20060180 Ver 3_Staff Comments_20111024

D�i V0
Mcmillan, Ian
From Kulz Eric
Sent Monday October 24 2011 8 27 AM
To Tugwell Todd SAW
Cc Homewood Sue Mcmillan Ian
Subject Buffer Width Stream Credit Document
Todd
Sue Homewood in our WS Regional Office and I are reviewing mitigation documents proposing a bunch of preservation
at their site in Watauga County It appears that they are using our draft document to increase credit of preservation
reaches with buffers wider than standard
In addition some of the preservation reaches already have CE s put on by the original owner (owner went bankrupt and
new company picked up the project development) The current owner is proposing more restrictive CE s (i a disallowing
some uses that were apparently allowed in the original CE) as well as wider buffers than the original CE Sue is trying to
find a copy of the original CE to see what it said
Quite complicated I know But my main question is did we intend for our Buffer Width document/ ethod to apply to
preservation? I don t think we ever discussed it
Please let me know
Eric
Eric W Kulz
Environmental Senior Specialist
N C Division of Water Quality
Wetlands Program Development Unit
1650 MSC
Raleigh NC 27699 1650
Phone [phone] Please note this is a new phone number
Fax [phone]
E mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties

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APPENDIX A
Proposal for Mitigation Potential in Existing Phase -1 Conservation Easement
Introduction The Applicant is proposing to include preservation of streams buffers and
adjacent uplands as a component of the compensatory mitigation plan for the RBR
development It is anticipated that preservation would make up approximately a third of
the required stream mitigation for the proposed impacts The preservation mitigation
initiative will involve placing an overlay easement over the existing Phase 1
Conservation Easement (P 1 CE) originally recorded in October of 2007 (Figure A -1)
and currently held by the Blue Ridge Conservancy (formally Blue Ridge Rural Land
Trust) a land trust that operates in the northwest North Carolina mountain region
The overlay easement will eliminate a number of reserved uses of the land specifically
allowed by the current P 1 CE Agreement Those uses to be eliminated are those that
pose a threat to water quality and aquatic habitat values The overlay easement will
closely follow the model easement found on the USACE web site The overlay easement
will cover the vast majonty of the existing P 1 CE but there will be a few areas excluded
Most notably, there will be a 100 foot wide exclusion zone extending along the southern
or western edge of Elk Creek and Laurel Creek or the property boundary (where the
creeks are off site) This zone is reserved to allow for a trail to be built at a future date to
facilitate the public trout fishing program the Applicant has worked out with NCWRC
and to facilitate a perimeter loop trail around the entire property (See Figure A 1)
In addition to the overlay easement the preservation mitigation initiative will involve the
creation of a new conservation easement area of approximately 130 acres (Figure A 1)
This new area will be adjacent to the P 1 CE in an area previously planned for residential
lot development Approximately 34 lots will be eliminated and 0 9 miles of subdivision
road This new area will provide protection to over 1000 linear feet of headwater streams
and wetland seeps in five separate drainages Additionally the new area will broaden
several narrow buffer comdors within the existing P 1 CE to provide broad buffers over
200 feet wide
In the following sections we provide a detailed description of why this proposal complies
with the 2008 Mitigation Rule and specifically the 5 criteria spelled out for preservation
to be considered a component of any compensatory mitigation plan We provide maps
and tables showing the areas within the P 1 CE that are threatened by land uses allowed
in the current easement agreement We also provide a spreadsheet showing calculations
for the total amount of preservation mitigation credit we feel is appropriate for the
proposed initiative
2008 Mitigation Rule The Final Rule for Compensatory Mitigation for Losses of
Aquatic Resources published 4 10 2008 set forth five entena to be met before
Preservation Mitigation may be used to compensate for impacts to aquatic resources
Each of the criteria is listed below followed by information demonstrating that each has
been satisfied
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c Continuation of existing watershed restoration and protection initiatives
and projects The proposed preservation mitigation Initiative is consistent
with the goals stated in the NC EEP watershed plan which satisfies the
"watershed approach to compensatory mitigation" required in the 2008
rule
d Collaborative efforts with local resource agencies land trusts and willing
landowners to implement new stream riparian buffer and wetland
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1 The resources to be preserved provide important physical, chemical, or
biological functions for the watershed All streams considered In this
'
preservation mitigation proposal are located within the Elk Creek & Tributaries
including Dugger Creek 14 digit hydrological unit (03040101010050) All of the
'
streams considered in this proposal are classified as ORW and Trout Within this
area there are in excess of 68 000 linear feet of headwater streams and over 15
acres of mapped wetlands This entire area is consider a high value source area for
'
Elk Creek providing excellent quality flow water quality and habitat diversity
According to the August 2007 Laurelmor Phase 1 Conservation Easement
Baseline Documentation" prepared by Equinox Environmental Inc the area
'
contains
a Three NC rare plant communities
b Five NC rare animal species
'
c Eight NC watch list species
d Suitable habitat for 10 potentially occurring rare vascular plant species and
9 rare ammal species
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Proximity to several Significant Natural Heritage Areas and Federal Lands
f Outstanding Resource Waters
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g Several significant rock outcrops
11 The resources to be preserved contribute signiflcantly to the ecological
'
sustainability of the watershed The NC Ecosystem Enhancement Program
(EEP) has developed a watershed plan for the Upper Yadkin River Basin, which
includes the RBR project area and all proposed impact sites The "Upper Yadkin
'
Pee Dee River Basin Restoration Priorities 2009' document lists primary
watershed restoration goals to Include
a Restoration of water quality and aquatic habitat in impaired stream
segments, The proposed preservation area does not Include any impaired
'
stream segments and no restoration efforts are proposed
b Protection of high resource value water including HQW ORW and WSW
'
as well as those containing large numbers or rare and endangered aquatic
species (NHEOs), The proposed preservation mitigation initiative will
provide enhanced protection for over 68 000 linear feet of high resource
'
value waters and associated riparian areas containing large numbers of
rare species
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c Continuation of existing watershed restoration and protection initiatives
and projects The proposed preservation mitigation Initiative is consistent
with the goals stated in the NC EEP watershed plan which satisfies the
"watershed approach to compensatory mitigation" required in the 2008
rule
d Collaborative efforts with local resource agencies land trusts and willing
landowners to implement new stream riparian buffer and wetland
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restoration enhancement and preservation projects to priority sub
watersheds within targeted local watersheds (TLWs) The proposed
preservation mitigation initiative is located with a TLW this initiative will
involve the creation of a more restrictive overlay easement over an
existing easement held by a local land trust The local land trust has been
consulted and is enthusiastic about this initiative Additionally a
collaborative effort with the NC WRC is underway to allow public access
fishing in Elk Creek through the P l CE
e Improved management of stormwater runoff While no stormwater
management BMPs are proposed as part of the proposed preservation
mitigation initiative stormwater management planning for the RBR
project will result in much lower densities than allowed by the regulations
and will incorporate stormwater BMPs in numerous areas not required by
regulation as well as in all high density areas
f Implementation of agricultural BMPs There are no agricultural activities
within the P 1 CE
iii Preservation is determined to be appropriate and practicable In this case
the proposed preservation mitigation initiative is both appropriate and practicable
This assertion follows from several factors that are apparent when considering the
project in its entirety
a The scale of this project is immense by local standards but the proposed
impacts are relatively small, confined to one specific activity and one area
of the project site While virtually the entire 6300 acre site drains to ORW
waters and is more stringently regulated than much of the nearby land the
Applicant has elected to keep development density well below even these
more stringent regulatory thresholds In doing this the Applicant has
planned for the preservation of large areas of open space most of which
could be used more actively for residential development more intensive
recreational use or some other use that could threaten the pristine nature
of the P 1 CE In fact the proposed preservation mitigation initiative
involves the addition of approximately 130 acres of new easement area,
eliminating 34 previously planned single family residential lots These lots
alone could easily be valued at more than $4 500 000 The creation of tins
easement area also eliminates approximately 0 9 miles of previously
planned subdivision grade road These are significant mitigation measures
b The proposed preservation mitigation initiative is only part of the total
compensatory mitigation plan With total proposed impacts of
approximately 3000 linear feet and a total mitigation requirement of
approximately 9000 linear feet the proposed preservation mitigation
initiative will account for only about a third of the total mitigation
requirement
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The goal of compensatory mitigation is to offset losses of aquatic
functions caused by unavoidable impacts to aquatic resources In
considering the appropriateness of the proposed compensatory mitigation
plan, the District Engineer must consider the following options in the
order presented
1) Mitigation Bank
2) In Lieu Fee Program
3) Permittee Responsible Mitigatior
First there are no currently active mitigation banks in the watershed that
would reasonably replace the aquatic resource functions that will be lost
due to unavoidable impacts Second, there exists an active In lieu fee
program administered by the NC EEP This program has a current
watershed plan for the Upper Yadkin River Basin that identifies
restoration priorities The 2008 Mitigation Rule states that the District
Engineer should give preference to In lieu fee mitigation over permittee
responsible mitigation because "In lieu fee projects typically involve
larger more ecologically valuable parcels, and more rigorous scientific
and technical analysis planning and implementation than permittee
responsible mitigation " However the rule states, ' these same
considerations may be used to override this preference where appropriate "
In this case the proposed permittee responsible mitigation plan is
preferable for several reasons supported by the 2008 rule
• The proposed permittee responsible mitigation plan will involve
a large ecologically valuable parcel The project site is 6300
acres The proposed preservation mitigation initiative will
involve a contiguous easement area of approximately 755 acres
that is ecologically rich and highly valued
• The project site where the impacts and on site mitigation will
occur is located within a targeted local watershed (TLW)
identified in the EEP watershed plan The off site mitigation is
located adjacent to this same I LW and shares the same problems
and potential for functional uplift as described for the TLW
• The proposed preservation mitigation area is located upstream of
' an impaired reach of Elk Creek and will contribute positively to
the water quality of Elk Creek ov,.,r the long term
' • There are two existing non EEP watershed projects located in
this same TLW The establishment of additional water quality
projects in this TLW is compatible with the 2008 rule's stated
' objective to " consolidating compensatory mitigation projects
where ecologically appropriate '
' RBR lP Comment Responses 9/16/2011
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iv The resources are under threat of destruction of adverse modifications There
are three different categories of stream corridors that are proposed to be part of
the preservation mitigation Initiative each is defined below along with a
description of the threats to these areas that will be mitigated
a Stream corridors outside the existing _P 1 CE that will be permanently
protected within the proposed new conservation easement area. None of
this stream length is currently within the Phase I CE There are 4 separate
headwater systems (Figure A 13) in this category with a total stream
length of 1118 linear feet all of which is intermittent (Table PM 1) The
proposed approximate 130 acre new conservation easement area will
create broad undisturbed buffers (> 150 feet each side) along each of
these stream corridors Previously this area was planned for residential
development with approximately 0 9 miles of roadway and 34 single
family lots all of this will now be eliminated
b Stream corridors within the existing P l CE that are narrow (buffer
widths less than 150 feet and in some cases between 30 and 50 feet) that
will be expanded by the new conservation easement area Threats from
minimal existing buffers are mapped on Figure A 12 and shown in Table
A 4 I'his threat category is based on existing buffers within the P 1 CE
being less than 100 feet average width each side In many cases this width
is less than 50 feet average width each side This threat will be eliminated
through the creation of a new conservation easement area that will extend
the existing buffers to widths greater than 150 feet on each side of the
stream The new area is approximately 110 acres and will occur over an
area previously planned for single family residential lot development The
proposed new easement area will result in the elimination of 34 lots and
approximately 0 9 miles of subdivision roads The quantity of stream
length from which this threat will be removed is approximately 2033
linear feet of perennial stream and 3396 linear feet of intermittent stream
Additionally this new easement area will expand the existing buffer width
from an average width of about 85 feet to over 150 feet along the left
bank of approximately 1400 linear feet of perennial stream
c Stream corridors within the existing P 1 CE that are threatened by land use
activities allowed by the existing CE Agreement The existing P 1 CE was
established primarily with the goal of preserving the land in a natural
condition but allowed for a variety of uses that would create value for the
development As is described below, several of these allowed uses would
result in land disturbing activities in the Immediate vicinity of streams and
wetlands These activities would generally be minor in scope but some,
such as trail construction and maintenance or legacy timber harvesting
could result in increased sedimentation of streams and some deterioration
of aquatic and riparian habitat values The proposed new overlay easement
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will eliminate the rights of the owner to permit or perform any of the
defined activities
1) Threats from maintenance of existing roads and trails within
the Phase 1 Conservation Easement (P l CE) are mapped on
Figures A 3 A 4, and A 5 and shown on Table A 1 This threat
category is based on the owners right as spelled out in
paragraphs 2 3 and 2 12 of the existing Conservation Easement
Agreement (CE Agreement) Specifically these paragraphs allow
the Grantor the right to maintain existing improvements
including old farm roads utility access roads wells hiking and
horseback trails and to perform drainage, erosion control or
flooding related repairs or maintenance These activities could
result in periodic land disturbing activities causing erosion and
sedimentation of streams and altering drainage patterns While
hand pruning of vegetation along existing trails would still be
allowed in order to keep the trails passable no mechanized land
disturbance associated with maintenance or upgrades would be
allowed under the overlay easement Within the P 1 CE there are
approximately 11,655 linear feet of streams within 50 feet of an
existing road or trail Of this total all but approximately 312
linear feet of streams are classified as perennial
2) Threats from limited timber harvesting activities within the
P 1 CE are mapped on Figures A 6, A 7 and A 8 and shown on
Table A 2 This threat category is based on the owners right as
spelled out in paragraph 2 7 of the existing CE Agreement
Specifically this paragraph allows ' some limited timber
harvesting activity for the purpose of educational historic
reenactment habitat creation or enhancement, or other similar
activities " The CE Agreement states that ' all timber roads
shall be constructed of permeable materials including crusher run
installed to a depth of three (3) inches and shall be no wider than
ten (10) feet " This activity could result in substantial land
disturbance over many acres causing erosion and sedimentation
of streams altering drainage patterns impacting habitat within
the P 1 CE The proposed overlay easement will eliminate this
right In order to determine the extent of this threat a 50 foot
wide buffer was applied to all streams as specified in the CE
Agreement the remaining areas within the P 1 CE are all
technically threatened by this potential use However, it was
decided that not all areas would suitable for timber harvesting
activity primarily for the reason that many areas would be too
small to allow for a reasonable number of trees to be harvested
within a given block in other cases blocks were eliminated due
to poor access An arbitrary minimum block size was established
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of (10) acres Within the P 1 CE there are approximately 17756
linear feet of perennial streams and 2313 linear feet of
intermittent streams threatened by the potential for timber
harvesting activities Finally the CE Agreement states "Grantor
reserves the right to remove dead trees and trees that pose a
danger to the public and users of the recreational facilities (trails,
etc ) of the property' and 'Grantor and Grantee agree that under
some conditions it may be necessary to conduct limited logging
operations of the property such as after a windstorm or forest
fire has damaged the woodland' These rights will be retained in
the overlay easement although restrictive language will be added
to insure that any such activity is well justified
3) Threats from viewshed clearing within the P l CE are mapped
on Figures A 9 A 10 and A 11 and shown on Table A 3 This
threat category is based on the owner's right as spelled out in
paragraph 2 10 of the existing CE Agreement Specifically this
section allows for limited viewshed management limited
to within 200 feet of each home" In order to determine the
extent of this threat a 250 foot wide zone was established from
all roads and private drives serving lots adjacent to the P I CE
The 250 foot zone is based on the 200 foot wide viewshed
clearing limit and an assumption that most homes will be at least
50 feet from any road Where this zone encroaches within 150
feet of any stream within the P I CE, a potential threat was
determined to exist The overlay easement will eliminate any
viewshed clearing within the P 1 CE Within the P 1 CE there
are approximately 14 934 linear feet of perennial streams and
5165 linear feet of intermittent streams threatened by the
potential for viewshed management activities
4) Threat from recreational facility development This threat
category is based on the owner s right as spelled out in paragraph
2 11 of the existing CE Agreement Specifically this section
allows the owner' to build and maintain unpaved foot and
horseback trails to allow such recreational use of the property'
Allowable uses include hiking camping picnicking
horseback riding non motorized bicycling lawful hunting and
fishing and other recreational uses that require only minimal
facilities, surface alteration or other development of the land "
Additionally, the CE Agreement states " Grantor and Grantee
recognize that all terrain vehicles and other forms of
transportation may be used to fac litate recreation on the Property
and to maintain the recreational structures " The primary threats
associated with activities in this category are land disturbing
activities from trail or facility construction erosion
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' sedimentation of streams disruption of drainage patterns and
impacts to habitat No new trails or recreational facilities will be
' allowed within the overlay easement Within the P I CE there
are approximately 52,872 linear feet of perennial streams and
14,418 linear feet of intermittent streams threatened by the
' potential for new recreational facility or trail development
v The preserved site will be permanently protected through an appropriate
real estate or other legal instrument A new conservation easement is proposed
that will overlay much of the existing P 1 CE and include approximately 130
' acres of new currently unprotected riparian corridors and adjacent uplands The
new conservation easement agreement will contain more restrictive language that
will effectively remove all of the threats to the resource previously described
' This instrument will be recorded prior to any of the impacts occurring and will be
held in perpetuity by a local land trust
Determination of Available Preservation Mitmation Credits
The previous sections described how the proposed mitigation plan for the RBR protect
satisfies the 5 criteria of the 2008 mitigation rule particularly the preservation mitigation
component Also described above are the specific areas where preservation mitigation is
proposed and the mechanisms by which preserved areas will be established enhanced
(threat removal), and maintained This section will explain the rationale for, and describe
' a method for quantifying the total amount of mitigation credit available from the
proposed preservation activities
' Preservation mitigation credits are derived from three separate categories of stream
corridor protection as described under criteria (iv) above A detailed description of the
' quantification method for each category of stream corridor protection is provided below
1 Stream corridors outside the existing _P 1 CE that will be vermanently protected
' within the proposed new conservation easement area The total stream length that
falls into this category is 1118 linear feet all of which is intermittent Because all
of this stream length will be protected by a new conservation easement area all of
' the stream length is eligible for preservation mitigation credit Also because all of
this stream length is classified as intermittent a factor of 0 5 is used to calculate
mitigation credit Therefore the total amount of stream length available for
preservation mitigation credit in this category is 1118 * 0 5 = 559 linear feet (see
Preservation Mitigation Worksheet Iable PM 1)
' 2 Stream corridors within the existing P 1 CE that are narrow (buffer widths less
than 151 feet and in some cases between 30 and 50 feet) that will be expanded by
the new conservation easement area Mitigation credits in this category are based
' on providing increased buffer width over that which is currently provided The
determination of available credits is based on the Draft Regulatory Guidance
for the Calculation of Stream and Buffer Mitigation Credit for Buffer Widths
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Different From Standard Minimum Widths' (SBW Guidelines) put out for public
review by the NC Interagency Review Team (July 20 2010) There are 11 stream
reaches in this category Average existing buffer widths for each side of each
reach have been determined The proposed buffer width after the new 130 acre
easement area is established, will be greater than 151 feet for all reaches The
percent credit allowed is taken directly from Table PM -2 in the SBW Guidelines
For example if a 100 foot long perennial stream reach has an average existing
buffer width of 40 feet on each side of the stream Table PM 2 in the SBW
Guidelines calls for a 4 5% increase in stream mitigation credit for that reach If,
the same 100 foot long reach had an average buffer width of greater than 151 -feet
on each side of the stream Table PM 2 would allow for an 18 5% increase in
stream mitigation credit Therefore stream length eligible for preservation
mitigation credit in this example for increasing the average buffer width of the
reach, from 40 feet to greater than 151 feet, is 18 5% 4 5% = 14% and the
actual amount of eligible stream length would be 14 feet if the example reach
was an intermittent stream the credit allowed would be divided by 2 yielding 7
feet of mitigation credit for this reach For this entire category of stream corridor
protection/preservation there are roughly 2930 linear feet of perennial streams
and 1806 linear feet of intermittent streams The total amount of credit allowed
based on the described methodology is 280 linear feet (see Preservation
Mitigation Worksheet Table PM -2)
3 Stream corridors within the existnnit P 1 CE that are threatened by land use
activities allowed by the existing CE A eement The determination of total
stream length in this category available for preservation mitigation required a
two step process First to identify specific threats to water quality and quantify
stream length within the P 1 CE susceptible to each threat Second, to develop a
reasonable method to weight the relative water quality benefit to the streams and
riparian systems created by removing various threats The first step was discussed
under (w)(c)(4) above the second is described here In the existing condition all
streams within the P 1 CE are protected from encroachment from development,
road construction or other direct impacts associated with development The
threats described above are associated pnmanly with activities allowed within the
easement and riparian buffer areas These activities would cause periodic spikes
in erosion and sedimentation in these areas and would cause increased human use
and low level chronic impacts along stream corridors Because of the lower level
of threat posed by the listed activities the elimination of these activities should
only earn a fraction of the credit usually granted for preservation mitigation This
consideration is realized by allowing the removal of each threat to enhance the
resource protection value by 10% There are four listed threats so the maximum
resource protection value for any reach of stream would be 40% In fact there are
no specific areas that are threatened by more than 3 of the threat categories The
10% Threat Factor' is reasonable given that any one of the identified threats
could impact water quality for both the short and long term In the event there
were 3 or 4 of the threats is the same localized area it is reasonable to assume that
the impacts could be substantial It is important to note also that the impact from
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identified threats to these areas must be considered over the background level of
protection These areas are all classified as ORW and trout waters so there is
without any conservation easements a strong measure of background protection
In essence, what we are quantifying here is the difference between pristine or
nearly pristine and the same areas after logging viewshed clearing or the
construction of new trails suitable for equestrian use or even ATV use When
considered in this light a 10% threat factor seems reasonable or potentially too
low An example of the calculation follows There are 17 756 linear feet of
perennial streams and 2,313 linear feet of intermittent streams threatened by
potential forestry operations The total length of stream eligible for preservation
mitigation credit is (17,756 * 0 1) + (2,313 * 0 1 * 0 5) = 1 891 25 linear feet
This is the amount of stream eligible for preservation mitigation credit at a 5 1
ratio (see Preservation Mitigation Worksheet Table PM 3) Table PM4 shows
the total amount of stream length eligible for preservation mitigation and applies
the 5 1 ratio to determine the total number of stream mitigation credits available
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Preservation MiNation Worksheet
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Reynolds Blue Ridge IP comment responses
September 15, 2011
T
This worksheet provides a method for quantification of the mitigation credit to be received for providing
a new conservation easement adjacent to the existing Phase 1 Conservation Easement and establishing
a more restrictive overlay easement over the majority of the existing Phase T Conservation Easement that
will effectively remove several identified threats T
Table PM 1
Preservation of streams not currently within the Phase 1 C_onsery itlon Easement Boundary
_
" re resents stream length within the pro sed new 130 acre (approx) easement area
{
Stream Stream credit Credit
Location Length Class multiplier Allowed
LAM 2C 75 Int 05 375
LAM 1B 293 Int 05 1465
ELK MA 1 520 Int 05 260
ELK MC 230 Int 051 115
TOTAL 559 r
Table PM 2 I I t
1
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Stream Perservation Mitigation Credit from Expanded Buffer Widths
_
buffer widths exp anded by establishment of new easement area
Preservati
Proposed
Preservati
Stream
on Credit
Ex Buffer
Ex Buffer
Buffer
Stream
on Credit
Length
for
Total
Width
Width
Width
% credit
Length
for
Intermitte
Intermitte
Preservatio
Location
total
average
allowed
Perennial
Perennial
nt
nt
n Credit
LAM 3
175
85
7 5
320
24
71
2 66
2 6 66
LAM 2C
70
30
nvera-e
18 5
0
0 00
520
48 10
48 10
LAM 2B
145
70
10 5
0
0 00
380
19 95
19 95
LAM 2
165
80
7 5
0
000
145
544
544
LAM 2A
70
30
>150
185
0
000
167
15451
1545
LAM 1 B
112
52
>150
105
335
3518
25
131
3649
ELK MA
200
95
>150
7 5
425
3188
28
105
32 93
ELK MC
185
90
>150
7 5
0
000
470
1763
1763
ELK J
80
38
>150
14
85
11 90
0
000
1190
ELK-J
255
125
>150
3 5
165
578
0
000
578
SF 37
var
90 left
>150 left
375
1600
6000
0
000
6000
TOTAL
2930
1806
280 31
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Preservation Mitigation Worksheet (p2)
Reynolds Blue Ridge IP comment responses
September 15, 2011
Table PM
Stream Preservation Mid ation Credit from Identified Threat Removal
Existing
New Rec Foresty Rec Viewshed
Trail Dev Blocks Trails Clearing Totals
Peren 1 52872 17756 11343 14934
T Factor 1 01 01 01 01
52872 17756 11343 14934 96905
_ T
Intermit 14418 2313 312 5165
T factor 01 01 01 01
Int Factor 05 05 05 —05
7209 11565 156 25825 11104
T factor Threat-factor-0 1 for each threat removed The total length of stream for
which a particular threat is removed is multiplied by 0 1 and the product
Is the amount of stream eligible for preservation mitigation credit at a
five to-on i ratio I 7
Int factor Intermittent streams are valued at half the rate of perennial streams for I }
compensatory mitigation credit
r
Table PM-4
TOTAL Preservation Mitigation Credits Available
Source
New Easement Area
Expanded Buffers
Removed Threats
TOTAL
Wit Ratio
Mit Credits
Quantity
559
280
10800
11639 1
5
23278
If preservation mitigation credits are applied at a 5 1 ratio there will be 2327 stream t
_
mite ation credits available from the preservation mite ation initiative
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TABLE A -1
Reynolds Blue Ridge
June 22, 2011
Threat to Streams within 50' of Existing Trails
Perennial
Stream Name
Length (ft)
PC -EP
736
PC -AP
344
PC -CP
125
PC -DP
100
PK -AP
496
FB -WCP
5215
FB -8BP
438
FB -18AP
810
SF -31 DP
285
SF -32AP
2794
TOTAL 11343
Threat Summary of Streams near Existing Trails
Length (ft)
Length (ft)
Intermittent Streams
312
Perennial Streams
11343
Total Streams
11655
Total No. Crossings
22
Intermittent
Stream Name
Length (ft)
FB -8BJ
312
TOTAL 312

BOX 1
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FIGURE A -3
Reynolds Blue Ridge
Threat Summary Maps
June 22, 2011
Trails Within 50' of Streams
U '
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TABLE A -2
Reynolds Blue Ridge
June 22, 2011
' Threat to Streams within 50' of Allowable Forestry Blocks
Perennial
Stream Name
Length (ft)
PC -JP
2520
PC -HP
999
PC -EP
2838
LA -EP
1307
LC -AP
1238
LC -EP
235
LC -DP
694
SF -30FP
349
SF -30AP
3262
SF -37DP
1194
SF -31 AP
3120
TOTAL 17756
Intermittent
Stream Name
Length (ft)
PC -FJ
210
PC -HJ
155
PC -IJ
295
LA -EJ
280
LC -DJ
403
LC -EJ
71
SF -30FJ
186
SF -30GJ
139
SF -30IJ
574
TOTAL 2313
i
1
1
Threat Summary of Streams near Forestry Blocks
Intermittent Streams
Len th (ft)
Perennial Streams
2313
Total Streams
17756
20069

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3
3
Reynolds Blue Ridge
Therat Summary Maps
June 22, 2011
Forestry Blocks
[B-ON-3]
FIGURE A-8
Existing Trails, Logging and
Forest Roads
Streams Threatened by
Allowed Forestry Practice
■
Foresty Blocks
Existing Phase I Conservation
Easement Boundary
FIGURE A-8
I
- - --------
-AP
-AP
'4 ELK-EAJ
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ap
iscalimer. Map intended
o ant
for planning purposes only; not
to be used for construction purposes. Basernap provided by McGill Enghteming. NOT to scale
I
- - --------

i�
1
7
n
1
TABLE A -3
Reynolds Blue Ridge
June 22, 2011
Threat to Streams within 150' of Potential Viewshed Clearing
Perennial
Stream Name Length (ft)
ELK BP
2503
ELK EBP
55
SF -32AP
1468
SF -31CP
103
S F -31 AP
2000
SF -37AP
1203
ELK -MAP
470
LAM -1 BP
422
LAM -3P
331
FB -8AP
556
FB -8BP
169
FB -WAP
562
FB -WCP
1725
PK -AP
528
PC -AP
594
PC -EP
1864
PC -JP 1381
292
TOTAL 14934
Intermittent
Stream Name Length (ft)
ELK BJ
131
ELK CJ
50
SF -32AJ
202
SF -31 DJ
64
SFA/BJ
358
SF -30IJ
150
SF -30AJ2
164
SF -30FJ
175
ELK -MCJ
460
ELK -MBJ
135
LAM -2J
30
LAM -2BJ
410
LAM -2CJ
431
LAM -3J
72
FB -8BJ
505
FB -WAJ
61
FB -WBJ
292
FB -WCJ
190
FB -WDJ
174
PC -AJ
307
PC -BJ
152
PC -CJ
465
PC -DJ
30
PC -FJ
25
PC -JJ 1132
TOTAL 5165
Threat Summary of Streams near Viewshed
Zones
Length (ft)
Intermittent Streams
5165
Perennial Streams
14934
Total Streams
20099

BOX 1
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Reynolds Blue Ridge
Threat Summary Maps
June 22, 2011
Viewshed Clearing
,s
FIGURE A -9
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TABLE A-4
Reynolds Blue Ridge
June 22, 2011
Threats to Streams
Due to Existing Minimal Riparian Buffers
Perennial
Stream Name
Length (ft)
LAM -3P
288
LAM -2P
28
LAM -2AP
21
ELK -MAP
238
ELK-JP
1203
SF -37EP
1400
TOTAL 3178
Intermittent
Stream Name
Length (ft)
LAM -3J
72
LAM -2CJ
598
LAM -2BJ
677
LAM -2AJ
168
LAM -2J
277
LAM -1 BJ
315
ELK -MBJ
264
ELK -MAJ
524
ELK -MCJ
501
TOTAL 3396
Threat Summary of Streams with Minimal Riparian Buffers
Length (ft)
Intermittent Streams
3396
Perennial Streams
3178
Total Streams
6574

1
1
1
Mao Discalimer: Mai) intended for olannim ourooses only: not to be used for construction ourvoses. Baseman provided by McGill Ensineerim. Not to Scale.

Reynolds Blue Ridge
August 18, 2011
1 Wetlands Not Currently
I Conservation Easement
Figure A -13
Streams and Wetlands Cun=tly
Not Protected by Phase 1
Conservation Easement
New 130 -acre Conservation
Easement Boundary
Existing Phase I Conservation
Easement Boundary
N
w— E
S
Man nicralimPr• Man intended for nlannino mimnerm nnly not M be naeA fnr rnnctntrtinn nrtmnsea Raseman nmvideA by McGill Rnoinenrinv Writ to Rrale.

Mcmillan, Ian
From
Sent
To
Subject
Attachments
FYI IRT related stuff
Kulz Eric
Thursday October 20 2011 10 12 AM
Mcmillan Ian
FW December IRT Agenda (UNCLASSIFIED)
Nahunta Information Request 30Jun2011 pdf
Eric W Kulz
Environmental Senior Specialist
N C Division of Water Quality
Wetlands Program Development Unit
1650 MSC
Raleigh, NC 27699 1650
Phone [phone] Please note this is a new phone number
Fax [phone]
E mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
Original Message
From Lekson, David M SAW fmailto David M Lekson(@usace army mill
Sent Thursday, October 20, 2011 10 05 AM
To Norton Webster
Cc Tugwell, Todd SAW, Lekson, David M SAW, Wescott, William G SAW, Cox, David R , Wilson,
Travis W , Rebecca Fox, Sollod, Steve, Kulz, Eric, John Ellis(&fws Rov
Subject RE December IRT Agenda (UNCLASSIFIED)
Classification UNCLASSIFIED
Caveats NONE
Good morning Norton working my way through the emails Re your request to be placed on the
December IRT agenda, please review pgs 2 4 of the attached to make sure you cross all t s
before you submit this important information to the IRT
Thanks)
David
Original Message
From Norton Webster fmailto norton@ebxusa coml
Sent Monday, October 03, 2011 2 33 PM
To Tugwell, Todd SAW
Subject October IRT Agenda
Todd,
Thank you again for your time last week with us in the mountains I hope you had an
enjoyable weekend out there as well When you get a chance, please send me the location and
agenda for the October 11th IRT meeting Also, please put Nahunta on the agenda for the
December meeting I am planning on having all of the Nahunta documents to the IRT members 30
days before the December meeting
Also, how do I obtain -he Latest dra t stream guidance? I have a version from abOLt a year
dgo and I wojld prefer to iot have to do a FOIA request
1

Thank you again for your help
Norton
Classification UNCLASSIFIED
Caveats NONE

Mcmillan, Ian
From Kulz Eric
Sent Thursday October 20 2011 10 20 AM
To Lekson David M SAW Cox David R Wilson Travis W Rebecca Fox Sollod Steve
John _Ellis @finis gov
Cc Tugwell Todd SAW Wescott William G SAW Mcmillan Ian Karoly Cyndi
Subject RE EBX Nahunta project (UNCLASSIFIED)
Hi Everyone
Please include Ian McMillan and me on all IRT correspondence Due to personnel changes here
at DWQ, both recently and over the past several years, Ian and I are going to try to
establish some continuity with respect to DWQ representation at all IRT meetings and
functions Ian and I (or both of us) will try to attend all IRT meetings going forward
Thanks for your patience,
Eric
Eric W Kulz
Environmental Senior Specialist
N C Division of Water Quality
Wetlands Program Development Unit
1650 MSC
Raleigh, NC 27699 1650
Phone [phone] Please note this is a new phone number
Fax [phone]
E mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
Original Message
From Lekson, David M SAW fmailto David M Lekson(@usace army mill
Sent Thursday, October 20, 2011 10 14 AM
To Cox, David R , Wilson, Travis W , Rebecca Fox, Sollod, Steve, Kulz, Eric,
John Ellis(@fws Rov
Cc Lekson, David M SAW, Tugwell, Todd SAW, Wescott, William G SAW
Subject RE EBX Nahunta project (UNCLASSIFIED)
Classification UNCLASSIFIED
Caveats NONE
All,
Please see the email below my attempt to provide you with the Nahunta
Yr5 report was ,just thwarted by the size of the document so I 11 be sending you a disc asap
The referenced letter is attached thanks) D
Original Message
From Lekson, David M SAW
Sent Thursday, October 20, 2011 10 03 AM
To Tupwell, Todd SAN Lekson David M SAW, Wescott, William G SAW Cox, Dav d R , Wilson,
Travis 4 Rebecca Fcx, collod, StL4e, Kulz, Eric, John Ellis(@fws gov
Cc Lekson David M SAW
1

Subject EBX Nahunta project (UNCLASSIFIED)
Classification UNCLASSIFIED
Caveats NONE
All,
Norton Webster recently expressed an interest in having Nahunta placed on the December
IRT agenda Accordingly, please see the two attached documents as follows
1 The letter I sent to Norton Webster back in June listing everything he must provide
the IRT before we will make a final decision (pgs 2 4) I will be sending Norton a reminder
in my next email
2 As per the letter (pg 1, para 3), Norton submitted the Yr5 monitoring report
However, I have not received the requested wetland data forms for the Nahunta Preservation
area so we don t have to finalize the credit release issue yet
Please review the Yr5 report and provide me with your comments We will most definitely have
to conduct an onsite inspection before we sign off on anything and early next year would be
the time frame I would recommend
Thanks'
David
P S (Nahunta presents the IRT with several very complicated decisions that we encounter on
ALL mitigation banks and projects more soon )
Classification UNCLASSIFIED
Caveats NONE
Classification UNCLASSIFIED
Caveats NONE
2

Mcmillan, Ian
From Lekson David M SAW [David M Lekson@usace army mil]
Sent Thursday October 20 2011 10 22 AM
To Kulz Eric Mcmillan Ian
Cc Tugwell Todd SAW Wescott William G SAW Karoly Cyndi Cox David R Wilson Travis
W Rebecca Fox Sollod Steve John_Ellis @fws gov
Subject RE EBX Nahunta project (UNCLASSIFIED)
Classification UNCLASSIFIED
Caveats NONE
Cool deal thanks' Welcome aboard Iani
Original Message
From Kulz, Eric jmailto eric kulz(ncdenr govl
Sent Thursday, October 20, 2011 10 20 AM
To Lekson, David M SAW, Cox, David R , Wilson,
John Ellis(fws gov
Cc Tugwell, Todd SAW, Wescott, William G SAW,
Subject RE EBX Nahunta project (UNCLASSIFIED)
Hi Everyone
Travis W , Rebecca Fox, Sollod, Steve,
Mcmillan, Ian, Karoly, Cyndi
Please include Ian McMillan and me on all IRT correspondence Due to personnel changes here
at DWQ, both recently and over the past several years, Ian and I are going to try to
establish some continuity with respect to DWQ representation at all IRT meetings and
functions Ian and I (or both of us) will try to attend all IRT meetings going forward
Thanks for your patience,
Eric
Eric W Kulz
Environmental Senior Specialist
N C Division of Water Quality
Wetlands Program Development Unit
1650 MSC
Raleigh, NC 27699 1650
Phone [phone] Please note this is a new phone number
Fax [phone]
E mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
Original Message
From Lekson, David M SAW fmailto David M Lekson(usace army mill
Sent Thursday, October 20, 2011 10 14 AM
lo Cox, David R , Wilson, Travis W , Rebecca Fox, Sollod, Steve, Kulz, Eric,
John Ellis(@fws gov
Cc Lekson, David M SAW, Tugwell, Todd SAW Wescott, William G SAW
Subject RE EBX Nahunta project (UNCLASSIFIED)
Class fic tion UNCLASS FIED
Caveats LONE
1

All,
Please see the email below my attempt to provide you with the Nahunta
Yr5 report was dust thwarted by the size of the document so I 11 be sending you a disc asap
The referenced letter is attached thanks) D
Original Message
From Lekson, David M SAW
Sent Thursday, October 20, 2011 10 03 AM
To Tugwell, Todd SAW, Lekson, David M SAW, Wescott, William G SAW, Cox, David R , Wilson,
Travis W , Rebecca Fox, Sollod, Steve, Kulz, Eric, John Ellis(&fws eov
Cc Lekson, David M SAW
Subject EBX Nahunta project (UNCLASSIFIED)
Classification UNCLASSIFIED
Caveats NONE
All,
Norton Webster recently expressed an interest in having Nahunta placed on the December
IRT agenda Accordingly, please see the two attached documents as follows
1 The letter I sent to Norton Webster back in June listing everything he must provide
the IRT before we will make a final decision (pgs 2 4) I will be sending Norton a reminder
in my next email
2 As per the letter (pg 1, para 3), Norton submitted the Yr5 monitoring report
However, I have not received the requested wetland data forms for the Nahunta Preservation
area so we don t have to finalize the credit release issue yet
Please review the Yr5 report and provide me with your comments We will most definitely have
to conduct an onsite inspection before we sign off on anything and early next year would be
the time frame I would recommend
Thanks)
David
P S (Nahunta presents the IRT with several very complicated decisions that we encounter on
ALL mitigation banks and projects more soon )
Classification UNCLASSIFIED
Caveats NONE
Classification UNCLASSIFIED
Caveats NONE
Classification UNCLASSIFIED
Caveats NONE
1