20171584 Ver 1_DWR comments on Draft Mitigation Plan_20190304

DWR comments on the Draft Dugger Mitigation Plan
March 4, 2019
1. Be advised that to utilize this bank, DWR needs to have a restoration credit paired with
preservation credit. In addition, in the near future (when new rules are approved by the
legislature), new DWR rules will state that no more than 25% of preservation can be used for
mitigation for a permit/project.
2. Crossings: From Table 11 it appears no improvements are being planned for any of the noted
crossings (with the exception of some hand work on crossing #11). From the photos in Appendix
H crossings 3, 4, and 5 appear to be in less than optimal condition. Also, the inlet structure near
crossing 14 appears to be in need of maintenance (dipping out??). DWR requests that WEI
consider optimizing any culvert crossings that are not fully functional or will receive more
vehicular traffic.
3. DWR concurs with the majority of the preservation ratios, except for the mainstem of Dugger
Ceek. The mainstem has a trail which runs, for the most part, immediately adjacent (or within
30 feet) to the stream. DWR recommends that the preservation ratio for the mainstem of
Dugger Creek be 7.5:1.
4. DWR likes the fact that the riparian buffers exceed the minimum required and in many cases
goes out well beyond 100-200 feet. In addition, the headwater tributaries and wetlands were
captured for the entire watershed.