Ver _Complete File_19961126

REPLY TO
ATTENTION OF

November 22, 1996

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890

Environmental Resources Section

Mr. Steven Kroeger
Division of Water Quality
North Carolina Department of Environment,
Health, and Natural Resources
4401 Reedy Creek Road
Raleigh, North Carolina 27607-6445

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Dear Mr. Kroeger:

We have developed a proposed Wetland Mitigation Plan for the Flood Damage Reduction
project at the Clinton Wastewater Treatment Plant. A copy of the plan is enclosed for your
review and comment.

Several concerns were raised during this coordination including a request for information
regarding our site selection process, the need for additional action to address the remote
location of the proposed mitigation site, and suitability of the Murphy Farms site to provide
compensatory mitigation under current North Carolina Division of Water Quality policy. These
concerns are addressed in the enclosed plan. In addition, comments regarding future flood
plain management by the city of Clinton have been provided to the city for their use.

The city of Clinton and the U.S. Army Corps of Engineers are anxious to have your
approval of the mitigation plan. We request your written comments regarding this proposal be
provided by December 6, 1996, to the following address: U.S. Army Corps of Engineers,
Wilmington District; Attention: Mr. Chuck Wilson (CESAW-EP-PE); Post Office Box 1890;
Wilmington, North Carolina 28402-1890.

If you have any questions regarding this letter, please contact Mr. Wilson at (910)
251-4746.

Sincerely,

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W. Coleman Long -"'-J ()
Acting Chief, Planning and
Environmental Branch

Enclosure

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WETLAND MITIGATION PLAN

FLOOD DAMAGE REDUCTION
CLINTON WASTEWATER TREATMENT PLANT
CITY OF CLINTON, NORTH CAROLINA

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FLOOD DAMAGE REDUCTION
CLINTON WASTEWATER TREATMENT PLANT
CITY OF CLINTON, NORTH CAROLINA

1.00 Proposed Project

The U.S. Army Corps of Engineers, Wilmington District, proposes to construct a flood
damage reduction project at the Clinton Wastewater Treatment Plant, <(linton, North Carolina.
This project described in the Detailed Proiect Report and Environmental Assessment on Flood
Damaae Reduction. Clinton Wastewater Treatment Plant. City of Clinton. North Carolina,
dated September 1993, included construction of a dike around the plant perimeter and minor
stream channel relocation for dike placement. The project also included the restoration of
4.8 acres of prior converted farmland (PC) on Williams Old Mill Branch or Great Coharie Creek
to offset 2.4 acres of wetland impacts.

The final dike alignment has been modified to avoid wetland impacts to the degree
practical. A survey of delineated wetlands within the final alignment shows a reduced wetland
impact area of only 1.8 acres and that stream channel relocation is no longer required.

In addition, the city of Clinton has recently acquired a 6-acre tract of land that is primarily
wetlands on Williams Old Mill Branch. A description and location of the tract is included in the
attached warranty deed (see Appendix A, Conservation Lands). Our analysis indicates that
long-term conservation of this tract and reduced flooding from the wastewater treatment plant
will improve water quality and aquatic habitat conditions. The 6-acre area located on Williams
Old Mill Branch would be surveyed and mapped by the city and land title amended by a
conservation easement assuring perpetual protection of the site.

2.00 Site Selection

, The site proposed for restoration in the Environmental Assessment, a small PC located
on Williams Old Mill Branch, has naturally reverted from PC to wetland and is no longer
suitable for restoration. Therefore, the identification of a new mitigation area was required.
Maps of U.S. Soil Conservation Service prior converted wetlands located in the Great Coharie
Creek 100-year flood plain were compiled by the U.S. Army Corps of Engineers during
feasibility level studies in 1993. These maps were reviewed by agents of the city of Clinton,
Sampson County, North Carolina, and the Wooten Company in August 1995. Sixteen flood
prone properties, with at least 5 acres currently or recently under cultivation, were identified for
further consideration. The aforementioned agents further narrowed the list to five sites which
were expected to be available for purchase, have a high potential for restoration, and direct
construction access. Th.ese five sites were inspected by the Corps in October 1995. Of the
sites visited, only one tract was found to have high potential for development as a mitigation
site; however, the owner of that site did not want to sell his property. Further investigation by
the city of Clinton, the Wooten Company, and Robert J. Goldstein and Associates, in January
1996, identified the proposed Murphy Farms site as a potential mitigation site for this project.

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3.00 Interagency Coordination

By letters dated August 9, 1996, and September 19, 1996, known interested parties were
provided an opportunity to comment on the Murphy Farms site and participate in the
development of this plan. An interagency field inspection of the proposed project area and the
Murphy Farms site was made on September 20, 1996. Agency comments regarding the
September 19 letter and site inspection are included in Appendix B.

All comments were considered in the development of this plan. Specific plan
requirements were incorporated to the degree practicable as described in section 5.00.
Request for additional information regarding site selection is provided in section 2.00. The
North Carolina Division of Water Quality (NCDWQ) indicated that current policy would not
allow mitigation at the Murphy Farms site. However, it is our understanding based on a
subsequent conversation with Mr. John Dorney of NCDWQ and Mr. Chuck Wilson that since
the project's 401 water quality certificate was issued under previous policy guidance the
current restrictions would nof apply.

4.00 Proposed Mitigation

Mitigation needs were recalculated consistent with procedures outlined in Attachment A,
Wetland Impacts and Mitigation Evaluation, Williams Old Mill Branch, to the previously
referenced Environmental Assessment assuming the following conditions: (1) a reduced
impact area of 1.8 acres and (2) prior establishment of the 6-acre conservation easement as
described above.

The mitigation plan includes the purchase and long-term management of a 3.6-acre
portion of the Murphy Farms Mitigation site described in the Murphv Familv Farms. Inc..
Mitigation Bank Comprehensive Wetlands Mitigation Plan (see Appendix C). Our evaluation
indicates that this action would provide suitable mitigation for project impacts resulting from the
filling of about 1.8 acres of wetlands associated with the proposed construction of the Flood
Damage Reduction project, Clinton Wastewater Treatment Plant, city of Clinton, North
Carolina.

Site Description. The Murphy Farms site is a 44-acre wetland restoration site formerly known
as Cypress Creek Bay that was developed as a private commercial venture on Murphy Family
Farms Tract 2233 (field 71). It is located adjacent to NC Highway 242, near Ammons's
Crossroads, northeastern Bladen County, North Carolina. The mitigation site and project
impact area are located within the Black River subbasin, and site development is generally
consistent with mitigation criteria described in the Detailed Proiect Report and Environmental
Assessment on Flood Damage Reduction. Clinton Wastewater Treatment Plant, dated
September 1993. The site which is designated prior converted wetlands (U.S. Natural
Resources Conservation Service letter dated March 20, 1996) was planted with wetland tree
species in 1995 and has had hydrologic restoration in 1996. The vendor will provide long-term
monitoring of the site and guarantee success of vegetation and hydrologic criteria over the
monitoring period as described in the purchase agreement.

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Site Development and Monitoring. The general site development and monitoring will be
conducted as described in Murphv Familv Farms. Inc.. Mitigation Bank Comprehensive
Wetlands Mitigation Plan as amended by the addition of th'e following terms and conditions.
Terms and Conditions.

. A 3.6-acre portion of the Murphy Farms site located near the site's original drainage would
be delineated, surveyed, and mapped in relation to the 44-acre site by the vendor.

. The sites hydrology will be confirmed to be saturated within 12 inches of the ground
surface, ponded, or flooded at least 12.5 percent of the growing season under reasonably
average climatic conditions. A hydrologic comparison to the mitigation site referenced wetland
will be made.

. Vegetation will be monitored to assure a minimum of 320 trees per acre including at least 6
hardwood species with no more than 20 percent of anyone species.

. Remediation, including site modifications and new plantings, will be made as needed to
meet hydrologic and vegetative goals. Periodic monitoring will be conducted as described in
the Murphv Familv Farms. Inc.. Mitigation Bank Comprehensive Wetlands Mitigation Plan but
will continue for at least 5 years after initial remediation is complete.

. The site is to be purchased by the city of Clinton. The purchase agreement will require the
site to be managed and protected in perpetuity. All commitments should be binding regardless
of future land ownership.

. Forestry activities are to be limited to that required for the management of old growth
hardwoods with no commercial harvest allowed.

. The previously described site documentation and annual monitoring reports will be
provided to the U.S. Fish and Wildlife Service, North Carolina Division of Water Quality, and
North Carolina Wildlife Resources Commission.

6.00 Success Criteria

This plan will be considered to be successful if at the end of 5 years the 3.6-acre site is
occupied by wetlands, as defined by 404 jurisdiction, with a minimum of 320 trees per acre
including at least 6 hardwood species and no more than 20 percent of anyone species.

7.00 Coordination

This plan has been coordinated with the following agencies and individuals.

Mr. John Hefner, Field Supervisor
Raleigh Field Office
U.S. Fish and Wildlife Service
Post Office Box 33726
Raleigh, North Carolina 27636-3726

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Mr. Wayne Hollowell
City of Clinton
Post Office Box 199
Clinton, North Carolina 28329-0199

Dr. Gerald Miller
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, NE.
Atlanta, Georgia 30365-2401

Mr. Keith Ashley
North Carolina Wildlife Resources Commission
102 Hillcrest Drive
Elizabethtown, North Carolina 28337-9782

Mr. John Dorney
Division of Water Quality
North Carolina Department of Environment,
Health, and Natural Resources
4401 Reedy Creek Road
Raleigh, North Carolina 27607 -6445

Mr. Olen Pike
The Wooten Company
120 North Boylan Avenue
Raleigh, North Carolina 27603-1451

Mr. Joe Best
City of Clinton
Post Office Box 199
Clinton, North Carolina 28329-0199

Mr. Frank McBride
North Carolina Wildlife Resources Commission
Post Office Box 118
Northside, North Carolina 27564-0118

Mr. Steven Kroeger
Division of Water Quality
North Carolina Department of Environment,
Health, and Natural Resources
4401 Reedy Creek Road
Raleigh, North Carolina 27607-6445

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Mr. Larry Hardy, Area Supervisor
Habitat Conservation Division
Beaufort Marine Fisheries Center
National Marine Fisheries Service
101 Pivers Island Road
Beaufort, North Carolina 28516-9722

Mr. Reef Ivy
Murphy Family Farms
Post Office Box 759
Rose Hill, North Carolina 28458-0759

Mr. Gary Mitchell
Mitchell and Associates, Inc
128 North Harding Street
Greenville, North Carolina 27858-1324

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APPENDIX A
CONSERVATION LANDS

NOR'l'H Ch....,UL.LNA,
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WARRANTY DEED

VULllbU ?AGE C:'ll.

WIT N E SSE T H:

SAMPSON COUNTY.

THIS DEED OF CONVEYANCE, Made this the 15th day of March,

1994, by and between J. McKINNON MOORE (WIDOWER), of Sampson County,
North Carolina, party of the first part; to the CITY OF CLINTON, a

municipal corporation organized and existing under the laws of the

State of North Carolina, party of the second part;

That the said party of the first part, for and in con-

sideration of the sum of Ten Dollars and other valuable considerations

to him in hand paid by the said party of the second part, the receipt

of which is hereby acknowledged, has bargained and sold, and by these

lying and being in NORTH CLINTON TOWNSHIP, Samp~on County, North

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presents does bargain, sell and convey unto the party of the second

part, its successors and assigns, that certain tract or 'parcel of land

BEGINNING at a stake on Beaver Dam where the old Williams
line crosses said run, and now called Faison's corner, and runs down
said run South 77 degrees 50 minutes \'lest 96 feettoa stake; thence
down said run South 50 degrees 20 minutes West 446 fe~t to a stake;
thence down said run South 86 degrees West 196 feet to a stake; thence
down said run South 75 degrees 30 minutes West 94 feet to a stake;
thence down said run South 83 degrees 25 minutes West 254 feet to the
mouth of the Marsh Branch; thence North 142 feet to a stake, Marable's
corner, draughon's old line; thence with the Draughon line North 55
degrees East 363 feet to a gum; thence the same line North 80 degrees
East 363 feet to a pine; thence the same line North 66 degrees East
479 feet to a holly in williams line; thence South 02 degrees 30 minu-
tes West 66 feet to a water oak; thence South 22 degrees West 447 feet
to the beginning, containing 6 acres, more or less, and being the same
lands described in deed from Mildred Amffions and others, to Jessie
Bethea and wife, Sarah Estelle Bethea, dated March 3, 1958, and
recorded in Book 677, at page 100, of the Sampson County Registry.
This also being the same land described in deed dated August 26, 1970,
from Jesse Bethea and wife, Sarah Estelle Bethea, to J. McKinnon Moore
and wife, Mildred J. Moore, recorded in Book 828, at page 467, in the
Sampson County Registry.

Carolina, and more particularly described as follows, to-wit:

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TO HAVE AND TO HOLD the above described lands, together

with all privileges and appurte~~~ses thereunto belonging unto the
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said party of the second part, J.ts1s~~,ctti?~9rs and fssigQs, to its only
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use and behoof forever .j?"k'.,

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~nd the said party of the first part covenants to and with

t~e said party of the second part, its successors and assigns, that he

is seized of said premises in fee and has a right to convey the same

in fee simple; that the same is free and clear from all encumbrances,

and that he does hereby warrant and will forever defend the title to

the same against the lawful claims of all persons whomsoever.

IN TESTIMONY WHEREOF, said party of the first part has

hereunto set his hand and seal the day and year first above written.

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J. McKINNON MOORE t..Q

(SEAL)

NORTH CAROLINA,

SAMPSON COUNTY.

I, ~~V , a Notary PUblic in
and for the coun and tate aforesaid, do hereby certify that J.
McKINNON MOORE (WIDOWER), personally appeared before me this day and
acknowledged the due execution of the foregoing instrument for the
purposes therein expressed.

~~~~ Witness my hand and notarial

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NOR'l't-bqA:,i.{d:l/fNA,
SAMPS6N;\t~OUNTY .

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seal, this the j/ day of

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foregoi n y. 1-t.o.i (V
ti c is certified
to be cor ect. This instrument was presented for registration this
day and hour and duly recorded in the office of the Register of Deeds
of Samnpson County, North Carolina, in Book ~, at page ~.

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REGISTER

, 1994, at 11=31 o'clock,

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This \:J.~ day of

BY:

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512 N. Salisbury Street, Raleigh, North Carolina 27611, 919~733~3391
Charles R. Fullwood, Executive Director

MEMORANDUM

TO: Chuck Wilson ".
Wilmington District, U.S. Army Corps of Engineers

FROM: Bennett Wynne dPJ
Habitat Conservation Section

DATE: September 25, 1996

SUBJECT: Post 9-20-96 meeting request for final comments regarding the mitigation plan for
the proposed flood damage reduction project at the'Clinton Wastewater Treatment
Plant, Sampson County, North Carolina.

The North Carolina Wildlife Commission provides the following comments in response to
the September 20, 1996 onsite meeting coordinated by the U.S. Army Corps of Engineers
(Corps). Our comments are provided in accordance with provisions of the National
Environmental Policy Act (42 U.S.C. 4332(2)(c)) and the Fish and Wildlife Coordination Act (48
Stat. 401, as amended; 16 U.S.C. 661-667d).

The proposed flood damage reduction project at the Clinton Wastewater Treatment Plant
has undergone several changes since first described in a 1993 Environmental Assessment. Project
background is described in August 9, 1996 correspondence from the Corps to the various review
agencies. At this point in time, 1.8 acres of riparian wetland impacts at the wastewater treatment
plant are proposed to be mitigated at a 44 acre PC site in Bladen County formerly known as
Cypress Creek Bay. The tract, owned by Murphy Family Farms, is some 20 miles distant of the
impact area and is planned for eventual use as a mitigation bank. According to project
proponents, the Bladen County site was targeted after a search for onsite and nearby mitigation
sites proved fruitless. During the September 20, 1996 meeting, a previously filled onsite area was
checked for hydric soils, but none were found. The proposed mitigation ratio is 2: 1.

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MEMO TO: Chuck Wilson

2

September 25, 1996

Much of the additional information we requested regarding the proposed Bladen County
site was provided at the September 20, 1996 meeting. Efforts to reduce the impact area and
attempts to locate an onsite or nearby mitigation site appear to have been extensive. This
combined with the threat to water quality of area streams when flood events inundate the
wastewater treatment plant persuades us to accept the proposed mitigation site under the
following conditions.

1. To reflect the distance of the mitigation site from the impact area and the fact that the
mitigation would be out-of-kind (riparian vs. bay), the mitigation ratio is changed from
2:1 to 4:1.

2. To enhance accountability, the 7.2 acre mitigation parcel for this specific project is
delineated and mapped. This mitigation parcel will then be superimposed on a map of the
entire 44 acre PC site. We suggest that the mitigation parcel be located as close to the
bay's original drainageway as possible.

3. The conservation easement with deed restrictions for the mitigation parcel will prohibit
timber harvest. Also, if ownership of the parcel changes, restrictions will continue to be
binding.

4. Ifremedial action is req~ed during the monitoring period, monitoring is extended 5.
years past the remedial action.

It should be noted that our acceptance of the proposed mitigation site under the aforementioned
conditions should not be taken as an indication that we will favorably review future attempts at
off-site or out-of-kind mitigation.

Thank you for the opportunity to comment. Please call me if you have questions at (919)
522-9736.

cc: s: \boatfish \habcon \coast\d4 (clintwwt. doc)

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I UNITED STATES DEPARTMENT OF COMMERCE
Ii NaciofUll OeMnie and Atmospharle AdmintstNtian
NATIONAL MARINE ASHEAIES SERVICE

I Southeast Regional Office
9721 Executive Center Drive North
st. Petersburg, Florida 33702

September 26, 1996

Lt. Colcme,l T~rry R. Youngb1uth
District. E:nq'ineer i"JVilwington Dicotrict
Department. ,:.f the Army, Corps of Engineers
P. C. BCJX 1;390
WillI' :i.ngt:on, North Cl"rolina 28402-1890

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Deal: Lt. Co l,one.l )~oiln<1bluth:

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Thi!:1 re~;poncls to your september 19, 1996, letter requesting our
CoIt1t.(~nt.f; .:m the !~(urphY FalJlily Farms, Inc., M~tigation Bank.
CorrJ;l;.ehensiYLW~t.l:allds Mitiqation Plan submitted for the proposad
flccd da:magl~ reduct.i.on project at the Clinton Wastewater Treatment
Plant" Cli.nt:onl North Carolina.

We 'havE! reviewed th(;l subject plan and have determined that fishery
reSC1:lrCE~S f"r \I/hi.c:h \lTe are responsible will be minimally impacted
by the prciposed project and the associated mitigation plan.
The:r(:~for.e, ',,'e ha,VE~ 110 comments.

If w(;! C~tn b,~ of fllr':her assistance, please advise.

cc: FWS, ATLA I GA.
FWS, R.;~leigh, :'lC
EP}.., ArrLA, GA
NCDEHN'H" RalEdgh I NC
NCDEill{l~ I Horelh,:~ad city, NC
F{SE02

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Fax:[phone]

Oct 18 '96 14:29

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Jo n atha), 'B~' H'l' we's,:' $e'cfetary : ,
A. prest~n Fiow~rd,; Jr:, P.E., Oirect~r

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.' 'Mr~,Chuq1c::WdsQn; CESAW-;EP-PE
PO Box 1890 'T::, .. ' '
Wil~ington~,~~:'f8402-1890 ,

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" ':', ,'Tb.aDk',ydri 'fQr:'ai::n.mgiIig, the,sit~"viSit to the Clinton wastewater'tre~tment plant and
the,~wphY'fanri'nutigation sit#:,on:,~te.inber 20, 1996. ~e site,:visitS V(ere 1very ::
':..': "oene~cial.< J teci)~zi,that, th~':hydr~wgy:~ yege~on at the ori~cO~a~x:y'
'u' rt.1itig8tio*-sire.,haye:becQ~j~6~ ~ making the si~ urisui~Ie. for iestonition.'
,Hqv;reye.t; this 'siti'isJtin<?rionirig well ~ a wetland aod,shotild, ,b,e ,conSidered. (<< ,
preServation:Qt, e~~ent.., We strOri,8ly encourage securing the OJ:i.gin~rsite as part of'
the~niiti~atio~pl#_: ' -,' ' , >,' '
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,,: '.... ~~~~~,.Site..~t_we:EijsC1JSS~:th~ search for, and the Jack of o~r s,uitable
, .' cpiiiperiSiltpii riiiti~p~ gles, ,in ~ ~rshed. It w~ noten$ely,cleat 6n hdw this ,search
was,conducied;; :Detiill~ 'on,ho~ this .se8rth:was conducted are necessary and Ihust include:
, l)"me: s~h'.~'2)'\vho cOB~cie4' ~,~h, and 3) when 'thes~h\V;~'40nducted. ,
'~e~p1ost,;i~~~~ r:~f~r~ inf~~n'is to suppo.rtthe. Sectioii4o.l:=,V~ter Quality,
, ,~ertlfi~on> :In~d~on:this iriformatlc;>n may be useful ill, the development of the Wetland
Restotatio~'PrQ~~' '; , '.,

" " :,." ~~t:,J~licy.prevenis ~ use .~:n~n,ri.parian siteS as .comp~nsato~ n)itigation fot
,.. ripai'iaQi~ac.~~l ~urt~g ~original,po~pensatory p,ritiga,tion Site:~ ap~servation or
, e~~~~pt;~IJ1p.~n~nt:'roa}':~.8. p~jof YOUJ;'"roitigation plap;. "H~~evei~. ~d~o~ '.:
, ~ompensatory,~tig$OIi, In, a ~ ~ lllaY' be necessary. ,Sec~ng a n.P~ SIte .
s.tiita~le:r~rIi~~~ori':~.pl'e:~~. AI~ugh the Murphy ?~y F~ si~"appears to
, have,an..excellentpotenttalJor:-nompaQ8IJ"w.etland rest9ratlon it IS unsUitable for
"compensatOlj.iriitigaq,on':for the rip~liaidinpa6ts associated with <tike,oo~tiud.tion at the
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Ointoi1~~~w~[tte~tinent plant. , ~ ':' '
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i786.:'~e~ c1~ct:roe ifY9U!h.ave afty,questions. My telephonenum~~:is. (919) 733-

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Steven Kroegerj, ' .
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Benne~VI~ne; N'C WR.C ~
Gary ,Mitchell; ~tcheU and Associates.

Environilienta!-Scienc~ ,Branch · 4401 Reedy Road
Telephone '919- 7 33:9960.' ,
An f,qual'Opporwnily ,Aftlrn\'~"" Action Employer

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Raleigh, North Caroruia 27607
, , PAl< # 733-99j9
jO% =yclodi.l~ poot OOllQUmer p.pe.

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United States Department of the Interior

FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh. Nonh Carolina 27636-3726
October 17, 1996

W. Coleman Long, Acting Chief
Environmental Planning Branch
U.S. Army Corps of Engineers
Wilmington District
P.O. Box 1890
Wilmington, North Carolina 28402-1890

Attention: Mr. Chuck Wilsont CESAW-EP-PE

Dear Mr. Long:

The U.S. Fish and Wildlife Service provides the following
supplemental comments regarding the Clinton Wastewater Treatment
Plant (WWTP) flood protection project in Sampson County, and the
Cypress Creek Bay prior converted agricultural lands mitigation
site at Murphy Farms in Bladen County, NorthCarolina.

As we have reported verbally, the Service concurs with the comments
in the memorandum from Bennett Wynne of the North Carolina Wildlife
Resources Commission (WRC) to you on September 25, 1996.
Specifically, we accept your contention that the protective berm
around the WWTP has been designed to minimize impacts to
jurisdictional wetlands, and, we agree that off-site mitigation may
provide some benefits that could not be gained onsite due to cost
constraints.

The WRC lists four conditionst which we concur with, for acceptance
of the proposal. These are: use a 4:1 mitigation to impact ratio;
locate the mitigation acreage near the bay's original drainage and
document it's location and areal extent in some enforceable manner;
develop means to ensure the mitigation site is protected in
perpetuity; and, monitor the mitigation site for five years after
the last remedial action occurs.

Additionally, during our site visit and in telephone conversations
afterwards, we concurred with additional conditions developed by
Steven Kroeger (of the North Carolina Department of Environmental
Management, Division of Water Quality [DWQ]). These additional

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conditions include: define mitigation success as (1) attaining the
same hydrologic regime as the reference sitel and (2) meet U.S.
Army Corps of Engineers I Wilmington District guidelines and
criteria for number of woody stems per mitigation acre.

The agencies have discussedl but not resolvedl a mechanism whereby
the City of Clinton develops regulations that implement non-
structural floodplain management as part of the mitigation plan.
Such a plan would be a good faith effort by the City demonstrating
their committment to restoring the water quality in the Great
Coharie Creek basin.

The Service believes that the sediments accumulating at the mouth
of Williams Old Mill Branch are the result of current riparian zone
and floodplain management regulations. Successfully identifying
individual sources of the material is unlikelYI and irrelevant.
The general loss of material from riparian zones and the upstream
floodplain, and its' subsequent deposition at the Branch mouth, is
indisputable. We believe that the extent of encroachment by road
and other developers, including homeownersl into riparian zones or
floodplains I is correlated with the amount of suspended matter
carried downstream.

The suspended matter in Williams Old Mill Branch are being
deposited where the Branchsl energy is dissipitated at the Branch
mouth. The depositional bar is blocking channels and creating a
hydraulic barrier. Water is backing up Williams Old Mill Branch,
and has semi-permanently inundated the floodplain areas adjacent to
the WWTP. We believe that if riparian and floodplain management in
Clinton is not improved I sediment accumulation will continue I and
the flooding on Williams Old Mill Branch (and Great Coharie Creek)
will increase in magnitude and frequency in response.

Flooding exacerbated by human activities degrades water quality and
destroys both terrestrial and aquatic habitat. If past experiences
are a guide, the increased magnitude of flooding will render the
protective dikes obsolete sooner than anticipated. Incursions of
flood water into the WWTP, and other sources of contamination are
likely to create adverse impacts on fish and wildlife resources.

We believe that by implementing non-structural floodplain
management planning as part of this project's mitigation, the City
of Clinton will provide long-term protection of itsl environment,
downstream water quality, and effectively protect life and
property.

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Finally, we note that the mitigation plan can be improved in
several ways, none of which we are requesting at this time. There
should be a series of reference sites to present a realistic
concept of natural variability in measured parameters. The
parameters should be summarized statistically, with a mean and
standard deviations. That would provide a statistically valid
indicator of success. The present mitigation site management plan
will not enable reviewers to determine whether the variance between
the single reference site and mitigation sites are reasonable
differences or indicate that success has not been met.

The concept, originally proposed by the applicant, that meeting the
minimal hydrology indicator of a jurisdictional wetland is adequate
should be rejected in these types of schemes. The Clean Water Act
has specific goals: to restore, enhance, and protect the
biological, chemical, and physical integrity of the nation IS
waters. The Service has published mitigation guidelines: we
believe that in-kind mitigation, including wetland form, function,
and structure, is ecologically very important and should be a
priority. From a biological perspective, it is unacceptable to use
a jurisdictional criteria such as hydrology to define the success
of a supposedly in-kind mitigation.

It is also our belief that mitigation should be functional for the
duration of an impact (generally, until a project is dismantled and
the site is reclaimed). This is fundamentally different than
providing assessments for five years after mitigation as commenced,
or for five years after remedial action has been completed. We
believe that it is only natural to assume that mitigation wetlands
may require periodic maintenance, just as a construction project or
dike may require maintenance. We believe that project proponents
should actively maintain any wetland mitigation just as they
maintain a given construction or other project.

Thank you for this opportunity to comment on the Clinton WWTP
project. If you have any questions or comments, please call Kevin
Moody at [phone] extension 19.

Sincerely,

TO~9Jt~:t

Acting Field Supervisor

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cc: NCWRC, Kinston, NC (Bennett Wynne)
NCWRC, Raleigh, NC (Frank McBride)
NCDEM, Raleigh, NC (Steven Kroeger)
EPA, Wetlands Regulatory Branch, Atlanta, GA (Thomas Welborn)
NMFS, Beaufort, NC (Larry Hardy)

FWS/R4:KMoody:KM10/15/96:919/856-4520 ext.19:B:\km-wwtp2

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APPENDIX C

Murohv Familv Farms. Inc.. Mitigation Bank Comprehensive Wetlands Mitigation
Plan

""t~..._, '.

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G ~F&s~

Mitchell and Associates, Inc.

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Environmental Consultants

128 N, Harding Street. Greenville. North Carolina 27858. 919 - 752 - 4077 . Fax: 919 - 752- 7380

DRAFT

MURPHY FAMILY FARMS, INC.
MITIGATION BANK

COMPREHENSIVE WETLANDS MITIGATION
PLAN

Requested by

Murphy Farms, Inc.
Post Office Box 759
Rose Hill, NC 28458

Prepared by

Mitchell and Associates, Inc.
128 North Harding Street
Greenville, NC 27858

September 11, 1996

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1.0 INTRODUCTION

Mitigation banking, the process by which land is restored, enhanced, or preserved
in perpetuity and then utilized to off-set impacts elsewhere is becoming a common
practice. This process is accepted by regulatory agencies as a feasible method to
compensate for unavoidable wetland loss as addressed in MOA (EP A, ACOE) 404 B 1
guidelines,
Murphy Farms, Inc, has began the process of restoration of prior converted (PC)
farmland to wetland status on a 44 acre tract in NE Bladen County to establish a
mitigation bank. The tract.lies within the South River watershed which discharges to the
Black River. These watersheds are subunits of the Cape Fear River. Mitchell and
Associates, Inc. has been retained by Murphy Family Farms to prepare a comprehensive
mitigation plan and continue with the necessary site modifications to re-establish
characteristic wetland vegetation, soils, and hydrology to satisfy the three mandatory
criteria for wetland status.

2.0 SITE DESCRIPTION

The mitigation site is located near the community of Ammon, Bladen County,
North Carolina (Figure 1.). Access to this site is via NC 242, approximately 3 miles,south
of the intersection ofNC 242 and NC 210. From NC 242 an unpaved private road leads
the site. This tract ofland lies in a previously drained Carolina Bay locally known as
Cypress Creek Bay. Prior to the initiation of the mitigation project the land was used for
agricultural purposes. Row crops, primarily feed com and soy beans have been planted on
the site within recent years. The USDA, Natural Resources Conservation Service (NRCS)
has designated the site as "PC" (see attached letter). '

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3.0 SITE HISTORY

Prior to any human impacts this land probably would have fit the description of a
Bay Forest. Bay Forest is a forest ecosystem designation described in the North Carolina
Natural Heritage Program's publication, Classification of the Natural Communities of
North Carolina, These forested wetlands are described as wet, nutrient poor, peatlands
dominated by the bay species, Persea borbonia (redbay), Gordonia lasianthus (loblolly-
bay), and Magnolia virginiana (sweetbay). Other canopy species include: Pinus serofina
(pond pine), Nyssa biflora (swamp tupelo), Acer robrom (red maple), PimiS taeda
(loblolly pine), and Chamaecyparis thoides (Atlantic white-cedar). Shrub species include:
Lyonia lucida (fetterbush); Cyrilla racemiflora (titi), Lyonia ligustrina (male-berry), lfex
coriacea (low gallberry), and lIex cassine (henderson-wood).
Although a precise site history is unavailable, this tract, like most forests of the
region, was probably an extractive forest resource (turpentine and selective logging) from
the mid nineteenth century until conversion to farm field within the last two decades.
Since conversion to agriculture, the site has been drained by ditching and all woody
vegetation and woody debris has been removed from the site. Agricultural practices at the
site consisted of conventional row cropping with com, soy bean, and possibly small grain.
The Bladen County soil survey (1990) indicates the presence of Pant ego Wlllbric
Paleaquuts) and Croatan (Terric Medisaprists). These soils are shallow histosols or
oligotrohpic mineral soils with organic sutface layers characterized by poor drainag~ and
highly decomposed organic material. Typically these soils are found within Carolina Bays,
depressions, and along flood plains. Agricultural practices such as annual cultivation, crop
removal, and drainage has altered the upper soil horizons. Most certainly, organic content
has decreased and upper soil horizons have been mixed.

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4.0 RESTORATION

4.1 Vegetation

In order to restore this tract to wetland status, tree and shrub species which are
commonly found in wetlands of this region were planted in March of 1995, prior to
involvement by Mitchell and Associates, Inc. Seedlings were planted in parallel rows
were planted in 6 foot intervals along each row with the exception of Atlantic white cedar
which was planted in 5 foot intervals, Atlantic White-cedar was planted in closer intervals
to facilitate dense canopy development commonly found under natural conditions. Pre-
emergent herbicide was applied to the site immediately following planting to reduce
noxious weed competition, Treatment consisted of banding the herbicide within the tree
rows to allow, suppress competing weeds, volunteer recruitment by wetland, and
minimize herbicide usage. Tree species and quantity planted within the mitigation site is
presented in Table 1.

Table 1. List of tree species planted, quantity, and percent of total each species makes up:

SPECIES QUANTITY PERCENT
Quercus phellos Willow Oak 1,000 3.7
Quercus arkansana Water Oak 1,000 3.7
Quercus fa/cata var. pagodifolia Chenybark Oak 2,000 7.4
Quercus lyrata Overcup Oak 2,000 7.4
Nyssa sylvatica Swamp Black Gum 8,500 31.8
Fraxinus pennsylvanica Green Ash 1,000, 3.7
Nyssa sylvatica var. biflora Tupelo Gum 3,000 11.4
Taxodium distichum Bald Cypress 3,400 12.3
Myrica cerifera Wax Myrtle 2,000 7.4
Alnus glutinosa Black Alder 2,000 7.4
Cephalanthus occidentalis Button Bush 1,000 3,7

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Total 26,900 100.0

Chamaecyparis thyoides

Atlantic White-cedar

2,000

4.2 Hydrology

The original hydrology within the tract, as well as Cypress Creek Bay has been
altered by ditching, Ditches were allowed to remain open for the first year after planting
to facilitate drainage and root development. In August 1996 a series of earthen plugs
were used to stop water flow and create saturated soil conditions. Additionally, the main
in flowing ditch was diverted into the tract to facilitate soil saturation without affecting the
drainage in adjacent farm fields (Figure 3,). A flashboard riser was established at the
southwestern end of the tract to allow further hydrological manipulation of the tract, but
has been abandon and replaced with a permanent earthen plug.

4.3 Soils

Soil characteristics have been altered by the agricultural practices. With the
removal of the natural hydrologic regime, tillage, compactor, and crop removal the
organic content of the soils most likely decreased. Presently, the site is void of Coarse
woody debris and woody roots. In the two years since the cessation of cultivation, a...
surface organic layer has developed from senesced herbaceous plants; An accumulation of
leaf litter and woody debris should develop as the stand ages.

4.4 Tree Density I Survivorship

On 28 June 1995 a site visit was conducted to estimate vegetation survivorship.
A qualitative spot check of sampling status indicated an approximately 70 - 80%
survivorship for broadleaf and shrub species. Improper planting resulting in root exposure
is the likely cause of most tree mortality. Additionally, late (March) planting and

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excessive spring drought may have increased-plant stress and mortality. Conversely the
conifer species, Taxodium distichum (bald cypress) and Chamaecyparis thyoides (Atlantic
White-cedar) exhibited high survivorship (>90%).
Herbicide application had been successful in suppression of weed growth within
the planting strips, Outside planting strips, weed growth was occurring but did not merit
control measures at this time. Eupatorium capillifolium (dog fennel) was the primary
weed observed at the site,

On 03 November 1995 a second site visit was conducted and a more extensive and
quantitative survey was completed. The tract was divided into four blocks based on an
apparent planting pattern 'and field design (Figure 2.): Block 1 was planted with broadleaf
species only, Block 2 was planted with broadleaf species and Taxodium distichum (bald
cypress), Block 3 was planted with broadleaf species only, and Block 4 was planted with
Chamaecyparis thyoides (Atlantic White-cedar) only Tree and shrub survivorship in each
of the four blocks was 45%,63%,52%, and 78% respectively. Among all species
Taxodium distichum (bald cypress), Chamaecyparis thyoides ~Atlantic White-cedar) an~
Fraxinus pennsylvanica (green ash) attained the highest survival rates. Weed status wa{
determined based on a qualitative, visual assessment in each block. Andropogon
virginicus (broomsedge), Panicum spp., Eupatorium capillifolium (dog fennel), and '.
Polygonum spp. (smartweed) were the most problematic weed species in Blocks 1 and 2.
Eupatorium capillifolium and Panicum spp. were the most problematic species in Blocks
3 and 4, Soil organic content (low bulk density) was greatest in Block 1,0.47 g/cm'.
Block 4 had the greatest mineral content; bulk density of 1.18 glcm>. Hydrology within
the site remained unchanged.

On 20 August 1996 a site visit was conducted to determine actual tree densities in
each block. A 1/10th acre radius permanent plot was established within each block.
Surviving sapling density in each plot was recorded, as well as qualitative observations of
weed species. Tree density in each block is presented in Table 2.

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II

Table 2. Density of all tree species present in 1/1Oth acre plots located in each of the four
blocks, See Figure 2 for location of plots.

Mean tree density within the mitigation bank is 399 trees per acre. Trees appear
healthy with new growth evident. Weed suppression was still somewhat apparent along
planting rows, however, some weeds had overtopped saplings. Dominant weed species
present consist of Eupatorium capillifolium (dog fennel) and Panicum spp.

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5.0 SITE MONITORING

To insure the successful restoration and enhancement of this site long term
monitoring will be required. The key to attain a desired restored and enhanced wetland
system will be to insure that every measure is taken to provide the conditions for wetland
soils and hydrology to develop and establish the desired vegetation. In order to be
successful with restoration and enhancement, long term monitoring of the site will be
required. Vegetative counts, soil characteristics, and hydrologic regime will be monitored
for a period of 5 years. Site visits will be conducted every 6 months during this time
period. Reports of the mitigation bank status as well as any needed remedial measured
required will be filed withtbe Mitigation Bank Review Team (MBRT) after each site visit.

5.1 Vegetation

Vegetation planted within the mitigation site; as well as naturally occurring
wetland species and weed status will be monitored by 1/10 acre permanent plot methods
during each site visit. Canopy densities will be assessed annually with the use of a
densitometer. To remediate initial sapling losses, additional plantings of Taxodium
distichum (bald cypress) will be initiated in spring 1997.

5.2 Hydrology

Hydrologic monitoring within the mitigation site will consist of determining the
water level at various locations across the site. Monitoring wells will be placed in three
locations within the mitigation site after remedial planting and will be utilized to monitor
hydrology within the site. Monitoring of the wells will take place during each site visit.
Wells will consist of3" diameter lined well pipe, each well will be installed to a depth of at
least 1 m,

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5.3 Soil

Soil characteristics will be monitored by visually examining organic accumulation
and horizon development. Bulk density will be measured to determine soil organic
content. Hydric soil characteristics are expected to be enhanced as a result of hydrology
manipulations.

6.0 Restoration of Ecological Functions

As a result of this restoration effort, several ecological functions should be re-
established, Initially, an increase in carbon storage, water storage, and the removal of
potential pollutants from agricultural runoff is expected. The site will undoubtedly serve as
wildlife habitat for many game and non-game species.
The site is already being utilized by a number mammali~ herpetological, and bird
species, These include Odocoileus virginianus (white-tailed deer), (quail), and
Agkistrodon contortrix (southern copperhead), Elaphe obsoleta obsoleta(black rat
snake),Crotalus horridus (timber rattlesnake), and others. As the tre,estand ages and
developes a canopy the site will be utilized by other wildlife which forage and shelter in
adult tree stands such as: Ursus americanus (black bear), Vulpes vuIpes (red fox),
Urocyon cinereoargenteus (gray fox), Procyon /otor (raccoon), Didelphis virginiana
(opossum), Sciurus carolinensis (gray squirrel), and smaller rodents.
Bird species include: various species of predatory hawks and owls, as well as
smaller bird species such as Turdus migratorius (american robin), Cyanocitta cristata
(blue jay), Mimus polyglottos (mocking bird), Cantopus virens (eastern wood pewee),
Panls carolinensis (Carolina chickadee), Thryothoros ludovicianus (Carolina wren),
Parus bic%r (tufted titmouse), among others. It should be noted that this habitat
provides excellent migratory and resident song bird habitat and nesting areas.

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Herpetological species found in the region include: Agkistrodon p;sc;vorus
(eastern cottonmouth), Agkistrodoll contortrix contortrix (southern copperhead), Crotalus
adamanteus (eastern diamondback rattlesnake), Nerodia erythrogaster erythrogaster
(redbelly water snake), Opheodrys aestivus (rough green snake), among others, Turtle
species in the region include: Terrapene carolina bauri (eastern box), Clemmys guttata
(spotted turtle), CheIydra serpentina (common snapping turtle), and Killostemon
sllbrubrum sllbrubrum (eastern mud turtle). Many toad species from both the Scaphiopus
(spadefoot) and Bufo (true toads) families, as well as frogs from the Hyla (tree frogs) and
Rana (true frogs) families, Various species of salamanders from the Ambystoma (mole
salamanders), Notophthalmus (newts), and Plethodon (woodland salamanders) families,
Anolis carolinensis (green'anole) is also found in the region, and open water system will
be left in the center to facilitate amphibian habitat.

7.0 Preservation and Protection

Ultimately, the intent of this mitigation package is to put this land in a natural state
in perpetuity. This will be achieved through conservation easements created with deed
restrictions. Furthennore, this will establish the head water wetland to a historic channel
Cypress Creek which will add to the needed buffer to the major river, stream, and
tributary corridors of the greater Cape Fear basin. Recent depletion of our wetland
stocks increase the need for preserving wetland functions in a natural state. In addition,
continued availability of Nationwide Permits to property owners in urban areas increase
the need for the creation of successful mitigation bank locations which will preserve and
protect large contiguous wetland areas and establish valuable wildlife corridors. In this
particular region of North Carolina, drained Carolina Bays are common. Future
restoration of adjacent bay areas is proposed which will serve to put more of our
watersheds with wetland buffer in a natural state for the future preservation for the health
and well being of our natural ecosystem.

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Appendix 1. Bibliography

1. Brinson, M, M, (1993). "A hydrogeomorphic classification for wetlands," Technical
Report WRP-DE-4, US. Army Engineer Waterways Experiment Station, Vicksburg, MS.

2. Lewis, W, M. and National Reaserch Council (US.). (1995). Committee on
Characterization of Wetlands. <'Wetlands: characteristics and boundaries". pp. 307.

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\

(~1)
,,,, . . ;t.,v
"\-~y

United States
Department of
Agriculture

Naturot
Resources
Conservation
Service

, :! 2 Agriculture Service Center
::,; ,; III Circlt:
;::;',Ioethtown, NC 28337
y,S 1 0-862-6936 (F191 0-862-6138

March 20, 1996

Gary A. Mitchell, President
Mitchell and Associates, Inc.
128 N. Harding St.
Greenville, NC 27858

Dear Mr. Mitchell,

Per your request, this is to confirm that Murphy Family Farms tract 2233, field 70 and 71
11<lVe a wetlands de,signation of-"pe" (Prior Converted Wetlands).

The only comment or question 1 have with regards to YOl,' restoration plan is will you need
to re-route the main canal along the access on the southv.c.s~ side of the field in order to
(LIlly restore hydrology?

Please call me if I can be of further assistance.

s:cerel,y,. J

~G.~
Samuel G. Warren
District Conservationist

'I'_~ ~.....I"~eC St.,tE:S Department of Agriculture CUSOAI ptohibits discrimination in its proQrams on the basis of race. COIOf, national origin, sex. religion, age, disability, politic81 beliefs and marital Of
" . .c. ::;~C:::~l:>. (Not .11 prohibited bases apply to .U programsJ. Persons with disebilitic$ who require alternative me6flS 101 communication of progr.m information (braiUc. tarce ptiot, aUciiot.ape. c~-=.;
..C :.":OC' '>1e USDA Office of Communic.tions.t 12021720-6881 (voicel or (2021 720-7808ITDD1,

~;l.;;!..,nt, write the Secretary of Agriculture. U.S. Department of Agriculture, Washington D.C., 20260 Of ':ilIJ C?O.2J 720.7327 (voice) Of (202) 720--4107 (TOOL uSDA is an eqU.it
. :':;';'~~I\unity employer.

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