20181461 Ver 1_Draft Mitigation Plan Comment Memo_20200624

Strickland, Bev
From: Barnes, Kyle W CIV USARMY CESAW (US) <[e-mail]>
Sent: Wednesday, June 24, 2020 11:58 AM
To: Daniel S. Coggin; Tara Allden; Daren Pait; Hughes, Doug
Cc: Tugwell, Todd J CIV USARMY CESAW (US); Kim Browning; Davis, Erin B; Wilson, Travis
W.; Bowers, Todd
Subject: [External] SAW-2017-02019 Beaufort 56; SAW-2019-00254 Craven 26;
SAW-2019-00255 Craven 30 UMBI - Draft Mitigation Plan Comment Memo
Attachments: Long Term Management Cost Estimate Template.pdf, Middle Neuse UMBI Feb 20,
2020 Mod Comments MFR.pdf
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Good afternoon,
Attached are the Middle Neuse Stream and Wetland Draft Umbrella Mitigation Plan for
Beaufort 56, Craven 26, and Craven 30 , (dated February 2020) IRT comments. You may
proceed with developing the final mitigation plan for Middle Neuse Stream and Wetland
Beaufort 56 , Craven 26, and Craven 20 UMBI Mitigation Site provided you adequately address
all comments/concerns in the enclosed memo. Please ensure that each member of the IRT is
provided a copy of the Final Mitigation Plan. In addition, please submit your Nationwide
Permit 27 application and request for a PJD to this office for review and approval prior to
discharging fill material into waters of the United States.
Please let me know if you have any questions.
Sincerely,
Kyle Barnes
Regulatory Project Manager
US Army Corps of Engineers
Wilmington District
Washington Field Office
910-251-4584
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Thank you for taking the time to visit this site and complete the survey.

Worksheet for Conservation Easement Stewardship Endowment
Property Name:
Annual Monitoring Costs Calculations:
Date:
Quantity
Rate
Cost
1. Staff time includes salary and benefits
A
Staff time prior to visit
includes landowner contact and file review
B.
Staff time to monitor easement
(includes travel, discussions with landowner, considers size of tract,
number of parcels, terrain, etc.
C
Staff time post -visit
(includes completing report, submitting documentation)
D.
Annual cost of staff time needed to address the exercise of reserved
rights by landowner. 10 % chance happening in any given year (10
hours X $50)*10 % _ $50.00
E.
Annual cost of staff time needed to address minor violations. 10%
chance happening in any given year (10 hours X $50)*10% _ $50.00
2. Travel Costs for a Monitoring Visit
A.
Reimbursement per mile(per IRSguidelines)
B.
Reimbursement for meals
C.
Reimbursement for lodging
3. Supplies
A.
4. Miscellaneous Duties
A.
B.
5. Site Mana ement
A. Site specific management plans and reserved rights.
Total Annual Monitoring Costs: Per Year
Defendingan
Easement into Perpetuity
A.
Staff time
B.
Legal Counsel
C.
Other Incidentals
Stewardship Complexities
A.
No Additional Stewardship Complexities
B.
Level 1 Stewardship Complexities*
C.
Level 2 Stewardship Complexities—
D.
Level 3 Stewardship Complexities —
Total Annual Monitoring Costs
Amount needed to earn annual monitoring costs at 3% APR
Total Cost for Legal Defense
Stewardship Complexities

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
Washington Regulatory Field Office
2407 West 5" Street
Washington, North Carolina 27889
'TfASTATES OF P���
June 12, 2020
CESAW-RGBarnes
MEMORANDUM FOR RECORD
SUBJECT: The Middle Neuse Stream and Wetland Umbrella Mitigation Bank- Draft Mitigation
Plan Review, Beaufort and Craven Counties, NC
PURPOSE: The comments listed below were received from the NCIRT during the 30-day
comment period in accordance with Section 332.8(g) of the 2008 Mitigation Rule.
USACE AID#'s: SAW-2017-02019 Beaufort 56; SAW-2019-00254 Craven 26; SAW-2019-
00255 Craven 30
DWR comments on the Weyerhaeuser Draft Mitigation Plans: Craven 26, Craven 30, and
Beaufort 56
Comments by Mac Haupt, Erin Davis and Anthony Scarbraugh
Overall comments (applies to every site):
1. DWR will require a JD or preliminary JD to provide final comments for the draft
mitigation plan for each site. (DWR noted the Sponsor response to our comments
{overall comment E} in the February 12, 2020 comment document.)
2. On mitigation projects with significant wetland credit proposed, DWR expects significant
soil work to be submitted in the draft mitigation plan (soil profiles shown in areas with
different soil series to confirm hydric soils). In addition, for these sites, the topo
elevation gradually goes toward more upland -like characteristics as you get closer to the
easement boundaries. Any areas proposed for wetland restoration credit that appear as
yellow or green on the LiDAR maps should be thoroughly investigated from a hydric
soils standpoint and have gauges installed pre -construction. DWR requests a detailed
soils report by a licensed soil scientist, including a delineation of existing and relic hydric
soil areas, be included as an appendix to the mitigation plan. Additionally, wetland
restoration areas more than 100 feet from proposed ditch filling or P1 stream restoration
should indicate the source of expected hydrologic improvements. Moreover, if during
construction any excavation (in the proposed restoration area) occurs greater than 12
inches, the wetland area would be considered creation.
3. All design sheets should show existing wetlands.
4. All mitigation plans need to have a planting plan in the design sheets. DWR noted the
vegetative notes and detail sheet; however, the planting plan shows where certain species

will be planted. According to the current submittal, certain wetland trees such as bald
cypress will be planted in all the wetland areas, some of these proposed wetland
restoration areas will not be as wet or may contain upland soils.
5. All plans should install gauges to cover different soil series and topographic differences
on the site. All of the sites could use more gauges. The more gauges that are installed
initially in the questionable areas, the less arguments later during the monitoring and
credit release phase of the projects.
Craven 26:
1. Table 2 (and 15)- DWR will accept a 10:1 ratio for preservation of the wetlands.
2. Section 8.1- Vegetative Monitoring- DWR recommends a plot size of 100 square meters
(or 0.025 acres). Most other providers are utilizing this plot size. The plot size of 0.02 ac
in a minimum plot size requirement in the 2016 Mitigation Update, if you want to go
larger that is your call.
3. Section 8.3- Headwater Stream Flow Performance Standards -for consistency purposes,
DWR requires that the stream flow standard be required for all monitoring years. DWR
understands the logic behind your proposal of only being required for years 2 thru 7,
however, the IRT (and DWR) has been quite flexible regarding first year reviews of
credit release for hydrologic standards.
4. Appendix C-DWR would like to see where these cross sections (pre -construction) were
taken shown on a map. Also, for XS3-UT2 Reach 2, please provide more scale
increments in the future.
5. Design sheets- comparing typical cross section of UT3, 3A (and preconstruction x-
sections) to other design sheets:
a. Looking at the pre -construction x sections and the typical for UT3 and UT3A
(Design sheet 6) it appears that there will be no pilot channel dug. DWR likes
these x sections.
b. Looking at the Design sheet 22-24 for UT3-3A, as well as the UT reach 1, it
appears as if a small channel may be dug. DWR does not want a channel or small
ditch dug through these headwater areas.
c. DWR hopes to see a headwater constructed with very gradual slopes (like the
20:1 in your typical) which do meet at the low point in the valley but does not
have a pilot channel.
6. DWR believes much of the area proposed for wetland restoration that surrounds UT3,
UT3A and UT1 reach 3 may not qualify as wetland restoration. Also, this includes the
large proposed wetland restoration area west of the confluence of UT reach 2 and UT2
reach 2. These areas would need a higher density of gauges due to the questionable nature
of the restored hydrology. For example, the area above the preservation wetland at the
top of UT3A is a large proposed restoration area, currently this area shows 1 gauge
(would need at least 3-4 gauges). Also, this area has no ditching, how is the hydrology to
be restored?
7. DWR believes that UT3 is an already functioning headwater. The credit approach stated
earlier is enhancement while Design sheet 22 shows restoration. DWR does not believe

grading should occur in this reach (above the road). Moreover, DWR does not support a
1.5:1 ratio for the reach above the road. DWR does support a 1.5:1 ratio below the road.
8. As stated in previous comments, DWR requests the designer and on -site construction
manager be mindful of constructing channel, (Design sheets 13-14, e.g. UT1 reach 3,
stations 54+00 thru 62+00), that allows overbank flooding.
Craven 30
April 27, 2020
1. Table 3 and Table 7- Table 3 shows the drainage areas of Reaches UT 3, 4, and 5 of 46
acres or less. Table 7 (from Russell, 2008) shows the mean drainage area for coastal plain
intermittent channels as 40 acres. DWR believes a more accurate predictor of
intermittent flow, with significant aquatic life, for mitigation sites should be the 90% row
showing 101 acres needed for intermittent channels. DWR believes reaches UT 3, 4, and
5 will be at risk (credit) for showing channel characteristics given the small drainage
areas.
2. Section 8.3 Performance Standards- Headwater Stream Flow Performance Standards -for
consistency purposed, DWR requires that the stream flow standard be required for all
monitoring years. DWR understands the logic behind your proposal of only being
required for years 2 thru 7, however, the IRT (and DWR) have been quite flexible
regarding first year reviews of credit release for hydrologic standards.
3. Figure I I- shows crest gauges for the intermittent reaches, as DWR has stated in previous
comments, the gauges must be automatic recording flow gauges placed in a riffle -like
feature in the upper third of the reach.
4. In the future, please label the reaches for Figures I 1-13.
5. Appendix C- please reference on a map where the pre -construction cross sections are
located.
6. Design sheet 6- in the future, please make sure all the sheets have numbers.
7. All Design sheets should show existing wetlands. For example, design sheet 17 does not
show the wetlands that make up most of the upper area of UT5 (this is another example
of why we need to see a JD or preliminary JD).
8. All other restoration reaches on each site shows a priority 1 approach. Why does UT I
reach 2 propose a priority 2 approach given Weyerhaeuser controls the surrounding
watershed and the culvert crossing?
9. Based on recent field observations, the upper section of UT5, between the roads, looks
like an herbaceous wetland. DWR requests this area be re-evaluated for as a potential
jurisdictional feature. DWR believes this area will remain a wetland and not develop as a
headwater stream. In fact, we would not expect headwater characteristics to form until
stations 408+00 or 409+00. DWR asks that the approach and crediting for this area be
reassessed.
10. Design sheet 12- DWR requests that the Designer and on -site manager be particularly
careful of grading in the headwater reaches so as to not resemble a ditch going through a
wetland. This has been an issue with several other providers on similar design approaches
for headwaters.

Beaufort 56
April 27, 2020
1. DWR believes for these projects any headwater tributary that is proposed for restoration
that has under 100 acres of drainage area is at risk for stream credit loss. (see comment
#1 for Craven 30). UT2 seems particularly vulnerable to not being able to provide the
necessary flow for the headwater valley.
2. Section 8. 1 -Vegetative monitoring- DWR recommends monitoring at least 2% of the site
area planted with size plots at least 0.02 acres (2016 Mitigation Update). You certainly
can monitor 5% of the site and use the size plot you wish, however; DWR believes you
need more wetland monitoring gauges so you might want to consider reducing the
number of vegetative plots while increasing the number of wetland gauges.
3. Section 8.3- Performance Standards- Wetland Performance Standards- DWR
recommends the wetland hydrologic performance criterion for this site to have a 10%
saturation/hydroperiod for the growing season. The site contains 3 major soil series;
Pantego (12-15%), Tomotely (10-12%), and Leon (7-9%){saturation ranges from the
October 2016 Mitigation Update}. Rather than split the site up and have 3 different
wetland criteria, DWR will support having one 10% wetland hydrologic hydroperiod for
the growing season.
4. On this site there is a relatively intact (wetland? Need to see JD...) hardwood area. DWR
recommends not to disturb this stand. We realize the edges of this stand will be impacted
by ditch filling; however, it appears that large areas would not need to be affected (graded
or cut).
5. Figure 11- Monitoring Plan- DWR will require more wetland gauges be installed at this
site. We recommend having at least 5 gauges for the area to the east of UT2 and north of
Pollard Swamp reaches 1 and 2. This is the area primarily made up of the Leon soil.
DWR recommends at least 4 gauges in the Tomotely soil and 3 gauges in the Pantego soil
area. Finally, DWR recommends at least one gauge in the Leaf soil (stream left on the
Pollard Swamp reach 3). DWR recommends examining the soil map for placement. If
there any questions, DWR would be glad to provide assistance.
6. Appendix C- please reference on a map where the pre -construction cross sections are
located.
7. Design sheet 6 (and all other design sheets that have ditches that extend to the easement
boundary)- Please provide design sheets for all areas within the conservation easement.
For example, DWR has a question as to how the ditches will be filled near the edge of the
conservation easement. And, if the ditches are not filled immediately adjacent to the
easement, what affect that might have on the surrounding wetlands proposed for
restoration credit.
8. Design sheet 12- DWR assumes the ditch coming into Pollard Swamp reach 2 will
remain open given the drawing. The wetlands adjacent to the ditch will likely show a
drainage affect and therefore should not be considered for restoration credit. In addition,
since reach 3 of Pollard Swamp is priority 1, how will you ensure the incoming ditch
elevation not cause hydrologic trespass?

9. Design sheet 12 and 13- a ditch which parallels the road will be filled. How might this
impact areas offsite, particularly the road? Will a ditch be dug on the other side of the
road to carry the water offsite?
Corps Comments:
Beaufort 56:
1. Figure 10: The Conservation Easement is labeled as 45.7 acres. I believe this should
be 99.1 acres.
2. Figure 11: Please update the legend. It's unclear what the yellow, blue and pink dots are.
3. Section 8.3: Please remove the "...at year 3, 5, or 7." From the standard that no one
species may comprise more than 50% of the total composition within any given plot.
4. Page 29, Headwater Stream Performance Standard: At least 30-days consecutive
flow for intermittent streams should occur in monitoring years 1-7. Most of the
information in this section is not actually a performance standard and would be more
appropriate in the Approach Description. I would suggest breaking this performance
standard into several sections to address flow duration, years 1-4 indicators, and
years 5-7 indicators.
5. I suggest adding a performance standard for visual monitoring.
6. It would be beneficial to discuss the results of the NCSAM/NCWAM forms in the text.
7. Please show existing wetlands on the figures and design sheets. More soils work
and a completed PJD is needed given the amount of wetlands proposed on this
site.
8. Figure 12: Please ensure that the road crossing was deducted from the buffer calculation.
Craven 26:
1. Figure 12: Please ensure that the terminal ends and three crossings were deducted
from the buffer calculations.
2. Wetland preservation is typically credited at 10:1 unless it's a large tract in
pristine condition. Given the small area of preservation this area is more
appropriate to receive 10:1.
3. Section 8.3: Please remove the "...at year 3, 5, or 7." From the standard that no
one species may comprise more than 50% of the total composition within any
given plot.
4. Headwater Stream Performance Standard: At least 30-days consecutive flow for
intermittent streams should occur in monitoring years 1-7. I would suggest breaking
this performance standard into several sections to address flow duration, years 1-4
indicators, and years 5-7 indicators.
5. I suggest adding a performance standard for visual monitoring.
Craven 30:
1. Figure 13: Are Nutrient/buffer credits being sought on this project? Or is the
green polygon labeled Nutrient/Buffer credit area for the wider buffers?

2. Same suggestions for revising the performance standards as in Craven 26.
3. Conservation Easement, Page 7: Please include the acceptance letter from Unique
Places to Save, including the spreadsheet with the breakdown of costs for the Long
Term Stewardship amount. This will be needed for all three sites.
USFW:
B56 3.3 Endangered Species:
Narrative says that no habitat is present for any of the species,
yet once again in the table it says potential habitat present. Red cockaded woodpecker for
example. IF there is potentially suitable habitat present on the site then more explanation
should be included. Did they look for them, are there older longleaf or other species of pines
present that are large enough to make it potentially suitable habitat? I know it's a pine
dominated area, but wasn't sure about the sizes, basal area etc. What makes them think they
wouldn't be there? Even if it is to say that the project activities wouldn't occur in the
potentially suitable habit ... it needs to be addressed so we know they have thought about it
during the project planning. Also, Neuse River Waterdog status needs to be updated to
Proposed Threatened for Federal Status.
C26 3.3 Endangered Species:
Same general comments as B56. In addition to NRWD, Carolina
Madtom needs to be changed to Proposed Endangered for Federal Status. Venus flytrap has
been petitioned for listing, so Federal status should say Petitioned.
C30. 3.3 Endangered Species:
Same general comments as B56. Also, Neuse River Waterdog
status needs to be updated to Proposed Threatened for Federal Status. Venus flytrap has
been petitioned for listing, so Federal status should say Petitioned
Kyle Barnes
Project Manager
Washington Field Office