20201384 Ver 1_Draft prospectus (pre-app) site visit_20200810

Strickland, Bev
From: Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, August 10, 2020 10:40 AM
To: Tugwell, Todd J CIV USARMY CESAW (US); Kim Browning; Haywood, Casey M CIV
USARMY CESAW (USA); Davis, Erin B; Wilson, Travis W.
Subject: [External] SAW-2020-01380 / RES Cape Fear 03 / Bobs Branch Mitigation Site / draft
prospectus (pre-app) site visit
Attachments: 20200805 Bobs Bra nch_InstrumentMod_CF03030003_DRAFT. pdf; 20200805
Cove rLetter_BobsBra nch_DRAFT-Su bmitta1.pdf
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Good morning IRT,
RES has a new site in the works for the Cape Fear 03. Given we do not have a UMBI approved at this time, we
will consider this to be a pre-app on -site meeting. We had originally thrown out Sept 15th, but that date does
not work for RES. I am proposing that we shoot for Oct 6th for the site visit. Please let me know if this date
works for you and we'll lock it in. I've attached the pre -prospectus document for your reference.
Thanks,
Sam
Samantha Dailey
Regulatory Project Manager
U.S. Army Corps of Engineers
Regulatory Division
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
[phone], Ext. 22
[e-mail]

RES Cape Fear 03 Umbrella Mitigation Bank
Bobs Branch Mitigation Project
Instrument Modification
Cape Fear River Basin
HUC 03030003
Cal
Prepared by: Resource Environmental Solutions, LLC
fires
Bank Sponsor: Environmental Banc & Exchange, LLC
3600 Glenwood Avenue, Suite 100
Raleigh, North Carolina 27612
919-623-9889
August 2020

0
Table of Contents
1 INTRODUCTION.............................................................................................................................. I
1.1
Project Description........................................................................................................................1
1.2
Project Location............................................................................................................................1
1.3
Service Area..................................................................................................................................1
1.4
Identified Watershed Needs..........................................................................................................1
1.5
Purpose and Objectives................................................................................................................. 2
1.6
Technical Feasibility..................................................................................................................... 2
1.7
Site Ownership.............................................................................................................................. 4
2 QUALIFICATIONS........................................................................................................................... 4
2.1
Bank Sponsor................................................................................................................................ 4
2.2
Bank Sponsor Qualifications........................................................................................................ 4
3 EXISTING CONDITIONS................................................................................................................ 5
3.1
Existing Jurisdictional Waters of the US...................................................................................... 5
3.2
Existing Reach Conditions............................................................................................................ 5
3.3
Physiography and Soils................................................................................................................. 7
3.4
Endangered/Threatened Species................................................................................................... 7
3.5
Vegetation.....................................................................................................................................
8
3.6
Cultural Resources........................................................................................................................
8
3.7
Constraints....................................................................................................................................
8
4 PROPOSED
BANK CONDITIONS................................................................................................. 9
4.1
Conceptual Mitigation Plan.......................................................................................................... 9
4.2
Stream Restoration........................................................................................................................ 9
4.1
Potential Wetland Rehabilitation and Enhancement...................................................................10
5 MONITORING.................................................................................................................................10
5.1
Reference Ecosystems.................................................................................................................10
5.2
As -Built Survey..........................................................................................................................11
5.3
Visual Monitoring.......................................................................................................................11
5.4
Cross Sections.............................................................................................................................11
5.5
Vegetative Success Criteria........................................................................................................11
5.6
Adaptive Management................................................................................................................12
6 BANK ESTABLISHMENT AND OPERATION...........................................................................12
6.1
Establishment and Operation of the Bank...................................................................................12
6.2
Proposed Credit Release Schedule..............................................................................................12
6.2.1 Initial Allocation of Released Credits.................................................................................
12
6.2.2 Subsequent Credit Releases................................................................................................
13
6.3
Financial Assurances...................................................................................................................14
6.4
Proposed Ownership and Long -Term Management...................................................................14
6.5
Assurance of Water Rights.........................................................................................................14
7
References.......................................................................................................................................14
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List of Figures
Figure 1. Project Vicinity Map
Figure 2. Parcel Access Map
Figure 3. USGS Quadrangle Map
Figure 4. Historical Imagery
Figure 5. Existing Conditions Map
Figure 6. Soils Map
Figure 7. Stream Concept Design
Figure 8. LiDAR
Appendices
Appendix A — NC DWR Stream Determination
Appendix B — Landowner Authorization Forms
Appendix C — Existing Conditions Photo Log
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INTRODUCTION
Environmental Banc & Exchange, LLC (EBX), a wholly owned subsidiary of Resource Environmental
Solutions (RES), is pleased to propose the Bobs Branch Mitigation Project (the Project) for inclusion in the
RES Cape Fear 03 Umbrella Mitigation Bank (the Bank). The Project has been identified as having potential
to help meet the compensatory mitigation requirements for stream and wetland impacts in hydrologic unit
03030003 of the Cape Fear River Basin (Cape Fear 03).
This mitigation plan will be prepared in accordance with the RES Cape Fear 03 Umbrella Mitigation Bank
made and entered into by EBX, LLC and the United States Army Corps of Engineers (USACE). In addition
to the stream restoration, the Project is proposing to provide riparian buffer mitigation through the NC
Division of Water Resources (DWR) Randleman Lake Riparian Buffer Mitigation program.
1.1 Project Description
The Project is in Randolph County, approximately two miles northwest of New Market, North Carolina
within the 14-digit HUC 03030003010060 (Figure 1). The Project consists of two parcels totaling 11.68
acres of conservation easement (Figure 2). The Project has a total drainage area of 218 acres (Figure 3)
and is located within a semi urban area, and land use within the project area is currently comprised of
primarily open pasture with a few pockets of forested area, mostly acting as a living fence line. Historic
land disturbance principally includes conventional agricultural practices such as channel manipulation and
livestock access (Figure 4).
The Project will involve the stream restoration and enhancement of two unnamed tributaries of and
including, Bob Branch (Reach BB1-A, BB1-B, and BS1 and BS2). Bob Branch flows west to east. BSI
flows northeast to Bob Branch and BS2 flows north to drain into Bob Branch. In addition to the stream
reaches, there are multiple degraded wetland areas within the project area that have been impacted by
livestock access and/or ditching. The conceptual design presents the opportunity to provide up to 3,307
stream mitigation units (SMU). The Project will provide critical ecological uplift to aquatic and riparian
corridors that would otherwise be even further degraded by agricultural uses and continued livestock access.
1.2 Project Location
To access the Project from the town of New Market, NC, travel north approximately one mile on State
Road 1009. Turn left on Marlboro Church Road and continue for 0.5 mile. Then turn right onto Old Edgar
Road and continue for 0.6 mile to the access road of the project on the right. The latitude and longitude of
the access road to the Project is 35.84275°N and-79.8953°W.
1.3 Service Area
This Bank will provide stream and wetland mitigation credits to offset unavoidable impacts both stream
and wetland resources within the Cape Fear River Basin (8-digit USGS HUC 03030003). In a separate
mitigation bank instrument with DWR this project is proposing to provide riparian buffer mitigation credits
for the Randleman Lake watershed.
1.4 Identified Watershed Needs
The 2009 Cape Fear River Basin Restoration Priorities (RBRP) identified several restoration needs for the
entire Cape Fear River Basin, as well as for HUC 03030003, specifically. Protection of a number of mussel
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species and improvement in water quality to waters draining to Randleman Reservoir are recommendations
for the Cape Fear 03. Water quality stressors currently affecting the Project include livestock production
and lack of forested riparian buffer. Field evaluations determined all reaches to be either intermittent or
perennial. A combination of stream restoration and enhancement is proposed to increase water quality and
ecological function and protect these features in perpetuity.
1.5 Purpose and Objectives
The purpose of the proposed Project is to generate compensatory mitigation credits for inclusion in the RES
Cape Fear 03 Umbrella Mitigation Bank in the Cape Fear River Basin. The project goals address stressors
identified in the watershed, and include the following:
• Improve water transport from watershed to channels in a non -erosive manner;
• Improve water quality within the restored channel reaches and downstream watercourses by
reducing sediment and nutrient loads;
• Improve flood flow attenuation on site and downstream by allowing for overbank flows and
connection to the active floodplain;
• Improve instream habitat;
• Restore and enhance native riparian and wetland plant communities; and
• Improve ecological processes by reducing water temperature, improving terrestrial and aquatic
habitat, and restoring a native plant community.
The project goals will be addressed through the following project objectives:
• Design and reconstruct stream channels sized to convey bankfull flows that will maintain a stable
dimension, profile, and planform based on watershed and reference reach conditions;
• Add in -stream structures and bank stabilization measures to protect restored and enhanced streams;
• Install habitat features such as brush toes, constructed riffles, woody materials, and pools of varying
depths to restored and enhanced streams;
• Reduce bank height ratios and increase entrenchment ratios to reference reach conditions;
• Increase forested riparian buffers to at least 50 feet on both sides of the channel along the project
reaches with a hardwood riparian plant community;
• Re-establish and enhance wetlands by planting native wetland plant species;
• Establish a permanent conservation easement on the Project;
• Add fencing to exclude cattle from water resources therefore lessening stream and wetland soil
erosion and improving overall water quality.
The proposed Project is designed to help meet these goals. The project will address stressors identified in
the watershed through nutrient removal, sediment removal, runoff filtration, and improved aquatic and
terrestrial habitat. These project goals will be achieved through restoration and enhancement of the streams,
wetlands and riparian buffers.
1.6 Technical Feasibility
The technical feasibility of the Bank is assured due to RES' extensive experience with stream and wetland
restoration in North Carolina and throughout the Southeast. Examples of EBX's success include the projects
listed in Table 1.
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Bobs Branch Mitigation Project
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Table 1. Summary of RES Projects across the State of North Carolina
ProjectBasin #
Projects in various
Various
stages of development,
Broad
3
Counties
18,510
13.11
NA
construction,
monitoring, and
completion
Projects in various
Cape Fear-
Randolph,
stages of development,
Randleman
10
Guilford
2,828
0
3,172,672.750
construction,
monitoring, and
completion
161,955.830
Projects in various
Cape Fear-
Alamance,
BMU
stages of development,
Jordan
7
Orange,
13,662
8.2
27,571.840
construction,
Lake
Guilford
lbs N
monitoring, and
820.680 lbs P
completion
Projects in various
Various
stages of development,
Cape Fear
10
Counties
59,762
50.5
NA
construction,
monitoring, and
completion
Projects in various
Various
stages of development,
Catawba
14
Counties
78,210
45.5
1,547,829
construction,
monitoring, and
completion
French
7
Henderson
24,525
3.9
NA
Projects in development
Broad
Mitchell
Little
2
Macon,
4,766
4.5
NA
Projects in Monitoring
Tennessee
Jackson
Lumber
2
Anson,
Lenoir
4,098
69
NA
Projects closed out
9,764,220.550
Projects in various
Various
BMU
stages of development,
Neuse
33
Counties
119,948
648
392,710.04
construction
lbs N
monitoring, and
completion
Roanoke
3
Various
20,331
112.2
NA
Projects closed out
Counties
Tar-
Pamlico
1
Halifax
6,757
85.8
0
Projects closed out
White Oak
1
Onslow
3,770
0
NA
Project in Development
Projects in various
Various
stages of development,
Yadkin
18
Counties
90,784
0
NA
construction,
monitoring, and
completion
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1.7 Site Ownership
The land required for the construction, management, and stewardship of this mitigation project includes
portions of the parcels listed in Table 2. A landowner map is also provided in Figure 2. EBX, LLC has
obtained a legal option to develop the mitigation project and establish a permanent conservation easement
on the necessary area on the subject parcels.
Table 2. Bobs Branch Landowner Information
Landowner1County
Barry B. Spencer 7736611524 Randolph
Barry B. Spencer & Gina Rae Spencer 7736536035 Randolph
2 QUALIFICATIONS
2.1 Bank Sponsor
The Project shall be established under the terms and conditions of the RES Cape Fear 03 Umbrella
Mitigation Bank made and entered into by EBX, LLC, acting as the Bank Sponsor.
Company Name: Environmental Banc & Exchange, LLC
Company Address: 3600 Glenwood Avenue, Suite 100, Raleigh, NC 27612
Contact Name: Jamey McEachran
Telephone: [phone]
Email: [e-mail]
2.2 Bank Sponsor Qualifications
RES is the nation's largest and most experienced dedicated ecological offset provider. RES develops and
supplies ecological solutions to help public and private sector clients obtain required permits for
unavoidable, project -related impacts to wetlands, streams, and habitats. RES helps clients proactively
manage risk from operations in environmentally sensitive areas by providing impact analyses, streamlining
permitting processes, and limiting liability and regulatory exposure.
Key RES milestones and achievements include:
• Restoration, enhancement, and preservation of 58,024 acres of wetlands
• Restoration of over 328 miles of streams
• Rehabilitation, preservation, and/or management of over 15,000 acres of special -status species
habitat
• Successful close-out of over 100 mitigation sites
• Permitting and development of over 200 permitee-responsible mitigation projects
• Design, permitting, management, and development of 138 wetland, stream, species and
conservation banks
• Delivery of 20,000 acres of custom, turnkey mitigation solutions
• Design and construction of over 350 stormwater management facilities
• Reductions of over 267 tons of water quality nutrients
• Planting of over 17,400,000 trees across all operating regions
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• Development and operation of nurseries in three states including the largest coastal nursery in
Louisiana
Facilitation of compensatory mitigation and nutrient offsets for over 3,434 federal and state
permits
In North Carolina, RES and its affiliated companies have a long history of supplying mitigation contracts
with North Carolina state agencies. With a regional office in Raleigh staffed with full-time professionals,
RES has the ability to carry out existing projects, as well as secure and carry out new projects and banks in
the State.
3 EXISTING CONDITIONS
3.1 Existing Jurisdictional Waters of the US
United States Fish and Wildlife Service (FWS) National Wetland Inventory (NWI) mapping depicts no
wetlands within the proposed project easement. A wetland delineation has not yet been performed. The
Project will be delineated by RES and confirmed by the USACE during the design phase of the project.
The stream channels were classified using DWR methodology (NCDWR, 2010) (Appendix A).
The Project area includes unnamed tributaries to Bob Branch, which eventually drains to the Deep River
(now the Randleman Lake) by way of Bob Branch. The current State classifications for Bob Branch is
Water Supply IV (WS-IV) and Class C. Classification WS-IV refers to waters that are used for
consumption, culinary or food processing purposes. These waters are generally in moderately to highly
developed watersheds or Protected Areas. Class C waters have protections supporting "secondary
recreation, fishing, wildlife, fish consumption, aquatic life including propagation, survival and
maintenance of biological integrity, and agriculture. Secondary recreation includes wading, boating, and
other uses involving human body contact with water where such activities take place in an infrequent,
unorganized, or incidental manner" (NCDEQ, 2020).
3.2 Existing Reach Conditions
In general, all or portions of the Project streams do not function to their full potential. Current conditions
demonstrate significant habitat degradation as a result of impacts from historic agriculture, including
livestock husbandry (Figure 4). The Project reaches are generally channelized, lack bedform diversity, and
are oversized with poor riparian buffer conditions. Some existing stream parameters are summarized in
Table 3 and can be found in Figure 3 and Figure 5. Photos that show existing field conditions can be seen
in Appendix C.
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Table 3. Bobs Branch Project Stream Summary
Reach I
Hydrology Status
ream
Determinatio
Drainage Reach
Area (acres) Length (LF)
Livestoc
Acces
..
BSI
390
Yes
*Stream determination score determined by NCDWR Stream Identification Form 4.11, see Appendix A.
Reach BBl
Reach BB 1, is part of a named stream, Bob Branch, that enters the project under a fence from the northwest
corner and flows east through the project area and exits at the northeastern corner. Eventually, Bob Branch
drains directly to Randleman Lake. The reach has a 218-acre drainage area. Two unnamed tributaries, BS 1
and BS2, drain into 13131. Reach BB 1 is broken into two reaches BB 1-A and BB 1-B based on existing
conditions, and proposed treatment types. Reach 13131-A is the most upstream section of 13131 that ends at
the confluence with BSL This reach is mostly stable throughout but is lacking bedform diversity and
pattern, most likely due to continued access from cattle and an absent riparian buffer. Channel substrate is
silt/sand mixed with gravel and the banks are heavily vegetated with herbaceous vegetation. The channel
top of bank measures approximately 10 feet wide and 3 feet deep. Reach BB1-B begins at the confluence
with BSI and flows east through the project area. The reach is either splayed out or channelized with little
to no bedform diversity and is oversized. There are areas of active erosion and incision with stretches of a
stability based on the location of fencing. Majority of the reach lacks a riparian buffer. The channel
measures approximately 6 feet wide and two to three feet deep.
Reach BS1
Reach BSI flows northeast to the confluence with 13131. The channel has been channelized, is oversized
and widening and lacks bedform diversity. The channel substrate is silty most likely due to the continued
sediment input from livestock access but the banks are vegetated. The riparian buffer is mostly bare, with
little to no presence of healthy vegetation or forested canopy. In addition, the adjacent stream banks are
exposed to constant livestock activity. There is a livestock crossing with a 24-inch corrugated plastic pipe
culvert in the upper third of the reach. The channel measures approximately nine feet wide and two and a
half feet deep, and the drainage area is approximately 33 acres.
Reach BS2
Reach BS2 begins at a headcut at the southern end of the project and flows north to its confluence with
13131. The channel has been manipulated and is degraded and oversized with very little tree canopy or
healthy vegetation in the adjacent riparian buffer. Some sections of the reach have decent bedform diversity
and sinuosity where other areas are ditched or splayed out due to the agricultural activities. The top of the
reach where the slope is greatest shows areas of active erosion and incision with increased stability further
downstream where the slope decreases. The stream and riparian buffer are exposed to livestock activity.
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There are two culvert livestock crossings within the reach. The channel measures approximately 6 feet
wide and 2.5 feet deep, and the drainage area is approximately 52 acres.
3.3 Physiography and Soils
The site is located in the Southern Outer Piedmont level IV ecoregion within the Piedmont level III
ecoregion. With lower elevations and less relief compared to other areas of the Piedmont, the landforms of
this ecoregion consist of irregular, rolling plains. The geologic composition of the region is red, clayey
subsoils underlain by deep saprolite and gneiss, schist, and granite bedrock. Interspersed throughout the
region are also areas of diabase, diorite, or gabbro bedrock that form alkaline soils. Natural vegetation
communities consist of mixed oak forests, while historic land use trends have promoted the establishment
of loblolly and shortleaf pine forests (USEPA).
The Natural Resource Conservation Service (MRCS) depicts three soil mapping units across the Project
(Figure 6). The map units and soil characteristics are summarized in Table 4. The map units are Chewacla
and Wehadkee soils, 0 to 2 percent slopes, frequently flooded, Mecklenburg loam, 8 to 15 percent slopes,
Mecklenburg clay loam, 2 to 8 percent slopes, moderately eroded and Mecklenburg clay loam, 8 to 15
percent slopes, moderately eroded. The mapped soil data presented here are for reference only. Additional
work will be conducted as needed to support the project.
Table 4. Bobs Branch Mapped Soil Series
Map Unit
Unit Na4n.dric
Hydrologic
Symbol
-Status
Soil Group
Setting
Chewacla and Wehadkee
Somewhat
CmA
soils, 0 to 2 percent
poorly drained
Hydric
C/D
Floodplains
slopes, frequently flooded
MaC
Mecklenburg loam, 8 to
Well drained
Non-
C
Ridges and
15 percent slopes
hydric
hillslopes
Mecklenburg clay loam,
Non-
Ridges and
McB2
2 to 8 percent slopes,
Well drained
Hydric
C
hillslopes
moderately eroded
Mecklenburg clay loam,
Non-
Ridges and
McC2
8 to 15 percent slopes,
Well drained
Hydric
C
hillslopes
moderately eroded
3.4 Endangered/Threatened Species
The US Fish and Wildlife Service (USFWS, 2018) database (accessed April 16, 2020) for Randolph
County, North Carolina lists one endangered species, Schweinitz's sunflower (Helianthus schweinitzii), as
being within proximity of the proposed project. In addition, The Bald eagle (Haliaeetus leucocephalus) is
protected under the Bald and Golden Eagle Protection Act (BGPA) and prohibits take of bald and golden
eagles. (Table 5).
In addition to the USFWS database, the North Carolina Natural Heritage Program (NCNHP, 2020) GIS
database was consulted to determine whether previously cataloged occurrences of protected species were
mapped within one mile of the project. Results from NHP indicate that there is one known occurrence of
state threatened or endangered species within a one -mile radius of the project area (NHP, 2020). This
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occurrence is for the Schweinitiz's sunflower, a species of the Aster family. No protected species or
potential habitat for protected species was observed during preliminary site evaluations, however a survey
for the Schweinitz's sunflower will be conducted during the optimal survey window in late August —
October to ensure there are no individuals on site. Based on initial site investigations, no impacts to state
protected species are anticipated as a result of the proposed project. The decision phase of the project will
include USFWS and North Carolina Wildlife Resource Commission coordination to confirm these findings.
Table 5. Federally Protected Species in Randolph County
" Scientific name Federal Habitat Record Status
Vascular Plant:
Schweinitz's sunflower
Helianthus schweinitzii
E
No
Current
Vertebrate:
Bald Eagle
Haliaeetus leucocephalus
BGPA
No
Current
*BGPA = Bald and Golden Eagle Protection Act, E = Endangered
3.5 Vegetation
The Project is characterized primarily by active livestock pasture. The pasture is dominated by pasture
grasses with the presence of other herbaceous species like fescue grass (Festuca sp.), dogfennel
(Eupatorium capifollium), and common rush (Juncus effuses). Very few trees are on -site with the exception
of scattered Eastern red cedar (Juniperus virginiana). Some herbaceous plants have established themselves
in many parts of the stream channels and banks on -site, including an identified species of Persicaria, and
very few occurrences of a Rumex species. Invasive species are also present throughout, including Japanese
stiltgrass (Microstegium vimineum).
3.6 Cultural Resources
On April 16, 2020, the North Carolina State Historic Preservation Office (SHPO) website database was
reviewed to determine if any listed or potentially eligible historic or archeological resources in the proposed
project area existed. This search did not reveal any registered occurrence within the project area. In
addition, the search did not reveal any registered occurrence of any possible historic or archeological
resources within a mile of the proposed project area. The environmental screening phase of the Project will
include SHPO coordination to confirm these findings.
3.7 Constraints
There are minimal constraints to the Project that will be considered during the design of the project. The
project is not within a FEMA regulatory floodway (Figure 5) and therefore no FEMA permitting will be
required for this project as currently designed. Hydrologic trespass is not anticipated for the project and
will not be permitted to adjacent properties upstream or downstream of the Project. A tree survey will be
conducted to design the mitigation measures and access to minimize impacts to significant specimen trees.
Trees that are necessary to remove for project construction will be utilized for in -stream habitat structures.
The proposed mitigation project is located within five miles of one air transport facility. The Johnson Field
is a publicly owned and operated airport and is located approximately 2 miles West of the Project. The
proposed Project will not affect the operations of this airport (Figure 1).
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There are currently three existing crossings on Project streams used by livestock that will be removed and
replaced with one crossing further upstream of the project (Figure 7).
4 PROPOSED BANK CONDITIONS
4.1 Conceptual Mitigation Plan
The Project presents the opportunity to provide 3,307.00 stream mitigation units (SMUs). Additionally,
8.41 acres of riparian buffer mitigation will be developed with NCDWR. These will be derived from a
combination of stream restoration. Tables 6 details the mitigation types and credits generated. The proposed
conceptual design plan is shown in Figures 7.
Table 6. Bobs Branch Proposed Stream Mitigation Summary
Reach
Mitigation
Proposed Length (LF)
Ratio
SMUs
BB1-A
Enhancement II
350
2.5:1
140.000
BB1-B
Restoration
1,236
1:1
1,236.000
BSI
Restoration
412
1:1
412.000
BS2
Restoration
1,519
1:1
1,519.000
Total Length
3,517
Total SMUs
3,307.000
4.2 Stream Restoration
Current stream conditions along the proposed restoration reaches demonstrate habitat degradation as a result
of impacts from agricultural land use, channel modification, and historic land disturbance. Additionally,
the riparian buffer is absent throughout the project area.
Stream restoration and enhancement efforts along the tributaries at the Project will be accomplished through
analyses of geomorphic conditions and watershed characteristics. The design approach applies a
combination of analytical and reference reach -based design methods that meet objectives commensurate
with both ecological and geomorphic improvements. Proposed treatment activities may range from minor
bank grading and planting to re-establishing a stable planform and hydraulic geometry. For reaches
requiring full restoration, natural design concepts will be applied and verified through rigorous engineering
analyses and modeling. The objective of this approach is to design a geomorphically stable channel that
provides habitat improvements and ties into the existing landscape. The Project will include Restoration
and Enhancement II. A conceptual plan view is provided in Figure 7.
The Project has been broken into the following design reaches:
Reach BBI-A
Because Reach BB1-A is mostly stable and aggrading, Enhancement II is proposed for Reach BB1-A,
which will entail maintaining the channel along its existing alignment but constructing a more stable profile
and cross section. Habitat will further be improved by planting the riparian buffer and excluding livestock
access.
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Reach 13131-11
Restoration is proposed for 13131-13 after the confluence with BS1. Restoration will entail the design and
construction of a stable meandering channel within the natural valley with appropriate width/depth ratio
and cross -sectional area. Restoration activities will include using log and rock structures to provide vertical
stability, assist in maintaining riffle, run, and pool features and to provide habitat features. Habitat will
further be improved by widening and planting buffers and excluding livestock by installing fencing.
Reach BS1
Restoration is proposed for Reach BS1. Restoration will entail the design and construction of a stable
meandering channel with appropriate width/depth ratio and cross -sectional area. Restoration activities will
include using log and rock structures to provide vertical stability, assist in maintaining riffle, run, and pool
features and to provide habitat features. Additional restoration activities will include the removal of a
culvert livestock crossing. Habitat will further be improved by widening and planting buffers and excluding
livestock by installing fencing.
Reach BS2
Restoration is proposed for Reach BS2. Restoration will entail the design and construction of a stable
meandering channel with appropriate width/depth ratio and cross -sectional area. Restoration activities will
include using log and rock structures to provide vertical stability, assist in maintaining riffle, run, and pool
features and to provide habitat features. Restoration will begin at the head cut with a sediment control
structure. Additional restoration activities will include the removal of two culvert livestock crossings and a
degraded well. Habitat will further be improved by planting the riparian buffer and excluding livestock by
installing fencing.
4.1 Potential Wetland Rehabilitation and Enhancement
A small area in the riparian floodplain of BB1-B as well as between BBI-A and BSI has potential to be
restored or enhanced wetlands. The area would be restored by restoring the hydrology to the natural valley,
promoting overbank flow, groundwater recharge through channel restoration, and the construction of
micro -depressions in the floodplain, as well as removal of cattle and re-establishment of native vegetation.
5 MONITORING
Stream stability, hydrology, and vegetation survival will be monitored across the site to determine the
success of the stream and wetland mitigation. Stream stability will be monitored with cross section surveys
and visual assessment stream walks. Vegetation survival rates will be monitored using vegetation plots over
approximately two percent of the planted area. The success criteria for the Project will follow current
accepted and approved success criteria presented in the USACE Stream and Wetland Mitigation Guidelines,
and subsequent agency guidance. Monitoring reports will be prepared annually and submitted to the
Interagency Review Team (IRT). Specific success criteria components are presented below.
5.1 Reference Ecosystems
An appropriate local reference community will be identified and surveyed during the mitigation plan phase.
RES Cape Fear 03 Umbrella Mitigation Bank 10 Instrument Modification
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5.2 As -Built Survey
An as -built topographic survey will be conducted immediately following construction to document
floodplain grading, channel planform, profile, and dimension. The survey will include a complete profile
of centerline, thalweg, water surface, bankfull, and top of bank to compare with future geomorphic data.
Longitudinal profiles will not be required in annual monitoring reports unless requested by the IRT.
5.3 Visual Monitoring
Visual monitoring of all mitigation areas will be conducted a minimum of twice per monitoring year by
qualified individuals. A Current Conditions Plan View (CCPV) and associated tables will be submitted
every monitoring year in the annual monitoring report. The Current Condition Plan View (CCPV) provides
the spatial distributions and qualitative performance ratings for certain monitoring features. Visual
assessments will include vegetation density, vigor, invasive species, and easement encroachments. Visual
assessments of stream stability will include a complete stream walk and structure inspection. Digital images
will be recorded at fixed representative locations during each monitoring event, as well as at any noted
problem areas or areas of concern. Results of visual monitoring will be presented in a plan view exhibit
with a brief description of problem areas and digital images. Photographs will be used to subjectively
evaluate channel aggradation or degradation, bank erosion, success of riparian vegetation and effectiveness
of erosion control measures. Longitudinal photos should indicate the absence of developing bars within the
channel or an excessive increase in channel depth. Lateral photos should not indicate excessive erosion or
continuing degradation of the banks over time. A series of photos over time should indicate successional
maturation of riparian vegetation.
5.4 Cross Sections
Permanent cross -sections will be installed at approximately one per 20 bankfull widths with half in pools
and half in riffles on all reaches that include restoration or significant channel stabilization. All cross-section
measurements will include bank height ratio and entrenchment ratio. There should be minimal changes in
the annual monitoring cross sections from the as -built cross sections. If changes do take place, they will be
evaluated to determine if they represent a movement toward a less stable condition (for example down -
cutting or erosion) or are minor changes that represent an increase in stability (for example settling,
vegetative changes, deposition along the banks, or decrease in width/depth ratio). Channel stability should
be demonstrated through a minimum of four bankfull events documented in the seven-year monitoring
period. Cross-section surveys will occur in monitoring Years 1, 2, 3, 5, and 7.
5.5 Vegetative Success Criteria
Vegetation monitoring plots will be a minimum of 0.02 acres in size and cover approximately two percent
of the planted area. The following data will be recorded for all trees in the plots: species, height, planting
date (or volunteer), and grid location. Monitoring will occur each year during the monitoring period. The
interim measures of vegetative success for the Projects will be the survival of at least 320 planted three-
year old trees per acre at the end of Year 3 and 260 five-year old trees per acre at the end of Year 5. The
final vegetative success criteria will be the survival of 210 trees per acre with an average height of 10 feet
at the end of Year 7 of the monitoring period. Invasive and noxious species will be monitored and controlled
so that none become dominant or alter the desired community structure of The Project. If necessary, EBX,
LLC will develop a species -specific control plan.
RES Cape Fear 03 Umbrella Mitigation Bank 11 Instrument Modification
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5.6 Adaptive Management
The Mitigation Plan will include a detailed adaptive management plan that will address how potential
problems are resolved. In the event that the Project or a specific component of the Project fails to achieve
the defined success criteria, RES will notify the USACE of the need to develop necessary adaptive
management plans and/or implement appropriate remedial actions for the Project. Remedial action required
will be designed to achieve the success criteria specified previously, and will include identification of the
causes of failure, remedial design approach, work schedule, and monitoring criteria that will take into
account physical and climatic conditions. If needed, a corrective action plan will be created to change the
management of the Project, to meet success criteria. Once the Corrective Action Plan is prepared and
finalized RES will:
1. Notify the USACE as required by the Nationwide 27 permit general conditions.
2. Revise performance standards, maintenance requirements, and monitoring requirements as
necessary and/or required by the USAGE.
3. Obtain other permits as necessary.
4. Prepare Corrective Action Plan for review and approval by IRT.
5. Implement the Corrective Action Plan.
6. Provide the IRT a Record Drawing of Corrective Actions. This document shall depict the extent
and nature of the work performed.
6 BANK ESTABLISHMENT AND OPERATION
6.1 Establishment and Operation of the Bank
Bank parcels shall be established under the terms and conditions of the RES Cape Fear 03 Umbrella
Mitigation Banking Instrument (UMBI) made and entered into by and among EBX, LLC, and the USACE,
the United States Environmental Protection Agency (USEPA), the USFWS, the National Marine Fisheries
Services, the NCDWR, and the North Carolina Wildlife Resources Commission, collectively, the IRT.
6.2 Proposed Credit Release Schedule
All credit releases will be based on the total credit generated as reported in the approved mitigation plan of
the project. Under no circumstances shall any mitigation project be debited until the necessary Department
of the Army (DA) authorization has been received for its construction or the District Engineer (DE) has
otherwise provided written approval for the project in the case where no DA authorization is required for
construction of the mitigation project. The DE, in consultation with the IRT, will determine if performance
standards have been satisfied sufficiently to meet the requirements of the release schedules below. In cases
where some performance standards have not been met, credits may still be released depending on the
specifics of the case. Monitoring may be required to restart or be extended, depending on the extent to
which the Project fails to meet the specified performance standard. The release of project credits will be
subject to the criteria described in Table 7.
6.2.1 Initial Allocation of Released Credits
The initial allocation of released credits, as specified in the mitigation plan can be released by the IRT with
written approval of the DE upon satisfactory completion of the following activities:
RES Cape Fear 03 Umbrella Mitigation Bank 12 Instrument Modification
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a) Execution of the UMBI by the Sponsor and the USACE
b) Approval of the final mitigation plan
c) Mitigation site must be secured
d) Delivery of financial assurances
e) Recordation of the long-term protection mechanism and title opinion acceptable to the USACE
f) Issuance of the 404-permit verification for construction of the Project, if required
6.2.2 Subsequent Credit Releases
The second credit release will occur after the completion of implementation of the Mitigation Plan and IRT
approval of the Baseline Monitoring Report and As -built Survey. All subsequent credit releases must be
approved by the DE, in consultation with the IRT, based on a determination that required performance
standards have been achieved. As projects approach milestones associated with credit release, the Sponsor
will submit a request for credit release to the DE along with documentation substantiating achievement of
criteria required for release to occur. This documentation will be included with the annual monitoring
report.
Table 7. Stream Credit Release Schedule
nterim
Total
MilestoneRelea
it Release Activity
1
Site Establishment (includes all required criteria stated above)
15%
15%
Completion of all initial physical and biological
2
15%
30%
improvements made pursuant to the Mitigation Plan
Year 1 monitoring report demonstrates that channels are
3
o
10 /0
0
40 /o
stable and interim performance standards have been met
Year 2 monitoring report demonstrates that channels are
4*
o
10 /0
0
50 /o
stable and interim performance standards have been met
Year 3 monitoring report demonstrates that channels are
5
o
10 /0
0
60 /o
stable and interim performance standards have been met
Year 4 monitoring report demonstrates that channels are
605%
6*
stable and interim performance standards have been met
5%
(75 /o )
Year 5 monitoring report demonstrates that channels are
75%
7
10%
stable and interim performance standards have been met
(85%**)
Year 6 monitoring report demonstrates that channels are
80%
8
stable and interim performance standards have been met
5 /� o
(90%**)
Year 7 monitoring report demonstrates that channels are
90%
9
stable and interim performance standards have been met
10%
(100%**)
project has received close-out approval.
*Please note that vegetation plot data may not be required with monitoring reports submitted during
these monitoring years unless otherwise stated by the Mitigation Plan or directed by the IRT.
* *10% reserve of credits to be held back until the bankfull event performance standard has been met.
RES Cape Fear 03 Umbrella Mitigation Bank
Bobs Branch Mitigation Project
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August 2020

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6.3 Financial Assurances
The Sponsor shall provide financial assurances in the form of a Performance Bond to the IRT sufficient to
assure completion of all mitigation work, required reporting and monitoring, and any remedial work
required. Financial assurances shall be payable at the direction of the USACE to the project designee or to
a standby trust. Financial assurances structured to provide funds to the USACE in the event of default by
the Bank Sponsor are not acceptable. A financial assurance must be in the form that ensures that the USACE
receives notification at least 120 days in advance of any termination or revocation.
6.4 Proposed Ownership and Long -Term Management
EBX, LLC, acting as the Bank Sponsor, will establish a Conservation Easement, and will monitor the
Project for a minimum of seven years. The Mitigation Plan will provide detailed information regarding
bank operation, including long term management and annual monitoring activities, for review and approval
by the IRT. Upon approval of the projects by the IRT, the project will be transferred to a long-term land
steward. The long-term steward shall be responsible for periodic inspection of the project to ensure that
restrictions required in the Conservation Easement or the deed restriction document(s) are upheld.
Endowment funds required to uphold easement and deed restrictions shall be negotiated prior to site transfer
to the responsible parry.
The Bank Sponsor will ensure that the Conservation Easement will allow for the implementation of an
initial monitoring phase, which will be developed during the design phase and conducted by the Bank
Sponsor. The Conservation Easement will allow for yearly monitoring and, if necessary, maintenance of
the project during the initial monitoring phase. These activities will be conducted in accordance with the
terms and conditions of the RES Cape Fear 03 Umbrella Mitigation Bank made and entered into by EBX,
LLC and USACE.
6.5 Assurance of Water Rights
Sufficient water rights exist to support the long-term sustainability of the Project, as there are no "severed"
rights on the property.
7 References
North Carolina National Heritage Program (NCNHP). 2020. "North Carolina Natural Heritage Data
Explorer." https://ncnhde.natureserve.org/. (Accessed March 2020).
North Carolina Department of Environmental Quality (NCDEQ). "Classifications." Water Resources
https:Hdeq.nc. gov/about/divisions/water-resources/planning/classification-
standards/classifications. (Accessed March 2020).
NC DEQ. "Cape Fear River Basinwide Water Quality Plan." Cape Fear 2005.
hgps:Hfiles.nc. gov/ncdeq/Water%20Qualiiy/PlanningBPUBPU/Cape_Fear/Cape%20Fear%20P1
ans/2006%20Plan/CPF%202005.pdf (Accessed March 2020).
RES Cape Fear 03 Umbrella Mitigation Bank 14 Instrument Modification
Bobs Branch Mitigation Project August 2020

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North Carolina Department of Environment and Natural Resources (NCDENR) 2012. "Water Quality
Stream Classifications for Streams in North Carolina." Water Quality
http://portal.ncdenr.ora/web/wq/home. (Accessed March 2020).
North Carolina Department of Natural and Cultural Resources (NCDNCR). 2020. "NC State Historic
Preservation Office." NCSHPO. hMs://www.ncdcr.gov/about/history/division-historical-
resources/nc-state-historic-preservation-office (Accessed March 2020).
North Carolina Division of Water Quality (NCDWQ). 2010. "Methodology for Identification of
Intermittent and Perennial Streams and Their Origins." NC DWR.
htips:Hfiles.nc.gov/ncdeg/Water%200uality/Surface%2OWater%2OProtection/401/Policies Quid
es_Manuals/StreamID_v_4pointl l_Final_sept_01_2010.pdf. (Accessed March 2020).
United States Environmental Protection Agency (USEPA). 2002. "Ecoregions of North Carolina and
South Carolina." US EPA. https://www.epa.gov/eco-research/ecore,gion-download-files-state-
region-4. (Accessed March 2020).
United States Fish and Wildlife Service (USFWS). 2018. "Threatened and Endangered Species in North
Carolina." North Carolina Ecological Services.
https://www.fws.gov/raleigh/species/cpiylist/union.html. (Accessed March 2020).
United State Department of Agriculture — Natural Resource Conservation Service (USDA NRCS). 2020.
Web Soil Survey; http://websoilsurvey.nres.usda.gov. (Accessed March 2020).
RES Cape Fear 03 Umbrella Mitigation Bank 15 Instrument Modification
Bobs Branch Mitigation Project August 2020

List of Figures
Figure 1. Project Vicinity Map
Figure 2. Parcel Access Map
Figure 3. USGS Quadrangle Map
Figure 4. Historical Imagery
Figure 5. Existing Conditions Map
Figure 6. Soils Map
Figure 7. Stream Concept Design
Figure 8. LiDAR

Glen
17Zh
Hilly Ridge G Links
x
Legend
Proposed Easement
14 Digit HUC - 03030003010060
Cape Fear River Basin - 03030003
K;
tom,
5o is
Wa►mart Supercenter q,
d:,
AA c Lea nsv !"e
Ey Greensboro
Nallhurg
Jamestown
os P:e ant
Kg olnt Ga n
C
J
Trrn Leve' Cross
Thomasville
GraysChape'
L
Randleman Lake Service Area Cedar Falls
�4 NC NHP Element Occurrence (NC NHP October 2019) Ramseur
Bobs Branch Project s oro crOSE
a
- Other Managed Area (NC NHP July 2019) „
C Farmer
5 Mile Aviation Zone Denton LEI
ng av 35.84275,-79.8953
i
" Figure 1 - Project Vicinity Date: 7/31/2020
w e Drawn by: RPP res
Bobs Branch
s Mitigation Project Checked by: MDE
0 0.5 1
Mile Randolph County, North Caolina 1 inch = 1 mile
r

Legend
ii
Proposed Easement
Project Parcel
Parcel
Parcel Access
O Parking Spot
I E
S
0 1 50 3011
JESPENCER,15
BARRYi BRUCE
FiqUFV Z - rdFuel Access Date: 8/3/2020
Bobs Branch Drawn by: RPP
Mitigation Project Checked by: MDE
Randolph County, North Carolina 1 inch = 300 feet
pres�

iz
Park ' r
• ,`1 � •tit - / _•_
_ .• Z .ti• 4
• r \ i
•
•
,
New
Q
Legend �'' '✓� }
Proposed Easement',•'
i �f 1 r• � -_
Drainage Area
® 6131 (218 ac) a.�►a y
BS1 (33 ac)
- BS2 (52 ac)
" Figure 3 - USGS Quadrangle Date: 8/3/2020
Glenola (1982)
w e Drawn by: RPP res
Bobs Branch
0 400 800 Mitigation Project Checked by: MDE
Feet Randolph County, North Carolina inch=SOOfeet

1993 7,
Source: USGS Earth E
............
V,
D: NCOneMap
P"
+ k 1���•h '.r :..ram. � . .
Q
kQ,
it -
Legend
Proposed Easement S NCO M Source: ING MaoMal,
IN Figure 4 - Historical Imagery Date: 8/3/2020
E Bobs Branch Drawn by: Roo
S Mitigation Project Checked by: MDE
0 250 500
fires

I i
j
14
r fY'
4*• 1
P Y
R k
t
i
t1�� in
Le
pend
Proposed Easement
kr7?y kt
FEMA Zone AE - None r
® FEMA Floodway -None
® NWI Wetland - (October 2019) - None
Cross Section and Stream Form " • " - - �'_'`
® Existing Culverted Livestock Crossing
Stream Form
Existing Stream
-- Intermittent
Perennial Y
" Figure 5 - Existing Conditions Date: 8/6/2020
- w e Drawn by: RPP res
Bobs Branch
s 0 150 300 Mitigation Project Checked by: MDE
e Feet Randolph County, North Carolina inch=300feet

All
"Y
it , JJ
Culvert Remov.-'
Legend,`
Proposed Easement 11.68 ac
Potential Wetland 1.61 ac
IZAAW
Proposed Fencing 2,929 ft Reach ID Mitigation Approach Length Ratio smu
13131-A Enhancement 11 350 2.5 140.000
Approach
13131-13 Restoration 1,236 1 1,236.000
Restoration
BS1 Restoration 412 1 412.000
Enhancement 11 Restoration 1,519 1 1,519.000
Total 3,517 3,307.000
N
Figure 7 - Stream Design Concept Date: 8/6/2020
W E
Drawn by: RPP
Bobs Branch
S ���
Mitigation Project Checked by: MDE
0 100 200
1 Feet Randolph County, North Carolina inch = 200 feet

Appendix A
NC DWR Stream Identification Form 4.11

NC DWQ Stream Identification Form Summary
REACH
BS1
BS2
BB1-US
BB1-DS
A. Geomorphology (Subtotal =)
11
18
13.5
19
1a. Continuity of channel bed and bank
2
3
2
3
2. Sinuosity of channel along thalweg
1
2
2
2
3. In -channel structure: ex. riffle -pool, step -pool,
ripple -pool sequence
1
1
1
2
4. Particle size of stream substrate
1
2
2
3
5. Active/relict floodplain
3
2
3
2
6. Depositional bars or benches
1
2
1
2
7. Recent alluvial deposits
1
2
1
2
8. Headcuts
0
2
0
1
9. Grade control
0.5
1
0.5
1
10. Natural valley
0.5
1
1
1
11. Second or greater order channel
0
0
0
0
B. Hydrology (Subtotal =)
6
6.5
9.5
11.5
12. Presence of Baseflow
2
2
2
3
13. Iron oxidizing bacteria
0
2
1
1
14. Leaf litter
1.5
1.5
1.5
1.5
15. Sediment on plants or debris
1
0.5
1
1.5
16. Organic debris lines or piles
1.5
0.5
1
1.5
17. Soil -based evidence of high water table?
0
0
3
3
C. Biology (Subtotal =)
3.75
4.75
7.25
8.75
18. Fibrous roots in streambed
1
2
2
2
19. Rooted upland plants in streambed
2
2
2
3
20. Macrobenthos (note diversity and
abundance
0
0
1
1
21. Aquatic Mollusks
0
0
0
0
22. Fish
0
0
0.5
0.5
23. Crayfish
0
0
0
0
24. Amphibians
0
0
1
1
25. Algae
0
0
0
0.5
26. Wetland plants in streambed
0.75
0.75
0.75
0.75
Total Points Subtotal= 20.75 1 29.25 1 30.25 1 39.25
Stream Determinationj Intermittent I Intermittent I Perennial I Perennial

Appendix B
Landowner Authorization Forms

Landowner Authorization Form
Site:
Property Legal Description
Deed Book/Page: 1514/0840,2260/0218
County: Randobh
Parcel ID Numbers: 7736536035, 7736611524
Street Address: OLD EDGAR RD-. SOPHIA fiiE
Property Owner: Spencer, Barry Bruce & Ginyltae
The undersigned, registered property owner of the above property, do hereby authorize
Resource Environmental Solutions, the NC Division of Water Resources, and the US Army Corps of Engineers,
their employees, agents or assigns to have reasonable access to the above referenced property for the evaluation of
the property as a potential stream, wetland, and or riparian buffer restoration project, including conducting stream
and or wetland determinations and delineations, as well as issuance and acceptance of any required permit(s) or
certification(s).
Property Owner Address: 2879 MARLBORO CHURCH RD SOPHIA, NC
I/We hereby certify the above information to be true and accurate to the best of my/our knowledge.
(Proper Authorized Signature) Date
(Property Owner Printed Name)
(Property Owner Authorized Signature) Date
(Property Owner Printed Name)
4846-3189-9210, v. 1

Appendix C
Existing Conditions Photo Log

Existing Conditions Photos
Upstream BSI (June 23, 2020)
Upstream BB1-A (June 23, 2020)
Downstream BSI (June 23, 2020)
Downstream BB1-A (June 23, 2020)

Upstream BB1-B (June 23, 2020)
Top of BS2 (upstream, June 23, 2020)
Bottom of BS2 (upstream, June 23, 2020)
Downstream BB1-B (June 23, 2020)
Middle of BS2 (upstream, June 23, 2020)
Bottom of BS2 (downstream, June 23, 2020)

Potential Wetland on site at the confluence
of BS2 and BB1-B (June 23, 2020)
Overview of site from eastern boundary
(January 2020)
Potential Wetlands on site on right bank of
BB1-B (June 23, 2020)
Overview of BS2 from drone (January 2020)

fires
August 6, 2020
Samantha Dailey
U.S. Army Corps of Engineers
Regulatory Division
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Dear Ms. Dailey,
3600 Glenwood Avenue, Suite 100
Raleigh, NC 27612
Corporate Headquarters
6575 West Loop South, Suite 300
Bellaire, TX 77401
Main: 713.520.5400
On behalf of Environmental Banc & Exchange LLC (EBX), a Resource Environmental Solutions (RES) affiliate, I am
pleased to submit the Draft Instrument Modification for the Bobs Branch Project. This Project will be the second Project
in the RES Cape Fear 03 Umbrella Mitigation Bank (UMBI) and is located within a watershed primarily
composed of agriculture, forests, and commercial and residential areas. The Project has been identified by RES
to provide compensatory mitigation for unavoidable stream and potentially wetland impacts in hydrologic unit
code (HUC) 03030003 of the Cape Fear River Basin. This Project was originally identified as a riparian buffer
project to service the Randleman Lake Watershed, similar to the first project in the UMBI, the Feed and Seed
Mitigation Project. The water quality benefits from this project would increase with stream restoration work in
addition to riparian buffer restoration activities.
The Project is located in Randolph County, NC, approximately two miles northwest of New Market. The latitude
and longitude for the Project is 35.84275°N and-79.89530W. The Project provides 11.68 acres of proposed
conservation easement and will involve the restoration and enhancement of Bobs Branch (a direct tributary to
Randleman Lake) and two of its unnamed tributaries. The conceptual design presents 3,517 linear feet of stream
mitigation generating 3,307 Stream Mitigation Units (SMUs) with the potential of some wetland rehabilitation.
Additionally, the project will restore around 8.41 acres of riparian buffer.
The parcels that make up the project area are currently in livestock production; current and historic impacts
include channel modifications and livestock access. RES has signed an option agreement with the landowner to
record conservation easements on all land located within the bank boundary. The easement will be conveyed to
an appropriate conservation easement holder who will serve as long-term manager for the mitigation property.
Please feel free to contact me directly at 919-623-9889 with any questions that you may have concerning the
Project. The attached Instrument Modification includes specific project details and mapping. We thank you in
advance for your timely response and cooperation.
We look forward to discussing this project with you in more detail as your review progresses.
Thank you,
Jamey McEachran I Project Manager
res.us