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Home My WebLink About20140332 Ver 1_Regional staff comments_20150714Baker, Virginia From: Homewood, Sue Sent: Tuesday, July 14, 2015 12:13 PM To: Baker, Virginia Subject: RE: Notice of NCDMS Draft Mitigation Plan Portal Review / Browns Summit Mitigation Project / Guilford County / SAW - 2014 -01642 (UNCLASSIFIED) The BMP manual won't be around for long so don't study it too hard. The problem is that it was written with development in mind, not mitigation plans so I don't think we should hold mitigation sites to the same level of detail as the manual requires but there has to be some standards to hold mitigation sites to. So it's sort of a gray area that judgement just needs to be used. That's why it's hard to provide comments. Honestly I could probably become comfortable by just talking directly to the designer, but then there'd be no documentation for when questions /concerns arise at closeout. I say just wing it until Karen replaces Eric and then you won't have to worry about this stuff anymore anyway .... or a lot less often at least. Have you thought about begging Cyndi to take you to the lab when she goes? Ha! Sue Homewood NC DENR Winston -Salem Regional Office Division of Water Resources — Water Quality Programs 450 W. Hanes Mill Rd, Suite 300 (Please note my new contact information) Winston Salem NC 27105 Voice: (336) 776 -9693 Cell: (336) 813 -1863 E -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Baker, Virginia Sent: Tuesday, July 14, 2015 12:09 PM To: Homewood, Sue Cc: Karoly, Cyndi; Higgins, Karen Subject: RE: Notice of NCDMS Draft Mitigation Plan Portal Review / Browns Summit Mitigation Project / Guilford County / SAW- 2014 -01642 (UNCLASSIFIED) Hey Sue, Thanks for looking in section 17 and providing input. I think I need to get familiar with what the BMP manual asks for so I can recognize when a plan is complete and when it is not. They do have some performance standards for R6, but it is only vegetation success in terms of stems per acre and that does not guarantee a BMP is functioning properly. I think I am good with this, feel free to stop by if you want. Thanks much!!! I have to wander if we need to be adjusting the BMP manual to account for all these mitigation BMPs we are getting, I think there will just be more of them in the future. Ginny From: Homewood, Sue Sent: Tuesday, July 14, 2015 11:27 AM To: Baker, Virginia Cc: Karoly, Cyndi; Higgins, Karen Subject: RE: Notice of NCDMS Draft Mitigation Plan Portal Review / Browns Summit Mitigation Project / Guilford County / SAW- 2014 -01642 (UNCLASSIFIED) Ginny, I made some suggested changes to your text. Here's the thing, at the current level of detail they provided it's hard to document that they are following the BIVIP manual for the Constructed wetlands. That said, what they show is a reasonable conceptual plan, and so is the RSC, but the problem becomes that if we don't have more documentation of how it's going to function then we don't have confidence that it will work and provide value to the project. It's a fine line in, since the BIVIP manual was developed for urban development use it may not be the appropriate tool for mitigation site design, but we need something to feel certain that the BIVIP will provide value and we will be able to 10 to I'm in Archdale today. I have a meeting from 1 :30 — 3. If you want to talk in person I'm on the 9t" floor in the office next to Niki Maher. I can stay after 3 if you don't catch me before then. Ps, the step pool above and below the constructed wetlands are fine, those are more inlet /outlet channels (where in development sites you'd use pipes) and don't need to show they meet the RSC that the other channel would meet. I can explain that more if want. << File: Brown Summit Comments 7- 13- 15- sh.docx >> Sue Homewood NC DENR Winston -Salem Regional Office Division of Water Resources — Water Quality Programs 450 W. Hanes Mill Rd, Suite 300 (Please note my new contact information) Winston Salem NC 27105 Voice: (336) 776 -9693 Cell: (336) 813 -1863 E -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Baker, Virginia Sent: Monday, July 13, 2015 12:49 PM To: Homewood, Sue Cc: Karoly, Cyndi; Higgins, Karen Subject: RE: Notice of NCDMS Draft Mitigation Plan Portal Review / Browns Summit Mitigation Project / Guilford County / SAW- 2014 -01642 (UNCLASSIFIED) << File: Brown Summit Comments 7- 13- 15.docx >> Here are the comments for Brown Summit. Let me know what you think should be revised after reviewing Section 17, p. 17 -19 and 17 -21. Thanks a bunch. I need to take that training Annette mentioned that is offered on BMPS the next time it is available. Ginny From: Homewood, Sue Sent: Friday, June 19, 2015 11:39 AM To: Baker, Virginia; Karoly, Cyndi Cc: Higgins, Karen Subject: FW: Notice of NCDMS Draft Mitigation Plan Portal Review / Browns Summit Mitigation Project / Guilford County / SAW- 2014 -01642 (UNCLASSIFIED) Ginny and Cyndi, Here are my comments on the Draft mit plan for your review. If you need me to expand on anything, please let me know. In general the plan follows what the IRT members discussed during multiple site visits The information regarding the two BMPS is weak. Section 7.0 provides no specific details of how the two BMPS will be designed. They may not need to meet the BMP manual (and RSC isn't even in there) however a general discussion about how they will be designed and what the objectives are would be beneficial. The table provides very little information, as it does for streams and wetlands but those are then expanded upon in the text. Section 8.0 states that the BMPS will be monitored and maintained in accordance with the BMP manual however RSC isn't in the manual so there's no monitoring or maintenance criteria. Also, if they don't design the wetland to BMP manual then the monitoring or maintenance may not make sense for what they end up with. Section 9.0 is very vague. It talks about monitoring and corrective measures for instability but it doesn't actually give performance standards which is what this section is supposed to cover. Maybe they are proposing that the performance standard is solely stability and no other performance standard should be required. In general for the BMPS the document is weak. I'm not necessarily suggesting they have to design a specific way, or monitor or even what the performance standards should be, but unless the document is clear what the expectation is then I think in the future there could be problems with closeout or requests for repairs etc. I just think it needs to be clear, even if that's "we propose to do almost nothing and still get credit ". I hope that makes sense. I guess now that they are pushing credits for stormwater so much more I'm looking at these plans that have "valley length" credit a little differently. I think both BMPS are reasonably chosen for their location and will provide benefit to the overall project, but I also think we could end up at close out with different opinions of "success" or what triggers corrective action, etc. Ps: I wrote this in a very informal way, for your review, if you cut and paste into the portal you may need to re -word the text for general distribution. Sue Homewood NC DENR Winston -Salem Regional Office Division of Water Resources — Water Quality Programs 450 W. Hanes Mill Rd, Suite 300 (Please note my new contact information) Winston Salem NC 27105 Voice: (336) 776 -9693 Cell: (336) 813 -1863 E -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. - - - -- Original Message---- - From: Tugwell, Todd SAW [ mailto :Todd.TuRwelI @usace.armv.mill Sent: Tuesday, June 16, 2015 10:26 AM To: Fritz Rohde (Fritz. Rohde @noaa.Rov); Chapman, Amy; Baker, Virginia; bowers.todd @epa.Rov; Karoly, Cyndi; Cox, David R.; Hall, Dolores; Emilv JerniRan(?fws.2ov; Gibby, Jean B SAW; Homewood, Sue; Hughes, Andrea W SAW; Bailey, David E SAW; Higgins, Karen; Kathrvn Matthews @fws.Rov; McLendon, Scott C SAW; Poupart, Jeff; Gledhill- earley, Renee; Wilson, Travis W.; Wicker, Henry M JR SAW Cc: Schaffer, Jeff; Baumgartner, Tim; Vanstell, Kayne; Hunt, Scott Subject: Notice of NCDMS Draft Mitigation Plan Portal Review / Browns Summit Mitigation Project / Guilford County / SAW- 2014 -01642 (UNCLASSIFIED) Classification: UNCLASSIFIED Caveats: NONE No The below referenced Draft Mitigation Plan has been posted by NCDMS on the Mitigation Plan Review Portal. Per Section 332.8(g) of the 2008 Mitigation Rule, this review period will remain open for 30 calendar days from this email notification. Please post comments by 5 PM on the 30 -day comment deadline shown below. When posting comments please indicate if your concerns are great enough that you intend to initiate the Dispute Resolution Process described in Section 332.8(3) of the Mitigation Rule. Comments posted after the 30 -day comment deadline (shown below) may not be considered. This comment period may be extended at the request of NCDMS if they determine that additional time is necessary to make changes to the Draft Mitigation Plan. Please note that NCDMS may post responses to the comments on the portal as well. At the conclusion of this comment period, notification will be provided to NCDMS and the NCIRT of the District Engineer's intent to approve or disapprove this project. More information, including instructions to access and use the portal, and a flow chart detailing the process are included in the document attached to this email notice. NCDMS Mitigation Plan Review Portal Address: http: // portal. ncdenr. org /group /eep -irt /mitigation -plan- review Project Name: Browns Summit Mitigation Site USACE Action ID #: SAW- 2014 -01642 NCDMS Project #: 96313 County: Guilford River Basin: Cape Fear H UC: 03030002 Assets: 5,194 SMUs (3,846 If R; 1,450633 If El; 1,084 If Ell) and 2.69 RWMU (4.44 ac R including 0.72 re- establishment and 3.72 rehabilitation) Provider: Michael Baker Engineering, Inc. NCDMS Project Manager: Jeff Schaffer, email: jeff.schaffer @ncdenr.gov 30 -Day Comment Start Date: June 16, 2015 30 -Day Comment Deadline: July 16, 2015 60 -Day Intent to Approve Deadline: August 15, 2015 Questions may be addressed to Todd Tugwell with the U.S. Army Corps of Engineers at the address and number below. Todd Tugwell Special Projects Manager Wilmington District, US Army Corps of Engineers 11405 Falls of the Neuse Road Wake Forest, NC 27587 Office: 919 - 846 -2564 Mobile: 919 - 710 -0240 Classification: UNCLASSIFIED Caveats: NONE << File: NCIRT Mitigation Plan Review Process for NCDMS Projects 20150616.pdf >>