20231113 Ver 1_PRM_TurkeyMP_Comments

Turkey Mitigation Site – Draft Plan Comments
Page 2, Section 1.0 – Note total LF & acres don’t equate total credit. The impact 2:1 LF and acre totals aren’t double the impact totals.
Page 6, Table 2 – Please confirm the number of marsh treatment areas. Are perched culverts being upgraded or removed?
Page 7, Section 5 – Please add an existing vegetative community characterization subsection and include a list of invasive species observed onsite.
Page 9, Section 5.4 – Please include the NCLSS soil investigation report and detailed drained soil delineation map(s).
Page 10, Section 5.5 – Was potential suitable habitat for the for Schwineitz Sunflower assessed within the proposed project area? TCB coordination?
Page 13, Tables 4 & 5 – Please add a table footnote clarifying that Stream SA4 and Wetlands 13, 15 and 16 are not located within the proposed PRM Site.
Page 14, Section 5.8 – It would be helpful to have an NCSAM and NCWAM results summary table.
Page 16, Section 5.12.3 – Reach SA4 is not located within the proposed PRM site. Is basing proposed and existing conditions model on an offsite stream suitable for the PRM site design?
Was an existing conditions model run on any of the small drainage intermittent reaches within the project site?
Page 19, Section 6.1.1 – Based on observations from other mitigation sites, soil compaction and low soil fertility can be issues for vegetation establishment and vigor along Priority
2 cut benches and side slopes. Please place a monitoring veg plot within a proposed P2 cut area.
Page 21, Section 6.2.2 –
Reach SA4 is not located within the proposed PRM site, please remove references.
Design Drawing No. 38 does not show braided headwater restoration, please confirm that this approach is being proposed for SA11. If so, please show on design drawings.
Page 23, Section 6.2.5 – Vernal pools, ephemeral pools, storage depressions and constructed depressions are mentioned throughout the plan. Do these features differ in proposed location,
design and/or function? If more than 0.5-ft microtopographic grading is proposed, please include a design drawing feature callout and detail (specifying max. depth). Grading of any
depressions within a proposed wetland credit area should have a max. depth of less than 1-ft, except potentially for wetland establishment areas. Grading of depressions outside of wetland
areas but within the floodplain should be designed to seasonally dry for habitat value.
Page 23, Section 6.2.8 – Based on past mitigation project reviews, typically marsh treatment features have a max. depth of 2 feet or less. A BMP with a 4-ft pool depth would be considered
more of a wet pond feature. Please confirm the
total number of marsh treatment areas proposed for this project (Table 2 and Figure 9).
Page 24, Section 6.2.10 – Related to the livestock removal, please note the proposed decommissioning of the existing well onsite shown on Drawing No. 9.
Page 25, Table 9 – The scientific name of brown top millet is Urochloa ramose.
Page 27, Table 11 – If green ash is substituted in, the total percent stems should be capped at 5% due to the risk of high mortality from the emerald ash borer. Also please limit box
elder and eastern cottonwood stem totals to 10% since both species are known to be prolific and could affect community diversity.
Page 28, Section 8.0 – Please provide an as-built redline drawing set identifying deviations and field changes from the approved design drawings, including planting plan.
Page 31, Sections 8.3 – Please include discussion of the installation and monitoring of flow and bankfull measurement gauges within this hydrology monitoring section.
Page 31, Section 8.4 –
Please specify the bankfull performance standard of four events in separate years.
Based on the design drawings, upper SA10 is the only reach proposed as braided headwater. The SA10 stream length included in Table 14 appears to only account for the single thread reach
segment. Therefore, a braided headwater performance standard and monitoring protocol is not required. However, annual visual monitoring should be performed to verify stability of flow
paths and note potential problem areas (e.g., headcuts). Also, please note that if a braided headwater stream was proposed it would be required to meet 30 days consecutive flow annually
and would not be considered an ephemeral feature.
Page 32, Section 8.5 –
What is the distance from the site to the Wadesboro data station? Is an onsite rain gauge proposed?
Please confirm that the growing season start and end dates will not change once established in the as-built report.
Annual maintenance inspections of monitoring equipment and quarterly data downloads are encouraged. Performance standard success cannot be inferred if required data is not provided.

Please note that wetland hydrology is an annual performance standard.
Page 33, Section 8.6 –
Please include previous years’ data in vegetation and stream summary tables.
Visual Documentation – Please provide an annual visual assessment of the project area and easement boundary, invasive species cover, encroachments, etc. Please include fixed photo stations
at each cross section, gauge location and easement break stream crossing. Please also
include fix photos stations on all restoration reaches that don’t have a cross section and/or gauge (e.g., SA6, SA10) and at the marsh treatment area upstream of SA6.
Page 34, Table 13 – Annual management of invasive species is strongly encouraged.
Page 36, Section 12 – Please remove the “UMBI” reference.
Page 37-38, Tables 14 & 15 – Please add a column indicating the proposed mitigation credit ratio.
Page 38, Table 15 – Please include breakdown of each proposed wetland area with associated acreage in this table or an additional table.
Figure 4 – The Existing Wetlands included in legend are not shown on map, please add.
Figure 9 –
Flow gauges on all intermittent restoration reaches should be located within the upper one-third of the reach, please shift gauges on the map accordingly. Please relocate the flow gauge
from SA1 to SA5. Please add gauges to measure bankfull events on lower SA1 and lower SA3.
Please be cognizant of proposed microtopography grading when selecting groundwater gauge locations. Depressions and fill areas should be avoided. Locations should be representative of
the larger wetland credit area. Please add a gauge to Wetland 2 and Wetland 5 rehabilitation areas.
All wetland credit areas associated with vegetative uplift (enhancement, rehab, reestablishment, establishment) should be monitored using either fixed veg plots or random transects during
the 7-year monitoring period.
The agency site meeting minutes figure showed marsh treatment areas upslope of SA2 and SA8. Why were these BMP locations cut from this plan?
Appendix A – Please indicate that Reach SA4 Photos 13 – 24 are not located within the proposed PRM site.
Appendix F –
Reach SA4 was used to develop the site-specific regional curve. Similar question as the existing/proposed conditions model, is SA4 representative of the small drainage area intermittent
reaches located within the PRM site proposed for restoration?
Please confirm the SA1 drainage area. Table 7 notes a 314-acre drainage area for SA1.
Why do the drainage areas change for SA1 and SA4 between the site data and ecoregion data?
The drainage areas for the seven intermittent streams onsite range from 2.1 ac. to 10.5 ac., which is considerably smaller than the ecoregion reference streams listed. Are there any
concerns designing site streams based on larger drainage area systems?

Please provide a map showing reference stream locations relative to the PRM site.
Appendix H – General design drawing questions/comments:
The project grading plans only show log grade control structures. Adding woody material to stream and wetland systems is generally encouraged, particularly as habitat enhancement. However,
the use of only log grade control structures can be a concern for long-term channel stability, particularly for intermittent B-type channels with slope. Based on observations from other
mitigation sites, log structures can be more prone to rot quicker and pipe along intermittent channels affecting the grade control functionality. Please discuss the structure selection
process, including the evaluation of risks.
Log step pools are called out along proposed C-type channels. Typically, C-type channels are associated with a riffle-pool sequence rather than a step-pool sequence. The plan narrative
discusses riffle-pool morphology and increasing increase riffle length and natural pool-to-pool spacing (Table 1), as well as using constructed riffles, alluvial riffles, and log riffles
along restored streams. The design drawing legend include only a habitat enhancement riffle structure. But no riffles are shown or called out on the plan drawings. If riffle structures
are proposed, please indicate type(s) and locations on plan view drawings and add design details as needed. Also, please specify min./max. riffle length.
There are no meander bend bank treatments proposed. Are there any concerns about long-term bank stability?
Is sufficient bedform diversity and instream habitat enhancement uplift expected from installing only log step/vane structures?
Drawing No. 2 – A Floodplain Sill is noted under Special Notes. If proposed for this project, please include a design detail and show of plan drawings.
Drawing No. 4 – In the legend, please rename Stream Rehabilitation to Stream Restoration to be consistent with the project narrative and figures.
Drawing No. 7 – Please confirm the callout “grade irregular topography +/- 0.5 ft. along proposed stream floodplain” includes backfilling existing stream channels. Also, please add a
max. depth to the callout (applies to subsequent drawings).
Drawing No. 8 – Backfilling of the existing channel is shown as wetland establishment in one area and reestablishment in another, seemingly based on the adjacent wetland type. For consistency
all channel backfill areas proposed for wetland credit should be considered establishment due to the required hydric soil development of the fill material. This comment applies to MMO1,
MM03 and MM06.
Drawing No. 10 and 23 – Will livestock have access to the stream within the easement break upstream and/or downstream of the bridge? If fencing is proposed, please include an overall
fencing plan with approximate locations of proposed gates.

Drawing No. 11 – Please confirm that all areas of existing channel located outside proposed limits of grading will be backfilled (applies to subsequent drawings).
Drawing No. 17 – The site meeting minutes indicate light EI approach at top of SA2, which would indicate a current level of function and some areas of stability. However, limits of grading
are shown along this entire reach. Were there any stream, bank or wetland areas assessed to be stable and to be avoided/protected during construction?
Drawing No. 28 – In the site visit meeting minutes DWR recommended a braided headwater approached for the upper SA5 reach. Are there any concerns about upper SA5 having enough flow to
support a single stem stream and maintain channel features through the surrounding wetland? With the amount of excavation proposed please elaborate on the justification of a stream
restoration approach through the existing Wetland 2.
Drawing No. 37 – Are there any concerns about creating flow paths within an existing wetland having a drainage effect on the wetland? If the flow paths are shallower and more dispersed
than the existing stream channel, would wetland reestablishment or establishment be expected to develop downslope of the wetland rehabilitation area?
Drawing No. 38 –
Is the existing culvert called out proposed be removed? If so, should limits of grading be extended upstream? If not, please include culvert dimensions. Typically, structures proposed
to remain are excluded from the conservation easement or identified as internal crossings. If this structure is proposed to remain within the easement, future maintenance allowances
need to be discussed with the long-term steward and included in the CE agreement.
Please provide context for the callout “armor sides of pool as necessary”. Does this callout apply to only this specific location?
Sheet 60 –
The proposed borrow area located between SA7 and SA1 is not consistent with conditions required for wetland reestablishment. If excavation is proposed in this area, the wetland type
will need to be changed to establishment due to the soil disturbance and consequent time required for hydric soil development.
Three of the four proposed borrow areas are located in the vicinity of existing and/or proposed wetland areas. Please discuss the potential risk of lateral drainage effect that excavating
a borrow area adjacent to wetland may pose. How could this affect the function uplift proposed in adjacent wetland rehabilitation and enhancement areas?
Drawing No. D1 –
Marsh treatment area – The plan drawings show no swales or flow paths from any of the proposed marsh treatment outlets, please confirm. If
swales or flow paths are added during construction, please callout on redline drawings.
Braided flow path – Please specify a flow path max. depth.
Drawing No. D2 – The bridge crossing example photo appears heavily armored, potentially more than necessary to retain the appropriate channel dimension. Please consider aquatic passage
limitations during construction of these proposed crossings.
Drawing No. D3 –
Clay channel plug – A 5-ft minimum channel plug length is much shorter than what is typically proposed on mitigation projects, which can be up to a 50-ft min. length in the coastal plain.
Are there any concerns about the stability or flow risks of installing a narrow plug?
Rootwad – If proposed, please show this structure on plan drawings.
Drawing No. D4 –
Toe wood and live brush layering – This is a commonly used bank structure on mitigation projects. As designed it can add wood to the system, enhance pool habitat, and provide bank stabilization.
Please show proposed locations of this structure on plan drawings.
Log step pool – Please consider aquatic passage in the design and construction of step pools throughout the project. A footer rock is not typically called out on log step details for
mitigation projects. Is there any concern about shifting or piping between the log and rock? What are the proposed dimensions of footer rocks?
Drawing No. D5 –
The bank boulders example photo shows what appears to be boulders lining a straight segment of stream. For this project, how and where would bank boulders potentially be used (e.g.,
reinforce meander bends)? A long section of rock lined channel is generally not consistent with mitigation project design objectives in this ecoregion.
Section 6.0 (page 19) notes that field conditions may result in structure substitutions and the addition of boulder riffles and boulder cross-vanes. Please provide typical design details
for these structures and identify them as potential substitution structures.
Drawing No. D6 –
Cascade – Please identify the max. pool depth.
Wetland cell – Where is this feature being proposed? Will these areas be seeded and planted with bareroot stems?
General Mitigation Plan Comment – Summary tables are an efficient tool to aid in agency plan review. Please consider adding a project attribute table, essential morphology parameters
table, and monitoring summary table (see examples).