20081235 Ver 1_Mitigation Bank Proposal Review_20080912

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen Sullins, Director
Division of Water Quality
September 12, 2008
Mr. David Lekson
Department of the Army, Corps of Engineers
Washington Regulatory Field Office
P.O. Box 1000
Washington, NC 27889-1000
Re: Brice Creek Wetland Mitigation Bank
Craven County
ORM ID SAW-2008-02310
NC DWQ # 20081235
Dear. Mr. Lekson:
The Division of Water Quality (DWQ) 401 Oversight and Express Review Permitting Unit has reviewed
the Bank Prospectus for the above-referenced mitigation bank. Our comments- are as follows:
The proposed hydrologic success criterion of 8% saturation during the growing season mayor may not
adequately identify successfully restored areas of the targeted wetland type. While developing site
success criteria in the absence of substantial reference data, it would be appropriate for the applicant to
consider information from available resources, such as ecological community descriptions in
combination with hydrologic regime ranges in the 1987 Corps of Engineers Wetlands Delineation
Manual. Schafale and Weakley (Classification of the Natural Communities of North Carolina, Third
Approximation, 1990) describe Nonriverine Wet Hardwood Forests as seasonally saturated or flooded
by high water tables, poor drainage, and perhaps by sheet flow from adjacent pocosins. We recommend
that comparison with monitoring data from an appropriate reference wetland be included in evaluating
the success of the proposed restoration area, especially during years with precipitation totals outside of
the normal range.
DWQ has concerns regarding the proposed geographic service area. Mitigation is required in order to
offset degradation of water quality due to unavoidable impacts to aquatic resources. If the mitigation
site is hydrologically separated (e.g. by a topographic break between river basins) from the impact site,
then it may not provide any uplift in the quality of the effected waters. Our rules (15A NCAC 2H .0506
(h)(8)) indicate that mitigation shall occur within the same river basin when practical, and current
policies note our preference for mitigation within the same 8-digit hydrologic unit as the impact.
NPe h
o Carolina
Naturally
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
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Mr. Lekson
Proposed Brice Creek Wetland Mitigation Bank
Page 2 of 2
Although we have some concerns, the site does appear to be well suited for the proposed mitigation
activities. We look forward to visiting the site and reviewing a more detailed mitigation plan for the
project.
Please feel free to contact Tammy Hill at [phone] or [e-mail] regarding any
issues related to this bank.
Sincerely,
Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
Cc: File Copy (Tammy Hill)
DWQ, Washington Regional Office
Ms. Kathy Matthews, US EPA
Mr. Ron Sechler, NMFS
Mr. Howard Hall, US F W S
Ms Maria Dunn, NC WRC
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
Naturally
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