20160847 Ver 2_field comments-Draft Prospectus_20160621

Strickland, Bev
From:Daniel Ingram <[e-mail]>
Sent:Tuesday, June 21, 2016 8:16 AM
To:Bailey, David E SAW
Cc:Haupt, Mac; Tugwell, Todd SAW; Hughes, Andrea W SAW
Subject:RE: RES Cape Fear Umbrella Mitigation Bank - Draft Prospectus
Thanks, David.

We will address these comments and re-submit the Prospectus. I think some of the design comments will have to be
left somewhat unresolved pending survey and preliminary design, but I can re-phrase the prospectus to indicate that.

Daniel Ingram|Resource Environmental Solutions, LLC

Direct: 919.209-1056 | Mobile: [phone]

From: Bailey, David E SAW \[mailto:[e-mail]\]
Sent: Monday, June 20, 2016 5:05 PM
To: Daniel Ingram <[e-mail]>
Cc: Haupt, Mac ([e-mail]) <[e-mail]>; Tugwell, Todd SAW
<[e-mail]>; Hughes, Andrea W SAW <[e-mail]>
Subject: RE: RES Cape Fear Umbrella Mitigation Bank - Draft Prospectus

Daniel,

Thank you for your draft Prospectus for the above referenced project. Please reference Action ID: SAW-2016-01258 in
future correspondence related to this project. Note that this email contains official comments regarding the draft
Prospectus as well as the bank sites; if a signed letter is preferred please let me know.

Comments from USACE:

1)Please see the text comments on the attached pdf.

2)The District is not in favor of treating the entire Cape Fear River under a single instrument due to differences

between ecoregions and the resources they provide.
3)Dairyland:

a.it must be demonstrated that the channel can be reconnected to the floodplain to justify a restoration

approach, otherwise the reach should be enhancement at a reduced ratio (5:1).
b.the western drainage, from UT-1 down to HB-3 has been historically impacted by beaver, and several

dams are still present within the system. We have concerns about the stated uplift in these reaches,
particularly given the recent removal of several dams on this reach, especially upstream of the road
crossing. This system is still in transition following the removal of the dams, so it is difficult to determine
what the appropriate approach is in some areas.
c.UTs 2 and 3 are in reasonable condition and there is little justification for credit due to functional uplift

on these reaches. UT-1 does not appear to be a stream system, but rather a wetland drainage, so
stream enhancement along this reach is not appropriate.
4)Cloud and Banner:

a.the large wetland area draining to UT-4 is primarily preservation, not enhancement. Some

enhancement may be appropriate in the immediate vicinity of the primary ditch along the northeastern
side, but that is really the extent. The wetland is generally of good quality, though 5:1 for preservation
is a high ratio in this case due to the age of the vegetation and level of threat. Also, It is not clear if the
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stream (UT-4) should start within this wetland, as this feature appears to be a ditch dug to drain the
wetland rather than a stream.
b.Further evaluation of the main stem of Back Creek is necessary to assess the appropriate approach and

credit amount.

Comments from NCDWR:

1)Section 1.1.1: Dairyland-the second paragraph mentions that this project will also offer nutrient offset through

the NCDMS. During the site visit you mentioned that the buffer portion of this site may be used for some of the
Duke/Coal Ash settlement case. If any part of this or any project is targeted for the Duke settlement case,
specific language should be included that governs its credit management, especially crediting, oversight, and
long term management.
2)Table 2 identifies Chewacla as hydric, however it is only a hydric B.

3)Table 4 identifies Chewacla, Congaree, Helena, and Mixed Alluvial land as hydric, although none are hydric A.

4)The proposed mitigation summary in Table 6 agrees with what we saw in the field. The only thing we would

have to further investigate would be UT-1 which is proposed as EIII at 5:1. NCDWR would not accept the
increase in SMUs for "non-standard" methods until we investigate the method and determine repeatability.
Also, recently removed beaver dams seen during the site visit were a concern.
5)Table 7: changes needed include:

a.Back Creek: if planting is all that is proposed (EII), NCDWR is not sure 2.5:1 is appropriate. The IRT should

look at EII a little closer.
b.UT-1: this should be removed, my field notes showed no stream there.

c.UT-2: this may not all be EII, could be some preservation.

d.UT-6: may have to see more on EI section before agreeing to give credit, although this looked mostly ok.

e.Wetlands: the only wetland enhancement on this project is north (and to the east) of Back Creek. The

wetlands located south of Back Creek are basically preservation. I don't recall the wetland located to the
north of Back Creek and on the western portion of the site.

Thank you for your submittal and use of the draft Prospectus in this process. Please use the above information in
reviewing and revising the Prospectus for resubmittal. Site-specific questions should be directed to Todd Tugwell
(USACE) and Mac Haupt (NCDWR). IF you have any other questions please let me know.

Sincerely,

Dave Bailey

---
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.
Fax: [phone]
Email: [e-mail]

The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete the Customer Satisfaction Survey located at
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0.

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-----Original Message-----
From: Daniel Ingram \[mailto:[e-mail]\]
Sent: Friday, May 20, 2016 2:06 PM
To: Tugwell, Todd SAW <[e-mail]>; Bailey, David E SAW <[e-mail]>
Cc: Haupt, Mac ([e-mail]) <[e-mail]>
Subject: \[EXTERNAL\] RE: RES Cape Fear Umbrella Mitigation Bank - Draft Prospectus

My apologies… the version I sent this morning was not the correct file. Please use the attached prospectus. Thanks.

Daniel Ingram|Resource Environmental Solutions, LLC

Direct: 919.209-1056 | Mobile: [phone]

From: Daniel Ingram
Sent: Friday, May 20, 2016 9:02 AM
To: 'Tugwell, Todd SAW' <[e-mail]>; Bailey, David E SAW <[e-mail]>
Cc: Haupt, Mac ([e-mail]) <[e-mail]>
Subject: RES Cape Fear Umbrella Mitigation Bank - Draft Prospectus

Todd and David,

The prospectus for the RES Cape Fear Umbrella Bank is attached. This includes the Dairyland and Cloud and Banner
sites. Please review and let me know if you need anything else for the public notice and IRT coordination. I can send
copies to the other IRT members if needed. Thanks.

Daniel Ingram|NC Regulatory Manager|Resource Environmental Solutions, LLC

302 Jefferson St., Suite 110 | Raleigh, NC 27605
Direct: 919.209-1056 | Mobile: [phone]

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