HomeMy WebLinkAbout20181032 Ver 1_USACE eApproval Letter_20200612Strickland, Bev
From: Browning, Kimberly D CIV USARMY CESAW (USA)
<Kimberly.D.Browning@usace.army.mil>
Sent: Friday, June 12, 2020 11:38 AM
To: Baumgartner, Tim
Cc: Reid, Matthew; Wiesner, Paul; Eric Neuhaus; John Hutton; Tugwell, Todd J CIV
USARMY CESAW (US); Davis, Erin B; Merritt, Katie; Byron Hamstead
(byron_hamstead@fws.gov); Bowers, Todd; Wilson, Travis W.; Crumbley, Tyler A CIV
USARMY CESAW (USA); Brown, David W CIV USARMY CESAW (USA); McLendon, C S
CIV USARMY CESAW (USA); Jones, M Scott (Scott) CIV USARMY CESAW (USA); Leslie,
Andrea J; Xu, Lin; Haywood, Casey M CIV USARMY CESAW (USA)
Subject: [External] eApproval Letter/ NCDMS Banner Farm Mitigation Site/ Henderson Co./
SAW-2018-01153
Attachments: Draft Mit Plan Comment Memo -Banner Farm_SAW-2018-01153.pdf; eApproval
Letter -Banner Farm_SAW-2018-01153.pdf
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
report.spam@nc.gov
Mr. Baumgartner,
Attached is the Banner Farm Mitigation Plan approval letter and copies of all comments generated during the project
review. Please note that this letter approves the Draft Mitigation Plan provided that the Final Mitigation Plan
adequately addresses all comments on the attached memo. Please provide a copy of the Final Mitigation Plan when you
submit the Preconstruction Notice for the NWP 27. If no permit is required to construct the project, please submit a
copy of the Final Mitigation Plan to our office at least 30 days prior to beginning construction. Also, please ensure that a
copy of the Final Mitigation Plan is posted to the NCDMS project documents so that all members of the IRT have access
to the Final plan.
Please let me know if you have any questions about the process or the attached letter.
Have a good weekend,
Kim
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers
3331 Heritage Trade Dr, Ste. 105 1 Wake Forest, NC 27587 1 919.554.4884 x60
BUILDING STRONG
REPLY TO
ATTENTION OF:
Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON. NORTH CAROLINA 28403-1343
June 12, 2020
Re: NCIRT Review and USACE Approval of the NCDMS Banner Farm Mitigation Site /
Henderson Co./ SAW-2018-01153/ NCDMS Project # 100062
Mr. Tim Baumgartner
North Carolina Division of Mitigation Services
1652 Mail Service Center
Raleigh, NC 27699-1652
Dear Mr. Baumgartner:
The purpose of this letter is to provide the North Carolina Division of Mitigation Services
(NCDMS) with all comments generated by the North Carolina Interagency Review Team
(NCIRT) during the 30-day comment period for the Banner Farm Draft Mitigation Plan, which
closed on May 8, 2020. These comments are attached for your review.
Based on our review of these comments, we have determined that no major concerns
have been identified with the Draft Mitigation Plan, which is considered approved with this
correspondence. However, several minor issues were identified, as described in the attached
comment memo, which must be addressed in the Final Mitigation Plan.
The Final Mitigation Plan is to be submitted with the Preconstruction Notification (PCN)
Application for Nationwide permit approval of the project along with a copy of this letter. Issues
identified above must be addressed in the Final Mitigation Plan. All changes made to the Final
Mitigation Plan should be summarized in an errata sheet included at the beginning of the
document. If it is determined that the project does not require a Department of the Army permit,
you must still provide a copy of the Final Mitigation Plan, along with a copy of this letter, to the
appropriate USACE field office at least 30 days in advance of beginning construction of the
project. Please note that this approval does not preclude the inclusion of permit conditions in
the permit authorization for the project, particularly if issues mentioned above are not
satisfactorily addressed. Additionally, this letter provides initial approval for the Mitigation Plan,
but this does not guarantee that the project will generate the requested amount of mitigation
credit. As you are aware, unforeseen issues may arise during construction or monitoring of the
project that may require maintenance or reconstruction that may lead to reduced credit.
Thank you for your prompt attention to this matter, and if you have any questions
regarding this letter, the mitigation plan review process, or the requirements of the Mitigation
Rule, please call me at 919-554-4884, ext 60.
Sincerely,
Digitally signed by
BROWNING.KIMBERLY. BROWN ING.KIMBERLY.DANIELLE.1527
DANIELLE.1 52768351 0 683510
Date: 2020.06.12 11:32:36-04'00'
Kim Browning
Mitigation Project Manager
for Tyler Crumbley
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
Matthew Reid, Paul Wiesner—NCDMS
Eric Neuhaus, John Hutton—WEI
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
REPLY TO
ATTENTION OF:
CESAW-RG/Browning
MEMORANDUM FOR RECORD
May 28, 2020
SUBJECT: Banner Farm Mitigation Site - NCIRT Comments during 30-day Mitigation Plan Review
PURPOSE: The comments listed below were received during 30-day comment period in accordance
with Section 332.8(g) of the 2008 Mitigation Rule in response to the Notice of NCDMS Mitigation Plan
Review.
NCDMS Project Name: Banner Farm Mitigation Site, Henderson County, NC
USACE AID#: SAW-2018-01153
NCDMS #: 100062
30-Day Comment Deadline: May 8, 2020
DWR Comments, Mac Haupt & Erin Davis:
1. Page 3, Section 3.3 — It's stated that watershed processes and stressors from outside the project
are likely to remain consistent through project closeout. What about after closeout? Please
consider potential future land use changes in evaluating project risks and uncertainties for long-
term site stability and protection (e.g. risk of encroachment). This could include consulting utility
companies, local/county planning departments and NCDOT on anticipated projects in the
vicinity.
2. Page 6, Table 5 — Wetland restoration requires the uplift of multiple functions. Shouldn't
hydrologic and vegetative methods be listed for wetland areas proposed for restoration?
3. Page 9, Section 3.6 — For existing culvert crossings proposed to remain, please include a
description of their current condition to confirm that sizing is appropriate and that they are not
perched, buried or otherwise inhibiting aquatic passage.
4. Page 13, Section 5.0 — This Plan does not include a "Site Constraints to Functional Uplift"
subsection. DWR considers easement breaks as site constraints since fragmentation impacts
the site's potential functional uplift. Please include a discussion on the coordination completed
to minimize the quantity and width of proposed stream crossings. Is herbicide spraying a
standard maintenance activity implemented within these utility corridors?
5. Page 33, Section 8.6.4 — DWR is concerned with proposed wetland restoration areas
represented by cross-section #4 on Sheet 3.4 and cross-section #6 on Sheet 3.5 where 2-3 feet
of soil will be excavated. DWR supports a wetland creation credit ratio of 3:1 for areas excavated
more than 12 inches. Additionally, DWR is concerned about the drainage effect these cut areas
will have on adjacent proposed wetland restoration areas and we request groundwater gauges
be placed to demonstrate the attainment of the 12% hydroperiod.
6. Page 35, Section 8.7.1 — The proposed work on Banner Creek Reach 1 appears more
associated with an Enhancement 1 approach, additional justification is needed to support
Restoration credit. DWR is concerned about tree mortality if a restoration scale approach is
implemented.
7. Page 34, Section 8.7.1 — Since establishment of vegetative cover and vigor can be a challenge
on Priority II restoration banks/benches, please include a discussion on how the soil restoration
will be addressed during construction and reference potential adaptive management.
8. Page 36, Section 8.7.2 — DWR would like to see trees removed during construction, which are
not used for in -stream structures or habitat, be scattered as LWD within wetland restoration
areas. Also, wetland areas should be disked to reduce compaction and DWR would prefer
furrows not exceed a depth of 6 inches.
9. Page 36, Section 8.8 —
a. Please identify the target community types.
b. Please indicate if fescue will be treated prior to or during site construction. DWR
recommends early treatment based on observations of fescue impeding planted
vegetation establishment and vigor.
c. Please reference the planting window specified in the 2016 NCIRT Mitigation Update
Guidance.
10. Page 37, Section 8.9 — Please confirm whether any maintained pedestrian trails for future
hunting activities are proposed within the mitigation site. If so, approximate locations of trails
should be shown on the site figure or design drawings. DWR does not support any new vehicle
access paths/roads, including for ATV use, within the site.
11. Page 37, Section 8.10 — Table 17 is a helpful summary of easement break information, could
you possibly add whether the breaks include culvert crossings and if the culverts will remain or
be replaced. Also, based on the number of Duke Energy utility easement breaks and the
proposed work to be completed within their easements (e.g. channel filling, culvert removal),
please provide a brief summary of the coordination and authorization process.
12. Page 39, Section 9.4 — DWR appreciates that gauge ground surface elevation and soil profile
data will be recorded and included in the MYO Report.
13. Page 40, Section 10.0 — DWR requests the inclusion of red -line drawings in the baseline
monitoring report comparing record drawings to final mitigation plan design sheets.
14. Page 41, Table 18 — Please remove the phrase "based on the soil type". The proposed 12%
hydroperiod applies to all wetland restoration areas as stated in Section 9.4.
15. Page 42, Section 10.1 — Please also include visual monitoring photo locations at proposed
crossings.
16. Page 43, Section 11.0 —
a. Please specific an expected maximum duration between "periodic" inspections.
b. Adequate signage should be installed along CE boundaries abutting utility corridors and
road right-of-ways that are regularly maintained. Of particular concern are the two cut
outs for individual utility poles along Banner Farm Road.
17. Page 44, Section 12.0 — Please include the IRT/DWR in adaptive management planning
coordination.
18. Page 44, Section 13.0 — DWR would support a 2:1 ratio for wetland rehabilitation areas as being
more representative of the functional uplift delta based on existing wetland hydrology, soils and
vegetation.
19. Figure 10 — DWR requests one additional gauge and five groundwater gauge relocations — see
figure markup (attached).
20.Appendix 7 — Please include the coordinates for the Sierra Nevada well location.
21.Appendix 8 —
a. Sheet 0.3 — For clarity, can you please reference the "CR, JR, CH, RR" used within the
proposed bankfull icon on the plan views.
b. Sheet 0.3 — It would help our review to see the existing channel areas proposed to be
filled as a shaded feature on the plan view sheets.
c. Sheet 2.1.4 — There appears to be an existing stormwater pipe that discharges within the
proposed easement. Please confirm that this structure will be removed.
d. Sheet 2.2.1 — Please explain the design rationale for starting UT1 west of the existing
channel rather that to the east. The original concept plan shows the UT1 relocated east
of the existing channel where there appears to be area to achieve moderate sinuosity
between stream crossing constraints. DWR is concerned about the current design's high
sinuosity with regard to long-term stability and adequate sediment transport.
e. Sheet 4.1 —
i. American beech is listed twice under the open area buffer planting.
ii. Please confirm that the appropriate stratum is listed for the buffer zone species.
iii. DWR appreciates the diversity of species and stratum incorporated into the buffer
and riparian zone planting lists. However, the wetland planting zone accounts for
approx. 80% of the site's planting area and only has 6 species proposed, of which
3 species comprise 75% of the total stems. Since red maple is already present at
the site, it should be removed from the planting list. DWR requests that the wetland
planting list be revisited to enhance species and stratum diversity, with no single
species comprising more than 20%.
f. Sheet 6.2 — DWR recommends footer logs be incorporated in all log sills.
g. Sheet 6.3 — Please rename Lunker Log or Cover Log for consistency with legend icon.
h. Sheet 6.4 — Where is channel stabilization (fully lined with erosion control matting)
proposed?
22.Appendix 9 — DWR appreciates the removal technique details included. The kudzu and bamboo
onsite are particularly concerning. Please identify which species were treated and where in the
annual monitoring reports.
23.Appendix 10 — DWR appreciated the site -specific maintenance plan, including mention of visits
after major flooding events.
NCWRC Comments, Andrea Leslie:
1. There will not be a trout moratorium required for this project.
2. The reestablishment and rehabilitation of nearly 40 acres of wetland in the French Broad
floodplain is very exciting. Many of the French Broad floodplain wetlands have been lost, and
this project has the opportunity to provide an important ecological role for the area, especially in
terms of habitat.
3. Please provide a single map that shows the planting plan for the entire site, noting where the
different zones of plantings will occur (e.g., wetland, open area buffer planting, partially
vegetated area buffer planting, riparian planting).
4. We appreciate the planting plan for the open area buffer, partially vegetated area buffer, and
riparian planting zones. Good attention has been given to canopy, shrub/subcanopy, and
herbaceous strata. We recommend removing silver maple from the planting list, as it can be
invasive. It is known from wetlands in Henderson County, but it will likely come in on its own.
5. However, the wetland planting plan only consists of 6 tree species, with no other strata (including
herbaceous) addressed. As the wetland acreage of this site is significant, we ask the designer
to round out their wetland planting plan with other strata and with a more diverse tree list. Were
the Sierra Nevada wetland and Henry Fork wetland used as plant reference sites? If so, the
Henry Fork site may not be the best reference for vegetation, given it is a piedmont site. Given
its setting, we recommend gearing this to the Montane Alluvial Forest Large River Subtype in
the Guide to the Natural Communities of North Carolina (see https://files.nc.gov/dncr-
nhp/documents/files/Natural-Community-Classification-Fourth-Approximation-2012.pdf
<Blockedhttps://files.nc.gov/dncr-nhp/documents/files/Natural-Community-Classification-
Fourth-Approximation-2012.pdf). NCWRC is open to working with Wildlands on the planting
plan.
6. We consulted with the NC Natural Heritage program and offer the following recommendations
on the planting plan:
a. Trees: Eliminate Willow Oak, as it is not a Blue Ridge species. We recommend
eliminating Red Maple as well, as it will come in on its own. Here is a list of tree species
that would be worthy additions — Box Elder, Black Willow, River Birch, Tulip Poplar,
Shingle Oak, Black Gum, Pitch Pine (on hummocks, higher ground). We recommend
bringing in at least 4 of these species into your planting plan.
b. Shrubs/understory trees: Develop a list of shrubs/smaller trees, considering Sweetspire,
Viburnum rufidulum, Viburnum prunifolium, Viburnum nudum, Leucothoe racimosa,
Leucothoe fontanesiana, Spice Bush, Buttonbush, Sweet Birch, Ironwood, American
Holly, River Birch.
c. Herbaceous species: We assume that the designer already has a set of species for the
wetland herbaceous layer that didn't make it into the plan. Worth adding to this list would
be Cinna arundinacea, Glyceria striata, Glyceria septentrionalis, Virginia Wildrye, River
Oats.
7. We encourage Wildlands to incorporate rivercane into their project. Rivercane is found on the
French Broad River floodplain; it has been eliminated from much of its former extent in western
NC, and there is a renewed effort to reestablish this species.
USACE Comments, Kim Browning:
1. Please add some discussion regarding the outlet at STA 37+97 to the French Broad River since
this area is prone to backwater flooding.
2. Figure 6 shows existing groundwater gages, while Figure 11 shows gages in different locations.
Will the existing gages still be monitored, or just moved during construction? It would be
beneficial to have gages in approximately the same areas to compare pre and post construction
data and justify functional uplift.
3. Please remove red and silver maple from the planting plan.
4. Table 5: It would be beneficial to show the current NCSAM rating in this table.
5. Rehabilitation areas indicate that hydrology is already above 12% and are currently jurisdictional
and providing wetland functions. This would be more appropriate for an enhancement ratio of
2:1 based on functional uplift.
6. Page 33: There is concern with proposed wetland restoration areas where more than 12" of soil
will be excavated. The text cites that 12% of reestablishment and 18% of rehab wetlands will be
graded deeper than 12", which is a considerable amount. Typically, these areas would be more
appropriate for a wetland creation credit ratio of 3:1; however, after receiving clarification from
WEI, I feel more comfortable that the grading is to support the slope requirements for the stream
restoration. Attached is additional information received from WEI to justify that the grading is not
for wetland hydrology needs.
7. Given the flat slope and the huge sediment load coming into the system from The French Broad
River, there is concern that without sufficient flow, the stream channels may fill in with sediment
and become more wetland -like.
a. Section 9.1.1: Recommend adding a performance standard to maintain channel
characteristics and an OHWM. Backwater flooding of the French Broad River will likely
cause aggradation, and clearing sediment and vegetation from the channel after
monitoring year two is not recommended.
8. Figure 6 shows Wetland T, but Figure 10 shows this area as a small tributary. Table 9 indicates
that this area will have a temporary impact of 0.04 ac from floodplain grading. Please clarify what
is happening in this area when submitting the PCN.
a. Additionally, please estimate the number or acres of trees to be cleared to address the
NLEB 4(d) rule.
b. When submitting the PCN, please combine all impacts by reach. For example, if there
are three 60' culverts on reach 1, list it as 180' of permanent impact rather than listing it
as three separate impacts. But permanent and temporary impacts still need to be
separated.
9. Reach 1, as presented, seems to be more appropriate as an enhancement level 1 reach at 1.5:1.
Please provide additional justification why this reach is proposed as restoration at 1:1.
10. Section 8.7.2: It would be beneficial to add some coarse woody debris to the depressional areas
in the buffers and throughout the adjacent wetlands for habitat, and to help store sediment,
increase water storage/infiltration, and absorb water energy during overbank events. I was
pleased to see the inclusion of wood in the stream design for habitat.
11. Section 8.8: In addition to the planting plan in the design sheets, it would be helpful to see a map
view of the different planting zones.
12. Section 8.9: It would be beneficial to add a discussion regarding utility line maintenance and
potential for the road culverts to be replaced in the future.
13. What is the situation with Banner Creek Reach 2, above Banner Farm Road, where no channel
work is proposed?
14.There is a section of Banner Creek Reach 3 that runs under the powerline. Please clarify that
this is a non -credited section.
15. Recommend adding a performance standard for invasive species to be less than 5% of the
conservation easement, and a zero tolerance for kudzu and bamboo.
16.Table 18: The IRT prefers the use of pressure transducers over crest gages.
BROWN INGXIMBERL Digitally signed by
Y.DANIELLE.1527683 BROWN INGXIMBERLY.DANIELLE.
1527683510
510 Date: 2020.05.28 15:57:25-04'00'
Kim Browning
Mitigation Project Manager
Regulatory Division
Memorandum to the Record
May 6, 2020
Agency Comments for the Banner Farm Stream and Wetland Mitigation Site
(SAW-2018-01153) Mitigation Plan Associated with the NCDMS In -Lieu Fee
Program in Henderson County, NC
Kim,
Thank you for the opportunity to provide feedback and comments on the Banner Farm Stream
and Wetland Mitigation Site (the Site or Project) Mitigation Plan as an addition to the North
Carolina Division of Mitigation Resources In -Lieu Fee Program (NCDMS ILF). Wildlands
Engineering, Inc., has presented a potentially suitable plan to provide compensatory mitigation
for jurisdictional wetland impacts associated with the US Army Corps of Engineers Clean Water
Act Section 404 permit program. The project involves the restoration of approximately 6,300
existing linear feet of incised and straightened streams and the restoration of over 35.7 acres of
historically altered wetlands. Restoration of project streams and wetlands will provide 6,294 cool
stream mitigation units (SMUs) and 34.8 wetland mitigation units (WMUs). The Site will be
protected by a 46.6-acre conservation easement and was selected by NCDMS to provide SMUs
and WMUs in the French Broad River Catalog Unit 06010105 (French Broad 05). No nutrient
offsets or riparian buffers are presented specifically for additional compensatory mitigation
credit.
Note: It is understood that site visits have been made by IRT members during the development of
site feasibility to provide mitigation credit. In that regard, I feel it necessary to denote that I have
not been on -site during this process and that my comments may reflect a lack of on -site
observation and evaluation.
The EPA Region 4 Ocean, Wetlands and Stream Protection Branch offers the following site -
specific comments as they pertain to the Banner Farm Draft Mitigation Plan dated April 1, 2020.
Page numbers refer to the entire pdf document offered for review:
• Section 6.0/Page 29 Regulatory Considerations:
o Recommend citing the Public Notice issued under Section 404 (SAW-2018-
01153) on August 28, 2018.
• Section 8.7/Page 35 Project Implementation:
o Sponsor may want to state actual buffer widths along Banner Creek. According to
the plans/drawings the buffer appears to be 50' in width along the entire Banner
Creek Reach 1. I wish to commend Wildlands for providing minimum buffer
widths of 50 feet or more throughout the project.
• Section 8.8/Page 50 Vegetation and Planting Plan (see Sheet 4.1 also)
o Sponsor needs to justify the choice of Quercus falcata var pagodifolia for this
site. That tree species is chiefly found in the coastal plain and is not known in NC
mountain counties such as Henderson. (source: Radford et. al. Manual of Vascular
Flora of the Carolinas 1964)
o Recommend removing Alnus serrulata listed as an Alternate and replaced with a
more suitable canopy reaching species.
• Section 8.9/Page 51 Project Risk and Uncertainties
o Has the sponsor considered expanding the project further south of the UT2
wetland area to capture more of the agriculture area and include it within the CE?
It sounds like the landowners would be fine with abandoning the field if they
could still hunt on it. Are there cost considerations and a lack of wetland credits
needed?
• Section 9.2/Page 53 Vegetation.
o Plot number (24 fixed and 12 mobile) and size (0.024 ac or 100m2) should be
included here. (per Table 19)
• Table 18/Page 55: Monitoring Plan
o Recommend adding stem heights for MY 5 and MY 7 in vegetation.
Thank you for the opportunity to provide feedback, comments and concerns with the Banner
Farm Stream and Wetland Draft Mitigation Site Plan in Henderson County, NC. The sponsor has
provided a potentially suitable plan to offset impacts and provide compensatory stream and
wetland credits to the NCDMS ILF program within the French Broad 05 watershed geographic
service area. If you or the sponsor have any questions or need clarification on any of the
comments stated above, please contact me at 404-562-9225 or at bowers.todd@epa.gov.
Best Regards,
Todd Bowers
Comments submitted to Kimberly Brown (SAW -PM) via email on May 6, 2020
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j Non -Project Streams
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Banner Farm Mitigation Site
1*,WILDLANDS 0 300 600 Feet French Broad River Basin 06010105
ENGINEERING I I I I
Henderson County, NC
From: Eric Neuhaus <eneuhaus@wildlandseng.com>
Sent: Thursday, May 28, 2020 1:27 PM
To: Browning, Kimberly D CIV USARMY CESAW (USA) <Kimberly.D.Browning@usace.army.mil>
Cc: Reid, Matthew <matthew.reid@ncdenr.gov>; John Hutton <ihutton@wild landseng.com>
Subject: Banner Farms Wetland Grading: Mit Plan Discussion
Kim,
I wanted to follow up after our phone conversation yesterday regarding Banner Farms, the potential
wetland grading, and the proposed crediting ratios within the submitted mitigation plan. I understand
the concerns regarding the wetland grading depths over 12 inches. As we discussed on the phone, the
grading within the proposed wetland areas is not dictated by wetland hydrology or the exposure of relic
hydric soils, but rather the removal of extensive agricultural manipulation and the overall function of the
stream/wetland complex as it relates to sediment transport and existing grade constraints.
Design evaluations and site observations indicate that a high sand load from the French Broad River is
regularly delivered to the project streams through either overbank events and/or backwater conditions.
Based on these observations, channel aggradation was identified as a fundamental risk to project assets,
particularly stream crediting. To alleviate this design risk, minimum bankfull stream slopes of 0.1% were
maintained for the designed channels. Pool slopes were held at zero, and riffles were shortened where
possible to increase slopes (>0.2%) and maintain adequate stream power to flush high sand loads from
the built channels incurred from the French Broad River. To maintain these slopes and work within
existing site constraints, grading over 12 inches was required within proposed wetland areas. The
grading was minimized as much as possible and only represents 4.47-acres of the proposed 35.78-acres
of restored wetland as indicated in the NCDMS comment responses and the associated wetland grading
exhibit provided with the NCDMS comments.
The upstream end of UT2, where the stream is being transitioned to a Priority 1 approach from the
Banner Farm Road culvert represents 0.5 acres of the cut that exceeds 12 inches. Additionally, the
agricultural berm/channel side cast material between the old channel of UT2 and the proposed
alignment of UT2, which can be seen in Sheet 3.3 in wetland cross sections 2 and 3 represents 1.2 acres
of cut that exceeds 12-inches. I highlight these areas to further emphasize that grading depths were a
product of stream design, site constraints, and agricultural manipulation. While I understand the
concern regarding the grading depths, I believe the design of the streams and their associated slopes is
pivotal to the success of the project as a stream and wetland complex.
If you have questions or want to discuss further, feel free to reach out.
Thanks!
Eric Neuhaus, PE I Water Resources Engineer
0: 828.774.5547 x105 M:865.207.8835
Wildlands Engineering, Inc.
167-B Haywood Road
Asheville, NC 28806
0' 150' 300' 450'
(HORIZONTAL)
Grading with cut greater than 12" depth
Grading with cut less than 12" depth
*Areas not shaded may be ungraded or fill areas.
Wetland Re-establishment Boundary
Wetland Rehabilitation Boundary
STA:200+18
START UT2 - RESTORATION
KIRBY & SHERRI JOHNSON
PIN:9539895929
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PIN:9630826726
\ DB: 1598 PG: 219
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END UT2 - RESTORATION
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END BANNER CREEK REACH 3 - RESTORATION
START BANNER CREEK REACH 4A- RESTORATION
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END BANNER CREEK REACH 1- RESTORATION / I
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PIN: 9630924395
DB: 3150 PG: 641
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PROPOSED WETLAND REHABILITATION BOUNDARY
STA:18+00 _ I
/ END BANNER CREEK REACH 2 - RESTORATION
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START BANNER CREEK REACH 3 - RESTORATION
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A i MOUNTAIN BEAN HOLDINGS, INC.
1`1 I PIN:9640028341
DB: 3150 PG: 641
cE CF TRACK 2
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STA:112+82
CF I END UT1- RESTORATION
STA:33+77
END BANNER CREEK REACH 4A- RESTORATION
START BANNER CREEK REACH 4B - RESTORATION 9
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E
STA:37+97
END BANNER CREEK REACH 4B - RESTORATION
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