20150414 Ver 1_NCDMS Draft MP Approval Ltr_SAW-2015-00827_20160724

Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
July 15, 2016
Re: NCIRT Review and USACE Approval of the Sandy Bridge Mitigation Plan;
SAW -2015-00827; DMS Project#96920
Mr. Tim Baumgartner
North Carolina Division of Mitigation Services
1652 Mail Service Center
Raleigh, NC 27699-1652
Dear Mr. Baumgartner:
The purpose of this letter is to provide the North Carolina Division of Mitigation
Services (NCDMS) with all comments generated by the North Carolina Interagency Review
Team (NCIRT) during the 30 -day comment period for the Sandy Bridge Mitigation Plan, which
closed on May 11, 2016. These comments are attached for your review.
We have evaluated the comments generated during the review process and determined
that the concerns raised during the review have been adequately addressed by the provider in
their final response letter. Therefore, the Mitigation Plan is considered approved with this
correspondence provided the proposed changes are incorporated into the Final Mitigation Plan.
A copy of the Final Mitigation Plan is to be submitted with the Preconstruction
Notification (PCN) application for Nationwide permit approval of the project along with a copy
of this letter. All changes that were made to the Final Mitigation Plan should be summarized
in an errata sheet included at the beginning of the document. If it is determined that the project
does not require a Department of the Army permit, you must still provide a copy of the Final
Mitigation Plan, along with a copy of this letter, to the appropriate USACE field office at least
30 days in advance of beginning construction of the project. Please note that this approval does
not preclude the inclusion of permit conditions in the permit authorization for the project,
particularly if issues mentioned above are not satisfactorily addressed. Additionally, this letter
provides initial approval for the Mitigation Plan, but this does not guarantee that the project
will generate the requested amount of mitigation credit. As you are aware, unforeseen issues
may arise during construction or monitoring of the project that may require maintenance or
reconstruction that may lead to reduced credit.

Thank you for your prompt attention to this matter. If you have questions regarding this
letter, the mitigation plan review process, or the requirements of the Mitigation Rule, please
call me at 919-846-2564.
Sincerely,
Digitally signed by HUGHES.ANDREA.WADE.1258339165
HUGHES.ANDREA.WADE.125
DN: r–U5, o=U.S. Government, ou=DOD, —PKI,
8339165 ou=USA,—LISA,
Date: 2016.07.16 20:54:44 -04'00'
Andrea Hughes
Mitigation Project Manager
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List

REPLY TO
ATTENTION OF:
CESAW-RG/Hughes
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
MEMORANDUM FOR RECORD
May 13, 2016
SUBJECT: Sandy Bridge Farm Restoration Site - NCIRT Comments During 30 -day Mitigation Plan
Review
PURPOSE: The comments listed below were posted to the NCDMS Mitigation Plan Review Portal
during the 30 -day comment period in accordance with Section 332.8(g) of the 2008 Mitigation Rule.
NCDMS Project Name: Sandy Bridge Farm Restoration Site, Rutherford County, NC
USACE AID#: SAW -2015-00827
NCDMS #: 96920
30 -Day Comment Deadline: May 11, 2016
Paul Wiesner, NCDMS, April 28, 2016:
The table on page 35 incorrectly says "Vegetation will be monitored using the Carolina
Vegetation Survey (CVS) protocols". Please note that this table will be updated in the final
mitigation plan. The Full Delivery provider will monitor tree and shrubs by height and species.
Volunteers will be recorded, but counted separately from planted trees. CVS protocols will not
be utilized for this project.
Todd Bowers, USEPA, May 5, 2016:
1. General comments: Tables and Figures are not labeled as such and referred to by their number in
the document text. Example: The table on page 15 in Section 4.0 has no table #. I am a bit
disappointed to discover that the stream restoration work is now restricted to the area downstream
of the bridge and that the protected area for wetland/riparian habitat has decreased somewhat
from the original proposal. I am troubled by the sponsor possibly getting credit for wetlands
within the 50 -foot riparian zone adjacent to the stream. This is not spelled out directly and the
maps make this approach unclear so I am assuming that some of the 6.94 acres of wetlands are
within the riparian zone. Full stream credit requires the riparian zone and although in the past the
IRT has given wetland credit in the riparian areas I do not think that this approach should
continue unless it can be justified. Some clarity is needed to fully denote that the 0.67 acres of
jurisdictional wetland on east side of T1 is not being fully rehabilitated but that only 0.59 acres of
it is (removal of ditches?).
2. The unnamed tributary (T2) which flows into Tributary 1 (project stream) has a name: Logan
Creek. This was found on the Conservation Easement Survey on page 51 (Appendix A)
3. Recommend the sponsor rename T1 to something appropriate such as Hughes Creek.
4. Page 1: Recommend addition of programmatic goal of providing wetland and stream mitigation
credits to the NCDMS in -lieu fee program for compensatory mitigation needs in the GSA.

5. Page 1: The Water Quality Treatment Area shown on page 162 and 163 (Site Plans) is not
mentioned in the document and should be included (or removed from site plans) as one of the
objectives addressing the goal of protecting and improving water quality leaving the site.
6. Page 1: Add improving water quality leaving the site as a project goal.
7. Page 1: Add "planting a riparian buffer to stabilize stream banks, provide nutrient inputs to the
stream and provide shade to aid thermal regulation of the stream" to the objectives.
8. Page 1: Add "improve aquatic habitat" as a goal and "addition of structures and large woody
debris to improve aquatic habitat" as an objective.
9. Page 15: Baseline Information Table - NCDWQ should be changed to NCDWR
10. Page 15: The "mapped soil series" is Chewacla and Dogue (ChA and DoB). A footnote should be
made that the analysis of soils does not match the mapped series as per the text found on page 3.
11. Page 15: A footnote should be added to clarify and justify that not all of the 1.38 acres of
jurisdictional wetlands are included in "existing wetland size". I have to assume here that the
wetlands minus the 0.59 acres are just ditches.
12. Pages 18, 19, 21, 22, 25, 27, 31, 32 and 35: no table #. See comment above
13. Page 19: I'm a bit unclear on why the wetlands included in the jurisdictional determination are
not jurisdictional. I understand they are mainly ditches used to drain the on-site wetlands but why
are they not included as "jurisdictional"? WI is 0.67 acres but only 0.59 acres is considered for
rehab?
14. Page 22: Stream credit release schedule reserve is 10% and differs from text on page 23 which
states 15% of credits held in reserve for bankfull events.
15. Page 23: Planting 968 stems per acre seems excessively dense especially when considering that
75% of the trees can die and the site satisfy the vegetation monitoring performance standard. This
rate of mortality seems very wasteful of time and resources. Please consider planting at a stem
density of 600-700 stems per acre.
16. Page 23: Recommend breaking out the plant communities that apply to the riparian zone (live
stakes), wetland (Piedmont Alluvial Forest) and upland areas outside the stream buffer and
wetland (Piedmont Alluvial Forest?). Including FAC and FACU species in the planting plan may
be better suited for upland areas on-site.
17. Page 23: Recommend removing several species from the wetland planting plan due to 1) not
included in Shafale 2012 and 2) not considered OBL-FACW. Consider removing Acer rubrum,
Cornus amomum, Hamamelis virginiana, Diospyros virginiana, and Quercus phellos.
Recommend adding Lindera benzoin and Carpinus carolinana as suitable understory species.
18. Page 25: The table lacks goals and objectives to address aquatic habitat and biology as well as
water quality goals and objectives.
19. Page 26: does the project creek flow into unnamed tributary T2/Logan Creek or is it the other
way around?
20. Page 26: Describe type and depth of "additional grading".
21. Page 30: Need to delineate between wetland and riparian zone. Once again I am troubled by the
overlap in credit implied here. Also would like to see the "water quality treatment area" outlined
here.
22. Page 31: Include a beaver contingency plan in the maintenance plan table.
23. Page 31 and 32: State the number of consecutive days during the growing season needed to meet
the minimum standard for wetland performance.
24. Page 33: Recommend separate vegetation monitoring for riparian zones and wetland areas.
25. Overall recommendation: Collection of baseline data to include water quality and benthic
macroinvertebrates to better establish demonstrated functional lift at the end of the project. This
project looks great for improving hydrology and stream geomorphology but there is also great
potential for this highly degraded stream to have suitable habitat, improved water quality and an
aquatic insect community that reflects those improvements.

26. Recommend at least one monitoring well and one vegetation plot set up outside the wetland
restoration areas. This will demonstrate the limits of wetland hydrology and plant survival outside
of the adjacent wetland area.
Travis Wilson, NCWRC, May 6, 2016:
Red maple is shown as a planted species, this is not necessary. Although Red maple is found in
late successional forest communities it will establish as an early successional species on disturbed
sites and should naturally recolonize in the project area. Planted species should be comprised of
climax community species with the intent of reducing the temporal lag associated with restoring
these systems in the absence of an existing seed source.
Mac Haupt, Virginia Baker, NCD WR, May 9, 2016:
1. Sandy Bridge Farm Restoration site is a good candidate for stream and wetland mitigation. The
unnamed tributary to Catheys Creek and associated wetland appear to be highly degraded from
years of agricultural land use and should benefit substantially form restorative measures.
However DWR does have concerns related to the success and monitoring standards proposed.
2. DWR is concerned about the hydrology success criteria proposed for the Sandy Bridge Farm
Restoration site (page 32). DWR recognizes that there is "inherent variability in site soils and
associated drainage patterns" that would result in variable hydrologic conditions across the site,
but still considers 6.5% to be too low for a restoration site that will be generating riverine wetland
credits. DWR recommends raising the minimum well hydrologic success criteria to 10% which is
consistent with what would be expected for riverine wetlands with Chewacla and Wehadkee soils.
In addition, DWR would like to evaluate the model utilized in the spatial averaging before
allowing its use a determinant of wetland hydrologic success.
3. DWR is concerned that the proposed restored wetland acreage may not be achieved throughout,
especially closer to the edges and in areas further from the stream influence. We recommend that
an additional well be added in the open area in the middle where none exists and a transect of
wells be added closer to the SW edge.
4. It should be noted that during construction the wetland should be graded no more then 6-8" for
restoration. Please further discuss the grading plans mentioned on page 26 and 28.
5. DWR does have some concern that the reference reach used for the design is located in a different
basin and more importantly a different physiographic region (page 19).
6. Please further explain the stream Geomorphic Performance standards (page 32), what are the
expected ranges for this proposed type of stream, how far different from the reference is
considered stable and successful? DWR does have some reservations about maintaining channel
stability along the restored reach since the designed bankfull channel will be "slightly
undersized".
7. DWR is concerned with not having the appropriate monitoring results to determine site
performance success OR percent of site performance success needed for credit release during
monitor years 2, 4, and 6. By year six it is certainly more likely to determine if a site is trending
toward success, but this will certainly not be evident by year 2. If the site is not meeting or only
partially meeting success criteria at the end of a detailed monitoring year this could be
problematic for credit release the following year without accurate results. Additionally, site trends
that can be evaluated with detailed monitoring methods such as stream cross-section monitoring
and vegetative stem count data will not necessarily be identified with visual monitoring solely.
Therefore, needed adaptive management strategies may be overlooked or addressed later in the
monitoring period potentially delaying a site closeout.

8. How was the stream location that follows the west side of the site determined as opposed to
further to the east closer to the north south running ditches? Were there soil indicators?
Andrea Hughes, USACE, May 11, 2016:
1. Page 21, Determination of Credits: Please separate the wetland rehabilitation and wetland re-
establishment credits.
2. Page 22: Credit Release Schedules: Regarding early release, please note this provision is only for
high-quality sites that have consistently and fully met all performance standards and have not had
any major or reoccurring problems. Requests for early closure must be submitted in writing along
with the year 5 or 6 monitoring report and justification for the request.
3. Page 23: Subsequent Credit Releases: For stream projects, a reserve of 10% of a site's total
stream credits shall be released after two bank -full events.
4. Page 23: Mitigation Work Plan: We recommend removing Acer rubrum from the planting list or
limit this species to 5% of planted species.
5. Page 24: Design Parameters: The plan states that the riffle cross-section has been designed
smaller than typical bank full flow to encourage frequent overbank flooding into the
stream/wetland complex. Please provide details regarding the design (difference?) and the
rationale for the design (to meet wetland hydrology performance standards?).
6. Page 25: Design Parameters: Please provide additional details regarding the proposed grading for
the wetland restoration areas.
7. Page 31: Performance Standards: The monitoring period is 7 years. Regarding early release, see
comment above.
8. Page 31: Performance Standards, Vegetation: Within planted portions of the site, a minimum of
320 planted stems per acre must be present at year three; a minimum of 260 planted stems per acre
must be present at year five; and a minimum of 210 planted stems per acre must be present at year
seven. Individual plot data for planted species must be provided. Plot data cannot be averaged
across plots over the entire site to obtain a single figure for stem density for the purposes of meeting
performance standards.
9. Page 32: Performance Standards, Wetland: Hydrology performance should be based on gauge
data that demonstrates saturation/inundation for 10% of the growing season (217 days) rather
than a spatial average.
10. Page 32: Performance Standards, Geomorphic: Performance standards should relate directly to
the goals and objectives, and the monitoring protocols for the project. The table on page ii lists
goals, objectives, and monitoring protocols for the project. Please provide specific (quantitative)
performance standards to document that the project is meeting these goals and objectives.
11. Page 33, Monitoring, Vegetation: Vegetation plots must be monitored for 7 years, with data
collection occurring in years 1, 2, 3, 5, and 7.
12. Page 33, Monitoring, Wetland Hydrology: Well data must be monitored for 7 years with data
collection in years 1, 2, 3, 4, 5, 6, and 7. Also, according to the field notes the provider was
advised to install monitoring wells pre and post construction in order to generate wetland credits
for areas adjacent to the stream. The pre -construction data should be provided in the mitigation
plan.
13. Page 34, Monitoring, Geomorphology: Channel stability (i.e., cross-sections, bank pins, bed
materials, etc.) must be monitored for 7 years, with data collection occurring in years 1, 2, 3, 5,
and 7.
14. Page 34, Monitoring, Reporting: Planted vegetation must be in the ground for at least 180 days
prior to the initiation of the first year of monitoring (Year 1).
15. Page 34, Monitoring, Reporting: Full monitoring reports must be provided in years 1, 2, 3, 5, and
7. Limited monitoring reports may be submitted for years 4 and 6.
16. Appendix A: Please provide a copy of the conservation easement document.

17. Appendix B: The project is located within the boundaries of a designated historic district. Please
provide documentation to support the categorical exclusion.
18. Appendix B: Rutherford County T&E species include the Bog turtle, the Northern Long Ear bat,
and the Indiana bat. It appears that construction activities may require tree removal on the lower
end of the project. Please provide discussion regarding any effects the project may have on these
or other known T&E species for Rutherford County.
19. Other: Regarding the project location, it appears that the project is located in close proximity to
the Rutherford County Airport. Compensatory mitigation projects that have the potential to
attract waterfowl and other bird species that might pose a threat to aircraft should not be sited
within the limits specified by the Federal Aviation Administration Advisory Circular on
Hazardous Wildlife Attracts on or near Airports (AC No: 150/5200-33, 5/1/97) currently 10,000
feet from the airport and 5 statute miles if the attractant may cause hazardous wildlife movement
into or across the approach or departure airspace. Please provide written confirmation from the
FAA that the mitigation project will not present a hazard to aircraft.signed by
`A'
H U G H ES.A N D R EA. V V HUGHIly S AND EA WADE.1258339165
DN: c=US, o=U.S. Government, ou=DoD, ou=PKI,
ADE.1258339165 Date: o—USA
cn= UGHE .ANDREA. ADE.1258339165
Andrea Hughes
Mitigation Project Manager
Regulatory Division