20181273 Ver 1_Notice of Intent to Approve SAW-2018-01788_20200828

Strickland, Bev
From:
Browning, Kimberly D CIV USARMY CESAW (USA)
<[e-mail]>
Sent:
Friday, August 28, 2020 2:38 PM
To:
Tugwell, Todd J CIV USARMY CESAW (US); Davis, Erin B; Wilson, Travis W.; Leslie,
Andrea J; Bowers, Todd; Merritt, Katie; Haywood, Casey M CIV USARMY CESAW (USA);
Byron Hamstead ([e-mail]); McLendon, C S CIV USARMY CESAW
(USA); Smith, Ronnie D CIV USARMY CESAW (USA); Jones, M Scott (Scott) CIV
USARMY CESAW (USA); Steve Kichefski
Cc:
Jeff Keaton; Reid, Matthew; Wiesner, Paul
Subject:
[External] Notice of Intent to Approve/ NCDMS Bug Headwaters Mitigation Site/
Wilkes Co./ SAW-2018-01788
Attachments:
Draft Mit Plan Comment Memo -Bug Headwaters SAW-2018-01788.pdf
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Good afternoon folks an happy Friday,
We have completed our review of the Draft Mitigation Plan for the NCDMS Bug Headwaters Mitigation Project (SAW-
2018-01788). Please see the attached memo, which includes all NCIRT comments that were posted on the DIMS
SharePoint site during the review process along with additional comments provided by Wilmington District staff
following our review.
We have evaluated the comments generated during the review period, and determined that the concerns raised are
generally minor and can be addressed in the final mitigation plan. Accordingly, it is our intent to approve this Draft
Mitigation Plan (contingent upon the attached comments being addressed in the Final Mitigation Plan) unless a member
of the NCIRT initiates the Dispute Resolution Process, as described in the Final Mitigation Rule (33 CFR Section
332.8(e)). Please note that initiation of this process requires that a senior official of the agency objecting to the approval
of the mitigation plan (instrument amendment) notify the District Engineer by letter within 15 days of this email (by COB
on September 11, 2020). Please notify me if you intend to initiate the Dispute Resolution Process.
Provided that we do not receive any objections, we will provide an approval letter to NCDMS at the conclusion of the 15-
day Dispute Resolution window. This approval will also transmit all comments generated during the review process to
NCDMS, which must be addressed in the Final Mitigation Plan to be submitted with the Preconstruction Notification
Application for NWP 27. All NCIRT members will receive a copy of the approval letter and all comments for your records.
Thank you for your participation.
Kim
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
REPLY TO
ATTENTION OF:
CESAW-RG/Browning
MEMORANDUM FOR RECORD
August 28, 2020
SUBJECT: Bug Headwaters Mitigation Site - NCIRT Comments during 30-day Mitigation Plan Review
PURPOSE: The comments listed below were received during 30-day comment period in accordance
with Section 332.8(g) of the 2008 Mitigation Rule in response to the Notice of NCDMS Mitigation Plan
Review.
NCDMS Project Name: Bug Headwaters Mitigation Site, Wilkes County, NC
USACE AID#: SAW-2018-01788
NCDMS #: 100084
30-Day Comment Deadline: July 23, 2020
USACE Comments, Kim Browning:
1. Please include the NCSAM forms and a brief summary in the text.
2. Design Sheet 3.0: In the future, please include the indicator status in the planting list (FAC,
FACW, etc.).
3. Please provide a veg plot along Big Bugaboo Creek reach 3 in the wetland planting zone 4.
4. Planting List: Please eliminate silver maple from the planting list —it is very limited in North
Carolina, and it wouldn't be found on the smaller tributaries. Additionally, it would be preferable
to reduce the percentage of sycamore planted to less than 20%.
5. UT1: given the small drainage area (7 acres) and that this reach is intermittent, please move the
flow gauge to the upper 1/3 of this reach.
6. UT2B: It in unclear from the description on page 10 whether this reach is spring -fed, and given
the very small drainage area, flow is a concern. If you do not plan to install a flow gauge on this
reach, please be sure to use photos/video to document flow. Small reaches with such small
drainage areas really should have a flow gauge. Both consecutive days flow and cumulative
days should be documented.
7. There are many existing headwater forest wetlands within the easement and stream relocation
is estimated to impact approximately 1.343 acres. Though it is anticipated that the total wetland
acreage will increase as a result of stream restoration, the Corps must still ensure that there is
no net loss of wetlands. If you do not plan to install wetland gauges and monitor hydrology,
please plan to reverify the extent of jurisdiction at the end of the monitoring period to document
that wetland acreage was not lost.
8. Table 9: Please summarize the total impacts, both temporary and permanent.
9. August 28, 2020 I corresponded with Byron Hamstead, FWS, regarding the bog turtle and Rusty
Patched Bumble Bee locations in Wilkes County. His reply was that both bog turtle and rusty
patched bumble bee are not subject to Section 7 requirements and there would only be concerns

for bog turtle if its habitat was disturbed and impact avoidance was not possible. In which case
a survey would be requested. I did confirm that there were proposed impacts to existing
wetlands, but that the wetlands have been negatively impacted by cattle and that it was very
unlikely that BT habitat was present. This correspondence will serve as documentation that
threatened and endangered species were considered.
10. Section 3.4: The Corps issued the PJD June 21, 2020.
11. Section 3.7: Another item for discussion could be the wetland enhancement and potential bog
turtle habitat that may arise from stream restoration and cattle exclusion.
12. Section 3.8: Do the adjacent agricultural fields to the north provide a sediment source?
appreciate the thoughtfulness of this section.
13. Table 20: the 30-days of consecutive flow applies to all intermittent channels, annually, not just
on restored reaches. Intermittent streams dry seasonally and should demonstrate flow for
periods longer than 30 consecutive days.
DWR Comments, Erin Davis:
1. DWR appreciates that the site's conservation easement was expanded to include many of the
stream origins and riparian wetland areas.
2. Page 4, Section 3.3 - Please reference the completion of NC SAM in this section and include
the NC SAM field assessment forms and rating sheets in Appendix 1.
3. Page 13, Section 3.6 -
a. Are there any existing stream culvert crossings that will be removed, relocated or
replaced?
b. Was there any discussion with the utility provider about the possibly of relocating the
overhead line right-of-way to along Austin Traphill Road?
4. Page 15, Table 7 - Are vernal pools being proposed? If so, please provide additional design
details.
5. Page 16, 5.1 - Why couldn't the Big Bugaboo Creek Reach 2 stream crossing be shifted
upstream to avoid permanent wetland impacts/loss?
6. Page 18, Table 10 - Based on the planting plan, it appears only supplemental planting is
proposed for UT4. Correct?
7. Page 22, Table 15 - Are there any concerns about the long-term stability and adequate
sediment transport along UT3 with the high design sinuosity shown on Sheets 1.38 - 1.44?
8. Page 24, Section 6.6 - Has the amount of available onsite woody material for proposed stream
stabilization and habitat structures been evaluated? If necessary, will offsite woody material be
sourced to complete construction of all of the structures shown on the design sheets?
9. Page 27-28, UT5 & UT6 - Understanding that these reaches are not for credit, can you please
include the existing/proposed reach length in the narrative.
10. Page 28, Section 6.7 - Please reference the planting window specified in the 2016 NCIRT
Mitigation Update Guidance.
11. Page 29, Table 19 - Based on the described UT4 existing conditions and proposed work,
DWR believes that 4:1 is a more appropriate credit ratio for this reach.
12. Page 30, Table 20 - Please note the flow performance standard is for "each year".
13. Page 31, Section 10 - Please specify an expected maximum duration between "periodic"
inspections.
14. Page 32, Section 11 - DWR's General Water Quality Certification 4134 requires notification for
any repairs that result in a change from the approved plans.
15. Figure 10 - Please shift the intermittent reach flow gauges at least 50 feet upstream. Also,
please show existing wetlands.

16. Sheet 0.3 —
a. Are channel plugs proposed? If so, please indicate approximate locations and include a
typical detail.
b. Also, there were no "fill existing channel" callouts. It would help our review to see the
existing channel areas proposed to be filled as a shaded feature on the plan view
sheets. Note that if partial filling is proposed, the final grade in these areas should be
designed to seasonally dry.
17. Sheet 1.01 — Is the Swale callout actually for a Rock Floodplain Outlet? If so, please update
the text. If not, please add a Swale typical detail. (Same comment for Sheet 1.21)
18. Sheet 1.15 — Are two existing channels converging on this sheet? There appears to be four
existing top of bank lines.
19. Sheet 1.20 — Are there any concerns about the long term stability of the sharp bend on Big
Bugaboo Creek Reach 4 just downstream of the UT4 confluence?
20. Sheet 1.37 — Why wasn't the steam origin of UT2B able to be captured within the conservation
easement?
21. Sheet 2.00 — Either on the design sheet or in the mitigation plan text, please indicate that the
proposed BMPs are designed to not require long-term maintenance.
22. Sheets 2.01 & 2.02 —Are these BMPs designed to wet year-round? They are not included in
the planting plan, but please confirm at minimum the side slopes will be vegetated. DWR
would like to see planting within the BMP bed, if possible.
23. Sheet 3.0 —
a. DWR understands that quantity substitutions may be necessary based on the nursery's
species available. However, we request that no species account for more than 20
percentage of a specified planting zone in order to promote diversity.
b. Have you had success planting Helesia tetraptera in restoration wetland areas? I was
not able to identify its wetland indicator status.
24. Sheet 6.0 — What are the proposed stone size(s) for the Rock Floodplain Outlet?
25. Design Sheets — Please include an overall fencing plan indicating existing and proposed
fencing and approximate locations of anticipated gates.
BROWNINGNM Digitally signed by
BROWN ING.KIMBERLY.DA
BERLY.DANIELL NIELLE.1527683510
E.1527683510 Date: 2020.08.2814:33:40
-04 00
Kim Browning
Mitigation Project Manager
Regulatory Division