20130411 Ver 1_Other Agency Correspondence_20130520

Strickland, Bev
From: Kulz, Eric
Sent: Monday, May 20, 2013 2:46 PM
To: Strickland, Bev
Subject: FW: dam removal decision points (UNCLASSIFIED)
Bev;
Please include in 13 -0411 and 13 -0412.
Thanks!!!
Eric W. Kulz
Environmental Senior Specialist
N.C. Division of Water Quality
Wetlands, Buffers, Stormwater -
1650 MSC
Raleigh, NC 27699 -1650
Phone: [phone]
Compliance & Permitting Unit
E -mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
- - - -- Original Message---- -
From: Matthews, Monte K SAW [mailto: Monte .K.Matthews(@usace.army.mil]
Sent: Monday, May 20, 2013 2:31 PM
To: Williams, Andrew E SAW; Matthews, Monte K SAW; Bryant, Shari L.; Kulz, Eric; Homewood,
Sue; bowers.todd(@epa.gov; 'Fritz Rohde'; emily -jernigan(@fws.gov; Matthews, Kathryn; Hall,
Dolores
Subject: dam removal decision points (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Hello Hoosier and Swepsonville IRT's;
Andy and I realize that the local IRT's have some fairly large decisions to make regarding
limits of impoundments, credit generation, and service area for these banks. The fact that
the Dam Removal Guidance has been rescinded doesn't help us - in fact, it probably makes it
tougher because we now could be seen as setting a precedent for the next dam removal bank.
In an effort to lessen the burden of these decisions, our initial thoughts are that we (the
local IRT's) should come to an agreement on the three topics listed below, then present them
via email to the state IRT for an endorsement. If the state IRT recommends a slight
modification prior to endorsing, we can consider it and resubmit. Regardless, this will
allow the local IRT the ability to develop the solutions they feel are best for their bank,
yet keep the precedent- setting sanctions at the state level.
So, to start the discussion on these three topics:
1) It is our hope that the group will be able to establish the limits of impoundment during
the field on the 19th. After seeing the photos and listening to John's methodologies, I'm
1

optimistic that this will be a fairly easy decision ......... I don't get to be optimistic very
often, so I'm not very good at it and may be completely off base.
2) The service area discussion is applicable to the Hoosier prospectus - those of you on this
IRT, please let me know your thoughts on the service area expansion if you have not included
them within your comments on the draft prospectus. My early vote would be to leave it as a
case -by -case decision, but the state IRT has expanded a service area for another bank (Dismal
Swamp) and we should consider this as we make a final decision. If you need additional
information on the thought process for the Dismal Swamp decision let me know - I have the
approval letter that explains it in pretty good detail.
3) This leaves the credit generation - which pertains to both banks and is probably the
toughest one of the three. Andy and I agree that the logic to determine credits should be
applicable to both banks, so we would like to include the IRT's from both banks into one
discussion. Keep in mind that this doesn't mean that both banks should earn the same amount
of credits, only that the reasoning should be consistent. If you have any early ideas on how
best to assign credits, just let us know by replying to everyone above - for now, let's keep
this within the agencies so that we can have a candid discussion.
Here are a few general thoughts to get us started - a) A simple solution may work best. I
know it sounds obvious, but the simpler the solution, the easier it will be to reproduce on
different sites. Some folks thought that the old Guidance got a bit complicated when
describing credit generation, and if we can keep this from happening we may be able to apply
it easily across sites. b) Historically, the Corps assesses a lower mitigation ratio for
inundation when compared to filling. This is because after you inundate a stream, you still
have an aquatic resource of some kind (pond, lake, etc.). Should the reverse be true - where
earning credits from removing inundation produces a lower ratio? c) John will probably alter
his goals for the banks to align with the objectives in the old Guidance. Should a certain
set ratio be applied to each goal?
Feel free to throw out any ideas as we work toward a solution - or perhaps you liked the
credit generation that was provided within the old Guidance and would suggest we continue to
use it? Maybe we can have a good handle on this by the site visit -
lu[6no '
i
Monte Matthews
Regulatory Project Manager
US Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
919 - 554 -4884 x 30
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Classification: UNCLASSIFIED
Caveats: NONE
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