20141024 Ver 1 _Response To IRT Comments_FinalMP _20141230

Michael B r Michael Baker Engineering, Inc.
5550 Seventy -Seven Center Dr., Ste. 320 1 Charlotte, North Carolina 28217
1 N T E R N A T 1 0 N A L Office: 704.665.2200 1 Fax: [phone]
December 23, 2014
Lin Xu, Permit Coordinator and Harry Tsomides, Project Manager
NC Department of Environment and Natural Resources
Ecosystem Enhancement Program
1652 Mail Service Center
Raleigh, NC 27699 -1652
Subject: Task 3: Response Letter to NCIRT 30 -day review comments for the
UT to Town Creek Restoration Site — Option A, Stanly County
Yadkin Cataloging Unit 03040105
NCEEP Project ID No. 94648; NCDENR Contract No.# 003277
USACE Action ID No.: SAW- 2013 -01280
Baker Project No.: 120857
Dear Mr. Xu and Mr. Tsomides:
Please find enclosed the Final Mitigation Plan and our responses to the NCIRT review comments
dated December 2, 2014 regarding the UT to Town Creek Restoration Site — Option A Project,
located in Stanly County, NC. We have revised Final Draft Mitigation Plan documents in
response to the referenced review comments and USACE mitigation plan approval letter dated
December 17, 2014. Each comment /response has been grouped per the NCIRT reviewer and is
outlined below.
Todd Bowers, USEPA, 17 Oct, 2014:
1. The applicant has omitted the Credit Release Schedule for wetland and stream credit units.
Response: Though the Credit Release Schedule was not required as an inclusionary item
for the previous NCEEP Mitigation Plan Document, Version 1.0 (201Oa) which was
outlined in the RFP #16- 00283, we understand this is a requirement of the recent
Mitigation Plan Templates. Therefore, we have revised the Mitigation Plan to include the
Credit Release Schedule (Section 2). It is located in Table 2.1 on page 2 -2.
2. Recommend a 7 -year monitoring period for vegetation in those areas where forest wetlands
(headwater or bottomland hardwoods) are being established. This is per guidance dated
October 10, 2008 titled Revised Credit Release Schedule for Forested Wetlands and in
accordance with 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic
Resources.
Response: This project was included under the May 13, 2013 letter from NCEEP to the
NCIRT in entitled "EEP sites -seven year monitoring". As described in that letter, the
described projects were not contracted for seven years of monitoring under the relevant
RFPs. Based on that letter, Baker plans to conduct post - restoration monitoring for
wetland related mitigation work for five years as contracted. However, as stated in the
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Michael Baker Engineering, Inc.
5550 Seventy -Seven Center Dr., Ste. 320 1 Charlotte, North Carolina 28217
Office: 704.665.2200 1 Fax: [phone]
May 13, 2013 letter from NCEEP to the NCIRT, "In the fourth year of monitoring, EEP
will decide if the specific site may qualify for close out after five successful monitoring
years. For those, EEP will submit to the IRT for early closure. For any site that EEP
does not think meet early closeout criteria, EEP will contract out to complete the final
two years" of monitoring ( NCEEP, 2013). A copy of the letter has been included in
Appendix K for reference and clarification for the monitoring period rationale has been
included in Sections 2.2, 9.3, 10.0 and 10.3 of the Mitigation Plan.
3. While I agree completely with the amount of extra credit generated by the extra buffer widths
along Reaches 1 -3, I would like some clarity on how the extra width was calculated.
Was it from perpendicular lines from valley centerline, top of bank, or stream beltwidth. I
recommend the use of beltwidth for sinuous streams such as this to determine buffer width
averages.
Response: Average additional buffer widths were calculated from the top of bank to the
easement boundary along the proposed restoration alignment at fifty foot intervals.
4. Recommend a figure or map showing the areas where upland, riparian, and forested wetland
plantings will occur. Vegetation plots established for monitoring should adequately
cover each of these different vegetation communities.
Response: Riparian, upland, wetland planting areas have been added to Figure 7 —
Proposed Monitoring Device Locations and are also depicted in sheets 24 — 27 of the
plan set. Vegetation plot locations have been strategically placed to include an adequate
mix of the vegetative communities. See Figure 7 for reference.
5. Page 3 -8: Error in footnotes for Reach 2 in Table 3.4. Need to add footnotes 3 and 4 where
appropriate.
Response: References to footnotes have been revised to reflect the appropriate citation
for Reach 2. Upon review of the footnote references within this table it was noted that
Reach 4, 5, 6, and 7 also had citation errors. These errors have also been corrected.
Please note that due to plan revisions this table is now referred to as Table 4.4 and is
located on pages 4 -8 and 4 -9.
6. Page 7 -23: Existing conditions state that "wetlands are extremely impaired" yet they
scored High to Medium per the NCWAM evaluations. Can the applicant please provide
clarity in this situation?
Response: Overall wetland ratings ranged from Low to High, with Wetlands 3 and 5
receiving a Low rating, Wetlands 2, 4, 6, and 7 receiving a Medium rating, and only
Wetland 1 receiving a High rating. Within the project area, the extent of the impairments
to each wetland varies. The ratings /conditions relate to the cattle's propensity to use the
wetland area in question as a wallowing area and /or evidence that the wetland has been
historically ditched. Consequently Wetland 1 was able to achieve a High rating because
it is located where cattle do not have access and does not have evidence of ditching.
Impairments to Wetland 1 are predominantly caused by frequent bush - hogging and
rutting from heavy equipment access.
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Michael Baker Engineering, Inc.
5550 Seventy -Seven Center Dr., Ste. 320 1 Charlotte, North Carolina 28217
Office: 704.665.2200 1 Fax: [phone]
7. Page 7 -30 and 31: Stream buffer vegetation refers to Table 7.6. This should be corrected
to Table 7.7.
Response: References to the buffer vegetation table have been revised; however, due to
plan revisions this table is now referred to as Table 8.7 and is located on pages 8 -31
through 8 -32.
8. Page 7 -32: Table 7.7 in Constructed Wetlands the latin name for sweetflag is shown as
Nyssa sylvatica. This should be corrected to Acorus calumus.
Response: The latin name for swee flag has been corrected to Acornus calamus; however,
due to plan revisions this table is now referred to as Table 8.7 and swee flag is
referenced on page 8 -32.
Travis Wilson, NCWRC, 30 October, 2014:
9. While WRC agrees with the incorporation of the two wetland BMPs into the plan, the
design as shown as well as the steep topography on reach 7 give concern that these will
function more like traditional storm water retention basins and likely require routine
maintenance. The design and location of these BMPs should be such that little to no
maintenance is required.
Response: Baker understands that routine maintenance for water quality features can be
a concern; therefore, both constructed wetlands have been designed and located to
minimize long term maintenance needs by:
1. Extending the conservation easement and buffer plantings approximately 30 feet
beyond the footprint of each BMP to allow the buffer vegetation to act as pre-
treatment feature for both suspended sediment and nutrient loads,
2. Implementing permanent fencing outside the easement to ensure permanent
livestock exclusion, and
3. Providing a stable outlet mechanism /spillway for the BMPs to draw down so as to
maintain downstream stream functions while maintaining a storage capacity only
to support the permanent pool.
In addition, Baker will be providing post - construction monitoring and maintenance, as
needed, during the monitoring years thereby facilitating the wetland vegetation to
become established and functioning as intended prior to project closeout.
Ginny Baker, NCDWR, 31 October, 2014:
1. Notate on Figure 6 that area upstream of Reach 4, 5, and 7 is non- credited preservation as
noted on pg 7 -5 in Notes section.
Response: As requested, a notation has been added to Figure 6 to stipulate that the areas
upstream of the proposed design on Reaches 4, S, and 7, will include enhancement
plantings and be included as part of the conservation easement and permanently fenced,
but are not being sought for mitigation credit.
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Michael Baker Engineering, Inc.
5550 Seventy -Seven Center Dr., Ste. 320 1 Charlotte, North Carolina 28217
Office: 704.665.2200 1 Fax: [phone]
2. Wetland indicator status listed on pages 7 -31 and 7 -32 should be updated to current
National Wetland Plant List for the EMP region for 2014 which does not have "+" and " -"
designations. Please correct the following: Liriodendron tulipifera to FACU, Quercus
phellos to FAC, Alnus serrulata to OBL, Sambucus Canadensis to Sambucus nigra FAC,
Nyssa sylvatica to FAC, Hibiscus moscheutos to FACW, Elymus virginicus to FACW,
Tripsacum dactyloides to FACW, Coreopsis lanceolata to FACU, Dichanthelium
clandestinum to FAC. http: / /rsgisias .crrel.usace.army.mil /nwpl static /viewer.html#
Response: The Proposed Vegetation Plantings Table has been updated to reflect the
current National Wetland Plant List for the Eastern Mountains and Piedmont 2014
Regional Wetland Plant List. Please note that due to plan revisions this table is now
referred to as Table 8.7 and is located on pages 8 -31 through 8 -32.
3. DWR will require in our permit conditions that a monitoring gage be placed at the head
of and lower end near the confluence for all intermittent streams that are to be
restored with Priority 1 techniques that will raise the stream bed and potentially reduce
base flow. Reach 7.
Response: Baker will install a groundwater monitoring well, within the thalweg
(bottom) of the downstream portion of the restored intermittent reaches (Reach 6 and
7). In addition, a monitoring gage (pressure transducer) will be installed towards the
downstream portion of each restored intermittent reach to document base flow. The
devices will be inspected on a quarterly /semi - annual basis to document surface
hydrology and provide a basis for evaluating general flow response to rainfall events
and surface runoff during various water tables levels throughout the monitoring
period. See Figure 7 for the approximate location of the additional devices. References
to the implementation of these devices has also been included in Section 10.1.1 on page
10 -2.
4. A vegetation monitoring plot should be added (or moved into) the enhancement area.
Response: A vegetation monitoring plot has been relocated to the wetland enhancement
area of Wetland 3 as suggested. See Figure 7.
5. DWR recommends using burlap, or more natural light weight core fiber material that
would degrade quicker rather than geo -tech fabric for soil lifts and grade control /cross
vanes etc.
Response: Baker acknowledges this recommendation and will work with the construction
contractor to investigate the feasibility of incorporating this application. It has been our
experience that non -woven geotextile fabric is more appropriate and effective at
capturing finer material which helps seal /maintain structure integrity longer than
burlap /coin fiber material.
6. DWR recommends leaving some of the stumpage on site rather than complete removal
during grading process to promote regrowth.
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Michael Baker Engineering, Inc.
5550 Seventy -Seven Center Dr., Ste. 320 1 Charlotte, North Carolina 28217
Office: 704.665.2200 1 Fax: [phone]
Response: Baker acknowledges this recommendation and will work with the contractor
to incorporate this suggestion when feasible during the construction process.
7. DWR recommends the use of "screenings" from rock quarry for use in riffle pools and
backfilling cross vanes, etc. This material fills the gap between #57 stone and sand/soil
mediums.
Response: Baker intends to use suitable on -site stream bed material consisting of fine to
medium gravels to backfill and /or top dress riffles and stream structures.
Todd Tugwell, USA CE, 2 December, 2014:
1. The mitigation plan indicates 5 years of monitoring for both streams and wetlands,
however we have moved to 7 years of monitoring for both per the NCEEP guidance from
2011, and earlier for forested wetlands. Please update the plan to meet current.
Response: Please see comment response to question 2 under the heading of "Todd
Bowers, USEPA, 17 Oct, 2014 ".
This letter serves as the formal response to NCIRT comments and shall be submitted in conjunction
with the Preconstruction Notification (PCN) for Nationwide Permit (NWP) 27 application approval.
If you have any questions concerning the Final Mitigation Plan, please contact me at 704 - 665 -2206
or via email at ksuggsgmbakerintl.com. With this submittal, we have included six (6) hard copies of
the Final Mitigation Plan with NCIRT comments, four (4) copies of the completed PCN, and three
(3) CDs with electronic copies of the documents. We look forward to the NWP 27 authorization.
Sincerely,
y_S
Kristi Suggs, Project Manager
Michael Baker Engineering, Inc.
Enclosures: Final Mitigation Plan Documents, 401/404 PCN permit application for UT to Town
Creek Restoration Site — Option A Project.
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