20080833 Ver 1_Staff Comments_20080626

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June 26, 2008
Mr. Salam Murtada
N.C. Ecosystem Enhancement Program.
1619 Mail Service Center
Raleigh, NC 27699-1619
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
Re: Fletcher-Meritor Site - UT to Cane Creek (DWQ #08-0833)
Henderson County
Dear. Mr. Murtada:
The Division of Water Quality (DWQ) 401 Oversight and Express Review Permitting Unit has reviewed
the HEIR Memorandum which was prepared to address comments from both DWQ and the U.S.
Environmental Protection Agency relating to the proposed restoration site.
The response memorandum addresses the items requested in our letter dated June 13, 2008. The only
other item we would offer is the proposed success criteria of 5%. This is an issue that the DWQ has
identified as an area of discussion for the PACG-TC. A 5% hydrology criteria is considered
jurisdictional, but whether it is an appropriate hydrology target for a riparian wetland is a matter that is
up for discussion. Generally, 5% hydrology criteria is probably more applicable to non-riparian system
(e.g. pine flats or pocosins). Comparison with a reference wetland would provide usable data on the
success of the restored wetland in terms of achieving appropriate target wetland characteristics.
Of additional concern is the comments by USACE questioning whether the site has ever supported
jurisdictional wetlands. The soil boring data provided appeared inconclusive. We concur with the
USACE that the proposed work may be considered creation.
That said, DWQ deems the project issued, with the note that the proposed restoration is considered "at
risk", with the realization that restoration credit may not be awarded. Furthermore, specific comparison
with reference conditions will likely be required to deem the site successful at the end of the monitoring
period.
One
NhCarolina
Agam Iff
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/ncwetlands
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper
Mr. Murtada
N.C. Ecosystem Enhancement Program
Fletcher-Meritor Site - UT to Cane Creek
Page 2 of 2
Please feel free to contact Eric Kulz or Tammy Hill at [phone] if you have any questions
regarding this project or our comments.
Sin ely
Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
cc: File Copy (Eric Kulz)
Central Files
Kevin Barnett - DWQ ARO
Amanda Jones - USACE Asheville Regulatory Field Office
NOS thCarolina
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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/ncwetlands
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper