20081295 Ver 1_Mitigation Bank Proposal Review_20080905

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
September 5, 2008
Ms. Amanda Jones
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
Re: Farmer Creek Mitigation Bank
Avery County
Mitigation Bank Prospectus Comments
Dear. Ms. Jones:
Coleen H. Sullins, Director
Division of Water Quality
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We have reviewed the Prospectus for the above-referenced site. Based on the information presented in
the Prospectus, we have a number of questions/comments regarding the project as proposed. Our
comments are as follows:
• DWQ is concerned about the gaps between the restoration reaches on this project. DWQ feels
that one of the positive attributes of mitigation banks is that they generally result in the
restoration or enhancement of long reaches of streams. In many cases, larger projects have the
potential to provide higher ecological uplift than a series of smaller separate projects.
The gaps between the various restoration reaches may hinder the development of the stream
system at the site. Activities occurring in the gaps that are not under the control of the Sponsor
may negatively affect the restoration reaches.
• The stream monitoring should include installation of staff/crest gauges to document bankfull
events. Success criteria should include the occurrence off two bankfull events (in non-
consecutive years) over the proposed five-year monitoring period. This is referenced in the
credit release section of the Mitigation Plan (Section 6.2) but is not discussed in the sections on
monitoring or success criteria.
• The target hydrological success criterion proposed for the project is inundation or saturation for
12.5% of the growing season (consecutive days). Recent research conducted by DWQ has
shown that natural riparian wetlands are inundated or saturated for significant periods during the
year. DWQ feels that 12.5% should be the minimum acceptable hydrology target for riparian
wetlands, unless the reference wetland for the site shows drier conditions during an atypical year.
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
N e hCarolina
Noaturallff
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
Ms. Jones
U.S. Army Corps of Engineers.
Bass Mountain Mitigation Bank - Prospectus Comments
Page 2 of 2
DWQ does not agree with the proposed practice of perfo clog monitoringnCompen atodetermination to
document success if wetland parameters are marginal bas type mitigation is intended to replace the lost functions and values of a particular order to be considered he
monitoring data should reflect a trend toward the target wetland type
successful and generate mitigation credits.
Please note that DWQ reserves the right to provide additional comments based on the site visit and
review of more detailed design plans.
Please feel free to contact Eric Kulz or Tammy Hill at [phone] if you have any questions
regarding this project.
S' cerely,
0
Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
cc: File Copy (Eric Kulz)
Central Files
Roger Edwards - ARO
Noe hCarolina
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401 OversighUExpress 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.e n r. state. nc. us/n cwetla nd s
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper