20150416 Ver 1_Notice of Initial Credit Release_20201012

Strickland, Bev
From: King, Scott <[e-mail]>
Sent: Monday, October 12, 2020 10:33 AM
To: Kim Browning; Reid, Matthew; Wiesner, Paul; Allen, Melonie; Baumgartner, Tim;
McKeithan, Katie
Cc: Tugwell, Todd J CIV USARMY CESAW (US); Hamstead, Byron A; Bowers, Todd; Davis,
Erin B; Haywood, Casey M CIV (USA); Leslie, Andrea J; Wilson, Travis W.; McLendon, C
S CIV USARMY CESAW (USA); Smith, Ronnie D CIV USARMY CESAW (USA); Jones, M
Scott (Scott) CIV USARMY CESAW (USA)
Subject: [External] RE: EXTERNAL: Notice of Initial Credit Release/ NCDMS Russell Gap
Mitigation Site/ SAW-2015-00826 / Alexander County
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Good morning folks,
Please find below in red our responses to the IRT's comments on the Russell Gap As -Built report. Let me know if you
have any additional questions or comments.
Thank you very much,
Scott
Scott King, LSS, PWS I Soil Scientist - Ecosystem Restoration Group I Michael Baker International
8000 Regency Parkway, Suite 600 1 Cary, NC 27518 1 [O] 919-481-5731
[e-mail] I www.mbakerintl.com
Michael
..* We Make a Difference
ference
INTERNATIONAL
CQnW(W1th0: V =ln7A1M
From: Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, October 6, 2020 8:54 AM
To: Reid, Matthew <[e-mail]>; Wiesner, Paul <[e-mail]>; Allen, Melonie
<[e-mail]>; Baumgartner, Tim <[e-mail]>; King, Scott
<[e-mail]>; McKeithan, Katie<[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CESAW (USA) <[e-mail]>; Byron Hamstead
<[e-mail]>; Bowers, Todd <[e-mail]>; Davis, Erin B <[e-mail]>;
Haywood, Casey M CIV (USA) <[e-mail]>; Leslie, Andrea J <[e-mail]>;
Wilson, Travis W. <[e-mail]>; McLendon, C S CIV USARMY CESAW (USA)
<[e-mail]>; Smith, Ronnie D CIV USARMY CESAW (USA) <[e-mail]>;
Jones, M Scott (Scott) CIV USARMY CESAW (USA) <[e-mail]>
Subject: EXTERNAL: Notice of Initial Credit Release/ NCDMS Russell Gap Mitigation Site/ SAW-2015-00826 / Alexander
County

Good morning
The 15-Day Record Drawing and MY-0 review for the Russell Gap Mitigation Site (SAW-2015-00826) ended
October 2, 2020. Per Section 332.8(o)(9) of the 2008 Mitigation Rule, this review followed the streamlined
review process. There were no objections to issuing the initial credit release and the revised assets have been
approved at 9,166.949 warm SMUs and 7.053 WMUs. Please find attached the current signed ledger, and IRT
comments below. The IRT would like to visit this site in spring 2021.
DWR Comments, Erin Davis:
1. Regarding the change from rock step structures to boulder step structures, are there any concerns with
aquatic passage? There are no aquatic passage concerns from that change.
2. DWR is ok with the additional plant species installed. Thank you.
3. In future MYO baseline reports, please note whether there are changes in monitoring locations from the
approved mitigation plan (e.g. groundwater well MW12); not including minor shifts in field
placements. Understood. We will note all those in the future.
EPA Comments. Todd Bowers
The vegetation plot data in Appendix D has some serious deficiencies.
The species planted is not provided in the list. I find this troubling for several reasons. Since the
data was gathered immediately after planting the species should still be tagged and known.
Even in the absence of tags, a botanist with basic skills should be able to determine species
based on stem, bundle scar and bud characteristics. I trust this will be rectified in the growing
season monitoring report for Year 1. Bare root stems are not tagged by species. Baker staff
prides itself on excellent identification skills but it must be conceded that the difference between
some species can be very difficult to determine at the bare root stage. For instance the four
oaks we planted can look remarkably similar, as can ironwood, hazelnut, black gum, spicebush,
and redbud (again, in their bare root forms). By waiting until MY1 to positively confirm species
(as we noted other providers had done previously), we avoid the inevitable misidentifications
which lead to incorrect veg tables and CVS files, the revisions of which lead to confusion on
everyone's part in looking between MYO and MY1. However, it appears that holding off
identification leads to confusion as well, so in the future Baker will confirm species in the field
during MYO and make all necessary revisions in MY1 as was previously done.
o I found that several plots (permanent plots 5, 6, 8, 9 and 10; random plots 1, 2, 3, 7 and 9) are
well below the desired planted density of 680 stems per acre. One plot, random 2, is nearing the
threshold for year 3 success of 320 stems per acre. Granted this plot/exact location is likely not
to be sampled again but it is indicative of potential trouble of tree survival in this location. Plant
mortality and density are closely assessed throughout the monitoring period and Baker will
ensure that all required threshold densities for monitoring year are met as per the project
success criteria.
o Planted species percentages cannot be determined or verified by plot data to confirm if planted
percentages follows the desired species ratios in the mitigation plan. The plants will be identified
and reported in MY1 and percentages could then be extrapolated. i iowever, Baker confirmed
with the contractor during the planting effort that he was able to obtain all the species required,
with the modification noted in the report (i.e. the addition of Shumard oak).
o I have no issues with substituting Shumard oak on -site but the percentages are unknown.
Shumard oak was planted at approximately 10% in the Upland Tree planting zone.
The color scheme used for the site assets is a bit odd and unlike others I have seen by both Baker and
other providers. This is a topic that the IRT can discuss internally but providers should agree to some
sort of color scheme for legends in forthcoming plans and reports. Tthe green for stream restoration is
difficult to see and it is mainly used for preservation on other projects. Baker will adjust the color
scheme shown in the CCPV to match our other projects starting in MY1. We have worked to achieve
consistency on those for ease of use by all.
I appreciate Baker's use of 50-foot riparian buffers on this site especially as livestock operations and
other agricultural purposes are continuing as an adjacent land use. I did not submit comments on the
original mitigation plan but this would have been included as a recommendation. Thank you.

• Deviations from the mitigation plan as far as rock step pool features substituted with boulder steps on
Reaches 11, 13, 15, 18, 19 and 27 are noted and I have no concerns. Gate locations and fence
adjustments are noted and approved of as well. Very good, thank you.
• Excellent spread of photos highlighting stream structures, veg plots and gauges. 'hank you.
Please contact the mitigation office if you have questions.
Thanks,
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers