20191132 Ver 1_USACE Initial Evaluation Letter with Comments_20200106

Strickland, Bev
From: Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, January 6, 2020 2:51 PM
To: Andrea Eckardt; Jake McLean
Cc: Tugwell, Todd J CIV USARMY CESAW (US); Kim Browning; Haupt, Mac; Davis, Erin B;
Bowers, Todd; Leslie, Andrea J; Wilson, Travis W.; Byron Hamstead
([e-mail]); Jones, M Scott (Scott) CIV USARMY CESAW (USA)
Subject: [External] Initial Evaluation Letter with Comments for the Wildlands Little Tennessee
Umbrella Mitigation Bank — East Buffalo Site (SAW-2019-01296) Graham County, NC
Attachments: SAW-2019-01296 WildlandsLittleTennesseeUMB-
EastBuffaloSite_lnitial Evaluation Response.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]<maiIto: [e-mail]>
Andrea,
Attached to this message is the Initial Evaluation Letter with comments for the Wildlands Little Tennessee Umbrella
Mitigation Bank— East Buffalo Site (SAW-2019-01296) in Graham County North Carolina. Feel free to contact me with
any questions.
This electronic copy is your official notification; no paper copy will be mailed. Feel free to contact me with any questions.
Regards,
Steve Kichefski
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District, Asheville Field Office
151 Patton Avenue, Suite 208
Asheville, NC 28801
(828)-271-7980 Ext. 4234
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 our website at
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0 to complete the survey online.

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
January 6, 2019
Regulatory Division
Re: NCIRT Review of the Wildlands Little Tennessee Umbrella Mitigation Bank Prospectus:
East Buffalo Site (SAW-2019-01296)
Wildlands Holdings IV, LLC
Attn: Mr. Shawn Wilkerson
1430 South Mint Street, Suite 104
Charlotte, North Carolina 28203
Dear Mr. Wilkerson:
This letter is in regard to your prospectus document for the proposed Yadkin Valley
Umbrella Mitigation Bank. The proposal consists of the establishment and operation of a 255-
acre stream mitigation bank located at the intersection of East Buffalo Road and Buffalo Lane,
near Robbinsville, Graham County, North Carolina (35.36389;-83.80889).
The Corps determined the prospectus document was complete and issued a public notice
(P/N # SAW-2019-01296) on July 17, 2019. The purpose of this notice was to solicit the views
of interested State and Federal agencies and other parties either interested in or affected by the
proposed work. In addition, the Corps and members of the Interagency Review Team (IRT)
conducted a field review of the proposed mitigation site on November 19, 2018. Attached are
comments received in response to the public notice or the initial field visit memo from the NC
Wildlife Resources Commission, the NC Division of Water Resources, the NC State Historic
Preservation Office, the Cherokee Nation and a field visit memo incorporating comments from
the attending IRT members.
The Corps has reviewed the information provided and considered the comments received
in response to the public notice and the field site visits. We have determined that the proposed
mitigation bank appears to have the potential to restore and protect aquatic resources within the

Lower Little Tennessee watershed 8-digit Hydrologic Unit Code (HUC) 06010204 of the Upper
Tennessee River Basin. Therefore, the bank sponsor may proceed with preparation of a draft
Mitigation Banking Instrument (MBI).
Please provide a response to the attached comments with your draft plan submittal. We
appreciate your interest in restoring and protecting waters of the United States. If you have
questions concerning the path forward for the proposed mitigation bank, please do not hesitate to
contact me at [phone] extension 4234.
Sincerely,
KICHEFSKI.STEVEN.L. Digitally signed by
KICH E FSKI.STEVEN.L.1386908539
1386908539 Date: 2020.01.0614:48:01-05'00'
Steve Kichefski
Regulatory Project Manager
Enclosures
Electronic Copies Furnished:
Todd Bowers, USEPA
Mac Haupt, NCDWR
Erin Davis, NCDWR
Byron Hamstead, USFWS
Andrea Leslie, NCWRC
Todd Tugwell, USACE
Kim Browning, USACE
Scott Jones, USACE

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
CESAW-RG/Kichefski
MEMORANDUM FOR RECORD
December 4, 2020
SUBJECT: Proposed Wildlands Little Tennessee Umbrella Mitigation Bank (UMB) Comment
Response (SAW-2019-01296)
PURPOSE: The comments listed below were received in response to the preliminary
site visit or the Prospectus document during the 30-day comment period in accordance
with Section 332.8(g) of the 2008 Mitigation Rule.
Zan Price, NCDWR
The following comments received via email January 9, 2019 in addition to comments incorporated
into field visit memo.
1. I generally don't have any issues with the updated pre -prospectus. I don't recall seeing UT
1 or UT6 on the November site visit so I can't comment on those reaches.
Andrea Leslie, NCWRC
Comments during the site visit were incorporated into the field visit memo except for the ones
noted below, which were received via email January 14, 2019.
1. There are several references to "NHP Managed Areas". Change NHP managed areas to
NHP Natural Areas.
2. I noted multi -flora rose on UT2 and multi -flora and privet on UT5; this should be treated. I
recommend that reaches proposed for preservation should be surveyed for invasives and
those found treated.
Elizabeth Toombs, Cherokee Nation, August 15, 2019
See attached comment letter.
Renee Gledhill -Early, SHPO, August 19, 2019
See attached comment letter.
Steve Kichefski/Todd Tugwell, USACE
General comments not captured in the field visit memo that was received via email from
Wildlands on December 12, 2018:
1. All resource labels used in the jurisdictional delineations should be the same or referenced
in the plan submittal for comparison.
2. Please be aware that final mitigation ratios will be determined at the draft mitigation plan

stage when a more comprehensive project submittal is available for evaluation.
3. UT2 seemed to have more sediment than some of the other preservation reaches (except
UT5), and the buffer vegetation was younger, so the trib was generally not as high quality.
4. UT3 had several hundred feet of underground flow that disconnected it from the upper
watershed. This area needed to be identified.
5. East Buffalo Creek main stem (upstream of the confluence with Ut2 Reach 2) appeared to
have areas that could use bank stabilization, especially on the right bank where the grass
was mowed. This area is a candidate for E2 (2.5:1) if the amount work needed justifies the
ratio. In the revised pre -prospectus, this reach is still shown at a 4:1 ratio.
6. The buffer width was discussed, and IRT applauded the fact that the buffer is proposed to
be much wider than the minimum requirement. It was also discussed that the wider buffers
would be considered toward justification for the proposed credit ratios, rather than being
considered using the non-standard buffer credit tool. This is primarily due to the extent of
preservation proposed on the site.
7. Field visit notes indicated that UT and UT6 were not being accepted for credit as part of
the bank due to their disconnected nature, however, as always final credit ratios will be set
as part of the draft plan review should Wildlands feel they should be included with the
project.
8. As discussed during the preliminary site visit, any crossings or buffer infringement by the
power lines north of East Buffalo Road will be considered when evaluating project streams
or wetlands.
9. Elaborate with draft plan submittal how the proposed work will affect any
existing wetlands alongside the current or relocated channels.
10. The remaining USACE comments were given during the site visit and included
within the site visit memo attached.
Steve Kichefski
Regulatory Project Manager
Asheville Field Office

Oflim of Bye CbW
BM John Baku
GWY.B DSP
Principal Chief
CHEROKEE NATION
0P c6 145sBran7Y
O-EOG.0
P.O. Bax W - Tahlequah, OK 74465-OW • 91 &453-5aW • cherokse M
S. JOB CnMCIlden
Deputy Principal Chief
aa. KU dEaF,0,Y
WPJX DWA O-EOGA
August 15, 2019
Steve Kichefski
United States Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
Re: SAW-2019-01296, Wildlands Little Tennessee Umbrella Mitigation Bank
Mr. Steve Kichefski:
The Cherokee Nation (Nation) is in receipt of your correspondence about SAW-2019-01296, and
appreciates the opportunity to provide comment upon this project. Please allow this letter to serve
as the Nation's interest in acting as a consulting party to this proposed project.
The Nation maintains databases and records of cultural, historic, and pre -historic resources in this
area. Our Historic Preservation Office reviewed this project, cross referenced the project's legal
description against our information, and found no instances where this project intersects or adjoins
such resources. Thus, the Nation does not foresee this project imparting impacts to Cherokee
cultural resources at this time.
However, the Nation requests that the United States Army Corps of Engineers (USACE) halt all
project activities immediately and re -contact our Offices for further consultation if items of cultural
significance are discovered during the course of this project.
Additionally, the Nation requests that the USACE conduct appropriate inquiries with other
pertinent Tribal and Historic Preservation Offices regarding historic and prehistoric resources not
included in the Nation's databases or records.
If you require additional information or have any questions, please contact me at your convenience.
Thank you for your time and attention to this matter.
Wado,
Elizabeth Toombs, Tribal Historic Preservation Officer
Cherokee Nation Tribal Historic Preservation Office
[e-mail]
918.453.5389

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
August 19, 2019
Steve Kichefski
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
Office of Archives and History
Deputy Secretary Kevin Cherry
Re: Wildlands Little Tennessee Umbrella Mitigation Bank, Little Tenncssee River Basin,
SAW-2019-01296, Graham County, ER 19-2305
Dear Mr. Kichefski:
We have received the public notice for the above project for review and have the following comment.
There are no known recorded archaeological sites within the project boundaries. However, the project area has
never been systematically surveyed to determine the location or significance of archaeological resources. Based
on the topographic and hydrological situation and the density of archaeological sites in the area, as well as the
recorded Cherokee history in the Buffalo Town area, there is a high probability for the presence of prehistoric
or historic archaeological sites at the project location.
We recommend that a comprehensive survey be conducted by an experienced archaeologist to identify and
evaluate the significance of archaeological remains that may be damaged or destroyed by the proposed project.
The archaeological survey is recommended for that portion of the project area with slopes of fifteen percent or
less. Potential effects on unknown resources must be assessed prior to the initiation of construction activities.
Two paper copies and one digital copy of the resulting archaeological survey report, as well as one digital and
one paper copy of the appropriate site forms, should be forwarded to us for review and comment as soon as
they are available and well in advance of any construction activities.
A list of archaeological consultants who have conducted or expressed an interest in contract work in North
Carolina is available at https://archaeology.ncdcr.gov/programs/environmental-review/archaeolOgical-
consultants. The archaeologists listed, or any other experienced archaeologist, may be contacted to conduct the
recommended survey.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.reviewkncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
(�� W(A&&%
Ramona Bartos, Deputy
Deputy State Historic Preservation Officer