20181442 Ver 1_SAW-2018-01883 Draft Mitigation Plan Comments_20210208

Strickland, Bev
From:
Jessop, Jordan E CIV USARMY CESAW (USA) <[e-mail]>
Sent:
Monday, February 8, 2021 2:05 PM
To:
Bradley Breslow
Cc:
Kim Browning; Tugwell, Todd J CIV USARMY CESAW (US); Davis, Erin B; Haywood,
Casey M CIV (USA); [e-mail]; Bowers, Todd; Dunn, Maria T.;
Wilson, Travis W.
Subject:
[External] SAW-2018-01883 Dugout Site Draft Mitigation Plan Comments
Attachments:
SAW-2018-01883 Dugout Stream and Wetland Site Draft Mit Plan Comments.pdf
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Good afternoon Brad,
Please find the attached Draft Mitigation Plan IRT comments. You may proceed with developing the final mitigation plan
for the Dudley Pond Mitigation Site provided you adequately address all comments/concerns in the enclosed
memo. Please ensure that each member of the IRT is provided a copy of the Final Mitigation Plan. In addition, please
submit your Nationwide Permit 27 application to this office for review and approval prior to discharging fill material into
waters of the United States.
Please let me know if you have any questions.
Best regards,
Jordan
Jordan Jessop
Wilmington Regulatory Field Office
U.S. Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403
[phone] (direct line)
[e-mail]
1

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
February 8, 2021
CESAW-RG/Jessop
MEMORANDUM FOR RECORD
Action ID: SAW-2018-01883 (RES Dugout Stream and Wetland Mitigation Site Cape Fear 05)
SUBJECT: Dugout Mitigation Site Draft Mitigation Plan IRT Comment Memo
NC Division of Water Resources Comments (Erin Davis):
1. DWR concurs that this site has the opportunity for substantial functional uplift. DWR
appreciates that this project includes a larger drainage area stream, tributa riesto their origin
points, floodplain wetland restoration/enhancement and only a single easement break. Within
the plan, DWR liked all of the tables, inclusion of NCSAM/NCWAM data, attentionto species
diversity and percent caps, all the woody material to be added to the system, and thoroughness
of the soil report.
2. Page 11, Section 3.3— Please expand on the future land use discussionto include potential
adjacent land use changes. Consultation with local/regional planning documents and/or
agencies is encouraged.
3. Page 13, Section 3.5— Please note the presence of beaver onsite. Does the presence of beaver
influence the site's functional uplift potential or long-term management approaches/narratives?
4. Page 28, ReachTV1-A (and Wetland WD) — Please include invasive treatment as a listed activity.
As mentioned during the December 2, 2020 sitevisit, DWR supports an understory/shrub live
whip planting activity with monitoring (not tied to standard performance requirements) for a
credit ratio adjustment.
5. Page 30, Sediment Transport Analysis — Should the third sentence reference piedmont or coastal
plain?
6. Page 32, Re-establishment—DWR appreciates the installationof baseline groundwater wells.
The date should be April 2020, correct?
7. Page 34, Section 6.4.1— With the recognition that red maple, sweetgum and pine are all native,
they can be considered temporally undesirable on mitigation sites if overcrowding and
outcompeting the planted stem species to limit community diversity. Is there a plan to thin
dense areas ofthese species during construction and/or monitoring?
8. Page 36, Soil Restoration— Please include a brief discussion of soil restoration for proposed
bench cuts along Reach GC4.
9. Page 40, Section 7 — Please clarify that surface flow and wetla nd hydroperiod a re a nnua I success
criteria.
10. Page 41, Section 8 — Please include a discussion of monitoring activities for TV1-C (e.g. photo
points, cross section) and TV1-A understory/shrub planting (e.g. species survival tracking).

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11. Page 44, Table 15 — Pleases pecifythe hydrope riod for "each" growing season. Also, please add
fence inspection to the last row.
12. Page 46, Section 10 — Please clarify when the project will be transferred to UP2S and when their
inspection responsibly begins. DWR recommends higher sign posts or PVC extensions be
considered along the easement boundary section that abuts row crop if corn will continue to be
in rotation.
13. DWR would welcome the inclusion on a Risks and Uncertainties section tot hem itigation plan
narrative. For example: What risks areas sociated with restoring a larger drainage area stream in
the coastal plain? Given the proximity to Fayetteville and surrounding residential land use, what
are the risks associated with future watershed development? Is there a risk of ditching outside
of the south easement boundary if the adjacent area continues to be logged? Is the adjacent
row crop area leased? If so, is that considered to be at a higher risk of encroachment? Does the
presence of beaver increase the riskof the long-term manager dealing with hydrologic trespass?
14. Figure 11— DWR requests the proposed wetland gauge in WG be relocated to west of TV1-B
near the proposed swale. DWR questions if the proposed swale will have a drainage effect on
the wetland reestablishment and enhancement areas along TV1-B and TV5-B.
15. Figures— For future mitigation plans, DWR would appreciate the inclusion of a LiDAR map.
16. Appendix A — Please confirm the acreage total in the UP2S table.
17. Appendix B —Please include the 2018 IRTsitewalk meeting minutes.
18. Appendix C— Please add a figure showing cross-section locations and clearly denote which
sections were used as the project reference sites.
19. Sheet S2 — Will the channel feature located northwest of the of the stream and ditch
intersection be filled or connected to project stream?
20. Sheet S3 — Will the channel feature ending at the easement boundary west of the existing
stream need to be stabilized?
21. Sheet S6 — As discussed during the December 2, 2020 site visit, DWR supports the replacement
of the proposed brush bed with a ford structure in the easement break. Iffeasible, DWR would
prefer this area be an internal stream crossing ratherthan external easement break.
22. Sheet D2— Channel Plug — DWR is concerned that a 30-ft minimum plug may not be sufficient. It
seems a minimum 50-ft to 100-ft plug is more typical in the coastal plain. Also, based on the soil
report findings of primarily permeable material onsite, the impervious select material for the
plug core may necessitate an offsite source.
23. Sheet D2— Channel Backfill — DWR recommends that partially -filled ditch/channel areas be
designed to seasonallydry. Areas of open waterwithin wetland credit areas without obligate
plants present during monitoring may be a concern.
24. Sheet D3— Hay Bale Toe —This treatment is not shown on the plans or included in the legend. If
proposed, please identify locations (DWR assumes it would only be proposed on TV1-B and TV5-
B). Also, please provide more information about this technique (including photos over time) and
situations/places it has been successfully implemented. Also, please provide adaptive
management strategiesfor dealing with potential bank instability issues in these proposed
treatment areas for this site. Is onsite brush toe material availability a consideration in its use?
25. Sheet D5— Please add a typical detail for the proposed log drop/cross vane shown at Station
52+00 on Sheet S9.

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U.S. Army Corps of Engineers Comments (Casey Haywood):
1. Section 3.5 Existing Stream Reach Conditions: Please mention the current presence of beaver on
site.
2. Section 3.5 Existing Stream Reach Conditions or 3.6 Existing Wetland Conditions: It was noted in
later sections that along livestock -adjacent project boundaries fencing would be installed, please
clarify in the narrative if and where cattle currently have access to any portion of the stream.
3. Section 6.2 Design Parameters Reach GC3- please provide more detail on the fill of the old
channel. Please explain what is meant by "partiallyfilled". In later sections it is mentioned this is
being done to provide flood control and habitat diversity. If vernal pools will be created the
depth should be between 8-14 inches to ensure they are seasonallydry.
4. Section 6.2 Design Parameters, ReachTVI-B-with this being a mix of offline and inline
restoration was the old channel being filled here also or was the offline only being done to
address the headcut? If the old channel is being filled, please include in the list of restoration
activities
5. Section 6.2 Design Parameters, Reach TV1-C-What methods (if any) will be used to spread flows
from TV1-13 to ensure channel formation and encourage a multithread system of TV1-C- is the
approach being used here passive restoration?
6. Section 7.1 Add performance standards forthe multithread reach TV1-Cthat will demonstrate
evidence of flow pattern and channel formation such as scour, sediment deposition, water
staining, formation of bed and bank, ordinary high-water mark etc.
7. Section 8 Monitoring Plan- Please include a fixed photo point on reachTV1-C
8. Appendix A: Acreage on the Unique Place to Save table does not match easement acreage.
Please verify.
9. Appreciated the tables in the report, information was useful and added clarification.
U.S. Army Corps of Engineers Comments (JordanJessop):
1. Please provide additional justification for the wetland enhancement credit ratios for wetland
WA.
a. How will you demonstrate enhancement? Can you demonstrate it does not normally
flood it its current condition? If necessary, please install gauges to document current
baseline data, and gauges post -construction to demonstrate hydrological improvement.
b. Please provide a performance standard for this area that demonstrates improved
hydrology.
2. Regarding the (mostly) backfilled stream- please provide an estimate of the areas and depths.
3. If necessary, please adjust the planting plan accordingly to reflect the differences in hydrology in
the partiallyfilled channel bed sections.
4. Section 7.2.1Wetland Hydrology Criteria- Ifthereis not an ecological justification for the
proposed 12% saturation threshold, please revise to 16%.

M
5. Please provide additional details on the current state of beaver activity on -site and proposed
management.
6. Please provide additional details on the understory invasive species management in the western
portion of the site, including any proposed understory planting, as discussed on -site.
7. Given the proximity to a residential neighborhood, and impacts we have seen on others ites,
concern exists that there will be future encroachments adjacent to the housing development
and we suggest fencing this area, or at the very least place additional easement signs for
increased visibility.
Digitally signed by
Jordan Jessop
Date:2021.02.08
13:51:42-05'00'