20210755 Ver 2_DWR Comments - Mit Plan_20221019

North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 1611 Mail Service Center Raleigh, North Carolina 27699-1611
919.707.9000

October 19, 2022
Division of Mitigation Services Attn: Lin Xu (via electronic mail: [e-mail] )
Please find below, comments provided by Division of Water Resources on the Chappels Creek Buffer Mitigation Plan: Reviewed by Katie Merritt:
1) Beavers are a large factor to consider for this project and should be noted as a “Site Constraint” considering the amount of flooding that has been witnessed on this site just in the last 2 years from Beaver Activity. The provider should include an adaptive management plan in with this Plan to provide details on how they intend to respond during monitoring if Beaver activity has induced more flooding beyond the existing conditions of the site. DWR does not promote Beaver Trapping on this site particularly, but the Provider needs to adapt to the Beaver activity being so prevalent and DWR and DMS should have an idea as to what the Provider is prepared to do in the event the beaver activity causes additional flooding and/or tree mortality. 2) Section 1.1, page 4: when describing DWR correspondence regarding the viability of Chappels Creek, the Plan needs to cite that the viability was for Buffer Mitigation and Nutrient Offset. Currently the Plan implies the viability assessment performed by DWR was only for Buffer Viability/Buffer mitigation; Therefore, the text needs to be edited for clarification. 3) Throughout the Plan, both EBX and RES are noted as responsible parties. Which one should be the responsible Party? 4) Section 2.2.4: It states that there is a power-line running through JM1 and Pond A. However, maps show the powerline crossing Pond B. Explain. 5) Figures – no comments, all looks compliant 6) Project Credit Table – All cells appear to be compliant except for items listed below: a. Labeled as “Table 1” but there is already a Table 1 within the Mitigation Plan, which is called Project Attributes b. Since Pond A is a Beaver Impoundment, add a note to the Project Credit Table that states, “Pond A is an in-line Beaver impoundment”. Otherwise, it implies that it is the same as Pond B, which is man-made. c. TH1 is shown as having restoration, but the coordinating figures only show Preservation off TH1