20140044 Ver 1_EPA Email Comments_20140415

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Kulz, Eric
From: Bowers, Todd <bowers.todd @epa.gov>
Sent: Tuesday, April 15, 2014 2:05 PM
To: Crumbley, Tyler SAW; Tugwell, Todd SAW; Kulz, Eric; Wilson, Travis W.
Subject: RE: [EXTERNAL] FW: Holler mitigation plan comments
Gentlemen,
I stand by mine as well. Schafale and Weakley (Third Aprox. 1990 p. 205) does not list sweetgum as a component of the
Non - riverine swamp forest. The only mention of sweetgum is near the bottom of the page where it says "Disturbed
exampled(SIC) dominated by species such as A. rubrum and Liquidambar styraciflua may often be recognized by
remnant Taxodium" If I am misinterpreting this then I will take the hit. I'm not going to address the volunteer ability of
rm and sg as its been addressed again and I am well aware of their rapid growth ability and the desire to meet height
requirement.
I have no problem with option 2 presented below other than I think the diversity and wildlife benefits are much greater
with option 3 providing we are willing to exempt them the average height requirements (I am).
Thank you for the opportunity to back up my comments.
-Todd
- - - -- Original Message---- -
From: Crumbley, Tyler SAW [mailto:Tyler.Crumbley @usace.army.mil]
Sent: Tuesday, April 15, 2014 1:18 PM
To: Tugwell, Todd SAW; eric.kulz @ncdenr.gov; Bowers, Todd; Travis Wilson (travis.wilson @ncwildlife.org)
Subject: FW: [EXTERNAL] FW: Holler mitigation plan comments
Gentlemen,
Please see the discussion below and let me know your thoughts, as I would like to get back with Ed soon so he can
finalize his plan. I did speak with him over the phone this morning and he assured me that they will further address all
the comments and call them out in the final mit plan.
Thanks
-Tyler
- - - -- Original Message---- -
From: edtemple [mailto:edtemple @vol.com]
Sent: Tuesday, April 15, 2014 12:09 PM
To: Crumbley, Tyler SAW
Cc: ashbybrown @woodswaterandwildlife.com; 'Smith, Heather'
Subject: [EXTERNAL] FW: Hofler mitigation plan comments
Tyler,
1

Per our conversation this morning, please see below the revised proposed tree planting specs. We look forward to your
guidance. Thanks
Ed
From: Ashby Brown [ mailto: ashbybrown @woodswaterandwildlife.com]
Sent: Thursday, April 10, 2014 10:55 AM
To: Smith, Heather
Cc: edtemple @vol.com
Subject: Hofler mitigation plan comments
Heather:
Below is my response to the latest round of comments from the IRT regarding the planting schedule for the Hofler
project. Specifically the inclusion of red maple and sweetgum and the exclusion of understory species. I've addressed
the comments in detail so it's long. Sorry, bear with me.
First, let's address the comments themselves. I perfectly understand the reasoning behind them and they are valid
comments.
Eric's comments regarding sweet gum and red maple (from the original commenting period):
From item 3) It has been our observation that these species volunteer prolifically and based on research conducted by
DWR on older
mitigation sites, they will become major canopy species over time through natural processes.
From item 4) Also, Schafale and Weakley identify laurel oak (Quercus laurifolia; FACW) and swamp tupelo (Nyssa biflora;
OBL), as common canopy species on nonriverine wet hardwood forests (hardwood flat).
Yes, both gum and maple will become canopy components which is exactly the reason they were chosen for inclusion in
the planting list. Schafale and Weakley include both species in the forest type and (my copy at least) says nothing about
the pre- requisite disturbance as Todd notes in his comment below:

From pages 1 and 2 of the current IRT response (from Todd):
Planting 15% sweetgum and red maple is excessive based on the ability of these species to vigorously volunteer on
disturbed sites and their lack of hard mast production. Recommend removing or reducing the percent of sweetgum and
red maple planted. Adding some minor understory species such as Persea palustris and Cyrilla racemiflora per Erik
Kulz's recommendation is encouraged per analysis of Schafale and Weakley Nonriverine Swamp Forest (Non - Riverine
Swamp Forest per NCWAM). Sweetgum is not even listed as a component of non - riverine swamp forests unless highly
disturbed.
Again, I can find no reference in the forest type description in either document to a pre- requisite site disturbance for the
existence of maple and sweetgum in the canopy. Perhaps.it exists elsewhere in the manual. I would point out that
nearly every currently forested acre east of the Mississippi River owes its existence to some sort of disturbance - as will
the one we will be establishing on the Hofler site.
From the NCWAM user manual, version 4.1:
Page 26:
3.1.6 Hardwood Flat
Hardwood Flats are found primarily in the Coastal Plain ecoregions (see Figure 1 and Appendix
E) on poorly drained, interstream flats. These areas are usually seasonally saturated or
intermittently to seasonally inundated by a high water table or poor drainage, but have a shorter
hydroperiod than Non - Riverine Swamp Forests. The primary source of water is a high water
table resulting from precipitation and overland runoff. In their reference state, Hardwood Flats
generally occur on mineral soils. These systems are commonly dominated by hardwood tree
species including various oaks (examples: swamp chestnut oak Quercus michauxii], laurel oak
Q. laurifolia, cherrybark oak Q. pagoda, tulip poplar Liriodendron tulipifera, sweetgum
Liquidambar styraciflua, American elm, Ulmus Americana, red maple Acer rubrum, and
black gum Nyssa biflora.
From page 28:

3.1.7 Non - Riverine Swamp Forest
Non - Riverine Swamp Forests occur primarily in the embayed region (the northeastern Middle
Atlantic Coastal Plain ecoregion; see Figure 1 and Appendix E) on poorly drained, interstream
flats not contiguous with streams, rivers, or estuaries.
This wetland type is seasonally to semi - permanently inundated with hydrology driven by groundwater
discharge, overland runoff, and /or
precipitation rather than overbank or tidal flooding. Non - Riverine Swamp Forest is typically
characterized by hummocky ground surface relief that provides good water storage. This
wetland type occurs on mucky mineral or organic soils. Non - Riverine Swamp Forest is typically
characterized by forest vegetation, often dominated by bald cypress Taxodium distichum
black gum,Nyssa biflora, Atlantic white cedar,Chamaecyperis thyoides, loblolly pine Pinus
taeda, pond pine P.- serotina, tulip poplarl-iriodendron tulipifera, and red maple Acer rubrum
According to our mitigation plan we are trying to establish a forested stand that might resemble either a non - riverine
hardwood swamp or a hardwood flat. Given the topography and the proximity of the site to adjacent streams, we will
likely produce something that more resembles a hardwood flat rather than a non - riverine swamp forest. But the
components of the species list was chosen to suit both types as best as possible and to offer the greatest chance of
success. One very important characteristic of the site needs to be pointed out and that is its proximity to an adjacent
loblolly pine seed wall. Pine incursion on the site will be a problem and we will deal with it as a form of competition, but
once we are no longer obligated to maintain the site, it may very well continue to be a problem. For that reason alone,
emphasis should be placed on capturing the site as quickly as possible with hardwood species.
Also, some other information also needs to be considered:
From: Silvics of Forest Trees of the United States, 1965, Agriculture Handbook 654 Published by the U. S. Forest Service
Swamp tupelo (Nyssa sylvatica var. biflora)
Swamp tupelo not only tolerates flooding but actually thrives under those conditions (16). It is seldom found on sites
that are not inundated much of the growing season. Swamp tupelo grows in headwater swamps, strands, ponds, river
bottoms, bays, estuaries, and low coves. Normally it does not grow in the deeper parts of swamps or overflow river
bottoms.

The type of water regime is more important to growth of swamp tupelo than the soil type (11). Best growth is achieved
on sites where the soil is continuously saturated with very shallow moving water. Growth can be reduced as much as 50
percent when the water is stagnant, as in ponds. Intermittent flooding, with periodic drying cycles, or continuous deep
flooding even by moving water, also reduces growth.
The site requirements of swamp tupelo do not match the hydrology regime we are likely to produce on this site for the
species to experience good growth. We have planted it on other sites and it has done very poorly.
Also, from the same publication regarding hornbeam (C. caroliniana):
Heights of mature individuals generally range from 5 to 6 m (15 to 20 ft) in Canada and from 8 to 11 m (25 to 35 ft) in
the South.
If I can expect a minimum of 25 feet in height at maturity for this species, what height should I expect at age 7? Will it
average 10 feet? Doubtful.
From the NRCS Plants Database online Cyrilla racemiflora will have a height after 20 years of 20 feet. Again, this species
will be unlikely to measure on average 10 feet after 7 years.
From the NRCS Plants Database online P. palustris will have a maximum height of 25 feet after 20 years. Same height
problem.
From the NRCS Plants Database online, Liriodendron tulipifera (yellow poplar) is rated as FACU across the board in all
regions yet it is listed as a climax component of both a non - riverine wet hardwood forest and a non - riverine swamp
forest by Schafale and Weakley and the NCWAM manual. As such, does this make it available for inclusion in the
planting list?
Given this information, N. biflora is not appropriate to the site. The understory species C. caroliniana, C. racemiflora
and P. palustris are "underachievers" in height growth so we cannot consider them for inclusion simply to add to species
diversity and definitely not as a substitution for gum and maple.
So where am I going with all this? Here: From page 2 of the current monitoring requirements:
"Planted vegetation must average 10 feet in height in each plot at year 7 in sites located in the
coastal and piedmont counties ..."
I have no particular fondness for either gum or maple, but by implementing a height requirement, EEP has forced a
change of strategy and species diversity will necessarily suffer. Full delivery providers no longer have the luxury of
adding shrub and small tree species to the planting mix that will not contribute to the success of the project. We won't
get paid at the end for having a greater number of species, but we will suffer the consequences if the trees don't meet
the height requirement and number per acre. Hardwood species are extremely site sensitive and what we are being
asked to produce is a well performing mixed species hardwood plantation - under very poor soil conditions. Due to the
success criteria in the contract, silvics of the species must come into consideration. We can't add species simply because
they are listed in Schafale and Weakley's very general (and by no means all- inclusive) description of a forest type. We
entered into the contract knowing we had two vegetation success criteria to meet and we have developed a planting
list that has the best chance of meeting them. Spending money to plant species that will hinder our ability to meet the
height requirement is, to say the least, a very poor business decision. To put it bluntly, we can't afford to remove our
two fastest growing species and replace them with two or more slow growing or smaller species.

Given those contract requirements, here are several sound recommendations for the IRT to consider:
1. Leave the planting schedule as is.
2. Replace all or a portion of the sweetgum and maple with poplar (L. tulipifera). Leave the remainder of the
schedule as is. After all, L. tulipifera is listed as a component of both forest types - in both documents referenced in the
comments. This option should be considered before being dismissed out of hand because of the wetland rating. Poplar
is a good tree to have in the mix. It has great longevity and better form than gum or maple and is a better food source
for birds.
3. Replace half of the sweetgum and maple (or substituted L. tulipifera) with understory species ONLY if they are
exempted in writing from inclusion in the calculation of average height to satisfy the contract requirement of the 10 foot
height at year 7. The bays (swamp and sweet) are fairly good survivors, but from what I've seen at age 5 they rarely
exceed 4 feet in height. Cyrilla is a poor survivor. I have little experience with ironwood so I would naturally shy away
from an unknown. Wax myrtle is a good survivor. Buttonbush is a good survivor. We are at the upper extreme of the
natural range for laurel oak, but I would consider it as an understory species since it is a prolific acorn producer when
mature (though relatively short lived for an oak). But it must also be included in the exemption for height.
So, let me know what happens.
Ashby Brown
Society of American Foresters, Certified Forester
North Carolina Registered Forester
Maryland Licensed Forester