HomeMy WebLinkAboutNotice of Initial Credit Release_ NCDMS Monkey Wall Mitigation Site_ SAW-2018-01162_ Mitchell CountyFrom:
Davis, Erin B
To:
Baker, Caroline D
Subject:
FW: [External] FW: Notice of Initial Credit Release/ NCDMS Monkey Wall Mitigation Site/ SAW-2018-01162/
Mitchell County
Date:
Monday, December 12, 2022 1:57:59 PM
Attachments:
MYO MonkevWall ResoonseTOIRTCOmments.odf
Laserfiche Upload: Email & Attachment
DWR#: 20181029 v.I
Doc Date: 12/9/22
Doc Type: Mitigation — Mitigation Information
Doc Name: General topic of email title
-----Original Message -----
From: Isenhour, Kimberly T CIV USARMY CESAW (USA) <Kimberly.D.Browning(a,)usace.army.mil>
Sent: Friday, December 9, 2022 10:08 AM
To: Tugwell, Todd J CIV USARMY CESAW (US)<Todd.J.Tugwell@usace.army.mil>; Haywood, Casey M CIV
USARMY CESAW (USA) <Casey.M.Haywood(ousace.army.mil>; Davis, Erin B <erin.davis(0ncdenr.gov>;
Wilson, Travis W.<travis.wilson(oncwildlife.org>; Leslie, Andrea J <andrea.leslie@ncwildlife.org>; Bowers, Todd
<bowers.todd (0epa. gov>
Subject: [External] FW: Notice of Initial Credit Release/ NCDMS Monkey Wall Mitigation Site/ SAW-2018-01162/
Mitchell County
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Attached are RES' response to IRT comments on Monkey Wall. I'm not really thrilled with their response to why
they changed plant species after the plan was approved, but hopefully they got the message that such changes should
be made with IRT review and approval.
Kim Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers 1 919.946.5107
-----Original Message -----
From: Ryan Medric <rmedric@res.us>
Sent: Thursday, December 08, 2022 3:11 PM
To: Isenhour, Kimberly T CIV USARMY CESAW (USA) <Kimberly.D.Browning@usace.army.mil>
Cc: Tsomides, Harry <harry.tsomides&cdenr.gov>; Jamey Mceachran <jmceachran@res.us>; Emily Ulman
<eulman(a�jres.us>; Wiesner, Paul <paul.wiesner@ncdenr.gov>
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: Notice of Initial Credit Release/ NCDMS Monkey Wall
Mitigation Site/ SAW-2018-01162/ Mitchell County
Hi Kim,
Please find attached RES' responses to the IRT comments on the Monkey Wall MYO Report. This memo will also
be included in the MY report.
Thanks!
Ryan Medric
Project Manager
RES I res.us <Blockedhttp://www.res.us/>
D: 919.741.6268 1 M: 703.424.6313
From: Isenhour, Kimberly T CIV USARMY CESAW (USA) <Kimberly.D.Browning(a,)usace.army.mil>
Sent: Wednesday, November 30, 2022 1:54 PM
To: Wiesner, Paul <paul.wiesner&cdenr.gov>
Cc: Jamey Mceachran <jmceachran@res.us>; Ryan Medric <rmedric@res.us>; Tsomides, Harry
<harry.tsomides@ncdenr.gov>; Melonie Allen <melonie.allen&cdenr.gov>; Harmon, Beth
<Beth.Harmon&cdenr.gov>, Stanfill, Jim <jim.stanfill@ncdenr.gov>; Tugwell, Todd J CIV USARMY CESAW
(USA)<Todd.J.Tugwell@usace.army.mil>; Haywood, Casey M CIV USARMY CESAW (USA)
<Casey.M.Haywood@usace.army.mil>; Crumbley, Tyler A CIV USARMY CESAW (USA)
<Tyler.A.Crumbley2@usace.army.mil>; travis.wilson@ncwildlife.org; Bowers, Todd <bowers.todd@epa.gov>;
Andrea Leslie <andrea.leslie@ncwildlife.org>; erin.davis@ncdenr.gov; Youngman, Holland J
<holland_youngman@fws.gov>
Subject: [EXTERNAL] Notice of Initial Credit Release/ NCDMS Monkey Wall Mitigation Site/ SAW-2018-01162/
Mitchell County
Hi Paul,
The 15-Day As-Built/MYO review for the NCDMS Monkey Wall Mitigation Site (SAW-2018-01162) ended
November 23, 2022. Per Section 332.8(o)(9) of the 2008 Mitigation Rule, this review followed the streamlined
review process. All comments received from the NCIRT are incorporated in the email below. There were no
objections to issuing the initial 30% credit release of 1234.778 Cold stream mitigation units. Please find attached
the current signed ledger. The IRT is not requesting a site visit at this time.
Kim Isenhour, USAGE:
The IRT has significant concerns that four species appear to have been planted that were not on the approved
mitigation plan plant list, and other species were omitted (see attached). These changes were not mentioned in the
MYO report, nor was a planting plan included. As mentioned previously, the IRT would like to stress that proposed
changes to the planting plan should be submitted for IRT review prior to be planted. We understand that species
availability may be a consideration, and we try to have flexibility to allow appropriate changes, but these proposed
changes should be addressed to the IRT prior to moving forward. Most concerning is that the final mitigation plan
planting list was altered after the draft mitigation plan approval was issued. Approval of the final mitigation plan is
contingent upon IRT comments from the draft mitigation plan being addressed. If the final mitigation plan is not
adjusted per IRT comments, or if additional adjustments are made, the IRT must be notified upon receipt of the final
mitigation plan that changes were proposed before the final mitigation plan is considered approved.
Casey Haywood, USAGE:
1. I have no issue with the Addendum request that was previously discussed with the IRT that included an
additional 241.461 SMU generated by relocating the utility lines to the southern boundary. The effort to limit site
fragmentation is appreciated.
2. Noted that veg plots 6 & 7 were relocated because they interfered with the relocated powerline easement
and were shifted outside the ROW. When comparing the monitoring plan map (Figure 12 of the MP) to the MYO
CCPV (Figure 2) it appears that veg plots 8 and 10 shifted much closer to the stream which limits the representation
of the outer buffer on the northwestern section of the site. Were these moved due to the steep slopes? It will be
important to capture this area through visual assessment and/or a random plot in future monitoring reports.
3. The report noted that RES removed the old powerline poles Oct 2022; did this work result in any areas that
needed to be replanted? Were there any concerns of compaction in this area? If so, it would also be helpful to
capture the old utility corridor with one of the random veg plots in next year's monitoring report.
4. Please include the planting plan in the AB record drawings in future reports. Sheet P1 from the Mitigation
Plan was not included in the submittal. As discussed with other projects, please include wetland indicator statuses on
the planting table for future reports.
Todd Bowers, USEPA:
I have reviewed the MYO/As-Built monitoring report for the Monkey Wall mitigation site (a component of the
NCDMS In -Lieu Fee Program) dated October 2022 submitted by Resource Environmental Solutions, LLC (RES).
RES respectfully requests the first credit release for the Monkey Wall Mitigation Project for 30% of the total stream
credits. The project preserved, enhanced and restored, 3,625.0 linear feet of streams in Mitchell County, NC. The
work proposed on the Site will provide, upon closeout, 4,115.930 cold stream mitigation units (SMUs) within the
French Broad River Basin. According to RES, an additional 241.461 SMU (non-standard buffer width adjustment)
were generated by relocating the utility lines that intersected the project through the center of the conservation
easement to the southern boundary of the easement; thus making the 25.3 acre site contiguous.
According to RES, stream construction was completed in October 2021 and planting was completed on March 10,
2022. The Monkey Wall Project was built to design plans and guidelines. The as -built stream length was exactly the
same as proposed in the mitigation plan plus the stream length that was originally removed under the utility lines. A
total of 12 cross sections , two stage recorders, and two flow gauges were installed and geomorphology data
collection for MYO was conducted on March 24, 2022. Setup and monitoring of 13 fixed vegetation plots and three
random vegetation plots was completed after planting and stream construction on March 24, 2022. The original
installation of two plots, 6 and 7, interfered with the relocated powerline easement and were therefore shifted
outside of the right-of-way on May 3, 2022.
Overall, the Site looks good, baseline stream profiles and cross sections match the proposed design, is performing as
intended, and is on track to meet success criteria. All vegetation plots are on track (599 stems/acre average) to
exceed the MY3 interim requirement of 320 planted stems per acre, and all streams within the Site are stable and
meeting project goals. Invasive species were controlled across the Site prior to and during construction and will
continued to be assessed throughout the monitoring years.
The following items or highlights from the As -Built Condition Assessment were of concern:
* There did not seem to be a planting plan figure or sheet denoting the extent of planted vegetation. Some of the
site was not planted (preservation) and some of the site is wet so I am curious if there was any shift in species in the
denoted wetlands.
The type or target forest community is not mentioned in the monitoring or success criteria narrative.
Overall, I am very satisfied with the report and the work that has been completed at the site. Relocation of the
powerline and very wide buffers really makes this site so much more contiguous and robust especially for species
that need less forest edge exposure. Having not been on -site, I really appreciated the detailed ground -level stream
and veg plot photos. I recommend the appropriate credit release (Milestone 2) for cold stream mitigation units for
this monitoring milestone. I have no other substantial comments at this time.
Andrea Leslie, NCWRC:
The MYO report states that everything was planted in the correct percentages as was in the final mit plan. But those
numbers and species are different than what I reviewed in the draft mit plan. Of issue — the draft mit plan noted a
number of species that were good choices — e.g., Sweet Birch, Fraser Magnolia. But the MO report doesn't have
these listed as planted; they have other species that were not in the draft plan, including River Birch.
Erin Davis, NCDWR:
DWR has reviewed DMS' Monkey Wall as -built and baseline report, including the mitigation plan addendum. We
support the proposed credit release, including the additional credit from the utility line relocation. DWR is not
requesting a site visit for this review. DWR concurs with Corps comments. Our only additional question is whether
rock was used along any of the newly constructed swales? Of particular concern is if rock was installed in the
existing wetland near the confluence of the two tributaries.
Please reach out with any questions.
Regards,
Kim
Kim Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers 1 919.946.5107