20181096 Ver 1_RE Planting Modification Request_20210212

Strickland, Bev
From: Davis, Erin B
Sent: Friday, February 12, 2021 10:20 AM
To: Steve Kichefski (Steve [e-mail])
Subject: RE: [External] FW: [Non-DoD Source] Hair Sheep - Planting Modification Request.
Steve,
I've reviewed the information provided by KCI for their planting modification request. Unfortunately, I am not that
familiar with this site since Mac did the site walk, mitigation plan and permit application review. But I do agree with the
comments and concerns raised by Andrea, Travis and Todd Bowers. I do not believe bald cypress is appropriate for
planting a mitigation site in this ecoregion and in general coastal Plain community species should not be referenced for a
Surry County site. I would encourage an additional effort be made to locate a local reference community since I too
question their selected single target community. This may be a case for a mosaic wetland types where areas of
shrub/herb cover may be more appropriate than attempting a homogeneous forest community, and where site -specific
monitoring and success criteria can be discussed (e.g. vigor, diversity).
I look forward to visiting the site and discussing the asset modification next month.
Many thanks,
Erin B. Davis, PWS
Stream & Wetland Mitigation Coordinator
401 & Buffer Permitting Branch
Division of Water Resources
Department of Environmental Quality
919-817-0360 cell
erin.davis(cDncdenr.gov
From: Leslie, Andrea J
Sent: Wednesday, February 3, 2021 2:58 PM
To: Steve Kichefski <[e-mail]>; Munzer, Olivia <[e-mail]>; Wilson, Travis
W. <[e-mail]>; Kim Browning <[e-mail]>; Tugwell, Todd J CIV USARMY
CESAW (US) <[e-mail]>; Haywood, Casey M CIV (USA) <[e-mail]>;
Hamstead, Byron A <byron_hamstead @fws.gov>; Bowers, Todd <[e-mail]>; Davis, Erin B
<[e-mail]>
Subject: RE: [External] FW: [Non-DoD Source] Hair Sheep - Planting Modification Request.
All -
Travis and I have taken a look at this and have some thoughts and concerns -
Is the site un-naturally too wet? Did they get something wrong in the design or construction? I'm sure the
provider will say "once trees are on it, it will get drier and be fine" however I have seen a lot of sites too
wet to establish trees some due to design flaws and some due to appropriate hydrology but inappropriate
veg community. Bald Cypress don t like a lot of water either in the first several years of growth.
It looks like they may have graded the riparian area too low (most likely to increase overbank flooding to
assure wetland hydrologic success). It also looks like they're getting a lot of parallel erosion rills through
the floodplain. The erosive forces in the floodplain are usually due to an inappropriate design. Either the

flood prone width needed to be larger, or they forced a C channel construction (to get wetland) where the
valley was too confined and needed to be a B channel.
There was no target community named in their mit plan, and they have come around and named the 3rd
approximation (1990) Nat Comm of NC'Piedmont/Mountain Bottomland Forest' as their likely community
type. Looking at the description of that type and the photos of the site, I don't see it. That community is
supposed to be on floodplain terraces and ridges ... this is a headwater stream with no terrace. I haven't
spent any time looking into what would be a reasonable alternative, but I don't know if that's our job
anyway.
A big question is are they pushing this to be forested when it may be too wet to be? Should it just be a
scrubby -herbaceous area?
Bald cypress and swamp tupelo especially are inappropriate for the region/site - see the Vascular Flora of
NC site here: https://authl.dpr.ncparks.goy/flora/plant list.php. This is not a riverine swamp
forest. Overcup oak is likely not appropriate either - it's much more of a coastal plain/eastern piedmont
species.
M
Andrea Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Commission
645 Fish Hatchery Rd., Building B
Marion, NC 28752
828-400-4223 (cell)
www.ncwildlife.org
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From: Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, February 3, 2021 11:51 AM
To: Leslie, Andrea J <[e-mail]>; Munzer, Olivia <[e-mail]>; Wilson, Travis W.
<[e-mail]>; Kim Browning <[e-mail]>; Tugwell, Todd J CIV USARMY
CESAW (US) <[e-mail]>; Haywood, Casey M CIV (USA) <[e-mail]>;
Hamstead, Byron A <byron [e-mail]>; Bowers, Todd <[e-mail]>; Davis, Erin B
<eri n.davis@ ncdenr.gov>
Subject: [External] FW: [Non-DoD Source] Hair Sheep - Planting Modification Request.
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From: Bowers, Todd <[e-mail]>
Sent: Wednesday, February 3, 2021 10:57 AM
To: Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Subject: RE: [Non-DoD Source] Hair Sheep - Planting Modification Request.

Thanks Steve,
I concur with your assessment. I'm a bit late in the game here myself since I did not provide an analysis during
the site development period but I appreciate the opportunity to provide some input for the modifications. As you
can probably guess, I will not be attending the site visits planned for this spring. Please pass this conversation
along to the rest of the group; I overlooked that when I responded this morning.
-Todd B.
Todd Allen Bowers
US EPA Region 4 Oceans, Wetlands and Streams Protection Branch
61 Forsyth St. SW
Atlanta, GA 30303
404.562.9225
Bowers.todd&epa.gov
Note: I am currently teleworking and away from the office. Please contact me via email or at 919.523.2637.
From: Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, February 3, 2021 10:34 AM
To: Bowers, Todd <[e-mail]>
Subject: RE: [Non-DoD Source] Hair Sheep - Planting Modification Request.
Todd,
Thanks for your quick response. I agree that we need to get them a quick answer on planting so that they can order
plants and get them in the ground during the dormant period, which is why I made the comment timeline a little shorter
than usual. I hoped they would have the site planted by the time we visit.
Since they were not pursuing wetland credit I don't think they have any well data, but I will say that some of the areas in
question were close to meeting wetland criteria when doing preliminary site visits. Especially the upper area at the
confluence of the 2 small tribs there did seem to be seeps around but the slightly incised nature of the channels likely
were draining the area before wetland criteria could be met. Also, a lower area on that trib, where the existing wetland
is located, is a drained pond bottom. I am keeping in mind that it was a wet year last year and additional root uptake by
reforested areas should reduce hydrology.
Part of their upcoming modification submittal will be to add wetland credit to their project, which would require the
placement of wells to meet performance criteria. My thoughts are for them to plant a mix of facultative to obligate
species (with extra of the wetter species) to see what takes, since providers typically overplant sites.
My concerns about their planting list are that some of the species (such as the bald cypress), don't seem to fit the target
community for the region. This site did not go thru the same scrutiny over target community that I have been applying
to more recent banks, however, it is a good opportunity to try to steer it back to the method of developing planting lists
based on a target community more appropriate for the area.
If you are good with it, I may forward this to the rest of the email list, since I think it is an informative conversation?

Steve
From: Bowers, Todd <[e-mail]>
Sent: Wednesday, February 3, 2021 9:44 AM
To: Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Subject: RE: [Non-DoD Source] Hair Sheep - Planting Modification Request.
Steve,
I have a few comments and concerns with the planting modification proposal for the KCI Yadkin 01 LIMB Hair
Sheep Site. On the surface the planting plan and species list seems reasonable as the goal is to try and get
more suitable obligate species to occupy Zone 1 due to wetness. The undated photos included in the proposal
certainly display a site that is very wet but these are only snapshots and do not correlate with any precipitation
data or ground water monitoring data. While I do not think that KCI is trying to represent the site as wetter than
it actually is, there is little information to support their claim that obligate species are needed. Looking back
over the proposed restoration plan, it was indeed noted that wetland hydrology was going to be enhanced
along T-2, potentially expanding the existing wetlands. Since wetland restoration or credit was not being
sought on this site, hydrology monitoring was not proposed and in hindsight could have provided more
evidence that the site is wetter than anticipated. Can KCI provide any information as to how wet the site will be
during the growing season?
I personally do not have any particular issues with planting bald cypress at this site in Surry County as I have
seen in many locations west of Alamance County across NC. I cannot say the same for Atlantic white cedar
and would recommend not including that species.
I would encourage the rest of the IRT to respond rapidly to this request so that KCI can plant the site while the
dormancy period is still available. If they wait until after the site visit proposed for March 22, the opportunity to
plant outside of the growing season (After April 1?) may be lost.
Thank you for the opportunity to provide feedback on the proposed modification of the planting plan for the Hair
Sheep site.
Best Regards,
Todd B.
Todd Allen Bowers
US EPA Region 4 Oceans, Wetlands and Streams Protection Branch
61 Forsyth St. SW
Atlanta, GA 30303
404.562.9225
Bowers.todd(aepa.gov
Note: I am currently teleworking and away from the office. Please contact me via email or at 919.523.2637.

From: Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, February 2, 2021 8:44 PM
To: Andrea Leslie (Andrea. Leslie@ ncwildlife.org) <[e-mail]>; Munzer, Olivia
<[e-mail]>; Wilson, Travis W. <[e-mail]>; Browning, Kimberly D CIV USARMY
CESAW (USA) <[e-mail]>; Tugwell, Todd J CIV USARMY CESAW (USA)
<[e-mail]>; Haywood, Casey M CIV (USA) <[e-mail]>; Hamstead,
Byron <byron [e-mail]>; Bowers, Todd <[e-mail]>; Davis, Erin B <[e-mail]>
Subject: FW: [Non-DoD Source] Hair Sheep - Planting Modification Request.
Good evening,
KCI has completed construction of the Hair Sheep Site in Surry County and is seeking comment regarding proposed
modification to their planting list for a portion of the site. Certain parts of the project are wetter than expected and they
wish to modify the planting plan to more hydrophytic species in those areas.
They are proposing some species that may not naturally occur in Surry County such as bald cypress in their effort to
balance commercial availability and species tolerance to the wetness of the area. I support modifying to wetter species
based on site conditions, but have concerns about some of the species proposed. Please provide any comment to their
proposal by Friday, February 12th, especially concerning the species requested and potential alternates more
appropriate for that county/community type.
KCI plans to submit their as -built report as soon as the planting is worked out/installed and intends to include a
modification request seeking wetland credit. I have already set up a tentative field visit on Monday, March 22nd in order
to review the as -built and evaluate their modification request (as long as their package is submitted on schedule).
Olivia —This is a Surry County site, but added you for awareness due to the relevance to our recent veg workgroup
discussions and the close proximity of your work area.
Feel free to contact me with any questions.
Regards,
Steve Kichefski
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District, Asheville Field Office
151 Patton Avenue, Suite 208
Asheville, NC 28801
(828)-271-7980 Ext. 4234
(828)-933-8032 cell
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 our website at
http://corpsmapu.usace.army.mil/cm apex/f?p=136:4:0 to complete the survey online.
5

From: Tim Morris <[e-mail]>
Sent: Monday, February 1, 2021 7:25 PM
To: Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Cc: Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>
Subject: [Non-DoD Source] Hair Sheep - Planting Modification Request.
I'm using Mimecast to share large files with you. Please see the attached instructions.
Steve —As discussed over the phone, attached is a memo requesting a modification to our planting plan for Hair Sheep
to allow some wetter species in the area of Tributary 2. As the memo indicates, the area is much wetter than
anticipated. Please let me know If you have questions or comments. We intend to plant the site relatively soon, so a
quick reply is greatly appreciated.
TimothyJ. Morris
KCI Technologies, Inc./KCI Environmental Technologies and Construction Inc.
4505 Falls of Neuse Road — Suite 400
Raleigh NC, 27609
919-278-2511 (Office)
919-793-6886 (Mobile)