20090104 Ver 1_Public Notice Response_20090401

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STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
BEVERLY EAVES PERDUE
GOVERNOR
March 31, 2009
Mr. Eric Alsmeyer
USACE
Raleigh Regulatory Field Office
3331 Heritage Trade Dr., Suite 105
Wake Forest, NC 27587
Dear Sir;.
This letter is a response to 2 letters from the public notice for the Rolesville Bypass
(NCDOT TIP No. R-2814). One letter from the U.S. Environmental Protection Agency (EPA)
dated March 4, 2009 and from the U.S. Fish and Wildlife Service dated March 10, 2009.
In these letters it recommends that the North Carolina Department of Transportation
(NCDOT) mitigate at a ratio of 2:1 from the mitigation sites proposed in our permit application.
NCDOT's permit application proposed a 1:1 ratio from the mitigation sites. These letters
indicate that the recommendation for higher ratios is from concern of replacing impacts to mature
(or relatively mature) forested systems with a newly planted site. To address these concerns,
NCDOT prepared the following site specific descriptions of the quality of the impacted wetlands
for Sections A and B. This is followed by a summary of the proposed mitigation sites, Jeffreys
Warehouse and Marks Creek, and their respective quality and ecological benefits. The
justification for NCDOT's proposal of the 1:1 ratio comes from the comparison of the qualities
of the impacted sites to the qualities of the mitigation sites.
R-2814A
Sites 1 and 2- These wetlands lie along the edge of US 401 and behind a subdivision.
They receive roadway runoff. The impacted areas contain no mature hardwoods, only scattered
loblolly pines 40-50 years old with young tulip poplar and sweetgum in the understory.
Site 3- This wetland has only herbaceous vegetation and is located just past the toe of
slope of US 401 and is located under a powerline. It has been disturbed in the past few years by
the construction of a waterline.
MAILING ADDRESS:
NC DEPARTMENT OF TRANSPORTATION TELEPHONE: [phone] LOCATION:
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS 4701 Atlantic Ave.,
NATURAL ENVIRONMENT UNIT FAX: [phone] Suite 116
1598 MAIL SERVICE CENTER Raleigh, 127604
RALEIGH 1 27699-1598 WEBSITE:W VNCDOT.ORG
EUGENE A. CONTI, JR.
SECRETARY
Site 4- This wetland is located just off the roadway of US 401 with some second growth
\j. hardwoods of red maple, and blackgum and some shrubs.
"Site 6- This wetland is located just off the roadway of US 401. No mature hardwoods are
found the in wetland, only second growth tulip poplar and green ash with some cane and shrubs
in understory. This wetland has been disturbed in past by logging and is surrounded by pine
regeneration and second growth red maple and tulip poplar.
R-2814B

Site 2- This headwater wetland has been disturbed by logging in the past. It only contains
shrubs of sweetgum, blackberry, catbriar and honeysuckle. The wetland is surrounded by second
growth loblolly pine; red maple and white oak _• .. . ............ ...:. ?, ? „_ .
Sites 3 and 4- These wetlands contain all herbaceous vegetation and are highly disturbed
because they are located underneath a powerline.
Site 7- This wetland is an old beaver swamp. The impact area contains no mature
hardwoods. Several snags exist within the wetland with some scattered second growth
hardwoods. Most vegetation is shrubs and herbaceous. The canopy is very open. A sewer line
runs parallel to the wetland.
Site 13- This wetland is located just off a road. It contains no mature hardwoods, only
some scattered second growth hardwoods, shrubs and cane. It is near an agricultural field and
part of surrounding area has been clearcut and now contains pine regeneration.
Site 14- The upper wetland is dammed up by beavers and is impounded. It contains
second growth blackgum and red maple and is surrounded by residential property. The lower
wetland contains second growth hardwoods of red maple, tulip poplar and sweetgum and is
partially surrounded by cleared areas.
Site 15- This wetland appears to have been clearcut approximately 5-7 years ago and is
surrounded by residential fields.
Site 17- This wetland is located next to a road and a powerline. It contains second growth
hardwoods of red maple, green ash and tulip poplar.
None of the wetlands impacted in Sections A and B contain mature hardwood trees. The
wetlands only contain scattered second growth hardwood trees along with pine and hardwood
saplings with invasive shrubs and vines in the understory. The species most commonly found
were red maple, sweetgum, tulip poplar and blackgum. Most of the wetlands are disturbed by
recent and past logging activities, are located along the edges of roadways and residences, have
been impacted by beavers, or are located within powerlines.
Each of the impact sites have been subjected to disturbances that affect the level of
function and overall quality of the wetlands. As evident by the descriptions above, these wetland
stressors include but are not limited to nutrient enrichment, contaminants, sedimentation, thermal
alteration, vegetation alteration, hydrologic alterations, soil disturbance, and habitat
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fragmentation. These stressors reduce the level of habitat, water quality, and hydrology functions
of the wetlands.
The Jeffreys Warehouse site is proposed to offset 2.62 acres of riverme wetland impacts
and 1.77 acres of non-riverine wetland impacts associated with R-2814 A and B. The site is
approximately 88 acres, located along the east side of Little River. The site provides 3.66 acres of
riverine restoration and 23 acres of non-riverine restoration, in addition to stream and buffer
restoration. The site was replanted in 2007 after invasive species control measures were
implemented and to correct the initial poor planting techniques. The 2008 supplemental planting
was only in the vicinity of plots 6 and 7, both of which are located in the non-riverine restoration
areas. Field notes indicate the tree seedlings were being outcompeted by thick hydrophytic
herbaceous growth. All other plots were well above the vegetation success criteria. The
supplemental planting does not indicate poor site conditions or lack•of success _inmetland-:.........
restoration. Furthermore, restoration of the site provided a high functional lift by converting an
agricultural field drained by a dredged stream to a wooded wetland with a naturalized stream,
providing habitat and buffer along the Little River.
The Marks Creek site is proposed to offset 3,141 feet of stream impacts associated with
R-2814 A and B. The site is approximately 66 acres, located along the west side of Marks Creek
near Knightdale. The site provides 3,250 feet of Priority I stream restoration, in addition to
riverine wetland restoration, enhancement, and preservation and riparian and upland buffer
restoration and preservation. The fifth year of monitoring was completed in 2008. The Marks
Creek Site has met the required stream monitoring protocols including channel stability,
vegetation growth and survival, and required bankfull events. All of the restored tributary
profiles remain stable. All sixteen of the cross sections along the tributaries remain stable. There
is extensive growth of vegetation throughout the stream corridor, both within and outside of the
bankfull limits associated with the channel. Some areas of wetland restoration are not meeting
hydrologic success criteria. However, these areas are exceeding the vegetation success criteria
with an average of 600 stems per acre. The site restoration succeeded in establishing a forested
riverine wetland and stream system, providing a continuum of aquatic and terrestrial habitat
along Marks Creek. This site restoration provided a high functional lift from its previous
condition of a residential yard, ponded streams, and unbuffered cattle pastures.
As previously stated, NCDOT's proposal of 1:1 mitigation ratio is justified by the
comparison of the qualities of the impacted sites to the qualities of the mitigation sites. We
appreciate your consideration of this request in light of the comparative conditions and functions
of the impact sites and mitigation sites.

If you have any questions or need additional information, please call Rachelle Beauregard
at 431-6764.
Sincerely,
'1r"' Gregory J. Thorpe, Ph.D.
Environmental Management Director, PDEA
Cc:
Kathy Matthews, USEPA
Brian Wrenn, DWQ
Gary Jordan, USFWS
Travis Wilson, NCWRC
Clarence W. Coleman, P.E., FHWA
LeiLani Paugh, NCDOT-NEU