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HomeMy WebLinkAbout20120747 Ver 1_USACE Correspondence_20130118IkO47 DEPARTMENT OF THE ARMY WILMINGTON DISTRICT, CORPS OF ENGINEERS 69 DARLINGTON AVENUE WILMINGTON, NORTH CAROLINA 28403 -1343 REPLY TO p OATTENTIONOF. 18 January, 20 3 Regulatory Division Re: NCIRT Review and USACE Approval of the Devils Racetrack Mitigation Plan (SAW 2012 - 00810) Ms. Suzanne Klimek North Carolina Ecosystem Enhancement Program 1652 Mail Service Center 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 Devil's Racetrack Stream and Wetland Draft Mitigation Plan, which closed on 26 August, 2012. Due to a few significant issues an additional review meeting was conducted on 12 September, 2012 between the USACE, NCDWQ, NCEEP, and Wildlands Engineering. These comments and meeting minutes are attached for your review. Based on our review of the proposed changes from the 12 September, 2012 meeting, we have determined that there are no additional concerns with the Draft Mitigation Plan. The changes discussed in the initial commenting phase and agreed to in the subsequent meeting will be reflected in the Final Mitigation Plan and submitted along with the PCN for permit authorization. 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, CRUMBLEYTYL y'lri" ER AUTRY 1007 � 509975 Tyler Crumbley Regulatory Specialist Enclosures Electronic Copies Furnished CESAW- RG -R/T Brown Jessica Kemp, NCEEP John Hutton, Wildlands Engineering 1, 1 WILDLANDS ENGINEERING September 20, 2012 Mi. Todd Tugwell US AI my Col ps of Engmeei s 11405 Falls of Neuse Road Wake Forest, NC 27587 Re Devil's Racetrack Mitigation Site Response to comments on Diaft Mitigation Plan Dear Mi. Tugwell- We have ieviewed the comments on the Di aft Mitigation Plan dated Septembei 10, 2012 and have ievised tine Mitigation Plan accolduigly We will submit the revised Mitigation Plan along with the PCN as requested Below aie responses to each of your comments For your convenience, the comments are iepr rated with our response in italics. I The mitigation plan indicates that partial credit is to be awarded for portions of the stream and wetland restoration under the power lines on the pioperty, and Table 15 on Page 49 -50 lists a 25% ieduction of credit (1.33.1 ratio) The IRT has previously discussed teduction for stream and wetland projects within maintained utility lines. If the resulting areas will be maintained mechanically as woody pees and sluubs (as proposed in the mitigation plan), the subsequent reduction ofciedit should be 50% If the areas will be treated with herbicide and maintained as herbaceous -only, the subsequent ieduction of credit should be 75 %. Additionally, these areas should be avoided where possible. Ciossmgs needed to maintain the utilities should also be accounted for, and iftheie are stream reaches Immediately adjacent to the easements where the buffer is less than the iequued 50 feet (coastal and piedmont) due to maintenance, these areas may be fti thei reduced in accordance to current guidance for non- standard buffer widths Pet yom comment and ow subsequent discussion of this issue at ow 9112112 meeting, we agree to rertse the ratios as you hm,e suggested using the 75% reduction in credits for wetland and streams nn the power hne easement Tlnese changes hm,e been made to the uutigatnou plan Also based on discussions din nng the 9112112 meeting, we hm�e added tell to the mingation plan slating that we will not meet vegetation n egntrements in power hne easements 2 It is not clear from the plans piovided with the mitigation plan which ditches will remain open, both within and bordering the mitigation site hi particulai, will ditches Iemam open along the boundary of the site with the campground and along Devil's Racetrack Road, and if so, what drainage effect will they have on the wetland restoiation A map indicating all ditches on and bodering the site, Including if they will iemam open, would be helpful fl new figure (Figure 11) has been ci eated tihowmg the plan for which ditches will be filled and which will be left open ni,ahm the pi oject site and along the pi (yea boundaries This figtu a will be included in the final vetmou of the Hiliganon Plan that will he submitted with the PCAa �lhltllands I nguuuuig Ins phom 919 Cif -9956 • la\ 919 S-)I -9947 • 560i Chapel bill Road, 9 1)2 - R alogh NC 27607 3 The Plan shows proposed iestoration a sheam tluough in existing pond on Middle Blanch, along with wetland ►estoiatioii innniediately below t ie pond. We pievi6usly discussed the possibility of using the pond as a BMP ►athei than restoring a stream through it, but still plovid►ng stream credit. Was this option explored? We continue to have concerns about conducting iestoration within_tlfe pond and dam area. Page 64 of the mitigation plan indicated that up to 7 feet of fill would have to graded fiom the dam area, and fill will likely have to be placed within the pond bed Both of these activities inc►ease the likelihood of problems with soils, hydrology and vegetation Please provide moie detail about the proposed wo►k in these areas. it may be moie appiopitate io consider these areas as creation than iestoration due to the fact that so march earthwork has to be conducted to achieve the proposed conditions. iVe agree that file B111P apps oath (herecifter refer/ ed to as a headwater nvetland) within file pond footprint on Middle Branch is a better option and hcn�e revised fire Mitigation Plan to Y eflecl this change By changing to a headii ater Welland, cut depths downstream of the pond can be reduced significantly The discussion on page 64 has been edited to reflect fills change and all other m efen ences to 11iddle Branch hcn,e been edited acco►•dingly Thus cluilige will be shown on the final tonsil llction plans 4 We continue to have concerns that several of the sheanis proposed for the site were likely not streams before the site was converted to agi icultmal use, and that these drainages were constructed as ditches through wetlands If so, the project would result un created streams that would pumas ily serve to under mine the functional value of the wetland in these areas One example of this is North Blanch, which is proposed to be consti ucted through an area of the site where histoi ical aerial photographs do not seem show any indication of a founei stream This drainage will also be substantially reduced in watershed size due to the rerouting of the main stein of Devil's Racetrack Sheam through the center of the site As we have discussed before, it also does not appear that the proposed restoration of Devil's Racetrack Sheam on the east side of Devil's Racetrack Road was located in its proposed alignment based on the historical aerials Rather it appears that this area was moie of an expansive wetland floodplarn adjacent to the Civet Establishing a sheam along the con idol of the dkihng ditch may set ve to unpi ove the connectivity of the sheam with the floodplarn, but to what extent will restore the histoi is conditions and finictions of the system? Additionally, will this approach lead to issues concerning hydrologic hespass of areas of the floodplai in that are not part of the pi6ject? As discussed ill the 91121121RT meeting, North Branch is aJm•isdiclional sb•eam upsh•ernri ofthe ponil ii,here it enters Devil s Racetn•ack Creek with a colifribritmg cb•ar»age area of 119 acres If left in its cm i ent configuration, this stream would remain ni all incised channel that flows into a roadside ditch along Devils Racetrack Road restilting ill poor wale/ quality and contributing to flooding of acjacelnf residential prroperfies II'hile, the/ a is little historical photographic evidence to indicate the original con fgin•afion of flits channel, then e qs a valley sigimmire along the proposed alignment of North Branch Restoration of this /-each cis proposed ii,ill result in reconnection of the stn earn to sal rounding Welland floodplams while significantly uuproving channel •form and reducing potential water quahry stressors Based on dnscussions,al the 9112112 meeting, it appears that the IRT agn ees nvilh this apps oath, lhei-efoi e no modifications to this deSlgan al-e pi oposed Tlhe alignment of Devil's Racetrack Cm eek (East) ►vas also discussed al the 9112112 meeting lVe reviewed the 1911 MRCS soils map showing the alignment of Devil's Racetrack in a sumlar con fguralion to its can n emit statics, discussed tae, facl that diem e is no clem evidence that the ci eek flowed to file south into a lad ge slough that connects to the Neese River, discussed the curl ent degraded sfalus of the stream and the disconnection fr•onh the Meuse via the drop inlet sh•utclitre, and reviewed the landscape setting along lei-m-ace of the Neese as opposed to a low elevation backwaleh irelland condition It is my undeislonding that everyone, agieed that, ii,hile it is unclear u,lhat the Wildlnnd, rn^_uieennL, InL • phnne 9 10551 -99b6 ° Ian 919 -5-i 1 9987 - Wi Ompel Ihll Roar 11 12" - R.ilu =h, NC 27607 it tie historical condition of flits stream channel ivas, the design apps oath i epi esents the best ►vay to connect flits ci eek to the ]Tense River and open tip anadi amons fish spaivnmg habitat Therefor e no modifications to flits design are proposed 1 5. One of the four overall goals of the pioject is listed as iesto►ing fish passage from the Neuse Rive► to Devil's Racetiack Cieek. Is this appiopiiate as a piimaiy goal of the project as opposed to a secondary benefit, and if so, what pei foi mance standards can be included to demonstrate success 1Ve agree that while this is a likely ecological benefit of the project, it should not be considered as a primaq goal We have edited the iitigation Plan to reflect flits change 6 The project proposes to replace the culvert under Devil's Racetiack Road Has approval foi this replacement been received from NCDOT, and are then concerns with getting approval to raise the existing invert of this culvert9 The NCDOT encroaclmtenf agi•eentenf has been discussed in detail ►with the local dish•icl office The official application and associated modeling documentation was submitted to the district office on 9118112 The main concei n of the district office was that we not show a rise in 50 yir floor! elevations on any adjacent pr oper ties The overall site plan will actually reduce 50 yi flood elevations on adjacent par eels by as much as 0 7 ft IJ,e do not anticipate any problems with gelling approval for this action and will pi -owde the final approval leffer to the IRT when it is received 7 Page 68 and 69 of the Mitigation Plan that discuss per formance'standaids iefei to 7 years of monitoring foi certain activities and 5 years foi other activities, including photo documentation and stream and hydrology assessments. Please clearly indicate which monttoiing activities ate pioposed lot 5 years and which are pioposed for 7 years, ensuring that they ate in compliance with the monitoi ing iequnements foi the RFP. All monitor ing actn,ittes are pr oporecifor 7),ears Tlus tivas a mistake in the AIttigatton Plan rnid has been corrected It is oin under standing that f vegetative performance standat ds ai e met by year 5 there is the potential that the IRT would not require vegetative monitoring in year s 6 and 7 This language was left inichanged 8. We have previously discussed our concerns regarding whether several of the pioposed ti ibutaiies will have adequate hydrology, of whether these systems were constructed as ditches through wetlands. Page 68 of the plan includes peifoimance standards that require a minimum flow of 20 consecutive days pet year under normal circumstances This standard seems too low to demonstrate that the channels will be at least rntetmtttent Additionally, it is not cleat from the standards how flow will be documented. Per discussions at the 9112112 meeting, we have changed this performance standar d to 30 days of consecutive flow 9 It would be helpful if Table 15 were modified to include a column foi credits (WMU's and SMU's) lire agree rind have made this change to Table 15 10. No information was p►esented on the location and number of proposed nionitomig wells Please piovlde a copy of the pioposed well and vegetation plots to the USACE foi ieview pi rot to initiating monitor ing The locations of the monitor ing wells and vegetation plots should be placed to represent the entne site, including (lie edges of the pioposed wetland areas Adddionally, placing wells m hanseds peipendiculai to the valley can help in evaluating the site 11hldl,nuk Cngunum„ Inc > phom 919 SCI X1956 • Li\ 919 Sit 9987 • i60i Clupel I till Rudd, 4 122 • Raleigh, NC 27607 An additional figure (Figure 12) has been created showing the plan for monitoring well placement post construction. If you have any questions or need any additional information on the revisions discussed above, you can reach me at (919) 851 -9986 eat 102. We look forward to continuing working with you for the remainder o the project. SincerAy, Iin ygct manag Wildlands Engineering, Inc. • phone 919 -851 -9986 • fax 919 -851 -9987 • 5603 Chapel Hill Road, 9 122 • Raleigh, NC 27607 Devil's Racetrack Mitigation Site Small Stream Hydrologic Assessment Meeting Meeting Summary September 12, 2012 Attendees Todd Tugwell /USACE Tyler Crumbley /USACE Eric Kulz /DWQ Guy Pearce /EEP Jeff Schaffer /EEP Jessica Kemp /EEP Michael Ellison /EEP John Hutton /Wildlands Engineering Jeff Keaton /Wildlands Engineering Meeting Introduction John Hutton of Wildlands Engineering, Inc (WEI) began by discussing the purpose of the meeting and said that the meeting would follow a similar agenda as the previous IRT meeting held on March 15, 2012 John said that the meeting would focus on four topics that were the same as the previous meeting as well as the design approach to Devil's Racetrack East where it connects down to the Neuse River The agenda topics are listed below Small Stream Questions 1 Would stream channels naturally form at the slope /drainage area combinations that exist on the site? 2 Are the small streams on the site Jurisdictional? 3 Are the small streams degraded? 4 What is the correct approach for design on the small streams? Large Stream Questions 1 How did Devil's Racetrack Creek historically cross the Neuse Floodplain? 1 What is the correct approach to restoration of this channelized system? Topic 1: Would streams form in the watersheds of the small channels on the site? John gave an introduction on the overall configuration of the site and showed a map of the site He described the overall site and reviewed the current locations of each of the four small reaches John then presented a series of historical aerial photos to illustrate the conditions of the site and the small streams from 1939 through 1988 He described the changes to the site over time that can be observed on the aerial photos He pointed out that the site was wooded in 1939 but that faint signatures of the stream channels could be seen on the photo Next he showed the 1949 aerial which still showed the site being wooded but more clearly showed the alignments of each of the four small streams at that 1 time John then showed the 1971 aerial photo which still showed the site being wooded It did not appear that significant manipulation had occurred at that time Todd Tugwell pointed out that he thought the site had probably been cleared at some previous time and that the stream signatures looked as if channelization had been done at some point in the past and Eric Kulz agreed John then showed the 1988 aerial photo and discussed how during the time between 1971 and 1988 the site had been cleared and the stream had been channelized and relocated He stated that the aerials showed major manipulation of the site between 1971 and 1988 and that WEI discussions with the farmer who worked on the site during that period also indicated that was true Guy stated that one question he had about the site was whether the small streams would maintain flow in the lower sections once the valley slopes flattened out John said that, while WEI is aware that could be a problem, he didn't think it would be on the Devil's Racetrack site because the slopes on the small streams don't ever become low enough for that to occur Eric discussed his comment on the mitigation plan that Devil's Racetrack Creek (East) may have connected to a slough to the south of the existing channel instead of connecting directly to the Neuse River as WEI plans John referred to the aerial photography and showed a soils map dated 1911 which clearly showed Devil's Racetrack Creek (East) connecting directly to the Neuse as planned by WEI John also discussed WEI's field investigation to see if the creek likely once connected to the slough to the south He explained that there is high ground between the current location of the creek and the slough and a connection between the two was very unlikely Eric then raised another topic that he commented on when reviewing the Devil's Racetrack Mitigation Plan — that valley signatures for the small streams don't show up on the LIDAR available for the site John responded to this comment initially by suggesting that part of the reason the valleys don't show up well on the LIDAR is that the color ramp symbology of the map would not show the valleys because there is too much vertical relief in the area John showed mapping with contour intervals that were based on LIDAR data to illustrate this point Todd agreed with Eric and thought that the valleys should be visible Eric asked if the small streams should be considered stream creation John then followed up by saying that WEI has done a lot of analysis to show that the work proposed for the small streams should be restoration and began reviewing the analyses for the group First John showed the reference reaches for the site and told the group that these reaches were used as traditional reference reaches for the project designs and also to investigate slope - drainage area combinations that lead to stream formation in this landscape The reference reaches include Johanna Branch which has been used as a reference for multiple projects in the area, the Cox and Westbrook mitigation sites near Johanna Branch and four streams from the Scout Camp reference site On the Scout site, there is a small steep stream draining to a larger stream with a flatter slope on either side of the site Todd mentioned that the reference reaches were very good but the small streams did not cross wide floodplains before connecting with the larger streams the way the small streams on the project site would before they connect with Devil's Racetrack Creek John mentioned again that the slopes of the lower reaches of the small streams stayed relatively steep in the proposed designs John then discussed an analysis of channel initiation that WEI had performed on the reference reaches A figure illustrating the results of the study was shown to the group The figure is a plot of the slope (y- axis) and drainage area (x -axis) of locations where the reference streams have well- formed channels, poorly- formed channels, or moderately well- formed channels John discussed that the best way to decipher any relations between slope and drainage area was to visually separate the points to show break lines between slope - drainage area combinations below which no well- formed channels were observed on the reference sites and above which channels were always observed The plot also included slope -area points for each of the design reaches on the project site Jeff and John discussed where these points fell with regard to the break lines The middle and downstream reaches of Southeast Branch fell to the right of the break line representing the slope - drainage area combinations always resulting in channel formation This indicates that natural stream channels would form in those watersheds Two reaches, UTto Southeast Branch and Southeast Branch, fell between the two break lines indicating that channels would sometimes form in those watersheds Four of the reaches, Southwest Branch Upstream, Southwest Branch Downstream, Middle Branch Upstream, and Middle Branch Downstream, fell on or to the left of the breakline representing slope - drainage area relations below which no channel formation was observed This indicates that channels would not form in these watersheds John pointed out, however, that the reference reaches on the plot were formed by rainfall - runoff hydrology John discussed the fact that Southwest Branch and Middle Branch were actually spring fed streams and they had very nearly perennial flow Therefore, even though the plot shown to the group indicates that streams would not form in those watersheds, the plot does not represent spring -fed streams and there is reason to believe that streams would naturally form downstream of springs producing as much flow as the ones at the upstream end of Southwest and Middle Branch Todd mentioned that the plot shows that all of the reference sites are steeper than the design sites and is concerned that project channels will not maintain flow in area where slopes are flatter He stressed that performance standards will be important Topic 2: Are the channels jurisdictional? John then showed pictures of the current conditions of the design reaches and discussed each of these reaches He also showed pictures that illustrated flow conditions in each of the reaches overtime from January 2011 through November 2011 John indicated that flow was observed in these channels all throughout this period Some of the photographs showed discharge monitoring weirs that WEI had installed on the four small channels John discussed the reasons for installing the weirs —to demonstrate continuous flow in the channels and to assist with design discharge determination John showed plots of the discharge data collected at the weirs The data sets for streamflow and rainfall for Southeast, Middle, and Southwest Branches have been updated since the previous meeting in March and include data from December 2011 to early June 2012 (UT to Southeast Branch was not updated) The plots indicated that three of the small streams flowed almost continually for this time period but that UT to Southeast Branch only flowed in response to rain events The plots were also updated with text showing the number of total days of flow, the number of consecutive days of flow, and the number of days flow data were collected for each stream These numbers help to illustrate that the streams flow most of the time John then showed and discussed a table of long -term rainfall averages for Johnston County by month compared to rainfall data collected for several months (updated since the March meeting to September 2011 -June 2012) by the rain gauge installed and monitored by WEI on the project site The table showed that rainfall totals below normal for every month in the period except for May 2012 John indicated that three of the small streams maintained flow during this dry period and that this was a further indication that the streams were perennial An ensuing discussion arose about how many consecutive days of flow the IRT members thought would be appropriate as a performance standard for Coastal Plain streams Thirty days was a length of time that most in the group thought would be appropriate EEP staff present discussed the difficulty of finding streams to restore in the coastal plain and how these types of performance standards would make that even harder Todd brought up the idea of building a headwaters wetland feature to treat runoff in the area at the upstream end of Middle Branch by retrofitting the pond to work essentially as an extended detention wetland rather than rebuilding a stream channel through the pond John said that WEI would not have any problem redesigning that area to be a wetland feature instead of stream restoration Todd discussed that he would want to see water quality monitoring on inflow and outflow of the wetland feature but that the results would not be tied to performance standards for the Devil's Racetrack project The information would be used to help the IRT determine if these types of project features would be appropriate for future projects Todd stated that he was concerned that the flow data only indicated that the ditches were draining surrounding wetlands and groundwater and that if the channel inverts were raised the main source of hydrology might be cutoff John showed profile plots of Middle Branch and Southwest branch indicating the elevation of the spring head in relation to any channel adjustments proposed in the design The spring heads are, in both cases, situated 4 -6 feet above the highest point proposed for grade adjustment on the project Todd brought up the concern that even though flow originates at a higher elevation, flow could be lost in the downstream section due to infiltration when the streams are disconnected from groundwater John pointed out that groundwater would be raised significantly throughout the site as discussed in the next section John then discussed that the stream valleys had been filled and that WEI has had discussions with the farmer who worked the site in the early eighties when the mass grading was completed The grading included channelizing many of the streams on site and filling in some of the valleys Next, John showed an email from Thomas Brown who is the USACE field office representative who is working on the JD determination for the Devil's Racetrack Site The email indicated that Thomas believes that all of the streams on the site except for UTto Southeast Branch are jurisdictional although no official determination has been made at this point Topic 3: What is the potential for uplift if these small streams are restored? John began this discussion topic by showing examples of the existing cross sections of the small streams overlaid with the proposed design cross section The design cross sections would be much smaller and 4 at a, higher elevation than the existing channels John also showed pictures of the streams to show erosion and obvious channelization that will be corrected by the project John also addressed the issue that had been raised about cutting off groundwater flow by raising the stream beds by pointing out that by raising the channel invert of Devil's Racetrack Creek, the entire water table would be raised by several feet so that groundwater would still contribute to stream flow in the small reaches To illustrate this point, he showed a plot of the preliminary Drainmod model results used to analyze the wetland hydrology The plot showed changes in water table depth overtime for both the existing and proposed conditions The proposed water table stayed much higher than the existing demonstrating that the water table would be significantly raised as a result of the project John also mentioned that this is one of the key benefits of the project and that significant ecological uplift would result from the restoration wetland hydrology At this point, Guy raised an issue related to the planting plan of the site He described how the small channels might be completely covered by vegetation and that planting willows on top of the stream banks to shade out shrubs, cattails, etc would help to maintain the channels Michael Ellison suggested that other species such as Green Ash and sycamore could serve the same purpose Michael also mentioned that EEP is concerned with the use of live stakes on stream banks and that they would like WEI to not use on the small stream channel banks as is typically done on this project John said that WEI is planning to plant juncus -carex sod on the site to use as sod mat on the stream banks John stated that WEI would revise the planting plan before finalizing the mitigation plan Topic 4: The design approach John showed plots of the existing and proposed profiles for the small channels He described how the designs that WEI plans to implement would not cut of the springs contributing flow to Southwest and Middle Branches John introduced the topic of the design plan for the connection of Devil's Racetrack Creek (East) to the Neuse River He described the plan for this element of the project and discussed how it will provide a new spawning area for anadromous fish John showed a picture of the current "drop structure" that connects Devil's Racetrack Creek (East) with the river and pointed out that fish cannot swim up Devil's Racetrack Creek with this current configuration The reconstructed confluence will be the level of the river so that migrating fish can swim upstream on the creek Hard substrate will also be used as grade control and as an aid to spawning habitat for shad (a significant anadromous species in the Neuse River) Todd stated that fish passage should not be an overall goal because there is no plan to measure it Jeff Jurek suggested leaving as a goal in the mitigation plan but calling it a secondary goal Eric stated that he was not sure if Devil's Racetrack (East) should be considered stream restoration as opposed to stream creation John re- emphasized that WEI explored all options to redesign this portion of the project, including connecting Devil's Racetrack Creek to the slough to the south of the current channel John stated that all available information indicates that a stream has been in the location of the proposed alignment for Devil's Racetrack Creek (East) for at least as long as any recorded information indicates He said the design represents the best possible way to connect the Creek to the Neuse River Next there was a brief discussion on the agricultural ditches on the site that will be filled Todd asked for clarification on which ditches will be filled John explained the plan for filling the ditches, including the ditch along Devil's Racetrack road which will be filled to the elevation of the culvert that will be replaced under the road Since this ditch will not be filled all the way to the surrounding floodplain, Todd indicated that he would like to see a groundwater monitoring well near this ditch to show the effect of leaving the ditch partially unfilled on nearby wetlands Todd then stated that, in general, the IRT would like to see proposed well locations for groundwater monitoring with future mitigation plans so that they have an opportunity to comment on well placement John asked if there was a target for number of wells for a particular area and Todd said that there was not John suggested for Devil's Racetrack that wells be installed in transects across the site John also mentioned for IRT members who were not present at the March 15 meeting that monitoring weirs could be installed at log drops in the small streams to monitor flow to see if streams are meeting hydrology success criteria Todd then stated that he did not think any stream or wetland credit should be given for the areas of the project within the power line easement A general discussion of how this should be applied to mitigation projects followed Todd stated that since he had put a reduced credit ratio of 4 1(75% reduction in credits) for areas in the power line easement in his written response to the mitigation plan, that he would be OK with that ratio for those areas on the Devil's Racetrack site Todd also asked that WEI state in the mitigation plan that vegetation success criteria would not be met in the power line easement Since WEI had no more information to present, a summary discussion ensued Todd stated that he had no "over- riding comments" and indicated if the items discussed during this meeting were addressed in the final mitigation plan then it would be approved He asked that WEI send a memo describing the changes that were going to be made based on the discussions during this meeting Eric said that his comments about the project had all been addressed during this meeting and that he had no further comments He indicated that he would send a follow up response to the IRT stating that his concerns had been addressed Todd stated that when the final mitigation plan is received, the IRT comment period will end The meeting was adjourned