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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Pocosin Lakes National Wildlife Refuge
205 South Ludington Drive
P.O. Box 329
Columbia, NC 27925 -0329
Phone: [phone]
April 29, 2013
Ms. Karen Higgins, Supervisor
Wetlands, Buffers, Stormwater — Compliance & Permitting Unit
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699
Dear Ms. Higgins:
U'S.
FLSFI &, W UMLWE
SERVICE
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This letter is in response to your April 22, 2013 letter placing our application for a 401 Water quality
certification for our Watershed 2 Hydrology Restoration Infrastructure project (DWQ #: 12 -0953) on
hold. I'm providing the requested information (see below) in order to remove our application from the
"on- hold" status.
In September 2012, I showed Mr. Roberto Scheller (DWQ's Washington Office) the project site and he
indicated he didn't see any problems with the project. On April 26, 2013, at the request of Ms. Jennifer
Burdette (DWQ's Raleigh Office), I showed Ms. Burdette and Mr. Scheller the project site and they
indicated DWQ's concerns regarding the issues raised in your letter have been alleviated.
The berm you are requesting information about will be built on the north side of County Line Canal (see
attached map). The berm will be constructed with dredge material from County Line Canal. The
material will be a mixture of clay, sand, silt, and organics piled to a height of approximately four feet.
After it dries, we'll shape it and it will settle. The finished height of the berm will be 2.5 to 3 feet above
ground level. After construction, the berm will be allowed to vegetate naturally. In this region, berms
have been constructed in this manner for decades without experiencing erosion problems. The berm will
be constructed approximately 25 feet from the edge of County Line Canal; water coming off the canal
side of the berm will have to cross 25 feet of peat soil, with vegetation and woody debris on it, before
entering the canal.
Stop log water control structures (WCSs) in the Evans and Ferebee Canals (see attached map) will drain
excess water held by the berm in to the canal system. Water running south in what's left of the V-
ditches (following the 2008 Evans Road Fire) will encounter the berm and spread out overland east and
west until it reaches one of these structures and flows in to Evans or County Line Canal. Therefore,

2
some inundation at the base of the berm is necessary to restore the hydrology on the adjacent refuge
lands, but the WCSs will limit the amount of that inundation (no matter how high the berm is built).
A greater risk of erosion from the berm comes from the potential for it to be overtopped during a
hurricane. A higher berm (four feet or more) would reduce this risk, but it would require a much larger
footprint than what we've proposed. During and following hurricanes and other large rainfall events,
higher levels of water will be held against the berm until it has time to drain out through the WCSs.
As stated in our application, our objective is to restore, to the extent practicable, the natural hydrology of
the pocosin; it is not to create impounded areas (although some inundation is necessary to achieve our
overall objective). In early 2010, representatives from the US Fish and Wildlife Service (Service) and
NCDWQ met on site to discuss the concerns that DWQ had with the peatland hydrology restoration
work occurring at Pocosin Lakes NWR. A large amount of information was exchanged and DWQ
issued a modified certification based on an enhanced understanding of the restoration work. The Service
has carefully considered the impacts and benefits of peatland hydrology restoration on water quality and
provided a summary of our findings to DWQ in 2010. I have enclosed a copy of that document here for
your information.
I hope this letter provides all the information needed to complete the processing of our application.
Please contact me if you need have any questions.
Sincerely,
lJoward Phillips
Refuge Manager
cc: Josh Pelletier, USA COE

USFWS March 2010 Draft
Preliminary Review — Water Quality Impacts of Historic Peatland
Ditching and Draining and Water Quality Benefits of Peatland
Hydrology Restoration at Pocosin Lakes National Wildlife Refuge
Background: Pocosins, also known as southeastern shrub bogs, are characterized by
very dense growth of mostly broadleaf evergreen shrubs. The typically thick layer of
peat soils underlying pocosins acts as a nutrient and metal sponge over geologic time,
locking -up mercury, nitrogen, phosphorus and carbon in vegetation and the ever
deepening soil layer. As pocosins southeast of Lake Phelps were drained for now
defunct farming and peat mining operations, their nutrient retention functions were
diminished. When these lands became part of Pocosin Lakes National Wildlife Refuge
(NWR) in 1990, managers began restoring natural water levels. Restoration will return
the lands to a more natural state and sequester tons of nutrients, including nitrogen,
which are a source of regional water quality problems.
The North Carolina Division of Coastal Management has a concise overview of the
value of peatlands, the negative environmental consequences of their artificial drainage,
and the importance of restoration (Madden 2005):
"Natural peatlands in coastal North Carolina provide many ecological and societal
benefits. These systems are unique and provide habitat for endangered species,
storage of carbon, protection of estuarine water quality, and flood control, as well as
hunting and recreation. Drainage and modification of peatlands diminishes these
intrinsic values, resulting in soil loss to subsidence, carbon emissions, loss of habitat
and diminished water quality and peat water holding capacity. Restoration efforts
should focus on returning these functions for the benefit of the natural environment
and society."
Wetland restoration is among the high priority actions in the recent North Carolina
Coastal Habitat Protection Plan (Street et al. 2005), and the wetland restoration work at
Pocosin Lakes NWR has long been supported by other natural resource managers in
the State, as evidenced by its overt mention in the Albemarle - Pamlico Estuarine Study's
1994 Comprehensive Conservation and Management Plan (page 107):
"Enhance existing efforts to restore the functions and values of degraded wetlands
and vital fisheries habitats. Develop and begin implementing an expanded program
to restore wetlands.
Agencies such as the U.S. Fish and Wildlife Service, Wildlife Resources
Commission, Division of Forest Resources, Division of Environmental Management,
and the Division of Coastal Management, among others, would seek funds to
develop and demonstrate restoration technology. Restoration demonstration projects
should emphasize endemic species such as Atlantic white cedar and longleaf pine.
For example, the USFWS is now planning to use a two -year EPA 319 Clean Water
Fund grant to develop and conduct restoration projects in the Pocosin Lakes
National Wildlife Refuge."

USFWS March 2010 Draft
The restoration work at Pocosin lakes NWR is also highlighted as a Current Water
Quality Initiative in the North Carolina Division of Water Quality's Tar - Pamlico River
Basinwide Water Quality Management Plan (NCDWQ 1999, Section 3, Chapter 2).
The Service is committed to working with others to ensure the environmentally -sound
restoration of lands we manage. This review was prepared to summarize the science
related to impacts of peatland drainage and the benefits of restoration. While the
information here has been presented previously, the summary is intended to facilitate its
access by interested stakeholders, including the North Carolina Division of Coastal
Management and Division of Water Quality.
Issue 1: Artificial drainage of peatlands on the Albemarle - Pamlico peninsula has
negative environmental consequences, including degraded water quality
The Albemarle - Pamlico peninsula is the site of the greatest pocosin acreage in the U.S.
(Ingram and Otte 1981, Richardson et al. 1981). Many of the pocosin wetlands are also
underlain by peat, including those at Pocosin Lakes NWR where peat depth typically
exceeds 4 -feet and exceeds 8 -feet over large acreages (Daniel 1980, Environmental
Sciences and Engineering, Inc. 1982; USFWS, 1990). The wetland hydrology that
allowed for peat accumulation also provided the conditions for accumulation of
atmospheric mercury and nutrients over geologic time (Zillioux et al. 1993). There is
well- documented concern that drainage- enhanced oxidation of soils re- mobilizes
mercury (Lodenius et al. 1987) and nutrients (Brinson 1991). Artificial drainage also
contributes to off -site water quality impacts by speeding the pace of run -off and
increasing discharge peaks (Kirby -Smith and Barber 1979, Daniel 1980, Gregory et al.
1984). An unintended consequence of drainage is enhanced fire intensity, leading to
soil loss and off -site transport of constituents previously immobilized in the soil matrix.
The water quality impacts of draining these lands can be better appreciated with an
understanding of the historic nutrient and metal accumulation in organic soils, and the
known oxidation of organic soils and off -site impacts following artificial lowering of the
water table.
Nutrients and mercury accumulate in deep organic soils as they form
Pocosins are extremely flat and generally removed from large streams so that their
natural drainage is poor. Poor drainage and organic matter input (leaves, sticks, etc.)
over thousands of years causes soil genesis dominated by organic material
accumulation in the surface layers. Although other soil types are found in and on the
periphery of pocosins, they are characterized by deep organic soils, or Histosols,
with a minimum of 20 -30% organic matter and a depth of organic matter > 40 cm
(Ash et al. 1983; McDonald et al. 1983). Histosols include sapric (muck) and fibric
(peat) soils and combinations of these classifications. The water retention capacity
of histosols further retards water flow, and organic matter influence on natural
pocosin hydrology has been described as a "giant sponge" (McDonald et al. 1983).

USFWS March 2010 Draft
Leaf -fall into the "giant sponge" results in soils with significant quantities of nutrients.
Peat nitrogen content ranges from 0.9 to 2.4 percent dry weight while peat carbon
content averages 43 percent dry weight over several studies (Thompson et al. 2003,
Ingram and Otte 1981, Bridgham and Richardson, 1993). Peatlands store far lower
amounts of phosphorus (Gilliam 1991, Richardson 1999). During their formation, the
raised peat soils' only external source of nutrients is rainfall which is low in
phosphorus; phosphorus is correspondingly the primary limiting nutrient in peatlands
(Walbridge and Richardson 1991, Frost 1995) and therefore highly conserved in the
vegetation and microbial communities. Peatlands hence store, phosphorus, but at a
low rate and the physical accretion of peat soils accounts for most of their long -term
storage (Richardson 1999).
The cation exchange capacity of peat soils is high; they accumulate natural and
anthropogenic sources of metals, including mercury from the atmosphere. The
primary mechanism for global transport of mercury is volatilization to the
atmosphere, movement controlled by weather patterns, and wet and dry deposition
back to the land or water surface (U.S. Environmental Protection Agency 1997).
Mercury in wet and dry deposition tends to bind to organic matter unless re-
disturbed. Thus, pocosins' combination of organic soils, flat topography, and poor
drainage which form the "giant sponge" described by McDonald et al. (1983) results
in an efficient reservoir for historic and current airborne deposition of mercury. Peat
soils are so efficient in their accumulation of mercury that soil cores in peat bogs
have been successfully used to examine trends in atmospheric mercury deposition
through time (Zillioux et al. 1993). Mercury concentrations in peat from the area
south of Lake Phelps ranged from 40 to 193 ng /g (dry weight) with a geometric
mean in surface samples of 71 ng /g (Evans et al. 1984; DiGiulio and Ryan 1987).
For these reasons and others, the peat soils at Pocosin Lakes NWR are a resource
which requires significant management consideration and responsibility. The refuge
is underlain by an estimated 33 million dry tons of peat (Venters 1991). The
magnitude of the peat soil lens ( -4 -8') and the refuge area ( >110,000 acres)
demonstrates the significance of this nutrient and mercury store.
Organic soils oxidize following artificial lowering of the water table
The presence of relatively young ( <10,000 years) peat deposits at the refuge and
their absence in nearby areas is explained by the unique combination of hydrology
(rainfall exceeding run -off and evapotranspiration) and soils that favored peat
formation. An excerpt from the Pocosin Lakes National Wildlife Refuge Hydraulic
and Hydrologic Study and Water Management Plan (USDA 1994) provides a good
overview of the natural state:
"The soils of the NWR were believed to be created by a combination of factors
that exist in the Albemarle - Pamlico Peninsula. The rainfall of this area generally
exceeds the evapotranspiration and groundwater discharge rates, thus resulting
in excess moisture (Heath 1975). The NWR landscape is gently sloping with

USFWS March 2010 Draft
great distances between natural drainage outlets, creating significant drainage
problems that result in ponding of surface water and overland flow during wet
periods (Daniels, Gamble, and Wheeler 1977). This was a significant factor in
the development of the organic soils because the landscape remained saturated
with water for extended periods. Consequently, this enhanced swamp developed
in areas that were higher in elevation than the surrounding mineral soils, thus the
term pocosin, or swamp on a hill (Lilly 1981)."
Degradation of refuge peatlands commenced when mining and farming interests
lowered the water table and removed vegetation impacting two of the critical
components of peat formation. Artificial drainage of peatlands in eastern North
Carolina began before 1800, and considerable acreage in the Albemarle peninsula
was converted before 1900 (Ashe 1894, Lilly 1981, McMullan 1984). The volume of
peat on the Albemarle peninsula is probably less than half the original amount owing
to the effects of drainage, agriculture, and fire (Lilly 1981). There are descriptions of
subsidence exceeding 3 -feet as a consequence of drainage and agriculture (Ruffin
1861, Dolman and Buol 1967, Lilly 1981, Whitehead and Oaks 1979). Drainage of
organic soils can result in the loss of at least a third of peat thickness (Farnham and
Finney 1965), and sometimes more (Dolman and Buol 1967, Lilly 1981).
Some of the initial loss in volume is due to mechanical shrinkage (Dolman and Buol
1967, Skaggs et al. 1980). In addition, drainage makes pocosins drier, which
increases the frequency and severity of fires. Since peat soils have a high organic
matter content, they will burn (Ash et al. 1983; McDonald et al. 1983). A 1985
wildfire covering 38,000 hectares resulted in the loss of as much as a meter of peat
soils in this area (U.S. Fish and Wildlife Service 1990). The most severely affected
area from this fire covered 20,000 acres (Venters 1991); assuming one meter soil
loss and the geometric mean mercury of 71 ng /g, this fire could have resulted in the
release of - 21,000 kg of mercury. Sharitz and Gibbons (1982) note that wildfires in
pocosins during periods of dry whether (and a low water table) can burn enough
peat soil to form a lake when the water table returns to normal levels.
Last, drainage causes peat to oxidize rather than accumulating. If subjected to
drainage, fire, and tillage over a long enough period of time, all blackland soils will
become mineral soils (Lilly 1981, USFWS 2002).

USFWS March 2010 Draft
Soil oxidation and loss contribute nitrogen, other nutrients and mercury to
regional waters. Excess nitrogen and mercury are known sources of water
quality impairment in the Pamlico River and tributaries
Loss of soils results in off -site delivery of a portion of their nutrient and mercury load.
Drainage canals artificially lower the groundwater table and enhance off -site
transport of soil constituents that, when delivered in excess to downstream fresh
water streams and estuaries, become contaminants (Daniel 1980, 1981, Gale and
Adams 1984, Gregory et al. 1984). The land that became Pocosin Lakes NWR was
significantly ditched and drained in the 1970's (Heath 1975; Sharitz and Gibbons
1982; Ash et al. 1983; McDonald et al. 1983). Drainage patterns on Pocosin Lakes
NWR have been described (Heath 1975, Daniel 1980, Soil Conservation Service
1994). Drainage water from Washington County and western Hyde County moves
south in canals toward Clark -Mill Creek and Pungo River.
Excess mercury and excess nitrogen are both parameters of concern for water
quality impairment in the Tar - Pamlico river basin (NCDWQ 1999). Mercury is the
cause of impaired use due to fish consumption advisories in the area. Excess
nitrogen is cited as the parameter of concern for non - attainment of water quality
goals in portions of the Pungo and Pamlico Rivers. Clearly, actions that exacerbate
releases of nitrogen and mercury are counter to water quality management.
Phosphorus is less of a concern because the deep organic soils in the area are low
in phosphorus (Gilliam 1991, Walbridge 1991, Bridgham and Richardson 2003) as is
the drainage water leaving these sites (Kirby -Smith and Barber, 1979, Skaggs et al.
1980, Brinson 1991) unless they drain peatlands modified for agriculture with
significant fertilizer additions.
Peat Methanol Associates analyzed water quality in the area south of Phelps Lake to
determine the potential impact of a proposed peat - methanol plant (Environmental
Science and Engineering 1982). Unfiltered water samples in the major canals
exceeded North Carolina standards for mercury, presumably a result of seepage
from surrounding peat land. Mercury bound to particles suspended in surface water
draining the area would be an additional source of mercury in the Pungo River
(Hinesley and Wicker 1997). Recall from the discussion above that peat soils
contain 0.9 to 2.4 percent nitrogen; any off -site transport adds more of problem
parameters to the receiving waters.
The impacts of drainage in the area have been concisely stated by Daniels (1980,
1981):
"...drainage and development of wetlands, particularly wetlands underlain by
deep organic soils, will result in some rather substantial changes to water quality.
When the increased amounts of nutrients, sediment, and other dissolved
constituents are rapidly carried by canal runoff to coastal waters, the resulting
drop in salinity and increase in nutrients can result in algal growth and
eutrophication and ultimate disruption of marine habitat along the coastal fringe"

USFWS March 2010 Draft
Knowledge that altered redox cycling and overall oxidation of peat soils from artificial
drainage can lead to nutrient (Ash et al. 1983) and mercury (Zillioux et al. 1993)
release supported large scale efforts by the Service and partners to restore wetland
hydrology at Pocosin Lakes NWR. The benefits of wetland restoration are well -
recognized. The 1994 and 1999 Basinwide Management Plans for the Tar - Pamlico
basin note that large portions of the Pamlico River and the Pungo River were
considered partially impaired and recommended a 30% reduction of nitrogen loads.
The following information documents how wetland restoration contributes to meeting
that goal.
Issue 2: Wetland restoration can retard the off -site loss of soil constituents,
reestablish the nutrient and metal sequestration realized in soil genesis, and help
protect water quality
Water quality is affected by land use (Chescheir et al. 1990, Evans et al. 1989, Skaggs
et al. 1980, Treece 1994). Drainage water from undisturbed forested watersheds carries
a lower nutrient load than drainage water from developed soils. Restoration of wetland
conditions in peatlands formerly drained for agriculture will reduce nutrient export, and
improve water quality (USFWS 2002). In short, the engineering aspects of the
hydrology restoration provide a mechanism for improving the quality of waters
discharged via off -site transport. Three important aspects of this restoration for water
quality benefits are discussed next.
North Carolina Division of Water Quality and U.S. Environmental Protection
Agency- funded Clean Water Act 319 nonpoint source pollution reduction
demonstration project funds supported on -site research that demonstrates the
efficacy of drained peatland restoration
As noted in the 1994 Albemarle - Pamlico Estuarine Study CCMP, the Service
received USEPA funding for a demonstration project on the benefits of drained
peatland restoration. In 1995, the Service began installing flashboard risers to
restore wetland hydrology to a 17,000 -acre tract on Pocosin Lakes NWR (USFWS
2002). In the original project, a grid of stainless steel piezometers was
systematically installed across the 640 -acre area. Depth of the water table, nitrogen
and mercury concentrations in surface water were measured quarterly for 3 years in
canals adjoining the study blocks. The goal of exporting less than 13 ng /liter of
mercury in the surface water of canals was realized. In 1997, 1998, and 1999,
average mercury concentrations in surface water were 7 -9 ng /liter. Heavy
construction activity in Boerma canal during 1999 caused no observable change in
mercury concentrations in drainage water. Analyses indicate that wetland
restoration efforts have reduced mobilization of mercury from these soils (Hinesley
and Wicker 1996, 1997, 1998).
Peer reviewed calculations estimate substantial nutrient benefits of
restoration

USFWS March 2010 Draft
The total nitrogen and carbon sequestration estimate for restored peatlands has
three primary components: 1) the amount retained in peat soils once soil genesis is
re- established, 2) the amount retained that would otherwise be lost without
hydrology restoration (or the stop loss component), and 3) the amount sequestered
in the above ground biomass. The following discussion details the calculations for
estimates of each component; these calculations have been reviewed by soil and
wetland scientists with North Carolina State University and Duke University.
1) Amount retained in peat soils
• Depth of peat lens northwest of Pungo Lake = 7.6 feet (Dolman and Buol 1967)
• Age of peat soils northwest of Pungo Lake = 7500 y (Dolman and Buol 1967)
• Bulk density range from 0.049 to 0.347 g /cm3 (Thompson et al. 2003,
Walbridge 1991, Ingram and Otte 1981)
• Peat nitrogen content 0.9 to 2.4 percent N dry weight; Peat carbon content
42.56% (Thompson et al. 2003, Ingram and Otte 1981, Bridgham and Richardson,
1993)
Nitrogen: Assuming a peat bulk density of 0.2 g /cm3 (or 5.66 kg /ft3, mid -range from
above) and a peat nitrogen content of 1.35 %N d.w. (mid -range for site - specific values
reported above), the amount of nitrogen sequestered in peat soils is estimated at 7.4 lb
N /acre /yr
Carbon: Assuming a peat bulk density of 0.2 g /cm3 (or 5.66 kg /ft3, mid -range from above)
and a peat carbon content of 42.56 %C d.w., the amount of carbon sequestered in peat
soils is estimated at 234.1 lb C /acre /yr
2) Amount retained which would otherwise be lost without hydrology restoration
• Rate of peat loss in current drained state = 0.8 cm /yr (Dolman and Buol 1967)
• Peat bulk density range from 0.049 to 0.347 g /cm3
• Peat nitrogen content 0.9 to 2.4% N d.w.; Peat carbon content of 42.56%
Nitrogen: Assuming a peat bulk density of 0.2 g /cm3 (or 5.66 kg /ft3, mid -range from
above), a rate of peat loss of 0.8 cm /yr (or 0.026 ft/yr), and a peat nitrogen content of
1.35 %N d.w. (mid -range for site - specific values reported above), the amount of
nitrogen retained that would otherwise be lost without hydrology restoration (or the
stop loss component) is estimated at 193 lb N /acre /yr
Carbon: Assuming a peat bulk density of 0.2 g /cm3 (or 5.66 kg /ft3, mid -range from
above), a rate of peat loss of 0.8 cm /yr (or 0.026 ft/yr), and a peat carbon content of
42.56 %N d.w., the amount of carbon retained that would otherwise be lost without
hydrology restoration (or the stop loss component) is estimated at
6,077 lb C /acre /yr
3) Amount sequestered in the above ground biomass
• Above ground biomass in tall pocosins = 3300 to 4700 g /m2 (Christensen et al.
1981) as cited in Sharitz and Gibbons (1982)
• Mean percent nitrogen in live tissue from wetland bog habitat = 0.85% N d.w.
with range reported 0.08 — 2.08% N d.w. (Bedford et al. 1999). Individual studies

USFWS March 2010 Draft
referenced indicate that shrub pocosin habitat vegetation within this category fall at
the low end of this range (e.g., 0.082 and 0.096% N d.w. for fetterbush (Lyonia
lucida) and zenobia ( Zenobia pulverulenta), respectively)
• Age of mature vegetation stand in tall pocosins = 50 years (conservative)
Nitrogen: Conservatively assuming an above ground biomass of 3300 g /m2 and
0.09% N d.w. in above ground biomass (mid -range for values reported from shrub
pocosins), the amount of nitrogen sequestered in the above ground biomass is
estimated at 0.6 lb N /acre /yr
Carbon: Conservatively assuming that 50% of tall pocosin habitat is wood (and
cellulose and lignin comprise 69 and 28% of wood, respectively), and the carbon
content of cellulose and lignin is 44 and 64 %, respectively, the carbon content of
biomass is calculated as 141.9 lb C /acre /yr
Organic matter accumulation in the soils also has the benefit of counteracting the
pace of change from sea level rise (Pearsall and Poulter 2006).
Therefore, given the three components of sequestration, the total retention potential
in restored peatlands is estimated as 200 lb N /acre /yr and 6500 lb C /acre /yr (about
the amount of carbon in 24,000 Ibs of CO2).
The Service's restoration work is proceeding in phases within each of the three
Watersheds (WSs). Phase I of the WS 1 project encompassed four blocks and is
nearly complete. A return to ideal (e.g., soil saturation) hydrology conditions will
occur gradually as rainfall allows water levels in the blocks to rise. When the Phase
I blocks reach appropriate wetness conditions, approximately 3,520 acres of
hydrology wetland restoration will be complete. At that time, the restored acreage
for Phase I work will result in retention of about 700,000 pounds of nitrogen per year
and 22.7 million pounds of carbon per year). Proposed work for Phase II of this
project, which has already been initiated by the refuge, involves raising roads by
performing routine canal and road maintenance work along strategic sections of the
canal /road grid system. Phase II efforts, like Phase I, will rely on rainfall into the
restoration blocks to raise water levels. When appropriate hydrology conditions are
achieved, the restored acreage for Phase II work will result in retention of 796,000
pounds of nitrogen per year and 25.7 million pounds of carbon per year (USFWS
2007).
Benefits of restoration have been embraced by natural resource managers
The wetland restoration work at Pocosin Lakes NWR has long been supported by
other natural resource managers in the State. Funding (from U.S. EPA and the
North Carolina Department of the Environment and Natural Resources) and
research (North Carolina State University) partnerships have facilitated the work.
Important to the success of this partnership has been the accrual of water quality
and wildlife habitat benefits with de minimis environmental impacts. The restoration

USFWS March 2010 Draft
is achieved by installing water control structures to raise the water table, encourage
the more natural sheet flow (Daniels 1980, 1981) (rather than channelized flow from
the artificial ditches) and attenuate run -off. In eastern North Carolina, the use of
these water control structures to attenuate flows and mitigate off -site water quality
impacts is well documented; it is among the most frequently used and encouraged
best management practice in the highly altered hydrologic network of eastern North
Carolina. In order to facilitate sheet flows, maintain access, and manage water
levels in responsiveness to neighbors, the work involves raising strategic sections of
the roads (about 2 feet above their prior elevation) to enhance their dike - effect within
the restored wetland blocks allowing continued access for refuge management
purposes. Road raising material is obtained from canal dredging (removing
accumulated sediments from the bottom of the canal), dredge spoil placement on
the adjacent roads, dredge spoil drying and road re- grading. In the work that has
been done to date, no off -site water quality impacts have been observed or are
anticipated.
Restoration will return the lands to a more natural state and sequester tons of
nutrients, including nitrogen, which are a source of local water quality problems.
Restoration does not change the ultimate receiving waters of the canal network, it
simply raises water levels on -site, and attenuates flows off -site, both of which are
recognized as benefiting regional water quality. All excavation work is in the highly
altered canal network and behind water control structures, ameliorating the potential
for short -term sediment disturbance to cause off -site impacts.
The National Wildlife Refuge System Improvement Act of 1997 under Section 5,
entitled Administration of the System, states:
"...the Secretary [of the Interior] shall ... ensure the biological integrity, diversity,
and environmental health of the National Wildlife Refuge System are
maintained..." and also "...assist in the maintenance of adequate water quantity
and quality to fulfill the mission of the System and the purposes of each refuge."
Additionally, a, New paragraph (4)(F) of Section 4(a) of the NWRSAA (National
Wildlife Refuge System Administrative Act of 1966) directs the Secretary to assist
in the maintenance of adequate quantities and quality of water to fulfill the
mission of the System and the needs of each refuge. The restoration work is
important to the Service's environmental stewardship obligations. It is being
conducted in a manner which embraces on -site restoration research
collaborations and best management practices.
Summary: Extensively altered prior to Service acquisition, drained peatlands at
Pocosin Lakes NWR have been a focus of restoration by the Service and partners.
Peat in the area of the old East Dismal Swamp formed over the last 9,000 years; its
high organic content and poor drainage resulted in retention of metals and nutrients
over geologic time (similar to the way an activated charcoal filter cleans water by
accumulating contaminants). When peat bogs are ditched, the water table is lowered
and the peat is aerated, which accelerates decomposition and nutrient and metal

USFWS March 2010 Draft
release. South of Lake Phelps, extensive drainage prior to Service acquisition
enhances off -site run -off of metals and nutrients, and these are known parameters of
concern in regional water quality impairment. Wildfires are more intense in the drained
peatlands than the natural state, and they exacerbate soil loss and mobilization of soil
constituents that can degrade run -off water following fires.
Work to restore the wetlands has demonstrable benefits to water quality, both estimated
from the published site ecology literature as well as measured through site - specific
research. Restoration will return the lands to a more natural state and sequester tons of
carbon and nutrients, including nitrogen, which is a source of local water quality
problems. Hydrology restoration work is also the best long -term management strategy
to minimize adverse effects of peat fires. The decreased incidence of peat fires is a soil
conservation side benefit which also has important sea -level rise implications in this
low -lying portion of North Carolina's coastal plain.
Restoration does not change the ultimate receiving waters of the canal network, it
simply raises water levels on -site, and attenuates flows off -site, both of which are
recognized as benefiting regional water quality. All excavation work is in the highly
altered canal network and behind water control structures, ameliorating the potential for
short -term sediment disturbance to cause off -site impacts.
References:
Albemarle - Pamlico Estuarine Study. 1994. Comprehensive Conservation and
Management Plan. Albemarle - Pamlico Estuarine Study, Raleigh, NC.
Ash, A.N., C.B. McDonald, E.S. Kane and C.A. Pories. 1983. Natural and modified
pocosins: Literature synthesis and manufacturing options. FWS /OBS- 83/04. U.S. Fish
and Wildlife Service, Washington, DC.
Ashe, W. W. 1894. The forest, forest lands, and forest products of eastern North
Carolina. North Carolina Geological Survey Bull. No. 5. Josephus Daniels, State
Publisher and Binder. Presses of E. M. Uzzell. 127 p.
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USFWS March 2010 Draft
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14

a
North Carolina [aepartment (A Envirow,�er a,-)d haturai P- ,sr�ur(,w.;
Uvision of VV,7Ier Quali °v
Pat McCrory Charles 'VVakiid, P. E
Governor Director
April 22, 2013
Pocosin Lakes National Wildlife Refuge
Attn: Howard Phillips
P O Box 329
Columbia, NC 27925
,john 1. Skvarla, III
Secretary
DWQ #: 12 -0953
Washington & Hyde Counties
Pocosin Lakes Refuge Watershed 2 Hydrology Restoration Infrastructure
USACE Action ID. No. SAW- 2012 -01548
Dear Mr. Phillips:
On October 12, 2012, the Division of Water Quality (Division) received your application
requesting a 401 Water Quality Certification from the Division for your project. A Public Notice
was issued by the U.S. Army Corps of Engineers on October 9, 2012 and received by the Division
on April 9, 2013. The Division has determined that your application is incomplete and cannot
be processed. The application is on -hold until all of the following information is received.
Please explain why the proposed berm needs to be 4 feet in height to restore wetland
hydrology and prevent woody debris from entering County Line Canal.
2. Based on the berm's proposed construction out of dredge material with 1.5 to 1 slopes,
please explain how it would be sufficient to hold the amount of water that would be
impounded without a clay core and prevent erosion of the berm into the canal.
Pursuant to Title 15A NCAC 02H .0502(c), the applicant shall furnish all of the above requested
information for the proper consideration of the application. If all of the requested information
is not received in writing within 30 calendar days of receipt of this letter, the Division will be
unable to approve the application and it will be returned. The return of this project will
necessitate reapplication to the Division for approval, including a complete application package
and the appropriate fee.
,Jet Eti ,i, n,- -tei )i l ( nd nil
N ortI� C �irci 01a
oc .gin 5 S� �. F itiai� � ,� � �� u'(' ^- '� {� , 1 1, ho, 4
m a ,� .r� f- , It'Y

Pocosin Lakes Refuge Watershed 2 Hydrology Restoration Infrastructure
Page 2 of 2
April 22, 2013
Respond in writing within 30 calendar days of receipt of this letter by sending four copies of all
of the above requested information to the Wetlands, Buffers, Stormwater — Compliance and
Permitting (Webscape) Unit, 1650 Mail Service Center, Raleigh, NC 27699 -1650.
Please be aware that you have no authorization under Section 401 of the Clean Water Act for
this activity and any work done within waters of the state may be a violation of North Carolina
General Statutes and Administrative Code.
Please contact Roberto Scheller at 252 - 948 -3940 or roberto.scheller @ncdenr.Rov if you have
any questions or concerns.
Sincerely,
Karen Higgins, Super ' r
Wetlands, Buffers,
St water —
Compliance & Permitting Unit
cc: U.S. Army Corps of Engineers, Washington Regulatory Field Office
DWQ WaRO 401 files
File Copy
File name: 120953PocosinLakesRefugeWatershed2HydrologyRestorationlnfrastructure( Washington &Hyde)_401_IC_Hold.docx