20141149 Ver 1_Staff Comments_20160531

Homewood, Sue
From:Haupt, Mac
Sent:Sunday, May 29, 2016 4:45 PM
To:Bailey, David E SAW
Cc:Homewood, Sue
Subject:Re: Octobank comments
Attachments:Cape Fear 02 umbrella bank review 14May2016.docx
David,

Unfortunately I have to fly out to a funeral tomorrow so my time scheduled for a proper review is shot. I am attaching
comments from Sue Homewood of our Winston-Salem RO and giving you some of my brief comments primarily looking at
the wetlands.

Here are my comments:

1. Motes Creek- the proposed hydroperiod performance (10%) is fine, however, they want to use the Feb 1- Oct 22nd
growing season based on the Eastern Regional Supplement. DWR does not approve of a growing season metric for
Alamance County starting before March 1st. The soil survey does state April 17th and that date is late. DWR believes that
February 1st, or anytime in February is not suitable to initiate the growing season start date...
2. Same comment for the Rocky Top site...
3. Same comment for the Benton Branch site...(although in Caswell County), in addition, they should install several
groundwater gauges in the proposed wetland enhancement area since it is fairly large...

I will look over more thoroughly when I get back Thursday, but did not want to hold you up any further.

Thanks,
Mac

________________________________________
From: Bailey, David E SAW <[e-mail]>
Sent: Monday, May 23, 2016 8:46 AM
To: Haupt, Mac
Subject: RE: Octobank comments

That would be fine, Mac. Thanks.

---
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.
Fax: [phone]
Email: [e-mail]

1

Cape Fear 02 Umbrella Mitigation Bank Final Prospectus – Restoration Systems May 12, 2016

General comments (many of these comments are similar to previously submitted comments):

The Division has concerns that the restoration of low scoring intermittent streams will disconnect

these streams from groundwater. A disconnection with groundwater could result in a channel
becoming non-jurisdictional and no longer viable for mitigation credit.
Specific site comments:
Motes Creek:

UT1 is identified as a perennial stream in the mitigation plan but there is no evidence or

documentation of the USACE or DWR classifying this channels as intermittent or perennial.

The monitoring map shows two surface water gauges proposed for UT1, however the text of the

mitigation plan (page 35) states there will be a surface water gauge in the lower portion of the
stream.

A surface water gauges should be installed within UT1 in the middle portion of the stream

channel where the existing conditions are the driest and therefore of the most concern for
retaining flow after restoration.
Orphan Creek:

The Division prefers to see at least one vegetation monitoring plot to be located within a wetland

enhancement area.

Labels for the UTs should be consistent between maps in future documents.


The Division strongly suggests that future design drawings clearly indicate how the upper portion

UT1A (also referred to as UT1) will be constructed within the existing wetland with clear
indication of the temporary or permanent impacts that will occur to the wetland.
Rocky Top:

The Division prefers to see at least one vegetation monitoring plot to be located within a wetland

enhancement area.
Benton Branch:

The Division continues to have concerns that restoration of UT1 and UT2 and removal of the

upstream ponds will not result in channel forming flows. The mitigation plan should clearly
indicate how and when a final jurisdictional determination will be made, and what actions will
occur if these features are not determined to be jurisdictional after restoration.

UT1 and UT2 are identified as perennial streams in the mitigation plan but there is no evidence or

documentation of the USACE or DWR classifying these channels as intermittent or perennial.

Surface water gauges should be installed in the upper reaches of UT1 and UT2 as well as at the

confluence of these channels as proposed.