20081267 Ver 1_Preservation Plan Review_20081203

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
December 3, 2008
Mr. Bill Biddlecome
Washington Regulatory Field Office
U.S. Army Corps of Engineers
P.O. Box 1000
Washington, NC 27889-1000
Re: Neu-Con Mitigation Bank
- Juniper Farms Mitigation Site (Johnston County) DWQ # 20081267
- Cox II Mitigation Site (Johnston County) DWQ # 20081266
- Tull-Wooten II Mitigation Site (Lenoir County) DWQ # 20081268
Dear Mr. Biddlecome:
The Division of Water Quality (DWQ) 401 Oversight and Express Review Permitting Unit has reviewed
the Preservation Letters and visited the sites for the above-referenced mitigation areas proposed for
addition to the Neu-Con Umbrella Mitigation Bank. Based on this review, DWQ supports the inclusion
of all three sites in the Umbrella Bank, but we have a few remaining comments. We appreciate your
consideration of our comments below.
General Comments
• DWQ appreciates the proposed use of a conservation easement monitoring data sheet to
document site observations over the long term. We request that our office be copied when such
forms are submitted to the Corps.
• If an agency has been identified to hold the conservation easement on any of the parcels, it would
be helpful to have that information included in the Preservation Letters.
Valentine Mitigation Site
• Some of the successional areas contain very young forest ecosystems and small inclusions of
open water and uplands. We suggest a mitigation ratio higher than 6:1 for these areas.
Cox II Mitigation Site
• We would like to see a more in-depth description of the method used to determine the line
between riverine and non-riverine wetlands.
Tull-Wooten II Mitigation Site
• The Preservation Letter should contain a map detailing the representative sampling point
locations.
N?oc"?nCarolina
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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. Biddlecome
US Army Corps of Engineers
Neu-Con Umbrella Mitigation Bank - site additions
Page 2 of 2
DWQ appreciates the opportunity to comment on the proposed additions to the Neu-Con Umbrella
Mitigation Bank. If you have any questions related to our comments or this mitigation bank, please feel
free to contact Tammy Hill at [phone] or [e-mail].
Sincerely,
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Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
Cc: File Copy (Tammy Hill)
Matt Matthews - DWQ, Wetlands and Stormwater Branch
Kathy Matthews - USEPA
Howard Hall - USFWS
Ron Sechler - National Marine Fisheries Service
Travis Wilson - NCWRC
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 Carolina
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Natumlly
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper