20180795 Ver 1_Response to IRT comments_20191125

Slingshot Mitigation Plan Comment Responses:
DWR Comments, Mac Haupt and Erin Davis:
This site is in the Jordan Lake watershed, are there any plans to pursue riparian buffer or nutrient offset
strategy?
• No, RS has not been contracted by DMS for buffer or nutrient credits.
2. The number of crossings for the size of the site is a negative aspect of this site. Is there any way at least
one crossing could be removed?
• No, the conservation easement has already been recorded. The farthest downstream
crossing was originally 45' in width and scaled down to a 25' width based on the IRT field
notes. The additional crossings are required by the landowner.
3. Section 3.5- DWR noted that there is only one soil profile boring listed in the Appendix. Given that this
site has wetland restoration credit, a much more thorough soil characterization will need to occur
before DWR will approve the proposed wetlands in this mitigation plan. During the site visit,
DWR field notes stated that many of our soil cores did not see lower chromas required for hydric
soils.
• Additional soil profiles have been added to the appendix, with the locations depicted on
Figure 4.
4. Section 8.1.1- Outfall Structures- DWR does not support the use of the Terracell drop structure. DWR
prefers the utilization of natural materials in the channel bed. Moreover, DWR does not believe the
slope change is so drastic that the artificial structure is warranted.
• Terracel has been changed to Drop Structure in Figure 513, Figure 713, and in the text of the
document.
5. Section 8.3- Wetland Restoration — the plan states that, "...the construction of ephemeral pools will add
an important component to groundwater restoration activities. These activities will result in the
restoration of 1.02 acres of jurisdictional ....riverine wetlands." DWR would like to stress that if
ephemeral pools are counted as wetland restoration then they will need to be constructed so that
there is periodic drying.
• Ephemeral pools will be constructed such that they dry during the summer and will have
woody debris habitat incorporated into the feature.
6. Table 14 Planting Plan- DWR is recommending a cap of 5% in the planting of Green Ash due to the green
ash borer.
• The planting list has been updated to include species ordered for the Site. The final
planting list includes 400 green ash, which is less than 4% the total number of planted
stems.
7. Table 16- Monitoring Table-DWR requires a stream gauge on UT3 in the upper third of the reach.
• This is an EII reach added by the IRT/DMS. As the channel was identified by the IRT,
confirmed to be a stream by NCDWR and the Corps of Engineer during a PDJ, and no
channel alternation work is to be conducted within, or adjacent to the channel, we
respectfully request to leave this gauge off the monitoring protocol for the Site.
8. Table 16- DWR likes the fact that benthic macroinvertebrates will be monitored.
• Good.
9. From a landscape position standpoint, DWR would rather not have mitigation sites draining (in close
proximity) into ponds or lakes.
• This is an unavoidable aspect of this Site and was discussed during our initial Site visit.
Note: Downstream, Lake Reidsville, is a municipal drinking water source for the Town of
Reidsville and the local government is very appreciative of the project for the water quality
benefit.
10. Figure 513- there are areas which appear to be in green where the current channel exists. Are these areas
meant to be proposed for wetland restoration credit? If these areas are proposed for wetland credit,
DWR believes restoration credit may not be appropriate.
RS has successfully performed and received R credit in old stream channels in the past. We

have data from many similar projects that shows that these areas are successfully converted
back to wetlands.
11. DWR notes that there were no photos of the site in the mitigation plan. It is often beneficial in the
review of the document to have the photos, especially if it has been awhile since the site visit. In
addition, DWR would like to see photos associated with the cross sections (Appendix B) if at all
possible.
• Appendix J has been added to the document and contains Site photographs. Photographs of
existing conditions cross sections is not available.
12. Design sheet 2C- shows an engineered riffle with rip rap being placed on the bank slope. DWR does
not approve of rip rap being placed on the banks.
• This has been removed from the plans set.
13. Design sheet 4- DWR needs to see a scale on these sheets. Also, the thick dashed black line, is that
limits of disturbance? DWR prefers that significant markings on the plan view be clearly labeled.
• Completed
14. Design sheet 8- DWR does not believe the utilization of a Terracell structure is warranted when the rest
of the project was using log cross vanes.
• Terracel has been changed to Drop Structure in Figure 513, Figure 713, and in the text of the
document.
15. Design sheet E2- What activities will be done to return the areas utilized as haul roads back to natural
conditions?
• See construction notes, these will be added to the haul road sheets.
16. What percentage of this project has less than 50 foot buffers?
UT 4 has less than a 50-foot buffer on its right bank, as it enters the property. UT 4 is a
preservation reach and accounts for less than 2% of the buffer area. All other streams have
a minimum 50-foot buffer on both stream banks.
USACE Comments, Kim Browning:
17. The correct USACE Action ID is SAW-2018-01170. Please correct the cover page.
• The USACE Action ID has been updated.
18. Please depict photo points/digital image stations on Figures 10. If the fixed cross-section locations are
to be used, please describe that in the text in section 7.1.
• A note was added to Table 15 indicating the following. "Visual Assessment will be
complimented by permanent photographic points located at each permanent cross section
and vegetation plot."
19. Section 8.3- Wetland Restoration — The inclusion of ephemeral/vernal pools is acceptable, and should
be 8-14" depressions that dry up yearly so that predatory species cannot colonize.
• Ephemeral pools will be constructed no deeper than 12 inches, will incorporate woody
debris for habitat, and will be expected to dry during summer months.
20. This section also discusses filling drainage ditches. If ditches are to be filled, please show these areas on
the construction plans, and the length of the ditch plug.
• Channel plugs will be added to the construction plans.
21. It would be beneficial to add some coarse woody debris to the depressional areas in the buffers and
throughout the adjacent wetlands for habitat, and to help store sediment, increase water
storage/infiltration, and absorb water energy during overbank events.
• Woody debris will be included as small piles in the riparian and wetland areas for habitat.
22. Please discuss how fescue will be treated within the buffer establishment area.
RS acknowledges that this site does face challenges based on the existing vegetation. These
challenges will be overcome through a combination of herbicide applications and
mechanical site prep techniques. Preliminary herbicide treatments have already been made
targeting woody non-native invasive species (NNIS) including Kudzu, Tree of Heaven,
Privet, and Multiflora Rose (September 2019) both within the site boundaries and along the

margins of the site on the parent tract. An additional herbicide treatment for privet and
fescue is planned before the end of 2019 (pre -construction). During construction
mechanical site prep techniques including ripping will be used to diminish any remaining
undesired pasture grasses and facilitate tree establishment. The planned permanent seed
mix will also mitigate the regrowth of fescue by including cool season forbs. After
construction a regular herbicide program will be implemented targeting both dense pasture
grasses and NNIS. This integrated approach will provide a high level of control of fescue
and other undesired species and will support establishment of the desired hardwood forest
community.
23. UT3- should have a flow gauge in the upper third of the reach.
• This is an EII reach added by the IRT/DMS. As the channel was identified by the IRT,
confirmed to be a stream by NCDWR and the Corps of Engineer during a PDJ, and no
channel alteration work is to be conducted within, or adjacent to the channel, we
respectfully request to leave this gauge off the monitoring protocol for the Site.
24. Section 7.0- Potential constraints... the last sentence is unclear.
Section 7.0 was altered to clarify work conducted for the document.
25. Table 1- Are additional credits for macroinvertebrate sampling being sought? If so, please clarify this
table.
• RS is not seeking extra credit for macroinvertebrate sampling on this project.
26. Table 16- Will fixed photo points be monitored annually? If so, please indicate if they will be at all
cross- sections, or depict on monitoring map.
• A note was added to Table 15 indicating the following. "Visual Assessment will be
complimented by permanent photographic points located at each permanent cross section
and vegetation plot."
27. Table 17 Success CriteriaStreams, please add a statement (regarding UT3) at least 30-days
continuous surface water flow for intermittent streams.
The statement was added to Table 17 Success Criteria for streams.
28. Stream restoration will bisect existing wetlands where Slingshot Creek intersects with GA Wetland, and
where UT intersects with GE Wetland. At least one wetland gauge should be installed in wetland
GE to ensure no functional loss.
• An additional groundwater gauge was added to Wetland GE to ensure no functional loss.
In addition, Table 16 was updated to include 10 groundwater gauges, instead of 9
groundwater gauges.
29. Figure 3 in the JD —All streams are referred to as Troublesome Creek. Isn't this Slingshot Creek? Was
this what it was called when proposed as a bank site? Please use consistent labeling throughout
the review period, and it's especially important for the PCN to track impacts.
• During our NCDMS review it was requested we change the name from Troublesome Creek
(as designated in the PJD submittal) to Slingshot Creek.
30. When submitting the PCN, please include an estimate of the number of trees, or acres, to be cleared for
the NLEB 4(d) Rule.
• We will include an estimate of the number of trees, or acres to be cleared in our PCN
submittal.
31. Table 14--Please confirm that one target community is being proposed for the entire Project Site
(stream side, wetland, and upland areas). If multiple planting zones are proposed, please show
zones on a figure/design sheet and reference in the planting table.
• Figures 8A and 8B (Planting Plan) depict the locations of planting zones and the number
of species to be planted within each planting zone. The table depicted in the figures match
Table 14 in the document, which specifies species and number of seedlings to be planted
in each planting zone.