20141149 Ver 1_DWR Octobank comments to USACE_20161206

Strickland, Bev
From:Homewood, Sue
Sent:Tuesday, December 06, 2016 2:34 PM
To:Bailey, David E SAW
Subject:FW: Octobank comments
David,

I am forwarding Mac’s comments below with the understanding that at this stage in the process some of the comments
may not be addressed with the sponsor.

I have the following comments:

As previously noted in the Division’s comments on May 12, 2016:
Surface water gauges should be installed in the upper reach of UT2 at the Benton Branch site
Throughout the mitigation plans some channels have been identified as perennial streams, however there is no
evidence or documentation that either the USACE or DWR have classified the channels as such.

Thanks,

Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality

336 776 9693 office
336 813 1863 mobile
[e-mail]

450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Haupt, Mac
Sent: Monday, December 05, 2016 3:45 PM
To: Homewood, Sue <[e-mail]>
Subject: Octobank comments

Sue,

Below are my comments:

Rocky Top Site
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1.It was beneficial seeing the NCSAM and NCWAM ratings for the site, we should push for the Quant Tool

utilization in the future as well.
2.Since the site proposes to raise the stream bed I would also put a couple of gauges in the wetland enhancement

areas (a. to document increased hydro and overbank, b. document that the channel is not draining the wetland)
3.Section 6.1.3 states that the Goldston (non-hydric) is underlain by a hydric layer (Worsham). At what depth

does the Worsham occur and does the profile fit the series description?
4.Assuming Marsh treatment areas will not be maintained except through the monitoring period. Afterward they

are expected to fill with sediment, organic matter and vegetation…
5.The growing season of March 1- Oct. 22 is acceptable

6.The wetland hydroperiod of 10% is acceptable

7.Figure 10 does not show any stream monitoring cross-sections

8.Section 11.1.1-Stream Success Criteria states that, “…success will be based on evaluations of functional lift

identified on NCSAM calculations.” It was not the purpose or application to apply NCSAM metrics at the end of
the mitigation monitoring period, rather it is the purpose of the Stream Pyramid Quantification Tool which
should be utilized to document functional uplift.
9.Terracell-my experience with these is that they can tear up pretty easily. I wonder why they are not stepping

down with cross vanes (costs, I guess). In general, I would inform them that these will be watched very closely
and that perhaps some language should be inserted in Contingency Plan Section for streams relating to these
structures.

Motes Creek Site
1.It is interesting that UT1 rates out as high in NCSAM. They may want to talk about how this reach qualifies for

the credit of EI vs EII.
2.I would recommend a couple of gauges in the wetland enhancement area.

3.The growing season of March 1- Oct. 22 is acceptable

4.The wetland hydroperiod of 10% is acceptable

5.Stream success criteria- see comment #7 for Rocky Top site.

6.Figure 10 shows a lot of cross sections…I would get rid a few of these and use the $$$ for few more wetland

groundwater gauges.
7.Terracells- see #9 Rocky Top

Benton Branch
1.The growing season of March 1- Oct. 22 is acceptable

2.The wetland hydroperiod of 10% is acceptable

3.Again, Figure 10A and B showing a lot of cross sections

4.Stream success criteria- see comment #7 for Rocky Top site.

5.I would recommend a couple of gauges in the wetland enhancement area.

6.I would put a veg plot in each of the filled ponds.

7.Also, they have two gauges proposed in two of the filled ponds; I would put two gauges in the other one as well.

8.Terracells- see #9 Rocky Top

Orphan Creek
1.Wetland areas should have gauges based on my comments above (Rocky Top site), guess I won’t hold them to

10% but we probably should state that if these gauges don’t show significant wetland hydrology, then the credit
may be reduced accordingly.
2.Terracells- see #9 Rocky Top

3.Again, a lot of cross sections

I will be in the IRT meeting for most of tomorrow. But if you have any questions or concerns I can talk Wednesday.

Thanks,

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Mac Haupt, LSS
Stream & Wetland Mitigation Coordinator
401 & Buffer Permitting Branch
Division of Water Resources
Department of Environmental Quality

919 807-6476 office
[e-mail]

512 N. Salisbury Street, Suite 942-K, Raleigh, NC 27604
1617 Mail Service Center
Raleigh, NC 27699-1617

Email correspondence to and from this address is subject to the

North Carolina Public Records Law and may be disclosed to third parties

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