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