20180199 Ver 1_eApproval Letter_20200630

Strickland, Bev
From:
Browning, Kimberly D CIV USARMY CESAW (USA)
<[e-mail]>
Sent:
Tuesday, June 30, 2020 8:56 AM
To:
Baumgartner, Tim
Cc:
Kayne Vanstell; Catherine Manner; Crocker, Lindsay; Tugwell, Todd J CIV USARMY
CESAW (US); Davis, Erin B; Bowers, Todd; Wilson, Travis W.; Hopper, Christopher D CIV
(USA); Gibby, Jean B CIV USARMY CESAW (USA); McLendon, C S CIV USARMY CESAW
(USA); Crumbley, Tyler A CIV USARMY CESAW (USA); [e-mail];
Merritt, Katie; Haywood, Casey M CIV USARMY CESAW (USA)
Subject:
[External] eApproval Letter / NCDMS Buffalo Creek Tributaries Site/ Johnston County/
SAW-2018-00425
Attachments:
Draft Mit Plan Comment Memo_Buffao Creek Tribs_SAW-2018-00425.pdf; eApproval
Letter -Buffalo Creek Tribs_SAW-2018-00425.pdf
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Mr. Baumgartner,
Attached is the Buffalo Creek Tribs Draft 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.
Respectfully,
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 (r)

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
June 10, 2020
SUBJECT: Buffalo Creek Tributaries 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: Buffalo Creek Tributaries Mitigation Site, Johnston County, NC
USACE AID#: SAW-2018-00425
NCDMS #: 100042
30-Day Comment Deadline: May 10, 2020
DWR Comments, Mac Hauat:
1. Section 2- Watershed Approach- this section mentioned an area being developed into a
subdivision on stream right near the bottom of MS-R2. One of the Figures (7e) shows a
stormwater pond built at the edge of the development, please make sure the designer is aware
of where the outlet will drain into the conservation easement and take the necessary design
steps to account for the stormflow input.
2. Section 3.1.4- Benthic Macroinvertebrates and Aquatic Habitat-DWR likes the fact that
monitoring of macrobenthics will occur.
3. Table 8- Existing Channel Morphology Summary- DWR notes that all the R tributaries have small
drainage areas. DWR noted that stream gauges will be placed on R4 and R6. Does WLS have
any concerns regarding the stormwater ponds regulating the flow for R4 and R5? Please realize
that if DWR notes any flow issues at any time during the project construction or monitoring
phase, we may require more flow gauges be installed on the other tributaries (R3 and/or R5) as
well.
4. Section 3.4.5- Jurisdictional WOTUS- and Section 6.4- Wetland Design Approach- and Appendix
9- after review of the document, discerning the initial amount of jurisdictional wetlands seemed
to be a major issue. Recalling the site visit, it seems there were more jurisdictional wetlands than
represented on the second PJD. While we did not recall as many wetlands as represented on
the first PJD. In addition, evidently the Technical Proposal showed more
rehabilitation/enhancement wetlands as well. DWR accepts the current approach, however; it
did raise red flags as to how many jurisdictional wetlands were on site initially. With the concerns
about the status of the current wetlands and the proposed wetland re-establishment, DWR will
be reviewing closely the wetland gauge (see comment #8) data.

5. Section 6.5.2- Planting Material and Methods- DWR expects the site to be planted by March 15.
If planting is desired to be done at a later date, the IRT should be notified. Planting at the end
of May will not be accepted.
6. Section 8.2.1- Hydrologic Monitoring-DWR prefers pressure transducers to crest gauges to
monitor overbank flooding. Especially with this project where the stream channel is expected to
be lifted and the flood frequency increased, we would like to see a more accurate form of
measurement utilized.
7. Section 8.3 and 8.4 Wetland and Vegetation Monitoring- DWR requires more wetland gauges
be installed on this project. Given the back and forth regarding the PJD, more gauges are
essential to confirm the extent of the wetland re-establishment proposed. There should be at
least nine wetland gauges. DWR requires the addition of 5 more wetland monitoring gauges.
In addition, there should be more vegetation plots. Currently you are showing 5, none are
located at the bottom of MS-R2. DWR recommends at least 8-10 vegetation plots. Please note,
some of these can be random plots.
8. Photos- from the photos it seems a new (large) culvert was installed. DWR is hoping your
designer was in touch with these folks regarding the desired culvert invert elevations.
9. Appendix 3- Typically, DWR likes to see the final conservation easement before final approval
of draft mitigation comments.
10. Design sheet 3- DWR is not crazy about the streambank slopes shown on your typical cross
sections. The slopes seem abit steep, I believe we made this comment previously.
11. Design sheet Typicals- DWR did not find the vernal pool typical.
12. Design sheets 8-12- after review of these sheets, it appears that the channel bed is being raised
2-3 feet. Is this correct? DWR is expecting significantly increased overbank flooding to increase
the hydrology of the adjacent wetlands.
13. Please realize any cut over 12 inches adjacent to the channel area will result in a change of
wetland approach from re-establishment to creation.
USACE Comments, Kim Browning:
1. On future projects, please keep the same stream and wetland labels throughout the life of the
project. It's difficult to refer to notes from the technical proposal and compare them to the JD
and mitigation plan when labels change.
2. Reach R5: Is a BMP being planned to address the runoff from the sheep pen upstream at the
school?
3. Reach MS-R2: There is some concern with the loss of slope and sedimentation. Please include
fixed photo points along this reach to document stream channel characteristics.
4. Section 6.5: Please identify the target community types.
5. Section 6.5.2: Please reference the planting window specified in the 2016 NCIRT Mitigation
Update Guidance.
6. Table 20: In regard to the note indicating species substitutions may occur due to availability or
refinement, please re -line the As -Built and MYO report if substitutions occur.
7. Please place a veg plot in W3. Additionally, please add random plots along reaches R6 and R5.
8. Reach R4: Given that this reach is currently ephemeral, it's suggested that additional photos or
video footage be submitted during monitoring to supplement flow data.
9. Section 3.4.5: When submitting the 404 permit applications, please submit that through DMS.
The PJD should be submitted to Chris Hopper in the Raleigh Regulatory Office
10. Section 3.1.4: I'm pleased to see that benthic monitoring will occur. Please indicate the location
of sampling on Figure 10. Additionally, if you plan to request additional credit for this monitoring,
please adjust the credit tables accordingly.
11. Please add a section regarding potential future risks and uncertainties, such as adjacent
development or logging, beaver, sewer/water line maintenance, beaver impacts, road/culvert
maintenance.

12. Section 7.1 Stream profiles, vertical stability, floodplain access section: This standard should
apply to all reaches where the channels were adjusted to reference conditions through design
and construction, to include both restoration and El reaches.
a. Page 47, first paragraph: please QA this paragraph for wording.
13. Section 8.1: Please show the location of the fixed photo points on Figure 10. If cross -sections
are to be used for photo points, please indicate in the text. Additionally, it would be helpful to
have photo points at crossings to show the condition of the culverts.
Digitally signed by
BROWN ING.KIMBERLY. BROWN ING.KIMBERLY.DANIELLE.152
DANIELLE.1 52768351 0 7683510
Date: 2020.06.11 14:43:58-04'00'
Kim Browning
Mitigation Project Manager
Regulatory Division

REPLY TO
ATTENTION OF:
Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON. NORTH CAROLINA 28403-1343
June 29, 2020
Re: NCIRT Review and USACE Approval of the NCDMS Buffalo Creek Tributaries Mitigation
Site / Johnson Co./ SAW-2018-00425/ NCDMS Project # 100042
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 Buffalo Creek Tributaries Draft Mitigation
Plan, which closed on May 10, 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,
signed by
BROWN INGXIMBERLY. ROWINING.KIMBERLY.DANIELLE.1527
DANIELLE.1527683510 3510 Date:2
Date: 2020.06.29 15:42:19-04'00'
Kim Browning
Mitigation Project Manager
for Tyler Crumbley
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
Lindsay Crocker—NCDMS
Catherine Manner, Kayne Van Stell—WLS