20201654 Ver 2_Revised IP - preliminary comments and questions_20220310

Strickland, Bev
From: Leslie, Andrea J
Sent: Thursday, March 10, 2022 8:32 AM
To: Homewood, Sue; Brandee Boggs ([e-mail])
Cc: Jeff Golladay; Hamstead, Byron A
Subject: Mulberry Gap Farms revised IP - preliminary comments and questions
Follow Up Flag: Follow up
Flag Status: Flagged
Folks
I've reviewed the revised IP package that I received on 2/28 (there was a mix-up, and I didn't know it was
out for review until then). My preliminary concerns and questions about the application are listed below:
1. Compensatory mitigation approach.
a. Table 3 provides proposed mitigation ratios for stream impacts, which range from 2:1 to
0.5:1. The approach taken to determine the mitigation ratio for each impact is unclear and needs
to be justified. The ratios proposed do not appear to be linked to the NCSAM scores. In general,
we do not support any ratio less than 1:1, and any ratio less than 2:1 should be clearly justified.
b. A 828.5-ft reach of Hopewell Branch is proposed for on -site mitigation. No mitigation approach
is described. We would like to see a conceptual plan for any reach proposed and see the proposed
reach in the field.
2. Additional design/engineering information needed.
a. 480 ft of stream enhancement is proposed on Thompson Branch. We would like to see additional
design information. Could the plan view show the actual dimensions of the log jam structures, the
areas of the right bank that will be subjected to revetments (and which types of revetment will be
used where)?
b. Attachment H is a response to NCWRC's 9/ 1 /2021 comments on the technical documents
(especially the 7/9/21 "Project Justification and Design Narrative for Proposed BDAs") included
in the 7/16/21 response to NCWRC's comments on the initial IP application. Although this
response is dated 11 / 1 /2021, NCWRC did not receive this response separately. It addresses
NCWRC's 9/ 1 /21 questions, noting changes made in the design to address these questions. Some
of these changes have been made in the IP materials, and some have not.
i. Attachment H (#3a) notes that the deep marsh/submergent zone (Zone D) will no longer
be planted due to the limiting water depths. However, Sheet L-2.00 still lists species to be
planted in that zone.
ii. Attachment H (#3b) notes that the species list has been revised per input from Kevin
Caldwell and is provided in engineering plans sheet C8O5. This is not included in the IP
packet, and the species lists in Sheet L-2.00 of Attachment C and pp. 27-28 of Attachment
A have not changed.
iii. Sheet L-2.00 (Attachment C) still includes alternative species that Attachment H (#3d)
notes would be eliminated.
iv. The monitoring plan does not reflect 7 years of vegetation monitoring as noted in #4 of
Attachment H; instead, 3 years of monitoring reports are proposed. In addition, CVS plots
are still described as the method for vegetation monitoring instead of line transect
monitoring noted in Attachment H.
Andrea
i

Andrea Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Commission
645 Fish Hatchery Rd., Building B
Marion, NC 28752
828-400-4223 (cell)
www.ncwildlife.org
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