20200999 Ver 1_Draft-Prospectus Field Notes_20201123

Strickland, Bev
From: Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, November 23, 2020 7:32 AM
To: Tugwell, Todd J CIV USARMY CESAW (US); Kim Browning; Haywood, Casey M CIV
(USA); Davis, Erin B; Wilson, Travis W.; Bowers, Todd
Subject: [External] FW: [Non-DoD Source] Re: SAW-2020-00626 / Clearwater Mitigation
Solutions, LLC / Neuse 01 UMBI / Lowgrounds Wetland Mitigation Site / Draft -
Prospectus Field Notes
Attachments: 2020-11-20 Re UPDATED IRT Meeting Minutes to Sam Dailey Lowgrounds.pdf;
2020-11-20 Lowgrounds_ImpactLevel Map.pdf
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Happy Monday, Ya'll,
Please find some additional information/response to comments, along with a map that provides the level of
work that would be required (reference Kevin's email below). Please let me know if you have any questions.
Best Regards,
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]
-----Original Message -----
From: Kevin Yates <[e-mail]>
Sent: Friday, November 20, 2020 1:29 PM
To: Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>
Cc: Grant Lewis <[e-mail]>
Subject: [Non-DoD Source] Re: SAW-2020-00626 / Clearwater Mitigation Solutions, LLC / Neuse 01 UMBI /
Lowgrounds Wetland Mitigation Site / Draft -Prospectus Field Notes
Hey Sam,

Please see attached our response to the additional comments provided, along with the impact level map
referenced in our response to comments.
Let me know if you have any questions.
Thanks and have a great weekend,
KY
Kevin Yates
Clearwater Mitigation Solutions
919-624-6901
On Thu, Oct 1, 2020 at 10:20 AM Dailey, Samantha J CIV USARMY CESAW (USA)
<[e-mail] <mailto:[e-mail]> > wrote:
Greeting morning,
My apologies for the delay on getting these meeting minutes/field notes to everyone. On August 19,
2020, members of the IRT and Clearwater Mitigation Solutions, LLC conducted an on -site field visit. Attached
are the meeting minutes provided by Clearwater regarding the above referenced site. Clearwater captured
most of the discussion regarding the site; however, the USACE has a few additional comments to add and/or
reiterate:
1) The IRT request that you generate a map that demonstrates the level/depth of soil manipulation
required for the different types of "management areas", as referenced in your meeting minutes.
2) Given the level of manipulation in certain areas on -site it may be more appropriate for wetland
creation, rather than restoration, which may result in a lower ratio. It is also likely that the pond areas would
be considered creation as a result of the new soil composition that would be required. As referenced in your
meeting minutes, there was also discussion regarding a longer (10 year) monitoring period.
3) How will you be removing the irrigation system and gravel on -site?
Please let me know if you have any additional questions.
Best Regards,
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] <mailto:[e-mail]>

Legend
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Impact Level in Acres Area)
High 17.3 ac (32%)
Low 24.1 ac (45%)
Medium 12.0 ac (23%)
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CLEAR WATER MITIGATION SOL UTIONS 6
November 20, 2020 (Revisions to Original Dated 08121120)
MEETING MINUTES
LOWGROUNDS - IRT Site Visit
Corps Action ID: SAW-2020-00626
Site Visit Date: 08/19/2020
On August 19, 2020 the USACE, NCDWR, Axiom Environmental, and Clearwater Mitigation
convened, on -site, at 9:30am to review the Lowgrounds mitigation site, located at 2508 Devil's
Racetrack Road, Four Oaks, NC 27524. Below is a list of attendees and general site visit notes.
Attendees:
USACE
Sam Dailey
USACE
Todd Tugwell
NCDWR
Erin Davis
Clearwater
Kevin Yates
Axiom
Grant Lewis
Site Visit Notes:
1) The Site has been and currently continues an operating plant nursery. USACE
representatives expressed concern about intensive manipulations at the Site including
roads, concrete pads, gravel fill, bedding for landscape pads, excavation of ponds, and
other infrastructure associated with the nursery. Ultimately it was decided to map the
Site as three management categories including the following.
a. Intensive management — roads, ponds, concrete pads, gravel pads greater than 12
inches in depth, and/or other areas with greater than 12 inches of cut/fill.
b. Moderate management — gravel pads/landscape pads with less than 12 inches of
cut/fill or other areas that have been managed but may retain soil structure that is
relatively intact.
c. Low management — areas of open grass or forest that exhibit a low risk of
mitigation success.
The IRT will assess proposed credit ratios on these areas once a percentage of the Site with each
management category has been determined.
2) Areas of intense/moderate management may still receive better credit ratios if an
alternative monitoring period is proposed. It was discussed that a 10-year monitoring
period may be proposed that will provide the IRT with assurance that vegetative success
will be met. The 10 year monitoring period can have a 7-year success period if the
vegetative community is thriving; however, an additional two years of monitoring (Years
9 and 10) may occur if the IRT deems it necessary.
3) Clearwater Mitigation indicated the easement may be pared down to remove some
intensively managed areas if that is favorable by the IRT.
4) A portion of the Site that is characterized by mature loblolly pines may be cleared of trees
to minimize the seed source for proposed plant communities.
Clearwater Mitigation Solutions
604 Macon Place
Raleigh, NC 27609
919-624-6901
[e-mail]

CLEAR WATER MITIGATION SOLUTIONS ® Cool Run IRT Meeting Minutes
Revisions provided by Clearwater on November 20, 2020
Below are responses to additional comments provided by Ms. Sam Dailey on October 1, 2020:
Comment 1) The IRT request that you generate a map that demonstrates the level/depth of soil
manipulation required for the different types of "management areas'; as referenced in your
meeting minutes.
Re: Please see attached map delineating three levels of impacts relative to the depth of
associated fill, infrastructure, and existing conditions. The highest level of impacts were
considered to be within the pond bottoms, infrastructure with concrete pads, within gravel
driveways and raised beds with fill depths of approximately 8-12". The measured 12" of fill
within the plant beds, aligns with estimates of fill depths given by the nursery operator. The
total estimated area for the highest level of impact is 17.3-acres. The medium level of
impact was considered to be mostly raised plant beds with 2-8" of fill, and totals 12.0-acres.
The lowest level of impact was considered to be areas at close to natural grade elevation,
with scattered areas with 1-2" of fill or surface alteration, and consists of 24.1-acres
Mitigation ratios proposed for the high, medium, and low impact levels are 3:1, 1.5:1, and
1:1, respectively. A summary of wetland mitigation units (WMU's) using proposed ratios is
summarized in Table 1, below.
Table 1: Wetland Mitgation Summary
Wetland Mitigation Type
Impact Level
Acreage
Mitigation Ratio
riparian WMU
Riparian Reestablishment
High
13.05
3:1
4.35
Riparian Reestablishment
Medium
8.13
1.5:1
5.42
Riparian Reestablishment
Low
21.18
1:1
21.18
Totals
42.36 acres
30.95 WMUs
Wetland Mitigation Type
Impact Level
Acreage
Mitigation Ratio
riparian WMU
Non -Riparian Reestablishment
High
4.25
3:1
1.41
Non -Riparian Reestablishment
Medium
3.87
1.5:1
2.58
Non -Riparian Reestablishment
Low
2.92
1:1
2.92
Totals
11.04 acres
6.91 WMUs
Comment 2) Given the level of manipulation in certain areas on -site it may be more appropriate
for wetland creation, rather than restoration, which may result in a lower ratio. It is also likely
that the pond areas would be considered creation as a result of the new soil composition that
would be required. As referenced in your meeting minutes, there was also discussion regarding a
longer (10 year) monitoring period.
Clearwater Mitigation Solutions Page 3
604 Macon Pl.
Raleigh, NC 27609
919-624-6901

CLEAR WATER MITIGATION SOLUTIONS ® Cool Run IRT Meeting Minutes
Re: The pond areas haven been categorized as highly impacted areas, with a lesser valued
credit ratio of 3:1. Clearwater is willing to extend the monitoring period to 10-years in some
of the higher impacted areas, if practical. However, given the reduced credit ratios in these
areas, and the amount of work required, the higher impacted areas may be excluded from the
conservation easement and/or non-credit generating areas within the easement.
Comment 3) How will you be removing the irrigation system and gravel on -site?
Re: Clearwater met with an experienced grading contractor, Brady Johnson of Baxter
Johnson, onsite at the nursery, on November 11, 2020. Mr. Johnson assessed the gravel on -
site and explained that he would be able to remove and stockpile the gravel using a motor
grader. The gravel and soil would then be screened out using a trommel, and suitable topsoil
would be set aside and placed back in areas where the gravel was removed.
It is anticipated that the irrigation system would also be removed and decommissioned
during the gravel removal process. In speaking with the nursery operator, the irrigation
system is composed of pvc piping just below the surface.
Clearwater Mitigation Solutions Page 3
604 Macon Pl.
Raleigh, NC 27609
919-624-6901