20081143 Ver 1_Mitigation Plan Review_20080725

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WATF9 p Michael F. Easley, Governor
William G. Ross Jr., Secretary
t? North Carolina Department of Environment and Natural Resources
5 Coleen H. Sullins, Director
Division of Water Quality
July 25, 2008
Mr. Andy Williams
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re: Cripple Creek Stream and Wetland Mitigation Bank
Alamance County
Prospectus and Mitigation Plan Comments
Dear. Mr. Williams:
We have reviewed the Mitigation Plan for the above-referenced site. In addition, DWQ representatives
visited the site on March 23, 2007. Our comments from the site visit were presented to the Sponsor in a
letter from you dated May 15, 2007.
Our review of the Prospectus and Mitigation Plan has generated the following comments:
• The planting plan for the streamside areas and the bioretention BMP includes tag alder (Alnus
serrulata). Tag alder is proposed to comprise 33% of the stems planted in the streamside areas.
DWQ acknowledges that tag alder is a natural component of riparian areas and wetlands
throughout North Carolina. However, this species fixes nitrogen, and the downstream waters
have a supplemental classification of NSW (nutrient sensitive waters).
DWQ recommends reducing the numbers of tag alder planted, possibly substituting silky
dogwood (Cornus ammomum), elderberry (Sambucus canadensis) or other appropriate species
that do not fix nitrogen. Should tag alder currently be present on the site, DWQ does encourage
the use of existing plants as transplants, as they would certainly be well-adapted for conditions at
the site, and would likely be of a larger size than nursery stock.
The report states that both riparian and non-riparian wetlands are to be restored and enhanced,
and that hydrology monitoring will be conducted. The target hydrology is inundation or
saturation for 12.5% of the growing season; DWQ considers this hydrology criteria to be
acceptable for the bottomland hardwood wetlands proposed for the site. Comparison with
hydrology in the reference wetlands is also necessary to evaluate the performance of the
restored/enhanced wetlands during atypical climatic conditions.
Nom n,--u ina
aturally
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. Williams
U.S. Army Corps of Engineers.
Cripple Creek Stream and Wetland Mitigation Bank - Prospectus/Mit. Plan Comments
Page 2 of 2
However, DWQ does not concur with the suggestion that if wetland target hydrology is not met,
that a jurisdictional determination would be performed for the purpose of attributing success to
the project. Failure of the site (or portions of the site) to meet hydrology criteria or to achieve
hydrology comparable to a functioning natural reference wetland would require evaluation by the
MBRT and possible credit deduction for the areas that are not functioning appropriately for the
target wetland type.
Based on the site visit and information provided in the Prospectus and the Mitigation Plan, the site
appears to be a good candidate for a mitigation site. However, DWQ reserves the right to provide
additional comments based on review of the permit application and more detailed design plans.
Please feel free to contact Eric Kulz at [phone] if you have any questions regarding this project.
Sincerely, M
Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
cc: File Copy (Eric Kulz)
Central Files
Sue Homewood - WSRO
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
None Carolina
Morally
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper