20041713 Ver 1_Other Agency Comments_20050701

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NCDENR
North Carolina Depattrrient of I_nvironrnent and Natural Resources
Division of Coastal Mlanagernent
Michael F, Easley, Governor Charles S, Jones, Director William G. Iioss,lr., Secretary
MEMORANDUM
July 1, 2005
TO: Stephen Rynas
Federal Consistency Coordinator
DCM - Morehead City Office
151-13 Hwy. 24
Hestron Plaza 11
Morehead City, NC 28557
FROM: Melissa Carle, Wetlands Specialist
SUBJECT: Proposed Fill of 0.117 Acres of Wetlands to Facilitate Construction of
Residential Development
LOCATION: Dolphin Ridge and Royall Oaks Subdivisions off of Coast Guard Road in
Emerald Isle, Carteret County
Thank you for the opportunity to review the consistency certification for the above referenced
project. After reviewing both the consistency certification and mitigation plan, I would like to
offer the following comments:
1. There is no indication in the consistency documents that any effort was made to avoid
or minimize these proposed impacts to Section 404 wetlands. Inter-dunal depression
wetlands are an increasingly threatened wetland type in North Carolina due to
development pressures on the barrier islands and should be preserved when possible
through avoidance and minimization before compensatory mitigation is allowed.
2. The accepted mitigation ratio for wetland creation is 3:1, not 1:1. The reason that a
higher ratio is typically required for creation projects than for restoration projects is
that creating a wetland where one has never existed is more difficult and has a lower
probability of success than restoring a wetland that once existed at a site. While the
proximity of the creation sites to existing wetlands may reduce the risk involved with
wetland creation, it does not eliminate it entirely.
3. There should be a provision in the vegetation success criteria that invasive species
will not count toward the vegetation cover percentages required for the site to achieve
success. Under the success criteria as they are currently stated, a site dominated by
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