20141127 Ver 1_Emails_20160324

Strickland, Bev
From:Melia, Gregory
Sent:Thursday, March 24, 2016 8:19 AM
To:Baker, Virginia; Andrea Hughes ([e-mail]); Haupt, Mac
Cc:Russell, Periann; Jeff Keaton ([e-mail]); Schaffer, Jeff
Subject:RE: meeting
OK, Thanks Ginny.

Andrea – are you good with these changes?

So, we are going to try and get additional pre-data to better characterize the existing condition. Even if we cannot get
enough pre-data to feel confident on this one and have to abandon the effort I think we would like to do this in other
cases when opportunities arise, so I think this exchange and discussion has value regardless.

Thanks,

Greg

From: Baker, Virginia
Sent: Wednesday, March 23, 2016 10:01 PM
To: Andrea Hughes ([e-mail]) <[e-mail]>; Melia, Gregory
<[e-mail]>; Haupt, Mac <[e-mail]>
Cc: Russell, Periann <[e-mail]>; Jeff Keaton ([e-mail])
<[e-mail]>; Schaffer, Jeff <[e-mail]>
Subject: RE: meeting

Hi Greg, I am fine with the changes you made, thanks for getting this turned around so quickly. Ginny
Sent from Outlook Mobile

On Wed, Mar 23, 2016 at 3:01 AM -0700, "Melia, Gregory" <[e-mail]> wrote:
Folks,

The attached includes sections highlighted in yellow that are relevant to our discussion the other day.

Note:
The Qual 4 reference was already in the footnote of table 20
There was a reference to the stage recorder and rain gage is section 12.2.2, but I beefed things up on this topic in
section 12.2.5
I removed some of the detail we discussed.

Once you are OK with the revisions here I can PDF this and integrate this with the existing version and make sure all
parties get a copy.
1

Hopefully this will permit issuance of the permit by Friday.

I will be in the field through mid-afternoon and then back in the office.

Thanks,

Greg

From: Baker, Virginia
Sent: Tuesday, March 22, 2016 4:39 PM
To: Melia, Gregory <[e-mail]>
Cc: Higgins, Karen <[e-mail]>; Haupt, Mac <[e-mail]>
Subject: RE: meeting

Hi Greg,
I will be working part of the day tomorrow at home so if the revisions to the Mudlick Plan are done please send them to
th
me. Otherwise I will review them when I get back on Apr 4, I’m not sure of Mac will want to issue this before then.
th
Please, see my comments below in your March 18 email. I was going to see if Karen had any other input, but she has
not had a chance to get back to me.
Ginny

From: Melia, Gregory
Sent: Friday, March 18, 2016 8:46 PM
To: Baker, Virginia <[e-mail]>
Subject: RE: meeting

Thanks Ginny

OK, that makes sense. I could see you wanting that in the permit language

Have a good weekend

Please Note our new Department Name Below

Greg Melia

Stream Sciences and Monitoring Specialist | Science & Analysis Section |
NC Dept of Environmental Quality
Division of Mitigation Services |

Mail: 1652 Mail Service Center, Raleigh, NC 27699-1652 | Office: 217 West Jones St, Suite 3000A, Raleigh, NC 27603

Office: 919.707.8919 | Fax: [phone] | Mobile: [phone] | http://portal.ncdenr.org/web/eep
Parking and visitor access information

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: Friday, March 18, 2016 6:14 PM
To: Melia, Gregory <[e-mail]>
2

Cc: Haupt, Mac <[e-mail]>
Subject: RE: meeting

Hey Greg, Thanks for checking on the base samples Wildlands collected. Since the plan will need to have some flexibility
in regards to base samples, assuming the results direct you to move forward I wanted to check with Karen on my
response to item 3. We can permit the plan as is, you are right there, but we might want to put some kind of a
“disclaimer” in our permit conditions regarding the extra wq monitoring methodology. I should be able to get back to
you early next week when I hear back from Karen. Number 1 and 2 are clear since we discussed.

Ginny
From: Melia, Gregory
Sent: Friday, March 18, 2016 11:15 AM
To: Baker, Virginia <[e-mail]>
Cc: Haupt, Mac <[e-mail]>; Schaffer, Jeff <[e-mail]>; Andrea Hughes
([e-mail]) <[e-mail]>
Subject: RE: meeting

Ginny,

Just glancing at the Wildlands pre-work it looks like the results were a lot better organized than I thought, but it looks
they have 4 base flow and 4 storm flow samples at this point for the physico-chemical parameters. That’s not enough
obviously, but I would like to leave it open because I’m hoping that I will be able to get out with our summer interns or
tech and get more samples. Bet estimate for construction is October-Nov. Alternatively I may be able to locate a
neighboring disturbed site further up in the watershed that will serve as a “disturbed proxy” and we could collect
supplemental data from to pool with the data we’ve already collected to characterize the pre-con condition.

My thought on using another site further upstream as a “disturbed proxy” seems to be an approach that should be
avoided. I would think this would introduce too much variability into your sample design and analysis, although I would
be open to hearing what Jamie and your contacts at NC State think about that.

Collecting some additional baseline data this summer with an intern would be more useful and seems to be a better
approach. Could language be added to your revision of the methodology (even if these are potential plans) along these
lines?

From my point of view, the language in the mit plan and the above makes 3 things clear:

1.The supplemental credit sought is contingent upon the cost, so the exact amount will never be known in

advance, only that it will not exceed 10% (and will in all likelihood be substantially less than that) Yes

2.The pre-con and/or disturbed data set will inform the final scope, which now looks like we won’t know for sure

at least until the fall based on my discussion above. (Yes, see above)

3.The supplemental credit being sought exists outside the mitigation per se and the permit is really to properly

consider and account for impacts and to some extent approve the mitigation/mitigation approach. It seems
what we are proposing here is “firewalled” from those functions of the permitting process, so should it matter if
we move forward with some uncertainty given what is spelled out in the plan? As I mentioned before since the
water quality methodology is still in this “flexible” state and the fact that the whole sampling may or may not
move forward DWR would probably put a “disclaimer” in our approval conditions. Generally I am more
comfortable with the macroinvertebrate and fish methodology (and success criteria) that was proposed since
3

those are DWR methods that have been tested and used for a number of years. Please be sure to reference the
methodology and mention the Qual 4 macroinvertebrate procedure you plan to use since there are four
methods in that SOP for macroinverts. Larry Eaton had expressed some concern about who would do the IDs
and also I think about carrying out the procedure correctly. It is possible someone from the lab could answer
questions or do some brief training on the Qual 4 procedures.

Again, I don’t have a lot of the regulatory perspective on this, but given what I’ve stated above, let us know your
thoughts.

Thanks,

Greg

Please Note our new Department Name Below

Greg Melia

Stream Sciences and Monitoring Specialist | Science & Analysis Section |
NC Dept of Environmental Quality
Division of Mitigation Services |

Mail: 1652 Mail Service Center, Raleigh, NC 27699-1652 | Office: 217 West Jones St, Suite 3000A, Raleigh, NC 27603

Office: 919.707.8919 | Fax: [phone] | Mobile: [phone] | http://portal.ncdenr.org/web/eep
Parking and visitor access information

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: Thursday, March 17, 2016 5:48 PM
To: Melia, Gregory <[e-mail]>
Cc: Haupt, Mac <[e-mail]>
Subject: RE: meeting

Hi Greg, Thanks, I’m sure if you are going on vacation as I am you have a number of things to get done before you leave
so I understand.

I think your saying that no extra credit would be sought if the pre –data indicated the effort was not worthwhile may
have been in there and I missed it, but we discussed that in the meeting so that part is clear. I was kind of wandering
about the number of event samples for the pre data, if you ended up obtaining too few (<12-14? Jamie had mentioned
17?) would you then move forward or not? I know you were also going to look at the WQ results in making your
decision, but I was not real clear on exactly what the deciding factor would be.

I’m not 100% certain about moving forward with the permit when the extra credits are hinging on the baseline results
being evaluated first, I’m also too new to the regulatory world and have not issued permits to have an answer to your
question on flexibility. That one so I might like to have Mac confer with Karen first before issuing the 401 while these
prelim results are pending. This is also a unique project so there’s that too. Since it sounds like you will have the data
assessed and we will still be within the 60d window (although not the 30d window) it may not be an issue.
4

Ginny

From: Melia, Gregory
Sent: Thursday, March 17, 2016 3:38 PM
To: Baker, Virginia <[e-mail]>
Subject: RE: meeting

Thanks, Ginny

Yes, I will try and get a look at that as soon as I can, but I’m out the week after next and I’ve got a ton to get done on
many fronts before then. So, I can get the revised mit plan text by next week, but I’m not sure about the assessment of
the pre-data.

Doesn’t my language in the narrative that indicates that the pre-data once assessed will help inform the final monitoring
plan (which can range from nothing, to implementing the full plan) kind of address the concern?

Again, I don’t have the regulatory perspective in mind a lot of the time, so is there a problem with the mit plan moving
forward with this kind of flexibility?

If so, let me know

Thanks,

Greg

Please Note our new Department Name Below

Greg Melia

Stream Sciences and Monitoring Specialist | Science & Analysis Section |
NC Dept of Environmental Quality
Division of Mitigation Services |

Mail: 1652 Mail Service Center, Raleigh, NC 27699-1652 | Office: 217 West Jones St, Suite 3000A, Raleigh, NC 27603

Office: 919.707.8919 | Fax: [phone] | Mobile: [phone] | http://portal.ncdenr.org/web/eep
Parking and visitor access information

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: Thursday, March 17, 2016 2:54 PM
To: Melia, Gregory <[e-mail]>
Cc: Haupt, Mac <[e-mail]>; Hughes, Andrea W SAW <[e-mail]>; Schaffer, Jeff
<[e-mail]>
Subject: meeting

Hey Greg, thanks again for planning the meeting today, I felt much more comfortable with my questions being answered
and your approach moving forward. If you are able to get the revisions out by next Wed before I go on vacation that
would be much appreciated. Also, if you are able, to can you let me know the number of sample events (base and storm
flow) that occurred for the baseline conditions. You had indicated the wq baseline is complete now, right (?), but it will
be 2-3 more weeks before the baseline is reviewed and you know if this extra sampling will go forward.
5

Thanks!

Ginny Baker

Transportation Permitting Unit

NCDEQ-Division of Water Resources

1650 Mail Service Center

Raleigh, NC 27699-1650

Phone-[phone], Fax-[phone]

6