20190603 Ver 2_Wildlands Response to IRT Comments_20200106

Strickland, Bev
From: Chris Roessler <[e-mail]>
Sent: Monday, January 6, 2020 1:53 PM
To: Barnes, Kyle W CIV USARMY CESAW (US); John Hutton
Cc: Tugwell, Todd J CIV USARMY CESAW (US); Kim Browning; Haupt, Mac; Davis, Erin B;
Bowers, Todd; Wells, Emily N; Twyla Cheatwood; Wilson, Travis W.; Gledhill-earley,
Renee
Subject: [External] RE: Pasquotank Umbrella Mitigation Bank/Folly Swamp
Attachments: FollySwamp_Wildlands Response to IRT Comments_6Jan2020.pdf
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Hi Kyle-> Attached are Wildlands' response to your additional comments on the Prospectus. Please feel free to let us
know if you have any further concerns or thoughts.
Separately, would you or Kim please work with us to schedule the IRT to see the—12,000 linear foot preservation site in
Gates County? We're calling that Acorn Hill. We'll have a pre -Prospectus ready before that visit.
Thanks very much, Chris
Chris Roessler I Senior Scientist/Project Manager
0: 919.851.9986, x 111 M: 919.624.0905
Wildlands Engineering, Inc.
312 W. Millbrook Rd, Suite 225
Raleigh, NC 27609
-----Original Message -----
From: Chris Roessler
Sent: Tuesday, December 10, 2019 8:01 AM
To: Barnes, Kyle W CIV USARMY CESAW (US) <[e-mail]>; John Hutton
<[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CESAW (US) <[e-mail]>; Browning, Kimberly D CIV USARMY
CESAW (USA) <[e-mail]>; [e-mail]; Davis, Erin B <[e-mail]>;
[e-mail]; Wells, Emily <[e-mail]>; Twyla Cheatwood <[e-mail]>;
[e-mail]; [e-mail]
Subject: RE: Pasquotank Umbrella Mitigation Bank/Folly Swamp
Got it, Kyle, thank you. No need for a paper copy.
We included a response to comments letter in the Prospectus that addressed Mac's and Kim's comments from the
December 2018 site visit.

We will draft another response to comments letter for the additional comments you provided on the Prospectus. Good
to communicate now while we're developing the design and mitigation plan.
I'll be in touch with that by next week. Have a good one, Chris
Chris Roessler I Senior Scientist/Project Manager
0: 919.851.9986, x 111 M: 919.624.0905
Wildlands Engineering, Inc.
312 W. Millbrook Rd, Suite 225
Raleigh, NC 27609
-----Original Message -----
From: Barnes, Kyle W CIV USARMY CESAW (US) <[e-mail]>
Sent: Friday, December 6, 2019 10:56 AM
To: Chris Roessler <[e-mail]>; John Hutton <[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CESAW (US) <[e-mail]>; Browning, Kimberly D CIV USARMY
CESAW (USA) <[e-mail]>; [e-mail]; Davis, Erin B <[e-mail]>;
[e-mail]; Wells, Emily <[e-mail]>; Twyla Cheatwood <[e-mail]>;
[e-mail]; [e-mail]
Subject: Pasquotank Umbrella Mitigation Bank/Folly Swamp
Chris,
Attached are the comments that resulted from site visits, public notice, and the submittal of the prospectus for the
Pasquotank Umbrella Mitigation Bank/Folly Swamp site in Gates County, North Carolina, Corps Action ID# SAW-2018-
02026. Also included is the initial evaluation letter for this phase.
This electronic copy is an official Department of the Army Notification. However, if you wish to receive a paper copy, one
will be mailed upon request.
Please let me know if you have any questions or concerns.
Kyle Barnes
Regulatory Project Manager
US Army Corps of Engineers
Wilmington District
Washington Field Office
910-251-4584
We at the U.S. Army Corps of Engineers Regulatory Branch are committed to improving service to our customers. We
would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
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Thank you for taking the time to visit this site and complete the survey.

WILDLANDS
ENGINEERING
January 6, 2020
Mr. Kyle Barnes
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Washington Field Office
RE: Response to IRT comments on December 18, 2018 Field Meeting Minutes
Folly Swamp Mitigation Site, Gates County, NC
Pasquotank River Basin - 03020105
USACE Action ID No. SAW-2018-02026
Dear Mr. Barnes,
Wildlands received comments from Kyle Barnes and the NC IRT on December 6, 2019 on the Folly
Swamp Prospectus. This letter provides our responses to those comments.
Comments on Folly Swamp Prospectus
Kyle Barnes, USACE, December 6, 2019
1. The Pasquotank HUC is 02010205. The prospectus indicates the Pasquotank HUC as 03020105 in
multiple locations.
Thank you for noting that. We'll look to get it right in the mitigation plan.
2. Wetlands have been identified outside of the project area along Folly Swamp Reach 1. 1 have
concern that there may be a drainage effect on these adjacent wetlands.
Wildlands will install a groundwater gage(s) to monitor wetlands hydrology in this area before
and after construction to determine whether the stream design created a drainage effect. This
area will be identified in the preconstruction notification for an NWP 27. Additionally, Wildlands
will seek to minimize impacts to this area and conduct a wetlands delineation in the area by
MY5 to show that additional wetlands are created. Wildlands will offset any impacts to the
identified wetlands with onsite creation of floodplain wetlands.
3. The project as discussed will result in a significant amount of spoil and the needed area to
stockpile. Areas adjacent to Powell Branch and within the floodplain of the non -project area of
Folly Swamp have been identified as spoil stockpile areas. Removing vegetation and stockpiling
spoil within these areas are counter to the purpose of stream and wetland mitigation. These
areas should be avoided for spoil stockpiling because it removes or reduces existing
buffer/riparian area.
Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609

The identification of spoil disposal locations included large blocks to evaluate jurisdictional
wetlands. Our intention is not to put spoil immediately adjacent to the conservation easement,
but we wanted to know where wetlands are present in the general areas. Wildlands will place
spoil in non -project areas (i.e., outside of CEs) such that the no negative effect on drainage is
created. If spoil placement causes runoff to enter the CE as concentrated flow, Wildlands will
include design measures to detain and diffuse the runoff.
Finally, Wildlands will be obtaining a no -rise certification for FEMA flood mapping so the spoil
must be placed outside of the 100-year floodplain limits.
Some concern for Morgan Branch. Stockpiling soil in the identified area only limits the function of
the buffer/riparian area outside of the project area.
See response above. A travel way is located between Folly Ditch and the proposed spoil area.
We will be targeting an area along NC 32 for spoil disposal and will keep it some distance from
Folly Ditch and the conservation easement. Any effect on drainage into the CE will be
ameliorated with design measures that promote runoff detention and diffusion.
5. Barker Branch: I have concern that the project will have issues with the owner/farmer when the
land outside of the easement becomes wetter. There needs to be a larger easement area to
prevent additional ditching and draining when the agricultural fields become too wet to farm.
We considered this when drafting the proposed conservation easement. The easement extends
more than 500 feet upstream from the start of stream credit. It also covers two ditches that
drain to Barker Branch. The valley rises quickly beyond the existing right bank so more of the
easement will be beyond the left bank. We will examine the proposed contours to determine if
the mitigation project would adversely affect agriculture. Due to wet conditions, the landowner
and farmer have low expectations, now and in the future, for crop yield from the field adjacent
to and southwest of the proposed CE.
In addition, installing the culvert to Greene Branch will remove flow from the ditch on the west
side of this field. Finally, we may widen the proposed CE if it appears doing so would include
agricultural land that will become unacceptably wet as a result of the project.
6. Green Branch: The headwater approach in upper Green Branch is a concern due to the fact that
it is fully dependent on flow from adjacent property that enters through a culvert. After seeing
the site in a high rainfall season and a semi drought season I have concern that the headwater
reach will only be a wetland in "normal" conditions.
We acknowledge your and Mac's concern. We will base our approach on the Outer Coastal Plain
Guidance and set performance standards accordingly. We will also monitor stream flow as well
as wetland hydrology and herbaceous plant communities.
Wildlands has visited several examples of the Coastal Plain headwater approach, including the
DMS Watts Site in Perquimans County, and the Nutrien Hell Swamp and Sage Gut Sites in
Beaufort County. These sites appear to be slowly showing a trend toward having stream
characteristics.

On the IRT site visit to Greene Branch in December 2018, Mac Haupt stated that, at this time,
the requirement for stream hydrology is 30 consecutive days of streamflow. This is confirmed by
the October 2016 IRT mitigation guidance. Mac suggested measuring streamflow with a camera
is probably the best method for a coastal plain headwater approach.
7. Flow is a concern on Powell, Morgan, Green, and Barker's Branch.
See the acknowledgement above. Flow is not expected to be an issue on Powell or Morgan
Branch due to the drainage area size. Barker Branch is known to have streamflow at nearly all
times according to the farmer.
We hope that these responses adequately address the IRT's comments. If not, feedback is requested as
we proceed into the mitigation plan phase.
Sincerely,
Chris Roessler
Project Manager
[e-mail]