20021794 Ver 1_Monitoring Report Review_20080805

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August 5, 2008
Mr. Bill Biddlecome
Washington Regulatory Field Office
U.S. Army Corps of Engineers
P.O. Box 1000
Washington, NC 27889-1000
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: Neu-Con Wetland/Stream Umbrella Mitigation Bank
Comments on Monitoring Reports and Proposed Bank Additions
Dear. Mr. Biddlecome:
The Division of Water Quality (DWQ) 401 Oversight and Express Review Permitting Unit has reviewed
the monitoring reports for the five Neu-Con sites that are currently in monitoring, as well as the
Executive Summaries for the proposed additions to the bank.
One general comment is that in future reports, DWQ requests to see monitoring results for all years in
tabular and/or graphical format, as appropriate, to allow evaluation of trends over time. Some of the
Neu-Con project reports already include this data.
Our comments on specific sites are as follows:
Westbrook Lowgrounds - Johnston County (DWQ #02-0569)
Stream Restoration
The physical stream monitoring data appear to indicate that the stream has met applicable
success criteria, despite undercutting of two log vanes and shifting of one of the rock cross
vanes. Riparian vegetation appears to have met success criteria of 260 stems per acre at the end
of year 5. Bankfull events have been documented.
DWQ would like to conduct a site inspection prior to closeout of the stream portion of the
project.
Wetland Restoration
Hydrology results have been variable at the site. In general, except for 2006 results, the
restoration hydroperiod was significantly lower than that of the reference. Four of eight wells
met the success criteria of continual saturation during 9% of the growing season during most
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: h_t_tp://h2o.enr.state.nc.us/ncwetiands
Noce h Carolina
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Mr. Biddlecome
U.S. Army Corps of Engineers
Neu-Con Wetland/Stream Mitigation Bank - DWQ Comments
Page 2
years. If the project Sponsor would like to close the project at this time, a substantial area will
need to be removed from mitigation credit. Based on monitoring data, the area around Well AW
1 is not a jurisdictional wetland. The MBRT can decide on a process for determining the final
mitigation area available for credit, or the project Sponsor can submit an adaptive management
plan for review and continue monitoring site conditions.
Vegetation success criteria have been met at all sampling plots through Year 5.
Nahunta - Wayne County (DWQ #04-0895)
Stream Restoration
• The physical stream monitoring data appear to indicate that the stream has met applicable
success criteria to date. Repairs were conducted on Tapp Reach 3 due to a sediment deposit that
apparently resulted in some erosion. Riparian vegetation appears to have met the success criteria
of 320 stems per acre in year 3. Bankfull events were recorded for all reaches.
• The habitat scores were extremely low for all of the restoration reaches evaluated, which is
discouraging considering the site has completed its third year of monitoring. Comparison to the
reference reach appears to show that the restored streams are not developing suitable
macrobenthos habitats. DWQ requests that the Sponsor provide an interpretation of the data, and
potential reasons why the habitat scores are consistently low between all of the restoration
reaches.
• DWQ has concerns regarding the macrobenthos monitoring being conducted at this site. The
occurrence of Heptagenia spp.in Gonder Reach 6 appears unlikely, as this is normally a
mountain/piedmont species, and is usually found in the presence of other Heptageniid mayflies.
The data from the reference reach did not include any midges. We find this very unlikely, as
midges are generally ubiquitous and are fairly abundant in most aquatic environments.
• DWQ requests that biotic index values be calculated for each of the restoration reaches, as well
as for the reference reach. Such values will allow for comparison of the data over time, and may
show trends (positive or negative) in the development of macrobenthos communities. Future
sampling data should be compiled with this years data in subsequent monitoring reports to allow
for comparison of the data over time.
Wetland Restoration
• Nearly all of the monitoring wells failed to meet either a hydroperiod of 12.5% of the growing
season or comparison with reference hydrology during 2007. Given the extreme drought that
occurred during this growing season, future hydrology data will be necessary to fully evaluate
Noe Carolina
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: htto://h2o.enr.state.nc.us/ncwetlands
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper
Mr. Biddlecome
U.S. Army Corps of Engineers
Neu-Con Wetland/Stream Mitigation Bank - DWQ Comments
Page 3
the success of the project. At this time, DWQ agrees with the monitoring report conclusion that
the site's hydrology results are inconclusive.
Marston - Jones County (DWQ #03-1035)
Stream Restoration
• The physical stream monitoring data appear to indicate that the stream has met applicable
success criteria to date. The beaver dam should be removed. Riparian vegetation appears to be
on target to meet the success criterion of 260 stems per acre at the end of year 5.. Four bankfull
events were recorded.
• Macrobenthos monitoring results were not available at the time the monitoring report was
completed. These data will be reviewed when provided. The Sponsor is requested to provide the
data and analyses outlined in the comments on the Nahunta site (habitat scores, biotic index
values, etc.).
Wetland Restoration
• 50% of the monitoring wells did not meet approved success criteria. A reference well was
installed and began generating data on April 24, 2007, over a month after the start of the growing
season. Conclusions for the entire growing season cannot be based on this reference since it
missed the early part of the season during which the longest periods of saturation had already
been recorded in the monitoring wells. The 2007 drought impacted many mitigation projects in
North Carolina, and all five years of monitoring data will be considered during closeout
decision-making after 2008.
• The report noted that beavers have reduced the number of cypress trees along the upper reach of
the project. The project sponsor should comment on the need for a remediation plan to address
the beaver activity and the loss of trees.
Alexander - Greene County (DWQ #02-1794)
Wetland Restoration
• After the completion of five years of monitoring in 2007, the project Sponsor has requested to be
released from further monitoring requirements at this site. All approved success criteria for
wetland hydrology and vegetation have been met at all monitoring points. DWQ would like to
perform an on-site evaluation of the project prior to making a final decision about the release of
the site
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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
Mr. Biddlecome
U.S. Army Corps of Engineers
Neu-Con Wetland/Stream Mitigation Bank - DWQ Comments
Page 4
Casey-King - Lenoir County (DWQ #01-1644)
Wetland Restoration
• This project was released from further hydrologic monitoring after review of the 2006 (Year 5)
monitoring results. Vegetation monitoring continued through the 2007 growing season, during
which all plots met approved success criteria. DWQ would like to perform an on-site evaluation
of the project prior to making a final decision about the release of the site.
Proposed Addition - Tull-Wooten Preservation Site - Lenoir County
The Tull-Wooten expansion appears to be a good candidate for providing mitigation credits through
preservation of a mature wetland complex connected to the Neuse River.
Proposed Addition - Cox Preservation/Restoration Site - Lenoir County
The Cox Preservation/Restoration Site also expands the area of established mitigation projects. More
details regarding the restoration and monitoring plan will be necessary prior to approval of the project.
Additional description of the preservation area will also need to be provided; for example, the data sheet
for Cox data point 4 appears to indicate that it does not exhibit wetland hydrology, and the preservation
boundary shown in Figure 3 extends past the edge of hydric soils.
Proposed Addition - Valentine Preservation Site - Lenoir County
The Valentine Preservation Site has potential to provide mitigation credits, but additional information
from the eastern part of the site and the areas with Chewacla soils will be needed prior to determining
the available credit. Factors such as the young age of the western forest community and the amount of
open water on the site may reduce preservation credits.
We look forward to MBRT field visits and further discussion of these proposed sites.
Nom` Carolina
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401 Oversight(Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Cfabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / Fax [phone]
Internet: ham://h2o.enr.state.nc.us/ncwetlands
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Mr. Biddlecome
U.S. Army Corps of Engineers
Neu-Con Wetland/Stream Mitigation Bank - DWQ Comments
Page 5
Please feel free to contact Tammy Hill or Eric Kulz at [phone] if you have any questions
regarding this project or our comments.
Sincerely,
Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
cc: File Copy (Eric Kulz)
Central Files
Kathy Matthews - USEPA
Travis Wilson - NC Wildlife Resources Commission
Gary Jordan - US Fish and Wildlife Service
Ron Sechler - National Marine Fisheries Service
Norton Webster - Environmental Banc and Exchange, 909 Capability Drive, Suite 3100
Raleigh, NC 27606
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: htto./lh2o.enr.state. nc.uslncwetlands
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An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper