20080868 Ver 2_Other Agency Comments_20090519

Response to Jim Gregory's letter of April 16, 2009, regarding the PCS Bonnerton Nonriverine
Wet Hardwood Forest site.
Mike Schafale, North Carolina Natural Heritage Program
April 23, 2009
Dr. Gregory's primary assertion is that the area does not meet the definition of a Nonriverine
Wet Hardwood Forest and that, because of past land use, it is not a significant example of a
Nonriverine Wet Hardwood Forest.
As Dr. Gregory notes, Nonriverine Wet Hardwood Forest was first defined as a type by the
Natural Heritage Program. The name was first used in the program's classification of natural
communities, based on concepts that had been used previously by program contractors and likely
earlier in the scientific community. Dr. Gregory refers to Schafale and Weakley (1990), the
program's official classification of natural communities, and Schafale (2008), a recent
manuscript on status and trends of Nonriverine Wet Hardwood Forests. However, neither of
these documents define Nonriverine Wet Hardwood Forests as having to be dominated by
swamp chestnut oak, cherrybark oak, and laurel oak. Schafale and Weakley (1990) describe
them as being dominated by various hardwood trees, with these three species named first but
with sweetgum, tulip poplar, red maple, and several other species also named. Many of the
earliest qualitative descriptions of specific sites described them as dominated by these oaks, but
later quantitative study of some of the same sites found that, while abundant, oaks did not
dominate.
Schafale (2008) does not define Nonriverine Wet Hardwood Forest as having to be dominated by
the three oak species. In fact, it specifically discusses the fact that, while the presence of wetland
oaks is important, these species often do not dominate in the best remaining examples and that
their dominance is not crucial to recognition of the type. Nowhere is there a suggestion that all
three species must be present to recognize the type or for an occurrence to be a good example.
Because swamp chestnut oak, cherrybark oak, and laurel oak are collectively the most frequent
oak species in these communities, they are often emphasized in other descriptions of the type.
Abundant presence of other wetland oaks would also potentially support recognition as
Nonriverine Wet Hardwood Forest. However, a forest that had no oaks and consisted only of
the other trees mentioned in descriptions would not be considered an extant example of the type,
but would be either a degraded example or a successional forest of some other type.
The fact that the Bonnerton site shows evidence of human action and past land use does not
disqualify it from being a significant example and from being regarded as a Significant Natural
Heritage Area. Indeed, there could be no Significant Natural Heritage Areas at all under such a
definition that required no human influence. The Natural Heritage Program seeks the least
altered, closest-to-natural examples remaining for each community type, and those closest to this
ideal are regarded as the most significant. While we have not formalized definitions for mature
forests, in our experience, any hardwood forest that has most trees 12 inches dbh or over and has
some many trees 18-20 inches is unusually mature. While forestry books may suggest trees
should be 20 inches to be considered mature, this does not appear to match the practice in that
field, as most stands are harvested well before trees reach that size. While I noted the evidence of
past logging that Dr. Gregory cites, such evidence is common even in our best natural areas.
There are no Nonriverine Wet Hardwood Forests that have not been logged, and selective
logging of the sort noted by Dr. Gregory is the least alteration we can expect to find in any
remnants of these communities. The Bonnerton site is in better condition than most remaining
examples despite these impacts. Its condition and relatively large size place it among the best
examples of this community type known to remain.
I am not sure how relevant Dr. Gregory's other observations on hydrology and soils are. He
notes that the soils have hydric indicators. Most of the site has wetland vegetation, though there
are minor marginal upland inclusions. The southern red oaks he reported may have been in such
upland inclusions, which are also marked by beech trees. I visited the site with a number of
people experienced in delineating wetlands, and there was no dispute that the area was
jurisdicational wetland. Standing water does not always occur in Nonriverine Wet Hardwood
Forests, though sporadic ponded water, along with seasonal saturated soil and widespread hydric
indicators, would be expected.
RE: PCS - 404 Permit; Gregory Summary Page 1 of 2
RE: PCS - 404 Permit; Gregory Summary
Schafale, Michael
Sent: Thursday, April 23, 2009 12:21 PM
To: Fox. [e-mail]
Cc: Dorney, John
Oh. I should have figured there was more coming. This will take longer to work
through. I won't get it done today, and tomorrow is questionable too. Sorry.
-----Original Message-----
From: [e-mail] [mailto:[e-mail]]
Sent: Thursday, April 23, 2009 11:20 AM
To: Schafale, Michael
Subject: Fw: PCS - 404 Permit; Gregory Summary
Mike,
Just received a final copy of Gregory report. Earlier version I sent you was a
draft. Haven't had a chance to review yet but wanted to forward on to you -- not
sure how it is changed. Let me know if you want to revise the information you sent
me earlier. Thanks! b
Becky Fox
Wetland Regulatory Section
USEPA
Phone: [phone]
Email: [e-mail]
----- Forwarded by Rebecca Fox/R4/USEPA/US on 04/23/2009 11:17 AM -----
WCARY@brookspier
ce.com
To
04/23/2009 10:10 [e-mail]
AM 1,
[e-mail],
Palmer Hough/DC/USEPA/US@EPA,
Stan Meiburg/R4/USEPA/US@EPA, Jim
Giattina/R4/USEPA/US@EPA, Tom
Welborn/R4/USEPA/US@EPA, Jennifer
Derby/R4/USEPA/US@EPA, Gregory
Peck/DC/USEPA/US@EPA, Suzanne
Schwartz/DC/USEPA/US@EPA, David
Evans/DC/USEPA/US@EPA, Brian
Frazer/DC/USEPA/US@EPA, Rebecca
Fox/R4/USEPA/US@EPA
cc
James Gregory
<[e-mail]>,
[e-mail],
[e-mail],
[e-mail],
[e-mail]
Subject
PCS - 404 Permit; Gregory Summary
https://mail.nc.gov/owa/?ae=Item&t=IPM.Note&id=RgAAAAC 1 sF9yPPCxSoAItly3U0b... 4/24/2009
RE: PCS - 404 Permit; Gregory Summary
Page 2 of 2
Attached is Dr. Gregory's report on his initial assessment of the portion of the
Bonnerton tract listed by NHP along with the two maps referenced in that report.
Please review the list of recipients and forward this to anyone in your agency who
should have received it (these are the only addresses I have).
6-19-08 map
1-6-09 Biotic Communities
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(See attached file: Gregory report NRWH stands 4-22-09.pdf)(See attached
file: 20090422220441160.pdf)(See attached file: 20090422220446795.pdf)
https://mail.nc.gov/owa/?ae=Item&t=IPM.Note&id=RgAAAAC 1 sF9yPPCxSoAItly3U0b... 4/24/2009