20090633 Ver 1_Restoration Plan Review_20090615

Kulz, Eric
From: Kulz, Eric
Sent: Monday, June 15, 2009 12:02 PM
To: Jones, Toni Wyche
Cc: Homewood, Sue; Chapman, Amy; Karoly, Cyndi
Subject: UT to West Fork Deep River - Forsyth and Guilford Counties (20090633)
Toni;
DWQ has reviewed the PCN and Restoration Plan for the above-referenced project. DWQ concurs with the proposed
stream restoration and enhancement activities, and we feel the site is a good candidate for restoration. The 401 Water
Quality Certification for the project is deemed issued.
However, please note the following issues regarding stream mitigation credit and the Randleman buffers.
1) Several of the UTs have quite smal drainage areas, (UT-A = 0.03 square miles, UT-C = 0.07 square miles and UT-D =
0.15 square miles). DWQ recommends that personnel from the DWQ Winston-Salem Regional Office be contacted to
evaluate the streams on the site. Several of the UTs may be intermittent. As such, they may not be suitable as
compensatory mitigation for impacts to perennial streams. Please note that DWQ is currently drafting policy regarding
requirements for mitigation for intermittent streams, and therefore any intermittent stream located on this site may be
suitable to provide intermittent stream mitigation.
Also please note that restoration (e.g. construction of a new channel) is not recommended for intermittent streams, as
changing of the elevation of the stream bed may result in a loss of connection with the water table and result in an
ephemeral channel. In such a case, the loss of channel would be considered a loss of stream function and may warrant
mitigation. Enhancement of degraded intermittent streams is recommended over restoration.
2) It is unclear in your Restoration Plan if Randleman buffer credit is to be generated at thtis site. For Randleman buffer
mitigation to be generated, the restored or enhanced buffer must be 50 feet wide, as measured from the top of bank.
As indicated in your Restoration Plan, "in areas where the 50-foot buffer extends outside of the easement, the easement
boundary was defaulted to as the buffer restoration boundary". No Randleman buffer credit may be generated in areas
where the restored or enhanced buffers are less than 50 feet wide. Also, the restored or enhanced buffer must be
protected within the conservation easement.
Please note that in areas with buffers less than 50 feet wide, stream credit may be adjusted as well, depending on the
extent of narrower buffers.
3) Areas where utility easements are located within the 50-foot buffer cannot be used as Randleman buffer credit.
Restored/Enhanced buffers must be forested and within a conservation easement to receive buffer credit.
4) Areas along Reach 1 of the main stem are currently wooded, and cannot be used for Randleman buffer credit (e.g.
buffer preservation cannot generate mitigation credit). Where existing wooded buffer is less than 50 feet wide and
located within the conservation easement, the unforested areas can be restored and credit can be claimed for the
restored areas (as long as these are restored in accordance with the Guidelines for Riparian Buffer Restoration).
Please feel free to contact me if you have any questions regarding this project.
Eric