20091236 Ver 1_Credit Release Letter_20191204

Strickland, Bev
From: Sugg, Mickey T CIV USARMY CESAW (USA) < [e-mail] >
Sent: Wednesday, December 4, 2019 9:21 AM
To: [e-mail]; Bowers, Todd; fritz.rohde; Twyla Cheatwood - NOAA
Federal; Haupt, Mac; Davis, Erin B; MacPherson, Tara; Mairs, Robb L; Wilson, Travis W.;
Dunn, Maria T.
Cc: Tugwell, Todd J CIV USARMY CESAW (US); Kim Browning; Jessop, Jordan E CIV
USARMY CESAW (USA)
Subject: [External] LCFUMB (Brunswick Co.)- Credit Release Letter
Attachments: LCFUMB Credit Release 2019.pdf
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Good morning,
Enclosed is our credit release letter for both the Sneeden Tract (near Navassa/Leland) & White Springs Tract (near
Boiling Springs Lake). You will see that monitoring on the Sneeden tract is no longer needed & all remaining credits have
been released. There are a couple of concerns on the White Springs tract (Yr 4 monitoring) that need to be addressd,
which I understand from LMG are currently being planned. Tree suppression cuts will take place sometime in January.
If you have any questions/concerns, pls don't hesitate calling.
-mickey
Mickey Sugg, Chief
Wilmington Regulatory Field Office
U.S. Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403
[phone] (direct line)
[phone] (fax)
"The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete the Customer Satisfaction Survey located at:
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1

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
f/
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 26463-1343
December 2, 2019
Regulatory Division
Action ID. SAW-2009-02054
Mr. Jon Vincent
LCFUMB, LLC
1015 Ashes Drive, Suite 202
Wilmington, North Carolina 28405
Dear Mr. Vincent:
This letter serves to address the mitigation credit release from our evaluation, in
coordination with the Interagency Review Team (IRT), of the May 2019 Year 5
monitoring report for the Sneeden Tract and the April 2019 Year 4 monitoring report for
the White Springs Tract. Both tracts are associated with the establishment of the Lower
Cape Fear Umbrella Mitigation Bank (LCFUMB), in Brunswick County, North Carolina.
Please reference the January 23, 2013 executed Mitigation Banking Instrument (MBI);
and my June 5, 2019 onsite meeting with Messrs. Christian Preziosi, Corey Novak, and
Andy Dortch of Land Management Group, Inc., along with Messrs. Tyler Crumbley and
Jordan Jessop of our office. Also, reference our September 4, 2018 letter, which
includes the most updated credit release tables, concerning the previous year
monitoring reports.
Sneeden Tract:
In review of the 2018 data, it has been determined that the hydrology performance
standard has been met. Task 7.0 in Table 1A and Tasks 7.0 & 8.0 in Table 1 D of the
September 5, 2018 Updated Credit Release Tables (enclosed) has been fulfilled;
consequently, we hereby release the 15% (1.57 credits) of riparian (riverine) wetland
credits and 30% (or 733 linear feet) of the stream credits. These tasks represent the
remaining credit release for the Sneeden Tract.
Upon considering the monitoring performance and the site conditions, our office, in
coordination with the IRT, has determined to terminate your responsibilities to conduct
any further performance monitoring within the Sneeden Tract. By copy of this letter, we
acknowledge the final close-out of this tract and release all remaining wetland and
stream credits for compensatory mitigation use. Total released credits for this tract, as
depicted in the 2018 updated Tables 1A, 1 B, 1 C, and 1 D, comprise of the following:
91.1 riparian (riverine) wetland credits, 0.8 riparian (non-riverine) wetland credits, and
3,324 linear feet of stream credits.

-2-
White SDrinas Tract
In review of the monitoring results and the onsite inspection, the following items of
concern were observed: erosion of stream bed and bank in proximity of grade control
structures #1 and #2 and the increase volume of pine and sweet gum trees (mostly
pine) from the vicinity of cross sectional survey XS #1 to vegetative plot #2. During our
inspection, it was strongly recommended that corrective measures be taken to prevent
further stream channel erosion which could compromise the integrity of the site's stream
feature. Plans were to discuss the issue with a stream designer to determine the best
solution for long-term protection. For the pine and sweet gum populations, plans were
to conduct a suppression cut/removal sometime in the winter in order to increase growth
conditions and the survivability of the target planted stems. All draft plans must be
submitted to our office, which will be coordinated with the IRT, for review and
confirmation prior to implementing.
Although the majority of White Springs mitigation have met the performance
standards, our office is withholding both riparian (non-riverine) wetland credits and
stream credits based upon the concerns above. Consequently, it has been determined
that 5% (or 0.05 credit) of the riparian (non-riverine) wetlands will be withheld, while 5%
(or 0.05 credit) of the available 10% credits in Task 6.0 (Table 2A) are hereby released.
Also, 5% (or 75.4 linear feet) of stream credits will be withheld, while 5% (or 75.4 linear
feet) of the available 10% credits in Task 6.0 (Table 2C) are hereby released. All 10%
(or 6.44 credits) of the non -riparian wetland credits in Task 6.0 (Table 2B) are hereby
released for mitigation use. The non -riparian credit numbers reflect the 1.69 credit
reduction adjusted amount detailed in our September 4, 2018 letter.
To date, the combined total credit release for the Sneeden and White Springs Tracts
are the following: 91.1 riparian (riverine) wetland credits, 1.95 riparian (non-riverine)
wetland credits, 54.74 non -riparian wetland credits, and 4,304.2 linear feet of stream
credits.
Please be reminded of your obligations pursuant to the January 23, 2013 MBI;
including the continued maintenance inspections of the Bank, as well as beaver control,
in order to evaluate the condition and stability of all streams and wetlands. Should you
have any questions, please do not hesitate to contact me at the Wilmington Regulatory
Field Office, telephone [phone].
Sincerely,
Mickey Sug�g, Chi
Wilmington Regulatory Field Office

-3-
Copies Furnished via email w/ enclosure:
Mr. Jon Vincent, LCFUMB LLC
Mr. Christian Preziosi, Land Management Group, Inc.
Mr. Corey Novak, Land Management Group, Inc.
Ms. Tara McPherson, NC DCM
Mr. Todd Bowers, USEPA
Ms. Kathy Matthews, USFWS
Mr. Travis Wilson, NC WRC
Ms. Maria Dunn, NC WRC
Mr. Mac Haupt, NC DWR
Mr. Fritz Rohde, NMFS
Ms. Twyla Cheatwood, NMFS
Ms. Erin Davis, DWR
Mr. Robb Mair, NC DWR

LOWER CAPE FEAR UMBRELLA MITIGATION BANK
Updated Credit Release Tables - September 5, 2018
Table 1A. Credit Release for Riparian (Riverine) Wetland Enhancement and Restoration
(SNEEDEN TRACT')
Projected
Percentage of Wetland
Credits
Cumulative
Task
Credits Released (%
Credits
Completion Date
cumulative)
Released
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
1.58
1.58
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
15 (30)
1.57
.15
Biolo ical Im rovements3.0
P4.2
Year 1: Fulfill Success
1/2015
10(40)
1.05
Criteria
4.0 Year 2: Fulfill Success
1/2016
15 (55)
1.58
5.78
Criteria
5.0 Year 3: Fulfill Success
1/2017
20 (75)
2.10
7.88
Criteria
6.0 Year 4: Fulfill Success
1/2018
10 (85)
1.05
8.93
Criteria
7.0 Year 5: Fulfill Success
1/2019
15 (100)
1.57
10.5
Criteria
TOTAL
100%
10.5
10.5
Table 1B. Credit Release for Riparian (Riverine) Wetland Preservation - SNEEDEN TRACT
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (/o
Released
Credits
cumulative
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
12.1
12.1
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
85 (100)
68.5
68.5
Biological Improvements
TOTAL
100%
80.6
80.6
Table 1C. Credit Release for Riparian (Non-Riverine) Wetland Preservation - SNEEDEN TRACT
Projected
Percentage of WetlaTredits
Cumulative
Task
Completion Date
Credits Released (leasedCredits
cumulative
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)0.1
0.1
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
85 (100)
0.7
0.7
Biological Imrovements
TOTAL
100%
0.8
0.8
Refer to Table 3 (p. 5) of MBI for original credit release schedules for the Sneeden Tract.
Page 1 of 5 Pages

Tahle l )_ Credit Release Rchednle for Stream Restoration — SNF,FDF,N TRACT
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (%
Released
Credits
cumulative
Released
1.0 Signing of the MBI;
Recordation of Conservation
11/30/12
15 (15)
366
366
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
15 (30)
366
732
Biological Imrovements
3.0 Year 1: Fulfill Success
1/2015
10 (40)
244
976
Criteria
4.0 Year 2: Fulfill Success
1/2016
10 (50)
244
1,220
Criteria
5.0 Year 3: Fulfill Success
1/2017
10 (60)
244
1,464
Criteria
6.0 Year 4: Fulfill Success
1/2018
10 (70)
244
1,708
Criteria
7.0 Year 5: Fulfill Success
1/2019
15 (85)
366
2,074
Criteria
8.0 Documentation of Two
Bank -full Events in Separate
TBD
15 (100)
367
2,441
Years
TOTAL
100%
2,441
2,441
Tnhle lT.. Credit Release Srhednle for Stream Preservation — BNF,FDF,N TRACT
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (%
Released
Credits
cumulative
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
132
132
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
85 (100)
751
751
Biological Imrovements
TOTAL
100%
883
883
Page 2 of 5 Pages

Table 2A. Credit Release Schedule for Ri arian on-Riverine Forested Wetlands - WHITE SPRINGS'
Percentage of Wetland
Credits
Cumulative
TaskProjected
Completion Date
Credits Released (%
Released
Credits
cumulative)
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
0.3
0.3
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
2/2015
15 (30)
0.3
0.6
Biological Imrovements
3.0 Year 1: Fulfill Success
1/2016
10 (40)
0.2
0.8
Criteria
4.0 Year 2: Fulfill Success
1/2017
10 (50)
0.1
0.9
Criteria
5.0 Year I Fulfill Success
1/2018
10 (60)
0.2
1.1
Criteria
6.0 Year 4: Fulfill Success
1/2019
10 (70)
0.1
1.2
Criteria
7.0 Year 5: Fulfill Success
1/2020
10 (80)
0.2
1.4
Criteria
8.0 Year 6: Fulfill Success
1/2021
10 (90)
0.2
1.6
Criteria
9.0 Year 7: Fulfill Success
1/2022
10 (100)
0.2
1.8
Criteria
TOTAL
100%
1.8
1.8
Table 2B. Credit Release for Non -Riparian on -Forested Wetlands - WHITE SPRINGS
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (%
Released
Credits
cumulative
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
9.66
9.66
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
2/2015
15 (30)
9.66
19.32
Biological Imrovements
3.0 Year 1: Fulfill Success
1/2016
10 (40)
6.44
25.76
Criteria
4.0 Year 2: Fulfill Success
1/2017
15 (55)
9.66
35.42
Criteria
5.0 Year 3: Fulfill Success
1/2018
20 (75)
12.88
48.3
Criteria
6.0 Year 4: Fulfill Success
1/2019
10 (85)
6.44
54.74
Criteria i
7.0 Year 5: Fulfill Success
1/2020
15 (100)
9.66
64.41
Criteria
TOTAL
100%
64.41
64.41
' Refer to Table 2 (p. 5) of MBI for original credit release schedules for the White Springs Tract.
Page 3 of 5 Pages

Table 2C. Credit Release Schedule for Stream Restoration — WHTTE SPRINGS
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (%
Released
Credits
cumulative)
Released
1.0 Signing of the NMI;
Recordation of Conservation
11/30/12
15 (15)
226.2
226.2
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
2/2015
15 (30)
226.2
452.4
Biological Improvements
3.0 Year-1: Fulfill Success
1/2016
10 (40)
150.8
603.2
Criteria
4.0 Year 2: Fulfill Success
1/2017
10 (50)
150.8
754.0
Criteria
5.0 Year 3: Fulfill Success
1/2018
10 (60)
150.8
904.8
Criteria
6.0 Year 4: Fulfill Success
1/2019
10 (70)
150.8
1,055.6
Criteria
7.0 Year 5: Fulfill Success
1/2020
15 (85)
226.2
1,281.8
Criteria
8.0 Documentation of Two
Bank -full Events in Separate
TBD
15 (100)
226.2
1,508.0
Years
TOTAL
100%
1,508 1
1,508
Page 4 of 5 Pages

Table 2- Mitivation Tvne and Ouantitv (acres/I1)— WHITE SPRINGS TRACT
Community Type
Mitigation Type
Tract Quantity ac.ltf)
Credits
First -Order Stream
Restoration
White Springs 1,334
1,334
First -Order SBCF
Restoration
White Springs N/A
174
Riparian Wetlands
Restoration
White Springs 1.8
1.8r
(Non-Riverine Small Stream Swamp)
.
Non -Riparian Wetlands
Restoration
White Springs 64.41
64.41
(Pcosin/Wet Pine Savanna)
Stream Credits
1,508
Riparian Wetland Credits
1.8r
Non -Riparian Wetland Credits
64.41r
*r = restoration credit: re = restoration=eauivalent credit
Table 3. Mitigation Type and Quantity (acres/I1) — SNEEDEN TRACT
Community Type Mitigation Type Tract Quantity ac./IQ Credits
First -Order Stream
Restoration
Sneeden
2,441
2,441
First -Order Stream
Preservation
Sneeden
1,843
737
Zero -Order Stream
Preservation
Sneeden
366
146
Riparian Wetlands .
Riverine Cypress -Gum Swamp
Restoration
Sneeden
.5
.5r
Riparian Wetlands
Riverine Cypress -Gum Swamp
Enhancement
Sneeden
20
10re
Riparian Wetlands
Riverine Cypress -Gum Swam
Preservation
Sneeden
403
80.6re
Riparian Wetlands
Non-Riverine Small Stream Swamp
Preservation
Sneeden
4
0.8re
Total Stream Credits
3,324
Total Riparian Wetland Credits
91.9
*r = restoration credit; re = restoration=equivalent credit
Table 4. Mitigation Credits by Stream and Wetland Type
Mitigation Type
Quantity (If/ac)
Credits
Scream
5,984
4,832
Riparian Non-Riverine Wetland
5.8
2.6
Riparian Riverine Wetland
423.5
91.1
Non -Riparian Wetland
64.41
64.41
Page 5 of 5 Pages