20110896 Ver 1_More Info Received_20120424

Strickland, Bev
From: Mcmillan, Ian
Sent: Tuesday, April 24, 2012 10:17 AM
To: Strickland, Bev; Dennison, Laurie
Subject: FW: Orton Plantation Additional Info -- PLEASE COMMENT (UNCLASSIFIED)
Attachments: Avoidance & Minimization Proposal.DOC; Orton Plantation—Exclusion Areas - Exclusion Area
(2).pdf; Alternatives Analysis (5).DOC
DWQ No. 11 -0896
Ian J. McMillan, PWS, GISP
NCDENR/DiVision of Water Quality - Wetlands and Stormwater Branch
1650 Mail Service Center
Raleigh, NC 27699 -1650
Office: (919) 807 -6364
Fax: [phone]
Email: ian.mcmillan cincdenr.goi-
E -mail correspondence to and from this address may be subject to the North Carolina Public Records La-w and may be disclosed
to third parties.
- - - -- Original Message---- -
From: Dorney, John R [mailto: John. Dornev;a atkinsalobal. com]
Sent: Tuesday, April 24, 2012 8:52 AM
To: Mcmillan, Ian, Coburn, Chad
Subject: FW: Orton Plantation Additional Info -- PLEASE COMMENT (UNCLASSIFIED)
Just to be sure that you and Chad got this. Thank
- - - -- Original Message---- -
From: Hughes, Emily B SAW [mailto: Emile. B. Hughes ;a usace.army.mill
Sent: Monday, April 23, 2012 9:52 AM
To: 'Mcmillan, Ian', 'Coburn, Chad', 'Coats, Heather', 'Wilson, Debra', 'John — Ellis lcif- s.gov' 'Ellwood, Molly M.', smtp-
Sechler, Ron, 'Gledhill- earley, Renee', 'Jennifer Derby'; 'Jeffrey Garnett', chris.southerly <r ncdenr.goi
dai-id.cos ,-incvv- ildlife.org, pete benjamina'fvws.goN, ernon.cosa'mcaar.Qoi
Cc: Jolly, Samuel K SAW, McLendon, Scott C SAW, Beter, Dale E SAW, McCorcle, Justin P SAW, Frye, Jennifer S SAW,
Peter Talty cbrombv a'1mnton.com, Steve Morrison, Dorney, John R, mark.ncbrearity cc blla.com, Kim Williams, Christian
Preziosi
Subject: Orton Plantation Additional Info -- PLEASE COMMENT (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
All,
We -want to offer everyone -who attended the March 28 meeting the opportunity to read and comment on the most recent
submittal of information prodded by the Orton Team. The three documents attached, revised Avoidance and Minimization
Proposal, corresponding Exclusion Area Map and Alternatives Analysis, -were in response to the request for additional
information by several agencies at the meeting. The latest revised project plans indicate approximately 13.1 acres of reduced
,,v-etland impacts in the back rice fields. No revised compensatory mitigation plan has been submitted.
Please read over the documents thoroughly and respond -with comments by May 4, 2012. We would like to stress that your
involvement in this decision is Very important and your comments will be taken into full consideration. Please feel free to
contact myself or Dale Beter (910) 251 -4631 if you have any questions.
Thank you,

Emily
U.S. Arm-,- Corps of Engineers
Wilmington Regulatory Field Office
69 Darlington Avenue
Wilmington, North Carolina 28403
Office: (910) 251 -4635
Fax: [phone]
The Wilmington District is committed to prodding the highest level of support to the public. To help us ensure" e continue to
do so, please complete the Customer Satisfaction Survey at http: // pert. m-,- p.usace.arm -,- .mil /suri-e -,-.html
Classification: UNCLASSIFIED
Caveats: NONE
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ALTERNATIVES ANALYSIS
The stated purpose of the project is to protect and restore the various elements of the
historic rice field system at Orton Plantation. The following alternatives have been
considered by the Applicant:
A. No Action Alternative: Under this alternative, no dike improvements would be
made, no water control strictures would be replaced and no rice field preparation would
take place resulting in the continued deterioration and ultimate failure of the historic
dikes and water management system. Failure of the dikes and water control strictures
would render rice cultivation operations impossible. For those fields where the dikes
resisted erosional forces for a longer time, Phragmites infestations would increase,
dramatically reducing the habitat value of the fields. This site has been in rice cultivation
for the overwhelming majority of its history since the early 1700s. The loss of this
historic farming resource would be historically and culturally significant. Because this
alternative does not meet the Applicant's stated purpose and need, and because it would
result in the degradation or loss of a significant historic and cultural resource it has been
removed from further consideration.
B. Upland Alternative: Under this alternative, rice cultivation would take place in
upland areas at Orton Plantation. This alternative is not practicable due to the nature of
the historic and traditional cultivation practices to implement and manage the growth of
rice crops. The water management system is gravity -fed in a low elevation landscape.
The management of water is required for purposes of seed germination and the
elimination and prevention of competitive weed establishment. The hydrologic control
measures and devices remain positioned within areas that are wetlands due to their
landscape position, long -term soil saturation and periodic flooding. Resorting to an
upland alternative is essentially equivalent to the no action alternative in terms of the loss
or degradation of a significant historic and cultural resource. Rice cultivation in such
areas does not achieve the Applicant's stated purpose and need.
C. Rehabilitation of Rice Fields on Orton and Kendall Plantations: Historically, the
plantation operated as two groups of rice fields fed by two separate reserves. The Orton
Reserve (also known as Orton Pond) supplied fresh water to the five remaining rice fields
comprising the Orton Plantation and the Kendall Reserve supplied fresh water to the rice
fields north of Orton and south of Lilliput Creek. The dam impounding the Kendall
Reserve failed in the mid- twentieth century. The diked rice fields of the Kendall
Plantation were thereafter without a dependable source of fresh water. As a result, the
dikes around the Kendall Plantation rice fields ceased to be maintained and deteriorated
to the point that the rice fields returned to coastal marsh habitat. It is the Applicant's
understanding that prior owners of Orton Plantation previously sought to permit the
rehabilitation of portions of these rice fields, but withdrew their application when the
application met with agency resistance.
While this alternative would more completely satisfy the project purpose, it is not
believed to be the least environmentally damaging, practicable alternative (LEDPA).

Implementation of this alternative would require substantial structural improvements to
the Kendall Reserve Dam and, essentially, reconstruction of dikes involving the
placement of a significant amount of fill material around former rice fields. This
alternative would have a significant impact on coastal wetlands that have largely reverted
to a natural and high functioning condition. As a result, it has been eliminated from
further consideration.
D. Rehabilitation of the Rice Fields, Excluding Some of the Fields: The exclusion of
intact rice fields from the project has the benefit of reducing the amount of activity in the
wetlands within the excluded rice fields and partially satisfies the project purpose. In
those rice fields which are rehabilitated, the reintroduction of rice cultivation will result
in control of Phragmites. Wetlands within the rehabilitated rice fields will, with limited
exceptions, not lose overall wetland value, and will actually provide habitat value as good
or better than the habitat value presently offered by the rice fields. However, exclusion
of any rice fields will not achieve the project purpose. Reestablishing the historic extent
of the Orton Plantation Rice Fields supplied by the intact and functioning freshwater
Orton Reserve (Orton Pond) would necessarily include not only the two Front Rice
Fields, but Rice Field 41, Rice Field 49, and the Back Rice Fields. These fields are all
part of the same system that has been maintained over the last 287 years. The practicable
extent of historic rehabilitation includes all the fields of this system. Limitation of
rehabilitation efforts to only certain of the rice fields sacrifices the historical context of
the rice fields, impairs to a significant degree the historical visual landscape, reduces or
eliminates the value of the rice fields for crop rotation, diminishes the research value and
the ability to isolate rice varieties being researched, and relegates a unique historical
resource to a degraded "ruin."
1. Rehabilition Limited to Front Rice Fields: Rehabilitation of only the Front
Rice Fields would significantly reduce the historic value and impair the
functionality of the Orton Plantation rice field system and thus is not a feasible
alternative for satisfying the project purpose. By excluding the other system rice
fields, the extent of the historic visual landscape restoration would be limited in
nature. All fields not restored would continue to experience a dominating
Phragmites infestation, fi rther reinforcing an overall "Low " -value wetland
condition without the enhancement of a significant foraging food source for
waterbirds. This alternative minimizes the opportunity for agricultural research
and rice variety separation. Beneficial crop rotation combinations would be
limited as well. The Front Rice Fields are also most susceptible to damage in
hurricanes and severe storm events, thus putting at risk the potential "seed bank"
value.
2. Rehabilitation Limited to the Front Rice Fields and #1 Rice Field: While
another field is added to rice cultivation over the previous alternative, a similar
list of reasons exists as to why this alternative fails to achieve the Applicant's
stated project purpose. This alternative expands the number of fields in
production relating to variety separation, research potential, adding a more storm-

protected, Phragmites- controlled field with a partially expanded restored visual
landscape. The reasons to dismiss this alternative are that it does not achieve the
stated purpose of protecting and restoring the various elements of the historic rice
field system at Orton Plantation, continue to include the dismissal of entire rice
fields from the intact and functioning system maintained for centuries, the
limitation of historic visual landscape restoration, Phragmites infestation with lost
benefits to waterbird foraging, continued limitations to crop rotation
combinations, research and variety separation.
3. Rehabilitation Limited to the Front Rice Fields, #1 Rice Field and #9 Rice
Field: This alternative restores all of the rice fields except the Back Rice Field.
In addition to the preceding alternative discussion, which certainly applies, the
specific exclusion of the Back Rice Field from cultivation ignores that field's
essential fuunction as the "junction box" for the distribution of reserve - source
water to irrigate all of the surrounding fields. Different portions of the Back Rice
Field must be level and maintained in such a condition to assure the efficient
operation of the water management system by gravity flow of water to the other
fields. Water flowing to the 41 and 49 Rice Fields feeds directly from Back Rice
Field irrigation canals along the existing causeway. This necessitates the
continued and periodic maintenance of the canal system with excavated material
sidecast upon the field surface. Water flowing to the Front Rice Fields must flow
over the surface of the southeastern Back Rice Field where there are no large
irrigation canals. This requires maintaining a very level surface for overland
flooding to the east. The nature of the maintenance would be leveling the surface
to an appropriate grade and removing blockages as they develop over time,
including vegetation which interferes with the even flow of water, thus impairing
efficiency of operation of the water management system. The Back Rice Field is
also unique to the overall plantation in that it is believed to be the original rice
field following the creation of the Orton Reserve (Orton Pond). It is thought that
the Back Rice Field served as a testing ground for the overall larger plantation
system. This adds supplemental historical value to this field's restoration making
it not only part of the last remaining intact rice field system in North Carolina, but
perhaps the oldest rice field in the state. Therefore, exclusion of the Back Rice
Field fails to achieve the stated project purpose.
4. Rehabilitation Limited to the Back Rice Field: This alternative would restore
perhaps the oldest rice field within the Plantation, and probably within the State of
North Carolina, to rice cultivation. The discussed points within above
alternatives D.2 and D.3 remain relevant in varying degrees to this alternative.
The central recurring issue remains that the exclusion of any individual rice field
eliminates the opportunity to reap the historical and agricultural benefits of
rehabilitating the entire historic rice field system. This alternative excludes all of
the other rice fields. The significance of preserving a fiunctioning, intact system of
rice fields for its value culturally and agriculturally is truly unique within North
Carolina. The Back Rice Field is the critical component of the water management

system and the water management system itself would be superfluous without the
downstream rice fields. The downstream rice fields (significant historic
resources) would be relegated to "ruin." This alternative fails to achieve the
stated project purpose.
E. Rehabilitation of the Intact Orton Plantation System of Rice Fields (Applicant's
Preferred Alternative): As described, the preferred project is the least damaging,
practicable alternative that still meets the Applicant's purpose and need. The extent of
the proposed project area has been defined by identifying the limits of the functioning
water control system and dike system associated with Orton Reserve (Orton Pond). The
Applicant is proposing to protect and rehabilitate only those remaining rice fields that
have been maintained since the onset of environmental regulation. Unlike the effort
required to rehabilitate the rice fields of the Kendall Reserve System, rehabilitation of the
Orton Reserve rice fields is a practicable alternative to achieve the project purpose and is
consistent with conservation efforts of the owner. The preferred alternative also
represents minimal disturbance to freshwater wetlands that have been impounded for 287
years. The long -term and severe hydrologic modification to Orton rice fields has resulted
in documented functional degradation of the wetlands impounded within the rice fields
(refer to NCWAM discussion submitted earlier). Therefore, functional impact to
wetlands associated with implementation of the preferred alternative is negligible.
As a result of discussions with commenting agencies, the Applicant has submitted an
Avoidance and Minimization Proposal which addresses requests for habitat
diversification, and the avoidance of a "medium " - valued portion of the 49 Rice Field (per
NC WAM) as well as restoration and preservation of the historic visual landscape.
Operational farming efficiencies were also taken into consideration. The resulting
minimization of farmed wetland area in the 49 Rice Field and the Back Rice Field, based
on these parameters, serves to provide requested wildlife benefits from increased habitat
diversity and reduce the temporary wetland impacts associated with farming activities
while preserving the intact system of historic rice fields.
78308.000002 ENIF US 398624210

AVOIDANCE AND MINIMIZATION PROPOSAL
ORTON PLANTATION
U.S. ARMY CORPS OF ENGINEERS ACTION ID 4 SAW -2011 -00624
,Subn fitted April 11, 2012
Introduction
In response to agency comments received at the interagency meeting on March 28, 2012, Orton
Plantation Holdings LLC ( "Applicant ") proposes the following modifications to address those
comments and fi rther avoid and minimize impacts to waters of the United States. The
modifications consist of areas within the historic rice fields which Applicant proposes to exclude
from cultivation ( "Rice Field Exclusion Areas "). No activities required to be permitted under
Section 404 would be undertaken in the Rice Field Exclusion Areas which total 13.1 acres in
four separate areas.
Rice Field Exclusion Area Selection Criteria
The Rice Field Exclusion Areas were selected based on satisfying several of the following
criteria:
• Wetland fiunctional value based the NC Wetlands Assessment Methodology ( "NC WAM ");
• Wildlife habitat value enhancement provided by a mid- canopy or shrub -scrub transitional
zone (ecotone) between the wildlife habitat provided by forested canopy outside or on the
fringe of the rice fields and the wildlife habitat provided in the areas of rice cultivation;
• The degree of disturbance of, or intrusion into, the visual landscape component of the historic
value of the historic rice plantation;
• The degree to which cultivation of rice in a proposed Rice Field Exclusion Area would be
operationally inefficient using modern agricultural practices; and
• The degree of importance of an area of the rice field to the efficient fiunctioning of the water
management system.
Wetland Functional L`ahte
The overwhelming majority of the rice fields were rated as overall Low fiunctional value, due in
large part to the fact that the hydrology of the rice fields has been intensively manipulated since
the early 18th century. Additionally, because of the intensive hydrologic manipulation and
elimination of normal sediment transport from the Orton Reserve through these wetlands to the
coastal marsh or the Cape Fear River, the soils inside the rice fields have, particularly in the back
rice fields, taken on unusual characteristics, essentially transformed into floating mats of highly
organic material over a mineral substrate. In addition, this floating mat moves up and down

depending on the amount of water introduced or removed from the rice fields. Consequently,
these soils are generally not physically capable of supporting trees which would form a mature,
closed canopy typical of a forested riverine swamp. In essence, the rice fields are wetlands, but
they are not forested and are mostly incapable of becoming mature forested wetlands due to their
highly unstable substrate.
There is an area at the western extremity of, Rice Field 49 which has a watershed independent of,
and supplemental to, the water management system, such that the hydrology of this area is not
entirely dependent on the manipulation of the water management system. Consequently, this
area was rated overall Medium functional value using NC WAM. Because the resumption of
rice cultivation in this area would degrade the overall functional value as measured by NC WAM
from Medium to Low, this areas has been designated as a Rice Field Exclusion Area.
Wildlife Habitat Vahte Enhancement
Presently, there are a number of types of wildlife habitat provided within, and along the fringes
of, the rice fields. In some areas along the fringes of the historic field a forested canopy of
mature trees can be found Other areas of the rice fields have been allowed through disuse or
mismanagement over the years to grow into a shrub -scrub habitat. Additionally, large areas of
the rice fields have suffered infestation by Phragmites anstralis, a noxious weed.
Each of these vegetation assemblages provide habitat of greater or lesser value and diversity. In
general, soil conditions in the rice fields provide poor substrate for trees to form a mature, closed
canopy, and thus the habitat values provided by such a canopy are essentially absent in the
interior of the rice fields. However, a mature hardwood canopy exists in some locations at the
fringes and outside of the rice fields, providing significant habitat value for species favoring
those conditions. A cultivated rice field, along with rotational crop coverage, also provides
valuable habitat and feeding for waterbirds, a diverse array of amphibians, and other wildlife, as
described in the annotated bibliography submitted earlier.
The shrub -scrub condition that covered much of the back fields also has value for habitat for an
array of species distinguishable from either a mature forested canopy or a cultivated rice field.
Based on NC WAM analyses, the fuunctional value of the wetland in the back rice fields has
similar value in a shrub -scrub condition to that in a rice field condition. However, there is value
in the successional or transitional habitat provided between mature forested canopy and the
cultivated rice field by shrub -scrub habitat. Therefore, some Rice Field Exclusion Areas were
evaluated as to successional habitat values that could be provided if these areas were left in a
shrub -scrub condition, adjacent to mature forested canopy and cultivated rice field.
Visual Landscape
A significant component of, and contributor to, the historic uniqueness and value of Orton
Plantation is the visual landscape provided by the remaining, intact rice fields once they are
returned to rice cultivation. Protection of the visual landscape can be accomplished by
maintaining and cultivating rice in the intact rice fields in their entirety. The visual landscape
could be significantly impaired by taking substantial portions of the intact rice fields out of the
plans for cultivation, essentially severing those portions of the fields from the plantation.
2

Nowhere else in North Carolina, and in few, or perhaps no, places in the United States, has a rice
plantation dating back to the early 18th century been so well preserved, where a significant
portion of diked fields and the water management system designed and constricted by enslaved
West African craftsmen has been continuously maintained and operated. As a result of this
continuous maintenance and preservation, the plantation can be, and is proposed to be, returned
to a close approximation of its appearance and function from the important historic period of rice
culture in the 18th and 19th centuries. Moreover the project is proposed exclusively using private
sources of funding, which makes it singularly unique.
The historical importance of the Orton Plantation project is magnified by the adjacent state -
owned Brunswick Town historic site, which includes ruins of St. Philip's Church, Fort
Anderson, and Russellborough, the former colonial governor's mansion. The history of
Brunswick Town and Orton Plantation are inextricably linked (Brunswick Town was founded by
the original owner of Orton Plantation), and the opportunity to re- establish the appearance of the
plantation, in connection with the preservation of the Brunswick Town ruins, is unique in the
United States. This opportunity is especially valuable since Orton Plantation was never degraded
to ruins.
Given the unique value of the visual landscape component of the historical value of Orton
Plantation rice fields, Rice Field Exclusion Areas were evaluated based on the degree to which
they would intrude on the visual landscape provided by the rice fields. Attention was paid to the
visual isolation of the areas excluded, either by distance from readily accessible view locations
or by proximity or adjacency to intervening forested areas.
OpE'1 "ptlOYlp% EfflciencV
The principal purpose of the project for which a permit is required under Section 404 of the
Clean Water Act involves the resumption of rice cultivation in the remaining intact rice fields at
Orton Plantation. However, modern agricultural methods and practices will be employed, even
though heirloom varieties of rice will be grown. Traditional utilization of hand labor and farm
animals did not emphasize efficiency to the same degree as modern agriculture practices.
Certain areas within the Back Rice Field, in particular, pose operational challenges in terms of
maneuvering equipment because the area is limited spatially in terms of its configuration, or
would require a canal or ditch crossing. In such areas, the value and efficiency of rice
production was critically evaluated against the consequent impact to waters if such areas were
put into production.
However, some otherwise oddly configured or spatially limited areas were found to have
significant importance to the efficient operation of the water management system. In these areas,
which might otherwise be challenging for access and maneuverability of equipment, the efficient
functioning of water management and distribution system in an area with limited topographic
increments, depends on maintaining a level surface, which, in turn, requires some disturbance
and redistribution of the soil surface. Thus, areas which might satisfy the "operational
efficiency" criterion with respect to limitations on access or maneuverability of agricultural
equipment were not excluded based on the supervening need to manipulate the soil surface for
the purpose of optimizing efficiency of a water management system with very low tolerances.

Proposed Rice Field Exclusion Areas
The areas indicated on the attached aerial photograph (referred to hereinafter as "Rice Field
Exclusion Areas ") are proposed to be withheld from rice cultivation. No activities required to be
permitted under Section 404 of the Clean Water Act will be undertaken on the Rice Field
Exclusion Areas. The total acreage of avoidance of impact represented by the Rice Field
Exclusion Areas is 13.1 acres. No avoidance is proposed in the Front Rice Fields or in Rice
Field #1. One reason is for this determination is that almost the entirety of the Front Rice Fields,
and a significant portion of Rice Field 41, are infested by Phragmites australis. The elimination
of Phragmites in the process of putting the fields into a rice crop constitutes a significant positive
contribution to wildlife habitat values, as it provides, at the very least, a more valuable food
source for wildlife.' The overall plan for each of the exclusion areas will be to maintain them in
a shrub -scrub condition, thereby adding habitat diversity to this landscape, and further
enhancement of wetland value and function.
Rice Field Exclusion Area A
Rice Field Exclusion Area A is 3.8 acres in size and adjoins Rice Field 49 to the west. It was
selected as the only wetland area located within the intact rice fields which was rated overall
Medium value, using NCWAM. In designating Rice Field Exclusion Area A, Applicant has
avoided a wetland area within the rice fields which, according to NCWAM analysis, has a higher
degree of wetland values, and an area which would change to an overall Low value rating if it
was to be put into cultivation. Rice Field Exclusion Area A is the only wetland area within the
intact rice fields that has a relatively undisturbed and intact watershed separate from the water
management system which has been in place since the 18th century. Notwithstanding, the
hydrology of Rice Field Exclusion Area A is, and will continue to be, heavily influenced by the
operation of the water management system, since none of the Rice Field Exclusion Areas are
(nor cannot be, without installation of additional strictures), hydrologically isolated from the rice
fields.
Rice Field Exclusion Area A will remain, and will be maintained, in shrub -scrub vegetation
providing productive wildlife habitat distinct and complementary to the habitat values provided
by the adjacent mature forest canopy to the north, west and south and the cultivated rice field
adjoining to the east. The habitat value of Rice Field Exclusion Area A may be distinct from
other areas because it is hydrologically unique within the intact rice fields in that it receives
hydrologic contribution from a relatively undisturbed and intact watershed to its west and north.
I Infestation by Phragmites australis has been detected in Rice Field 49 and in the Back
Rice Field, , though to a less significant degree than in the Front Rice Fields or Rice Field 41.
However, domination by Phragmites australis will inevitably occur in all rice fields unless the
weed is actively and vigorously controlled. Failure to obtain permits, and, thus, the inability to
put the fields in rice production, would result in full or partial abandonment of efforts to control
Phragmites australis, and the resultant loss of significant wetland functions and values in all rice
fields.
4

Additionally, Rice Field Exclusion Area A is somewhat visually isolated from the remainder of
Rice Field 49 given its landscape position as its western extremity, and the farthest point from
the portion of the entrance causeway adjacent to and traversing the back rice fields.
Rice Field Exclusion Area B
Rice Field Exclusion Area B is 1.1 acres in size and adjoins the Back Rice Field at its northwest
corner. Unlike Rice Field Exclusion Area A, it is entirely hydrologically managed by the rice
field water management system, and is rated overall Low value by NC WAM. However, the
landscape position of Rice Field Exclusion Area B, on the edge of accessible sight lines from the
entrance causeway adjacent to and traversing the back rice fields, provides a degree of visual
isolation.
Additionally, Rice Field Exclusion Area B is bounded on the south and east by an irrigation
canal of considerable size which operationally isolates the area from the remainder of the Back
Rice Field. Given the relatively modest size of Rice Field Exclusion Area B, it would be
inefficient to conduct agricultural activities here, particularly since equipment crossings would
be necessary to conveniently provide access to agricultural machinery.
Finally, because the adjoining area outside the Back Rice Field to the northwest represents a
mature forested fringe, maintaining Rice Field Exclusion Area B in shrub -scrub vegetation will
provide productive habitat distinct and complementary to the habitat values provided by the
adjacent forested area to the west and north and the cultivated rice field adjoining to the south
and east.
Rice Field Exclusion Area C
Rice Field Exclusion Area C is 4.5 acres in size and adjoins the Back Rice Field on the eastern
edge of its northeastern corner. Its hydrology is totally managed by the rice field water
management system, and it is rated overall Low value by NC WAM. The landscape position of
Rice Field Exclusion Area C on the edge of accessible sight lines from the entrance causeway
adjacent to and traversing the back rice fields, and bordered by mature forest to the east, provides
a degree of visual isolation.
Rice Field Exclusion Area C is separated from the entrance causeway at the junction between the
Back Rice Field and Rice Field 41 because that intervening area must be level and managed to
maintain the efficiency of the water management system. In particular, the intervening area must
remain susceptible to management to facilitate the release of water out of the Back Rice Field to
the coastal marsh and the transit of water from the Back Rice Field to Rice Field 41.
Additionally, Rice Field Exclusion Area C is bounded on the west and south by a major
irrigation canal which imposes a degree of operational isolation from the remainder of the Back
Rice Field. While the size of Rice Field Exclusion Area C makes it the largest of the Rice Field
Exclusion Areas, the nature and size of the bordering irrigation canals would require the
installation of crossings that would fi rther impact waters of the United States, counterbalancing
its size from the perspective of agriculture operational efficiency.

Maintaining Rice Field Exclusion Area C in shrub -scrub vegetation will provide productive
habitat distinct and complementary to the habitat values provided by the adjacent forested area to
the east and the cultivated rice field adjoining to the south and west.
Finally, Rice Field Exclusion Area C provides the additional benefit of providing a degree of
buffer between the agricultural operations in the Back Rice Field and the cemetery located to the
southwest of the plantation office, mitigating to a degree the potential reduction in historic value
resulting from the incursion into the visual landscape.
Rice Field Exclusion Area D
Rice Field Exclusion Area D is 3.7 acres in size and adjoins the Back Rice Field to the west
along the lower southwestern quadrant of the Back Rice Field, to the southwest of the upland
"island." Unlike Rice Field Exclusion Area A, the supplemental watershed contributing water to
Rice Field Exclusion Area D has undergone a degree of disturbance and reduction, dating back
to the initial constriction of the water management system at Orton Pond Reserve and adjacent
rice fields in the 18th century. As with Rice Field Exclusion Area A, Rice Field Exclusion Area
D is, and will continue to be, heavily influenced by the operation of the rice plantation water
management system, since none of the Rice Field Exclusion Areas are (nor cannot be without
installation of additional strictures), hydrologically isolated from the remaining rice fields.
The landscape position of Rice Field Exclusion Area D to the southwest of the upland "island" in
the Back Rice Field visually isolates it from the entrance causeway and the readily accessible
points on the eastern edge of the Back Rice Field near the Plantation House and the plantation
office.
Maintaining Rice Field Exclusion Area D in shrub -scrub vegetation will provide productive
wildlife habitat distinct and complementary to the habitat values provided by the deep and
adjacent forested area surrounding Rice Field Exclusion Area D on three sides to the north, west
and south, and the wildlife habitat values provided by the cultivated rice fields to the east.
Comparable to Rice Field Exclusion Area C, Rice Field Exclusion Area D is of sufficient size
and configuration for efficient agricultural operation, but unlike Rice Field Exclusion Area C,
there is no irrigation canal that would impede access by agricultural equipment or otherwise
operationally isolate Rice Field Exclusion Area D. However, Applicant has determined that the
high degree of visual isolation and value for wildlife habitat enhancement in the most remote
location within the rice field system makes it an appropriate candidate for exclusion.
6
78308.000002 ENIF US 39708042\-7