Loading...
HomeMy WebLinkAbout015_WR_ CoverLetterWeston Solutions, Inc. WestonSolutions.com June 19, 2023 Sent Via Email to cnaumann@sandersonstewart.com Chris Naumann Bozeman Branch Manager Sanderson Stewart Re: June 2023 Wetland and Waterbodies Assessment Report for the North Park Development, and Response to Comments from TerraQuatic Dear Mr. Naumann: Weston Solutions, Inc. (Weston) has completed a Wetland and Waterbody Assessment Report for the North Park Development. This Report is an Addendum to the November 2021 report, and provides a more detailed and precise assessment of the area, as well as addressing the comments received from TerraQuatics on February 9, 2023. Weston has reviewed the comments received from TerraQuatic regarding the May 2022 Wetland and Waterbodies Assessment Report. Below, you will find Weston’s response to TerraQuatic’s comments provided in the February 9, 2023, letter. • Adequate information has been submitted for some of the City of Bozeman aquatic resource regulations. For example, the proper illustration of watercourse setbacks along creek wetland fringe. However, there may be two creeks within the site: these data are unclear and incomplete. o Weston conducted a second Wetland and Waterbodies Assessment for the Project (June 2023 Wetland and Waterbodies Assessment Report) and has identified Spring Creek and Mandeville Creek on Site. The June 2023 Wetland and Waterbodies Assessment Report is attached to this letter. • An aquatic resource report was also submitted; however, the report has several errors. I have enclosed an edited report for the submittal team’s wetland consultant to review. I have added several PDF notes within the body of the report explaining the errors. Some of the errors concern Army Corps data forms: incorrect hydric soil determination data and lack of relevant supportive determination information. This report requires correction and resubmittal; however, soil data will be difficult to obtain given winter conditions. The consultant is welcome to contact me to discuss any issues I have noted in the report. o The June 2023 Wetland and Waterbodies Assessment Report documents wetland hydric soils on Site. Wetland data forms documenting the hydric soils are included with the Report. Naumann Sanderson Stewart - 2 - 6/19/2023 • A large error that requires immediate correction concerns the delineation map and corresponding report data: The author of the report stated there are two creeks within the property: the creeks are not labeled on the map and there are no results describing length, acreage, etc. Include linear feet and acreage within the ordinary highwater mark (OHWM) on the delineation map (callouts are acceptable). An additional titled table is required within the report that includes both (?) of these watercourses; the report currently includes no information regarding the linear feet or OHWM acreage of the two (?) creeks. The acreage stated for the wetland fringe along the creeks likely includes the area within the OHWM: subtract the OHWM acreage from the entire polygon surrounding the wetland fringe and correct these errors within the report tables (which require titles and enumeration). These areas require differentiation during the Section 404 application process. The entire area (OHWM + wetland fringe) is required for functional assessment calculations (which have not been included in the report and are also required). o The June 2023 Wetland and Waterbodies Assessment Report documents Spring Creek and Mandeville Creek on Site. A table has been included in the report describing the length of Spring and Mandeville Creeks within the Survey Area as well as the area contained within the OHWM of both creeks. Spring Creek is approximately 1.37 miles long and the area within the OHWM is approximately 2.32 acres. Mandeville Creek is approximately 1,600 feet long and the area within the OHWM is approximately 0.35 acres. The wetlands delineated within the Survey Area totaled approximately 8.06 acres. This wetland area does not include the area within the OWHM. • No information has been included in a narrative regarding 404/310/401 (etc.) application/permit status. o Appropriate permits (318 Authorization, 310 Permit, 404 permit, and 401 certification) were obtained for all three development phases of the project that had impacts to waterbodies and/or wetlands using the May 2022 Wetland and Waterbodies Assessment Report. These phases include: MRL Culvert Extension, Trail C Rail Extension, and North Park West. Although the phases were permitted separately, the 404 permit and 401 certification for all phases are under one Nationwide Permit associated with the project. Although it is expected that there will be slightly less wetland impacts based on the June 2023 Wetland and Waterbodies Assessment Report, Weston will coordinate with the permitting entities for potential permit addendums or the need to reapply based on any future development changes and associated impacts. Naumann Sanderson Stewart - 3 - 6/19/2023 If you have any questions or comments regarding this letter or the June 2023 Wetland and Waterbodies Assessment Report, please feel free to contact Tim Steinhofer by phone at (914) 406-9323 or via email at timothy.steinhofer@westonsolutions.com, or me via phone at (406)461-1055 or via email at lisa.dewitt@westonsolutions.com. Sincerely, Weston Solutions, Inc. Lisa DeWitt Project Manager Enclosed: June 2023 Wetland and Waterbodies Assessment Report