20071134 Ver 1_More Info Letter_20070914

Re: Comments on U.S. 19/19E (SAW-2007-2197-357-300)
Subject: Re: Comments on U.S. 19/19E (SAW-2007-2197-357-300)
t+rom: Marisa Rodman <[e-mail]>
Date: Fri, 14 Sep 2007 13:14:11 -0400
To: [e-mail]
CC: [e-mail], [e-mail], [e-mail],
[e-mail], [e-mail], [e-mail],
[e-mail], [e-mail], Elizabeth Lee Lusk <[e-mail]>,
Phil Harris <[e-mail]>
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1 of 3 9/18/2007 11:27 AM

Re: Comments on U.S. 19/19E (SAW-2007-2197-357-300)
Good Afternoon All.
The following is in response to EPA's comments concerning the mitigation credit ratios proposed by
NCDOT for R-2518&19 and R-2519A.
Buffer Width:
Upon review of the average widths per side of each site on R-2518, there are only 2 of the 11 sites
with less than 30 ft buffer widths. One has 29 ft buffer widths and the other is one of the shortest sites,
covering only 525 ft. Many of the preservation sites have buffer widths well over 30 ft. Also, our two
largest sites, O and Q, have buffer widths of 60 and 78 ft. respectively.
Buffer Vegetation:
While the mitigation plan does state that some of the preservation sites have early successional
vegetation, our largest site, K ,which makes up almost one-third of the total linear ft. of preservation
with 4266 ft, has a mature buffer for almost its entire length. Also, these sites may have early
successional species but by purchasing and protecting these areas, eventually they will have mature
riparian vegetation.
Lastly, I would like to remind everyone of the extent of NCDOTs efforts. We have 5309 m (17,418 ft)
of streams being purchased as R/W that we plan to restore, enhance and preserve adjacent to the US
19 corridor to meet our mitigation needs. These sites will have controlled access to ensure they are
protected from local landowner, commercial, and residential development encroachment.
Several of enhancement and restoration areas are upstream or downstream of a preservation sites.
They include:
• A section of preservation on Site A connects the downstream sections of enhancement and
restoration to Site B
• Due to the added preservation downstream of Site E and upstream at Site G, the total,
continuous linear footage of these sites is 2719 ft of Middle Fork Creek. 2945 ft if you include
Site F, UT to Middle Fork, which flows into Site E
• The 787 ft. of restoration on Site I flows directly into Site H which is 1362 ft of preservation for
a total of 2149 ft. on Middle Fork Creek.
• Preservation @ Sites L&K provide an additona14791 ft on Middle Fork Creek
• Preservation portions of Site N and O added upstream and downstream of the restoration and
enhancement portions of these sites adds 2116 ft to what would have only been a 745 ft site,
protecting a total of 2861 ft on Ivy Gap Branch.
By connecting these sites with the preservation sites, we have protected extensive portions of the
entire stream system from any future development. The Department understands EPA not wanting to
set a precedent for lower ratios. However, it feels the extent of on-site preservation for this project is
an exception to the norm.
Based on the efforts to enhance the water quality adjacent to the roadway, NCDOT requests
reconsideration of 4:1 ratios for our preservation sites. Thank you for your time in considering these
points in support of NCDOT's request for better preservation ratios on this project.
2 of 3 9/18/2007 11:27 AM

Re: Comments on U.S. 19/19E (SAW-2007-2197-357-300)
Have a nice day and weekend.
Marisa
[e-mail] wrote:
Hi Dave,
Please find attached EPA's comments on the PN for U.S. 19/19E widening (R-2518A and B, and
R2519A).
Please call or email if you have any questions or comments.
Thanks, and have a good weekend,
Kathy Matthews
USEPA -Region 4 Wetlands Section
109 T.W. Alexander Dr.
Durham, NC 27711
MAIL CODE: E143-04
phone [phone]
cel 1919=619-7319
Marisa Rodman <MRodman(~i~dot.state.nc.us>
Environmental Specialist
Project Development & Environmental Analysis
3 of 3 9/18/2007 11:27 AM