20071843 Ver 1_Emails_20071203

Re: Stone Farm Bank
' - Subject: Re: Stone Farm Bank )9_/yq3
From: Tammy Hill <[e-mail]>
Date: Mon, 03 Dec 2007 14:13:35 -0500
To: "Sugg, Mickey T SAW" <[e-mail]. mil> I?
CC: [e-mail], Brent Manning <[e-mail]>, COPY
[e-mail], [e-mail], "smtp-Sechler, Ron" <[e-mail]>,
[e-mail], Eric Kulz <[e-mail]>
Hi, Mickey. Eric Kulz & I have reviewed the MBI & amended mitigation plan language
for Stone Farm Mitigation Bank. Here are our comments:
General comments & MBI:
1) MBI, section 2.1, 2nd line: change "steam" to "stream"
2) The service area detailed in Table 2 is acceptable to DWQ. As noted by Kathy
Matthews, the footnote to this table should be changed to refer to CU 03040207. We
agree that the MBRT may approve the application of bank credits to impacts that are
outside of the prescribed service area but within CU 03040207 and 03040206.
However, in doing so, the MBRT will bear in mind that the vast majority of the
mitigation project area is within CU 03040206.
Stream monitoring & credits:
1) Addendum to the Mitigation Plan (Exhibit B), page 5, last paragraph of D: "If
insufficient flow... stream credits may be reduced to the existing valley
length..." Add "or less" - as discussed in our previous comments, if the streams
do not demonstrate flow, DWQ may not award stream credits.
2) There may be some confusion regarding stream credits due to the differences in
stream classification between USACE and NCDWQ methods. According to the MBI,
20,355 LF of stream credit is to be generated. Review of the PCN revealed that two
of the ditches slated for restoration, the Main Stem and Hunters Creek, are
perennial, whereas the North Trib and the Southern Trib are intermittent. DWQ does
not currently require mitigation for impacts to intermittent streams. It is
possible that at some point in the future, once NCSAM is implemented, intermittent
mitigation credits may be required. In addition, these credits may be suitable to
mitigate for impacts to intermittent streams determined by USACE to be
"important". However, credits generated through the restoration of the North Trib
and the Southern Trib shall not be used to mitigate for impacts to perennial
streams.
3) It is not clear that the use of stream gauges will be able to demonstrate flow.
If these are crest gauges, it is our understanding that they measure maximum water
levels. Since no discrete channels are being constructed, it is unlikely that flow
meters would work. Some physical on-site observation and evidence of surface flow
of water is needed, such as the use of sand plots. Other evidence may be the
presence of wrack lines or the development of braided, dendritic flow pathways.
Monitoring should include actual field data and observations of flow, coupled with
the macrobenthos data. As discussed, the presence and persistence rheophilic
organisms would be the desired success criteria.
Feel free to give me a call to discuss any of our comments. It looks like the plan
is close to complete, and I'm excited about the possibilities at this site.
Warm regards,
Tammy
Tammy Hill
Environmental Senior Specialist
NC Division of Water Quality (401/Wetlands)
2321 Crabtree Blvd., Suite 250
I of 4 12/5/2007 9:57 AM
Re: Stone Farm Bank

Raleigh, NC 27604
919-715-9052 (voice)
919-733-6893 (fax)
[e-mail]
[e-mail] wrote:
Mickey,
I have finished reviewing the MBI for Stone Farm Bank, along with Land
Management Group's November 13, 2007 information. Please note my comments
below.
MBI Page 2, Section 2.2: The word "of" in the second line should be changed to
"or." Also, in the third line, the MBI should refer to 11404(b)(1) Guidelines."
MBI Page 4, Table 1: The mitigation credit ratio and number of credits in the
table should be revised to reflect a 10:1 ratio for preservation. I agree with
your previous email regarding the ratio. As you know, most of the justifications
given by LMG for a lower ratio are similar to the justifications that EPA uses to
allow for the use of preservation at all.
MBI Page 7: It would be helpful to have a map of the Geographic Service Area in
the MBI. Also, in the footnote, the MBI states that the "Bank may be suitable
for ... wetland impacts occurring anywhere within the same 8-digit hydrologic
unit (03030005 - Lower Cape Fear)." However, this project is not in or near the
Lower Cape Fear watershed. I would be agreeable to replacing 1103030005 - Lower
Cape Fear" with "03040207 - Coastal Carolina Unit of the Lumber."
MBI Page 8, Section 4.3: On the second line, change "EPA guidance" to "Joint
Agency guidance." Also, on line 3, change "then" to "the."
MBI Page 10, Table 3: This only provides a credit release schedule for
wetlands. A credit release schedule should be provided for the stream credits
also. The sponsor should coordinate with the Corps to determine what the
schedule should be.
I believe the language in Exhibit B (Addendum to mitigation plan) is acceptable.
I agree that the stream flow and macrobenthos monitoring, coupled with the
monitoring of bankful events, should be sufficient to document flow and/or
stream function.
LMG should incorporate Exhibit B (Addendum to mitigation plan) into the
mitigation plan and send out a final mitigation plan document. Or, to save
paper, LMG could send the agencies a loose copy of Exhibit B (not attached to
the MBI), so that we can incorporate it into the mitigaiton plan document
ourselves. It will be much less confusing for everyone in the future if we have
a complete and final plan to which to refer.
Thanks,
Kathy Matthews
USEPA - Region 4 Wetlands Section
109 T.W. Alexander Dr.
Durham, NC 27711
MAIL CODE: E143-04
phone [phone]
cell 919-619-7319
"I will not compare the [Rapanos] "decision" to making sausage because it would
excessively demean sausage makers." Robert B. Propst, Senior United States
District Judge
*"Sugg, Mickey T SAW" <[e-mail]>*
2 of 4 12/5/2007 9:57 AM
Re: Stone Farm Bank
.-
11/26/2007 08:41 AM
To
Kathy Matthews/RTP/USEPA/US@EPA, "Tammy Hill" <[e-mail]>,
"smtp-Sechler, Ron" <[e-mail]>, <howard [e-mail]>,
<[e-mail]>
cc
<[e-mail]>, "Brent Manning" <[e-mail]>
Subject
RE: Stone Farm Bank
Morning-
With the message below, I forgot to discuss the preservation issue. In reviewing
my earlier notes, I found where I requested a detailed description of the
preservation area so the team could make a good decision on what the ratios for
those areas should be. However, in discussing this with Brent last week, he
stated that the site was such a mixed baggage that it was difficult to do this.
I agree with Kathy that 5:1 is probably to low since a lot of the area has been
managed and there is a large component of loblolly pine and sweet gum. I don't
have a problem with 10:1, but I think that the ratio could be lowered if some of
the more desirable communities within the preservation area are mapped out with
more specific descriptions, or if a functional assessment is conducted (NCWAM).
For now, we can leave it at 10:1 and let it be the banker's choice if they
desire lower ratios.
Good week to ya',
-Mickey
*From:* Sugg, Mickey T SAW *
Sent:* Wednesday, November 21, 2007 12:38 PM*
To:* [e-mail]; 'Tammy Hill'; smtp-Sechler, Ron;
howard [e-mail]; [e-mail]*
Cc:* [e-mail]; Brent Manning*
Subject:* Stone Farm Bank
Morning-
It is my understanding that each of you should have received additional
information (copy of the MBI and an addendum to the plan) from Land Management
Group (LMG) regarding some of the questions raised for this bank, specifically
regarding the stream component (Kathy and Tammy). LMG addressed most of the
comments and included them in the addendum. They are proposing to monitor
bankfull events and tie them to the standard success criteria, which I think we
all concur. However, the big question is establishing flow. There is no success
criteria set for flow that I know of for any mitigation sites in NC. I don't
know of any literature that establishes a time period, whether consecutive
days/months or a total time period/year, to classify a waterbody as a stream.
When inspecting a property and determining if a waterbody is a stream, we
generally use ordinary high water marks, wrack lines, presence of benthos,
mapping tools (Lidar), DWQ stream assessment etc... to help determine the presence
(frequency/duration) of flows. But this is almost always for well established
tributaries that have been in place for decades. I think we can use LMG's level
of monitoring (photo-documentation, benthos, stream surveys, stream flow
monitoring) to give us a good idea of documenting the flow. With the bankfull
well data, stream gauge data, and velocity measurement, they can use the USGS
3 of 4 12/5/2007 9:57 AM
Re: Stone Farm Bank

methodology to extrapolate flow and to determine what the rate of discharge
(cfs) will be. By calculating the cfs, it should be simple to establish the
number of flow events that may occur within the channel. I think as a team we
could determine if the measurements are valid enough to release stream credits.
At this time, I recommend just keeping the bankfull event as the success
criteria, and use the other information as a tool to determine the health of the
stream.
Just some thoughts. Please read through the addendum and let me know if you
agree with what they are proposing, and if using only the standard bankfull
event as the success criteria is okay.
Have a great Thanksgiving,
-Mickey
4 of 4 12/5/2007 9:57 AM