20090134 Ver 1_Information Letter_20090414

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UNITED STATES ENVIRONMENTAL PROTECTION
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c PRO, E° ATLANTA, GEORGIA 30303-8960
April 7, 2009
Colonel Jefferson Ryscavage
District Engineer
Attn: Mr. William Wescott, Project Manager
Washington Regulatory Field Office
Wilmington District, Corps of Engineers
P.O. Box 1000
Washington, North Carolina 27889-1000
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Subject: North. Carolina Department of Transportation; Daniel Street Extension
TIP No. U-3826
Action I.D. #SAW-2009-00101
Dear Colonel Ryscavage:
This is in response to the Public Notice for the North Carolina Department of
Transportation's (NCDOT) Daniel Street Extension project (TIP No. U-3826). According to the
public notice, the applicant proposes to construct a two-lane facility on new location, including a
new bridge across the Tar River. Impacts are proposed to the Tar River and an unnamed
tributary to the Tar River, and 1.48 acres of adjacent wetlands (Riverine Swamp Forest and
Bottomland Hardwood Forest). As compensation for the permanent wetland impacts, NCDOT
proposes to use a combination, of on-site and off-site mitigation, at a 1:1 ratio. The impacts and
the proposed mitigation are located in the Tar River Basin (HUC code 03020103). No
compensation is proposed for the temporary impacts or stream impacts. The U.S. Environmental
Protection Agency (EPA), Region 4, Wetlands and Marine Regulatory Section has reviewed the
public notice, the permit application (and March 17, 2009 revisions to the application), the
mitigation plans and monitoring reports for the Mildred Woods mitigation site, and other
information related to the project. We also discussed this project with your staff by phone on
March 19, 2009. We have the following comments for your consideration.
As stated above, NCDOT proposes to utilize a combination of on-site and off-site
mitigation to compensate for the permanent impacts, at a l:1 ratio. However, EPA does not
believe that a 1:1 mitigation ratio is appropriate. The on-site mitigation consists of removal of an
old railroad bed to grade, restoring 0.94 acre of wetlands adjacent to the site. EPA recommends
a mitigation ratio of 2:1 for the on-site mitigation. This mitigation site has not been constructed
yet. The impacts from the road project are to high quality, mature wetlands. An unconstructed
forested wetland mitigation site does not provide an equivalent level of function as a mature
Intemet Address (URL) • http://www.epa.gov
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