20091236 Ver 3_USACE Correspondence_20120130

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON NORTH CAROLINA 28403 1343
REPLY TO
ATTENTION OF
January 27 2012
Regulatory Division
Action ID No SAW 2009 02054
Mr Jon Vincent
Wilmington River Club LLC
1508 Military Cutoff Road Suite 302
Wilmington North Carolina 28403
Dear Mr Vincent
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WEnANDa AND STORIVIWATE BRANCH
This letter serves as our review of the November 23 2011 Lower Cape Fear Umbrella
Mitigation Bank Plan (Plan) submitted by your agent Land Management Group Inc (LMG) and
subsequently provided to the Local Interagency Review Team (IRT) by e mail The Plan details
the development of your proposed Lower Cape Fear Umbrella Mitigation Bank which consist of
two separate tracts (Wlute Springs and Sneeden) located in Brunswick County North Carolina
The below comments also incorporate earlier discussions points raised in the December 10 2009
IRT onsite meeting on both sites and our February 2 2009 letter with attached IRT members
responses to your initial proposal
The following items must be further addressed clarified and/or updated prior to final
approval of the Plan
1) Geographic Service Areas (GSA) Earlier written comments recommended that the
GSA be restricted to the lower half of the 8 Digit HUC or within the Middle Atlantic Coastal
Plain Based on more recent NC IRT discussions we agree to your proposal of the entire
03030005 Lower Cape Fear HUC However we do request the inclusion of a map depicting the
12 Digit HUCs within 03030005
2) NCWAM Please provide information showing where each assessment was taken and
include additional evidence that the Upper Mill Creek keys out as a Riverme Swamp Forest
3) Water Budget (White Springs Tract) Please submit a water budget to further
demonstrate the proposal s probability of meeting the established hydrology performance
standard Our office is concerned that the bisection of Highway 133 MOTSU entrance road, NC
Hwy 87, and the surrounding ditches are having a greater local drainage effect than realized
This is further complicated with some monitoring results on the adjacent 31 acre Brunswick
County Airport mitigation tract

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4) Northern Perimeter Ditch (White Springs Tract) Please provide additional
description/discussion on this ditch and its onsrte drainage influence /diversion of flow on your
proposal (associated with concern in #3 above) Drawings show the ditch at 5 feet and it
appears to have potential of capturing or intercepting any subsurface flow from the north
5) Zero order Stream (White Springs Tract) Our office agrees that the site is suitable for
this type of stream However, there are concerns of the length and width of the reach (1 380
linear feet long) and how it was determined Based on historic photos USGS and LIDAR it
appears that the drainage feature extends closer to or less than 1 000 linear feet and not at the
proposed starting location Additionally upon review of the design drawings it is difficult to
discern a distinctive valley that is 100 feet or more wide With the historic wetland complex
having been severed and manipulated we question whether the site can support the size (length
and width) of zero order stream that has been proposed Please clarify the position for this sized
feature Also this proposal as depicted in Figure 13A shows a 50 foot wide riparian wetland on
either side of the planned 100 foot wide valley In reference to the July 4 2007 Information
regarding Stream Restoration in the Outer Coastal Plain of North Carolina guidance it states
that stream credit may only be awarded where the discernible valley is a minimum of 100 feet
wide and that areas outside this corridor may be used as riparian wetland mitigation but only
within that valley feature This additional 3 3 acre riparian wetland restoration area doesn t
appear to be supported by the information in the mitigation plan
6) 31 -acre Brunswick County Airport Tract (White Springs Tract) It has been our
recommendation since your initial proposal that this adjoining tract which is being utilized for
airport compensatory mitigation be integrated into the long term management with your plans if
possible Contact should be made with airport officials to discuss this option and our office is
willing to participate in those discussions
7) Prescribed Burn (White Springs Tract) Expand on this discussion to the extent
possible by providing a description of how, who when and any precautionary measures such as
plowing to contain the fire This discussion should include any concrete long term plans for
subsequent fires if proposed
8) Preservation (Sneeden Tract) There is mention of some of the riverme swamp forest
being recently logged but no further details on where and how much For logged areas within
the proposed preservation boundaries the ratios will be adjusted to reflect the value of those
areas Include a description/discussion of the wetland complex along Cartwheel Branch
9) Map (Sneeden Tract) Provide a more detailed map of the restoration and enhancement
area for Mill Creek similar to that of Figure 13A & B for White Springs Tract
10) Stream Enhancement (Sneeden Tract) Provide additional information of how this
boundary was established Is this the extent of what is currently impounded and where there is
no flow in the stream? Is there any information on the condition of the stream within the

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impounded area9 Has it been channelized, and what efforts will be taken to prevent any head
cutting that may occur9 With the observed channelization of Mill Creek on the downstream side
of the culvert/dam, it is presumed that some channelization has occurred on the upstream side of
the culvert Please clarify
11) Appendix J of the Plan (Sneeden Tract) Provide a location map of the wells
12) Success Criteria (both tracts) For wetland restoration change the growing season for
each performance standard to reflect the growing season as defined in the Corps Regional
Supplement for Coastal Plain Region The success criteria will generally define the growing
season as Feb01 to Nov30 of each year (White Springs Tract) For hydrology the non riparian
pocosin community should be changed from 8% to 10% and the non riparian pine savanna
community changed from 6% to 7% (Sneeden Tract) State the vegetation and hydrology
success criteria for the causeway riparian wetland restoration area on page 23 The target
hydrology performance standard should be a minimum of 25% for riverme swamp forest
13) Monitoring Plan (both tracts) A complete monitoring plan will be finalized when all
of the above information is provided Please include that the annual monitoring report will be
submitted to our office prior to February 1 of each year
14) Ownership (both tracts) It has been noted that Tri County Properties LLC has been
changed to Wilmington River Club LLC Please be advised and unless directed otherwise that
our office considers you as the main principle of ownership and not the LLC
15) Survey Reverification (White Springs Tract) Please contact our office to discuss the
reverification of the survey
Please make these corrections to the mitigation plan and resubmit to our office for final
approval If you have any questions regarding the banking process moving forward with the
establishment of your proposal or the information requested above please do not hesitate to
contact me at the Wilmington Regulatory Field Office telephone [phone]
Sincerely
7�-
Mickey Su g Project Manager
Wilmington Regulatory Division

Copies Furnished
Mr Steve Sollod
Transportation Project Coordinator
Division of Coastal Management
1638 Mail Service Center
Raleigh, North Carolina 27699 1638
Mr Ron Sechler
National Marine Fisheries Service
Pivers Island
Beaufort North Carolina 28516
Mr Fritz Rohde
National Marine Fisheries Service
Pivers Island
Beaufort, North Carolina 28516
Mr Mike Wicker
U S Fish and Wildlife Service
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh North Carolina 27636 3726
Ms Becky Fox
U S Environmental Protection Agency
Region 4
1307 Firefly Road
Whittier North Carolina 28789
4
Ms Joanne Steenhuis
Division of Water Quality
North Carolina Department of
Environment and Natural Resources
127 Cardinal Drive Extension
Wilmington North Carolina 28405
Mr Ian McMillan
North Carolina Department of
/ Environment and Natural Resources
�/ Webscape Unit
1650 Mail Service Center
Raleigh North Carolina 27699 1650
Mr Eric Kulz
North Carolina Department of
Environment and Natural Resrouces
Webscape Unit
1650 Mail Service Center
Raleigh North Carolina 27699 1650
Ms Molly Ellwood
North Carolina Wildlife Resources
Commission
127 Cardinal Drive Extension
Wilmington North Carolina 28405
Ms Debra Wilson
Division of Coastal Management
North Carolina Department of
Environment and Natural Resources
127 Cardinal Drive Extension
Wilmington North Carolina 28405
Mr Christian Preziosi
Land Management Group Inc
Post Office Box 2522
Wilmington North Carolina 28402