20021259 Ver 1_Other Agency Comments_20060808

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890
IN REPLY REFER TO August 3, 2006
Regulatory Division
Action ID No. 200121095, Deep Creek Wetland & Stream Mitigation Bank
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Mr. Lamar Beasley u
American Wetlands AUG 0 8 2006
23 10 Ballycairne Court
Reston, Virginia 20191 UENR - WATER QUALITY
WETLANDS AND STORMWATER BRANCH
Dear Mr. Beasley:
This correspondence is in reference to Deep Creek Wetland and Stream
Mitigation Bank that is being developed by American Wetlands. The site consists of
70.745 acres and is located on the west side of Dinkins Bottom Road (SR 1570), south of
US Highway 421, southwest of Yadkinville, adjacent to Deep Creek and one of its
tributaries, in Yadkin County, North Carolina.
Reference is made to the Year-Three Monitoring Report dated January 24, 2006,
our site inspection of March 28, 2006, and comments from the North Carolina Wildlife
Resources Commission in their letter dated April 21, 2006, and the North Carolina
Department of Environment and Natural Resources, Division of Water Quality (DWQ),
dated May 11, 2006. With respect to the report and the comments from the resource
agencies, Wells D3 and D9 did not meet success criteria for 2005. The addition of Well
D3A near Well D3 may assist to provide more conclusive data as to the extent of
successful hydrologic restoration within that area. The Division of Water Quality also
raised concerns regarding the vegetation data. Specifically, they were concerned that
sweet gum was being counted towards the success criteria for woody species for Plots 4,
7, and 12, which otherwise would not meet the success criteria. Plot D2 has only 6 trees,
making it marginally successful. However, the field inspection revealed that vegetation
success criteria on the site overall is acceptable with lower densities occurring within
microtopographic depressions where ponding may be hindering the successful
establishment of woody species.
With respect to the stream stability, all agencies are concerned about the stream
channel stability. During the site inspection, it was noted that beaver have constructed
dams along the stream reach that need to be addressed. While the benthic
macroinvertebrate survey demonstrates a shift from worms, mollusks and dipterans in
2003 to intolerant mayflies, stoneflies and caddisflies in 2005, DWQ expressed concern
that the 2003 samples may have been collected from pools, instead of riffles. In addition,
they stated that future macroinvertebrate collections should be taken in February instead
of April, to ensure that post-construction sampling occurs in the same month as the pre-
construction sampling. Furthermore, the cross-sectional profiles contained within the
report show the riffles getting consistently deeper over time, with the longitudinal profile
demonstrating a similar trend. These changes might be a result of the beaver activity or
of the bankfull height being constructed too high, particularly within the lower reaches of
the project, which would prevent flood waters from accessing the floodplain during
bankfull and slightly greater events. The increased stress on the outside bends could
cause down-cutting, potentially resulting in a need to perform some remedial work on the
bank and riparian area.
Reference is also made to the attached letter from American Wetlands dated May
30, 2006, concerning an additional 193 linear feet of stream channel credit that was
constructed when the site was built. Team members need to replace the proposed
generated credits from the original Mitigation Banking Instrument with the attached
document reflecting the as-built credits. Finally, while portions of the project still have
unresolved concerns that will require close observation and possible mediation, overall
the site appears to be meeting the success criteria. Accordingly, 10% of the wetland and
stream credits are now available since interim success criteria have been met.
Thank you for your time and cooperation. If you have any questions, please do
not hesitate to contact me at [phone], Ext. 24.
Sincerely,
Jean B. Manuele
Chief, Raleigh Regulatory
Field Office
Copies Furnished with attachments:
Ms. Rebecca Fox
United States Environmental Protection Agency
1349 Firefly Road
Whittier, North Carolina 28789
Ms. Marella Buncick
United States Fish and Wildlife Service
Fish and Wildlife Enhancement
160 Zillicoa Street
Asheville, North Carolina 28801
Ms. Amanda Mueller
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1650 Mail Service Center
Raleigh, North Carolina 27699
Mrs. Marla Chambers
North Carolina Wildlife Resources Commission
Habitat Conservation Program
112275 Swift Road
Oakboro, North Carolina 28129