20141127 Ver 1_Measurable WQ parameters_20141112

Baker, Virginia
From: Jennings, Heather
Sent: Wednesday, November lZ'ZUl4ll:06AM
To: Baker, Virginia; Nimmer,Kimberly
Subject: RE: measurable water quality parameters for mitigation site
Attachments: WQ-10EPArequirements.docx
I share all the concerns listed below and at this time cannot offer any suggestions. As Kim mentions, there have beer
many conversations with EPA on capturing incremental success, none of the options have yet to be approved. Atthi�
time we report load reductions to EPA (Nitorgen, Phosphorus, Sediment), but the only successes we can count are
delisted AU (which do not always correlate with the load reductions reported). VVe(319 Program) are encouraged to
document any/all successes, but do not receive any credit unless the waterbody is officially removed from the
303(d). We can document partial success using EPA WQ-10, that is defined as partial restoration in one or more
parameter, but not an actually de|istine/ u|| restoration. VVC-10 requirements are attached.
Another source would be Dane Line with NCSU, he has worked closely with Jean Spooner for many years.
You may want to consider EEPasa source aswell. Would nutrient offset bean option here, orisit suggested inthe
plan? |f so, this may beuseful:
Feel free to give Kim or myself a call to discuss further.
From: Baker Virginia
Sent: Wednesday, November 12, 20149:23 AM
To:Nimmer, Kimberly
Cm:]ennings Heather
Subject: RE: measurable water quality parameters for mitigation site
Hi Kim, thanks for taking the time to write to me on this issue. For what the consultant is proposing we will need more
then visual evidence, otherwise that would be an easy solution. Removal of cows with affective and working fences is
expected to get the credit they are requesting. But the additional credit is above and beyond what is normally given for
the work they are proposing so we need to come up with something quantitative or not use water quality as a method
to show success.
Heather if you have any suggestions it would be much appreciated.
I was also directed to ask Jean Spooner at NC state extension about this issue as well by Steve Kroeger.
Thanks, Ginny
From:Nimmer, Kimberly
Sent: Wednesday, November 12, 2014 8:57 AM
To: Baker, Virginia; ]ennings Heather
Subject: RE: measurable water quality parameters for mitigation site

Ginny,
| share your skepticism about how adequate and accurate the proposed method will be for demonstrating vvaterqua|ity
improvement and restoration success.
For the 319 grant program, success is all about removing streams from the 303d list by documenting improvements in
the parameters for which the stream was impaired. Knowing that this is usually a difficult, expensive, and long-term
effort, the program (nationally) has been looking for interim measures to document and highlight improvement. No
specific measures or techniques have been officially recommended. However, our program is trying to encourage
creative ways for projects to show improvement, especially recognizing how difficult this can be when constrained to a
3-year contract time period, which includes construction/project implementation time. This may not help your
situation, but we've even allowed the possibility of using photo documentation to document improvement (i.e., cows in
the stream before, cows fenced out after; visibly turbid stream during a storm event before, visibly clearer stream
during storm event after project implementation). This obviously does not provide quantified data, and couldn't help
with de|isting, but it can certainly show water quality has improved and perhaps point to where future monitoring
should occur.
With that said, some projects do conduct in stream monitoring, and the parameters sampled depend on what the
impairment/prob|emis. However, there isn't a standard monitoring plan that we require, so I'm not sure what to
recommend to the consultant you are currently working with.
Since Heather prepares our project success stories to submit to EPA, she may have additional insight or suggestions to
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From: Baker Virginia
Sent: Monday, November 10, 2014 4:29 IPM
To: Nimmer, KimUerly;]ennings Heather
Subject: measurable water quality parameters for mitigation site
Hi Kim and Heather,
I have taken over some of Eric Kulz's duties reviewing mitigation plans. There has been a trend in measuring ecological
uplift as a way to determine appropriate mitigation credit ratios and restoration techniques for streams. |just received a
mitigation plan that is proposing to use water quality measurements as a way of determining success.
The plan isto collect N,TP FCturbidity temp, pH, DO and conductivity. They would like to consider the sustained
improvement over baseline of just two of these as a way of measuring success. Although this sounds good, I have too

much experience with measuring water quality in wetlands and playing around with statistics to know it is not really
adequate since just random measurements can show some improvement. They will be collecting too few samples to
really do statistics and only two parameter improvement as a measure of success sounds too few to me.
Have you either of have any experience with how improvement has been measured in impaired 319 streams? I was
talking to Steve Kroeger out at the lab about this and he suggested I contact you. I was looking for something that I
could recommend to this consultant to incorporate in their mitigation plan.
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Phooe -(WP) 707 -8788, Fix-(WP) 755 -1290
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