20140957 Ver 2_Attachment 1_CEA Report_20170818

Attachment 1

Carpenter Environmental Associates, Inc.
Report on the Revised Individual 401 Water Quality Certification and Riparian
Buffer Authorization Application, Submitted by Atlantic Coast Pipeline, LLC, for
the Proposed Atlantic Coast Pipeline Project, Submitted to the North Carolina
Department of Environmental Quality on May 8, 2017
August 2017
Introduction
Carpenter Environmental Associates, Inc., (CEA) on behalf of Sierra Club (SC),
reviewed and analyzed portions of the Atlantic Coast Pipeline, LLC, (ACP) Revised 401
Water Quality Certification and Riparian Buffer Authorization Application (Application),
submitted by ACP, for the proposed Atlantic Coast Pipeline Project (ACPP), submitted to
the North Carolina Department of Environmental Quality on May 8, 2017, to evaluate
ACPs analysis and mitigation of potential impacts to aquatic life, water quality, and
ecologically sensitive habitats due to pipeline crossings.
CEA is a specialty consulting firm that provides environmental engineering, litigation
support, and environmental science services to a diverse group of clients consisting of the
legal community, advocacy groups, the insurance industry, other consultants and real
estate development groups.
CEA's staff consists of engineers, scientists, technicians, and support personnel that are
well versed in environmental statutes and in implementing regulations including the
Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA),
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
and their state counterparts, New York State Environmental Quality Review Act
(SEQRA), New York State Environmental Conservation Law (ECL), Endangered
Species Act (ESA) and many other state, and local laws and regulations.

Scope of Our Review
CEA's analysis focused on the potential environmental impacts to aquatic life, water
quality, and ecologically sensitive habitats due to wetland and waterbody crossings for
the North Carolina portion of the pipeline alignment, including the following:
• The biological significance of the water quality, ecologically sensitive habitat, and
freshwater/tidal wetland impacts in selected wetland/waterway crossings along
the project alignment.
• The potential impacts caused by waterbody/wetland pipeline crossing methods
including: Dam, Pump, Flume, and Horizontal Directional Drilling (HDD) and
the adequacy of impact mitigation and monitoring during such installation
activities.
• The adequacy of proposed pre- and post -installation studies and mitigation plans
for the project.
• Application deficiencies (data gaps) limiting the ability to fully evaluate relevant
issues.
Based on CEA's review of the Application and subsequent filings, it is our opinion that
the evaluation of wetland/waterbody impacts and proposed mitigation plans, as supported
by the FEIS, is inadequate and does not provide adequate protection of the
wetlands/waterbodies along the intended route. In summary, the Applicant has failed to:
• Adequately delineate the extent of wetlands that will be impacted within the
project area.
• Document the potential impacts for each specific crossing that may result from
the proposed actions.
• Adequately assess impacts to wetlands and identify adequate wetland mitigation
to be undertaken for wetland areas significantly impacted by the proposed
construction.
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• Adequately assess impacts and include adequate mitigation for adjacent
waterways to or from wetlands impacted by increased turbidity/total suspended
solids due to construction activities; deforestation and habitat disruption; invasive
species; the introduction of temporary and permanent access roads; stormwater
erosion; and pollutant introduction.
Background
The ACP consists of the construction of 604.6 miles of main and lateral pipelines; 3 new
compressor stations; valves, pig launchers, and receivers; and meter and regulating
(M&R) stations in West Virginia, Virginia, and North Carolina, capable of delivering up
to 1.5 billion cubic feet per day (Bcf/d) of natural gas to customers in Virginia and North
Carolina.' Approximately 14% of the pipeline alignment is located in
waterbody/wetlands.2 Approximately 798 acres of existing wetlands and 40,744 linear
feet of existing stream are located in North Carolina. The North Carolina alignment will
consist of approximately 186 miles of mainline; 12.2 miles of laterals; 1 compressor
station, 3 M&R stations, 11 valve sites; and 4 sets of pig launchers and receivers.3
Freshwater wetlands/waterbodies are present along and within the proposed pipeline
alignment. All wetlands provide different functions and value to the surrounding
community including but not limited to wildlife habitat, stormwater retention,
groundwater recharge, and nutrient cycling. Virtually all (26 of 30) of the wetlands
selected and reviewed by CEA were Riparian Forest Wetlands. These ecosystems are
dominantly reliant on surface waters and ground waters associated with streams, rivers,
and upland runoff and often are head waters for such systems. They are most commonly
the wettest during the winter when evaporation and plant activity are low and during the
Federal Energy Regulatory Commission, Atlantic Coast Pipeline and Supply Header Project,
Final Environmental Impact Statement, Volume 1, Atlantic Coast Pipeline, LLC, Dominion
Energy Transmission, Inc., Docket Nos. CP15-554-000, CP15-554-001, CP15-555-000, and
CP15-556-000, FERC/EIS-0274F, July 2017. [FEIS Volume 1]
FEIS Volume 1
FEIS Volume 1

wetter early growing seasons when flooding is most likely to occur. These system are
unusually efficient in nutrient/pollutant removal associated with runoff from upland
systems and, as such, are usually very productive systems that provide excellent water
quality protection for their associated water bodies. They are often critical flood water
storage and groundwater recharge areas. Wet forest provide unique deep habitat
environments that numerous species prefer and many depend on.
The wetlands and waterways being crossed by this project provide habitat for many
aquatic species including, but not limited to, federally endangered Atlantic sturgeon
(Acipenser oxyrhynchus ), several North Carolina State Species of concern (Neuse River
waterdog, Carolina madtom and the Chwanoke crayfish), as well as numerous species of
freshwater mussels, and hundreds of fish and aquatic insect species. Tables 8 and 9 of the
FEIS list the Federal and State endangered and species of concern by counties crossed.
The FEIS acknowledges that the Biological Evaluation is currently under review by the
Forest Service and that additional studies are required.
Review Methodologv
CEA reviewed documents provided by the Sierra Club and available on-line in support of
the wetland/waterbody impact evaluation.
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Based on the information provided in the Application and the FEIS, CEA selected 30
wetland/waterbody crossings as representative based on state regulatory class, waterbody
regime, and construction method as described in Appendix C-1, Wetland and Waterbody
Crossings for the Atlantic Coast Pipeline within the US Army Corps of Engineers
Wilmington District, to the Application.
State Regulatory Class
State Regulatory Class categories listed in Appendix C-1 include:','
• Anadromous Fish Spawning Area - Not defined in regulations or guidance
• C - Freshwater Aquatic Life, Secondary Recreation and Human Health (Applies
to all freshwater classifications)
• WSIII, IV,V - Water Supply and all Class C uses
• NSW - Nutrient Sensitive Water
• Sw -Swamp
• NA
• Unclassified
We retained crossings classified as NSW, WSI-V, SW, leaving forty crossings.
Waterbody Regime
Types of Waterbodies to be crossed by the ACP include:
• Ditch
• Ephemeral
• Intermittent
• NA
• Open Water
• Perennial
• Pond
• Blanks
4 NC Division of Water Resources, "Surface Water Quality Standards, Criteria and Protective
Values," July 5, 2017.
5 15A NCAC 02B .0101 General Procedures, Amended October 1, 1996.
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We retained waterbodies for ephemeral, intermittent, and perennial waterbodies for
analysis, which narrowed the analysis to 30 crossings.
Of these 30 crossings, 21 are perennial waterbodies, 6 are intermediate waterbodies,
and 3 are ephemeral (Table 1). Perennial systems are wetlands or waterways that have
saturated soils or flowing waters year round. Intermediate systems are saturated or
flowing part of the year. Ephemeral systems contain water only temporally after or
during rain events.
The highest level of impacts due to the pipeline will be realized at the Perennial
crossings. These impacts will include the generation and management of dredge spoils
often within a wetland area; increased downstream sedimentation and turbidity;
displacement and loss of aquatic organisms; loss of wetland, riparian upland, and
aquatic habitats; compaction of soils with the possibility of changes in hydrology; and
the potential for invasive species introduction.
Intermediate and ephemeral crossing impacts will also include the generation and
management of dredge spoils, wetland and riparian upland habitat loss, soil compaction
with possible hydrology impacts, and the potential for invasive species introduction.
The nature of saturation or flow typically associated with these systems lend them less
to maintaining aquatic species populations. Sedimentation and turbidity impacts would
only occur if crossing was performed during the wet seasons or during rain events.
Construction Method
Of the 30 crossings reviewed and analyzed 18 will be impacted by open cuts, 5 by
HDD, 6 by Dam/Pump, and 1 by cofferdam (Table 1). The high number of open cuts
were attributed to the applicant's claim that small transects being open for a smaller
amount of time would be less harmful to the environment.
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ANALYSIS/COMMENTS
Issues identified as part of our review include:
• Insufficient evaluation of specific site conditions and potential impacts due to
crossing methods.
• Insufficient evaluation of the potential for invasive plant and animal species in the
Forest Mitigation Plan to repopulate cleared areas.
• Insufficient restoration plans.
• Incomplete surveys of site-specific site species and habitat throughout the study
area.
I. Proiect Activities Posing Potential Environmental Impacts
The discussed crossing construction methods, open cut (mechanical dredging); dam,
pump/or flume water redirection; cofferdam, conventional boring and HDD, all will
result in some level of the following negative environmental impacts:
• Generation of dredge spoils/drilling spoils or muds that will have to be stockpiled
and managed are common to all crossings to varying degrees.
• Increased sedimentation or turbidity impacts will be realized heaviest by open cut
crossing, but will still be a potential source for all dry trench methods as well.
Sedimentation and turbidity impacts would be greatly reduced with both boring
methods.
• Displacement and loss of aquatic organisms and habitat will occur with all trench
methods but would be eliminated by boring methods.
• Entrainment of aquatic species would be limited to pumping and drill methods if
water is from natural source.
• Disruption and loss of wetland habitat will occur with all methods.
• Loss of riparian bank habitat and wet forest habitat fragmentation will occur with
all methods.
• Compaction of soils within the wetlands will occur with all methods because of
equipment needs, staging areas and access road.
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• Potential introduction of invasive species will occur with all methods.
The open cut methods proposed by ACP consist of digging a trench using a track hoe,
bulldozers, or draglines to dig a trench. The pipeline is placed in the trench and
backfilled with the stockpiled dredge spoils. This method utilizes no stream flow
control or diversion methods and is proposed for wetlands and areas of undefined
streams where ACP claims that dry crossings are "infeasible." No comparative
assessments of other methods of crossing are presented by ACP to support the necessity
of using this method or to support the statement that dry crossing are infeasible.
Assessments of site specific comparisons with dam and pump, cofferdam, flume or
boring methodology and their site specific anticipated impacts on the environment
should be provided and used as the basis to justify this approach, not convenience.
While usually considered to cause less impact to the environment, the dry crossing
methods have historically experienced significant problems leading to difficulties in
meeting turbidity standards across the nation.' The lack of site specific details relative
to corridor width, water depth, velocity, stream gradients, composition, size, and
distribution of bed materials, stream sinuosity, and equipment to be used have
historically contributed to sediment and turbidity releases and water quality violations
making these methods more time consuming and less attractive to applicants.
Successful utilization of these methods requires significant site specific detail and
planning.'
Flumes are installed and used to divert the highest anticipated flow during construction.
Dam diversion structures are placed upstream and downstream of the trench area.
Flumes are left in place during pipeline installation until final cleanup of the streambed
is complete. Flumes may be used in conjunction with dam and pump methods.
Golder Associates, River and Stream Crossings Study (Phase I) Executive Summary, 1998.
Kreider, Tyler, PE, Pipeline Stability at Water Crossings, undated.

Documented problem associated with the use of flume crossings include releases due to
poorly sealed dams, short flumes limiting ditch widths, the ability to maintain sinuous
channels, approach angle problems leading to an inability to thread the gas pipe under
the flume, equipment selection and bank and substrate problems associated with a lack
of understanding of on-site conditions.'
Dams and pumps are used to divert flow around the construction work area. Sandbags
and/or clean gravel and plastic liner are used to dam the waterbody upstream and
downstream. Energy dissipation devices are used to protect the streambed from
scouring at the discharge location. Upon completion of the pipe installation the trench is
backfilled and the stream bed stabilized. Dam and pump systems, while fairly effective,
again require significant effort and planning. Critical planning points to avoid failures
and releases identified with these systems included the necessity of having adequate
stream flow calculations, impermeable, high quality dams, onsite pumping capacity of
at least 150% of calculated flow, on-site replacement equipment, extra fuel and a good
contingency plan for unforeseen problems.' Some downstream sedimentation and
turbidity will occur with the removal of the dams.
Cofferdams, a temporary flow diversion structure, isolates stream segments and creates
discrete dry sections. Upon completion of the pipe installation, the trench is backfilled
and the flume removed. Again, significant site specific information about substrate
composition, bank stability, flow, and significant diversion design is required. Some
sediment and turbidity impact should be anticipated with the removal of the flume and
diversion structure.
HDD is accomplished by drilling a pilot hole, enlarging the pilot hole to accommodate
a pipeline along a designed directional path and pulling back the pipeline through the
Kreider, Tyler, PE, Pipeline Stability at Water Crossings, undated.
Kreider, Tyler, PE, Pipeline Stability at Water Crossings, undated.
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hole.10 This method uses drilling mud comprised of 65% water and 30% bentonite clay.
Each of the stages results in drill spoils requiring disposal and proper on-site
management using closed loop containment and containment pits.
The Conventional Boring method requires the installation of angular pits dug on either
side of the resource and the boring of a shaft like tunnel in which the pipeline is
installed. A boring machine with an auger drill is then used to tunnel under the resource
and a prefabricated pipe is installed. This method is most commonly used for short to
middle range reaches of roads, wetlands and other sensitive resources.
Potential Impacts to Wetlands
The Applicant has identified over 1,000 wetland crossings associated with the project.
CEA reviewed 30 proposed stream crossings representing 1,301 linear feet of center line
crossings (cic). Forested wetland represented 27 of these crossing. The Little River
Crossing at mile marker 82.5 represented a 57 cic with no linear feet of bank line work
space required (lfbl). The Neuse River crossing at mile marker 98.5 represented 138 cic
with an associated 113 IN work space all of which is locate in forested wetlands. The
unnamed tributary to Cypress Creek located at AP3 mile marker 7.8 is a proposed 2 cic
with 77 IN in an agricultural area.
A total of 3,609 IN of work space in forest wetland was also evaluated. These crossings
include waters and Palustrine Forest Wetlands, Palustrine Scrub Shrub Forest, and
Palustrine Emergent wetlands. The impacts associated with these activities will differ to
the degree of disruption and the type of system. Seven of these sites cross multiple
tributaries leading one to question the wisdom of the use of the Open Cut method in these
areas. In anticipation of increased impacts associated with multiple disruptions meeting a
io Kruse, H.M.G., "The trenchless technique horizontal directional drilling, Soil related risks and risk
mitigation," 0 Pipeline Technology Conference 2009.
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short distance downstream, I would suggest a feasibility evaluation with HDD technology
be explored.
With the exception of HDD, all of the method of crossing being proposed will result in
stream or wetland disturbance resulting in habitat loss ( permanent or temporary),
changes in species diversity, the loss of aquatic organisms, varying levels of
sedimentation and turbidity, the potential for the introduction of pollution and /or
invasive species and riparian disruption. The conventional boring method mentioned and
disregarded in the FEIS would seem a viable option for the single tributary crossings that
we assessed. This option if viable would eliminate the requirements for removal of
species, eliminate the loss of aquatic habitat and organisms and eliminate much of the
sedimentation and turbidity impacts. Fifteen of these crossings were between 10 and 100
cic. Feasibility analysis for the conventional boring option should be provided for each of
the open cut crossings proposed.
Lack of Complete Delineation
While the applicant delineated the specific areas where streams and wetlands would be
physically altered by construction activities, a complete investigation of the potential for
downstream and overall wetland system impacts was not provided. The applicant has yet
to conduct an adequate delineation of wetlands that may be impacted by the project."
Open Cut is the primary means proposed by ACP for crossing wetlands. Perennial wet
woods wetland habitat are to be transversed at 22 of the evaluated sites. As has been
previously discussed, these areas are saturated or flowing year round and are a major
source of groundwater recharge.
ACP has provided no analysis of groundwater flows through these critical wetland
habitats. Wetlands by definition have high water tables. The proposed trenching and
associated compaction of wetland soils associated with equipment activity, open cut, or
11 ACOE, Nationwide Permit 12.
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dry trench methods; access road placement and removal; and the potential for fracture
impacts associated with blasting can cause significant alterations in the water regime of
the wetlands. These alteration can significantly change the viability and functions of the
system by redistributing water redistributing or in the case of fracturing eliminate the
available waters to other areas.
Wetland confirmations in the field were limited to 300 feet from the pipeline. A review of
the provided maps suggest the wetlands are often significantly different from the desk top
assessments again suggesting that the true extent of the wetland situation within the
designated pipeline pathway is not understood. The full extent of impacts to wetlands
within these construction areas cannot be evaluated without a complete assessment of
current surface and groundwater conditions, including the delineation of ecological
features and their associated values throughout the complete area of potential impact.
ACP should install piezometers as required to understand the hydrology of the system to
a level that the potential for the proposed activities can be properly assessed.
In order for the project review to be thorough and complete, the applicant must
delineate/investigate the remaining portions of wetlands to be impacted by the project.
Without the benefit of a full investigation and impact analysis, their conclusion that
impacts to wetlands from the project will be minor remain as yet unjustified.
Insufficient Impact Anal
The Applicant generalizes impacts that may be realized as temporary. These impacts
include riparian banks, aquatic habitat loss, wetland habitat disruption and loss,
sedimentation and turbidity impacts, deforestation, and loss of wildlife and wildlife
habitat. Based on our experience, we would expect that the aquatic habitat loss, riparian
bank, and wetland habitat disruption if properly managed could meet restoration goals in
5 to 7 years. Some wildlife losses of near endangered species may never recover while
the mature hardwood canopy could take up to as much as a century to recover. ACP
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commonly turned to the method with the least cost and most potential for severe impacts
(open cut).
Open cut crossings divert no water during the stream crossing, utilizes equipment in
direct contact with flowing or pooling water, and lacks the potential for species protection
provided by the other available crossing techniques. Impacts associated with this method
can range from minor and temporary to severe and permanent depending on the specific
onsite conditions. Certain changes associated with the reduction of certain wildlife
species may be severe and permanent. One of the most critical issues to avoid significant
and permanent impacts in wetlands and stream crossing projects is site specific
planning. 12 ACP's lack of consideration for the potential impact of transecting and
fragmenting significant mature wet forest and proposing to trench significant wetlands
without understanding the overall hydrology of the system show a lack of the level of
planning required to truly predict their ability to protect the resources of the State.
Open cuts in forested wetlands associated with this project will result in permanent
habitat loss and fragmentation of the mature tree canopy and can result in several
negative impacts associated with the edge effect. Much of the area designated for clearing
for the proposed pipeline is mature wet forest. Examples of mature tree clearing is
evident throughout the areas near Sapory Creek near mile marker 56.3 and Contentia
Creek near mile marker 73.6. Significant impacts associated with these intrusions include
species differentiation due to light penetration, habitat intrusion by predator species,
habitat loss due to the edge effect, the disruption of reproductive populations and the
introduction of invasive species. 13 Critical studies such as invasive plant, migrating birds,
and depth of impacts of fragmentation are inadequately addressed.
12 MDE, Wetlands and Waterways Program, Recommended Best Management Practices For
Restoration of Wetlands After Temporary Impacts, December 2013.
13 Haddad, Nick; Habitat Fragmentation and It's Lasting Impact on Earth's Ecosystem, Science
Advance, March 2015.
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The Cerulean Warbler (Septophaga cerulean) which is currently on the federal list for
consideration as endangered was listed for 11 of the 30 sites we reviewed.
Acknowledgement and assessment of the negative impact should be weighed in over
review process.
The swath that will be required to lay the pipeline (75 feet with a 125 foot construction
corridor) will eliminate and fragment mature forest within this construction area for
decades. The 10 -foot wide swath above and centering the pipe will remain forever
treeless. This opening in the canopy will reduce habitat and animal population sizes and
decrease habitat heterogeneity associated with fragmentation of populations, light
penetration, and the disruption of primarily bird and amphibian breeding territories.
Some of the avian species found along the proposed pipeline that will undoubtedly be
affected include the Scarlet Tanager (Piranga olivacea), the Wood Thrush (Hylocichla
mustelina), and the Worm Eating Thrush (Helmitheros verminorom). All of these species
are deep forest birds that are very sensitive to nest predation and to parasitic nesters such
as the Brown Headed Cow Bird (Molothrus ater). The Brown Headed Cowbird is an
invasive edge species that lays its eggs in other birds nest allowing the other species to
raise its young. Females have been documented to invade 35 nests in a single breeding
season.
Other permanent impacts associated with the edge effect and habitat fragmentation
include changes in site hydrology associated with earth compaction during construction,
changes in plant diversity and in the introduction of diseases, and invasive species both
plant and animal. 14 Predator species that commonly invade fragmented forest include but
are not limited to crows, raccoons, coyotes and domestic cats.
14 Didham, Raphael K, Ecological Consequences of Habitat Fragmentation, John Wiley & Sons,
Ltd, November 2010.
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The FEIS addresses soil compaction testing as part of the restoration program and refers
to the FERC Upland Erosion Control, Revegetation, and Maintenance Plan (FERC Plan)
for the details regarding monitoring methods and frequency. The FERC Plan does not
provide details regarding methods or frequency.15Soil compaction from the transport and
use of heavy equipment, as previously discussed, is a major concern in wetlands because
of the potential to change and redistribute surface and groundwater pathways. Wetlands
are extremely sensitive to alterations in water regimes. Minor changes can redistribute
flow and alter species survival and diversity.
Wetland and stream crossing will disrupt critical and sensitive aquatic and wetland
habitats. These disruptions will result in various extents of species displacement and loss,
decreases in prey availability, and possibly restrict fish and amphibian passage for
foraging and breeding. Increases in sedimentation and turbidity associated with
construction as per the crossing proposed for this effort, sediment stock piling efforts,
long term episodic stormwater runoff from cleared right-of-way, and stream bank
clearings are common occurrences with any activity involving equipment working in
these systems and can cause severe impacts associated with biological oxygen demand,
reductions in dissolved oxygen, covering and elimination of interspatial habitats for
egg/larval development and aquatic insects, covering and suffocation of benthic
organisms to include mussel beds, introduction of toxics from contaminated sediments or
equipment contributions, and interference with fish visibility for feeding and breeding
activities. Such impacts have the potential to drastically change the species diversity of a
system by eliminating sensitive species and cover special habitats that are critical to
aquatic insects and larva opening the door for less desirable species representative of the
degraded habitat.
15 FERC, Office of Energy Projects, Upland Erosion Control, Revegetation, and Maintenance Plan,
May 2013.
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Protected Species
The Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS)
identified 32 Endangered Species Act (ESA) threatened or endangered species and
additional proposed species, critical habitants, and species under review in the project
area. 16 Surveys are still pending.
At the time of the release of the FEIS and currently, ACP has not provided critical
information on surveys of endangered, threatened and other plant and animal species of
special concern. The applicants' claim that they will conduct or complete such surveys in
2017 confirms the inadequacy of the FEIS, and thus the Application, when released to the
public. All potential impacts should be considered prior to DWR offering an opinion as to
the overall impact of the project on the environment. A new or supplemental impact
statement that contains this information and allows for a proper public review is
warranted.
Mitigation
Wetland mitigation should be required to compensate for the permanent and temporary
impacts the project will have on impacted wetlands (e.g. loss of functions and benefits).
Wetland functions and benefits range from ecological associations (e.g. forested
wetlands), special features (e.g. resident threatened or endangered species), hydrological
and pollution control features, distribution, and location and cover types. As has been
required for similar projects, the applicant should establish one acre of new wetlands in
kind, and preservation and enhancement of 10 acres of wetlands within the watershed for
each acre permanently impacted. 17
16 FEIS Volume 1.
17 USDOE. Office of Electricity Delivery and Energy Reliability, Final Champlain Hudson Power Express
Transmission Line Project Environmental Impact Assessment Volume I: Impact Analyses, Washington D.C.
August 2014.
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In order to ensure the survival of the designed mitigation schemes, a detailed
maintenance program must be incorporated into the mitigation plan. The applicant should
monitor the success of the wetland restoration for a period extensively longer than the
two years proposed. Restoration sites are very susceptible to upsets associated with
natural occurrences such as flood or drought events. Two years is too short of a period to
monitor and assure success.
The sensitivity of and possible significance of impacts within substantial forested and
emergent wetlands warrant monitoring and guaranteed survival for a much longer (5 to
10 years) period considering some of the areas will take up to 100 years to reach their
maximum. Stream crossings should be monitored 5 to 7 years to assure re-establishment
of the native community. This extended period will provide more protection for drought
or unusual weather conditions. Taking into consideration how fragile wetland systems
are, monitoring and replanting should be required and undertaken by the applicant to
attain initial planting density no matter how long is required for recovery. Failure to meet
target densities will result in an invasion or change in habitat. Quarterly reports required
by the Restoration and Rehabilitation plan should include documentation regarding the
re-establishment of wetland functions and values and/or provide recommendations to
achieve full compliance with mitigation and restoration requirements.
In this case, the Applicant has limited their discussion to general methods and procedures
using incomplete information for the specific crossings proposed. Therefore, it is not
clear that mitigation for the loss of wetlands or overall impacts on the total wetland
system or the impacts associated with the stream disruptions discussed above have been
or could be addressed under the current application submittal. The appropriateness of any
future planned mitigation cannot be fully assessed
The Application addresses the potential environmental impacts related to construction by
generally stating construction activities along aquatic portions of the proposed project
route could result, mostly on a temporary basis, increased water turbidity, disturbance
and resuspension of sediments, disturbances to aquatic species, localized degradation of
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aquatic species habitat, increased vessel traffic, increased air emissions, and increased
noise levels. The information provided simply does not support these claims.