20181096 Ver 1_SAW-2018-00712_KCI-Yadkin01UMB-HairSheep_MY2 Credit Release

June 5, 2023

Regulatory Division

SUBJECT: Year 2 Monitoring Report Review and Credit Release associated with KCI
Yadkin 01 Umbrella Mitigation Bank, Hair Sheep Mitigation Site, Action ID No. SAW-
2018-00712

Mr. Adam Spiller
KCI Technologies, Inc./KCI Environmental Technologies Construction Inc.
4505 Falls of Neuse Road, Suite 400
Raleigh, North Carolina 27609

Dear Mr. Spiller:

This correspondence is in reference to the KCI Yadkin 01 Umbrella Mitigation Bank,
Hair Sheep Mitigation Site. The site includes unnamed tributaries in the Yadkin River
Basin, Cataloging Unit (03040101), and is located in Surry County, North Carolina. The
purpose of this letter is to transmit comments provided by the NC Interagency Review
Team (NCIRT) during the review of the annual monitoring report (see attached) and to
confirm the Year 2 credit release for this mitigation site.

Pursuant to the site’s Umbrella Mitigation Banking Instrument and the site-specific
Mitigation Plan, the following mitigation credits shall be available for sale provided the
annual monitoring report demonstrates interim performance standards are being met :

• 10% of the total enhancement and/or restoration Stream Mitigation Units
(SMUs) and Wetland Mitigation Units (WMUs) associated with year 2 annual
monitoring (349.2 Warm Water SMUs and 0.085 WMUs)

Based on a review of the data provided for the stream restoration and enhancement
on the site, we confirm that you have satisfied the above requirements, 349.2 Warm
Water SMUs and 0.085 WMUs are now available for sale.

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343

Please review the comments provided by the NCIRT during their review of the
monitoring report. While it is not necessary to provide a response to specific comments
at this time, please be sure to address the issues raised in future monitoring report
submittals.

Please note that this electronic copy provided to you via email is your official copy.
Should you wish to receive a paper copy of this correspondence, please contact us.
Thank you for your time and cooperation. If you have any questions, please contact Mr.
Steve Kichefski by email at [e-mail] or by phone at (828) 933-
8032.

Sincerely,

for
Todd Tugwell
Chief, Mitigation Branch

Enclosure

cc (by email):
NCIRT Distribution List

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343

CESAW-RG/Kichefski June 5, 2023

MEMORANDUM FOR RECORD

SUBJECT: Action ID # SAW-2018-00712, NCIRT Review Comments on the KCI Yadkin
01 Umbrella Mitigation Bank, Hair Sheep Year 2 Monitoring Report

Todd Bowers, USEPA:

Thank you for the opportunity to provide feedback and comments on the Hair Sheep
Mitigation Site (the Site or Project) Monitoring Year 2 (MY1) annual report, dated
February 2023, as a component of the KCI Yadkin 01 Umbrella Mitigation Bank. KCI
Technologies Inc., is requesting a MY 2 credit release of 10% of 3,492 credits (or 349.2
credits) and the wetland mitigation credit request is for 10% of 0.855 total wetland
credits or 0.085 credits.

KCI appears to have met all requirements justifying the full 10% credit release and I
concur with their request. Vegetation growth across the site appears excellent, however
I am curious why the report references the MY5 density threshold (260 stems/acre)
rather than the MY3 interim density threshold of 320 stems/acre. The planned and
completed corrective actions to treat invasive species, landowner easement restrictions
and livestock encroachment, supplemental planting due to livestock damage, and the
need for BMP type retention basins have all been noted. The MY0 v MY2 photos,
especially PP4-6, wonderfully demonstrated the level of vegetation growth along the
streams. I have no other comments or concerns at this time.

Casey Haywood, USACE:

1. Please QAQC future reports for consistency.
a. Please update wetland success criteria in future reports. Table 10
indicates success criteria is 12% (21 days) but the narrative on page 2
states that the success criteria is 9% (19 days).
b. All groundwater gauges met success however the maps show GWG 3 as
failing.
2. Several of the gauges are meeting at 100%. In particular, the graphs for gauges
4, 6 & 7 indicate water above the ground surface. Please capture the creation
area near gauge 6 with a random veg plot next year.
3. There is a high number of red maples in fixed plot 4 and random 4. Please
continue to monitor and thin if needed.
4. Several invasive species have been located on site and plan to be treated spring
of 2023. Are the populations of invasives scattered throughout the site? It would
-2-

be helpful to include an estimate of the total acreage in future reports and include
the areas on the monitoring map.
5. Growing season: The IRT has had several discussions recently regarding the
reporting for growing seasons. For this report, the growing season began on
March 1st while last year’s growing season began on April 3rd; the end date for
the growing season was Oct 30th for both reports. Of particular concern is if you
begin the growing season as early as March 1st, it should also be extended at the
end of monitoring past October 30th. In addition, if you are using a modified
growing season that is not listed in the WETS tables, documentation of both bud
burst and leaf drop, along with the soil temperature data need to be provided in
the report. Due to several inconsistencies that can occur when documenting bud
burst and leaf senescence such as which species are selected, the location of
the vegetation, shading, etc., the IRT recommends only measuring the vegetative
indicators once and sticking with those dates. If you decide to use a modified
growing season, once you establish the dates (assuming it's a normal year),
please use those dates throughout the life of the project for consistency.

Steve Kichefski
Mitigation Project Manager
Mitigation Branch