HomeMy WebLinkAbout20140333 Ver 1_Approval Letter_20151006DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403 -1343
REPLY TO
ATTENTION OF: May 1 1 , 2015
Regulatory Division
Re: NCIRT Review and USACE Approval of the Holman Mill Stream Restoration Project Draft
Mitigation Plan; SAW- 2015- 00019; DMS Project #96316
Mr. Tim Baumgartner
North Carolina Division of Mitigation Services
1652 Mail Service Center
Raleigh, NC 27699 -1652
Dear Mr. Baumgartner:
The purpose of this letter is to provide the North Carolina Division of Mitigation Services
(NCDMS) with all comments generated by the North Carolina Interagency Review Team ( NCIRT)
during the 30 -day comment period for the Holman Mill Stream Restoration Project Draft Mitigation
Plan, which closed on 9 April, 2015. These comments are attached for your review.
Based on our review of these comments, we have determined that no major concerns have been
identified with the Draft Mitigation Plan, which is considered approved with this correspondence.
However, several minor issues were identified, as described in the attached comment memo, which must
be addressed in the Final Mitigation Plan.
The Final Mitigation Plan is to be submitted with the Preconstruction Notification (PCN)
Application for Nationwide permit approval of the project along with a copy of this letter. Issues
identified above must be addressed in the Final Mitigation Plan. All changes made to the Final
Mitigation Plan should be summarized in an errata sheet included at the beginning of the document. If it
is determined that the project does not require a Department of the Army permit, you must still provide a
copy of the Final Mitigation Plan, along with a copy of this letter, to the appropriate USACE field office
at least 30 days in advance of beginning construction of the project. Please note that this approval does
not preclude the inclusion of permit conditions in the permit authorization for the project, particularly if
issues mentioned above are not satisfactorily addressed. Additionally, this letter provides initial approval
for the Mitigation Plan, but this does not guarantee that the project will generate the requested amount of
mitigation credit. As you are aware, unforeseen issues may arise during construction or monitoring of
the project that may require maintenance or reconstruction that may lead to reduced credit.
Thank you for your prompt attention to this matter, and if you have any questions regarding this
letter, the mitigation plan review process, or the requirements of the Mitigation Rule, please call me at
919- 846 -2564.
Sincerely,
Di ' mt-0 A18HUGHES.ANDREA.WADE.12 DNt USo =U.S. Government,
58339165 cn= HUGHES.ANDREA.WADE.1258339165
Date: 2015.05.11 13:31:11-04'00'
Andrea Hughes
Special Projects Manager
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
Jeff Schaffer, NCDMS
John Hutton, Wildlands Engineering
REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 2 8403 -1 34 3
CESAW -RG /Hughes April 24, 2015
MEMORANDUM FOR RECORD
SUBJECT: Holman Mill - NCIRT Comments During 30 -day Mitigation Plan Review
PURPOSE: The comments listed below were posted to the NCDMS Mitigation Plan Review
Portal during the 30 -day comment period in accordance with Section 332.8(8) of the 2008
Mitigation Rule.
NCDMS Project Name: Holman Mill Stream Restoration Project, Alamance County, NC
USACE AID #: SAW- 2015 -00019
NCDMS #: 96316
30 -Day Comment Deadline: 9 April 2015
Ginnv Baker, NCDWR, 9 April, 2015:
1. Holman Mill Stream Mitigation is a well written and detailed mitigation plan.
2. The reference reach used for this study has a Rosgen E4 classification but a C4 is
proposed. Please explain the reasoning behind using an E4 stream as a reference for a
channel to be built as a C4.
3. Please correct Figure 9 which indicates the lower section of UT2 -R1 is E1. The plan
sheets indicate this lower section is El and should be labeled UT2 -R2. UT2 -R2 and UT2 -
R3 on Figure 9 should be labeled all UT2 -R3 as it is on the plan sheet. This correction
also supports what is on the Determination of Credits Table 9, p. 20, and written in the
Project Implementation Section 9.6, p. 30.
4. NCDWR recommends removing red maple (Acer rubrum) from the planting list as this
species will establish on its own and replacing it with one of the other native trees that
are known to occur already on this project site such as American elm (Ulmus americana)
or Sugar berry (Celtis laevigata).
Todd Bowers, USEPA, 26 March, 2015:
1. Please explain the reasons behind the omission of the pond and stream at the head of
UT213. It appears that cattle will still have access to the pond and stream and there will
continue to be a stressor on water quality on the UT to Pine Hill Branch (PHB). Cattle
exclusion of the project would logically include this area. If reasons include landowner
unwillingness to include this area in the conservation easement then it should be
documented. Cattle could be provided an alternate source of water and would not need
access to the pond /stream. This would support the opening paragraphs on Page 1.
2. Section 2.2: Wetlands present will be preserved and not proposed for credit at this time.
Does this imply that credit may be requested in the future?
3. Section 4.3 and Figure 4, Soils Map: HdC2 soil mapped color is not consistent with the
legend. Please correct.
4. Section 4.4 and Table 5: Stream valleys have slopes of 1.3 to 2.3 percent. Stream valley
slopes in Table 5 range from 0.7 to 3.0 percent. Please correct.
5. Section 4.5 and Figure 6: Hydrologic features outlined in Figure 6 should be shown as
they are in Figure 4 to denote perennial and intermittent streams. Reach Breaks for UT1
should be displayed on Figure 6 also. Figure 6 (and 9 -11) also shows that the
conservation easement for UT to PHB is outside of the project boundaries. Is this a
discrepancy?
6. Section 4.6, Table 5, Figure 6: A cross section with data is included for UT to PHB. Figure
6 does not show the location of this cross section. Please correct.
7. Section 4.6.3: Celtis laevigata is noted for sugarberry however the Wetland Data Sheet
for DP 10 lists Celtis occidentalis for sugarberry. Please correct if this is an error.
8. Section 4.6.4: UT2 in second paragraph should be UT2A. Please correct.
9. Section 4.6: Why is there no assessment of UT1A and UT2B? I understand these are
intermittent reaches but some evaluation of their condition should be provided.
10. Section 7, Table 9: Proposed credit for UT2A should be 540. Error was not carried
forward.
11. Section 7, Table 9 and Figures 9 &11: UT2 -R2 is listed as E1 approach and on the maps it
is shown as restoration. The plan views of UT2 -R2 also show E1 approach.
12. Section 9.6.1: The second paragraph discussion of UT2 -R2 is confusing. It states E1 for
the reach, and then describes how the bed will be raised and a riffle -pool sequence will
be constructed (P1 restoration). The sentence that follows this statement should read
"UT2 (Reach 3 and 4) to be restored using P1 restoration." This is similar to comment
#11.
13. Section 9.6.2 and Sheet 3.1 construction plans: Recommend replacing the 10% of Acer
rubrum with another riparian hardwood species such as Ulmus americana, Carya ovata
or Juglans nigra.
14. Section 9.6.2 and Sheet 3.1: If Alnus serrulata is going to be planted can we depend on it
reaching an average height of 10 feet by the end of the monitoring period?
15. Section 11.1.2: Include what signs would indicate vertical or lateral instability.
16. Section 11.1.6: Include a contingency plan on how to deal with volunteers. Will they or
will they not be counted towards meeting performance standards should planted stems
fail to meet stated density.
17. Plan Sheets 2.1 -2.6: UT1 is divided into four reaches UT1 -4 with differing approaches.
Figures 1 -11 do not illustrate UT1 -4 and the tables within the document do not
differentiate the reach numbers.
18. Abandoned channel plugs are not shown in Plan Sheets where P1 restoration is being
implemented. I understand these are not the plans being used for construction.
19. The cover and footer logs in pool bends are illustrated in reverse of the Cover log
diagram of Sheet 6.3.
20. Plan Sheets 2.1 - 2.12: Recommend showing proposed cross - section locations on the
plan view diagrams.
21. Wetland Data Forms contained within Pages 72 -171 in Appendix B have substituted DP2
for DP5, 8, 9, 11 -17, 19 -21, 23 -29 and 31 -33. Please replace with appropriate DP data
forms.
Andrea Huqhes, USACE, 24 April, 2015:
1. Please ensure that a JD is obtained from the USACE Raleigh field office prior to
submitting the NW 27 permit Pre - Construction Notification (PCN).
2. All temporary and permanent impacts to existing wetlands and streams must be
accounted for in the PCN and the loss or conversion of those waters must be replaced
on -site. Please include a map depicting the location of all impacts with the PCN.
Andrea Hughes
Special Projects Manager
Regulatory Division
Digitally signed by
HUGHES.ANDREA.
HUGHES.ANDREA.WADE.125833916S
DN: c -US, o =U.S. Government, ou -DoD,
WADE.1258339165
con= HUGHESANDREA.WADE.1258339165
Date: 2015.05.11 13:30:40 - 04'00'
Andrea Hughes
Special Projects Manager
Regulatory Division