20181271 Ver 1_eApproval Letter_20201005

Strickland, Bev
From:
Browning, Kimberly D CIV USARMY CESAW (USA)
<[e-mail]>
Sent:
Monday, October 5, 2020 11:41 AM
To:
Baumgartner, Tim
Cc:
Phillips, Kelly D; Aaron Earley; Wiesner, Paul; Shawn Wilkerson; Tugwell, Todd J CIV
USARMY CESAW (US); Davis, Erin B; Wilson, Travis W.; Bowers, Todd; Haywood, Casey
M CIV (USA); Byron Hamstead; Leslie, Andrea J; Merritt, Katie; Jones, M Scott (Scott)
CIV USARMY CESAW (USA); McLendon, C S CIV USARMY CESAW (USA); Smith, Ronnie
D CIV USARMY CESAW (USA)
Subject:
[External] eApproval Letter/ NCDMS Honey Mill Mitigation Site/ Surry Co./
SAW-2018-01789
Attachments:
Draft Mit Plan Comment Memo -Honey Mill_SAW-2018-01789.pdf; eApproval
Letter -Honey Mill_SAW-2018-01789.pdf
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Mr. Baumgartner,
Attached is the Honey Mill 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.
V/R,
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers

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
September 15, 2020
SUBJECT: Honey Mill 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: Honey Mill Mitigation Site, Surry County, NC
USACE AID#: SAW-2018-01789
NCDMS #: 100083
30-Day Comment Deadline: August 22, 2020
WRC Comments, Andrea Leslie:
1. As noted previously in an early review letter provided directly to the applicant, wild trout
reproduction should not be impacted by this project, and a trout moratorium is not needed.
2. Sambucus nigra is a European species of elderberry, but sometimes the native elderberry is
included in this group. Ensure that they are using the native elderberry (Sambucus canadensis).
3. Sweetbay magnolia is primarily a coastal plain species. Although it might be found in rare
seepage wetlands in this part of the state, it would not occur as a native species on typical stream
banks.
4. Lindera melissifolia is a federally listed species of boggy coastal plain sites. Do they mean
Lindera benzoin, which would be a fine understory planting?
5. River birch is not often found on small streams — it's typically associated with large rivers. Unless
it is found on site already, we recommend eliminating it and replacing it with something else.
6. Acer negundo is also typically associated with larger streams, as well.
7. Eliminate silver maple from the planting list —it is very limited in North Carolina, and it wouldn't
be found on small streams.
8. Cut down on the % of sycamore planted (20% of stems).
9. It appears that `riparian planting' areas will not include understory species. The `shaded
supplemental planting' list has a nice diversity of subcanopy and shrub layers — we recommend
bringing some of these species into the `riparian planting' areas. Could they include other
species already found on site in the riparian planting list?

WRC Comments, Travis Wilson:
1. The draft plan does not include a detail of the stream crossings. It states the crossings are all
existing utility, ford, or culvert crossing but then mentions the culverts will be buried. Therefore
I am assuming the crossing locations are existing but the structures will be reset to the
restored profile. If that is the case a detail showing the ford crossing and the culvert crossing
should be included.
EPA Comments, Todd Bowers:
1. 1 wish to convey that I while I understand that Surry County is considered "mountain" for the
purposes of generating mitigation credit, this site does not seem to meet the qualification of
a "mountain stream" but rather a "piedmont stream". I have several reasons for this
consideration.
■ The site elevation ranges within the current proposed conservation easement
between approximately 980- and 1,050-feet above sea level. According the NC
Wildlife Resources Commission, "the piedmont physiographic ecoregion
elevations range from about 1,500 feet in the foothills to about 200 feet at the
fall line." This site would be located in the piedmont from that perspective.
■ According to the sponsor and the draft mitigation plan, "the Site is located in
the Tugaloo terrane of the Piedmont physiographic province (NCGS, 2018).
The Piedmont Province is characterized by rolling, well rounded hills and long
low ridges, with elevations ranging from 300 to 1500 feet above sea level."
■ Cool water streams, while more common in the mountains of North Carolina,
do exist widely in the NC piedmont.
■ Many of the reference sites used to guide restoration of the site streams are
located in the piedmont ecoregion. According to the sponsor, "due to the variety
of slopes and project stream types present on the Site, the distribution of
reference reaches is wide, throughout North Carolina's foothills and western
Piedmont."
■ The NC SAM zone used to evaluate the streams within the project boundaries
is listed as "Piedmont".
■ According to Section 7.3.5 (Page 15-16), Wildlands developed a regional flood
frequency analysis tool that tailored the USGS 2009 publication "Magnitude
and Frequency of Rural Floods in the Southeastern United States, through
2006" to the Piedmont of North Carolina and used several gages located in the
Piedmont to develop flood frequency intervals for the project streams.
2. Since the site appears to have more piedmont than mountain characteristics, I highly
recommend that the sponsor reconsider the minimum buffer widths and conservation
easement boundaries of this project. The draft mitigation plan lists several instances where
discreet constructed BMPs are needed to offset drainage and polluted runoff from the
surrounding landscape. The land surrounding the site will continue to be used for livestock
grazing following the establishment of the conservation easement and completed fencing.
The primary stressor on water quality for the project streams will continue to be runoff from
livestock excrement and the best BMP to counter this stress is wider vegetated stream
buffers. The sponsor even states on page 23 that additional floodplain vegetation would lower
the risk to the site from agricultural runoff. Therefore, I recommend that the site incorporate
50-foot minimum riparian buffer widths. This will have the added effect of protecting the
stream floodplains and the pockets of wetlands contained within.
3. 1 recommend that the vegetation height requirement for satisfactory performance of
vegetative vigor be increased from 8 to 10 feet at the conclusion of the 7- year monitoring

period. The elevation of the project is not sufficiently high enough to warrant the use of the
lower standard used for mountain streams.
4. With the recommended wider buffers, I also recommend a corresponding increase in the
number of vegetation plots to monitor the vigor of planted trees.
5. The planting plan for the site appears adequate and appropriate for both canopy and
subcanopy species. Recommend listing the species that will be considered for the final height
requirement performance standard as some will not likely meet the 10-foot requirement at
the end of the proposed monitoring period; namely those considered for shaded
supplemental planting. I also recommend that any significant deviations from the planting
plan are approved by the IRT before purchase and planting.
USACE Comments, Kim Browning:
1. Figure 9: the veg plot on Venable Creek R2 should be relocated to the confluence of R3 and
UT2, to include the existing wetland.
2. Design sheets general note: Please ensure that when measuring the centerline of the channel
for crediting purposes that only one channel is measured at a confluence. An example is on
Sheet 2.36 where it appears that both channels are measured. Additionally, please ensure that
the centerline is used for crediting determination, not the thalweg. This is unclear on sheets 2.1
and 2.5.
3. Field notes indicate that the confluence of UT2 and UT2A is a wetland complex and would be
best suited as a wetland. This plan proposes single -thread restoration in this area. Please note
the concern of the IRT for this area to demonstrate wetland like characteristics and be willing
to document a single -thread channel throughout the monitoring period.
4. Page 6 discusses UT213; I'm unclear where this is on the Figures. (Perhaps it's the small
unlabeled line outside the easement?)
5. Section 7.2.4: It would be interesting to note the approximate number of mature trees that are
left on -site in areas where restoration will occur and note the survival rate of these existing
trees through the monitoring period. On the Agony Acres site, we noticed that a large number
of mature trees that were left in the buffer were actually damaged during construction and
began to die between MY4 and MY5. This is just an observation and the data would be
interesting to see, not just on this site.
6. Section 7.1: It would be beneficial to discuss the potential for utility line maintenance, and the
road culverts to be replaced/widened on Siloam Rd (UT1) and Little Mountain Church Rd
(Venable Creek R1). It appears that the conservation easement is at least 50 ft from the road
right-of-way, which is appreciated.
7. Section 7.9: There is some concern regarding the fact that the landowner is responsible for
installing the livestock watering facilities in relation to the fact that at least one of the crossings
is a ford crossing. Please confirm that these crossings will not be used for livestock access for
drinking if the landowner fails to install the watering tanks.
DWR Comments. Erin Davis:
1. Page 4, Section 3.2 — DWR appreciates that Surry County planning documents were reviewed
for this plan.
2. Page 6, Section 3.4 — Is the location of UT213 mapped on any of the plan figures? If not, can the
approximate location please be called out on Figure 2 (within and/or outside of the easement).
3. Page 9, Section 4.1 — There are five BMPs shown on Figure 9, but only four points of inputs are
mentioned in the text. Please clarify.
4. Page 10, Section 4.5 — There are two areas of Wetland C that aren't captured within the
conservation easement. Was protection of these resource areas discussed during site planning?

5. Page 11, Section 5.3 - DWR requests a groundwater gauge be installed in existing Wetland K
where hydrology may be impacted by proposed stream relocation in order to demonstrate no
significant functional loss of the resource.
6. Page 13, Section 7.1 - This section notes that wetland hydrology was assessed with
groundwater gages. I suspect this is a carryover, but if gage data is available please include it
in the final mitigation plan.
7. Page 21, Section 7.6 - DWR appreciates that an effort was made to capture the tributary origins
within the conservation easement. Please confirm whether the UT2 stream origin is included
(Sheet 2.12), and if it's not please explain why not (e.g. UT2A ends at property line).
8. Page 22, Section 7.8 - Please include at least one target community for the proposed planting
plan. DWR would like to see a mix of early successional native species and appropriate climax
species based on the designated target community.
9. Page 26, Table 15 - There are differences in the goals and objectives compared to Table 6.
Please review.
10. Page 29, Section 10 - DWR recommends an annual inspection of the site.
11. Page 30, Section 11 - Please confirm whether Wildlands or DMS would notify the NCIRT of site
issues.
12. Page 30, Section 12 - The memo referenced for the credit ratios includes a summary table in
which management objectives for UT2R1, UT2A, UT3R1, UT4, UT5, and UT6R1 specifies "spot
repair erosion and incision". However, only design sheets for UT4 show any stream work. Please
explain why spot erosion and incision areas identified during the proposal stage were not
addressed in the design stage.
13. Figure 9 - DWR requests the veg plot along Venable Creek Reach 2 be shifted downstream to
near the next set of cross sections along Reach 3.
14. Appendix 3 - Was NCWAM completed for the existing wetlands onsite? If so, please include the
corresponding forms. Also, two of the NCSAM rating sheets did not include an overall rating
score, please QAQC.
15. Sheet 0.3 - Please include roadway right-of-way boundary lines.
16. Sheet 2.1 - Are there any existing utility poles located within the internal crossing?
17. Sheet 2.2 - Will the existing farm road be relocated just outside of the easement? Are impacts
to Wetland B expected/accounted for?
18. Sheet 2.2 - The BMP detail (Sheet 6.9) includes an outlet channel, please show the approximate
location of this outlet channel on the plan view sheets (Sheets 2.2, 2.7 and 2.34).
19. Sheet 2.12 - The Enhancement II Treatment Note #4 is confusing to see on sheets that do not
show any grading (Sheets 2.12-2.15, 2.18-2.22, 2.24-2.26 and 2.32). If spot grading is proposed,
please show on the sheets.
20. Sheet 2.12 & 2.32 - Figure 2 indicates headcuts in the upper sections of UT2 and UT5. No
stream work is proposed for these reaches. Is further instability of these headcuts a concern?
Monitoring photo points may be helpful at these locations.
21. Sheet 2.16 - Please include a typical detail for the proposed culvert crossing.
22. Sheet 2.3 - DWR recommends that bench width be at least 1.5 times bankfull width. Particularly
of concern are the bench widths on the outer meander bends where much of the flow energy
vectors are directed.
23. Sheet 2.4 - UT2 and UT3 are designed to tie in to Venable Creek at meander bends rather than
riffle straights. Are there any long term stability concerns for these meander areas?
24. Sheet 2.8 - A ford crossing detail was not provided. With the existing bedrock I understand that
the streambed doesn't require reinforcement, but are the side slopes/access path areas stable?
Is any grading proposed? Will any riprap be placed along the banks?
25. Sheet 3.1 -
a. DWR questions whether sweetbay magnolia is an appropriate species for site based on
the species geographic range.

b. It would be helpful for our review to have the wetland indicator status included in the
tables.
c. DWR understands that quantity substitutions may be necessary based on the nursery's
species available. However, we request that no species (excluding live stakes) account
for more than 20 percentage of a specified planting zone in order to promote diversity
within the designated community type.
26. Sheet 6.9 — Will herbaceous plugs be installed in the shallow water planting zone of the
bioretention cells? I think fox sedge is the only OBL species in proposed seed mix.
27.Are channel plugs proposed? If so, please indicate approximate locations and include a typical
detail.
28. Please include an overall fencing plan indicating existing and proposed fencing and approximate
locations of anticipated gates.
BROWNING.KIMBER Digitally signed by
LY.DANIELLE.15276 BROWN INGXlMBERLY.DANIELLE.
1527683510
83510 Date: 2020.09.15 16:13:13-04'00'
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
October 5, 2020
Re: NCIRT Review and USACE Approval of the NCDMS Honey Mill Mitigation Site / Surry Co./
SAW-2018-01789/ NCDMS Project # 100083
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 Honey Mill Draft Mitigation Plan, which closed
on August 22, 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
BROWN INGXIMBERLY. BROWN ING.KIMBERLY.DANIELLE.
DAN I ELLE.1527683510 1527683510
Date: 2020.10.05 11:36:16-04'00'
Kim Browning
Mitigation Project Manager
for Ronnie Smith, Deputy Chief
USACE Regulatory Division
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
Paul Wiesner, Kelly Phillips—NCDMS
Aaron Earley—WEI