20171158 Ver 1_RS_CoverLetter_CommentResponse_20180703

June 19, 2018
Mr. Paul Wiesner
Western Region Supervisor
NC DEQ— Division of Mitigation Services
5 Ravenscroft Drive
Asheville, North Carolina 28801
Subject: Warren Wilson College Stream Mitigation Site Mitigation Plan Comment Response Letter:
DMS Contract #: 7188; DMS Project ID: 100019; RFP # 16-006991
Dear Mr. Wiesner,
Below are responses to DMS' Draft Warren Wilson College Stream Mitigation Plan comments.
General Comment: Please include the September 1, 2017 Post Contract IRT Meeting Minutes in the
appendices of the revised mitigation plan and confirm that the mitigation plan is consistent with the
meeting notes and IRT response e-mails (attached for reference).
iie post -IK I site visit into has been added to the document as Appendix L. I he document is consistent
with the meeting minutes as well as the IRT response emails.
Section 1.2 - Project Components and Structure: Recommend removing "In its current state"
from the first paragraph.
This was removed
Table 2: For the RFP Date, please provide the issuance date of the RFP. Propose changing the date to;
"September 16, 2016 (RFP Issuance Date)" and February 15, 2017 (RFP Opening Date) in the revised
report.
.Jle was revised to include both the issuance and opening dates.
Table 2: NCDMS Contract No. 100019 is incorrect. 100019 is the DMS project number. Propose changing
"NCDEQ Contract #7188 (Project Instituted)" & "May 22, 2017 (DEQ Contract Execution Date) in the
revised report.
This was updated as proposed.
Table 4: Please add thermal regime to the table.
".,.n summary section of the table.
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492

Table 4: Under Parameters; row Drainage area (acres and sq. miles) — Information in table is sq. miles
only. Please remove "acres" from the row header or add acres to the information.
"Acres" was removed.
Section 3 - Baseline and Existing Conditions: Consider adding a section for geology to include discussion
of geological controls present at the site.
3CCUU11 3.3 WdS Uldlle'CU w UeUluey u 3oils" and the following paragraph was added:
"Site UTs occur within an alluvial system with a floodplain composed of unconsolidated
sedimentary deposits. Therefore, bedrock control is not expected within Site UTs as it would be
on the Swannanoa River. Geologic probing on UT -8 revealed no bedrock."
Section 3.7 — Channel Stability Assessment (Page 17): Sediment: Please add a statement that addresses
capacity and competence of bedload, specifically the larger fraction of sediment. Your assessment of the
primary sediment source (fines from bank erosion) is great information, but when this source is abated,
what sizes will be transported under Qbf and .66 Qbf? This request may be as simple as interpreting
Table 9.
I he tollowing was added to the last paragraph of Section 3. /:
"Proposed stream power and shear stress values appear adequate to mobilize and transport
sediment through the Site, without aggradation of the channel or erosion on proposed
streambanks while maintaining channel bed material characterized by gravel -sized particles."
Section 6 (Page 21): Please clarify the reference to hydrology in NCSAM, e.g., hydro in NCSAM is local
rather than watershed hydro; correct?
Hydrology is one of the three primary stream functional metrics assessed by NCSAM and pertains to
local hydrology in the specific stream reach being assessed.
Section 7.1 -Existing Paths: Will the existing trail along UT3 be relocated a certain minimum distance
away from the project stream during construction? In the past, the IRT has suggested that trails be at
least 15 feet away from project streams. It is reported that the trails are approximately 5 feet wide. DMS
understands the trail/ footbridge crossings have been removed from the proposed mitigation credit. Has
additional buffer been included to offset the trail width where it runs parallel to UT3? Please include the
existing trails and/or proposed relocated trails on Figures 7-71 and the 60% plan set in the revised
mitigation plan.
The trails are in fact 2 -feet wide and located no closer than 20 feet from the channel (except where
crossing a UT). Since the trails are small, low -impact foot trails located under a mature forest canopy
and dense rhododendron stand, additional buffer is not proposed. The trails have been added to Figures
7D, 7E, and 7F.
Table 13: The biological conclusion for the Northern Long Eared Bat is "May Effect". The only
species that can have the "May Effect" only call is the Northern Long Eared Bat. Please update
the table accordingly.
This was updated.
General & Section 8.1— Drop Structures: Based on IRT feedback, DMS does not recommend the use of
Terracell in the design and construction of the proposed drop structure on UT -8.
.......11-- —.1 , , "" -—.1 _.b _ — — , , _.. — --1, — uctures and request the
use of Terracell. RS uses Terracell as a standard practice on all stream projects and has never had a
failure where it is installed.
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492

Section 8.4.8 — UT -6 (S -Field): The open water pond above the project reach will not be included in the
conservation easement. Will this pond area be fenced to exclude cattle above the project reach? Please
update the report text accordingly.
The pond is fenced to exclude livestock. The report has been updated.
Section 8.4.10 UT -8 (Forbat's Field): Will topsoil be stockpiled and redistributed along UT8 as part of the
floodplain excavation? Please update the text section accordingly.
___, —, uu_ — —, —L r.,u . ur_ _, _ _, -, u„u redistribution of topsoil within the
floodplain."
Success Criteria (Table 18 & 19): Does continuous surface flow monitoring apply to all streams or only
intermittent streams? The provider may want to consider adding a continuous monitoring gauge and/ or
trail camera to UT8 due to the small drainage area of the reach.
Continuous munitoring gauges and/or trail cameras are designated Tor U 1-3 and U I -b as designated in
Table 18 in the Number/Extent column; UT -8 was added to cover all UTs with lower flows.
Success Criteria (Table 19 & Table 20): Suggest rewording of BHR & ER success criteria by taking out;
during "any".
This was removed from both tables.
Appendix D — Preliminary Jurisdictional Determination: Please include the final approved map/s
associated with the PJD in the Appendix.
Appendix E — Categorical Exclusion Document: Please include the Categorical Exclusion
Summary and full signed checklist in the revised mitigation plan (attached). Please note that the
signature sheet provided in the draft does not include the DMS PM signature.
Appendix E was updated.
Appendix F: - Northern Long -Eared Bat (NLEB) 4 (d) Rule Streamlined Consultation Form: Please
change "Earned" to "Eared". Please also include the initial 11/30/17 e-mail from FHWA to USFWS
(attached) in the appendix.
,ament and the email was added to Aonendix F.
Appendix H — Financial Assurance: The following language should be included in the appendix;
"Pursuant to Section IV H and Appendix 111 of the NCDEQ DMS (formerly Ecosystem Enhancement
Program) In -Lieu Fee Instrument doted July 28, 2010, the North Carolina Deportment of Environmental
Quality (NCDEQ) has provided the USACE-Wilmington District with o formal commitment to fund projects
to satisfy mitigation requirements assumed by NCDEQ DMS. This commitment provides financial
assurance for oll mitigation projects implemented by the program."The RFP performance bonding
language can be removed.
he language was included in Appendix H and the previously used language was removed.
Appendix J - Credit Release Schedule: Please only include the credit release schedule applicable to the
site (please see attached).
Appendix 1 was updated.
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492

Plan Sheets:
Please format the pdf sheet sizes to their respective page sizes for proper scaling and printing. Some
of the draft hard copy pages received did not print properly.
o PDF sheet sizes were formatted to a 22 -inch by 34 -inch page size. A half-size set can be
printed on 11 -inch by 17 -inch paper if preferred.
Sheet G3 - Please add channel centerlines to the map.
Profile Sheets - If possible add profiles to the plan view sheets. Please adjust/exaggerate the vertical
axes on the profiles to better show the proposed bedforms. Please add lines for the existing thalweg
and for proposed bankfull to the profiles.
o In order to maintain consistency throughout the plan set, profiles were not added to plan
sheets. Although this would work for a few UTs, the nature of the alignment of the rest of
the UTs did not lend well to a plan/profile sheet.
o The vertical exaggeration of the profiles was adjusted to better show the proposed
bedform.
o The existing grade shown on the profile is the elevation of the surface along the alignment
of the proposed channel centerline. Since the proposed channel centerline and the existing
channel thalweg are not in the same horizontal location for many of the UTs, it would not be
accurate to show the existing thalweg of the current stream channel within the same profile
as the proposed thalweg.
o The proposed bankfull depth has been added to the profiles.
Structure Details 1 & 2 - Please include any of the notes and details shown in the Typical Structure
Detail sheets in the Mitigation Plan as appropriate to the final plan sheets.
,. 111 —1- — u u„ ..,. ,...,.,, u„u .., .n the plan set.
Thank you for your time, please feel free to contact me if you have any questions.
Sincerely,
Worth Creech
Project Manager
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492