20180665 Ver 1_Wildlands Response to IRT Comments_20201201

Strickland, Bev
From: Kristi Suggs <[e-mail]>
Sent: Tuesday, December 1, 2020 11:16 AM
To: Kim Browning
Cc: Tsomides, Harry; Aaron Earley; Wiesner, Paul; Shawn Wilkerson; Tugwell, Todd J CIV
USARMY CESAW (US); Haywood, Casey; Davis, Erin B; Wilson, Travis W.; Bowers, Todd;
Stanfill, Jim; Hamstead, Byron A; Baumgartner, Tim;
[e-mail]; Smith, Ronnie D CIV USARMY CESAW (USA)
Subject: [External] Wildlands Response to IRT Comments / Notice of Initial Credit Release /
NCDMS Alexander Farm Mitigation Site / Alexander Co. / SAW-2018-00451
Attachments: AlexanderFarm_100048_MYO_ResponseTolRTComments_2020.pdf
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Good Morning Kim,
I apologize for just now getting these responses back to you in reference to the Alexander Farm Baseline Report. I
thought that I had already sent them and then realized that I had meant to send them, but didn't. Since I was not
included on the original email that you had sent and you had requested for us to reply back to that email, I have
included the text from the original email below. I hope that is sufficient, if not please just let me know. For your
review, I have attached Wildlands' responses to the IRT's comments in reference to the Alexander Farm Mitigation
Site's As -built and Baseline Monitoring Report, DMS Project #100048. Please note that we will include a copy of these
responses as well as your email in the Appendix of the MY1 Report for the project. Please feel free to contact me if
you have any questions. Thank you very much!
Sincerely,
Kristi Suggs
Kristi Suggs I Senior Environmentol Scientist
0: 704.332.7754 x110 M: 704.579.4828
Wildlands Engineering, Inc.
1430 S. Mint St, Suite 104
Charlotte, NC 28203
From: Browning, Kimberly D CIV USARMY CESAW (USA) [mailto:[e-mail]]
Sent: Thursday, October 22, 2020 12:14 PM
To: Tsomides, Harry <[e-mail]>; Wiesner, Paul <[e-mail]>; Aaron Earley
<[e-mail]>; Shawn Wilkerson <[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CESAW (US)<[e-mail]>; Haywood, Casey M CIV (USA)
<[e-mail]>; Davis, Erin B <[e-mail]>; Wilson, Travis W.
1

<[e-mail]>; Bowers, Todd <[e-mail]>; Stanfill, Jim <[e-mail]>;
Hamstead, Byron A <byron [e-mail]>; Baumgartner, Tim <[e-mail]>; McLendon, C S
CIV USARMY CESAW (USA) <[e-mail]>; Smith, Ronnie D CIV USARMY CESAW (USA)
<[e-mail]>
Subject: [External] Notice of Initial Credit Release/ NCDMS Alexander Farm Mitigation Site/ Alexander Co./ SAW-2018-
00451
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Good afternoon,
The 15-Day Record Drawing review for the Alexander Farm Mitigation Site (SAW-2018-00451) ended October 20, 2020.
Per Section 332.8(o)(9) of the 2008 Mitigation Rule, this review followed the streamlined review process. All comments
received from the NCIRT are incorporated within this email. Please provide a response to comments by replying to this
email. There were no objections to issuing the initial credit release. Please find attached the current signed ledger.
USACE Comments. Kim Brownine:
The proposed and As -Built mitigation plan assets are consistent (4,258.100 SMUs), but the approved mitigation plan
length and the As -Built lengths differ (6,555 LF vs 6,519 LF). The As -Built credits should be adjusted to reflect the actual
amount built unless the difference is from areas that were not for credit. Please verify.
DWR Comments. Erin Davis:
1. Rock was added at 13 locations within the project. A few questions:
a. Were other stabilization options considered prior to deciding to harden these areas?
b. Was placement of rock within existing wetlands accounted for as permanent impacts in the submitted PCN? Rock
placed near stations 112+00, 113+00, 115+00, 144+50, and 166+50 appear to overlap the wetland polygons on the
redline drawings.
DWR requests an additional photo point near Station 118+00 focusing on the culvert crossing connection.
3. DWR appreciates the bulleted descriptions of field changes included in the baseline report. We would request that
a few more words be added to changes "due to site/field conditions" in order to provide context.
4. In future baseline reports, please note if monitoring locations have changed from locations shown in the approved
mitigation plan monitoring figure (this isn't meant to include shift of a few feet in the field). The IRT regularly comment
on gauge and plot locations during the draft mitigation plan review and need to be aware of changes in order to
compare documents.
EPA Comments, Todd Bowers:
* Excellent spread of photos highlighting stream structures, veg plots and gauges. I would recommend adding
photos of culverts at the cattle crossing easement break and at the road.
* Recommend identifying the unknown oak species as Quercus alba as it is the only other oak species that was
planted especially since they were just planted. I hope this gets rectified in the MY1 report.
* Recommend adding a beaver contingency to the Adaptive Management plan in Section 4.1.
* Late planting date (April 17, 2020) is noted and that the earliest date of MY1 monitoring will be October 17,
2020. (approximately 180-days post planting)
* Species change noted in planting plan. No concerns with substitutions.
* Recommend adding wetland indicator status to planting plans for vernal pools planting zone.
* 2.0 credit ratio for restoration work on Reaches 1A and 113 noted; due to contracted credit requirement.
Please contact the mitigation office if you have questions.
Thanks

Kim
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers

WILDLANDS
ENGINEERING
November 12, 2020
Kim Browning
Mitigation Project Manager
Regulatory Division, U.S. Army Corp of Engineers
[e-mail]
Subject: IRT Review Comments: 15-Day Record Drawing Review
Alexander Farm Mitigation Site, Alexander County
Yadkin River Basin — HUC 03040101
DMS Project ID No. 100048 / DEQ Contract #007416
Dear Ms. Browning:
Wildlands Engineering, Inc. (Wildlands) has reviewed the 15-Day Record Drawing review comments from
the NC Interagency Review Team (IRT) and subsequent email from Paul Wiesner at the NC Division of
Mitigation Services (DMS) in regard to the Alexander Farm Mitigation Site. The first set of comments
outlined below have been paraphrased from an email that Wildlands received on 10/22/2020 from Paul
Wiesner at DMS and references a brief discussion with Kim Browning at the U.S. Army Corps of Engineers
(USACE) about the 15-day Record Drawing review comments, which were received earlier in the day on
10/22/2020. The next set of comments are the actual 15-day Record Drawing review comments received
from the IRT. All comments are noted below in Bold. Wildlands' responses to all comments are noted
below in italics.
Email received from NCDMS on 10/22/2020
NCDMS, PAUL WIESNER
DMS Comment: Do not reduce the mitigation credit in future monitoring reports or in the DMS credit
ledger for Alexander Farm. However, please provide a better detailed explanation of the difference in
length (36 feet).
Wildlands response: As requested, Wildlands will not adjust the mitigation credit table in future Alexander
Farm monitoring reports to address the loss of 36 linear feet (LF) of stream at baseline conditions versus
the proposed design lengths that were specified in the mitigation plan. In addition, Wildlands' has included
a better detailed explanation for the difference in length and is outlined below.
• UT1 Reach 18:
o An alignment change from Station 116+50—117+44, which softened the meander pattern
just upstream of the culverted crossing, was conducted to improve bank stability and
reduce hydraulic stress on the channel. This resulted in a loss of 12 linear feet (LF) in as -
built length from the design length.
• UT1 Reach 2:
o An alignment change from Station 117+80 to 118+35, which softened the meander
pattern just downstream of the culverted crossing, was conducted to improve bank
stability and reduce hydraulic stress on the channel. This resulted in a loss of 5 LF in as -
built length from the design length.
Wildlands Engineering, Inc. • phone [phone] • fax [phone] • 1430 S. Mint Street, # 104 • Charlotte, NC 28203

WILDLANDS
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o An alignment change from Station 120+27 to 120+84, which softened the meander
pattern and shifted the channel alignment away from the existing right top of bank, was
conducted to improve bank stability, reduce hydraulic stress on the channel, and save
existing mature trees at the right top of bank. This resulted in a gain of 2 LF in as -built
length from the design length.
o The mitigation planset listed the end stationing on the reach at 130+50; however, this was
incorrect. The end stationing should have been noted at the easement break which was
Station 130+46. This accounted for a loss of 4 LF.
o The total net loss on UT1 Reach 2 at as -built was 7 LF.
• UT1 Reach 3
o The mitigation planset listed the begin stationing on the reach at 131+10; however, this
was incorrect. The begin stationing should have been noted at the easement break, which
was Station 131+27. This accounted for a loss of 17 LF in as -built length from the design
length.
DMS Comment: Please make sure to that all future MYO reports have a detailed explanation when
mitigation plan lengths do not match as -built lengths. Project credits established in the IRT approved
mitigation plan are the project credits at MYO unless there are significant deviations during
construction. Any upward or downward credit changes requires a mitigation plan addendum.
Wildlands response: Wildlands acknowledges this comment and will heed this request to provide a more
detailed explanation when there are differences between mitigation plan lengths and as -built record
drawing lengths. In addition, we understand that significant changes made during construction will
require credit changes and a mitigation plan addendum.
DMS Comment: Please do not provide any mitigation credit assessments as footnotes of the MYO asset
table. Please remove that from the Alexander MY1 report. Again, the project credits are established
at the IRT approved mitigation plan stage.
Wildlands response: The mitigation credit assessment footnote will not be included as part of the MY1
asset report table, nor any subsequent monitoring reports.
15-Day Record Drawing Review Comments (10/22/2020)
USACE, KIM BROWNING
USACE comment: The proposed and As -Built mitigation plan assets are consistent (4,258.100 SMUs),
but the approved mitigation plan length and the As -Built lengths differ (6,555 LF vs 6,519 LF). The As -
Built credits should be adjusted to reflect the actual amount built unless the difference is from areas
that were not for credit. Please verify.
Wildlands response: Per the email received from Paul Wiesner at DMS on 1012212020, this comment is no
longer an issue. Please see the first two comment responses listed under the "Email received from NC DMS
10/22/2020" for the updated comment request.
NC DWR, ERIN DAVIS
DWR comment: Rock was added at 13 locations within the project. A few questions:
a) Were other stabilization options considered prior to deciding to harden these areas?
Wildlands Engineering, Inc. • phone [phone] • fax [phone] • 1430 S. Mint Street, # 104 • Charlotte, NC 28203

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WILDLANDS
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b) Was placement of rock within existing wetlands accounted for as permanent impacts in the
submitted PCN? Rock placed near stations 112+00, 113+00, 115+00, 144+50, and 166+50 appear
to overlap the wetland polygons on the redline drawings.
Wildlands response:
a) Each of the areas where rock was added exhibited significant potential for erosion due to
concentrated overland flow. Wildlands considered three options at these and other locations: do
nothing, regrade a new swale connection, or add stone protection. Several locations were left alone
due to low risk. Regrading was not an option for most locations due to topography and impact to trees.
b) Most of the rock placement that overlapped into the wetland areas were included in the permanent
wetland impacts for the project, but not all. Approximately 0.005 acres were only permitted as
temporary impacts, while 0.0003 acres were inadvertently omitted in the permitted wetland acreage.
This error was oversight and was not done intentionally. The placement of stone protection within the
wetland outlet boundaries were conducted as field calls by the engineer because field conditions during
construction determined that the areas were at high risk for erosion and assumed that the areas were
included as part of the permitted allowances since they were within the limits of disturbance. Wildlands
acknowledges to do a better job in the future at assessing these type of site condition issues during the
design phase and communicating the potential for field changes, so that these areas are included as
part of the permanent impacts, in case there is a need for additional stability measures and/or design
changes during construction.
DWR comment: DWR requests an additional photo point near Station 118+00 focusing on the culvert
crossing connection.
Wildlands response: A photo point will be added upstream and downstream of the internal culvert crossing
near Station 118+00. The photo point will collect both an upstream and a downstream viewpoint and will
be included in the MY1 and subsequent monitoring reports.
DWR comment: DWR appreciates the bulleted descriptions of field changes included in the baseline
report. We would request that a few more words be added to changes "due to site/field conditions"
in order to provide context.
Wildlands response: As requested, Wildlands' will provide additional context to field change descriptions
in future baseline reports.
DWR comment: In future baseline reports, please note if monitoring locations have changed from
locations shown in the approved mitigation plan monitoring figure (this isn't meant to include shift of
a few feet in the field). The IRT regularly comment on gauge and plot locations during the draft
mitigation plan review and need to be aware of changes in order to compare documents.
Wildlands response: As requested, Wildlands' will note changes in monitoring locations in future
baseline reports when their established locations differ significantly from those in the approved
mitigation plan.
EPA, TODD BOWERS
EPA comment: Excellent spread of photos highlighting stream structures, veg plots and gauges. I would
recommend adding photos of culverts at the cattle crossing easement break and at the road.
Wildlands response: Thank you for the kind remark. As requested, Wildlands' has added a photo point
upstream and downstream of the internal cattle crossing near Station 118+00 and upstream and
Wildlands Engineering, Inc. • phone [phone] • fax [phone] • 1430 S. Mint Street, # 104 • Charlotte, NC 28203

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WILDLANDS
E N G I N E E R I N G
downstream of the Elk Shoals Church Road crossing. These photos will capture both an upstream and a
downstream viewpoint and will be included in the MY1 and subsequent monitoring reports.
EPA comment: Recommend identifying the unknown oak species as Quercus alba as it is the only
other oak species that was planted especially since they were just planted. I hope this gets rectified in
the MY1 report.
Wildlands response: Wildlands' acknowledges that the unknown oak species is likely Quercus alba and
will make sure to correctly identify the planted stem in the MY1 report.
EPA comment: Recommend adding a beaver contingency to the Adaptive Management plan in Section
4.1.
Wildlands response: The monitoring of nuisance beaver activity and the potential removal of beavers
and their dams is included through project close-out as part of Wildlands' adaptive management
measures listed in Section 4.1 for the stream maintenance component.
EPA comment: Late planting date (April 17, 2020) is noted and that the earliest date of MY1
monitoring will be October 17, 2020. (approximately 180-days post planting)
Wildlands response: Wildlands acknowledges that the 180-day post planting requirement for monitoring
did not expire until October 17, 2020 and made sure to wait until after that date to collect data for MY1.
EPA comment: Species change noted in planting plan. No concerns with substitutions.
Wildlands response: Thank you for confirming that the planted species substitutions are acceptable.
EPA comment: Recommend adding wetland indicator status to planting plans for vernal pools planting
zone.
Wildlands response: Wildlands acknowledges this request and will include the wetland indicator status
for planted vernal pool species in the record drawings of future baseline monitoring reports.
EPA comment: 2.0 credit ratio for restoration work on Reaches 1A and 1B noted; due to contracted
credit requirement.
Wildlands response: Wildlands' acknowledges the comment. No response is needed.
As requested, Wildlands has responded in this attached letter to the IRT's comments via email. In
addition, Wildlands would like to thank the IRT with taking the time to provide these thoughtful
comments, which will help us to continue to improve the quality of our mitigation deliverables.
Sincerely,
Kristi Suggs
Senior Environmental Scientist
[e-mail]
Wildlands Engineering, Inc. • phone [phone] • fax [phone] • 1430 S. Mint Street, # 104 • Charlotte, NC 28203