20111044_NCDOT Div 9-14 Monitoring Report Comments for 2016-Final_20170306

Water Resources
ENVIPONMENTAI �VPLITY
Mr. Randv Griffin
NC Department of Transportation
Project Development and Environmental Analysis
1548 MSC
Raleigh, NC 276°9-1548
ROY COOPER
Gnvrrnnr
MICHAEL S. RECAN
.SPClP(Qf��
S. JAY ZIMMERMAN
Otmc�or
March C6, 2017
Subject: NC Division of Water Resources comments on the N� Department of Transportation Annual
2016 Mon�torirg Reports for Divisions 3-14.
Dear Mr. Griffin:
The following review comments are for the NC DOT annual monitoring reports submitted to NC DWR as
per requirements of the permit conditions associated with each TIP. Thank you for your timely submittal
of the monitoring reports. Review comments were generated from review of the monitor plans as well
as site permit files, site inspections, and any other site specific meetings or communication. All site
specific comments are listed below.
Mitigatior sites have bee� ebserved to be r,�issin� signage (ofter alor.g the back side a�4ay from the
road) as wzs discussed in ±he DecemSer 19, 2016 !etter to DO? regarding on-site mitigation. Signag� is
needed to demarcate and ensure better protection of the conservation easement and mitigated natural
resource permiited by DWR to offset the transportation project impacts. Appropriaie signage is required
for sites proposed fur doseoui in 2017 ar�d future years.
The addition ef th= mitigation retio to most monitoring reports as requested last yezr was noted. DWR
suggests putting the ledger in table formai and including all relative information related to micigation
type, size, and crediting for the mitigation site (see below) for consistency.
Title i�fo - site name, TIP, 8 digit HUC
Mitigat'son Type
(Stream [warm/cool/cold) OR Wetland [Ncn-Riverine Riparian, Riverine Riparian, Non-
Riparian] OR Bufierj
Size (as-built size)
Mitigation Method (Restoration, Relocation, Enhancement, EI, EII, Preservation,
Creation)
Mitigation Ratio
Credits Generated
Credit Adjustments I.if apphcable)
Total Site Credits
Credits DeoitNd on Curr=nt Proiect
�Nothing Compares,..`
StareofNorthCarolina I EnvironmentalQuality I Water Resources
5¢ N. Salisbury 5treet I 1611 MailService Cen[er I Raleigh, NC27699-i611
9I9.707.4000

Credits Debited on Other Projects and which projects
Credits Remaining
It was noted in some of the monitoring reports that <180 days had passed between planting and the
first monitoring event. Please be reminded that the 2003 Guidance requires five years of monitoring and
the ACOE 2013 Compensatory Mitigation Site Update requires "vegetation to be in the ground for at
least 130 days prior to the initiation of the first year of monitorin�'. Sites that are monitored just three
months after planting will result in only 4 years and 3 months of monitoring.
In regards to crediting for future projects, it should a!so be noted that Enhancement Level II stream
(typically cattle removal, vegetation planting in the buffer, occasionally minor bank work or a structure
addition) and Enhancement Level I projects (typically some bank improvement or addition of structures
or both and planting of the buffer} have been generelly credited differently for DMS and bankers; EII at
2.5:1 and EI at 1.5:1. Projeds that have very minimal improvements proposed (e.g. solely live staking the
bank and removal of exotia) have also received 5:1 for EII. DWR would like to see more consistent
crediting for future DOT projects in regards to identifying the difference between sites that are
Enhancement I and Enhancement II and not lumping all stream enhancement into one category of
enhancement at 2:1. Additionally, DWR does not see the need for cross section monitoring for EII sites
that had no bank work done (see Division 12 comments) a�d would be open to this being removed from
projects that have a mitigation plan already approved. Any proposed changes to approved mitigatian
plans should be reviewed by all agencies for consensus first.
Please contad the DWR NCDOT Mitigation Coordinator, Ginny Baker at 919-707-8788 with any concerns
or questions regarding site comments or these can be discussed at the upcoming DOT Division 9-14
annual Mitigation Monitoring Report meeting.
Sinr.erely,
Amy Chapman, DWR Transportation Permitting Branch Supervisor
amv.chaqman@ncdenr.�ov, 919-707-8784
DIVISION 9
Yadkin River (TIP I-2304A, DWR# 20040275) - DWR has no significant concerns with the Yadkin River
site although it was noted during the site visit that there were some bare areas and planted trees were
not nearly as vigorous in the SW and higher elevation side of the site. Overell the site appears to be
meeting success criteria. Please continue monitoring.
DIVISION 12
UT to Pourth Creek ([I-40 — I-77 Interchange] TIP 1-3819A, DWRii 20113044) — The October 2016 site
visit showed that signage is needed on the entire back side and there have been issues with trespassing
as indicated by three sets of vehicle tracks. If the restoretive measures for UT to Fourth Creek were
solely planting of the buffer and removal of cattle with no bank work (essentially EII) then DWR does not
believe it is necessary to continue the cross-section monitoring and would recommend dis�ontinuing.
During the site visit it was observed the northern half of the UT to Fourth Creek is already heavily
�Nothing Compares�.�.
StateofNorthCaroGna I FnvironmenralQualrty I Water Resources
5R N. Salisbwy StreM � 16II Mail Service Crn[er � Raleigh, NC 2 769 9-1611
919.707.9000

forested. Has this area been planted according to the planting plan in the report? Assuming the planting
plan was followed, please also incl��de a vegetation monitoring plot in this area. Vegetation monitoring
should be continued and supplemental planting pursued as is proposed. The mitigation olan dated
February 15, 2012, says macroinvertebrate monitoring was to be do�e but this is not included in the
monitoring report. For Section 2.1, vegetation success, remove "restorative wetlands" in the first
sentence as this does not apply to this projeM. Has it been determined if this site will be impacted
during Phase II? ?lease continue monitoring
DIVISION 13
Crooked Creek and Middle Fork Creek (TIV B-4183, DWR#020130060) — Signage is needed. The site
appeared stable and to be meeting performance criteria based on monitoring reports and a DWR
December 2016 site visit. Please schedule a site visit for closeoui review.
Jacktown Creek (TIP B�191, DWR# 20040385) - It appears a lot of water and sediment has been
moving through the channel which has caused widening, bank sluffing, and down cutting. The
crossvanes have mostly been buried. Repairs were proposed for 2016 at Station 12+50 and discussed at
the 2015 monitoring report meeting but these were not mentioned in the 2016 monitoring report. Will
these be done and have the bank pins at 12+50 been reviewed recently? The buffer vegetation and
signage looked good. Please schedule a site visit to review these concerns in the field.
U519 Improvement sites, DWR� 20071134
DWR understands that there was to be a 50% credit reduction for new utility lines that were proposed in
2014 and presented at a meeting in Asheville. Please see the attached table and drewings for
restoretionjrelocation Sites C, E, F, J and N. These sites generated existing utility stream impacts with
the original pre-restored/relocated stream channel pattern rather than us�ng the restored/relocated
stream channel pattern. Since the original stream c�edits for each scream were based on the length of
the restored stream and there wEre �ot cred',t rzd�ctions applied to existing uiilities in 2007 the� the
change in credit value due moving utility lines should be based on the restored/relocated stream
channel pattern, not the original steam channel pattern.
DWR would like to request a single table be compiled for with the following information for DWRit
200711134:
TIP
Site Name
Mitigation Type(s) at Site
restoretion/relocation/restoretion, Enhancement, Preservation
mitigation ratio per mitigation type
credits ratio for each mitigation type
credit earned
credit adjustments - notation on credit adjustment due to relocation of utilities.
Please as provide this information for sites scheduled to be closed out in 2017 {R2518A and R2518B) and
any other U519 sites that as-built information is available for.
TIP R-2518A, DWR# 20071134
Baily Brench Site D— Comments for December 2016 letter. The upper section along Lower Bailey Brench
Rd has a two-foot drop that could prohibit aquatic passage, otherwise the site appears to have a stable
�Nothing Compares�
StateofNotthCarolina I FnvironmentalQualtty I Water Resources
SR N. Salisbwy 5treet � 1611 Mail 5ervice Center � Ralegh NC 2 76 9 9-1611
919.707.9000

stream with established vegetation. Please explain the discrepancies in the debit ledgers, MY1-MYS —
say'The Bailey Branch Site D stream mitigation site did not receive credit due to the site being
purchased as a Permanent Drainage Easement (PDE�:' MY6-MY7 —"The entire 82 linear feet of Bailey
Brench Site D stream mitigation site located within NCDOT's right-of-way was used for the R-2518A
project to compensate for unavoidable stream impacts".
Holland Creek Site M- The site appeared stable and to be meeting performance criteria based or
monitoring reports and a DWR December 2016 site visit. Please schedule a site visit for closeout review.
ivy Gap Branch Site N— Additional signage is needed along US19 and the back side. Bank erosion was
noted during a DWR site visit in December 2016. The vegetation appears successful although DWR does
have some conc�rns with the stream bank area at bank pin 4 and would like to review the other three
bank pin areas tnat were monitored at the closeout site visit.
Middle Fork Creek Site A- Signage is needed along the preservation section, back side of the section by
Beech Glen Road and all of the smatl upper piece on the SE side of US 19. The site appeared stable and
to be meeting performance criteria based on monitoring reports and a DWR December 2010 site visit.
Please schedule a site visit for closeout.
Middle Fork Creek Site E- The site appeared stable and to be meeting performance criteria based on
monitoring reports and DWR site visit in Dec 2016. Please schedule a site visit for closeout review.
Middle Fork Creek Site I— It was noted during a DWR field visit to Middle Fork Creek Site I that there is
bank stabilization also at the bend just downstream of PP#4 (the lowest full outer bend) which DWR
recommends also be reviewed for potential repairs since repairs are already planned. What is the time
schedule for planning and executing stream bank remediation to Middle Fark �reek Site I? What future
manitu� ing is planned ;�r this si±e? P�ease verify if the mowed path observed along the right buffer
(west buffer) was the area that was treated for Lezpedeza in 2014, ar was thi� a rnore recent
encroachment? 1"his area did not appear to be planted. Please include Middle Fork Creek Site I in the
field visit schedule during the closeouts for the other US-19 Improvement sites.
Preservation Sites —See above comments on signage. DWR has no further cornments on the monitoring
report, please schedule a site visit for closeout review.
Turkey Branch Site J— Comments from the December 2016 letter - The site has been encroached along
the right buffer, fencing and signage and some replanting is needed. Additionally, the stream feature
had some charecteristics of a linear wetland. Please schedule a site visit for closeout review contingent
on the above items being addressed.
UT to Middle Fork Creek Ske B- The site appeared stable and to be meeting performance criteria based
on monitoring reports and a DWR site visit in Dec 2016. Please schedule a site visit for closeout review.
UT to Middle Fark Creek Site C- Please see the above comments on credit adjustment error. The site
appeared stable and to be meeting performance criteria based on monitoring reports and a DWR site
visit in Dec 2016. Please schedule a site visit for closeout review.
UT to Middle Fork Creek Site F- Comments from the December 2016 letter - The plan sheet indicates
this channel starts at the fence line. In the feld, the channel piantings and signage start at the stakes
�Nothing Compares�_
StareofNorthCarolina I FnvironmenralQuality I Water Resources
SRN.Salisbwy5treet � 16llMailServiceCenter � RaleghNC27699-1611
919.707.9000

about 30 to 40 feet lower down. Please check this discrepancy and correct the plansheet and stream
footage as necessary prior to closeout review.
TIP R-2518B, DWR# 20071134
Bald Creek Site 1- Comments from the December 2016 letter - The back side of this site needs to be
signed. The site appeared stable and to be meeting performance criteria based on monitoring reports
and DWR site visit in Dec 2016. Please schedule a site visit for closeout review.
eald Creek Site 3—There is some minor fence damage from mowers, additionally the back side needs
signage. The site appeared stable and to be meeting performance criteria based on monitoring reports
and a DWR site visit in Dec 2016. Please schedule a site visit for closeout review.
Bald Creek Site 4— Have there been any other issues with beaver noted in 2016? What is the current
situation with Mt Pleasant Baptist church that had requested a Seledive Vegetation Removal (which
DOT denied) so their sign could be seen as was discussed at the 2015 monitoring report meeting? DWR
would like to ensure there will not be issues with encroachment after closeout. The site appeared
stable and to be meeting performance criteria based on a DWR site visit in Dec 2016 and monitoring
reports. Please schedule a site visit for closeout review.
Bald Creek Site 8- Comments from the December 2016 letter, the back side of site needs signage. The
2016 Monitoring Report figure for XSS does not show the 2016 results that are shown in the table
associated with the Figure, XS Area changed from 29.13 to 4338 sq ft after repairs. The site appeared
stable and to be meeting performance criteria based on monitoring reports and DWR site visit in Dec
2016. Please schedule a site visit for closeout review. DWR would like to review the repaired area prior
to closeout.
Phipps Creek Site 11- The site appeared stable and to be meeting performance criteria based on
monitoring reports and DWR site visit in Dec 2016. Please schedule a site visit for closeout review.
U7 to Bald Creek Hydro Site (Site 7) - Comments from the December 2016 letter - There is a headcut
approximately 30 feet below the top of the channel. Below the headcut the channel spreads out and
turns into a linear wetland with no bed and bank and a predominance of herbaceous vegetation
including cattail. Please schedule a site visit for closeout review.
UT to Cane River Site 12 —Comments from the December 2016 letter - The left buffer has a flatbed
trailer and hay bales parked inside the easement. This section of the easement should be fenced and
signed as it has been encroached in the past (pallets were inside the easement during the last field
review in 2014). The planting plan indicates both the right and left buffer were planted but field
observations indicated the upper part of the left buffer where the encroachment was noted has not
been planted nor does it appear plantings were ever done along the right buffer which was already
forested. Please schedule a site visit, the aforementioned concerns will need to be addressed prior to
closeout. Please note that during a 2014 field review visit there were also issues with encroachment
from the adjacent landowner. DWR recommends fencing the entire left buffer to avoid these re-
occurring issues with encroachment.
�Nothing Compares�
State of North Carolina I EnNronmenWl Quallty � Water Resources
SRN.SalisburyStreM I 1611Mail5erviceCenter I RaleighNC27699-16t1
919.707.9000

TIP R-2519A, DWR# 20071134
Georges Fork Site 26 - Comments from the December 2016 letter - Plantings and signage are needed.
The stream was unstable in sections where the structures appear to be in the wrong location for the
channel geomorphology. Bank erosion and undercutting is occurring. Are repairs planned for station
486+00 noted in the monitoring report? DWR would recommend using a bank pin to monitor this area.
Has the control access fence been extended to avoid the encroachments discussed during the 2015
monitoring report meeting? Please continue monitoring.
Plum Branch Site 33 - Comments from the December 2016 letter - The stream is stable. Vegetation is
sparse, some dead livestakes noted, supplemental planting should be considered. Please continue
monitoring.
Plum Branch Tributary Site 32 - Comments from the December 2016 letter - The culvert is perched and
has caused sediment and algae build-up. Very few trees were noted. Will the reforestation planned for
2017 be done throughout the site? DWR recommends resetting the clock on Plum Brench Tributary.
Please continue monitoring and include a site visit during the 2016 closeouts of the other US19
mitigation sites.
Shoal Creek Site 29 - Comments from the December 2016 letter - The stream appears stable, planted
trees noted, some additional livestakes could be helpful. Please continue monitoring.
East Prong Hunting Creek (TIP U-25506, DWRp 20103017) —Please list the stream footage restored at
1:1 for Site 3 and Site 4 in the debit ledger. Is the lower part of East Prong Horn at Site 3, that is not
being credited, still within a conservation easement? Please show the entire conservation easement on
the site map and indicate the sections that are credited and non-credited. What percent of the site is
receiving supplemental planting? DWR may want to recommend additional monitoring since this site
was only to be monitored for 3 years. In addition, it was noted in this report that the site was planted in
March 2015 then monitored in June 2015. Please see above comments related to monitoring length.
DIVISION 14
West Fork Pigeon River (TIP 8-3187) - No site specific comments, please keep monitoring
UT's to Hominy Creek (TIP I-5402, DWR# 20120309) —Please correct the •equation (change 106/2=80 to
160/2=80) in the Debit Table. At the 2015 monitoring meeting, putting the results of the benthic
monitoring, as proposed the Mitigation Plan with "no success criteria required", in the monitoring
report for 2016 was discussed (see 2015 meeting minutes for Division 9-14), but these results were not
in the plan. Was the monitoring done and can it be added as an addendum or put in the 2017 plan?
�Nothing Compares�
StareofNorthCarolina I EnvironmentalQualiry I Wattt Resources
SRN.Salisbury5treet I 16llMailServiceCenter I Raleigh.NC27699-1611
919707.9000

If you have any questions, please contact Virginia Baker at [phone] or [e-mail].
Sincerely,
�.��n.�,-�'�,
S. ay Zimmerman, Director
Division of Water Resources
CC: Virginia Baker, NC Division of Water Resources
Dave Wanucha, NC Division of Water Resources, Mooresville Regional Office
Donna Hood, NC Division of Water Resources, Winston-Salem Regional Office
Kevin Barnett, NC Division of Water Resources, Asheville Regional Office
Crystal Amschler, US Army Corps of Engineers
Steve Kichefski, US Army Corps of Engineers
Lori Beckwith, US Army Corps of Engineers
Andy Williams, US Army Corps of Engineers
Monte Matthews, US Army Corps of Engineers
Todd Bowers, Environmental Protection Agency
Marla Chambers, NC Wildlife Resources Commission
Marella Buncick, US Fish and Wildlife Service
Amy Euliss, NCDOT Division 9 Environmental Officer
Trish Beam, NCDOT Division 12 Environmental Supervisor
Roger Bryan, NCDOT Division 13 Environmental Supervisor
David McHenry, NCDOT Division 14 Environmental Supervisor
lason Elliott, NCDOT, Natural Environment Engineering Group
Byron Moore, NCDOT, Project Development and Environmental Analysis
Matthew Green, NCDOT, Roadside Environmental Unit
-' �'Nothing Compares -��.
$Ieh�oiNorthCarolina I ['nviraunentolQuality I Warer Npsuurces
SI2N.SalisburySlrect i 161!MaIlSerimCenter f Rald�h,NC27619-toll
HI2"i0'7'1p00