20090049 Ver 2_Corps of Engineer Correspondence_20131104

Homewood, Sue
From:Kulz, Eric
Sent:Monday, November 04, 2013 8:46 AM
To:Tugwell, Todd SAW
Cc:Homewood, Sue; Higgins, Karen
Subject:(DWR #09-0049)
Attachments:Glade II EEP Response to DWR Hold Letter 30Sept2013.pdf; Glade II 401.pdf
Todd:

I have attached the response letter from the designer (Confluence Engineering) dated September 19, 2013, via EEP letter
dated September 30, 2013.

The letter failed to address a number of our concerns, particularly the potential for the relocation of UT1 and
subsequent possible loss of base flow, as well as the possibility of removal of loss of hydrology from Wetland A due to
the relocation of UT1. In addition, upper UT1 (preservation reach) has an approx. 10-foot buffer on one side, and site
observation indicated that the buffer is immature, early-successional vegetation. As such, the proposed preservation
reach (UT to Glade R1) does not meet the requirements outlined in the December 5, 2012 document “Use of Stream
Preservation as Compensatory Mitigation in North Carolina” (NC Interagency Review Team), based on the width of the
proposed riparian buffer on one side and the overall quality of the riparian area. Therefore, DWR does not consider this
reach (129 linear feet) suitable to provide compensatory mitigation for impacts approved under a 401 Water Quality
Certification issued by DWR

While we intend to issue the 401, we wish to ensure our comments are included in the USACE record on this project,
and recommend a site inspection in year 2 or 3 to assess site conditions, as opposed to waiting until closeout. In
addition, we have added a condition stating that the proposed preservation reach is not suitable to provide
compensatory mitigation for impacts approved by DWR in a 401 WQC.

Please contact Sue Homewood or me if you have any questions.

Eric W. Kulz
Environmental Senior Specialist
401 and Buffer Permitting Unit
NCDENR - Division of Water Resources – Water Quality Permitting Section
1650 MSC
Raleigh, NC 27699-1650
Phone: [phone]

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

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