20081555 Ver 2_More Info Received_20110218 (18)

Strickland, Bev
From: Steenhuis, Joanne
Sent: Friday, February 18, 2011 3:09 PM
To: Mcmillan, Ian
Cc: Strickland, Bev
Subject: FW: Revisions to Shelter Creek Quarry Does DWQ # 08 1555
Attachments: Response to USACE RFAI 12-17-10 v5.pdf; Addendum Attachment 10 - Quarry Wetland
Impact Spreadsheet 2-17-11.pdf
From: Dana Lutheran [mailto:[e-mail]]
Sent: Thursday, February 17, 20114:00 PM
To: Ronnie D SAW Smith; Steenhuis, Joanne
Cc: David Syster
Subject: Revisions to Shelter Creek Quarry Docs
have attached the revised 12-17-11 letter ( this would be version 5). The revisions are in blue and
underlined. I also updated and attached the Addendum Attachment 10 - Shelter Creek Quarry
Spreadsheet. I sent the revised mitigation map via email earlier today.
I believe I have made all of the corrections necessary, but if you find something else, please call as
soon as possible. I would like to ensure that you guys have everything you need prior to the
weekend.
Dana
5r-6i
Southern Environmental Group, Inc.
5315 South College Road, Suite E
Wilmington, NC 28412
Phone: [phone]
Fax: [phone]
Mobile: [phone]
PREPARED BY: SEGi SHELTER CREEK QUARRY WETLAND SUMMARY SPREADSHEET Revised 2/17/11
WETLAND
AREA
SIZE (AC)
SIZE (SF)
IMPACT AREA **
TYPE NON-RIPARIAN
IMPACTS RIPARIAN
IMPACTS
PHASE
404 WET
401 WET
404 MIT
401 MIT
TOTAL MIT
A 7.2 313,632.0 7.2 Swamp Forest + IA A 0 Y
B 0.8 34,848.0 0.8 Wet Flat + IA Y
C 3.8 165,528.0 3.8 Wet Flat + I;a Y
D 5.9 257,004.0 5.9 Pocosin + IA Y
E 0.24 10,454.4 0.24 Bottomland Hardwood Forest • IB Y
F 1.4 60,984.0 1.4 Wet Flat + IB 1 Y
G 0.7 30,492.0 0.7 Wet Flat + IB Y
H 1.56 67,953.6 1.56 Wet Flat + IB V L Y
1 0.5 21,780.0 0.5 Bottomland Hardwood Forest • IB A Y
1 0.11 4,791.6 0.11 Wet Flat + IA V L Y
K 0.16 6,969.6 0.16 Wet Flat + IA V L Y
AA 1.2 52,272.0 1.2 Freshwater Marsh + ILA A Y
BB 0.54 23,522.4 0.54 Wet Flat + ILA V L Y
CC 0.24 10,454.4 0.24 Cypress Swamp + ILA V L Y
DD 4.9 213,444.0 4.9 Cypress Swamp + ILA A Y
EE 5.3 230,868.0 5.3 Cypress Swamp + IIA A Y
FF 3.4 148,104.0 3.4 Non-riverine Swamp + IIB A Y
GG 1.48 64,468.8 1.48 Bottomland Hardwood Forest • IIB A Y
HH 1.75 76,230.0 1.75 Bottomland Hardwood Forest • IIB A Y
11 0.31 13,503.6 0.31 Bottomland Hardwood Forest • IIB A Y
-jj-- 9-24 10,4544 9:99 N
KK* 2.12 92,347.2 0.11 Bottomland Hardwood Forest • IIB A Y
LL 4-4& 64
468
8 9
99 N
,
. :
MM 1.86 81,021.6 1.86 Bottomland Hardwood Forest • IIB A Y
NN 0.11 4791.6 0.11 Swamp Forest • IIB A Y
00 0.12 5,227.2 0.12 Swamp Forest • IIB A Y
PP 0.03 1,306.8 0.03 Swamp Forest • IIB A 0 Y
TOTAL 45.73 1,991,998.8 43.72 37.21 6.51 41.11 2.61 41.11 2.61
SF 1,904,443.2 1,620,867.6 283,575.6 1,790,751.6 113,691.6 1,790,751.6 113,691.6 1,904,443.2
* DENOTES ONLY A PORTION OF THE AREA IS TO BE IMPACTED. ** DENOTES NEW COLUMN
STRIKETu wont GH INDICATES THE ENTIRE AREA HAS BEEN REMOVED FROM IMPACTS. ITALICS DENOTE CHANGE FROM ORIGINAL.
Denotes the impact has been revised to reflect
the NWP impact of 0.102 AC
Page 1
PREPARED BY: SEGi SHELTER CREEK QUARRY WETLAND SUMMARY SPREADSHEET Revised 2/17/11
WETLAND TYPE BEING IMPACTED ACRES
Swamp Forest 7.46
Bottomland Hardwood Forest 6.25
Pocosin 5.9
Wet Flat 9.07
Freshwater Marsh 1.2
Non-riverine Swamp 3.4
Cypress Swamp 10.44
TOTAL 43.72
Mitigated Riparian Wetlands (AC) = 6.51
Mitigated Non-Riparian Wetlands (AC) = 37.21
Non-riparian Wetlands with NWP (AC) 0.10
Total Mitigated Wetlands (AC) = 43.82

*404 Wetlands to be Mitigated (AC) = 41.11
**401 Wetlands to be Mitigated (AC) = 2.61
*404 Impacts permitted with NWP 0.10
Total Wetlands to be Mitigated (AC) = 43.82
*to be mitigated at a 1:1 impact-to-mitigation ratio, by way of creation/restoration at the Croomsbridge Road
site and payment to the NCEEP
**to be mitigated for at 2:1 impact-to-mitigation ratio. The first part will be carried out by with
creation/restoration efforts on the Croomsbridge Road Site, while the second half of the 2:1 ratio will be
mitigated with preservation on the Croomsbridge Road site.
Page 2
,5outkern Lnvironmcntal Group, Inc.
53 15 South College Roan, Suite F- - Wilmington - NC - 2841 2
rhone: ? 10.452.271 1- rax: ? 10.452.2899 - nmaii: o{fice@s,i.us
17 December 2010
Electronic Mail
Mr. Ronnie Smith
US Army Corps of Engineers - Regulatory Division
69 Darlington Avenue
Wilmington, NC 28403
Ronme.D.Smitlik,usace.armv.mil
Re: Shelter Creek Quarry Individual Permit (v.5)
USACE AID #: SAW-2008-01720
DWQ Project #: 08-1555
Dear Mr. Smith,
IS EGI Project: 06-010.01
Thank you for taking the time to meet with Mr. David Syster and myself, to discuss the Shelter Creek
Quarry Individual Permit Application, currently under review by the USACE and DWQ. During our
meeting, the USACE stated a mitigation proposal was needed to complete IP application. This letter serves
to provide the required information outlined at that meeting as well as the preliminary mitigation proposal.
1. An updated "Milestone Map" that illustrates wetland impacts anticipated to
take place within 5 years of the mitigation site's commencement date, as well as a
commencement date, for the mitigation work;
Previously, SEGi submitted a milestone map that illustrated no wetland impacts within the
first five years. Since that submittal, that has changed. The Applicant believes approximately
7.97 AC of wetlands would be impacted within the first five years. The table below provides
the acreages for the impact areas. For locations of the impact areas, please see Attachment 1 -
Cursory Wetland Determination and Proposed Mitigation.
Impact Area Wetland Impact Acreage within First
5 Years Type
(404, Isolated)
A 1.4 404
B 0.8 404
C 3.8 404
J 0.11 Isolated
K 0.16 Isolated
AA 1.2 404
DD 0.49 404
Total 7.96
Total Mitigated Acreage
fable 1. Proposed wetland impacts to take place within S years
2 A LIDAR exhibit that illustrates historic wetland areas within the Croomsbridge property;
Please see Attachment 1 - Cursory Wetland Determination and Proposed Mitigation.
3. NCEEP costs for 2:1 and 1:1 mitigation-to-impact ratios, available NCEEP sites and/or
private mitigation banks within the HUC and, if any, the dates of credit availability for those
sites;
NCEEP
There are four (4) NCEEP sites located within the project HUC follows (see Attachment 2 -
NCEEP Mitigation Projects within Project HUC 03030007). They are as follows: Haw's Run
(PID 92154); Wallace Deer Club - Blanchard Tract (PID 92155); Wallace Deer Club -
Swinson Tract (PID 92103); and Wallace Deer Club - Tract 3-5 (PID 719). According to Ms.
Kelly Williams, with the NCEEP, as soon as a mitigation site is approved, credits become
available for that site. Thus, credits area available for all of the aforementioned mitigation
sites. Currently, the NCEEP In-Lieu Fee Schedule reflects the following fee per unit (AC), in
the Higher Fee HUs: Riparian Wetlands - $62,210/AC and Non-Riparian - $44,883/AC. The
NCEEP only sells credits in 1/4 AC increments. To mitigate through the NCEEP, a 2:1
mitigation-to-impact ratio would be required for those impacts proposed to take place within
5 years and a 1:1 mitigation-to-impact ratio for the remainder.
Hofmann Forest Wetland Mitigation Bank
This private mitigation bank is located within 50 miles of the project site, but it is not located
within the same HUC or drainage basin (see Attachment 3 - Hofmann Forest Vicinity Map).
Hofmann Forest only offers non-riparian mitigation credits. Thus, any riparian wetland
impacts would need to be offset using the NCEEP. Hofmann Forest has been completed and
credits are available. The credits are issued upon request and the fee mimics the NCEEP's
ILF schedule. However, Hofmann Forest does not limit the credits to be sold in 1/4 AC
increments. Because the mitigation bank is located outside the projects HUC, the mitigation-
to-impact ratio would increase to 3:1 for impacts proposed to take place within the first five
years and 2:1 for impacts proposed to place five years out.
Mitigation Cost Analysis through the NCEEP and Hofmann Forest
Based on the current NCEEP ILF schedule, the Applicant would expect to pay the following
cost for mitigation credits through the NCEEP and the Hofmann Forest:
NCEEP

Time Line Habitat (Riparian

/Non-riparian) Mitigated Impact

Acreage NCEEP Credits

AC
Cost
Within 5 years (2:1) NR 5.96 12.0 $538,596.00
Outside 5 years (1:1) NR 28.54 28.75 $1,290,386.25
R 6.51 6.75 $419,917.50
Total 41.01 47.5 $2.248.889.75
HOFMANN FOREST
Time Line Type (Riparian
/Non-riparian) Mitigated Impact
Acreage Hofmann Forest
Credits AC Cost
Within 5 years (3:1) NR 5.96 17.88 $802,508.04
Outside 5 years (2:1) NR 28.54 57.08 $2,561,921.64
R (NCEEP) 6.51 6.75 $419,917.50
Total 41.01 74.98 $3,784,347.18
Table 2. Cost comparison between the NCEEP and the Hofmann Forest Wetland Mitigation Bank
4. A comprehensive cost analysis for applicant responsible mitigation that should include, but is
not limited to; the cost of land, machinery, vegetation, environmental work (GPS of wetland
line, etc.), survey work (drawings), hydric material, labor, etc.;
Applicant responsible mitigation is anticipated to cost approximately $940,000. Below, you
will find a breakdown of costs associated with the proposed permitt ee responsible mitigation
project:
Land $250,000
Engineering $10,000
Surveying $20,000
Wetland Consulting $30,000
Soil & Erosion Control $25,000
Monitoring $25,000
Total Mitigation Cost $1,106,857
A 20% contingency buffer added to the Total Mitigation Cost elevates the potential cost of
the mitigation project to $1. _ million.
5. Include permittee responsible, alternative, mitigation site information, and why they were not
practicable;
Four (4) sites were considered in the search. Site selection was ranked and identified based
upon criteria that consider the potential for success, location within the project's drainage
basin, replacement values, anticipated long-term viability, feasibility, and cost. Each site is
discussed below:
Alternative Site I
Shaw Highway Site: At more than 1200 AC, this site was too large for the scope of
the Applicant's mitigation project. The current landowner was not interested in
subdividing the parcel and has since gone under contract by a third party. Therefore,
this site is not a practical alternative.
Alternative Site 2
3600 Acre Davis Farm Tract: As with the Shaw Highway Site, this site was too large
for the scope of the project and the landowner was not interested in subdividing.
Therefore, this site is not economically feasible.
Alternative Site 3
23 Acre Hwy 53 Site: On its own, this site is not large enough produce the acreage
necessary to offset the wetland impacts associated with mining project, and the
Applicant was unable to secure land contiguous to the site. In addition, based on
SEGi's field observations, the site would be difficult to establish hydrologic
conditions necessary to meet the criteria. Therefore, this site is not a logistically,
practicable alternative.
Alternative Site 4
Croomsbridge Road Site: The 158-acre site is situated adjacent to the North East
Cape Fear River. A cursory of the property indicates approximately 85.0 AC of
wetlands exist within the parcel boundaries (see Attachment 1 - Cursory Wetland
Determination and Proposed Mitigation). The tract exhibits characteristics similar to
that of the Quarry site. For instance, the two sites occupy a nearly identical landscape
position, in relation to their respective waterway; both are similar in related soil
types; and the two sites appear to be almost identical in vegetation composition and
succession. In addition, the two sites are both subject to the same seasonal overbank
flooding events, from their adjacent watercourse. Based on the comparison of the two
tracts and the cost of the land, the Croomsbridge road appears to be the most
practicable alternative.
6. The relation between the mitigation site and the Shelter Creek Quarry (e.g., location within
the flood plain, soils, etc.); and
Please see item 45, Alternative Site 4, above.
7. The mitigation-to-impact ratio will be 1:1 for wetland impacts proposed to take place 5 years
out from the commencement date of the mitigation work. Impacts to wetlands within the first
5 -years shall be offset with a mitigation-to-impact ratio of 2:1. If additional wetland impacts,
above that stated within the mitigation proposal, become necessary within the first 5 years, a
modification to the permit would be required prior to impacts taking place. Provide
preliminary mitigation proposal, which should include but is not limited to an area map that
depicts location, acreages, type of mitigation to occur (e.g., enhancement, restoration,
creation, etc.) and type of habitat proposed, brief planting plan, monitoring plan and success
criteria.
In total, the impact of 43.72 AC of wetlands (including both 404 and 401 jurisdictional
wetlands is necessary to facilitate the continued operation of the Shelter Creek Quarry. The
Applicant has agreed to mitigate for 41. 43.82 AC of the impacted wetlands (total
wetland impacts,
minus acreage of --functionally, low value" wetlands). Please see
Attachment 4 - Shelter Creek Quarry Wetland Summary Spreadsheet for acreage
calculations, including acreages for impacts to riparian and non-riparian wetlands.
With that said, for impacts proposed to take place within the first five years, the Applicant has
agreed to
At the
Croomsbridgc Road site, the Applicant's proposes to create/restore/enhance 41.78
AC of wetlands (see Attachment 1 - Cursory Wetland Determination and Proposed
Mitigation Map v.5). 7
In conjunction with the payment to the NCEEP and the creation/restoration/enhancement
activities, the Applicant also proposes to place the entire site into preservation. The Applicant
and SEGi feel the proposed mitigation plan is sufficient to offset temporal and permanent
impacts to wetlands and will result in no net loss of wetlands.
The proposed Success Criteria for wetland success will be based on the presence of the three
criteria described in the 1987 USACE Wetland Delineation Manual'. The mitigation site will
be deemed successful once it meets the three wetland parameters outlined in the manual and
as further described in below:
Vegetation
Vegetative data will be gathered including survival data of the planted specimens and
the presence of nuisance species. Species diversity and composition will be noted. For
success criteria to be met, we would expect a survival rate of 320-planted trees per
acre after 2 years, and 260 trees per acre after 5 years. No one species should account
for more than 20% of the composition. Any areas that do not meet these requirements
will be spot-planted.
Hydrology
Hydrologic monitoring within the site will consist of determining the water level at
various locations across the site to verify the presence of wetland hydrology during
the growing season. Monitoring wells will be installed to a depth of 20 inches and
will be sealed with sand and bentonite. These wells will take a daily reading of the
water table depth and this data will be processed into graphs and plotted against
National Weather Service rainfall data for the area. Success criteria of the hydrologic
parameter requires the site to exhibit one or more of the primary indicators; or two or
more, of the secondary indicators of hydrology as outlined in the 1987 Army Corps
of Engineers Wetlands Manual, for twelve percent of the growing season, under
normal conditions (e.g. normal rainfall, normal temperatures, etc..).
Soils
Soils will exhibit soil profiles typically found in wetlands.
A comprehensive mitigation plan will be submitted to the USACE for approval. Upon said
approval, implementation of the mitigation plan will begin. Note:
wetland impacts
will not take place until commencement of the mitigation project.
SEGi understands that our submittal and your acceptance of the enclosed information is all that remains to
complete the Individual Permit Application. Should I have forgotten anything or you deem additional
information is necessary, please feel free to email me at dlutheran(i)scgi.us or contact me at 910.452.2711.
As always, thank you for your continued time and assistance with this project.
Sincerely,
Dana A. Lutheran
Project Manager
Enclosures: Attachment 1 - Cursory Wetland Determination and Proposed Mitigation Map vt%5
Attachment 2 - NCEEP Mitigation Projects within Project HUC 03030007
Attachment 3 - Hofmann Forest Vicinity Map
Attachment 4 - Shelter Creek Quarry Wetland Summary Spreadsheet (2-17-11)
Attachment 5 - Milestone Wetland Impact Plan
Cc: Ms. Joanne Steenhuis - DWQ WiRO (Hand Delivery)
Mr. K-, _ - Client {U'
Mr. Stephen Rynas - DCM, CAMA Consistency Coordinator (Electronic Mail)
'US Army Corps of Engineers. Regulatory Guidance Letter, No. 02-02. Subject: Guidance on Compensatory Mitigation Projects
for Aquatic Resource Impacts under the Corps Regulatory Program Pursuant to Section 404 of the Clean Water Act and Section
10 of the Rivers and Harbors Act of 1899.