Notice of Initial Credit Release_ NCDMS Monkey Wall Mitigation Site

From: Davis, Erin B
To: Baker. Caroline D
Subject: FW: [External] Notice of Initial Credit Release/ NCDMS Monkey Wall Mitigation Site/ SAW-2018-01162/ Mitchell
County
Date: Monday, December 12, 2022 2:24:59 PM
Attachments: Monkey Wall 100069 FB 08 STR Initial Release KI.odf
Monkey Wall Plantino Lists.odf
Laserfiche Upload: Email & Attachment
DW R#: 20181029 v.1
Doc Date: 11/30/22
Doc Type: Mitigation —Mitigation Evaluation
Doc Name: General topic of email title
From: Isenhour, Kimberly T CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, November 30, 2022 1:54 PM
To: Wiesner, Paul <[e-mail]>
Cc: Jamey McEachran <[e-mail]>; Ryan Medric <[e-mail]>; Tsomides, Harry
<[e-mail]>; Allen, Melonie <[e-mail]>; Harmon, Beth
<[e-mail]>; Stanfill, Jim <[e-mail]>; Tugwell, Todd J CIV USARMY
CESAW (US)<[e-mail]>; Haywood, Casey M CIV USARMY CESAW (USA)
<[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW (USA)
<[e-mail]>; Wilson, Travis W. <[e-mail]>; Bowers,
Todd <[e-mail]>; Leslie, Andrea J <[e-mail]>; Davis, Erin B
<[e-mail]>; Youngman, Holland J <[e-mail]>
Subject: [External] Notice of Initial Credit Release/ NCDMS Monkey Wall Mitigation Site/ SAW-2018-
01162/ Mitchell County
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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, 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 priorto 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, USACE:
1. 1 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 some 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