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    4K views36 pages

    Milburnie Dam Agency Comments

    Uploaded by

    Restoration Systems, LLC

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    of 36
    i2/14/2a11 16:46 9198076494 WET AND SH20 BRANCH PAGE e2/n4 North Carolina Department of Environment and Natural Resources Ds of Water Guay Bevery Eaves Percue ‘Coleen H Suns Dee Freeman Governor Director Secretary Deceraber 14, 2011 DWQ Project # 10-0007 ‘Wake County CERTIFIED MAIL: RETURN RECEIPT REQUESTED Ms. Jean Gibby, Field Chief US. Army Comps of Bngineers Raleigh Regulatory Field Office co Py 3331 Heritage Trade Drive, Suite 105 Y ‘Wake Forest, North Carolina 27587 Subject Property: -‘Milburitie Dam Mitigation Bank Comiments on Pablic Notice of Final Prospectus Dear Ms. Gil yt ‘On behalf of the NC Division of Water Quality, we respectfully request that you consider the following comments within your review of the 404 Individual Permit request for the above referenced property. We should note we have not received an application for the proposed project, but have only teceived the Final Prospectus and supporting documents as described below. ‘These comments ate based on review of the: ‘+ Final Prospectus published as a Public Notice dated Novomber 10, 2011 on the US Army Corps of Engineers, Wilmington District website; + discussions with Restoration Systerns (RS) personnel during a meeting at DWQ on December 2, 2011; + plan sheots which provided to DW at the December 2, 2011 meeting; + discussions between Erie Knlz of this Office and Adam Riggsbee of Riverbank Beosystems at Restoration Systems’ offices on December 7, 2011; ‘review of reports entitled Milbunie Dam Removal Wetlands Study (Entrix and RS, October 27, 2009) and Milburnic Dam Wetlands Pre-Removel Wetland Delineations (The Catena Group and RS, March 7, 2011). 1, DWQ has reviewed the Milbumnie Dar Removal Wetlands Study, which provides data and methodology associated with the estimated wetlands losses resulting from removal of the dam. DWO acknowledges that existing monitoring data bes been collected but not yet compiled by Restoration Systems’ contractors. DWQ requests copies of all hydrological atid water quality ‘monitoring reports and data once these reports are completed. Weird, Burs, Soamaey, Congas end sri Un (6602) ‘gon Mal denice ere, Nort Cave 780-7650 Foon: 80607 €000 | FAX: 91607-0604, Inbar: hipyponalnetenonteoney sn Eq Opporely Aemahs Acton Enoger 12/14/2011 16:45 — s198e76494 WET AND SH20 BRANCH PAGE USACE Pege2 of 3 December 14,2011 Per our conversations with Adam Riggsbee, DWQ also requests a supplemental monitoring proposal to quantify hydrology around the perimeter of the wetlands of most concern, specifically Wetlands { and 2.as shown on Figure 6 of the Prospectus, The proposal should include a sufficient number of additional wells/piezometers to monitor hydrology along the periphery of these wetlands, as well os a monitoring schednle (e.g, frequency of monitoring). This proposal should be submitted to the Interagency Review Team (IRT) for approval. DWQ has reviewed the Pre-Removal Wetlands Delineation report as described above. The figures presented in the report show the wetland boundaries (Figure 2) at a seale of t inch = 1,000 feet, In addition, the “Project Study Area” boundary on the figure exchudes the western extent of Wetland 1 (Bridges Lake marsh). DWO requests more detailed wetland boundary maps for Wetlands 1 and 2, ag these are the ‘wetlands predicted to be most potentially affected by the removal of thedam. As per our discussions with Adam Riggsbee, DWQ acknowledges that this detailed type of information is typically submitted with a permit application. However, DWQ requests that this information, along with a jurisdictional verification of the wetland boundaries by USACE, be submitted as ‘soon as these are completed, ‘The Prospectus states that the Sponsor is exploring various engineering approaches to tetain the hydrology of the existing wetland areas, DWO requests that these approaches continue to be studied and seriously considered, as the wetlands are providing valuable nutrient removal functions. As with all 401 Water Quality Contification reviews, impacts to wetlands must be avoided and minimized to the extent practicable, Proposed mitigation options should also be developed and ptesented. ‘As discussed during our meeting with Adam Riggsbee, biological monitoring requirements are ‘oatlined in the guidance document Determining Appropriate Compensatory Mitigation Credit for Dara Removal Projects in North Carolina (June, 2008, USACE, Wilmington District, USEPA, Region 4, US Fish and Wildlife Service, NCDWO, NC Wildlife Resourees Commission, and NC Division of Water Resoutces). Comparison of pre- and post-removal monitoring results will be used to justify credit avards related to anadromous fish passage, Threatened and Endangered species recolonization, and conversion from lentic to lotic biological communities. DWQ acknowledges the challenges associated with access to the impoundment for conventional ological sampling, techniques. DWQ roquests that RS redouble theit efforts to develop an effective strategy to monitor biological components (fish, mussels and macrobenthos) prior to the

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