20080913 Ver 1_Staff Comments_20080717

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July 17, 2008
Mr. Salam Murtada
N.C. Ecosystem Enhancement Program.
1619 Mail Service Center
Raleigh, NC 27699-1619
Re: Mill Creek Restoration Site
Randolph County
DWQ #08-0913
Dear. Mr. Murtada:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H Sullins, Director
Division of Water Quality
The Division of Water Quality (DWQ) 401 Oversight and Express Review Permitting Unit has reviewed
the response to our June 26, 2008 comment letter regarding the above-referenced project. We agree
about the importance of including ephemeral and intermittent reaches as part of watershed restoration
projects, and are quite excited about the overall approach taken on this project and the potential for
improvement of water quality downstream.
However, DWQ does not agree with the designer's response regarding the use of a restored stream as a
reference for the project. While a five-year monitoring period is currently used to evaluate stream
mitigation projects, DWQ does not feel that this is an adequate amount of time to demonstrate that a
restored stream is functioning in a manner approaching a natural (or reference) stream, both
geomorphologically and ecologically. DWQ strongly disagrees with the suggestion that a five-year old
restored stream is "better" than a natural reference stream. In reviewing the longitudinal profiles and
photographs of Mickey Reach, it appears that a considerable amount of structures were used to construct
this project, and likely accounts for the stability.
If Mickey Reach is considered successful, and was designed based on Craig Creek, why would Craig
Creek not represent a suitable reference reach for Mill Creek?
Additionally, the reference reach is located in the mountain ecoregion, while the proposed restoration
reach is located in the Carolina Slate Belt (Piedmont). DWQ realizes that the valley types may be
similar since the restoration reach appears to be within the Uwharries, and the pre-restoration Mill Creek
reach is described as a cobble-bed stream. Given these similarities, a reference in the foothills or
mountains may be appropriate, as long as slopes, geology and soil characteristics are also considered.
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / Fax [phone]
Internet: htta://h2o.enr.state.nc.us/ncwetlands
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Mr. Murtada
N.C. Ecosystem Enhancement Program
Mill Creek Restoration Project
Page 2 of 2
In summary, DWQ does not feel it is appropriate to use a restored stream as a reference for a restoration
project at this time. Once we have a larger population of restoration projects deemed successful after a
longer time frame (e.g. 15+ years), it may be appropriate to use a carefully-selected restored stream as a
reference. Please revise the proposed plan, using a natural stream with an appropriate valley type,
watershed size and comparable stream order as a reference.
We look forward to your response to the comments listed above, and would like to resolve this issue in
order to approve this most-worthwhile restoration project. Please feel free to contact Eric Kulz at (919)
733-1786 if you have any questions regarding this project or our comments.
Sinc ely
I Cyndi B.
Karoly, Program Manager
401 Oversight and Express Review Program
cc: File Copy (Eric Kulz)
Central Files
Sue Homewood - DWQ WSRO
Jean Manuele - USACE Raleigh Regulatory Field Office
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / Fax [phone]
Internet: http://h2o.enr.state.nc.us/ncwetiands
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NhCarolina
Na mrally
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper