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Home My WebLink About20170887 Ver 2_Summary of BPDP Changes_20181029To Company: Re W ILDLANDS ENGINEERING MEMORANDUM Katie Merritt From: Andrea Eckardt DWR Date: October 29, 2018 Bethel Branch (DWR 2017-0887v2) Summary of Edits Below is a summary of the edits that were made to the Bethel Branch Bank Parcel Development Package, per the DWR comments from September 2018. DWR comments are in black, Wildlands update is in red. Page 1 (of PDF) • Crossed out - Nutrient Offset reference in title. Done Page 2 • Add something that confirms that the watershed draining to the ephemeral channel (ut3) meets the rule (see 15A NCAC 02B .0295(0)(7). The DWR Site Determination demonstrates that the ephemeral channel is directly connected to an intermittent stream. A watershed map has been added to the appendix to show that the entire area proposed for mitigation is within the contributing drainage area to the ephemeral stream. Section 6.0 includes details demonstrating that the area of mitigation on the ephemeral channel comprises no more than 25% of total area of mitigation. • Add an Existing Conditions Map. There is one from the Stream Mitigation Plan (Figure 7) but shows UT3 as an intermittent stream all the way to the pond. I'm fine with Figure 7 from the Stream Plan as long as it accurately depicts the channels from our stream determination. Figure 3 has been modified to show the existing stream alignment and DWR 2017 stream determinations. Page 3 • Remove all references to this site being a nutrient offset bank. Done • Cross -out "Nutrient Offset and' in title. Done • Cross -out "will be". Done • Insert "Approximately". Done • Insert "are proposed to be". Done • After looking at Figures 6-7, 1 added some clarification to this paragraph that provides more detail of the type of project you are constructing. All requested edits have been made to this section. • Insert "are proposed as". Done • Insert "are proposed as" Done • Insert "are proposed as" Done IW Wildlands Engineering, Inc. (P) 704.332.7754 • 1430 South Mint Street, Suite 104 • Charlotte, NC 28203 • Insert "However, a majority of the mitigated riparian areas will extend to just 50' perpendicular to the top of stream banks. Any areas that are less than 30' from the top of stream banks were removed from the creditable acreage for this bank." Done Page 4 • Insert "Haw River Sub -watershed of Jordan Lake". Done • Please identify what tributary onsite or offsite that stormwater runoff drains towards. "The Site includes unnamed tributaries that flow to South Fork Cane Creek." was added to the paragraph. • 3 calls were made on UT3, please add clarity here. Done 1. UT3 Upstream of pond and pond (which was ephemeral) 2. Pond outfall to UT3 intermittent flag (which was ephemeral) 3. Intermittent flag to UT2 confluence (which was intermittent) • Note: The reach upstream of the pond and the reach downstream of the pond were both determined to be Ephemeral. Therefore, at most, the reach restored through this pond would carry the same designation as its upstream and downstream reaches... and would be ephemeral as well. For this BPDP, we need to describe the projects assets based on the stream calls that were made prior to the BPDP submittal. If a request is made to re-evaluate the ephemeral channel UT3 stream reaches after construction, we may entertain that request. If the designation changes from Ephemeral to Intermittent at a later date, we will work it out and the assets at the time. Wildlands can get buffer credit on ephemeral channels under 0295 (o)(7). However it is up to Wildlands to make sure their buffer credits on the ephemeral channels comply with all of Rule .0295 9(o)(7). Therefore, Wildland needs to show how the credits don't exceed the 25% cap written out in the rule. Understood. See credit table in Section 6 for documentation of this rule. Page 5 • Do you mean UT2? Yes. That has ben corrected. Page 6 Use this section to describe how the ephemeral reaches being mitigated for buffer mitigation comply with all the .0295 (o)(7), including the pond as well, with regards to 1. Drainage area and the mitigation area of the whole site. This documentation is now referenced in Section 2.1 and a figure added to the appendix. 2. 25% cap This cap is documented in Section 6.0 now • Pond comments (may want to add a Section within 3.0 just for the ponds). Excluding pond preparation which will be mentioned in 3.1, both ponds needs to be discussed in detail in this section. Done • Has Wildlands requested a 401 for pond removal and stream restoration through the pond? If not, please stat the following: "A 401 will be required for all stream restoration work, including work within the pond on UT3 and will be obtained prior to any work in waters." Done 2 Include pond preparation here. Nothing is mentioned about how the pond on UT3 will be breached, drained, what the draw -down time is, etc. Additional information on the pond removal was added to this section. So no grading of soil, ripping, etc is intended to occur as part of the parcel preparation? I usually see this when the project is planned for stream restoration. Please confirm. Language has been added to clarify that grading will occur as part of the stream restoration project. Additional Sheets from the Stream and Wetland Mitigation Project were added to the Appendix as well. Pond Comments (may want to add a Section within 3.0 just for the Pond) 1. Excluding pond preparation which will be mentioned in 3.1 the pond needs to be discussed in detail in this section. In order to approve restoration credit within the footprint of pond #1, I'll need to see a draft Plan Sheet showing where the proposed stream channel will go and what is being done to "make" the stream channel. In our rules, only streams that are restored through pond bottoms can get buffer credits adjacent to them. There for, without any details provide here in the BPDP I can't confirm that Wildlands is actually doing a stream restoration in the pond or is allowing it to naturally regenerate. The natural regeneration of streams in ponds does not generate buffer mitigation credits. Understood. Plan sheet showing the proposed stream alignment, existing pond footprint, and conservation easement boundary was added to the Appendix. Page 7 • Insert "15A" Done Page 8 • Please add another plot and have it proposed to be placed within the pond footprint. Done • Insert "UMBI" Done Page 10 • Insert "When including the restoration proposed within the existing pond footprint" Done • Insert "but no wider than 100' from top of stream banks." Done • Add another row for "UT3 Intermittent Origin" Done • This area was determined to be "Ephemeral" at the pond outlet down to the DWR intermittent flag. Therefore, since I need to make sure your buffer credits along Ephemeral reaches don't exceed 25% of your total mitigation area (see .0295)0)(7) please give me the acreage along the ephemeral reach separate from the intermittent reach. If at As -built things change and DWR entertains another stream determination request, we can handle it then. Done • Insert "Ephemeral Reach" Done • This acreage should be included with the calculation used to determine if the mitigation credits along ephemeral reaches fall less than 25%. Done 3 • Insert "ephemeral reach" Done • Insert "within the existing pond footprint along UT3" Done • A complete survey showing tops of banks on all mitigated streams will be provided with the As -built Report. Any adjustments to mitigation credits will be based on the As -built survey and submitted with the As -Built Report. Done Page 11 • Add a column to the right of "Total Acreage" column and title it "Eligible Acreage" The "*" should be there to reference the rule citations below the table. Then, for the ephemeral restoration rows, determine what acreage is actually eligible to be used for credits using the 25% cap and enter that number in the field. Then do the same thing for Preservation. Done • Add a row for "Ephemeral" restoration and for Feature ID column use "UT3 reach" and "pond" for description. Done • 1 don't think the "*' is appropriate here. More appropriate on the "Eligible acreage" column Done • Cross -out Done • Deduct the ephemeral acreages from this total, including the pond acreages, which are ephemeral Done • After you make the "Eligible Acreage" column you will put max allowable acreage here. Done • Continue the column for acreage Totals here as well Done • Add a row "Total Ephemeral Restoration Credits" Done • You won't need this statement once you include the "Eligible Acreage" column requested above. Removed • Add another footnote here referencing the 25% verbiage on Ephemeral channels (see 0295(o)(7)) Done Page 12 • Delete this table. With the additional columns and rows requested in the previous table, I don't think you will need this one. Done • Cross out Done Page 13 • Add "Stream and Wetland Mitigation As -Built Report submitted to the IRT Done • Insert "DWR" Done • Insert "Buffer Mitigation" Done Page 15 • If Wildlands wants to use this bank for nutrient offsets, it needs to be written up to address that part. Currently it appears that the BPDP is only proposing buffer mitigation. Nutrient reference has been removed Page 21 • Add one more veg plot to your monitoring plan and put it within the pond footprint. Done 4 Page 23 • Would prefer a plan sheet of just the pond footprint showing the draft design. Plan sheet depicting the existing pond footprint, new stream alignment, and easement area was added to the Appendix. • Planting areas have been updated per earlier comment. Done 5