20191132 Ver 1_Draft Plan Comments_20200806

Strickland, Bev
From:
Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Sent:
Thursday, August 6, 2020 7:58 AM
To:
Jake McLean; Andrea Eckardt
Cc:
Leslie, Andrea J; Wilson, Travis W.; Davis, Erin B; Tugwell, Todd J CIV USARMY CESAW
(US); Kim Browning; Haywood, Casey M CIV USARMY CESAW (USA); Bowers, Todd;
Byron Hamstead ([e-mail]); Jones, M Scott (Scott) CIV USARMY
CESAW (USA)
Subject:
[External] SAW-2019-01296 Little Tennessee UMB - East Buffalo Site Draft Plan
Comments
Attachments:
SAW-2019-01296 LittleTennesseeUMB-EastBuffaloSite DraftPlanComments
6Aug2020.pdf
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Jake/Andrea,
Attached are the Little Tennessee UMB - East Buffalo Site (SAW-2019-01296) Draft Mitigation Plan IRT comments. You
may proceed with developing the final mitigation plan for the East Buffalo 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
comment response and Final Mitigation Plan. In addition, please submit your Nationwide Permit 27 application with the
submittal of the final plan, for review and approval prior to discharging fill material into waters of the United States.
Feel free to contact me with questions as you preparing the final plan submittal. This electronic copy is your official
Department of the Army Notification; no paper copy will be mailed, unless specifically requested.
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.
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
(828)-933-8032 cell
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
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
CESAW-RG/Kichefski August 6, 2020
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Action ID No. SAW-2019-01296
SUBJECT: Draft Plan Comment Memo for Little Tennessee Umbrella Mitigation Banking
Instrument —East Buffalo Mitigation Site
Mac Haunt & Erin Davis — NCDWR (June 5, 2020):
1. Page 7, Section 3.3.2 — Was NCSAM performed for the preservation reaches to demonstrate
existing high -quality conditions?
2. Page 31 — This section notes that favor will be given to reseeding streams with existing
streambed material. DWR appreciates this statement and highly supports efforts to salvage
existing instream habitat and organisms.
3. Page 36, Section 7.7.4 — This section mentions sloping of stream banks and constructing a
left bank flood bench. Do these activities correspond to the 50-ft area of grading shown on
Sheet 2.1.4?
4. Page 39, Section 7.8 —
a. The 2016 IRT Guidance specifies planting before March 15th. If planting cannot be
completed by March 151h, an extension request should be submitted to USACE/IRT.
Please note that planting after April 301h may result in a delay of the fast monitoring
year until the subsequent growing season.
b. Please identify a reference wetland and proposed target wetland community type(s).
c. In areas where priority 2 restoration is proposed, stream benches are constructed and
wetland caps are excavated, please include a discussion of soil assessment and/or
reuse of site topsoil/planting medium.
5. Page 40, Section 7.9 - Please indicate if fescue will be treated prior to or during site
construction. DWR recommends early treatment based on observations of fescue impeding
planted vegetation establishment and vigor.
6. Pages 40-42 — DWR appreciates the level of detail included in the Project Constraints and
Risk and Uncertainties Sections.
7. Page 43, Table 23 —
a. On the original concept map UTl was proposed as enhancement II at 4:1. Since no
channel work is proposed and only supplemental planting will be completed (without
applying a vegetative performance criteria), DWR thinks that 4:1 is a more
appropriate ratio.
b. It appears the new UT6 was added after the IRT site walk (and the old UT6 became
UT7). Since UT6 is isolated from the rest of the project site reaches, is less than 200
linear feet, has not been seen by the IRT and no assessment data has been provided to

demonstrate it as a high quality/functioning stream, DWR does not support it as credit
reach.
8. Page 49, Section 12 — DWR requests the inclusion of red -line drawings in the baseline
monitoring report comparing record drawings to final mitigation plan design sheets.
9. Page 49, Table 26 — Please remove the phrase "based on the soil type". The proposed 12%
hydroperiod applies to all wetland restoration areas as stated in Section 11.3.
10. Page 50, Table 26 —Please note the vigor performance standard.
11. Page 51, Table 27—
a. Table 1 states that 20.6 acres will be planted, which would mean a minimum of 17
veg plots (100 m2), unless supplemental planting areas are being counted. Currently
10 veg plots are proposed; DWR requests a minimum of 2 additional veg plots: 1 veg
plot located within the wetland enhancement areas and 1 veg plot located within the
wetland reestablishment area.
b. DWR requires visual monitoring be performed at all road crossings proposed for
removal along preservation reaches to verify that areas remain stable through the
monitoring period.
12. Figure 11 — DWR appreciates that non-credit existing wetlands are shown, but please
confirm that wetlands A, B and C included.
13. Sheet 0.3 —
a. Are there any specific trees proposed to be saved (icon not shown on plan views)?
b. Is any fencing proposed?
14. Sheet 2.3.1 — Can a callout please be added to specify where the UT2-2 creditable reach
begins.
15. Sheet 2.4.2 — Should the "proposed floodplain roughing" pattern icon be added to the areas
with associated callouts?
16. Sheet 2.4.3 — Please confirm the culvert shown south of station 4008+30 will be removed
along with the road naturalization.
17. Sheet 2.4.4 — No work/structures are proposed at the UT3 and UT4A confluence near the
easement boundary. Are there any concerns about long-term stability for this area?
18. Sheet 3.0 — Please removed red maple from the wetland planting list. For future planting
plans, it is helpful for our review to have the wetland indicator status included in the tables.
19. Sheet 6.7 — The bare root planting detail includes a nice description of the installation
procedure. Could additional information please be added to the live stake detail (e.g.
installation depth, typically planted dormant, etc.).
20. Sheet 6 (Details) —
a. Please provide a detail for the proposed vernal pool. Please note that the approximate
max. pool depth and that it will be designed to be seasonally dry.
b. Please provide detail(s) for relic channel backfill/partial backfrll and/or plugs.
21. Sheet 6.1 — The cascading riffle detail icon shown appears to correspond with the Sheet 0.3
legend icon for proposed pipe outlet protection. Please confirm.
22. Sheet 6.3 — Will the vegetated stone toe protection be live staked or solely seeded with
Juncus?
23. Design Sheets — It would help our review to see the existing channel areas proposed to be
filled as a shaded feature on the plan view sheets.
Andrea Leslie — NCWRC (May 29, 2020):
1. Capturing the headwaters of many of these streams has great value for both aquatic and
terrestrial habitat connectivity and adds value to the heavier restoration work downstream.

We are supportive of the road decommissioning and stream crossing rehabilitation in the
preservation areas. Once complete, will there be any roads and/or culverts left in the
preservation section of the project?
2. In addition, capturing the entire bottomland area in easement is valuable for protection of the
restoration and in providing a broader habitat corridor. As such, the planting plan is
especially important.
3. Please provide a wetland reference and target community for the wetland re-establishment,
rehabilitation, and enhancement areas. The vegetation plan should be based on
references/target communities. For the current list, we recommend diversifying the planting
list as appropriate and (1) eliminating red maple, as that is a pioneer species and should come
in on its own, (2) reducing the percentage of sycamore from 20% to 10-15% at most, and (3)
eliminating river birch, as this typically is only associated with large river floodplains in the
Blue Ridge. We also ask for a wetland herbaceous plant list.
4. Likewise, for the riparian area planting list, reduce sycamore from 20% to 10-15% at most
and eliminate river birch. Supplement the list with additional species, including understory
species.
5. 817 It of East Buffalo Creek Reach 2 and 976 ft of UT3 Reach 2 will be newly constructed
channel. The plan notes that substrate will be harvested from existing channels in the wet.
Please explain how this work will be staged, addressing both turbidity issues while
harvesting material in the wet and harvesting of stream biota. Please note that it is necessary
for the designer to rescue/move aquatic animals that are abandoned in the old channels. This
can also aid in jumpstarting the biological community within the new channel segments.
6. Wild trout reproduction should not be impacted by project activities and a trout moratorium
is not needed.
Todd Bowers — USEPA (May 29, 2020):
The EPA Region 4 Ocean, Wetlands and Stream Protection Branch offers the following site -
specific comments as they pertain to the East Buffalo Draft Mitigation Plan dated March 25,
2020:
1. Section 1/Page 1:
a. Very first sentence is confusing. Since when do UMBs include towns? This is
alluding to service area, so a rewording is recommended. Perhaps "serve the towns
of'?
b. Excellent consideration and inclusion of several complete watersheds flowing into
East Buffalo Creek (UT 2, 3, 4 and 7) as preservation components of a
comprehensive restoration plan.
2. Section 3.3.2/Pages 12-13:
Recommend adding "proposed for preservation" to the UT 2, 3, 4, 6 and 7 descriptions
similar to UTS, UT4a and UT4b1.
3. Section 4.1/Page 13:
Field visit date is erroneous, and an error carried forward from the Wilmington
District correspondence sent last year. See page 203 of the pdf document to confirm.
Proposed Wildlands Little Tennessee Umbrella Mitigation Bank (UMB) Comment
Response (SAW-2019-01296)]
4. Section 7.7.1/Page 33-35:
a. Commendation to the sponsor for considering and obtaining a conservation easement
that includes the watersheds of many of the UT components of the project. The very
wide buffers from the boundaries, protection of seeps and upland habitat,

decommissioning of access roads and capturing entire watersheds is an excellent
approach to preservation.
b. I understand and concur with the Enhancement approach for UT2 Reach 2 even as it
appears to be closer to restoration work. This conclusion is based on field notes and
discussions with other IRT members.
Section 7.7.2/Page 35:
"Enhancement II is proposed for East Buffalo Creek Reach 2" should be "East Buffalo
Creek Reach 1"
6. Section 7.7.12/Page 37:
a. Excellent proposal to remove/decommission the soils roads and crossings within the
areas proposed for preservation. I would add caution that language such as "This
work will improve water quality by reducing sedimentation to the streams across the
site from road erosion and will restore stream habitat and aquatic species passage"
may be misconstrued to allude that the project will improve water quality without any
data to prove it. Without data or other demonstrable evidence, the best the sponsor
can provide is "This work may improve water quality..." and I recommend that the
edit is made.
b. Per the included diagram, Sheet 5.0, the access points to the soil roads will be blocked
off from East Buffalo Creek Road. I recommend this same approach applied to the
road entering and leaving the Exclusion Area 2 to prevent internal access if the
property is developed.
c. Additionally, I recommend that the sponsor include some sort of monitoring
(visual/photos) to ensure that the stream crossings are stabilized, the site access has
been effectively blocked to motor vehicles, and that the vegetation (10 trees per 300
feet) is surviving to some extent. Preservation credits should be withheld until this
minor success criterion is demonstrated for at least two monitoring periods (years).
7. Sections 7.8/Page 39:
Recommend removing Red maple (Ater rubrum) from the planting plan for the wetland
planting zone and it is a vigorous volunteer species. Excellent consideration of a mix of
trees/shrubs for the overstory and sub canopy portions of the Riparian and Wetland
Planting zones.
8. Section 9.0/Page 43:
I concur with the sponsors approach to mitigation ratios based on this section and with
discussions with IRT members.
9. Table 23/Page 44:
UT4b1 is not included in the project component list (501f of no credit/preservation).
10. Section 10/Table 24/Page 45:
Recommend that preservation credits based on the 7:1 ratio be withheld until the forest
road decommissioning/stabilization is demonstrated to be successful for a minimum of
two monitoring periods to ensure the site is indeed stable. Release of 10:1 Preservation
credits should be released upon site establishment.
11. Section 10.1/Page 46:
Recommend that only UT 5, 6 and 7 credits be released under the initial allocation of
released credits.
12. Section 11.2/Page 47:
Please provide clearer language pertaining to fixed/permanent and random/mobile
vegetation plots. As I read it, the permanent plots are also randomly located so using the
word "random" may not be the best choice here. See note 5 of Table 29, which
demonstrates clearer distinction.

13. Table 26/Page 49:
Under the "Improve instream habitat" goal there should at least be some sort of visual
confirmation of performance of installed/constructed habitat features to minimize the
occurrence of piping or other instabilities. Here is where a measurement/metric pertaining
to large woody debris may be useful to demonstrate uplift of habitat function.
14. Figure 4/Watershed Map:
a. The East Buffalo Drainage (600 acres) seems to include East Buffalo Creek (600
acres) along with UT 5 (47 acres), UT 1 (52 acres) and UT 2 (51 acres) which totals
750 acres.
b. The UT 3 Drainage (156 acres) seems to include UT 3 (156 acres), UT 4 (78 acres)
and UT 4a (6 acres). The estimate for UT3 appears erroneous and should be about (72
acres).
Steve Kichefski — USACE:
1. Section 2 (page 2), Figure 2/3 & UMBI: Please clarify if the intent is to utilize all 3
HUC's combined as one service area as the report seems to suggest or whether each site
within the UMB will be tracked and have a service area of its particular HUC as the
UMBI seems to suggest?
2. Table 4 (page 6): Seems like the geomorphic location of the wetlands classified as seeps
are within a floodplain or crenulation and more likely to be relic bottomland hardwood
forest or headwater forest fragments, or so modified that it would be non -tidal freshwater
marsh?
3. Section 3.2 (page 5): Describe existing community types of preservation areas.
4. Section 5.4 (page 18): Please provide the archeological survey report that was submitted
to the SHPO in February 2020.
5. Section 7.6.3 (page 32), Section 11.3 (page 48), Figure 11, Table 27 & Plan page 0.2.2:
Please add two additional wetland ground water gages, the first in Wetland E and the
second in Wetland D north of the proposed powerline relocation. Also, based on the LSS
study and supplemental attachment/revised plan page, the boundaries of the groundwater
wells in the proposed establishment wetland have changed slightly and the groundwater
wells may need to be relocated to ensure they stay with the proposed wetland boundary.
6. Section 7.7.12 (page 37) & Section 10/11/12: I like the plan for forest road
decommissioning to help ensure long term function of the preservation reaches, however
there needs to be additional monitoring/performance objectives for the crossing
removal/road decommissioning areas to ensure their success. Also, a portion of
preservation credits should be withheld until those areas have demonstrated a trend
towards stability. For example, perhaps 15% of preservation credit is held and released
incrementally with the remaining stream credit as monitoring milestones are achieved or
after the bankfull criteria has been achieved. Is there a plan for accessing
decommissioned areas if repairs are needed?
7. Section 7.8 (page 39): Describe target communities for planting areas (both wetland and
upland), so appropriate species can be correlated. Remove red maple from the planting
list since it is so prone to becoming a volunteer.
8. Section 7.9 (page 40): Will treatment of such dense invasive areas need a modification of
veg approach such as a delay in planting or a clear need for supplemental planting while
the invasive are eradicated? Were any of the preservation areas assessed for invasive
species beyond treatments shown in the Invasives Treatment Plan sheet 3.4?
9. Section 7.1 (page 41): This section (and plans) seems to imply the utility line (including

relocated sections) can be accessed without any need for crossing the CE area streams or
additional encroachment of the CE outside of the ROW, but please confirm.
10. Please update the UMBI to the most recent 2020 version and include Erin Davis as the
NCDWR contact.
11. Section 10 (page 44): Add 404 approval to the requirements prior to credit release. That
line seems to duplicate information in Section 10.1 and 10.2?
12. Section 14.2 Table 31 (page 55): Verify that all boundaries will be marked and by what
method, including remote boundaries away from typical access points.
13. Section 15 Table 33 (page 58): A construction/supplemental planting and invasive
contingency of at least 8-10% is requested in the financial assurances.
14. Much of the design plan for UT3 Reach 2B (or the riffle details) does not show any type
of step or vane grade control structure anchoring in the downstream end of riffles despite
steep slopes. Please describe why there is not a concern for instability with this approach
or a design characteristic I may have missed that ensures the riffles remain stable.
15. Add additional vegetation monitoring plots in wetland enhancement and rehabilitation
areas for better performance assessment.
<d- G &
Steve Kichefski
Regulatory Project Manager
Asheville Regulatory Field Office