20140193 Ver 1_USACE Response to More Info_20201217

Strickland, Bev
From: Browning, Kimberly D CIV USARMY CESAW (USA)
<[e-mail]>
Sent: Thursday, December 17, 2020 3:29 PM
To: Jake McLean; Wiesner, Paul
Cc: Reid, Matthew; Eric Neuhaus; Shawn Wilkerson; Allen, Melonie; Haywood, Casey M
CIV (USA); Tugwell, Todd J CIV USARMY CESAW (US); Davis, Erin B; Bowers, Todd;
Wilson, Travis W.; Munzer, Olivia; Mimi Caddell; Kristi Suggs
Subject: [External] RE: DMS Mitigation Plan Addendum Request: Henry Fork Stream and
Wetland Mitigation Project/ SAW- 2014-00538/Catawba County
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:[e-mail]>
Hi Jake,
The IRT reviewed the additional information and response to comments for the Henry Fork site. The
consensus is that we agree with the proposal to re -plant and supply the veg data in spring. Although you are
using livestakes, we will still expect the vigor standard to be met in these areas to receive full credit. Hopefully
the gauges represent all the newly proposed wetland areas. If you feel that they do not capture all the
proposed wetlands, a re -verification of jurisdictional limits may be required prior to close-out.
Please reach out if you have any questions.
Thanks
Kim
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers
-----Original Message -----
From: Jake McLean <[e-mail]>
Sent: Thursday, December 10, 2020 12:41 PM
To: Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>; Wiesner, Paul
<[e-mail]>
Cc: Reid, Matthew <[e-mail]>; Eric Neuhaus <[e-mail]>; Shawn
Wilkerson <[e-mail]>; Allen, Melonie <[e-mail]>; Haywood, Casey M
CIV (USA) <[e-mail]>; Tugwell, Todd J CIV USARMY CESAW (USA)
<[e-mail]>; Davis, Erin B <[e-mail]>; Bowers, Todd
<[e-mail]>; Wilson, Travis W. <[e-mail]>; Munzer, Olivia
<[e-mail]>; Mimi Caddell <[e-mail]>; Kristi Suggs
<[e-mail]>
Subject: [Non-DoD Source] RE: Request for more information/ DIMS Mitigation Plan Addendum Request: Henry
Fork Stream and Wetland Mitigation Project/ SAW- 2014-00538/Catawba County

Hi Everyone,
I apologize for the delay in getting this response out. Please find our responses below in red text, and a copy
of this email response attached in pdf for your files. We will require additional time to collect vegetation data
and do planting to supplement these areas, but I'm hoping that based on this response we can get some
feedback on our proposed approach to guide us in moving forward with this. Although our perceived wetland
credit risk is low based on current data (see attached pdf), we understand that the IRT has viewed prior credit
establishment on the site through a holistic lens based on the unique nature of this site. Furthermore, we
understand that in order to agree to additional crediting on this site, this should include just effort to enhance
ecological uplift and provide associated documentation. If you feel that the efforts proposed below are not
commensurate with the credit being requested, we are amenable to revisit the ratio requested or the efforts
proposed.
Thanks,
Jake
From: Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, October 30, 2020 1:59 PM
To: Wiesner, Paul <[e-mail]>
Cc: Jake McLean <[e-mail]>; Reid, Matthew <[e-mail]>; Eric Neuhaus
<[e-mail]>; Shawn Wilkerson <[e-mail]>; Allen, Melonie
<[e-mail]>; Haywood, Casey M CIV (USA) <[e-mail]>; Tugwell,
Todd J CIV USARMY CESAW (USA)<[e-mail]>; Davis, Erin B <[e-mail]>;
Bowers, Todd <[e-mail]>; Wilson, Travis W. <[e-mail]>; Munzer, Olivia
<[e-mail]>
Subject: Request for more information/ DMS Mitigation Plan Addendum Request: Henry Fork Stream and
Wetland Mitigation Project/ SAW- 2014-00538/Catawba County
Good afternoon Paul,
The 15-day comment review period for the NCDMS Henry Fork Mitigation Plan Addendum (SAW-2014-00538)
closed on October 28, 2020. Per Section 332.8(o)(9) of the 2008 Mitigation Rule, this review followed the
streamlined review process. All comments received during the review process are below.
USACE Comments, Todd Tugwell and Kim Browning:

The Corps requests vegetation data for these proposed wetland areas prior to approving their addition to the
wetland assets.Some areas have woody stems (both planted and volunteer) while some do not. We propose
to map areas of existing high and low density stem counts within the proposed wetlands, and to plant areas of
low density during this dormant season at a rate of 600 stems/acre. We propose to set up 3 vegetation plots
to track density and vigor in the proposed wetlands over the remaining monitoring term - we will do this in a
way that includes representation of both existing and new stems. We also propose to visually monitor the
success of new plantings. New plantings are proposed to consist of wetland and deer -tolerant livestakes
which will limit diversity (and transplants from adjacent areas where available to supplement and diversify
species). We have observations of low success with planting bareroot or potted trees that have already been
rooted in a drier hydrologic regime and we have had significant vegetation setbacks and losses from deer on
this site. If deemed acceptable, vegetation data will be provided prior to the credit release meeting in April,
2021.
Only two of the five areas proposed have gauges in them. This is concerning because the IRT requested these
gauges back in March 2016 if WEI thought the wetland boundaries were going to be different from the
approved mitigation plan. We understand these were requested early on and have no response to counter
this concern - gages13, 14, and 15 were installed as soon as we determined we desired to make this request.
We feel that GWG1 is representative of Wetland DID and that GWG's 14 & 15 are representative of Wetlands
AA, BB, and CC.
Wetland EE appears to be relatively permanently impounded according to the gauge data, which raises
concern whether this area may be too wet to support trees.
The hydrologic regime of Wetland EE in 2019 was impacted by beaver impoundments - beaver were
subsequently trapped and removed. Related to tree growth - it is true that the variation in topography in all of
these wetlands influences the type of vegetation and habitat supported in each of these areas - some being
old irrigation ponds or having ditch remnants that are emergent in character. Intermittent impoundment by
beaver and riverine flooding have also influenced current vegetation. We proposed to attempt to establish
woody vegetation in all of the wetlands, but recognize that some of the areas may not support this. We can
accept that no credit may be offered for wetlands that do not support woody vegetation.
Prior to approving this addendum we request veg data for the proposed areas, and we would like a map that
shows the areas that are at-risk/not meeting success. Vegetation data will be collected and provided along
with other data specified above. The map showing at -risk areas determined by gage analysis and wetland
delineation is attached.
EPA, Todd Bowers:
At this time I have no specific comments on the proposed addendum for the site to provide 0.220 riparian
wetland mitigation units to only be used if proposed wetlands at the mitigation site do not meet the
thresholds or performance standards for success in the current mitigation plan. The created potential
wetlands appear to be providing the appropriate function based on the groundwater gauge data (GWG 13 and
15) and the vigorous vegetation growth shown in the attached photos.
As stated, the WMUs generated by this supplemental request would only be used to offset credits approved in
the mitigation plan that are not granted due to failure to meet performance.

WRC, Travis Wilson:
Looking at the mapped locations as well at the photos it looks like the vegetation is comprised of emergent
and pioneering species. All wetlands on this site were classified as Headwater forest. If these wetlands are
going to be classified the same they should follow the same planting plan and vegetative success criteria.
As discussed above, there are pockets of deeper water with prolonged inundation. We propose to plant
woody species from the livestake planting plan this winter in areas that have not already revegetated with
desired species (river birch, box elder, alders). Refer to proposed vegetative success monitoring in the
response to Corps comments. Further, we have treatment of cattails visible in the photos scheduled for next
year. We request that vegetation criteria be relaxed to the point of demonstrating successful establishment
and progression of woody species in these areas rather than achieving full term criteria by the currently
scheduled close-out date.
DWR, Erin Davis:
Are all of the proposed wetland creation areas outside of the original planted project area? I question whether
they would meet the standard veg density performance standard. One of the areas is sweetgum dominated.
Yes, most of the areas are outside of the planted area. We propose to perform the monitoring as stated
above. There are dense riverbirch and alder thickets in some of the proposed wetland areas, but I don't
believe that any areas are sweetgum monocultures. We have treated some such monocultures on the site
within and adjacent to planted areas and will consider the same treatment in these creations areas where
warranted. We do feel that with the difficulty of deer browsing on this site that establishment of canopy
through pioneering species with an eye towards later forest succession may be better than no canopy.
Please reach out if you have any questions.
Thanks
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers
-----Original Message-----

From: Haywood, Casey M CIV (USA) <[e-mail]
<mailto:[e-mail]> >
Sent: Tuesday, October 13, 2020 12:34 PM
To: Tugwell, Todd J CIV USARMY CESAW (USA) <[e-mail]
<mailto:[e-mail]> >; Browning, Kimberly D CIV USARMY CESAW (USA)
<[e-mail] <mailto:Kimberly. D. Browning@ usace.army.mil> >; Davis, Erin B
<[e-mail] <mailto:[e-mail]> >; Haywood, Casey M CIV (USA)
<[e-mail] <mailto:[e-mail]> >; Smith, Ronnie D CIV
USARMY CESAW (USA) <[e-mail] <mailto:[e-mail]> >;
McLendon, C S CIV USARMY CESAW (USA)<[e-mail]
<mailto:[e-mail]> >; Bowers, Todd <[e-mail]
<mailto:[e-mail]> >; Wilson, Travis W. <[e-mail]
<mailto:[e-mail]> >; Munzer, Olivia <[e-mail]
<mailto:[e-mail]> >; Byron Hamstead <[e-mail]
<mailto:[e-mail]> >
Cc: Jake McLean <jmclean@wild Iandseng.com <mailto:jmclean@wild Iandseng.com> >; Reid, Matthew
<[e-mail] <mailto:[e-mail]> >; Wiesner, Paul <[e-mail]
<mailto:[e-mail]> >; Eric Neuhaus <eneuhaus@wild landseng.com
<mailto:eneuhaus@wild landseng.com> >; Shawn Wilkerson <[e-mail]
<mailto:[e-mail]> >; Allen, Melonie <[e-mail]
<mailto: melon [e-mail]> >
Subject: Notice of NCDEQ - DMS Mitigation Plan Addendum Request: Henry Fork Stream and Wetland
Mitigation Project (DMS# 96306) - (SAW- 2014-00538) (DWR#20140193) - Catawba 03050102_Catawba
County
Good afternoon IRT,
The below referenced Mitigation Plan Addendum Request review has been requested by NCDMS. Per Section
332.8(o)(9) of the 2008 Mitigation Rule, this review follows the streamlined review process, which requires an
IRT review period of 15 calendar days from this email notification. Please provide any comments by 5 PM on
the 15-day comment deadline shown below. Comments provided after the 15-day comment deadline (shown
below) may not be considered.

At the conclusion of this comment period, a copy of all comments will be provided to NCDMS and the NCIRT
along with District Engineer's intent to approve or disapprove this AMP.
Wildlands Engineering, Inc. (WEI) has prepared a Mitigation Plan Addendum for the Henry Fork Mitigation Site
(DMS# 96306). WEI has identified five additional wetland areas that have developed following site
construction. These five wetland areas were not identified in the approved Jurisdictional Determination
(USACE) and they were not identified as having hydric soils in the LSS soils report from the IRT approved
Mitigation Plan. As a result, WEI is proposing a creation credit ratio of 3:1 for the additional 0.661 acres for a
total of 0.220 Riparian WMUs.
WEI is not seeking additional wetland credit above the approved Mitigation Plan and the DMS credit ledger
will not be updated. The purpose of proposing these additional areas for credit is to offset any wetland credits
that may be at risk of losing credit at project closeout. These additional areas have been monitored since
March 2019 (MY4) and will continue to be monitored through project closeout. Upon IRT review and approval
of this wetland addendum, Wildland's will document the additional wetland areas in this year's annual
monitoring report (MY5) and through project closeout.
The site is currently in MY5 (2020) and is scheduled to close in 2023.

Digital copies were uploaded to the IRT SharePoint page (10/6/2020) and DWR's Laser Fiche system
(10/6/2020) for IRT review. A copy is also attached.
15-Day Comment Start: October 13, 2020
15-Day Comment Deadline: October 28, 2020 45-Day DE Decision: November 27, 2020
Project information is as follows:
Henry Fork Mitigation Site
DMS Project # 96306
Institution Date: 2/15/2014
RFP 16-005298 (Issued: 6/6/2013)

Catawba River Basin
Cataloging Unit 03050103 Expanded Service Area
Catawba County, North Carolina
USACE Action ID: SAW- 2014-00538
DWR#: 20140193
Proposed Mitigation Project Credits:
4,807.667 SMU (cool)
4.222 WMU (riparian)
Full Delivery Provider: Wildlands Engineering Inc. — Contact: Jake McLean, [e-mail]
<mailto:[e-mail]><mailto:[e-mail]
<mailto:[e-mail]> > , [phone]

NCDEQ - DMS Project Manager: Matthew Reid, [e-mail]
<mailto:[e-mail]> <mailto:[e-mail] <mailto:[e-mail]>
> , [phone]
The Mitigation Plan Addendum has been uploaded to the IRT/ NCDEQ SharePoint Mitigation Plan Review page
and can be accessed here:
IRT SharePoint page:
Blockedhttps://ncconnect.sharepoint.com/sites/I RT-DMS/SitePages/Home.aspx
Hen ryFrk_96306_MPAddendum_2020.pdf
Blockedhttps://ncconnect.sharepoint.com/sites/I RT-
DMS/IRT%20Upload%20Documents%20Here/Forms/Allltems.aspx?id=%2Fsites%2FIRT%2DDMS%2FIRT%20Up
load%20Documents%2OHere%2FHenry%2OFork%20%2896306%29%2FHenryFrk%5F96306%5FMPAddendum
%5F2020%2Epdf&parent=%2Fsites%2FIRT%2DDMS%2FIRT%20Upload%20Documents%20Here%2FHenry%20F
ork%20%2896306%29 <Blockedhttps:Hncconnect.sharepoint.com/sites/IRT-
DMS/IRT%20Upload%20Documents%20Here/Forms/Allltems.aspx?id=%2Fsites%2FIRT%2DDMS%2FIRT%20Up
load%20Documents%2OHere%2FHenry%2OFork%20%2896306%29%2FHenryFrk%5F96306%5FMPAddendum

%5F2020%2Epdf&parent=%2Fsites%2FIRT%2DDMS%2FIRT%20Upload%20Documents%20Here%2FHenry%20F
ork%20%2896306%29>
Please contact the Mitigation Office if you have questions.
V/r,
Casey Haywood
Mitigation Specialist, Regulatory Division I U.S. Army Corps of Engineers
3331 Heritage Trade Dr, Ste. 105 1 Wake Forest, NC 27587 1
BUILDING STRONG °
10