20070245 Ver 2_Staff Comments_20080311

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NC Division of Water Quality
401 Oversight and Express Permitting Unit
March 11, 2008
Memorandum
To: Cyndi Karoly
Ian McMillan
File
From: Eric Kulz and Tammy Hill
Subject: DWQ # 20070245v2
Comments on IP Application - MARSOC/Camp Lejeune
Onslow County
Application by URS
Cyndi/Ian:
STREAM MITIGATION
All of the proposed impacts are to intermittent streams. Proposed mitigation is a combination of
EEP payment and on-site stream restoration (287 LF - removal of culverts). They did not provide
any details on the stream restoration except for some cross sections and grading plans, and there
is nothing in the application describing monitoring of the restored stream reaches.
They need to do stream monitoring. Despite the relatively short lengths of the reaches,
monitoring should be conducted in accordance with the interagency Stream Mitigation Guidelines
(2005). Monitoring Level I is required for all restoration projects. Annual channel stability
analyses and vegetation monitoring will be required, as well as photographic documentation of
stream conditions. Since the streams are intermittent, bankfull event documentation may not be
necessary or applicable.
WETLAND MITIGATION
On-site mitigation within 1 mile of the impact site is proposed at a 1:1 ratio for riparian wetland
impacts. This should be a 2:1 ratio (i.e. 1.828 acres of restoration to mitigate the loss of 0.914
acres of riparian wetlands). The on-site mitigation plan proposes monitoring to consist of as-built
elevation surveys and evaluation of vegetation after the first growing season. This is not
adequate to ensure long-term success of the project. Quantitative hydrology and vegetation
success criteria should be developed based on a reference ecosystem of the targeted wetland
type, and monitoring should continue through 5 years or until success criteria are achieved,
whichever is longer.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterquality.org/wetlands

NC Division of Water Quality
401 Oversight and Express Permitting Unit
For impacts to non-riparian wetlands, mitigation is proposed at a 1.5:1 ratio (5.15 acres of impact,
7.73 acres of mitigation) utilizing credits from the existing Greater Sandy Run Area (GSRA)
mitigation bank. This bank has been deemed successful and released from monitoring. Since
using established mitigation reduces temporal losses, the 1.5:1 ratio is acceptable if there is
concurrence with USACE. Otherwise, a 2:1 ratio will be required.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterquality.org/wetlands

NC Division of Water Quality
401 Oversight and Express Permitting Unit
March 11, 2008
Memorandum
To: Cyndi Karoly
Ian McMillan
File
From: Eric Kulz and Tammy Hill
Subject: DWQ # 20070245v2
Comments on IP Application - MARSOC/Camp Lejeune
Onslow County
Application by URS
Cyndi/Ian:
STREAM MITIGATION
All of the proposed impacts are to intermittent streams. Proposed mitigation is a combination of
EEP payment and on-site stream restoration (287 LF - removal of culverts). They did not provide
any details on the stream restoration except for some cross sections and grading plans, and there
is nothing in the application describing monitoring of the restored stream reaches.
They need to do stream monitoring. Despite the relatively short lengths of the reaches,
monitoring should be conducted in accordance with the interagency Stream Mitigation Guidelines
(2005). Monitoring Level I is required for all restoration projects. Annual channel stability
analyses and vegetation monitoring will be required, as well as photographic documentation of
stream conditions. Since the streams are intermittent, bankfull event documentation may not be
necessary or applicable.
WETLAND MITIGATION
On-site mitigation within 1 mile of the impact site is proposed at a 1:1 ratio for riparian wetland
impacts. This should be a 2:1 ratio (i.e. 1.828 acres of restoration to mitigate the loss of 0.914
acres of riparian wetlands). The on-site mitigation plan proposes monitoring to consist of as-built
elevation surveys and evaluation of vegetation after the first growing season. This is not
adequate to ensure long-term success of the project. Quantitative hydrology and vegetation
success criteria should be developed based on a reference ecosystem of the targeted wetland
type, and monitoring should continue through 5 years or until success criteria are achieved,
whichever is longer.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterquality.org/wetiands
11C
NC Division of Water Quality
401 Oversight and Express Permitting Unit
For impacts to non-riparian wetlands, mitigation is proposed at a 1.5:1 ratio (5.15 acres of impact,
7.73 acres of mitigation) utilizing credits from the existing Greater Sandy Run Area (GSRA)
mitigation bank. This bank has been deemed successful and released from monitoring. Since
using established mitigation reduces temporal losses, the 1.5:1 ratio is acceptable if there is
concurrence with USACE. Otherwise, a 2:1 ratio will be required.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterquality.org/wetlands