the -fact permit application?
❑ Yes ® No
2c. If you answered °yes° to one or both of the above questions, provide an explanation of the violation(s):
3. Cumulative Impacts (DWQ Requirement)
3a. Will this project (based on past and reasonably anticipated future impacts) result in
Yes ® No
additional development, which could impact nearby downstream water quality?
3b. If you answered 'yes' to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
4. Sewage Disposal (DWQ Requirement)
4a. Clearly detail the ultimate treatment methods and disposition (non - discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
Page 10 of 11
PCN Form — Version 1.3 December 10, 2008 Version

a. I . s
S. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or
❑ Yes ® No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act
® Yes ❑ No
impacts?
❑ Raleigh
5c. If yes, indicate the USFWS Field Office you have contacted.
® Asheville
5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat?
❑ Yes ® No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation
❑ Yes ® No
status (e.g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA- designated 100 -year floodplain?
❑ Yes ® No
8b. If yes, explain how project meets FEMA requirements:
8c. What source(s) did you use to make the floodplain determination?
Lin Xu
11/12110
Applicant/Agents Printed Name
Applicant/Agent's Signature
Date
(Agents signature is valid only if an authorization letter from the applicant
is provided.)
Page 11 of 11
PCN Form — Version 1.3 December 10, 2008 Version

V11
REPLY TO
ATTh MON OF.
Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403 -1343
15 October, 2012
Re: NCIRT Review and USACE Approval of the Moores Fork Stream Mitigation Project Draft
Mitigation Plan (SAW 2011- 02257)
Ms. Suzanne Klimek Dt i; o 10 12
North Carolina Ecosystem Enhancement Program
1652 Mail Service Center W� oeNR ENR & at WATER oU A< s
Raleigh, NC 27699 -1652
Dear Ms. Klimek:
The purpose of this letter is to approve the Draft Mitigation Plan and to provide the North
Carolina Ecosystem Enhancement Program (NCEEP) with all comments generated by the North
Carolina Interagency Review Team (NCIRT) during the 30 -day comment period for the Moores Fork
Draft Mitigation Plan. The plan was pulled from the Portal on 29 May, 2012, but was reposted and then
closed for further Agency comment or dispute on 14 October, 2012. The two comment and response
letters are attached for your review.
Based on our review of these comments and responses, we have determined that no major concerns have
been identified with the latest version of the Draft Mitigation Plan. However, the minor issues with the
Draft as discussed in the attached comment memos must be addressed in the Final Mitigation Plan.
The Final Mitigation Plan is to be submitted with the Preconstruction Notification (PCN) Application
for Nationwide permit approval of the project along with a copy of this letter and a summation of the
addressed comments. If it is determined that the project does not require a Department of the Army
permit, you must still provide a copy of the Final Mitigation Plan, along with a copy of this letter, to the
appropriate USACE field office at least 30 days in advance of beginning construction of the project.
Please note that this approval does not preclude the inclusion of permit conditions in the permit
authorization for the project, particularly if issues mentioned above are not satisfactorily addressed.
Additionally, this letter provides initial approval for the Mitigation Plan, but this does not guarantee that
the project will generate the requested amount of mitigation credit. As you are aware, unforeseen issues
may arise during construction or monitoring of the project that may require maintenance or
reconstruction that may lead to reduced credit.

Thank you for your prompt attention to this matter, and if you have any questions regarding this
letter, the mitigation plan review process, or the requirements of the Mitigation Rule, please call me at
919 - 846 -2564.
Sincerely,
Dgltauysigned by
CRUMBLEY.TYLERAUTRY.100750
WS
Date 2012.10.15 10:4932 -NW
Tyler Crumbley
Regulatory Specialist
Enclosures: Comment Letters
Electronic Copies Furnished:
NCIRT Distribution List
CESAW- RG/McLendon
CESAW- RG- R/Matthews
Jeff Jurek, NCEEP
Julie Cahill, NCEEP
""4

i
SJ _
RffiLY TO
ArreMON OR
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403.1343
CESAW- RG/Tugwell October 3, 2012
MEMORANDUM FOR RECORD
SUBJECT: NCIRT Comments During 30 -day Mitigation Plan Review
Purpose: The comments and responses listed below were posted to the NCEEP Mitigation Plan
Review Portal during the 30 -day comment period in accordance with Section 332.8(g) of the
2008 Mitigation Rule.
NCEEP Project Name: Moores Fork Stream Mitigation Project, Surry County, NC
USACE AID #: SAW- 2011 -02257
30 -Day Comment Deadline: September 29, 2012 (Second Review Period)
1. Eric Kulz, NCDWQ, August 29, 2012:
• The revisions to the technical part of the proposal are acceptable to DWQ. DWQ still
does not feel that the plan adequately justifies increased E1 and E2 ratios based on the
descriptions of the proposed activities and potential uplift described in Table 4a and the
report text. DWQ will defer to the chair of the IRT for the final decision on credit yield
for this project.
Response by Julie Cahill, NCEEP, September 26, 2012: This is addressing Eric Kulz comment
on 8/29/12, EEP is not proposing any ratios relative to treatments /uplifts that weren't
agreed to during the 7/13/12 Moores Fork IRT meeting.

t .1114
REPLY TO
ATTENITON OF.
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403 -1343
CESAW- RG/Tugwell May 29, 2012
MEMORANDUM FOR RECORD
SUBJECT: NCIRT Comments During 30 -day Mitigation Plan Review
Purpose: The comments and responses listed below were posted to the NCEEP Mitigation Plan
Review Portal during the 30 -day comment period in accordance with Section 332.8(g) of the
2008 Mitigation Rule.
NCEEP Project Name: Moores Fork Stream Mitigation Project, Surry County, NC
USACE AID #: SAW- 2011 -02257
30 -Day Comment Deadline: May 29, 2012 (originally May 11, 2012, but NCEEP agreed to an 18-
day extension)
1. Todd Tugwell, USACE, May 25, 2012:
• Stream preservation ratios are proposed at 5:1, which appear to be high for some of the
proposed streams where buffers are not mature or have been logged recently, such as
much of Barn Trib.
• The description of the approach to each tributary needs to be further clarified so that
each reach is addressed separately to describe the conditions, objectives, and activities
proposed to correct the conditions. These descriptions should provide a justification for
the credit ratios, since the ratios for several of the streams appear higher than justified
by the proposed activities, with Enhancement I ratios of 1:1 and Enhancement II ratios
of 1.5:1. The justification for these ratios, which should be based on the proposed
ecological uplift, needs to be explicitly explained in the mitigation plan under the
description for the proposed actions to be taken on the associated reach. In particular,
the reaches listed below do not appear to justify the proposed credit ratio:
• Moores Reach 1 is listed as El with a ratio of 1:1, yet much of the upstream portion
of this reach has vegetation on both sides and during the site visit, no cattle access
to this section was noted. In general, the wooded portion of this reach was in
decent condition, with enhancement potential limited to providing breaks in the
berm along the north side of the channel and planting/preserving a full buffer.
• Moores Reach 3 is listed as E1 with a ratio of 1:1, but several long stretches of the
channel do not appear to be proposed for any modification.

• The planting plan includes luglans nigra, which can have an allelopathic effect on
surrounding vegetation. We recommend this species be removed from the planting list.
• The design discharge for the proposed channels is substantially higher than the regional
curve predicts. Justification for this was provided in the mitigation plan, which stated
that "As noted in the previous section, the design cross sections will accommodate
sediment storage within the channel on point bars and /or in lateral bars upstream of
vane structures. This stored sediment is available for transport during large flow events,
which promotes long -term stability and sediment transport equilibrium." (Section 7.3.3,
Page 26) We are concerned that constructing a larger channel cross section than is
appropriate for the drainage area just to make room for sediment could restrict the
access of the channel to the floodplain and lead to channel instability. Also, if the
source of excess sediment is not address, sediment inputs to the system will continue
even once the additional cross sectional space has been filled with sediment. Please
provide additional justification to address these concerns.
• The plan states "For practical purposes based on available stone and log sizes, the step
height was capped at 16 inches." (Section 7.3.4, Page 27) We believe that 16 -inch steps
will potentially cause both aquatic passage limitations and structural instability. Please
consider revising or provide more detail to explain why this is not possible.
• Table 11 on Page 30 identifies the proposed success criteria (performance standards) for
the project. The proposed standards are much more comprehensive than what is
required by the 2003 Stream Mitigation Guidelines. Many of the standards do not
appear to be enforceable or able to demonstrate the proposed ecological service
enhancement. Additionally, many of proposed standards are not supported by any
monitoring requirement. In particular, the stated success criteria are of concern:
o For the riparian buffer habitat density and diversity states "<20% non - native species
at year 5, based on measurements of aerial extent ", which can be interpreted to
mean that up to 20% aerial coverage of an invasive species is acceptable.
• For the maintenance of stable channel bed and banks, the standards allows up to a
20% change in both cross sectional area and width -depth ratio in single year, which
may be a substantial change, particularly on a large stream.
• For thermal regulations, the project is unlikely to result in a change to water
temperature, so any standard for thermal regulation is likely to fail. Additionally,
taking two temperature measurements over the course of 5 years is not sufficient to
make a determination that the project has reduced water temperature.
• For filtration of runoff, "evidence of floating debris or fine sediment on buffer
vegetation at least twice by year 5" is more a measurement of overbank occurrence
than runoff.
• The use of level spreaders is proposed in the plans and is briefly discussed on page 27,
but no explanation is provided to demonstrate the need or benefit of these structures.
See additional comments by NCDWQ.
• The site vicinity map (Figure 1) appears to show Barn Trib as a restoration reach, while
Table 4 shows Barn Trib as an enhancement I reach. It would also be helpful if the plan
set and Figure 1 would identify the proposed type of work for each reach.

c . . 4►
• Please provide information on the potential impact (fill, drainage, etc.) to existing
wetlands located adjacent to Moores Fork. See additional comments by NCDWQ.
NCEEP Response: None
2. Travis Wilson, NCWRC, May 29,2012:
• Oversizing channel dimensions to promote sediment deposition in the channel is risky
and often leads to buried channel features and habitat. If appropriate, assess the
potential to promote sediment deposition in the floodplain by lowering the bankfull
elevation.
• Several success criteria are problematic: 20% variance for stability is generous and could
identity instability, temperature measurements are inconclusive and unnecessary, and
20% allowance for non - native vegetation is too high specifically since removal of these
species is a design objective.
• Furthermore we concur with comments provide by NCDWQ and USACE.
NCEEP Response: None
3. Sue Homewood, NCDWQ, May 10, 2012:
• The Division will need more detailed justification for credit ratios that are proposed for
the highest end of the typical ranges.
• The Division would like to see the proposed credit ratios called out on the plan sheets
for each reach /tributary.
• The Division requests details on whether work on Moores Fork 2 at Station 33 +00 and
MF3 at Stat 44 +00 can be done with minimal disturbance to adjacent wetlands.
• The Division will need a detailed construction sequence on how work will be
accomplished on the Silage Trib. The Division is concerned about efforts to restore the
Silage Trib without addressing the nutrients entering the channel from the adjacent
Silage runoff.
• The Division does not recommend use of a concave level spreader, and strongly
recommends against the use of a level spreader across swales, draws or channels that
will re- concentrate the stormwater.
• The Division is not comfortable with 20% invasive coverage by aerial extent as a
performance standard.
NCEEP Response: None