20090049 Ver 1_More Info Letter_20090128

Beverly Eaves Perdue, Governor
Dee Freeman., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H Sullins, Director
Division of Water Quality
January 28, 2009
Mr. Wyatt Brown
N.C. Ecosystem Enhancement Program
1619 Mail Service Center
Raleigh, NC 27699-1619
Re: Glade II Restoration Project
Alleghany County
DWQ #09-0049
ON HOLD/REQUEST FOR MORE INFORMATION
Dear. Mr. Brown:
The Division of Water Quality (DWQ) 401 Oversight and Express Review Permitting Unit has reviewed
the above-referenced application and restoration plan. In addition, Sue Homewood with the DWQ
Winston-Salem Regional Office visited the proposed project site on November 30, 2008.
We have several questions/comments regarding the proposed project. Our comments are as follows:
• Based on the information provided in the restoration plan and observations made during the site
visit, the proposed restoration of Glade Creek appears warranted, and we concur with the
proposed restoration approach.
However, we have a number of concerns regarding the Priority 1 Restoration/Relocation of the
UT. The UT will continue to be impacted by cattle upstream. Therefore, it is unlikely that
restoration/relocation of the UT will provide significant improved quality/functional uplift. In
addition, the existing UT is a B4/C4 channel and is being relocated and designed as a B4/C4
channel.
It is our opinion that this indicates little need for Relocation/Priority 1 Restoration. We agree
that there is incision at the downstream end of the existing channel. However, this can be
stabilized in the current location and will improve with the elevation changes proposed to Glade
Creek.
The Restoration Plan indicates that the UT relocation will provide additional flow to Wetland 2
which is isolated. Wetland 2 is at the toe of a slope and clearly is supplied by seepage observed
during the site visit. Isolated wetlands are naturally found in North Carolina and are not
necessarily considered to be impaired or degraded simply because they are not associated with
NorthCarolina
Aawatty
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. Brown
N.C. Ecosystem Enhancement Program
Glade Creek II Restoration Project
Page 2 of 3
riparian systems. Additional flow from the UT is unnecessary to ensure hydrology for wetland
2.
The Restoration Plan also states that the UT relocation will provide additional flow to Wetland 3
which is only influenced by flood flows from Glade Creek. The hydrology of many floodplain
wetlands are fed only by overbank flooding events. With the elevation changes proposed to
Glade Creek, some increase in overbank flooding should occur without the relocation of the UT.
These wetlands may be better candidates for enhancement or preservation, depending on the
vegetation quality.
An additional concern regarding the relocation of the UT to the floodplain of Glade Creek is the
extremely sandy nature of the Glade Creek floodplain soils. Regional Office personnel report
that the unconsolidated floodplain soils are of fairly significant depth. DWQ is concerned that
construction of the small relocated channel within these floodplain soils could result in the loss
of surface flow (flows may be subsurface).
The restoration plan attempts to address this concern by stating that constructed riffles and
matting will be utilized to stabilize the stream. However, subsurface flow is not a stability issue.
In addition using constructed riffles in a tributary that will be directly in the floodplain of a
much higher flow stream (Glade Creek) may result in the riffle material being mobilized during
high floodplain flows from Glade Creek and deposited outside the UT channel.
• The stream monitoring should include installation of staff/crest gauges to document bankfull
events. Success criteria should include the occurrence of two bankfull events (in non-
consecutive years) over the proposed five-year monitoring period.
DWQ requests clarification of wetland acreages included within the mitigation site. The
Executive Summary lists 0.16 acres of wetland restoration, 0.13 acres of wetland enhancement,
and 0.76 acres of wetland preservation, for a total of 1.05 acres. However, Section 5.1 of the
Restoration Plan provides descriptions of the wetlands, and the total acreage calculated is 0.951
acres. The PCN lists wetland impacts at 0.32 acres, and total wetlands on the site at 0.95 acres.
Please clarify.
Please note that the 401 Water Quality Certification (GC No. 3689) is not issued for this project pending
resolution of the issues described above.
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
NorthCarolina
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Mr. Brown
N.C. Ecosystem Enhancement Program
Glade Creek Il Restoration Project
Page 3 of 3
We look forward to your response to the comments listed above. Please feel free to contact Eric Kulz at
[phone] if you have any questions regarding this project or our comments.
Sincerely,
Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
cc: File Copy (Eric Kulz)
Matt Matthews - DWQ Wetlands and Stormwater Branch
Sue Homewood - DWQ WSRO
Amanda Jones - USACE Asheville Regulatory Field Office
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/newetlands
Wore n
thCarolina
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