20091236 Ver 2_YR 5 Credit Release Letter_20200630

Strickland, Bev
From: Sugg, Mickey T CIV USARMY CESAW (USA) < [e-mail] >
Sent: Tuesday, June 30, 2020 10:21 AM
To: [e-mail]; fritz.rohde; Twyla Cheatwood - NOAA Federal
([e-mail]); Davis, Erin B; Dunn, Maria T.; Wilson, Travis W.; Mairs,
Robb L; Snider, Holley; MacPherson, Tara; Bowers, Todd; Tugwell, Todd J CIV USARMY
CESAW (US); Kim Browning
Cc: Jon Vincent; Preziosi, Christian; Corey Novak; Jessop, Jordan E CIV USARMY CESAW
(USA)
Subject: [External] YR 5 Credit Release Letter for White Springs Tract (LCFUMB in Brunswick
Co- near Boiling Spring lakes)
Attachments: lowercapefear'20review. pdf
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[e-mail]
Good morning all,
I have attached the Yr. 5 credit release letter, which includes the release tables. In my previous email regarding 5%
withheld stream credits, I didn't realize we were at the potential credit release Task 8.0 in the stream table. You will see
that the 15% credits at Task 8.0 are being withheld in lieu of the 5% until the March stream corrective measure can be
reassessed.
Pls call me if you have any questions or would like to conduct a site visit,
-mickey
Mickey Sugg, Chief
Wilmington Regulatory Field Office
U.S. Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403
[phone] (direct line)
[phone] (fax)
"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 "

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
June 29, 2020
Regulatory Division
Action ID. SAW-2009-02054
Sent via Email:
Mr. Jon Vincent
LCFUMB, LLC
Dear Mr. Vincent:
This letter serves to address the mitigation credit release from our evaluation, in
coordination with the Interagency Review Team (IRT), of the March 2020 Year 5
monitoring report for the White Springs Tract associated with the establishment of the
Lower Cape Fear Umbrella Mitigation Bank (LCFUMB) in Brunswick County, North
Carolina. Please reference the January 23, 2013 executed Mitigation Banking
Instrument (MBI); and my May 27, 2020 onsite meeting with Messrs. Christian Preziosi
and Corey Novak of Land Management Group, Inc., along with Mr. Jordan Jessop of
our office. Also, reference our December 2, 2019 letter concerning the previous year
monitoring report.
White Springs Tract:
As disclosed in the report and observed during the site inspection, the contingency
plan had been initiated to address the abundance of volunteer pine and sweet gum and
the erosional location of the stream bed and bank in proximity of grade control
structures #1 and #2. The main pine and sweet gum suppression took place in August
2019 with subsequent events conducted into the early spring of 2020. However, the
stream corrective measure was not initiated until March 2020.
Our evaluation of the hydrology concern at Well #11 was expanded during our May
27th inspection. As current rainfall conditions provided a good baseline for our
assessment, it has been determined that the well location is situated along the
upland/wetland boundary. Hydrology conditions within the wetland side of the boundary
are comparable to the water level conditions in similar onsite landscape locations. With
this determination, our office has concluded that the performance standards for the non -
riparian wetland areas have been met and all hydrology monitoring can cease for this
wetland type.

-2-
For the riparian wetlands and stream components, it has been determined that the
success criteria have been met; however, the corrective measures for the stream bed
and bank are recent and stabilization has yet to be fully verified. Our office, through
coordination with the IRT, has agreed to reassess the stream stability at this location at
the end of the summer. With this uncertainty, the 15% (or 226.2 linear feet) in Task 8.0
of Table 2C will be withheld until the stability is verified. Stability at this location is
important because it is situated at the point of an elevation change and has a greater
potential of resulting in headcutting and compromising the upstream bed and bank if not
corrected.
In accordance with the September 5, 2018 Updated Credit Release Tables
(enclosed), the current credit release is the following: 10% (or 0.2) of the riparian
wetland credits in Task 7.0 of Table 2A, remaining 15% (or 9.66) of the non -riparian
wetland credits in Task 7.0 of Table 2B, and 15% (226.2 linear feet) of the stream
credits in Task 7.0 of Table 2C. All the 15% (226.2 linear feet) stream credits in Task
8.0 of Table 2C are being withheld until stream stability can be confirmed.
To date, total credit release for the White Springs Tract is 1.6 credits of riparian (non-
riverine) wetlands, 64.41 credits of non -riparian wetlands, and 1,281.8 linear feet of
stream credits. The non -riparian credit numbers reflect the 1.69 credit reduction
adjusted amount detailed in our September 4, 2018 letter.
Please be reminded of your obligations pursuant to the January 23, 2013 MBI;
including the continued maintenance inspections of the Bank, as well as beaver control,
in order to evaluate the condition and stability of all streams and wetlands. Should you
have any questions, please do not hesitate to contact me at the Wilmington Regulatory
Field Office, telephone [phone] or at [e-mail].
Sincerely,
SUGG.MICKEY. Digitally signed by
S U GG.M IC KEY.T.1229800830
T.1229800830 Date: 2020.06.30 09-56 04 -04'00'
Mickey Sugg, Chief
Wilmington Regulatory Field Office

-3-
Copies Furnished via email w/ enclosure:
Mr. Jon Vincent, LCFUMB LLC
Mr. Christian Preziosi, Land Management Group, Inc.
Mr. Corey Novak, Land Management Group, Inc.
Ms. Tara McPherson, NC DCM
Mr. Todd Bowers, USEPA
Ms. Kathy Matthews, USFWS
Mr. Travis Wilson, NC WRC
Ms. Maria Dunn, NC WRC
Mr. Fritz Rohde, NMFS
Ms. Twyla Cheatwood, NMFS
Ms. Erin Davis, DWR
Mr. Robb Mair, NC DWR

LOWER CAPE FEAR UMBRELLA MITIGATION BANK
Updated Credit Release Tables - September 5, 2018
Table IA. Credit Release for Riparian (Riverine) Wetland Enhancement and Restoration
SNEEDEN TRACT'
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (%
Released
Credits
cumulative
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
1.58
1.58
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
15 (30)
1.57
3.15
Biological Improvements
3.0 Year 1: Fulfill Success
1/2015
10 (40)
1.05
4.2
Criteria
4.0 Year 2: Fulfill Success
1/2016
15 (55)
1.58
5.78
Criteria
5.0 Year 3: Fulfill Success
1/2017
20 (75)
2.10
7.88
Criteria
6.0 Year 4: Fulfill Success
1/2018
10 (85)
1.05
8.93
Criteria
7.0 Year 5: Fulfill Success
1/2019
15 (100)
1.57
10.5
Criteria
TOTAL
100%
10.5
10.5
Table 1B. Credit Release for Ri arian (Riverine) Wetland Preservation - SNEEDEN TRACT
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (/o
Released
Credits
cumulative)
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
12.1
12.1
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
85 (100)
68.5
68.5
Biological Improvements
TOTAL
100%
80.6
80.6
Table 1C. Credit Release for Riparian (Non-Riverine) Wetland Preservation - SNEEDEN TRACT
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (/o
Released
Credits
cumulative)
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
0.1
0.1
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
85 (100)
0.7
0.7
Biological Improvements
TOTAL
100%
0.8
0.8
1 Refer to Table 3 (p. 5) of MBI for original credit release schedules for the Sneeden Tract.
Page 1 of 5 Pages

Table 1D. Credit Release Schedule for Stream Restoration — SNEEDEN TRACT
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (%
Released
Credits
cumulative
Released
1.0 Signing of the MBI;
Recordation of Conservation
11/30/12
15 (15)
366
366
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
15 (30)
366
732
Biological Improvements
3.0 Year 1: Fulfill Success
1/2015
10 (40)
244
976
Criteria
4.0 Year 2: Fulfill Success
1/2016
10 (50)
244
1,220
Criteria
5.0 Year 3: Fulfill Success
1/2017
10 (60)
244
1,464
Criteria
6.0 Year 4: Fulfill Success
1/2018
10 (70)
244
1,708
Criteria
7.0 Year 5: Fulfill Success
1/2019
15 (85)
366
2,074
Criteria
8.0 Documentation of Two
Bank -full Events in Separate
TBD
15 (100)
367
2,441
Years
TOTAL
100%
2,441
2,441
Table 1E. Credit Release Schedule for Stream Preservation — SNEEDEN TRACT
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (/o
Released
Credits
cumulative)
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
132
132
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
4/2014
85 (100)
751
751
Biological Improvements
TOTAL
100%
883
883
Page 2 of 5 Pages

Table 2A. Credit Release Schedule for Riparian (Non-Riverine) Forested Wetlands - WHITE SPRINGS2
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (%
Released
Credits
cumulative
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
0.3
0.3
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
2/2015
15 (30)
0.3
0.6
Biological Improvements
3.0 Year 1: Fulfill Success
1/2016
10 (40)
0.2
0.8
Criteria
4.0 Year 2: Fulfill Success
1/2017
10 (50)
0.1
0.9
Criteria
5.0 Year 3: Fulfill Success
1/2018
10 (60)
0.2
1.1
Criteria
6.0 Year 4: Fulfill Success
1/2019
10 (70)
0.1
1.2
Criteria
7.0 Year 5: Fulfill Success
1/2020
10 (80)
0.2
1.4
Criteria
8.0 Year 6: Fulfill Success
1/2021
10 (90)
0.2
1.6
Criteria
9.0 Year 7: Fulfill Success
1/2022
10 (100)
0.2
1.8
Criteria
TOTAL
100%
1.8
1.8
Table 2B. Credit Release for Non -Riparian (Non -Forested) Wetlands - WHITE SPRINGS
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (/o
Released
Credits
cumulative)
Released
1.0 Signing of the MBI;
Recordation of Conservation
1/15/13
15 (15)
9.66
9.66
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
2/2015
15 (30)
9.66
19.32
Biological Improvements
3.0 Year 1: Fulfill Success
1/2016
10 (40)
6.44
25.76
Criteria
4.0 Year 2: Fulfill Success
1/2017
15 (55)
9.66
35.42
Criteria
5.0 Year 3: Fulfill Success
1/2018
20 (75)
12.88
48.3
Criteria
6.0 Year 4: Fulfill Success
1/2019
10 (85)
6.44
54.74
Criteria
7.0 Year 5: Fulfill Success
1/2020
15 (100)
9.66
64.41
Criteria
TOTAL
100%
64.41
64.41
2 Refer to Table 2 (p. 5) of MBI for original credit release schedules for the White Springs Tract.
Page 3 of 5 Pages

Table 2C. Credit Release Schedule for Stream Restoration — WHITE SPRINGS
Projected
Percentage of Wetland
Credits
Cumulative
Task
Completion Date
Credits Released (%
Released
Credits
cumulative
Released
1.0 Signing of the MBI;
Recordation of Conservation
11/30/12
15 (15)
226.2
226.2
Easement Deed; Delivery of
Financial Assurances
2.0 Completion of Physical and
2/2015
15 (30)
226.2
452.4
Biological Improvements
3.0 Year 1: Fulfill Success
1/2016
10 (40)
150.8
603.2
Criteria
4.0 Year 2: Fulfill Success
1/2017
10 (50)
150.8
754.0
Criteria
5.0 Year 3: Fulfill Success
1/2018
10 (60)
150.8
904.8
Criteria
6.0 Year 4: Fulfill Success
1/2019
10 (70)
150.8
1,055.6
Criteria
7.0 Year 5: Fulfill Success
1/2020
15 (85)
226.2
1,281.8
Criteria
8.0 Documentation of Two
Bank -full Events in Separate
TBD
15 (100)
226.2
1,508.0
Years
TOTAL
100%
1,508
1,508
Page 4 of 5 Pages

Table 2. Mitigation Tvne and Ouantitv (acres/If) — WHITE SPRINGS TRACT
Community Type
Mitigation Type
Tract Quantity ac.11
Credits
First -Order Stream
Restoration
White Springs 1,334
1,334
First -Order SBCF
Restoration
White Springs N/A
174
Riparian Wetlands
Restoration
White Springs 1.8
1.8r
(Non-Riverine Small Stream Swamp)
Non -Riparian Wetlands
Restoration
White Springs 64.41
64.41
(Pcosin/Wet Pine Savanna)
Stream Credits
1,508
Riparian Wetland Credits
1.8r
Non -Riparian Wetland Credits
64.41r
*r = restoration credit; re = restoration=equivalent credit
Table 3. Mitigation Type and Quantity (acres/If) — SNEEDEN TRACT
Community Type Mitigation Type Tract Quantity ac.11 Credits
First -Order Stream
Restoration
Sneeden
2,441
2,441
First -Order Stream
Preservation
Sneeden
1,843
737
Zero -Order Stream
Preservation
Sneeden
366
146
Riparian Wetlands
Riverine Cypress -Gum Swam
Restoration
Sneeden
.5
.5r
Riparian Wetlands
Riverine Cypress -Gum Swam
Enhancement
Sneeden
20
1 Ore
Riparian Wetlands
Riverine Cypress -Gum Swamp
Preservation
Sneeden
403
80.6re
Riparian Wetlands
Non-Riverine Small Stream Swam
Preservation
Sneeden
4
0.8re
Total Stream Credits
3,324
Total Riparian Wetland Credits
91.9
'r = restoration credit; re = restoration=equivalent credit
Table 4. Mitigation Credits by Stream and Wetland Type
Mitigation Type
Quantity (Iflac)
Credits
Stream
5,984
4,832
Riparian Non-Riverine Wetland
5.8
2.6
Riparian (Riverine) Wetland
423.5
91.1
Non -Riparian Wetland
64.41
64.41
Page 5 of 5 Pages