HomeMy WebLinkAboutMY0_MonkeyWall_ResponseToIRTCommentsfires
December 8, 2022
Kim Isenhour
U.S. Army Corps of Engineers
3331 Heritage Trade Drive, #105
Wake Forest, NC 27587
3600 Glenwood Avenue, Suite 100
Raleigh, NC 27612
Response to IRT Comments — Baseline Report and As -Built Drawings
Monkey Wall Mitigation Site — Mitchell County
DMS Project ID No. 100069
Full Delivery Contract No. 7536
RFP No. 16-007336 (Issued September 8, 2017)
USACE Action ID No. SAW-2018-01162
DWR Project No. 2018-1029
Corporate Headquarters
6575 W Loop S #300
Bellaire, TX 77401
Main: 713.520.5400
Listed below are comments provided by IRT on November 30, 2022 regarding the Monkey Wall
Site: Baseline Report and As -Built Drawings and RES' responses (blue text).
Kim Isenhour, USACE:
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.
The changes to the planting plan were in response to the comment from NCWRC stating: "We
recommend supplementing the woody species planting list with some additional understory
species". RES responded to this comment saying, "RES agrees and has supplemented the
proposed planting list in Section 7.2.1 (Table 13) with the following understory species: tag alder
(Alnus serrulata), eastern redbud (Cercis canadensis), flowering dogwood (Cornus florida), and red
mulberry (Morus rubra). Instead of adding understory trees as additional species, RES replaced the
American ash (Fraxinus americana), red hickory (Carya ovalis), mountain magnolia (Magnolia
fraseri), and sourwood (Oxydenrum arboretum) with the understory species listed above as well as
res.us
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replaced sweet birch (Betula lenta) with river birch (Betula nigra) due to commercial availability.
RES acknowledges that the additional species should have been submitted to the IRT for approval.
RES will include planting plans in the record drawings from now on, however, Table 7 in Appendix
C of the monitoring reports shows the difference in species and amount planted between the
Final Mitigation Plan and As -Built. Lastly, RES did not mention any planting changes in the As -
Built report since the planted species matched the Final Mitigation Plan species which was
assumed to be the "approved" mitigation plan. If any supplemental planting is required during
the monitoring period, RES will attempt to include species from the Draft Mitigation Plan.
Casey Haywood, USACE:
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.
Vegetation plot 10 was moved downslope due to slippery conditions during as -built installation.
Vegetation plot 8 is located slightly downslope from proposed but is still very much on the slope.
RES will make sure visual assessment and random plots represent outer buffer areas throughout
the monitoring period.
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.
The powerline pole removal was minimally invasive and mainly followed old farm paths. RES will
perform a random veg plot in the old utility corridor in MY1 and assess if supplemental planting
is required.
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.
Noted.
Todd Bowers, USEPA:
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.
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The site was planted per the planting plan in the Final Mitigation Plan. As mentioned above, RES
will include redlined planting plans in the record drawings moving forward.
• The type or target forest community is not mentioned in the monitoring or success criteria
narrative.
Montane oak -hickory forest was the target forest community as stated in the Final Mitigation Plan.
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.
See comment response to USACE above.
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.
The constructed swales were graded, matted, and livestaked. No rock was added to the swales;
however, rock is present in the swales as rock is found naturally in the soil across the whole site.