HomeMy WebLinkAbout20050666 Ver 1_Other Agency Comments_20060405Re: 401, cumulative impact, Todd Kennedy]
Subject: Re: 401, cumulative impact, Todd Kennedy]
From: John Dorney <John.Dorney@ncmail.net>
Date: Wed, OS Apr 2006 16:43:41 -0400
To: wnrinc@aol.com
CC: Cyndi Karoly <Cyndi.Karoly@NCMail.Net>, Alan Johnson <Alan.Johnson@ncmail.net>
Based on past cumulative impact analyses and the problems in the watershed (sediment
for instance rather than bacteria), I expect that they need to look at three things
in the modeling - buffers, stormwater management (quantity and quality) and enhanced
sediment and erosion control measures. I expect that the analysis of buffer widths
would reflect what is in the literature (look at 30, 50 and 100 foot buffers and see
their varying effectiveness). If a 50 foot buffer along with the other measures is
modeled to be effective, then that is what the 401 will require. If another agency
thinks a larger buffer is needed, that is not a 401 issue as long as the modeling
supports a narrower buffer. How you client uses that analysis (beyond the 401) is
not DWQ's business.
If you need additional information, give me a call. thankx
wnrinct~aol.com wrote:
John, Working towards the CSI and it occurs to me that the if the USMP and its
buffers can address protected species (as Tom Reeder thinks they may) then the
proposed Mint Hill requirements would address the protected species issues as well
(since they are more restrictive). So, should our focus be primarily on the
buffers (i.e width and composition) and not treatment standards (i.e. TSS and peak
shaving)? The bigger questions are: Is DWQ looking for us to establish the
buffers baseline for protected species with this CSI?? Would this study then be
the basis for any position that DWQ takes with regard to our friends at the WRC???
I get the sense that we are going to be doing some of the dirty work here and I
just need to have a clearer idea of a what your objectives are.
It should be clear that my clients are going to build this project. We are going
to use 50' buffers and the 100 year floodplain buffer width. The buffers in
conjunction with the stormwater wetlands and LID represent the most that we can
do. The added value of the large scale restoration is gravy for the environment.
Chris
-----Original Message-----
From: John Dorney <John.Dorneyc~ncmail.net>
To: Chris Huysman <wnrinc~aol.com>
Sent: Wed, 05 Apr 2006 09:40:31 -0400
Subject: [Fwd: 401, cumulative impact, Todd Kennedy]
FYI. here is another cumlative impact-related approach to address 401 issues for
cumulative impact. enjoy! Attached Message
From: Steve Kroeger <steve.kroegerCncmail.net>
To: Susan Gale <susan.gale~ncmail.net>; John Dorney <John.DOrney~~ncmail.net>;
Steve Kroeger <steve.kroegerC~ncmail.net>
Subject: 401, cumulative impact, Todd Kennedy
Date: Tue, 04 Apr 2006 21:26:49 -0400
FYI -- the abstract of a talk given by Todd Kennedy at the WRRI conference
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