20130411 Ver 1_USFWS Comments_20130516

United States Department of the Interior
46 o HSI-I AND WILDLIFE SF.RVICL
a �
Raleigh I field Office
s ,�A� Post Office Box 33726
Raleigh, Noith Carolina 27636 -3726
May 16, 2013
Mi, Andiew Williams, Project Manager
Wilmington Regulatory Division
U S Army Carps of Engmeei s
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Subject Wildlands Engineering, Inc - Lower Swepsonville Dam Mitigation Bank
Draft Prospectus
Dear Mr Williams
This responds to Monte Matthews' email of April 17, 2013, requesting comments on the draft
prospectus for Wildlands Engineering Inc.'s Lower Swepsonville Dam Mitigation Bank The
U S Fish and Wildlife Service (Service) has reviewed the draft prospectus, and attended a
meeting to discuss the project at the Corps office on May 13, 2013. Kathy Matthews will be the
Interagency Review Team (IRT) member for this mitigation bank. At the May 13, 2013
meeting, Kathy provided copies of the Service's "Haw River Sediment Quality Assessment"
(July 2011), and a "Preliminary Sediment Survey" (August 28, 2008), which was prepared for
the Service by Restoration Systems.
At this tune, the Service does not have any concerns for impacts to federally - listed species from
this project Our concerns relate to consistency with other proposed dam removal projects, and
potential impacts to downstream habitat and fisheries from contaminated sediment
1 The South But Itngton Wastewater Tieatment Plant (WWTP) is located within the
impoundment of the dam in Big Alamance Creek. The Service is concerned about potential
ramifications to the WWTP's NPDES permit limits, as well as potential water quality and
sediment impacts from the WWTP. We recommend that the facility's NPDFS permit be
examined to deter mine whether the permit limits were formulated assuming impoundment of Big
Alamance Creek, or low flow of the stream. The Service's 2011 sediment quality assessment
indicated acutely -toxic contamination downstream of the WWTP. The sediment removal
management plan for the mitigation bank should include sediment testing within the
impoundment and consultation with the resource agencies to determine whether sediment should
be removed
2 At the May 13, 2013 meeting, the sponsor indicated that more conservation easements may be
purchased along the impoundment The Service recommends that in order to receive credit for
the approximately 2,570 linear feet of tributaries proposed, the tributaries should be protected
with conservation easements and a 50 -foot forested buffer on each side of the channel We also
encourage the establishment of 50 -foot forested buffers and conservation easements on as much

of the Haw maulstem and Big Alamance Creek as possible. Even with forested buffers and
conservation easements, the Service would be concerned about allowing 1.1 credit ratios for
tributary leaches that aie deeply incised We look forward to viewing the impounded areas and
discussing potential credit ratios at that time
3 In general, the Service does not have concezns with structuung available credits around goals
of the project (reestablishment of flow, water quality improvement, fish passage, etc ) Howevei,
we caution that all goals and success ciiteiia should be quantifiable and icasonable, and the
amount of credits offered foi teaching the goals should be appropiiate foi the level of effort and
measured level of improvement We look forward to discussing potential goals, success criteria,
and available credits
4 The Service anticipates that the mitigation plan will include, at a minimum, proposals for
monitoring of water quality, sediment quantity, quality, and movement, vegetation recruitment
and invasive plants, shoreline stability, fish passage, and habitat quality. In addition, remedial
plans should be included, should the provides fail to meet stated goals and success criteria, or if
adverse impacts aie discovered
Thank you foi the oppoitunrty to comment on this project. We look foiwaid to the field visit and
future opportunities foi input. If you have any questions concerning these comments, please
contact Kathy Matthews at (919) 856 -4520, Ext 27, of by e -mail at
<kathryn_matthews @fws gov>
Sin ely'
Pete B amin
Field Supervisor
cc*
Todd Bowei s, USEPA
Rosemary Hall, USEPA
Sue Homewood, NCDWQ
Eric Kulz, NCDWQ
Dolores Hall, NC Office of State Aichaeology
Shad Biyant, NCWRC