20110896 Ver 1_CAMA Application_20120511

L
Beverly Eaves Perdue
Governor
I1 - L'P
NCD N
North Carolina Department of Environment and Natural Resources
Division of Coastal Management
Braxton C Davis Aoki
Director
MEMORANDUM
TO
FROM
SUBJECT
Applicant
May 8 2012
Dee Freeman
Secretary
Cyndi Karoly Supervisor
401 Oversight & Express Permits Unit
Division of Water Quality Surface Water Protection
Doug Huggett, NC DENR DCM Mayor Permits Coordinator
400 Commerce Ave Morehead City NC 28557 (Courier 11- 12 -09)
CAMA/Dredge & Fill Permit Application Review
Orton Plantation Holdings LLC (c /o P Talty)
Project Location 9149 Orton Rd S E adjacent to the Cape Fear River & Orton
Creek in Winnabow NC Brunswick Co
Proposed Project Applicant proposes to construct riprap revetments along the existing
dike structure and to repair rebuild or replace the dike system
including associated water control structures and the overall
reversion to rice fields and rice production
Please indicate below your agency s position or viewpoint on the proposed project and
return this form by June 4, 2012 If you have any questions regarding the proposed
project contact Heather Coats (910)796 -7424 when appropriate, in depth comments
with supporting data is requested
REPLY This agency has no objection to the project as proposed
This agency has no comment on the proposed project
This agency approves of the project only if the recommended
changes are incorporated See attached
This agency objects to the project for reasons described in the
attached comments
SIGNED DATE
400 Commerce Ave Morehead City NC 28557 3421
Phone, 252 808 2808 1 FAX [phone] Internet www nccoastaimanaciement net
One
An Equal Opportunity \ Affirmative Action Employer NorthCarohna
NatutriallY

DIVISION OF COASTAL MANAGEMENT
FIELD INVESTIGATION REPORT
1 APPLICANT'S NAME Orton Plantation Holdings LLC c/o Peter Talty
2 LOCATION OF PROJECT SITE 9149 Orton Road SE Wmnabow Brunswick County
Photo Index 2006 13 6227 A P 1 10 13 6228 A P 8 24 2000 13 127 A P 1 10 13 128 A Q 7 24
1998 13 125 G W 1 10 13 126 H X 4 24
State Plane Coordinates X 223 93 85 Y 61012
Lat 33 054 54 05187 N Long 78 °12 40 00838 W
3 INVESTIGATION TYPE CAMA/ Dredge & Fill ROVER FILE # Q04251 IA
4 INVESTIGATIVE PROCEDURE Dates of Site Visit - 11/7/11 12/9/12 2/2/12
Was Applicant Present — Yes
5 PROCESSING PROCEDURE Application Received — Complete on 5/2/12
Office Wilmington
6 SITE DESCRIPTION
(A) Local Land Use Plan — Brunswick County
Land Classification From LUP — Conservation
(B) AEC(s) Involved PTA, EW ES
(C) Water Dependent Yes
(D) Intended Use Private
(E) Wastewater Treatment Existing — Septic
Planned — N/A
(F) Type of Structures Existing —Rice fields dikes & gravity water system plantation house and gardens
with associated structures
Planned — Shoreline /dike stabilization along the outer dike replacement of water
control structures construction of field access areas and the overall reversion to nce fields
(G) Estimated Annual Rate of Erosion N/A
Source- N/A
7 HABITAT DESCRIPTION (AREA)
T1RRT1(:RT) PTT T RTl nTMD
(A) Vegetated Wetlands
0 16 acres (Coastal)
2 41 acres ( §404)
—318 acres
( §404)
(B) Non Vegetated Wetlands
2 0 acres (PTA/EW)
(Open Water)
2 55 acres (FW canals)
(C) High Ground
—8 8 acres
(D) Total Area Disturbed —334 acres
(E) Primary Nursery Area No
(F) Water Classification SA & C Open No
8 PROJECT SUNMARY The applicant is proposing to construct nprap revetments along the existing
dike structure and to repair rebuild or replace the dike system including associated water control
structures and the overall reversion to nce fields and nce production

Orton Plantation Holdings, LLC c/o Peter Talty
Page 2
9 PROJECT DESCRIPTION
To find the project site travel west of US Hwy 74/76 out of Wilmington to NC Highway 133 South
towards Southport Travel approximately 12 5 miles to Plantation Road SE Veer left on Plantation Road
and follow it to Orton Road SE a distance of approximately 0 5 miles Turn left onto Orton Road SE
The gate will be located in front of you (Please note this property is gated and locked not allowing for
free access site visits should be arranged with the applicant ahead of time to guarantee access )
The property is located between NC Highway 133 and the Cape Fear River to the east and is bordered
by Orton Creek/Orton Road SE to the north and bordered by Orton Pond Spillway to the south
Orton Plantation is a former nee plantation developed around 1725 Construction included a gravity
based water control system with Orton Pond as the water supply source and creation of several nee
fields on the property named in this application as the Back Rice Field #9 Rice Field the #1 Rice
Field the `North Front Rice Field and the Front South Rice Field (See Figure 6) Rice production
ceased around the 1930 s and the NC Wildlife Resources Commission (WRC) later managed some of
the fields for wildlife habitat enhancement The named Front Rice Fields (both North and South) are
bordered by Orton Creek to the north Orton Pond spillway to the south and the Cape Fear River to the
east An earthen dike and a canal to the interior separate these waterbodies from the nee fields The dike
has a current elevation of approximately +7 to +8 5 above Mean Low Water ( +4 5 to +6 NAVD) A
water control structure is located at the northern end of the dike which drams to Orton Creek and another
structure is located on the southern end of the Front South Rice Field which drains to the Orton Pond
Spillway The interior canal has been historically excavated in order to provide material to fortify the
dike as wave activity and ship traffic subject the northern and center portions of the dike to strong
erosional forces requiring ongoing maintenance The `Number 1 & 9 Rice Fields are located inland
and to the north of the property and are adjacent to Orton Creek Recent erosion has caused a breach in
the northern part of the dike surrounding the # 1 Rice Field The Back Rice Field is located south of
the raised causeway leading from Orton Road to the plantation and is severed from the tidal flow by a
one way water control structure that allows freshwater drainage from the field to Orton Creek
State Permit #176 88 was issued by CRC variance to Kenneth M Sprunt on September 2 1988 for the
reconstruction of a dam/spillway State Permit #65 02 was issued to Orton Plantation by Settlement on
June 3 2002 for the long term maintenance of the outer dike adjacent to the Cape Fear River The
permit originally proposed repair to relic berms and to create two wildlife impoundments adjacent to
Allen s Creek at the northern end of the property The permit request was demed due to resource
agency concerns regarding adverse impacts to coastal/404 jurisdictional wetlands and loss of tidal marsh
habitat The applicant then retracted the proposal to construct the wildlife impoundments and a permit
was issued by settlement for the maintenance of the outer dike adjacent to the Front Rice This permit
has since been modified numerous tunes to allow for additional nprap stabilization and sheetpile
reinforcement along the Cape Fear River adjacent to the dike The permit was recently transferred to the
current owner Orton Plantation Holdings LLC, on March 17 2011 Recent clearing of the back nee
fields was performed under the belief that it qualified as exempted agricultural work
The waters of the Cape Fear River and Orton Creek are classified as SA & C, respectively by the NC
Division of Water Quality They are not designated as Primary Nursery Area (PNA) by the NC Division
of Marine Fisheries nor open to the harvesting of shellfish

Orton Plantation Holdings, LLC c/o Peter Talty
Page 3
PROPOSED PROJECT
The applicant is seeking authorization to construct dike and marsh revetments along the Cape Fear
River Orton Creek and the Orton Pond Spillway to augment the dike replace existing water control
structures and to revert the historic nee fields back to nee production
As proposed the existing dike would be raised in height to an elevation of approximately 7 3 above
MHW ( +9' NAVD) Along areas of the dike with marsh vegetation (a distance of approximately 5 900
linear feet) the applicant proposes to construct a riprap revetment immediately landward of the existing
wetland line and to augment the dike shifting it landward in order to maintain an adequate slope Riprap
would be installed at a 2 1 slope on the outer edge of the dike and the interior slope (nee field side)
would be constructed at a 15 1 slope Sheet piling would also be installed adjacent to the top of the dike
for additional protection (See Sheet 15 Section C C for a typical cross section detail) Along the two
severely eroded portions of the dike devoid of marsh vegetation (approximately 1 700 lmear feet) nprap
armoring of the dike is proposed which would extend up to 43 in width and up to 40 below the MHW
line The marsh armoring would result in the fill of coastal wetlands where there is a narrow remaining
fringe of marsh and at the ends of the two sections where it would taper back into the dike (Please refer
to Sheets 6 9 for plan view details and Sheet 15 of 15 Section A A for a typical cross section )
The applicant is also proposing several marsh revetments along areas of the shoreline experiencing
marsh erosion, but where there is still a functional marsh fringe present The combined length of all
sections would be approximately 1,9401mear feet The revetments would be located nmmediately
waterward of the marsh escarpment and would measure up to 30 in width As proposed several small
areas of marsh would also be filled as a result of the marsh revetment construction in order to maintain a
straighter alignment These structures would be constructed to a height of approximately 18 above
MHW ( +3 5' NAVD) and would range from 0 5 to 2 5 above the adjacent marsh substrate The
structures would be located a maximum distance of 200 and an overall average distance of 80'
waterward of MHW
The proposed protect also includes the raismg/augmentation of an additional 3 3001mear feet of dike
along the bank of Orton Creek at the #1 and #9 Rice Fields Sheet pile stabilization landward of
wetlands is shown to contain additional backfill associated with the increase in dike elevation with no
concomitant fill of wetlands on the interior side of the dikes (See Sheet CO 1 for location and Sheet C14
for Cross Section Detail)
Additionally the applicant is proposing the re establishment of the five former nee fields (the Front
North Front South Back #1 and #9 Rice Fields) The thirteen existing water control structures would be
repaired or replaced the remaining dikes would also be rebuilt and fortified and the former nee fields
would be cleared graded and ditched in preparation of the resumption of nee production Five water
control structures would be replaced within either the Estuarine Shoreline or Public Trust Shoreline
AECs #3 (Sheet C3) #4 (Sheet C4) #7 (Sheet 0), #12 (Sheet C12) & #13 (Sheet C13) See Figures 6
&7 for a plan showing all existing water control structures and the drainage pattern for the system
Permanent access points are also proposed in each of the fields consisting of the installation of a culvert
and fill Proposed Field Access Points are also shown on Figure 7 with a typical plan view and cross

Orton Plantation Holdings, LLC c/o Peter Talty
Page 4
section shown on Sheet C14 This plan shows a maximum fill footprmt of 390 square feet for each of the
permanent field access sites All five rice fields would be cleared for rice production including mowing
stump pulling root raking harrowing and grading
The canals and quarter ditches would be excavated using the sidecast method with excavated material
leveled and spread onto the fields The applicant states some ditches may be filled and the excavation of
new ditches may be created in order to achieve uniform flooding of the fields
10 ANTICIPATED IMPACTS
Approximately 7,000 square feet (0 16 acres) of coastal wetlands would be filled as a result of this
project primarily in the intertidal Public Trust Area and Estuarine Waters AECs An additional 2 acres
(more or less) of open water Public Trust Area and Estuarine Waters would also be filled in association
with the nprap marsh revetment Approximately 2 55 acres of freshwater canals and approximately 2 41
acres of vegetated §404 wetlands would be filled in association with the proposed dike enhancements
(both on the interior and exterior sides of the dike) An additional 0 11 acre of §404 wetlands would also
be permanently filled as a result of the construction of the field access points Approximately 8 84 acres
of high ground would be filled/disturbed as a result of the proposed dike work The replacement of the
culverts would result in the fill of 2 5 square feet of coastal wetlands and approximately 95 square feet
of §404 wetlands
Approximately 320 16 acres of §404 wetlands within the diked areas would also be impacted from the
proposed project due to the clearing grading and other work related to resuming the production of rice
Temporary increases in turbidity should be expected to result
Submitted by Heather Coats Date 5/7/2012 Office Wilmington

I1- og1(.0
ORTON PLANTATION
Historic Rice Field Protection and Restoration
Cape Fear River
Brunswick County, NC
Orton Plantation Holdings, LLC
May 2012
Submitted to
North Carolina Division of Coastal Management
Unites States Army Corps of Engineers RECEIVED
Prepared by
At�LMG
LAND MANAGEMENT GROUP nre
Environmental Consultants
MAY 0 2 2012
®CM WILM114GTON NC

TABLE OF CONTENTS
Orton Plantation
Historic Rice Field Protection and Restoration Protect
Orton Plantation Holdings, LLC
Brunswick County, NC
Revised 5 -01 -12
I
Project Narrative
II
DCM MP 1
Rice Field Drainage Structure #1
III
DCM MP2
Figure C3
IV
DCM — MP5
Rice Field Drainage Structure #4
V
Figures (37 total)
Figure C6
Project Area Figures (Land Management Group Inc)
Figure C7
Figure 1
Vicinity Map
Rice Field Drainage Structure #8
Figure 2
USGS Topographic Map
Figure C10
Figure 3
NRCS Soils Map
Rice Field Drainage Structure #11
Figure 4
2009 Aerial Photograph
Figure C13
Figure 5
1949 Aerial Photography
Rice Field Drainage Structure Details
Figure 6
Historic Orton Rice Fields
Figure 7
Proposed Repair Areas and Field Access Points
Water Control Structure and Field Access Point Figures (Norris & Tunstall Consulting Engineers PC)
Figure CO
Dike Work Vicinity Map
Figure C1
Rice Field Drainage Structure #1
Figure C2
Rice Field Drainage Structure #2
Figure C3
Rice Field Drainage Structure #3
Figure C4
Rice Field Drainage Structure #4
Figure C5
Rice Field Drainage Structure #5
Figure C6
Rice Field Drainage Structure #6
Figure C7
Rice Field Drainage Structure #7
Figure C8
Rice Field Drainage Structure #8
Figure C9
Rice Field Drainage Structure #9
Figure C10
Rice Field Drainage Structure #10
Figure C11
Rice Field Drainage Structure #11
Figure C12
Rice Field Drainage Structure #12
Figure C13
Rice Field Drainage Structure #13
Figure C 14
Rice Field Drainage Structure Details
River Dike Rehabilitation Figures (Olsen Associates Inc)
Sheet 1
Location Map
Sheet 2
Concept Plan
Sheet 3
Detail Sheet Index
Sheet 4
Concept Plan Details
Sheet 5
Concept Plan Details
Sheet 6
Concept Plan Details
Sheet 7
Concept Plan Details
Sheet 8
Concept Plan Details
Sheet 9
Concept Plan Details

VI
Sheet 10
Concept Plan Details
Sheet 11
Concept Plan Details
Sheet 12
Concept Plan Details
Sheet 13
Concept Plan Details
Sheet 14
Concept Plan Details
Sheet 15
Concept Sections
Appendices
Appendix A
404 Wetland Survey and Jurisdictional Determination
Appendix B
NC Wetland Assessment Method (WAM)
Appendix C
The Rice Coast Article
Appendix D
Project Purpose Supplement
Appendix E
Olsen Associates Memorandum
Appendix F
Shoreline Erosion Aerial
Appendix G
Avoidance and Minimization Proposal

PROJECT NARRATIVE
ORTON PLANTATION
HISTORIC RICE FIELD PROTECTION
AND
RESTORATION PROJECT
Cape Fear River
Brunswick County, North Carolina
5/1/12
I Introduction
Orton Plantation Holdings LLC (OPH) is submitting a NC Division of Coastal Management
(DCM) application for a mayor modification of their existing CAMA Mayor Permit number
65 02 for proposed activities to protect and restore the various elements of the historic nee
field system at Orton Plantation Note that the owner submitted an application for a US Army
Corps of Engineers (COE) Individual Permit (IP) on September 13 2011 for these activities
associated with the rehabilitation and operation of the nee field system The activities
include rehabilitation of the nee field dike revetment along an approximate 7 700 linear foot
(ft) segment of the shoreline of Orton Plantation adjacent to the Cape Fear River, repair and
reinforcement of other nee field embankments repair and replacement of structures
controlling water flows through the nee fields, and field preparation activities associated with
the resumption of nee cultivation
Orton Plantation received a CAMA Mayor Permit in 2002 (No 65 02) for the long term
maintenance of the existing nee field berms (dikes) for the protection of the historic nee
fields The LAMA Mayor Permit was renewed and modified through time and transferred to
the current ownership Orton Plantation Holdings LLC on March 17 2011 CAMA General
Permit No 56605 was issued in May 2011 for repairs to an existing entrance road culvert A
Corps of Engineers Nationwide 3 Permit (SAW 2011 00624) was issued in March 2012 for
the repair of a breach in the #1 Rice Field dike
II Protect Purpose
As stated in the COE IP application the purpose of the proposed project is to protect and
restore the various elements of the historic nee field system at Orton Plantation (See
Appendix D Project Purpose Supplement ) In order to achieve the scope of the project
purpose specific needs have been identified In particular in order to protect the front nee
fields from erosive forces of the Cape Fear River (especially from ship generated waves from
the nearby federal Wilmington Harbor Channel), the outer dike system needs to be to
restored, enhanced, and stabilized for a length of up to 7,700 feet, more or less along the
nverfront Note that this includes portions of the dike that exist along the banks of Orton
Creek and the Orton Pond spillway (refer to the attached Project Design Drawings)

In order to protect the remainder of the front nee fields as well as the #1 and #9 nee fields,
the existing earthen dikes need to be repaired and their crests re contoured to their pre
existing elevation There is also a need to supplement this field protection with the
installation of sheet pile on the outer slope of the dikes Several erosional areas have formed
and the reinforcement of these and future erosional areas as they develop is essential for the
protection and preservation of the historic nee fields
Thirteen water control structures have been identified that need to be repaired or replaced
The management of fresh water flows between the nee fields is critical to the success of the
restored agricultural operation
Additional Section 404/401 authorization is also being sought (via the COE IP application)
for activities within the fields that need to be performed to reinitiate nee cultivation These
activities include clearing of vegetation, maintenance and reestablishment of canal and
quarter ditch network, installation of thirteen permanent field equipment access points across
canals, installation of temporary quarter ditch crossing points and grading and leveling of
field surfaces including the spreading of material removed from the canal and ditch network
III Orton Plantation History
Title to the original Orton Plantation originated in a grant from the eight Lords Proprietor in
1725 Development of the nee plantation began in 1725, including the installation of the
gravity water system from Orton Pond The water management system on the remaining nee
fields is still in place having been continuously maintained by a series of owners although
components of the system have been repaired and replaced over the years with more modern
materials The design, however including the pattern of dikes, nee trunks irrigation canals
and interior irrigation ditches remains essentially the same as the original
The source of fresh water for the system is Orton Pond an 800 acre reservoir created by a
dam constructed in the first half of the eighteenth century Rice was continuously
commercially cultivated at Orton Plantation from the early 1700s to the 1930s with some
interruptions, notably during the Civil War In the post Depression years some of the nee
fields were managed as a wildlife refuge, using them to cultivate freshwater crops as a food
source for waterfowl including a period of contractual management by the NC Wildlife
Resources Commission beginning in the 1970s
In November of 2010 the property was purchased by the applicant Orton Plantation
Holdings LLC the principal of which is a direct descendant of Roger Moore developer of
the original Orton Plantation The applicants objective is to perform historic restoration
work at the plantation In support of this effort the owner recently submitted a nomination
request to the National Park Service for consideration of Orton Plantation to be registered as
a National Historic Landmark (see Appendix D) In addition the owner is actively
coordinating with the NC State Historic Preservation Office (SHPO) as part of the restoration
effort for the plantation
Orton Plantation Historic Rice Field Protection and Restoration Project 2
Mayor Modification to CAMA Mayor Permit # 65 02

IV Existing Conditions of Rice Field System
The portion of Orton Plantation functionally related to the proposed project is some 700 acres
in size and is located east of NC Hwy 133 and Plantation Road between Orton Creek to the
north and the Brunswick Town State Historic Site to the south The Cape Fear River and its
unnamed tributaries in this location are classified by the NC Division of Water Quality
(DWQ) as SC According to DWQ SC waters are tidal salt waters with suitable uses of
aquatic life propagation and survival fishing, wildlife and secondary recreation The
adjacent marshes and shallow bottom habitat have not been classified as Primary Nursery
Area (PNA) by the NC Division of Marine Fisheries Jurisdictional 404 wetlands were field
delineated within this portion of the plantation The delineation was inspected and approved
by the COE The COE issued a Notification of Jurisdictional Determination and signed the
wetland delineation survey on August 22 2011
The existing individual rice fields at Orton are denoted as the back rice field the #1 and #9
rice fields, and the north and south front rice fields The rice field irrigation ditch layout
consists of larger nm or feeder ditches that supply the majority of fresh water to the smaller
quarter ditches The quarter ditches are generally 55 apart and parallel to each other in
orientation throughout these fields The quarter ditches function to distribute water in a
uniform, non erosive manner to the interior of the fields Remnants of these quarter ditches
are still visible throughout the fields, but they are most distinct in past aerial photography
Currently, the interior areas of the rice fields are in various stages of vegetative succession
The back rice field contains wetland species predominantly in the herbaceous and
shrub /sapling strata with a few isolated taller trees based on the timing and extent of past
field activities The #1 and #9 rice fields contain a mixture of wetland herbaceous and shrub
vegetation The north and south rice fields are essentially completely herbaceous in nature
with Phragmites austrahs as the overwhelmingly dominant wetland species All of the
subject fields are located within the delineated, surveyed and approved jurisdictional 404
wetland limits Wetland areas on the exterior of rice field dikes adjacent to the Cape Fear
River Orton Creek and the Orton Pond Spillway are dominated by coastal wetland
vegetation species
The eastern edge of the front rice fields are separated from the Cape Fear River by a 162
mile (8,600 feet) long low crested narrow earthen dike This dike which records indicate
was initially constructed more than 250 years ago originally was sited well inland of the
Cape Fear River shoreline and somewhat protected from the river by a wider tidal wetland
area Historic aerial photography dating back to 1939 indicates that through at least 1956
there had been a continuous coastal marsh fringe facing the river that was roughly 100 to
200 wide More recently, the once stable marsh shoreline has become unstable and in places,
has eroded severely The central portion of the north front rice field revetment forms a
rounded headland with the COE maintained shipping channel at its closest approach
approximately 450 feet offshore Today this portion of the marsh fringe has experienced
such severe erosion that any energy dissipation function offered by the marsh fringe (and
concurrent protection for the dike) is largely non existent The marsh continues to actively
erode as evidenced by sections of coastal wetland vegetation (including the attached root mat
Orton Plantation Historic Rice Field Protection and Restoration Project 3
Mayor Modification to CAMA Mayor Permit # 65 02

r-
substrate) being detached In a comparison of digitized aerial photography between 1998 and
2012 marsh lost to erosion along the Orton riverfront shoreline totaled approximately 7 8
acres during that 14 year period (see Appendix F, Shoreline Erosion Aerial) The most rapid
erosion over that time period and previously was located along the headland and the southern
erosional area Loss of the marsh especially in the headland area has exacerbated the
erosional effects on the dike As such areas of the dike which were not constructed to
withstand the direct effect of the river s hydraulic forces, are now exposed to very different
conditions than those which existed at the time the dike was constructed at its current
location NC WAM evaluations done as part of the COE IP permit process confirm the effect
of this erosion since the wider salt marsh areas rate overall High with NC WAM and the
narrower eroding sections rate only overall Medium The revised design requests revetment
related salt marsh impacts in only the two areas of the dike that have experienced severe
recent erosion (as shown on Appendix F, which is a composite of the shoreline limits over
time)
Efforts to protect and repair the dikes over the past 30 years have included the placement of
concrete debris as np rap armoring and construction of localized retaining walls made of
wood steel, plastic and concrete However the past protective measures were not designed
engineered or constructed in a manner sufficient to last and to protect the revetment from the
increasingly severe erosional forces associated with the river and federal navigation channel
V Proposed Pro]ect
A Front Race Field Dike Rehabilitation /Enhancement
In general this portion of the project will include repairs to eroded portions of the dike, an
increase in the overall elevation of the existing dike to ensure the reduction or elimination of
wake /wave overtopping; enhancement and re vegetation of the interior slope of the dike, as
well as reconstruction and stabilization of the seaward face of the dike The existing dike
elevation is +4 5 to +6 NAVD The proposed dike elevation is +9 NAVD The total length
of the proposed revetment sections is approximately 1 700 lft with a riverside slope of 2 1
and a rice field side slope of 1 5 1 The improvements will also include the installation of
sheet pile panels within the core of the dike The upper surface of the enhanced dike and
revetment sections will be stabilized with np rap and/or gabion type matting to minimize
erosion of the upper crest of the formed revetment during high water events As illustrated on
the enclosed materials the length of the combined proposed enhanced dike and dike
revetment is approximately 7,700 feet Structure widths vary depending on the current level
of exposure to forces of the Cape Fear River The wider sections /revetments are to be located
along the headland shoulders where erosional impacts against the dike are the most severe
and where protective tidal marsh has either completely eroded away or has been significantly
diminished Generally, where a significant tidal marsh fringe is continuous to the north and
south of the headland area and between the proposed revetment sections a narrower section
of dike enhancement is proposed In areas with some beneficial marsh buffer still in place
the dike-will be enhanced by increasing its elevation and extending its width landward (to the
interior nce field, refer to attached drawings) rather than seaward As described in Section
VI below this method of dike enhancement reduces the extent of coastal wetland impacts
Orton Plantation Historic Rice Field Protection and Restoration Project 4
Mayor Modification to CAMA Mayor Permit # 65 02

To afford a greater level of protection to some of the dike revetment/enhancement transition
areas and the shoreline between the revetment sections on the headland as well as the
southern erosional area, marsh edge stabilization is proposed Marsh escarpment will be
stabilized using np rap or similar material (refer to attached drawings) The marsh edge
stabilization will be low profile and is intended to reduce the rate of marsh loss within
selected locations of the diked shoreline The existing elevation of the outer marsh edge is
+1 5 to +3 0 NAVD The proposed crest elevation of the marsh edge stabilization armor is
+3 5 NAVD or +18 MHW This planned crest elevation was selected from guidance for
high energy shorelines (VIMS 2006) This elevation is set relative to the tidal datums and
not the elevation of the marsh Since the marsh elevation vanes so will the distance between
the marsh elevation and the crest of the marsh armor A constant elevation of the marsh
armor crest is important in this setting due to the ship wave effects Such effects are not
common to other shorelines in NC where the armoring may exist
B Repair and Reinforcement of Other Rice Field Embankments
The proposed work on nce field dikes beyond the proposed front nce field dike enhancement
and revetment sections (the remainder of front nce field #1 and #9 nce fields) involves the
reinforcement of earthen dike areas through the contouring of dike crests to their pre existing
elevation and the installation of sheet pile with backfill, as necessary above the established
wetland boundary Earthen material will be placed in potential erosion areas along these
dikes as necessary and added to the top of the dikes for strengthening
C Water Control Structure Repair and Replacement
Orton s unique water control system from the Orton Pond reserve to the outlying nce fields
features numerous water control structures in the form of managed spillway gates gate
valves culvert pipes with and without flap gates and wooden nce trunks Authorization for
repair and replacement of thirteen (13) water control structures is requested in this
application The enclosed materials detail work to be done at each of the structure locations
In general, the structures will be repaired or replaced in their existing positions It should be
noted that the former structure controlling water flows between the north and south front nce
field along the existing cross dike could not be precisely located It is evident however that a
cross dike conduit existed, as it would have provided the only source of irrigation water to
the south front nce field so a replacement structure is proposed for this purpose
Most of the water control structures are bounded by wooden bulkheads (or retaining walls) in
various conditions The replacement and repair of the control structures will also require the
partial or complete dismantling and repair or replacement of these short lengths of
bulkheading Reconstructed bulkheads will be backfilled
D Rice Field Area Preparation
Clearing the nce fields of vegetation will be performed to produce a plantable surface
Methods of clearing will include mowing, stump pulling, root raking harrowing and surface
grading All methods may not be employed in all fields Vegetation debris will be piled and
burned The remaining ash will be spread over the fields and incorporated into the soil
Orton Plantation Historic Rice Field Protection and Restoration Project 5
Mayor Modification to CAMA Mayor Permit # 65 02

The canal and quarter ditch system will be maintained and reestablished through the
excavation of material from the existing canals and ditches primarily with a V shaped
excavator bucket Some existing ditches may be filled and some new ditches may be
constructed, depending on the variability of water distribution needs within the landscape
Excavated material will be temporarily sidecast onto the ditch shoulder and then spread
evenly over the field surface Final overall field surface grading and leveling will be
performed to assure uniform water distribution and flooding over the site
Permanent machinery access points to the surface of the rice fields will be installed in
thirteen (13) locations These access points typically will consist of the installation of a
culvert placed in the bottom of a canal or ditch with fill placed on top to produce a stable,
drivable surface Temporary machinery crossing points will be employed from time to time
in quarter ditches while field work is underway They will also consist of a buried culvert
with a drivable surface These crossings will be removed when field activities cease
VI Wetland Impacts
A Avoidance of Wetland Impacts
The applicant has avoided impacts to wetlands (including coastal wetlands) to the maximum
extent practicable Due to the nature of the work and the need to stabilize and rehabilitate
existing dikes activities necessarily involve work within wetland areas As a result, some
wetland impacts remain unavoidable
B Minimization of Wetland Impacts
The proposed protection and restoration of the existing historic nce field system is defined by
the current confining dike system and limits of the rice fields as depicted The applicant is
not seeking to re establish the much larger extent of rice fields that was once present to the
north and stretching upstream along Liliput Creek Remnants of that once existing dike
system and its canal and quarter ditch system can be readily observed in older aerial
photography as well as the remains of the fresh water reserve dam breast to the west
Past repeated dike protection efforts along the Cape Fear River effectively demonstrate that a
substantial structure is required to withstand the erosional forces of the Cape Fear River and
federal Wilmington Harbor Channel The size and mass of the revetment sections and
enhanced dike areas are critical for effective protection Consideration is also given to the
fact that much of the coastal and 404 wetland fringe facing the river has exhibited significant
erosion from ship generated waves Refer to the attached figure depicting the location of the
marsh edge over time (Appendix F)
Under the original submittal to NC DCM and the COE (former Table 1) the proposed plan
included 8 6 acres of permanent impacts to jurisdictional wetlands and waters Of this total
quantity 2 9 acres were 404 wetlands 15 acres were 404 /coastal wetlands, 0 3 acres were
surface rice field 404 wetlands 2 3 acres were fresh water canals (within nce fields) and 16
acres were open waters of the Cape Fear River An additional area of 2 5 acres of open river
waters was requested to be authorized for the potential future widening of the entire
revetment to the width dimensions of the headland area cross section
Orton Plantation Historic Rice Field Protection and Restoration Project 6
Mayor Modification to CAMA Mayor Permit # 65 02

However upon further coordination with NC DCM as well as other regulatory and resource
agencies the Applicant identified an alternative that further minimizes its permanent impacts
on wetlands by scaling back the revetment work from the entire dike facing the Cape Fear
River to only those two portions which are most immediately threatened by severe erosion
The method of dike rehabilitation along the river includes a combination of dike revetments
dike enhancement (via extending the width of the dike to the interior rice field) and marsh
edge stabilization These types of shoreline protection overlap in certain areas Beyond each
end of the revetment sections on the headland (Sheets 6, 7, 8, and 9 of 15) and along the
southern erosional area (Sheets 13 and 14 of 15) a length of marsh edge stabilization extends
in front of areas of dike enhancement The total length of the revetments is approximately
1700 Ift The total length of the dike enhancement areas is approximately 5 9001ft The total
length of the marsh edge stabilization areas is approximately 1940 Ift
Table 1 Impact Summary (Onizinal Submittal vs March/Apnl 2012 Design Modifications)
Impact Type
Original Plan
(acres)
March/Aprd2012 Design
Modifications (acres)
% Change
404 Wetlands
333
241
28%
404 /Coastal Wetlands
150
016
89%
Freshwater Canals
230
255
+11%
Open Water
160
200
+25%
As indicated above the applicant has reduced wetland (including coastal wetland) impacts to
the maximum extent practicable The relatively small area (0 16 acre) of coastal wetlands to
be disturbed is necessary to allow for transitions of the dike revetment to the dike
enhancement areas These transitions extend into areas where the remaining coastal marsh
fringe is very narrow and highly unstable In these transition areas the remaining coastal
marsh is littered with rock or concrete chunks overturned marsh mat substrate due to large
ship wakes or the marsh fringe is very narrow and actively eroding Recall the 7 8 acres lost
to erosion between 1998 and 2012 Please refer to the attached memorandum from Olsen
Associates Inc the project engineer further describing the need for coastal wetland
disturbance at these locations
The water control structure repair and replacement work mainly involves the replacement of
structures within their existing footprints with no resulting permanent wetland impact area
Minimal permanent wetland impacts will occur in association with the replacement of
Structure #5 where the pipe will be replaced and enlarged and the former bulkheads on either
end will be reconstructed The backfill of the bulkheads here will result in 75 square feet
(0 002 acres) of 404 wetland impact The installation of Structure #8, since the former
structure was not precisely located will result in a minimal 16 5 (0 0004 acres) square feet of
404 wetland impact At structures #4 and #13, replacement pipes will increase in diameter
from 12 to 18 and 9 to 12 respectively These increases result in a total of 2 5 square feet
of coastal wetland impact and 4 7 square feet of 404 wetland impact
Orton Plantation Historic Rice Field Protection and Restoration Project 7
Mayor Modification to CAMA Mayor Permit # 65 02

The permanent field access points will have a maximum wetlands /waters fill dimension of
26 x15 or 390 square feet at each location The total maximum permanent wetlands /waters
impact area for the thirteen (13) access points is 5 070 square feet (0 12 acres) This minimal
amount of impact area will allow for safe and efficient farm equipment access to various
segments of the rice field system It should be noted that as a result of comments received at
the 3/28/12 inter agency meeting concerning the Corps Individual Permit the applicant has
further minimized the farmed rice field extent (temporary wetland impacts) by some 13 1
acres in the Back Rice Field and the #9 Rice Field (see attached Rice Field Exclusion Areas
sheet and 4/11/12 Avoidance and Minimization Proposal) This resulted in the reduction
from 14 to 13 _field access points needed and the reduction of those permanent wetland
impacts by 0 009 acres
Refer to Table 1 for a summary of the change in wetland/waters impacts resulting from the
recent design modifications Of particular note is the reduction of impacts to both coastal
wetlands (89% reduction) and Section 404 wetlands (28% reduction)
Beyond the permanent wetland impacts for field access points and water control structure
replacement the described preparation of the rice fields themselves will temporarily affect
virtually all of the wetlands and waters within those fields a total of 317 60 acres (following
the described recent design modifications) However the nce fields will continue to remain
wetlands managed by the water control system The irrigation canal /ditch restoration will
involve the sidecastmg and spreading of material across the fields but the resulting thin
veneer of fill will not effect a conversion of these fields to uplands even on a temporary
basis Further, the ability to flood the fields remains as it has throughout the history of the
plantation The fields were and will be wetlands managed for agriculture and impacts are
considered to be temporary
C Compensatory Wetland Mitigation
Given the reduction of the extent of wetland impacts the Applicant no longer proposes to
conduct coastal marsh restoration on site Rather, the applicant will seek to purchase credits
from either the North Carolina Ecosystem Enhancement Program (EEP) or an approved
wetland mitigation bank to provide for adequate compensatory mitigation for unavoidable
impacts to jurisdictional wetlands Final types and quantities will be further determined
through the COE review and processing of the IP application
VII Contact Information
Orton Plantation Historic Rice Field Protection and Restoration Project 8
Mayor Modification to CAMA Mayor Permit # 65 02

All review agency questions and comments regarding this submittal should be directed to
Land Management Group Inc
Attn Orton Project
P O Box 2522
Wilmington NC 28405
Phone [phone]
Email smomson @lmgroup net
Orton Plantation Historic Rice Field Protection and Restoration Project 9
Mayor Modification to CAMA Mayor Permit # 65 02

DCM MP -1
APPLICATION for
Major Development
(last revised 12/27/06)
Permit
North Carolina DIVISION OF COASTAL MANAGEMENT
1 Primary Applicant/ Landowner Information
Business Name
Project Name (if applicable)
Orton Plantation Holdings Lic
Orton Plantation
Applicant 1 First Name
MI
Last Name
Last Name
Peter
Steve
Talty
Morrison
Applicant 2 First Name
MI
Last Name
Last Name
If additional applicants please attach an additional page(s) with names listed
Jenny
Mailing Address
PO Box
City
Mailing Address
State
17th Floor 1251 Avenue of the Americas
NA
New York
State
NY
ZIP
Country
Phone No
Wilmington
NC
FAX No
10020
USA
212 782
6295 ext NA
Phone No 2
NA
Street Address (if different from above)
City
State
ZIP
NA
Na
NA
NA
Email
Street Address (if different from above)
peter talty @bllc corn
City
State
2 Agent/Contractor Information
Business Name
Land Management Group Inc
Agent/ Contractor 1 First Name
MI
Last Name
Steve
Morrison
Agent/ Contractor 2 First Name
MI
Last Name
Jenny
Johnson
Mailing Address
PO Box
City
State
PO BOX
2522
Wilmington
NC
ZIP
Phone No 1
Phone No 2
28402
910 452
0001 ext
ext
FAX No
Contractor #
910 452 0060
Street Address (if different from above)
City
State
ZIP
3805 Wrightsville Ave
Wilmington
NC
28403
Email
smorrison @lmgoup net
<Form continues on back>

Form DCM MP 1 (Page 2 of 4)
APPLICATION for
Major Development Permit
3 Project Location
County (can be multiple)
Street Address
State Rd #
Brunswick
9149 Orton Road SE
NA
Subdivision Name
City
State
Zip
Orton Plantation
Wmnabow
NC
28479
Phone No
Lot No (s) (if many attach additional page with list)
NA ext
NA
a In which NC river basin is the project located?
b Name of body of water nearest to proposed project
-,eAi�
Orton Creek Cape Fear River
c Is the water body identified in (b) above natural or manmade?
d Name the closest major water body to the proposed project site
®Natural []Manmade ❑Unknown
Cape Fear River
e Is proposed work within city limits or planning jurisdiction?
f If applicable list the planning jurisdiction or city limit the proposed
❑Yes ®No
work falls within
NA
4
Site Description
a
Total length of shoreline on the tract (ft )
b Size of entire tract (sq ft )
over 11 000 feet
700 ac project area
c
Size of individual lot(s)
d Approximate elevation of tract above NHW (normal high water) or
NA
NWL (normal water level)
(If many lot sizes please attach additional page with a list)
020 ®NHW or ❑NWL
e
Vegetation on tract
Interior rice fields wetland herbaceous and shrub vegetation
Back rice field wetland herbaceous shrub sapling and tree strata
North and South rice fields wetland herbaceous species
Dike Orton Creek shoreline coastal wetland vegetation
f
Man made features and uses now on tract
Orton was developed as a rice plantation in 1725 inlcuding the gravity water system (dikes rice trunks irrigation canals
interior irrigation ditches ponds) which has been maintained and updated since original construction Additional man made
features include a plantation home with guest houses extensive gardens chapel and maintenance sheds
g
Identify and describe the existing land uses adjacent to the proposed project site
Undeveloped residential properties private cemetary Brunswick Town State Historic Site
h
How does local government zone the tract?
i Is the proposed project consistent with the applicable zoning?
CO RR Rural Low Density Development
(Attach zoning compliance certificate if applicable)
®Yes []No ❑NA
j
Is the proposed activity part of an urban waterfront redevelopment proposal? ❑Yes ®No
k
Has a professional archaeological assessment been done for the tract? If yes attach a copy ❑Yes ❑No [DNA
If yes by whom?
I
Is the proposed project located in a National Registered Historic District or does it involve a ®Yes ❑No ❑NA
National Register listed or eligible property?
<Form continues on next page>

Form DCM MP 1 (Page 3 of 4)
APPLICATION for
Mayor Development Permit
m (i) Are there wetlands on the site? NYes ❑No
(n) Are there coastal wetlands on the site? NYes ❑No
(iii) If yes to either (i) or (n) above has a delineation been conducted? NYes ❑No
(Attach documentation if available)
n Describe existing wastewater treatment facilities
On site septic
o Describe existing drinking water supply source
On site wells
p Describe existing storm water management or treatment systems
No on site stormwater treatment systems
5 Activities and Impacts
a
Will the project be for commercial public or private use? ❑Commercial ❑Public/Government
NPnvate /Community
b
Give a brief description of purpose use and daily operations of the project when complete
The purpose is to protect and restore the various elements of the historic nce field system at Orton Plantation Upon
completion the rice fields will be returned to operational status The plantation home and gardens will remain private use
c
Describe the proposed construction methodology types of construction equipment to be used during construction the number of each type
of equipment and where it is to be stored
Standard construction methods and equipment
Land based equipment to be strored on upland portions of the property Water based equipment to be stored on barge or
boat
d
List all development activities you propose
Construction of a permanent revetment along the Cape Fear River repair and reinforcement of rice field embankments
repair or replacement of water control structures field preparation activities for the resumption of farming
e
Are the proposed activities maintenance of an existing project new work or both? maintenance
f
What is the approximate total disturbed land area resulting from the proposed project? —345 ❑Sq Ft or ®Acres
g
Will the proposed project encroach on any public easement public accessway or other area NYes ❑No ❑NA
that the public has established use of?
h
Descnbe location and type of existing and proposed discharges to waters of the state
Rice field dikes ditches and fields for purposes of field protection /restoration and resumption of agriculture
i
Will wastewater or stormwater be discharged into a wetland? ❑Yes []No NNA
If yes will this discharged water be of the same salinity as the receiving water? ❑Yes ❑No NNA
l
Is there any mitigation proposed? NYes ❑No ❑NA
If yes attach a mitigation proposal
<Form continues on back>
I 9

Form DCM MP 1 (Page 4 of 4)
APPLICATION for
Major Development Permit
6
Additional Information
In
addition to this completed application form (MP 1) the following items below if applicable must be submitted in order for the application
package to be complete Items (a) — (f) are always applicable to any mayor development application Please consult the application
Instruction booklet on how to properly prepare the required items below
a
A project narrative
b
An accurate dated work plat (including plan view and cross sectional drawings) drawn to scale Please give the present status of the
proposed project Is any portion already complete? If previously authorized work clearly indicate on maps plats drawings to distinguish
between work completed and proposed
c
A site or location map that is sufficiently detailed to guide agency personnel unfamiliar with the area to the site
d
A copy of the deed (with state application only) or other instrument under which the applicant claims title to the affected properties
e
The appropriate application fee Check or money order made payable to DENR
f
A list of the names and complete addresses of the adjacent waterfront (riparian) landowners and signed return receipts as proof that such
owners have received a copy of the application and plats by certified mad Such landowners must be advised that they have 30 days in
which to submit comments on the proposed project to the Division of Coastal Management
Name NC Department of Transportation Phone No
Address 300 Division Road Wilmington NC 28401
Name State of North Carolina State Property Office Phone No
Address 116W Jones St Raleigh NC 27603
Name Phone No
Address
g
A list of previous state or federal permits issued for work on the project tract Include permit numbers permittee and issuing dates
SAW 2011 00624 COE Jurisdictional Determination Orton CAMA General Permit No 56605 DCM Orton Plantation
Plantation Holdings LLC 8/22/11 Holdings LLC 5/26/11
CAMA Major Permit No 65 02 DCM Transfer to Orton SAW 2011 00624 COE Nationwide 3 Permit Orton Plantation
Plantation Holdings LLC 3/17/11 Holdings LLC March 2012
h
Signed consultant or agent authorization form if applicable
i
Wetland delineation if necessary
j
A signed AEC hazard notice for projects in oceanfront and inlet areas (Must be signed by property owner)
k
A statement of compliance with the N C Environmental Policy Act (N C G S 113A 1 10) if necessary If the project involves expenditure
of public funds or use of public lands attach a statement documenting compliance with the North Carolina Environmental Policy Act
7 Certification and Permission to Enter on Land
I understand that any permit issued in response to this application will allow only the development described in the application
The project will be subject to the conditions and restrictions contained in the permit
I certify that I am authorized to grant and do in fact grant permission to representatives of state and federal review agencies to
enter on the aforementioned lands in connection with evaluating information related to this permit application and follow up
monitoring of the project
I further certify that the information provided in this application is truthful to the best of my knowledge
Date �' �� �Z Print Name V '
�r �nm, � 6 has b✓l.
Signature I/ 441,", y ttct
Please indicate application attachments pertaining to your proposed project
®DCM MP 2 Excavation and Fill Information ®DCM MP 5 Bridges and Culverts
❑DCM MP 3 Upland Development
❑DCM MP 4 Structures Information

Form DCM MP 2
EXCAVATION and FILL
(Except for bridges and culverts)
Attach this form to Joint Application for CAMA Mayor Permit Form DCM MP 1 Be sure to complete all other sections of the Joint
Application that relate to this proposed project Please include all supplemental information
Describe below the purpose of proposed excavation and /or fill activities All values should be given in feet
1 EXCAVATION [D This section not applicable
a Amount of material to be excavated from below NHW or NWL in b Type of material to be excavated
cubic yards
(i) Does the area to be excavated include coastal wetlands /marsh d High ground excavation in cubic yards
(CW) submerged aquatic vegetation (SAV) shell bottom (SB)
or other wetlands (WL)? If any boxes are checked provide the
number of square feet affected
❑CW ❑SAV ❑SB
❑WL ❑None
(u) Describe the purpose of the excavation in these areas
12 DISPOSAL OF EXCAVATED MATERIAL ® This section not applicable
a Location of disposal area b Dimensions of disposal area
c (i) Do you claim title to disposal area?
❑Yes ❑No ❑NA
(u) If no attach a letter granting permission from the owner
e (i) Does the disposal area include any coastal wetlands /marsh
(CW) submerged aquatic vegetation (SAV) shell bottom (SB)
or other wetlands (WL)? If any boxes are checked provide the
number of square feet affected
❑CW ❑SAV ❑SB
OWL ❑None
(u) Describe the purpose of disposal in these areas
d (i) Will a disposal area be available for future maintenance?
❑Yes ❑No ❑NA
(u) If yes where?
f (i) Does the disposal include any area in the water?
❑Yes ❑No ❑NA
(n) If yes how much water area is affected?
Access
Other
Channel
(NLW or
Canal
Boat Basin
Boat Ramp
Rock Groin
Rock
Breakwater
(excluding
shoreline
NWL)
stabilization)
1 940
Length
marsh armor
15 30 max
Width
marsh armor
Avg Existing
NA
NA
Depth
Final Project
NA
NA
Depth
1 EXCAVATION [D This section not applicable
a Amount of material to be excavated from below NHW or NWL in b Type of material to be excavated
cubic yards
(i) Does the area to be excavated include coastal wetlands /marsh d High ground excavation in cubic yards
(CW) submerged aquatic vegetation (SAV) shell bottom (SB)
or other wetlands (WL)? If any boxes are checked provide the
number of square feet affected
❑CW ❑SAV ❑SB
❑WL ❑None
(u) Describe the purpose of the excavation in these areas
12 DISPOSAL OF EXCAVATED MATERIAL ® This section not applicable
a Location of disposal area b Dimensions of disposal area
c (i) Do you claim title to disposal area?
❑Yes ❑No ❑NA
(u) If no attach a letter granting permission from the owner
e (i) Does the disposal area include any coastal wetlands /marsh
(CW) submerged aquatic vegetation (SAV) shell bottom (SB)
or other wetlands (WL)? If any boxes are checked provide the
number of square feet affected
❑CW ❑SAV ❑SB
OWL ❑None
(u) Describe the purpose of disposal in these areas
d (i) Will a disposal area be available for future maintenance?
❑Yes ❑No ❑NA
(u) If yes where?
f (i) Does the disposal include any area in the water?
❑Yes ❑No ❑NA
(n) If yes how much water area is affected?

3 SHORELINE STABILIZATION [I This section not applicable
(If development is a wood groin use MP 4 — Structures)
a Type of shoreline stabilization
® Q eVdhV A
Bulkhead NRiprap Breakwater /Sill ❑Other _
�atn- I�IvOVt� I A
Dt Mosh Avm t d
✓
c Average distance waterward of NHW or NWL 30 for revetment
80 for marsh armor dike enhancement and non riverfront dike
improvement are above MHW
e Type of stabilization material
Rock nprap sheetpde
g Number of square feet of fill to be placed below water level
Bulkhead backfill Riprap — 88,430 sf
Breakwater/Sill Other
I Source of fill material
Contractor supplied material
b Lengtn a o avu Me ennancernent, u 1,1uv reveuncm, c
1,940 marsh armor, d 3,300 non riverfront dike improvement
(See Olsen Sheet 2 of 15)
Width a 0 27 max, b 0-43 max, c 15 30 max, d 15 35 max
d Maximum distance waterward of NHW or NWL 40 for revetment
200 for marsh armor
(i) Has there been shoreline erosion during preceding 12
months?
®Yes []No F1 NA
(n) If yes state amount of erosion and source of erosion amount
information
Estimated up to 10 in one year Source of erosion is waves
and ship wakes
h Type of fill material
Rock and earthen fill
Total upland disturbed area for rice field dike work= —8 84 acres
Activity was deemed agricultural and exempt from erosion and
sedimentation permitting by Land Quality Section
4 OTHER FILL ACTIVITIES [I This section not applicable
(Excluding Shoreline Stabilization)
a 6) Will fill material be brought to the site? ®Yes ❑No ❑NA b (i) Will fill material be placed in coastal wetlands /marsh (CW)
If yes
(n) Amount of material to be placed in the water NA
(m) Dimensions of fill area 317 60 ac temporary disturbance,
0 11 ac fill
(iv) Purpose of fill
Temporary disturbance impacts are for rice field
preparation Permanent 0 11 ac fill for field access points
and water control structure replacement
submerged aquatic vegetation (SAV) shell bottom (SB) or
other wetlands (WL)? If any boxes are checked provide the
number of square feet affected
❑CW ❑SAV ❑SB
®WL 317 60 ac temporary disturbance, 0 11 ac permanent
fill ❑None
(n) Describe the purpose of the fill in these areas
Temporary disturbance impacts are for rice field preparation
Permanent 0 11 ac fill for field access points and water control
structure replacement
5 GENERAL
a How will excavated or fill material be kept on site and erosion b What type of construction equipment will be used (e g draglme
controlled? backhoe or hydraulic dredge)?
Geotextile fabric nprap Trackhoe dumptrucks
c (i) Will navigational aids be required as a result of the project?
❑Yes ®No ❑NA
(n) If yes explain what type and how they will be implemented
d (i) Will wetlands be crossed in transporting equipment to project
site? []Yes ®No ❑NA
(n) If yes explain steps that will be taken to avoid or minimize
environmental impacts

6--1 -1 (/
Date
Orton Plantation
Project Name
Orton Plantation Holdings LLC
Applicant Name
Applicant SAInature

Form DCM MP -5
BRIDGES and CULVERTS
Attach this form to Joint Application for CAMA Major Permit Form DCM MP 1 Be sure to complete all other sections of the Joint
Application that relate to this proposed project Please include all supplemental information
1 BRIDGES ®This section not applicable
a Is the proposed bridge
❑Commercial ❑Public/Government ❑Private /Community
c Type of bridge (construction material)
e (i) Will proposed bridge replace an existing bridge> []Yes ❑No
If yes
(u) Length of existing bridge
(w) Width of existing bridge
(iv) Navigation clearance underneath existing bridge
(v) Will all or a part of the existing bridge be removed?
(Explain)
b Water body to be crossed by bridge
d Water depth at the proposed crossing at NLW or NWL
f (Q Will proposed bridge replace an existing culvert? []Yes ❑No
If yes
(u) Length of existing culvert
(m) Width of existing culvert
(iv) Height of the top of the existing culvert above the NHW or
NWL
(v) Will all or a part of the existing culvert be removed?
(Explain)
9 Length of proposed bridge h Width of proposed bridge
i Will the proposed bridge affect existing water flow? []Yes ❑No t Will the proposed bridge affect navigation by reducing or
If yes explain increasing the existing navigable opening? ❑Yes ❑No
If yes explain
k Navigation clearance underneath proposed bridge I Have you contacted the U S Coast Guard concerning their
approval? ❑Yes []No
If yes explain
m Will the proposed bridge cross wetlands containing no navigable n Height of proposed bridge above wetlands
waters? ❑Yes ❑No
If yes explain
2 CULVERTS [I This section not applicable
a Number of culverts proposed 27 b Water body in which the culvert is to be placed
Connections between freshwater Irrigation canals and /or
ditches (C1 C2 C5 C6 C8 C9 C10 C11) Connections
between freshwater irrigation canals and /or ditches and
tidal waters (C3 C4 C12 C13 to Orton Creek C7 to Orton
Pond Spillway)

< Form continues on back>
c Type of culvert (construction material)
pvc pipe (13) wooden nce trunk (3) concrete or steel pipe (14)
d (i) Will proposed culvert replace an existing bridge?
[]Yes ®No
If yes
(n) Length of existing bridge
(w) Width of existing bridge
(iv) Navigation clearance underneath existing bridge _
(v) Will all or a part of the existing bridge be removed?
(Explain)
f Length of proposed culvert Vanes, see details
h Height of the top of the proposed culvert above the NHW or NWL
Varies, see details
Will the proposed culvert affect navigation by reducing or
increasing the existing navigable opening? ❑Yes ®No
If yes explain
e (i) Will proposed culvert replace an existing culvert?
If yes
(u) Length of existing culvert(s) Varies, see details
(in) Width of existing culvert(s) Varies, see details
(iv) Height of the top of the existing culvert above the NHW or
NWL Varies, see details
(v) Will all or a part of the existing culvert be removed?
(Explain) existing pvc pipes and wooden rice trunks
will be completely removed prior to new installation
g Width of proposed culvert Varies, see details
I Depth of culvert to be buried below existing bottom contour
Vanes, see details
k Will the proposed culvert affect existing water flow?
❑Yes ®No
If yes explain
3 EXCAVATION and FILL [I This section not applicable
a
(i) Will the placement of the proposed bridge or culvert require any
excavation below the NHW or NWL? ❑Yes ®No
If yes
(n) Avg length of area to be excavated
(iii) Avg width of area to be excavated
(iv) Avg depth of area to be excavated
(v) Amount of material to be excavated in cubic yards
b (i) Will the placement of the proposed bridge or culvert require any
excavation within coastal wetlands /marsh (CW) submerged
aquatic vegetation (SAV) shell bottom (SB) or other wetlands
(WL)? If any boxes are checked provide the number of square
feet affected
❑CW ❑SAV ❑SB
❑WL ®None
(n) Describe the purpose of the excavation in these areas

c (i) Will the placement of the proposed bridge or culvert require any
high ground excavation? ®Yes ❑No
If yes
(n) Avg length of area to be excavated varies, see details
(m) Avg width of area to be excavated vanes, see details
(iv) Avg depth of area to be excavated vanes, see details
(v) Amount of material to be excavated in cubic yards N/A
d If the placement of the bridge or culvert involves any excavation please complete the following
(i) Location of the spoil disposal area Adjacent upland as temporary disposal area material to be used as backfill for culverts
(n) Dimensions of the spoil disposal area See drawings C1 C13
(m) Do you claim title to the disposal area? ®Yes ❑No (If no attach a letter granting permission from the owner)
(iv) Will the disposal area be available for future maintenance? ®Yes ❑No
(v) Does the disposal area include any coastal wetlands /marsh (CW) submerged aquatic vegetation (SAVs) other wetlands (WL) or shell
bottom (SB)?
❑CW ❑SAV OWL ❑SB ®None
If any boxes are checked give dimensions if different from (n) above NA
(vi) Does the disposal area include any area below the NHW or NWL? ? ❑Yes ®No
If yes give dimensions if different from (n) above NA
e (i) Will the placement of the proposed bridge or culvert result in any
fill (other than excavated material described in Item d above) to
be placed below NHW or NWL? ❑Yes ®No
If yes
(ii) Avg length of area to be filled
(in) Avg width of area to be filled
(iv) Purpose of fill
f (i) Will the placement of the proposed bridge or culvert result in any
fill (other than excavated material described in Item d above) to
be placed within coastal wetlandsimarsh (CW) submerged
aquatic vegetation (SAV) shell bottom (SB) or other wetlands
(WL)? If any boxes are checked provide the number of square
feet affected
®CW 2 5 sf ❑SAV ❑SB
OWL 5,5562s ❑None
(u) Describe the purpose of the excavation in these areas
repair and replacement of water control structures
installation of field access points for farm equipment
g (i) Will the placement of the proposed bridge or culvert result in any
fill (other than excavated material described in Item d above) to
be placed on high ground? ❑Yes ®No
If yes
(n) Avg length of area to be filled
(in) Avg width of area to be filled
(iv) Purpose of fill
a Will the proposed project require the relocation of any existing b Will the proposed project require the construction of any temporary
utility lines? [-]Yes ®No detour structures? ❑Yes ®No
If yes explain If yes explain

If this portion of the proposed project has already received
approval from local authorities please attach a copy of the
approval or certification
< Form continues on back>
c Will the proposed project require any work channels? d How will excavated or fill material be kept on site and erosion
❑Yes ®No controlled?
If yes complete Form DCM MP 2 Material to be excavated temporarily then used as backfill
Any excess material to be hauled to requested dike
repair area
e What type of construction equipment will be used (for example f Will wetlands be crossed in transporting equipment to project site?
draglme backhoe or hydraulic dredge)? []Yes ®No
backhoe dump truck If yes explain steps that will be taken to avoid or minimize
environmental impacts
g Will the placement of the proposed bridge or culvert require any
shoreline stabilization? ❑Yes ®No
If yes complete form MP 2 Section 3 for Shoreline
Stabilization only
S-- / - / 2-,
Date
Orton Plantation
Project Name
Orton Plantation Holdings LLC
Applicant Name
" 4ZZ� &
Applicant Ognature

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Historic Rice Field Protection and Restoration Protect
Appendix A
404 Wetland Survey and Jurisdictional Determination

U S ARMY CORPS OF ENGINEERS
WILMINGTON DISTRICT
Action Id SAW 2011 00624 County Brunswick U S G S Quad Carohna Beach
NOTIFICATION OF JURISDICTIONAL DETERMINATION
Property Owner Orton Plantation Holdings LLC
Address 17th Floor /12 :1 Avenue of the Americas
New York, NY 10020
Telephone No
Property description
Size (acres) 1,188
Nearest Waterway Cape Fear River
USGS HUC 03030005
Agent Land Management Group, c/o Steve Morrison
Address 3805 Wrightsville Ave, Suite 15
Wilmington, NC 28403
Nearest Town Southport
River Basin Cape Fear
Coordinates N 33 056699, W 77 951451
Location description The property is located on the east side of River Road (NC Hwy 133), off of Orton Road SE,
Brunswick County, North Carolina Parcel Id Nos 1440000112,1440000111 ,1440000110,1440000105, and 14400001
Indicate Which of the Following Apply
A Preliminary Determination
Based on preliminary information there may be wetlands on the above described property We strongly suggest you have this
property inspected to determine the extent of Department of the Army (DA) Junsdiction To be considered final a Junsdictional
determination must be verified by the Corps This preliminary determination is not an appealable action under the Regulatory
Program Administrative Appeal Process (Reference 33 CFR Part 33 1)
B Approved Determination
X There are Navigable Waters of the United States within the above described property subject to the permit requirements
of Section 10 of the Rivers and Harbors Act and Section 404 of the Clean Water Act Unless there is a change in the law
or our published regulations, this determination may be relied upon for a period not to exceed five vears from the date of
this notification
X There are waters of the U S including wetlands on the above described property subject to the permit requirements of
Section 404 of the Clean Water Act (CWA)(33 USC & 1344) Unless there is a change in the law or our published
regulations, this determination may be relied upon for a period not to exceed five years from the date of this notification
We strongly sug�,est you have the wetlands on your property delineated Due to the size of your property and /or our present
workload the Corps may not be able to accomplish this wetland delineation in a timely manner For a more timely delineation
you may wish to obtain a consultant To be considered final any delineation must be verified by the Corps
_ The waters of the U S including wetland on your property have been delineated and the delineation has been verified by the
Corps We strongly suggest you have this delineation surveyed Upon completion this survey should be reviewed and verified
by the Corps Once verified this survey will provide an accurate depiction of all areas subject to CWA Jurisdiction on your
property which provided there is no change in the law or our published regulations may be relied upon for a period not to exceed
five years
r
X The waters of the U S including wetlands have been delineated and surveyed and are accurately depicted on the plat
signed by the Corps Regulatory Official identified below on 8/22/2011 Unless there is a change in the law or our
published regulations, this determination may be relied upon for a period not to exceed five years from the date of this
notification
There are no waters of the U S to include wetlands present on the above described property which are subject to the permit
requirements of Section 404 of the Clean Water Act ( -)3 USC 1.)44) Unless there is a change in the law or our published
regulations this determination may be relied upon for a period not to exceed five years from the date of this notification

X The property is located in one of the 20 Coastal Counties subject to i egulation under the Coastal Area Management Act
(CAMA) ) ou should contact the Division of Coastal Management in Wilmington NC at [phone] to determine
their requirements
Placement of dredged or fill material within waters of the US and/or wetlands without a Department of the Army permit may
constitute a violation of Section 301 of the Clean Water Act (.)3 USC § 1.) 11) If you have any questions regarding this determination
and/or the Corps regulatory program please contact Emily Hughes at 910 2-1 4635
C Basis For Determination
This site exhibits wetland criteria as described in the 1987 Corps Wetland Delineation Manual and is adiacent to the Cape
Fear Rives a Traditionally Navigable Water of the U S This determination is based on information submitted by Land
Management Group Inc and a site visit by Emily Hughes Brad Shaer and Ronnie Smith on 6/28/2011
D Remarks
The signed survev does not depict the limits of Section 10 Waters
E Appeals Information (This mfoi mation applies only to approved ,jurisdictional determinations as indicated in B
above)
This correspondence constitutes an approved jurisdictional determination for the abo-% e described site If you object to this
determination you may request an administrative appeal under Corps regulations at 33 CFR part 331 Enclosed you will find a
Notification of Appeal Process (NAP) fact sheet and request for appeal (RFA) form If you request to appeal this determmation you
must submit a completed RFA form to the following address
District Engineer Wilmington Regulatory Division
Attn Emily Hughes Project Manager
Wilmington Regulatory Field Office
69 Darlington Ave
Wilmington North Carolina 28403 1398
In order for an RFA to be accepted by the Corps the Corps must determine that it is complete that it meets the criteria for appeal
under 33 CFR part 3.)l 5 and that it has been received by the District Office within 60 days of the date of the NAP Should you
decide to submit an RFA form it must be received at the above address by 10/22/2011
* *It is not necessary to submit an RFA form to
Corps Regulatory Official
Date August 22 2011
Action Id SAW 2011 00624
District Office if you do not object to the determination in this correspondence **
Expiration Date August 22, 2016
The Wilmington District is committed to proN iding thc highest level of support to the public To help us ensure we continue to do so
please complete the Customer Satisfaction Survey located at our website at http /h e,ulator� us uesur\ L. uim/ to complete the survey
online
Copy furnished
Corey No, al. Land Management Group Inc 380-) Wrightsville Ave, Suite 1 >, Wilmington, NC 28403

NOTIFICATION OF ADMINISTRATIVE APPEAL, OPTIONS AND PROCESS AND
REQUEST FOR APPEAL
Applicant Orton Plantation Holdings LLC
File Number SAW 2011
00624
Date 8/22/2011
Attached is
See Section below
INITIAL PROFFERED PERMIT (Standard Permit or Letter of
permission)
A
PROFFERED PERMIT Standard Permit or Letter of permission)
B
PERMIT DENIAL
C
APPROVED JURISDICTIONAL DETERMINATION
D
PRELIMINARY JURISDICTIONAL DETERMINATION
E
SECTION I - The following identifies your rights and options regarding an administrative appeal of the above
decision Additional information may be found at http / /www usace army mil/met/functions /cw /cecwo /reg or
Coss regulations at 33 CFR Part 331
A INITIAL PROFFERED PERMIT You may accept or object to the permit
• ACCEPT If you received a Standard Permit you may sign the permit document and return it to the district engineer for final
authorization If you received a Letter of Permission (LOP) you may accept the LOP and your work is authorized Your signature
on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety and waive all nl hts to appeal the
permit including its terns and conditions and approved jurisdictional determinations associated with the permit
OBJECT If you object to the permit (Standard or LOP) because of certain terms and conditions therein you may request that the
permit be modified accordingly You must complete Section 11 of this form and return the form to the district engineer Your
objections must be received by the district engineer within 60 days of the date of this notice or you will forfeit your right to appeal
the permit in the future Upon receipt of your letter the district engineer will evaluate your objections and may (a) modify the
permit to address all of your concerns (b) modify the permit to address some of your objections or (c) not modify the permit
having determined that the permit should be issued as previously written After evaluating your objections the district engineer
will send you a proffered permit for your reconsideration as indicated in Section B below
B PROFFERED PERMIT You may accept or appeal the permit
• ACCEPT If you received a Standard Permit you may sign the permit document and return it to the district engineer for final
authorization If you received a Letter of Permission (LOP) you may accept the LOP and your work is authorized Your signature
on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety and waive all rights to appeal the
permit including its terms and conditions and approved jurisdictional determinations associated with the permit
APPEAL If you choose to decline the proffered permit (Standard or LOP) because of certain terms and conditions therein you
may appeal the declined permit under the Corps of Engineers Administrative Appeal Process by completing Section Il of this form
and sending the form to the division engineer This form must be received by the division engineer within 60 days of the date of
this notice
C PERMIT DENIAL You may appeal the denial of a permit under the Corps of Engineers Administrative Appeal Process by
completing Section II of this form and sending the form to the division engineer This form must be received by the division engineer
within 60 days of the date of this notice

D APPROVED JURISDICTIONAL DETERMINATION You may accept or appeal the approved TD or
provide new information
• ACCEPT 'i ou do not need to notify the Corps to accept an approx ed JD Failure to notify the Corps within 60 da} s of the date of
this notice means that you accept the approved JD in its entirety and A aive all rights to appeal the approved JD
• APPEAL If you disagree NN ith the approved TD you may appeal the approved JD under the Corps of Engineers Administrati\ e
Appeal Process by completing Section 1I of this form and sending the form to the division engineer This form must be received by
the division engineer \N ithin 60 da) s of the date of this notice
E PRELIMINARY JURISDICTIONAL DETERMINATION You do not need to respond to the Corps regarding
the preliminary JD The Preliminary JD is not appealable If you wish you may request an approved JD (which may be
appealed) by contacting the Corps district for further instruction Also you may provide new information for further
consideration by the Corps to reevaluate the JD
SECTION II REQUEST FOR APPEAL or OBJECTIONS TO AN INITIAL PROFFERED PERMIT
REASONS FOR APPEAL OR OBJECTIONS (Describe your reasons for appealing the decision or your objections to
an initial proffered permit in clear concise statements You may attach additional mforination to this form to clarify where
your reasons or objections are addressed in the administrative record )
ADDITIONAL INFORMATION The appeal is limited to a review of the administrative record the Corps
memorandum for the record of the appeal conference or meeting and any supplemental information that the review officer
has determined is needed to clarify the administrative record Neither the appellant nor the Corps may add new information
or analyses to the record However you may provide additional information to clarify the location of information that is
already in the administrative record
POINT OF CONTACT FOR QUESTIONS OR INFORMATION
If you have questions regarding this decision and/or the
If you only have questions regarding the appeal process you
appeal process you may contact
may also contact
District Engineer Wilmington Regulatory Division
Mr Jason Steele Administrative Appeal Review Officer
Attn Emily Hughes Project Manager
CESAD ET CO R
Wilmington Regulatory Field Office
U S Army Corps of Engineers South Atlantic Division
69 Darlington Ave
60 Forsyth Street Room 9M15
Wilmington North Carolina 28403 1398
Atlanta Georgia 30303 8801
RIGHT OF ENTRY Your signature below grants the right of entry to Corps of Engineers personnel and any government
consultants to conduct investigations of the project site during the course of the appeal process You will be provided a 15
day notice of any site investigation and will have the op ortunity to participate in all site investigations
Date
Telephone number
SiEnature of appellant or agent
For appeals on Initial Proffered Permits and approved Jurisdictional Determinations send this form to
Distnct Engineer Wilmington Regulatory Division Attn Emil3 Hughes Pi olect Manager Wilmington Regulatory
Field Office 69 Darlington Ave, Wilmington North Carolina 28403 1398
For Pei mit denials and Pi offered Permits send this foi m to
Division Engineer Commander, U S Army Engineer Division South Atlantic Attn Mr Jason Steele Administrative
Appeal Officer, CESAD ET CO R 60 Forst th Street Room 9M15 Atlanta Geoi gia 30303 8801

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Historic Rice Field Protection and Restoration Protect
Appendix S
NC Wetland Assessment Method (WAM)

Analysis of Wetland Function at Orton Plantation, Brunswick County, NC
Atkins North America
January 27, 2012
a Background
The North Carolina Wetland Assessment Method (NC WAM) was used to
conduct a wetland functional assessment for this project as desenbed below NC WAM
was developed by an interagency team including the NC Division of Water Quality
(DWQ) and the US Army Corps of Engineers (USACE) NC WAM has been presented
to the Environmental Management Commission (EMC) discussed at several scientific
conferences and used for several NC DOT project but apparently this is the first use of
NC WAM for a private project in NC
DWQ rules encourage use of a Wetland Evaluation Procedure that has
widespread acceptance in the scientific community (15A NCAC 2B 0103(c))
Snnilaily the Corps/EPA jomt mitigation rule mandates the use of `appropriate
functional or condition assessment methods where available 33 CFR 332 3(f) to
assess loss of aquatic resources functions The Orton Team believes that use of NC
WAM is appropnate for this project both from a state and federal viewpoint Therefore
NC WAM was used for this project to determine the existing level of function for the
wetlands on site
The purpose of the proposed permanent fills is to restore the revetments and
repair water control structures throughout the project while the temporary impact to the
non tidal freshwater marsh are needed to prepare the nee fields for regular replanting
The Corps Public Notice (US Army Corps of Engineers 2011) states that the nee fields
will continue to remain wetlands after these temporary impacts The project proposal
was to fill and thereby permanently impact a total of 3 33 acres of freshwater wetlands,
up to 1 5 acres of coastal wetland and 6 4 acres of open water as well as have temporary
impacts to 333 74 acres of freshwater wetland Based upon an evaluation of a range of
alternatives it is believed that the most appropnate and environmentally preferable
compensatory mitigation for the proposed wetland impacts is to provide high quality
coastal marsh restoration on the Orton Plantation property (i e on site ) to compensate
for the unavoidable impacts of the project As documented in the mitigation plan the
proposed mitigation will provide functional uplift that meets or exceeds the functions of
the low value freshwater wetlands and the high to medium value saltibrackish marsh that
will be unavoidably impacted by the project
Compensatory wetland mitigation is normally only required for permanent
impacts to wetlands — indeed the Division of Water Quality s rules refer to
As described elsewhere the pa oposed compensatory mitigation (on site salt/bi acl-ish mai sh
a estoi ation) may i esult in an inci ease in the total ai ea of dzstw bance to 1014, 1 aloe non tidal freshwater
marsh This distui bance will be unavoidable as pai t of the i estoration effoi t and will be offset accoi dangly
as described in the mitigation plan

unavoidable losses of existmg uses and replacement of wetland acres lost
1 �A NCAC 2H 0D06(h)(6) Therefore no mitigation is pioposed for temporary impacts
especially considering that the fieshwater wetlands are rated overall Low value The
open water impacts should not require compensatory mitigation since these impacts
affect ditches on the property or are needed to stabilize the revetments to continue to
protect the nee fields Therefore compensatory mitigation is proposed for the 1 5 acres
of impact to high to medium value salt marsh and 3 33 acres of impact to low value non -
tidal freshwater marsh
b Wetland Functional Assessment Process
NC WAM was used to determine the level of function for the wetlands on the
Orton Plantation property NC WAM (N C Wetland Functional Assessment Team 2010)
is an observationally based, rapid assessment method developed over the past several
years by an interagency team of wetland regulators and wetland experts in NC The
ultimate result compares the wetland to a suitable reference suite of relatively undisturbed
wetlands and results in ratings of High (less disturbed) Medium (moderately disturbed)
or Low (highly disturbed) On October 20 2011 John Dorney and Brad Allen from
Atkins conducted a site visit to the wetlands at Orton Plantation in order to evaluate the
level of function of these wetlands using the most current version (Version 4 1) of the NC
WAM In follow up visits on November 7 2011 and December 16, 2012, John Dorney
conducted several additional NC WAM evaluations on the site and at a nearby
iepresentative location (USS North Carolina) The purpose of this work was to visit
representative locations of each of these wetlands and conduct an NC WAM evaluation
in order to support the permit application and eventual compensatory mitigation plan for
unavoidable impacts to these wetlands These evaluations update those included with the
404 application package Because of the complexity of the site and the lack of directly
comparable reference sites the initial NC WAM evaluations erroneously rated the value
of the wetlands within the nee fields as determined by Mr Dorney and Mr Allen both of
whom were actively involved in the development of NC WAM and have been instructois
for all 12 classes taught to date The updated evaluations accurately reflect the level of
function present in the Orton Plantation wetlands This evaluation showed that freshwater
wetlands on the site are of Low overall functional value except for some anus of the nee
fields In addition the salt/brackish marsh along the Cape Fear River is of Medium
Quality where it has been narrowed by seveie erosion from the federal shipping channel
or of High value where it is wider Finally the salt/brackish marsh along the north side
of Orton Creek is also of High oveiall value All of these evaluations (except for the USS
North Carolina evaluations) are shown on Figure 1 which graphically depict the data
presented in Table 1
c Hydrological background
Mr Dillon Epp (Orton Plantation Project Manager) was queried concerning the
past and present practices of land and water management on the Orton Plantation The
purpose of obtaining this narrative was to document the substantial alterations to the
natural hydrologic regime and the resultant vegetation change that occurred (and

continues to occur) in response to this alteration The area was first impacted in the early
1700 s with construction of Orton Pond (the Pond) which is an 880 acre five mile long
pond built to supply gravity fed water to the nee plantation along Orton Creek and the
Cape Fear River Land for the nee plantation was probably cleared shortly thereafter
Originally we believe the front fields as well as fields # 1 and # 9 were probably
saltibrackish marshes and the back field was probably nvenne swamp forest based on
their position in the landscape relative to the location of Orton Creek the Cape Fear
River and local topography (Figure 1) Water flowed from the Pond to the fields when it
was needed for nee cultivation At other times which was the predominant condition
water from the Pond flowed (and flows) down the Pond spillway channel to the Cape
Fear River The nee fields were and are, allowed to dry out in the early spring when
historically the land was plowed by mule and oxen and then planted to nee As the nee
grew water was gradually added to the nee fields to keep the growing nee in standing
water but the water level was kept below the top of the growing nee plants Plantmg
occurred in April and nee was harvested in September The fields were allowed to
completely dry out before harvest One crop of nee was grown annually Since nee was
only grown for about 90 days (with some additional land preparation time and drying
time for harvest) during most of the year water flowed from Orton Pond via the spillway
channel to the Cape Fear River
Rice was grown until 1931 when a severe blight hit the area and prevented nee
cultivation After that tune, water levels in the nee fields were managed for waterfowl
but with approximately the same schedule Eventually Phrasrnrtes began to invade the
fields and despite efforts to control it, Phragmites eventually took over the fields
particularly the North Front Field and the South Front Field The Phraamites was
sprayed in late 2011 and the applicant plans to control its growth in the future From the
1949 aerial photo submitted with the permit application the extent of the so called
quarter ditches is readily apparent throughout the fields
It is also apparent from historical aerial photos that portions of the North Front
and South Front fields were used as spoil disposal areas from dredging of the Cape Fear
River This was confirmed by soil sampling that was done during the NC WAM
evaluations which found predominately sandy soils in several locations in the North Front
and South Front fields including a 122 acre upland location in the North Front field
Finally based on an analysis of aenal photos from 1998 2004 and 2010 (Figure 2)
erosion along the Cape Fear River has been significant but uneven with greater erosion
on the section that huts out into the River (associated with a narrower salt marsh fi-inge)
and along the southern end near the confluence of the Orton spillway channel with the
River
d Results of NC WANT evaluation
A total of seventeen (17) NC WAM forms were completed at locations with soil samples
taken at each location as well as observations of wetland condition (Table 1 and Figure
1) Multiple forms were completed on the North Front Field Field # 1 and the Back

Field, since slightly different soil conditions were found within these locations Since no
differences were found between the levels of function within these fields despite the
different soil conditions the data were combined into a single evaluation per field
Completed sheets for the seventeen sites were submitted with the application materials
Figure 1 depicts all the NC WAM data collected to date at Orton Plantation These data
graphically depict the results of the evaluations with separate maps for hydrology water
quality habitat and finally overall wetland quality In general hydrology is medium
over most of the site with the exception of a few arms of the Back Field where diking and
berming have severely impaired the hydrology and one arm which is rated High
(Evaluation 13) of the Back Field which is at a higher elevation and diains to the Back
Field Water quality is low over most of the site except for the brackish/salt marsh and a
few of the arms of the Back Field and Field # 9 as well as directly below Orton Pond
Habitat is also low over most of the site except for the brackish/salt marsh and several of
the arms of the Back Rice field Overall most of the wetland acreage on site is of Low
quality except for the brackish/salt marsh and locations with more matuie nverme swamp
forest and a few of the arms of the Back Rice field and Field # 9 Of the areas originally
requested to be put into nee plantation only one area (the arm of Field #9) has an overall
value higher than Low since this site is rated overall Medium Otherwise, all the areas
planned to be placed into nee cultivation are rated as Low overall value In contrast the
salt/brackish marsh on the site is generally of High overall quality and High for all three
functions except for the narrower fringe along the Cape Fear River where active erosion
has diminished the wetland function
Fresher ater m etlands Overall, thence field wetlands have Low levels of function
regardless of which specific field was evaluated This overall conclusion is consistent
with the high level of hydrologic manipulation as described above which resulted in our
evaluating metric 1 (Ground Surface Condition) as B (Severely altered) and metric 2
(Surface and Sub surface Storage Capacity and Duration) as C (Substantially altered)
for all the nee fields Even the now cleared Rivenne Swamp Forest on the southern part
of the Back Field (south of the Pine Island) had an overall low level of function This
condition is mainly due to the high degree of hydrologic manipulation, the intensity of
the quarter ditches and the presence of about two to thiee feet of a quasi - floating mat of
organic debris over mineral soil which makes this now cleared Rivenne Swamp Forest
very different in its characteristics from a reference Rivenne Swamp Forest Portions of
the wetland in the North Front Field have been exposed to salt water intrusion wheie the
dike was temporarily breached due to the eiosive forces of tides in the Cape Fear River
amplified by wave action resulting from ships using the nearby Corps maintained Cape
Fear shipping channel Overall this past salt water intrusion has not altered the level of
function of the wetland since it is of Low overall quality throughout the North Front field
The only exception to this overall Low rating was for arms of these nee fields that had
their own relatively undisturbed watersheds (Evaluations 9 12 and 13) In these
situations, the overall functional rating was either High or Medium depending on the
degree of past disturbance The two exceptions (Evaluations 13 and 14) were for arms of
the Back Rice field that had separate watersheds but those watersheds also had their

hydrology severely altered (Metric 1) or substantially altered (Metric 2) by berms for a
dam or the Orton spillway channel that cut across the watersheds of these wetlands
thereby severely altering the drainage much like that for the Back Field itself Of these
three locations with more than Low overall value only one location (Evaluation 9 at the
Field # 9 — western arm) was planned to be converted to nce fields
Salt/brackish marsh m etlands Two sets of NC WAM forms have been completed for
the salt/brackish marsh along the Cape Fear River by John Dorney of Atkins staff
(Evaluations 3, 4 and 5) One location (Evaluation 3) was rated on October 20 2011 near
the point boundary of the North and South Front fields where the salt marsh is wider and
more stable and the second location (Evaluation 4) was rated on November 7 2011 at the
narrower part of the marsh near the bulkhead dust south of the old breach near the middle
of the North Front nce fields (Table 1) The fringing salt/brackish marsh along the Cape
Fear River was evaluated at high tide near the mutual boundary of the North and South
fields This marsh was found to have a High level of function although it is notable that it
is being gradually and inexorably eioded from boat wakes from the Cape Fear shipping
channel in the Cape Fear River so it is uncertain how much longer it will remain in its
present condition The evaluation done on the narrower marsh along the Cape Fear River
showed that it is of Medium overall quality (Medium for Hydrology function High for
Water Quality function and Low for Habitat function) mainly where the marsh width is
about 100 foot or narrower The main reason that this salt/brackish marsh is of lower
quality than the marsh near the North and South Front field location is that the this marsh
is narrower and actively eroding which results in its lower quality Since a large portion
of the salt marsh to be impacted is of the lower condition, its replacement with High
quality salt/brackish marsh mitigation should more than offset the unavoidably lost
functions Finally an evaluation (Evaluation 5) was made for the salt/brackish marsh
along the north side of Orton Creek (across from Field # 1) which showed that this marsh
is of High overall quality and is therefore likely a suitable reference site for the planned
salt/brackish marsh restoration at the top end of the North Front Rice field
Battleship North Carolina site — Upon request of the US Army Corps of Engineers an
NC WAM evaluation was made of the nvenne swamp forest near the Battleship to
update the evaluation done in January 2006 by the Wetland Functional Assessment
Team This site provides a comparison to the condition of the nvenne swamp forest in
the Back Rice fields These evaluations are noted below as well The evaluations used
different versions of the NC WAM manual (version 3 1 from 2006 and version 4 1 for
2011) Overall this wetland still rated Low due to the severe hydrologic alteration at the
site (severely restricted overland and overbank flow) despite the fact that the site is
dominated by mature (although second or third growth) hardwood and cypress forest

Table 1 NC WAM evaluations of the level of wetland function for wetlands at Orton
Plantation
NC WAM
Location
Wetland
Date of
Hydrology
Water
Habitat
Overall
evaluation
Type
analysis
Quality
Value
number
(all
Version
41 of
Manual
except as
noted)
1
North
Non tidal
October
Medium
Low
Low
Low
Front Field
freshwater
20 2012
marsh
2
South
Non tidal
October
Medium
Low
Low
Low
Front Field
freshwater
20 2012
marsh
3
Tidal marsh
Salt /brackish
October
High
High
High
High
along Cape
marsh
20 2012
Fear River
at North
and South
Front field
boundary
4
Tidal marsh
Salt /brackish
November
Medium
High
Low
Medium
along Cape
marsh
7 2011
Fear River
near
bulkhead
5
Tidal marsh
Salt /brackish
December
High
High
High
High
along north
marsh
16 2011
side of
Orton
Creek
6
Field # 1
Non tidal
October
Medium
Low
Low
Low
freshwater
20 2012
marsh
7
Orton
Riverine
December
Medium
Medium
High
Medium
Creek
swamp
16 2011
below
forest
Orton Pond
8
Field # 9
Non tidal
October
Medium
Low
Low
Low
freshwater
20 2012

marsh
9
Field # 9 —
Riverine
December
Medium
High
Low
Medium
western
swamp
16 2011
arm
forest
10
Back field
Non tidal
October
Medium
Low
Low
Low
near access
freshwater
20 2012
road
marsh
11
Back field
Riverine
October
Low
Low
Low
Low
south of
swamp
20 2012
pine island
forest
12
Back field
Riverine
December
Medium
Low
Medium
Medium
# 8 arm to
swamp
16 2011
northeast
forest
13
Back field
Riverine
December
High
High
Medium
High
# 4 arm to
swamp
16 2011
south
forest
14
Back field
Riverine
December
Low
Low
Medium
Low
# 3 arm to
swamp
16 2011
south
forest
below
drained
pond
15
Back field
Riverine
December
Low
Low
Low
Low
# 2 arm to
swamp
16 2011
south
forest
16
USS North
Riverine
January
Low
Low
High
Low
Carolina
swamp
27 2006
forest
(Version
3 13 of
Manual)
17
USS North
Riverine
December
Low
Low
Medium
Low
Carolina
swamp
16 2011
forest

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Historic Rice Field Protection and Restoration Project
Appendix C
The Rice Coast Article

L
�s
W
L
Y
_ir (-I ��4 lip, 7 Ic supported a .7
�
s
by BILL'VtcDOUG 4LL,D / photograph) SYLVIA MARTIN
{ �,
'Y There are many tales of how nee first came
S
to the Southern coast The most popular ac t
z
count says that around 1694 an African snip s r wh x
captain made a gift of seed nce to a wealthy
w r
Charleston land baro4 How the nce got here r
isn t so important now but the legacy of the
crops the plantations and the culture that
grew from that seed nce is I�
For more than two centuries a narrow strip i
of marshland from North Carohna's Cape 7+
s
Fear to th&, Golden Isles of Georgia was the Southern Tice
coast the domain of more than 500 planters cultivating nearly
°3
Each plantation was a self contained city providing nearly
Jk
every need Tbr .he owner and his family a4 overseer and the
}
gardens and livestock for food rodpers who built bafrels for
-r
the nce carpenters bewmg massive %ur k. gates to 65-ntiol the
tides oa the }n&T1eXAT- 1as"li acks=ths and hou a servants
On most plantations stave. lived4m. an area calted the
street These broad avenues some as wide as 200 feet,
Tlliie
mirked the entrance to the plantation —the more cabins the
greater the planters wealth The houses were built of white
e
oo-Ti,
i
3
fireplace tempered winter s chill and was used for irookmg
A��l So rh culture
Y
i
V,
kt
u,,A-Ld
. rn
E
own vegetables after work in the fields was done
L
�s
W
L
Y
_ir (-I ��4 lip, 7 Ic supported a .7
sonea fu, 6wi1ieo c rly but time
C s -i i sit an erg A' (It 3 all not return
by BILL'VtcDOUG 4LL,D / photograph) SYLVIA MARTIN
{ �,
'Y There are many tales of how nee first came
S
to the Southern coast The most popular ac t
z
count says that around 1694 an African snip s r wh x
captain made a gift of seed nce to a wealthy
w r
Charleston land baro4 How the nce got here r
isn t so important now but the legacy of the
crops the plantations and the culture that
grew from that seed nce is I�
For more than two centuries a narrow strip i
of marshland from North Carohna's Cape 7+
s
Fear to th&, Golden Isles of Georgia was the Southern Tice
coast the domain of more than 500 planters cultivating nearly
100,000 acres of gram
Each plantation was a self contained city providing nearly
every need Tbr .he owner and his family a4 overseer and the
hundreds of slaves it tool, to bcufg in the crpp There were
gardens and livestock for food rodpers who built bafrels for
the nce carpenters bewmg massive %ur k. gates to 65-ntiol the
tides oa the }n&T1eXAT- 1as"li acks=ths and hou a servants
On most plantations stave. lived4m. an area calted the
street These broad avenues some as wide as 200 feet,
mirked the entrance to the plantation —the more cabins the
greater the planters wealth The houses were built of white
washed wood with a single room or perhaps two Inside a
fireplace tempered winter s chill and was used for irookmg
Chickens pigs and goats meandered about the street Crude
fences kept them out of the small plot& where slaves raised their
E
own vegetables after work in the fields was done
it P
The overseer usually lived at the end of the street since his
job was to watch over the slaves Overseers who failed in
managing the crop disciplining the field hands or keeping the
r"
valuable slaves healthy were soon unemployed But a good one
Y
could make handsome wages as much as $1,000 a year
"r
The master built his home apart from the slave community
usually selecting a point that overlooked the ncefields Many
xs���
plantation homes were simple structures but others such as
the one at Middleton Place on the Ashley River near Charles��
stun were grand examples of the wealth a planter could attain
z
k But the real heart of the plantations was the coastline—
and the iMgatton systems that fed river water to the fields
A mineral rich web of nvers —CapC Fear Waccamaw Pee
Dee Santee Altamaha Savannah and others lowed among
the cypress swamps and sandy islands dropping their upland
cargo of silt to make these among the most fertile of Southern
lands Twice a day silent tides slipped in bottling up the
streams and rivers spreading fresh water over cleared swamp-
land The warm growing season from April to September gave
"'S
the planters time to manage the crop It was flip perfect natural
THE OLD RICE MI–L AT MIDDLETON
PLACE NEAR CHARLESTON
134 Southern Living

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'FIELDS PREPARED FOR THE PLANTING
The watercolor paintings shown on these pages
are by Alice Ravenel Huger Smith (1876 1958)
descendant of a South Carolina nce plantation
family Done onginally to illustrate the book A
Carolina Rice Plantation of the Fifties published
in 1936, the paintings trace the seasons and
activities typical of 19th century nce plantations
The artist s watercolor wash captures the soft,
atmasphenc qualities of the Low Country setting
but also softens the image of hard work required
to bring the nce to harvest Smith donated her
paintings to The Carolina Art Association and
they are displayed annually at the Gibbes Art
GaBeiy in Charleston Etght are available as
reproductions in the same I941i x 241/2 inch size
as the originals For details, write to Gibbes Art
Gallery, 135 Meeting Street Charleston South
Carolina or call [phone]
system for nce cultivation And slavery made it possible
Clearing the lands and diking the fields took intensive labor
In return for the meager subsistence that a master offered —or
motivated by the crack of a whip — hundreds of field hands
waduig ,knee deep through murky swamps turned tangled
cypress swamps into ricelands with ax saw hoe and shovel
On cleared lands the ditches yielded mud to build a pro
13$ Southern Living
k
�ie +�°�s^ ^can �a+✓e .cavm«s -.'" ,c.,w � "" ,�.y _ � � "'�
Tif
THE POINT FLOW OR STRETCH WATER
tective dike 6 feet high and more than 12 feet thick
Massive trunk gates harnessed nature s own irrigation Hewn
from cypress logs the trunks were wooden channels leveled
and firmly anchored through the outermost dikes of a ncefield
A heavy door swung outward from each end To bring water
onto the field the outer door was raised and an mcommg tide
pushed fresh river water through the trunk floating the inner
z
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ti I
-r
IN j
'FIELDS PREPARED FOR THE PLANTING
The watercolor paintings shown on these pages
are by Alice Ravenel Huger Smith (1876 1958)
descendant of a South Carolina nce plantation
family Done onginally to illustrate the book A
Carolina Rice Plantation of the Fifties published
in 1936, the paintings trace the seasons and
activities typical of 19th century nce plantations
The artist s watercolor wash captures the soft,
atmasphenc qualities of the Low Country setting
but also softens the image of hard work required
to bring the nce to harvest Smith donated her
paintings to The Carolina Art Association and
they are displayed annually at the Gibbes Art
GaBeiy in Charleston Etght are available as
reproductions in the same I941i x 241/2 inch size
as the originals For details, write to Gibbes Art
Gallery, 135 Meeting Street Charleston South
Carolina or call [phone]
system for nce cultivation And slavery made it possible
Clearing the lands and diking the fields took intensive labor
In return for the meager subsistence that a master offered —or
motivated by the crack of a whip — hundreds of field hands
waduig ,knee deep through murky swamps turned tangled
cypress swamps into ricelands with ax saw hoe and shovel
On cleared lands the ditches yielded mud to build a pro
13$ Southern Living
k
�ie +�°�s^ ^can �a+✓e .cavm«s -.'" ,c.,w � "" ,�.y _ � � "'�
Tif
THE POINT FLOW OR STRETCH WATER
tective dike 6 feet high and more than 12 feet thick
Massive trunk gates harnessed nature s own irrigation Hewn
from cypress logs the trunks were wooden channels leveled
and firmly anchored through the outermost dikes of a ncefield
A heavy door swung outward from each end To bring water
onto the field the outer door was raised and an mcommg tide
pushed fresh river water through the trunk floating the inner

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door open As the tide began to ebb the inner door swung
back into place trappml, the water on the fields
To dram the field the inner door was pried open at low tide
Water rushed into the channel fhnging the outer door open in
its path A rising tide sealed the outer door shut, and the field
was dry again
Clearing new lands and preparing the fields for planting
r
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CUTTING THE RICE
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occupied the cool months a time for optmusm Then April
brought plantingtime and all healthy hands worked steadily
for two or three weeks to get the seed nce in the ground
• r •
Field hands carved long trenches 1 foot apart in the mud
while others followed behind carefully laying in the seed If
the rice had been clayed washed in mud and dried --it
wouldn t float away so trenches were then left uncovered
The first water was channeled into the fields the day of the
planting This sprout flow stayed on a week or so until the
seed rice could germinate It signaled the beginning of a
season long bout with nature that could end with a bountiful
harvest like that of 1849 when the state of South Carolina
produced nearly 107 500 to4s of gram Other years brought
disappointment In 172$ an August hurricane wiped out the
crop and much of Charleston with it
With the sprouts up fields dried rapidly in warm spring
sunshine Tiny plants began breaking through fertile soil and a
second controlled flooding the point flow went on Until
the rice formed points about 4 mches high the water stayed on
killing weeds and grasses This gave the roots time to
strengthen against the onslaught of bobolinks heading north
Planters also called them rice birds or May birds By any
name they could mean disaster Flocks swept down and devas
tated fields in minutes Young children or older folk'who were
too infirm for field labor became birdmmders Posted atop
the dikes throughout late spring they banged pans with
June 1983 137
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J

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` tiHAl(MG, ?T- Me -R1CF FROM TEE STP1 M AFIT-A THRESHING
o-i )r ra ked p Rio , h^ i d J e e� m�i -!- emoved46 rough coating that remained fonlfhe
--m P t4-ld r €I -um , th r -n d ti- a #am Large plantations built theirlown pulls, but manyplant
d ci r s t S1, �-d v.er o the +° ers preferred selling t ie nc$ la the rough or contra tmg obi "
' n flc is -t n ft� A ns milling in Georgetown Charleston or Savannah.
ater I coC f F In those same cities the clean pearl white gram was sold by
}as lu rr is c CO , rice merchants or factors to the highest bidders from the
t U r 2 r ors 1 r North and from Europe Inland a few miles planters in com
w I fortable houses marked another year s profits on the led$er a
In the midst of the sultry grow ing season only theslaves and
an overseer were found on the plantations brie anonymous
Charleston planter remarked I would as soon stand fifty feet
from the best Kentucky rifleman and be shot at by the b9ur as
to spend a night on my plantation in summer Miasma as
malaria was known along with stifling heat and humidity
drove the planters off their land
In the heat of the summer the stretch water went on
Slaves raised the water level every few days to support the
heavy gram,, stretching it to its full height Some called tills the
lay by water since the gradual raising of the water level kept
the wind from laying the nce into the water
Harvest came near the first of September Water was let of
at the ebb tide and the nce was cut with sickles or nce hooics
as soon as the soil could support the weight of the slaves No
one rested until the cut grain was safely tied in sheaves and
stacked near the winnowing house
SIave women threshed the dried gram by hand using a long
wooden flail to pound the nce from the stalk and loosen the
husks Then they tamed it in shallow round baskets up into
the winnowing house When a favorable wind blew they
dropped the nce to the floor below and the chaff swept away
with the breeze
138 Southern Living
victory over nature won find thousplias of slaves waded into
the swamps clearing new lands to begin another crop
• s 0
Rice culture reached its peak lust before the Civil War when
nearly 600 plantations operated in the Carolinas and Georgia.
But the war left the South with no alternative to the aptive
labor force that built the nce coast and as freedom spread the
culture began to slowly die along the Eastern seaboard
Planters found that land in Louisiana Texas and Arkansas
produced high quality nce on soils that stood the weight hf
heavy machinery That same machmery simply sank in the
boggy swamps of the once prosperous nce coast and even the
hard working slaves who stayed on for nominal pay couldift
keep pace with the mechaniza ion in the Gulf states
The rivers that had brought rill minerals to the cypress
swamps began filling with silt eroding from the cotton farms
upstream so floods were more common and more devastating
About the turn of this century a series of natural disasters—
two hurricanes in 1893 floods in 1906 1967 and 1908 and
violent storms during several growing seasons —took the last of
the viable Atlantic rice plantations The plantations turned to
other uses— wddhfe refuges hunting preserves shnmp and
crayfish industries --and the stoned Southern nce culture
quietly ended

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FISHNG IN A RICE FIELD DITCH r
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' VISIT THE RICE COAST
Although much of the evidence of our Southern nee hours on Saturday and from 2 to 4 30 p in on Sunday
,,M, l,ttlrc has vanished several historic sites and mterprptive Magnolia Plantation and Gardens Seven miles south of
c� :6rs listed below give visitors a chance to see exhibits Charleston on State 61 (803) 5711266 The gardens are
artifacts and homes from the nce era open daily from 8 a m to dusk The plantation house is
GEtJR{1 A
open from 9 a in to 5 p in
Mfddleton Place On State 61 14 miles north of Charles
lt�fwyl llS j'fdelc 'ten 4 92 1 r1ll s r )r n of Erne ton [phone] The plantation house and a nee mill
on 1J S j'7 (9, } ? �?fT3 �,n Int °z pr Ii ° eente containing artifacts and watercolor paintings are open daily
r1L is,, and n 11 utus arc open from 9 a In a p -n from 9 a in to 5 p in The restaurapt housed in a former
Tli sdav hroa, S t, ua and on Sarda� v terroon guest cottage is open from 11 a in to 3 p in Tuesday
N ,r €n C i-T OLII,,T ,, through Sunday
Orton I I.sntactton %,rd nh 'In Wrinalio,� _ -stiles south
aI WtlnlfnLror on S e t ^ (rt 9) 371 (u73 TI-e house i
)t t op n to the pul he nut -t priAm And ch. se a e ope-a
ca 1 froml b a M to z - rr MArt,h to Nave x t er
SOUTH L - �P31 -tNA
z sun een Ca "de-s n 'OU I d Inlet 1 m 1 5 h of
'dt r _1 -- 0 c 1 t S 1 bt 3' 7 421 S -a Its the
rtalf.. t of - / 2 A It r Lrj1Ln 1 s ted t mu tit
,a CIw 1i -)I. It t 11 ILe i 1011 I 1(„ )tclr dtIO" 13 tr"S
d r f3 d M to r d w-, t �.m— { nr t°mdS
s n -A t)n M1 1( t ,A -%I )f Cti ton ^)n
"f 76.) 11 8" —n I- Ic plant st 1 e a
loc 1I t --r( %,,inl- rce -t. -i ul Y -u-1 I - -1
I- E'"' V'S 1 L %m i; r'l' IS r ..1. -)o 1` n } 'I - r\
£ eta- -t ) z r I t - J JUG- amn Or -r n 3 1 t, t 17 oov m )v n
0 } sun sK t ) T , r i� anv , r of.ra,*, of
sr dI4F nI a cum Is oper om t130
Iri a I`Iron t ; t a,c- Fr ddy w1tt, , sonal
SymbGIs of the nce cultu e
(1 -t) d fek6e nce h of
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I rrt r f v de st
Ju,1 1= 139

Historic Rice Field Protection and Restoration Project
Appendix D
Protect Purpose Supplement

Project Purpose Supplement
Orton Plantation
1$astoric Ibce Field Protection and Restoration Project
As stated in the original permit application, the purpose of the proposed project is `to
protect and restore the various elements of the historic nce field system at Orton
Plantation' The Applicant s preferred alternative as presented in the Public Notice, has
been selected subsequent to careful consideration of a range of alternatives as detailed in
the project Alternatives Analysis and is believed to be the least environmentally
damaging practicable alternative (LEDPA) that satisfies the stated purpose
The purpose of the project is not the commercial production of nce Rather, the above
stated purpose involves the reestablishment of historic nce cultivation and revitalization
of tins historic resource as a defining landscape element of the Plantation In doing so,
agricultural practices related to nce cultivation will be employed within only the five nce
fields within the functioning, intact, hydrologic management system
In the fall of 2010, Orton Plantation was purchased by Orton Plantation Holdings LLC
The principal of the parent company of Orton Plantation Holdings LLC is a direct lineal
descendant of Roger Moore, the person who succeeded to the original crown grant and
established the plantation in 1725 As such, Orton Plantation Holdings LLC has an
interest and a purpose to reestablish the plantation for the cultivation of nce consistent
with the rehabilitation of the historic plantation buildings, gardens and cemeteries
Rehabilitation of these historic resources is being performed in close coordination with
the North Carolina State Historic Preservation Office (SHPO) In addition, the owner
recently submitted a formal application and nomination to the National Park Service for
consideration of Orton Plantation as a National Historic Landmark (refer to attached
correspondence) As the last remaining intact nce system of the 35 documented
plantations in operation during the Colonial and Antebellum periods in North Carolina,
Orton Plantation is believed to be of both regional and national historical significance
Orton s nce fields have the potential to be a primary source from which researchers can
gain understanding about historic nce production and its contribution to the culture and
economy of the Cape Fear Region and North Carolina during the Colonial and
Antebellum periods
The historic significance of the plantation and nce fields makes the effort to restore the
property to nce cultivation one of significant public interest SHPO concurs in this
assessment. Tangible public benefits are anticipated as a result of the proposed project
For instance the rehabilitation of nce fields and reestablishment of cultivation of
heirloom nce varieties can provide unique educational opportunities in a manner similar

to the recent longleaf pme restoration workshop held on the Orton property' The
proposed rehabilitation of the nee fields is consistent with the overall conservation effort
of the owner and the revitalization of these areas as an historic and educational resource
benefits the public interest
The protect purpose calls for rehabilitation and protection of the historic nee fields The
nee fields included in the project represent the surviving remnant of the much larger
operation which once flourished at Orton Plantation These remaining nee fields have
been continuously served by a constructed fresh water reserve (Orton Pond) that was
initially formed in the 18th century The overall water management system has been
continuously maintained for over 280 years The fields have been protected by dikes
continuously maintained for the same time period Other nee fields of the Kendall
system, north of the subject nee fields within the Orton property (totaling approximately
180 acres of former fields and over 600 acres of dammed freshwater reserve) have
reverted to coastal marsh as their protective dikes and the water management system
deteriorated to the point of becoming nonfunctional The system of nee fields for which
the project is proposed remains intact and functioning and as such, is the sole remaining
viable nee plantation in North Carolina out of the 5 000 plus acres of nee that were
grown in the state at the time of the Civil War (See the attached map of `Plantations on
the Lower Cape Fear 1725 to 1760 ) Agricultural practices related to nee cultivation will
be employed within only those areas functiomng as a part of the present day intact,
hydrologic management system The alternative of restoring all the historic nee fields,
including the Kendall system, was considered by the applicant However, this alternative
was eliminated from further consideration due to permit feasibility (the prior owners had
applied for and been denied permits for similar activity) the extent of disturbance to
coastal wetlands that would result from the project, and the cost and effort required to re
establish the water management system As a result, the applicant does not seek to
reestablish fields which have been lost over time due to the destruction of their dikes or
water management systems, but only to reestablish nee cultivation on fields that remain
intact and have been maintained as managed freshwater areas
The project purpose remains unchanged and is consistent with the overall historic
Plantation restoration currently underway The attached correspondence and supporting
information submitted to the National Park Service provides more detailed information
regarding the historical significance of Orton Plantation including the surrounding nee
fields which represent the last remaining intact system in North Carolina Rehabilitation
of this system is an integral component of the historic restoration efforts being
undertaken by Orton Plantation Holdings LLC and represents a unique opportunity to
maintain and protect a regionally significant resource
' Over 50 people (including members of the NC Coastal Land Trust the NC Wildlife Resources
Commission the US Fish and Wildlife Service and the Cape Fear River Watch) attended this workshop

Belvedere Property Management LLC
Peter J Taltv
VIM rMS1*nr
March 1 2012
Alexandra M Lord PhD
Branch Chief
National Historic Landmarks Program
National Park Service
1201 Eye Street, NW
Washington DC 20240
Re Orton Plantation, Winnnabow, North Carohna
Dear Ms Lord
Further to our various communications and on behalf of the new owner of Orton
Plantation I am now pleased to summit a formal inquiry request for potential listing of
Orton Plantation as a National Historic Landmark
Built in 1735 by Roger Moore co founder of the adjacent historic Brunswick Town, the
ongmal Orton Plantation house is one of the oldest structures in Brunswick County and
has evolved into what is now considered to be a near - perfect example of Southern
antebellum architecture In 1773 Moore created the first and largest rice plantation on
the Lower Cape Fear River and as one of 35 inter coastal plantations Orton is now the
last remaining intact rice system in North Carolina.
In 1973 the Orton Plantation house and 12 acres of gardens were nominated on the
National Register of Historic Places (a copy of the original nomination is included with
this inquiry) Orton Plantation Holdings LLC purchased the property in 2010 Louis
Moore Bacon a direct descendant of Roger Moore, is the owner of Orton Plantation
Holdings LLC and it has become his mantra to rehabilitate and where possible restore
the property to a semblance of its antebellum grandeur During its history Orton
Plantation has been attacked by Native Americans used as a military hospital and was a
home to lawyers physicians military leaders and a Colonial governor
As part of this process of rehabilitation and restoration an application has recently been
submitted to North Carolina State Historic Preservation Office to extend the existing
nomination to include Orton s historic rice fields A copy of this application is also
included together with supporting information
1251 - \%enue of the Americas i 7" Floor
New Yotl._ N1 10020

Rehabilitation worx is almost complete on the original Orton Plantation house and
gardens and the proposed rehabilitation and restoration of the nee fields are currently
pending subject to permit approval by the U S Army Corps of Engineers A Cultural
Landscape Report is being compiled to establish Orton s hnstonc context within a wider
landscape and highlight Orton s cultural importance in the development of the Lower
Cape Fear Region
From its settlement in 1725 the region became the most prosperous in North Carolina by
1775 At this time no other region developed as rapidly as Lower Cape Fear and the
Moore s proved to be pivotal in shaping the regions political and economic importance
within North Carolina. The nee grown and produced at Orton was of a high quality fine
gram, which was highly prized and sought after as seed nee by the larger South Carolina
plantations The annual production of seed nee was critical in order to maintain the vast
economies and rapid growth of nee plantations in the southern states Orton and other
Lower Cape Fear plantations were a key factor in maintaining the development and
success of the Southern based nee economy Orton s nee fields have the potential to be a
primary source from which researchers can gain understanding about Colonial and
Antebellum penods of North Carolina and the Cape Fear Region
The above is but a brief overview of Orton Plantations complex social and cultural
historic importance A more detailed history is included with the attached National
Register nomination and application
On behalf of the owner I would hope that in recognition of Orton Plantation s historic
importance, much of wluch we are still uncovering Orton Plantation house gardens and
the surrounding nee fields would qualify for nomination as a Historic National
Landmark

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A PR.FLIN41NARY PLANNING STUDY FOR if
ORTON PLANTATION
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Please type or print
STATE HISTORIC PRESERVATION OFFICE
NORTH CAROLINA DEPARTMENT OF CULTURAL RESOURCES
OFFICE OF ARCHIVES AND HISTORY
SURVEY AND PLANNING BRANCH
STUDY LIST APPLICATION
7 HISTORIC PROPERTY NAME Orton Plantation Rice Fields (adjacent and part of National
Register Nominated Orton Plantation House & Gardens — 92 acres)
Other names n/a
(if historic name is not known use current name or address)
2 LOCATION (give street address in urban areas give both street address and physical location in rural areas for
example N side of SR 1234 0 5 mi S of SR 1965 [1123 Jones Farm Road])
Street/Secondary Road (SR)/Highway
Junction of S R1530 and S R 1529 0 8 mile dnve on pnvate road
Town or vicinity Smdhville Township County Brunswick County
GENERAL INFORMATION
A Is this an individual property or a historic district? Individual Property
(If this is a district, please consult with the National Register Coordinator at the State Historic
Preservation Office for guidance in completing this application )
B Property use and construction date(s)
Individual Properties
Primary budding/resource provide historic and current use original construction date
and if appropriate dates of additions If exact date is unknown, give approximate date
As an integral part of Orton Plantation the rice fields where constructed between 1726 and
the late 1750 s by Roger Moore The nce fields remain intact in their onginal layout and
configuration Histonc earthen dikes, facing ditches and quarter drains are fully evident
together with associated and functioning canal ditch and trunk gate flood system Upon
his death in 1750 Roger Moore left his Orton & neighbonng Kendal Plantations with 250
slaves Brunswick 1850 census shows Orton having a profitable Sawmill Com mill and
Rice Threshing machine producing 15000 bushels of rough rice (annual production of
325 000 pounds of Rice) together with 77 slaves
BPV Orion SHPO Ride Field N orm 217920 V

Rice production expanded and flourished until end of the Civil War Brunswick 1860
census lists Orton as having 144 slaves in 40 houses A public auction of Orton in 1872
advertised 9 026 acres with 300 acres of superior rice land of which 225 acres produced
16 300 bushels of rice with houses detached for 200 hands Orton Plantation is the last
remaining fully intact rice field system in North Carolina and last remaining plantation on
the Cape Fear River of 60 plus plantations which provided high quality and highly prized
seed rice to the larger southern plantations Reference materials suggest that rice was
last commercially produced at Orton during the early 1930 s As part of restoration
proposals by the current owner the Rice Fields are currently subject to a USACE permit
review process
Subsidiary buddmgs (if present) provide same as above for each building
Slave quarters water powered mill ancillary structures and lighthouse are evident from
plans and brick remains on site and are currently being researched to establish extent and
purpose
Historic Datnets provide historic and current use and give range of dates for the entire district, not
for individual buildings
Orton Plantation is adjacent to Old Brunswick Historic District Orton being built by one of
the founding settlers of Brunswick Town
C Approximate acreage Approximately 465 acres (Includes Rice Fields at 320 acres and
existing Nat Reg House and Gardens Nomination at 12 acres)
D Have any bmldbngs on the property been moved? Yes ❑ No V
(If yes explain the reason for the move and provide further details and the date of the move Use an
additional sheet if necessary )
E Architect and/or builder (if known)
4 APPLICANT OR CONTACT PERSON INFORMATION (If other than owner)
Name Orton Plantation Holdings LLC
9149 Orton Road SE
Winnabow NC 28479
Attn Mr Peter Talty
Address 17th Floor 1251 Avenue of Americas
City /State New York NY Zip Code 10020 Daytime Tel [phone]
E -mail address peter tatty @bllc com Signature J_.. 3
I 8P1L0r1ar -SHP0 Ri -1 iL1d i_ mom? 9201

5 This application is submitted [check one of the following]
1� by the owner ❑ with the owner s knowledge but not at his or her request
❑ at the request of the owner ❑ without the owner s knowledge
6 REASON FOR REQUEST (Please be brief Use a separate sheet of paper if you desire to provide a
longer response)
In 2025 Orton Plantation rice fields will be 300 years old The principal shareholder of the
owner's parent company is a direct lineal descendant of Roger Moore the founder of the
plantation and therefore has a keen interest in its history Moore created the first and largest
rice plantation on the Lower Cape Fear and as one of 35 inter coastal plantations Orton is now
the last remaining intact rice system in North Carolina The principal of Orton Plantation
Holdings LLC wishes to ensure that the Plantation House Gardens Rice fields are understood
and preserved as a legacy of an important facet of North Carolina history
7 Does the owner plan to seek rehabilitation tax credits? Yes ❑ No
If "yes" checked, answer question 12 Is the property income producing ❑ or nonuicome
producing ❑?
8 Has the property ever been surveyed by the State Historic Preservation Office or by a locally- sponsored
historic preservation project? If yes please give the name and date of the survey protect if known
The Rice Fields have been surveyed and researched as part of current Restoration /
Rehabilitation Permit proposals and a shore line archaeology survey will be conducted during
Spring 2012 No other surveys have been carried out at this time
9 LEGAL OWNER OF PROPERTY (For individual property only give mayor s name/address for districts)
Orton Plantation Holdings LLC
10 SUPPORTING INFORMATION
Please attach all of the requested supporting information Incomplete applications cannot be considered All
materials subnutted become the property of the State Historic Preservation Office and cannot be returned
A Description (Include as an attachment on a separate sheet of paper)
1) For individual properties briefly describe the original and current appearance of the
building(s) both exterior and interior Include information on any historic features that have
been, or will be removed or altered and describe all current and proposed additions
2) Briefly describe the setting for both individual properties and historic districts For example,
is it in a commercial area, residential neighborhood or a rural landscape9
B Fhstory (Include as an attachment on a separate sheet of paper)
Briefly outline the history of the property and give a short explanation of why the property
or district is historically or architecturally important Be sure to include information on any
significant local statewide or national historical events associated with the property historical
BPMO11anSHP0 Rice Freld Nom 2 9')012

individuals related to it, and/or any historical trends with which it is associated A detailed essay
is not necessary however, the information should clearly explain why the property meets the
National Register criteria Please refer to the enclosed National Register Fact Sheet 2 for
information on the evaluation criteria
C Map /Site Plan (Include as an attachment on a separate sheet of paper)
Provide a street or road map with the location of the property marked on it A hand -drawn sketch
map with the street and/or route numbers and a north arrow is acceptable for properties located in
unmapped city or county ,jurisdictions If there are several buildings on the property (such as a
farmstead, school campus or industrial complex) please provide a sketch site plan showing the
location of all of the buildings
D Photographs
Photographs may be digital images submitted on a CD (preferred) or color prints or color slides
If you submit digital photographs please include proofs of the images on paper To save paper
and ink, as many as nine images may be placed on a single 8 x 10 sheet of paper, though images
should be at least 3 1/4" x 2 1/2 Black and white proofs on plain paper are acceptable You do
not need to use expensive inks or papers for proofs Proofs provide a quick reference for the
property file to show us what is on the CD
Please use a CD -R and not a CD RW to burn your photographs CD -RW disks often will not
read in computers other than the one in which they were created We cannot accept photographs
as attachments to email except when only two or three are being submitted to supplement an
application for which most photos have been already subrrutted on a CD Call or email us before
sending photos as attachments
We prefer digital images m.jpeg format of no more than 500 Kb per image However, of you do
not have an image editor to manipulate image size or format, we will accept the images as they
are created by your camera
If you submit nnnts or slides HPO staff will scan them at no cost to vou.
Study List applications are presented to the North Carolina National Register Advisory
Committee (NRAC) in a PowerPomt presentation assembled by staff We prefer that you not
submit your photographs in your own PowerPomt presentation If your application is for a large
district or an unusually complex property we may consider using a PowerPomt presentation that
you have assembled though we reserve the right to edit the presentation to meet the needs of the
NRAC and to be of acceptable length for the agenda.
For individual properties, please provide a set of photographs showing all sides of the budding(s)
representative interior views, outbuildings (if any) and views of the setting Prints, slides, CDs, and
proofs of digital photos should be labeled with the name of the property, location, county, view, and
date If a site plan is included in the application (see C above) please key the views to the plan
I 1 ADDITIONAL INFORMATION REQUIRED FOR HISTORIC DISTRICTS
Note Before completing a Study List application for a historic district please contact the National
Register
Coordinator at the State Historic Preservation QfflCe WO) HPO staff usually make a site visit before
evaluating a Study List application for a district
BPi/ Orion SHPO Rr Fwld 'V m ') 9 012

A Map
The map should show the proposed historic district with the tentative boundaries clearly delineated
Proposed boundaries are usually defined during the HPO staff site visit
B Photographs (See item 10 -D for information about formats for photographs)
Photographs should illustrate the character of the proposed historic district with exterior views of
significant buildings, a selection of typical buildings, distinctive landscape features, and a few
representative views of streetscapes Please key the photographs to the district map
12 ADDITIONAL INFORMATION REQUIRED FOR PROPERTIES WITH PLANNED
REHABILITATION TAX CREDIT PROJECTS
Provide specific information about the building s period of significance and additions and,
alterations that have acquired historic significance in their own right If exterior alterations new
additions or adjacent or related new construction are planned, describe how they impact the
significant historic features of the building or its setting Also, please contact the Restoration
Branch at 919 -807 6590 if you have not done so already
This application mihates preliminary consideration of a property for nomination to the National Register of Historic Places
This does not mean that a property is being nominated to the Register at this time nor does this application constitute a
National Register nomination form The Study Last application is an evaluation tool that enables the staff of the HPO and
members of the NRAC to determine if the property has the potential to meet the criteria for listing in the National Register
Study List applications are presented three tunes a year to the NRAC These meetings are held in February June and October
If the application is approved by the committee, the property will be placed on the Study List. Applicants will receive written
notification of the committees actions shortly after the meeting These actions include placement on the Study List, denial of
the application or deferral pending receipt of additional information, often obtained through a staff site visit. Once a property
is approved for the Study List, a formal nomination to the National Register may be prepared Placement on the Study List is
not a guarantee that a property can be successfully nominated to the National Register Please see the enclosed handout entitled
The Study List and the National Register of Historic Places in North Carolina The nomination process is explamed on the
enclosed National Register Fact Sheet 3 "HOW HISTORIC PROPERTIES ARE LISTED IN THE NATIONAL REGISTER
OF HISTORIC PLACES
Please remember that the APO staff is available to assist you with general information about the required
supporting items for the Study List application If you are unsure about any of the requirements, please
contact the APO
Return to Ann V Swallow
National Register Coordinator
Survey and Planning Branch, HPO
4617 Mail Service Center
Raleigh, NC 27699 -4617
Oftke Locaiwn Archives/State Library
Building
109 East Jones Street
Raleigh NC 27601
Tekyhone 919/807 6587
Fax- 919/807 -6599
mad ann swallow&cdcr gov
8PA.1VHm1,5HP0 Rice Field Nom 2 9 X012
HPO website www hpo ncdcr gov
APPLICATION CHECE LIST
Do you have the following items m your
application packet?
❑ Completed two -page form (questions 1 9)
[f Physical description (question 10A)
History/Significance (question l OB)
❑ Historic district map (for district only)
Q Map marked with property location
❑ Site plan (multiple buildmgs/resources only)
❑ Rehabilitation information (question 12)
❑ Photographs or CD and image proofs —
labeled

ORTON PLANTATION HISTORIC RICE FILEDS - STUDY LIST APPLICATION
(Section 10) SUPPORTING INFORMATION
A Description
Orton Rice fields remain intact (see attached Rice Field layout and configuration) This
diagram shows the rice fields in relation to Orton plantation house and gardens together with
an overlay of the historic canals facing ditches and quarter drains The current owner has an
enforceable agreement with respect to the withdrawal of water form the historic 8 mile long
Orton Pond which was built to supply Orton s rice fields and water powered mills, constructed
circa 1725 by the damming of Orton Creek
The onginal rice field dike system is fully intact notwithstanding occasional breaches which
have always been promptly repaired or are part of a current restoration proposal within a
USACE permit application review process The demise of other historic Cape Fear Plantations
due to hurricanes and economic downturns has resulted in Orton being the last remaining
functioning rice plantation
The Front rice fields are dominated by invasive Phragmites with the Back rice fields being
colonized by volunteer shrub /scrub wetland species Aerial images reveal a complex network
of intact historic facing ditches quarter ditches and dikes which are in need of rehabilitation
Historic trunk gates and water control valves have been replaced and renewed over time and
the rice fields can still be flooded as originally intended 19 h & 20th century repairs are evident
to both Trunk Gates and the dike revetments facing the Cape Fear Rarer
Orton Plantation rice fields together with Orton pond have a significant geomorphology which
has dominated the surrounding landscape for nearly 300 years Historic plans and images
show that what was once a barren landscape stripped of its timber for ship building and
construction has over time been softened by regeneration of wetland fringes by Cypress trees
together with human intervention by the planting of what are now majestic Live Oak avenues
13PM Or11m SHPO Rrce Feel) i oin.2 79 2011

ORTON PLANTATION HISTORIC RICE FILEDS - STUDY LIST APPLICATION
(Section 10) SUPPORTING INFORMATION
B History
Between 1700 and 1775 no colony in British America experienced more impressive growth
than North Carolina, and no region within the colony developed as rapidly as the Lower Cape
Fear Totally uninhabited by Europeans in 1700 this isolated comer of North Carolina's
southern coast is particularly noteworthy for its relatively late colonization and its rapid rise to
economic prominence First settled in 1725 the region grew to be the most prosperous in
North Carolina by 1775 The study of the eighteenth - century settlement of the Lower Cape
Fear is a prime example for understanding North Carolina and the entirety of colonial America
as a patchwork of regional cultures (Bradford J wood 2004)
One family the Moore s proved to be pivotal in the development of the Lower Cape Fear
During early 1700 s they shaped the regions political and economic importance within North
Carolina The Moore s provide an instructive if exceptional example As the most powerful
family in the region they articulated an elite model of behavior many other families no doubt
emulated The Moore s like many other settlers clearly developed impressive and complex
kinship ties to the Lower Cape Fear Maurice and Roger Moore were powerful men coming
from one of South Carolina s most prominent families Maurice s father James Moore came to
South Carolina from Barbados in the 1670 s and served as Governor of South Carolina
between 1700 and 1703 These connections insured that two of the 10 siblings Maurice and
Roger would become wealthy and influential plantation owners
Orton and Kendal plantations were created on lands granted by the Lords Proprietors in 1725
to Maurice Moore who along with brothers Roger Nathaniel and a group of settlers founded
Brunswick Town (now within Historic Brunswick Town District) Maurice established lands
further up river and passed ownership of the land to Roger Although the Moore's had
originally emigrated from Ireland via Barbados Orton and Kendal were named after the
Moore s ancestral homes in the Lake district of North of England Roger Moore was among the
first settlers to build a distinctive plantation system along the Cape Fear River Some
fragmentary business accounts reveal that by 1735 Moore already exported lumber turpentine
and wood shingles from Lower Cape Fear At this time Moore also traded with connections in
both South Carolina and Barbados
These accounts probably provide only a small glimpse of the range of activities on Moore s
Orton & Kendall plantations Fifteen years later Moore s will revealed that his resources
included "Twenty Odd Thousand Acres of Land & Near Two Hundred and Fifty Slaves"
making him almost certainly the wealthiest plantation owner in North Carolina
Some time between 1726 and 1730 Roger Moore established a modest house on the 10 000
acre site to be called Orton The house was burned down by Cree Indians and his next home
was established on neighboring land which subsequently became Kendal Plantation However
by 1735 he had moved his family to a more suitable brick mansion situated on the original
Orton house site Over time and subsequent ownerships the original brick structure was
enveloped and extended to create a Greek Revival Antebellum house that is one of the most
recognized in North Carolina today
I 8Pa10r1arZ;HP01bce Field -Nom -) '9''012

Orton Plantation s rice fields as seen today were constructed some time between 1726 and
1750 together with the damming and construction of Orton pond which was essential as a
reserve to supply the rice fields with water The pond and rice field layout is recorded on many
early historic navigation plans of the Cape Fear River Research is ongoing and current
thinking suggests that the back rice fields contiguous to Orton pond protected by higher
ground and most easily fortified against the brackish Cape Fear River were developed first as
a beta test site to experiment with rice cultivation Due to their success a large dike
impoundment was built out into a shallow portion of the Cape Fear River This was equipped
with extensive irngabon and water control structures to modulate water levels At the same
time sluices drained the fresh water of Orton pond through a series of paddies and canals
within the original "Back rice fields to the 200+ acres of rice fields that provide the magnificent
foreground view from the front of the plantation house Although cultivation of rice and other
crops has been intermittent in the last few decades, the original system of water controls
sluices canals and embankments are largely in place and functional
Orton was the first rice plantation in the Lower Cape Fear Region and one of the largest in
North Carolina and because of his vast land holdings Roger Moore was referred to as King
Roger The amount of slave labor that was needed to build the original pond and back rice
fields was significant but with commercial success even more slaves were imported to build
out and cultivate the massive front rice fields This horrendous and cruel labor system gave
way after the civil war to large agrarian employment and eventually more mechanized
cultivation
Upon his death in 1750 Moore left his Orton and Kendal estates and 250 slaves to his sons
half brothers George and William William died seven years later and passed Orton to wife
Mary and son Roger (the younger) Orton was thereafter passed through various ownerships
• Richard Quince 1770 -1796
• Benjamin Smith 1796 -1826 grandson of Roger Moore and Governor of North Carolina (1810
11) 1800 Brunswick census lists 199 slaves
• Dr Fredrick Jones Hill 1826 -1854 1830 Brunswick census lists 55 slaves 1850 census shows
profitable Sawmill Com mill and Rice Threshing Machine producing 15000 bushels of rough
rice (annual production of 325 000 pounds of Rice) with 77 slaves
• Thomas Calezance Miller 18541872 Rice plantation flourishes until end of Civil War 1860
Brunswick census lists 144 slaves in 40 houses
• Isaac B Grainger 1874 -1876
• Currer Richardson Roundell Feb 1876- July 1876
• Cot Kenneth McKenzie Murchison 1884 -1909
• Luola Murchison Sprunt and James Sprunt 1909 -1924
• James Laurance Sprunt 1924 -1973
• James Laurance Sprunt Jr, Laurance Gray Sprunt Kenneth Murchison Sprunt Samuel Nash
Sprunt
• 1978 -2010 Louis Moore Bacon (descendant of Roger Moore) as principal of parent company
to Orton Plantation Holdings LLC
I BP I Orton SHPO Rim Field glom 2 9 '10I

Current rehabilitation of National Register nominated Orton Plantation house and gardens
together with the proposed rehabilitation and restoration of the rice fields highlighted the need
to connect the plantation house gardens and rice fields as one historic entity hence the desire
and importance of including the rice fields on the National Register In order to understand the
rice field systems as agricultural features the fields should be considered in context of the
plantation plantation house, slave villages kitchens, outbuildings and burial grounds As
cultural landscapes rice fields consist of interconnected systems of land water vegetation
and wildlrfe that differentiate them from other cultural resources
The rice grown and produced at Orton was of a high quality fine grain which was highly prized
and sought after as seed rice by the larger southern plantations The annual production of
seed rice was critical in order to maintain the vast economies and rapid growth of rice
plantations in the southern states Orton and other Lower Cape Fear plantations were a key
factor in the maintaining the development and success of the Southern based rice economy
Orton Rice fields have the potential to be primary sources from which researchers can gain
understanding about Colonial and Antebellum penods of North Carolina and the Cape Fear
Region
Extensive slave labor made the economic development of the Lower Cape Fear possible and
the circumstances surrounding slavery did as much to differentiate the Lower Cape Fear form
other regions as anything else Contemporaries acknowledged that there were many more
slaves in the region than could be found on inland territories Although fiercely independent of
South Carolina Governance and Tax structure Lower Cape Fear nee plantations represented
the most northerly position of the Carolina Low Country and is known as the upper most limit of
the Deep South
Orton's rice fields are the last of the many rice plantation's of North Carolina
They stand as tangible record of the skill and labor exerted by enslaved laborers Although the
noted Civil War battlefields of Fort Fisher and Fort Anderson flank the southern boundary of
Orton the reason for the war itself was the demands of the slave labor practice that built and
cultivated the plantation's rice fields that will hopefully be restored as its own 'battleground'
testimony
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North Carolina
COUNTY
NATIONAL REGISTER OF hiSTORIC PLACES
Brunswick
INVENTORY - NOMINATION FORM
FOR NPS USE ONLY
ENTRY NUMBER DATE
(Type all entries — complete applicable sections)
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COMMON
Orton Plantation
AND /OR HISTORIC
2 LOCATION
STREET AND NUMBER
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DESCR BE THE PRESENT AND ORIGINAL (it kno ) PHYSICAL APPEARANCE
Orton is a large, imposing Classical Revival mansion set amid great
magnolias and lave oaks draped with Spanish moss The present house com-
bines elements from three centuries The earliest elements (the first -story
front and side brick walls) were built about 1735 as part of a one- and -one-
half story dwelling In the 1840s the house was enlarged into a two -story
Greek Revival temple -form structure Evidence in the attic suggests a
possible intermediate stage of development, with the front part of the house
being raised to two stores (a center hall plan one room deep) earlier, and
the portico and rear section following in the 1840s Neoclassical Revival
wings were added in 1910, and other work was done in the main house, blendir
with what was built in the 1840s To the rear is an expansion done in the
early 1960s
The temple form main block of Orton retains much of its original
character It is a two -story stuccoed brick structure and has a gable roof
covered with slate The main (east) facade features a massive tetrastyle
Doric portico The entablature carries around the sides of the building
The elliptical lunette in the center of the pediment is apparently a 1910
elaboration of an earlier louvered lunette
The facade has at both levels a central doorway, which is flanked at
the first level by single wide three -part windows and at the second by pair;
of normal size windows, this arrangement existed at least as early as 1890
The first -level entrance consists of a single door flanked by fluted Ionic
columns and sidelights An entablature with pulvinated frieze breaks out
over the columns, above it is a wide transom with tracery These elements,
within paneled soffit and reveals, are framed by a symmetrically molded
architrave with roundel corner blocks and base blocks featuring a Greek fre�
The first -floor facade windows have nave- over -nine sash in the center sects
(replacing the original sax- over -six) and three- over -three in the sidelights
They are framed and divided by symmetrically molded architraves with rounds
corner blocks At the second level, the doorway, of twentieth century de-
sign, consists of a double door beneath a transom, the upper part of each
leaf is glazed The symmetrically molded architrave has corner blocks and
base blocks featuring a Greek fret This doorway serves a balcony which,
though it had an earlier precedent, was elaborated in 1910 It is supporte(
by large, carved scroll brackets and enclosed by turned balusters and
paneled pedestals that carry a molded rail The four `windows at this level
contain six -over -six sash and are framed by symmetrically molded architrave
with roundel corner blocks like those below Louvered shutters appear on
all windows of the main block and wings, except at the rear
The addition of the wings about 1910 altered the side elevations As
seen in a circa 1890 photograph, the widely spaced two front bays of the
south side of the main block were identical at both levels, with windows
containing six- over -six sash flanking an interior end chimney Behind
these (but within the block of the house) was a porch with a two -bay
elliptical- arched open arcade, four closely placed windows appeared above
Today the wing covers the second bay and the rear porch is enclosed, the
second -floor fenestration is undisturbed No early picture of the north
elevation has been found, the present scheme with six bays and two inter3_o3
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F m 10 900 UNITED STATES DEPARTMENT OF THE INTERIOR STATE
0 iy 1969) NATIONAL PARK SERVICE ,r__
NATIONAL REGISTER OF HISTORIC PLACES I COUNTY
INVENTORY NOMINATION FORM Brunswick
FOR NPS USE ONLY
(Continuation Sheet) - ENTRY NUMBER DATE
(N mb It r r )
7 A
The one -story side wings echo many of the features of the Greek
Revival main block, the wall, cornice, and window treatments are identical
The south wing is a single room Three arched openings occur in the south
wall, that in the center containing a French door The northern wing is
much larger and contains three bedrooms and several baths The flat roofs
of the wings are enclosed with balustrades identical to that of the gallery
on the temple form section
the plan of Orton would seem to have developed as follows a center -
hall plan, one room, deep, ca 1735, perhaps then raised from a story- and -a-
half to two full stories with the same plan, in the 1840s a transverse
stair hall and rear rooms added This plan probably was maintained until
the 1910 renovation An 1872 notice of the auction of Orton, states that
"The Improvements consist of a TWO STORY DWELLING HOUSE, containing 10
Rooms, Brick Basement 11 Ten rooms can be accounted for in the pre -
1910 portion of the house Besides adding the wings, Kenneth Murchison,
architect for the 1910 additions, altered the floor plan and some of the
interior tram of the house -- mainly at the first level On the first floor,
the walls which formed the center hall were removed, creating a large
parlor, extending the width of the main block The windows to the rear of
the fireplaces were enlarged as entrances to the wings The rear porch was
enclosed and some alterations made to the rear
The two stylistic eras (1840s Greek Revival and 1910 Neoclassical
Revival) present in the interior features are so compatible that identifying
all of them is impossible In addition, it appears that some of the Greek
Revival molding was either reused or reproduced In the parlor) all the
windows are framed with symmetrically molded architraves with roundel corner
blocks The reveals are flat - paneled with alternating square and vertical
panels A panel also occurs beneath each window The doors are framed with
a modified version of the front entrance, each employing a pair of Ionic
columns and an entablature with a pulvinated frieze The fireplace at each
end of the room features a gray -black marble mantel with engaged Ionic
columns which support a frieze of serpentine with faceted panels in the
center tablet and end blocks Elaborate plaster work of classical motifs
dating from 1910 forms the cornice and adorns the ceiling The stair located
in a transverse hall behind the parlor rises in two flights with a landing in
between The newel is turned and covered with acanthus leaves Turned
balusters carry a handrail oval in section Behind the stair hall is the bil-
liard room which has a tall neo- Federal style mantel, a molded chair rail,
and a deeply molded baseboard In the dining room, a shallow dome forms the
central portion of the ceiling The woodwork consists of a high flat - paneled
wainscot, syybo trically molded architraves with paneled corner blocks, and a
neo - Federal style mantel The south end of the dining room is treated as a
solarium Its terrazzo floor is raised one step, and the room is visually
divided by a pair of Tuscan columns which occur at each end of the step A
handsome art nouveau copper chandelier is the focal point The central
spherical globe is encircled by a filigree ring from which hang eight smallerl
GPO 921 72

F m 10 300a UNITED STATES DEPARTMENT OF THE INTERIOR TATC
(J y 969) NATIONAL PARK SERVICE North Carolina
NATIONAL REGISTER OF HISTORIC PLACES COUNTY
INVENTORY NOMINA T IO t FORM Brunswick
FOR NPS USE ONLY
ENTRY NUMBER I DATE
(Continuation Sheet)
tNumbo 11 ont 1 )
7 B
bulbs, each with a foliated cup
The second floor, although partitioned to create dressing rooms, bath-
rooms, and closets, retains much of its simple Greek Revival finish The hall
is unusually narrow and has a heavily molded transverse elliptical arch
carried on paneled pilasters The architraves in the hall and those in the
southeast bedchamber are symmetrically molded and have faceted corner blocks
Plaster cornices also occur in those two areas Mantels remain only in the
two front bedchambers They are wood and follow simple straight lines
Molded chair rails also occur in those rooms, however, their era is undetermin
able
The Orton Plantation gardens, open to the public, are among the best -
known in the southeast The gardens were developed in the early twentieth
century, and tlmany of its important parts were designed by the landscape
architect, Robert Swann Sturtevant, 11 Live oaks shade extensive plantings of
azaleas, and other flowering trees and shrubs abound A formal "scroll
garden," a "white circle garden" and a "sun garden" are individually treated
A 1915 Memorial Chapel and a curious tomb said to be that of the first owner
of Orton, "King" Roger Moore are on the grounds as well The vast rice fields
have been leased to the North Carolina Wildlife Resources Commission as a
waterfowl sanctuary Still visible are many of the old ditches and drains,
part of the elaborate irrigation system for the rice fields, some are still
used to flood the fields for the autumn migration of the birds
6P0 921724
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❑ 151h C I y
❑ 17th C I y
19th C t y
SPEC rIC DATE(S) (Il Apt
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ARi=AS OF SIGNIFICANCE
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STATEMENT OF SIGNIFICANCE
Orton Plantation is an impressive and intriguing composite of three
centuries of remarkably eventful history It was a vast and fertile plan-
tation yielding great wealth first from naval stores, then from rice pro-
duction The house began as the relatively small circa 1735 home of the
colorful and powerful early settler, "King" Roger Moore, saw the rising and
falling fortunes of a series of notable owners including Governor Benjamin
Smith, grew to a sophisticated and imposing Greek Revival temple -form
structure in the 1840s, suffered the vicissitudes of the Civil War and
Reconstruction, was reclaimed in the 1880s as a luxurious winter hunting
retreat, and in the twentieth century has been lavishly expanded and
renovated, so that today, with its superb gardens it is perhaps the best -
known antebellum showplace in North Carolina, typifying the romanticized
ideal of the Southern mansion
Among the first settlers along the lower Cape Fear River were the
Moores, sons of James Moore, a governor of the province of South Carolina
They became acquainted with the area while on a military expedition to
relieve North Carolinians embattled by fierce Tuscarora Indians By 1728,
Maurice Moore had patents amounting to 9,210 acres and his brother Roger,
12,780 acres Roger Moore built on this land probably about 1725 His
house was located on the west bank of the Cape Fear River between present
cities of Wilmington and Southport Known as Orton, probably after an
English place name associated with the Moore family, it was burned by
Indians whose encampment was across the raver from it The imperious and
opulent Moore is supposed not long after to have armed his many slaves and
entirely eradicated the Cree band responsible Sometime before 1734 "King"
Roger Moore, as he was called, built the house whose walls form the core of
the present Orton A traveler's letter dated 1734 relates
Mr Roger Moore, hearing we had come, was so kind as to send fresh
horses for us to come up to his house, which we did and were kindly
received by him, he being the chief gentleman in all Cape Fear Has
house is built of brick and exceedingly pleasantly situated about
two miles from the town and about half a mile from the river, though
there is a creek that comes up close to the door between two beautiful
meadows about three miles in length He has a prospect of the town of,
Brunswick, and of another beautiful brick house, a building about half
a mile from him belonging to Eleazer Allen, Esq , late speaker to the
Commons House of Assembly in the province of South Carolina
I
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F m 10 300 UNITED STATES DEPARTMENT OF THE INTERIOR STATE
(J ly 1969) NATIONAL PARK SERVICE North Carolina
NATIONAL REGISTER OF HISTORIC PLACES COUNTY
INVENTORY NOMINATION FOPM Brunswick _
FOR NPS USE ONLY
ENTRY NUMBER DATE
(Continuation Sheet)
(Nu b all nt 1
8 A
Still another nearby house, Russellborough, was owned by the Moores and served
as the residences of royal governors Arthur Dobbs and William Tryon The only:
lucrative trade of the Cape Fear area at this time was in naval stores purchas )d
by England for hpr ships Orton with its rash pane forests no doubt contr3.butid
much lumber, turpentine, tar, and patch to this trade King Roger Moore died
in 1750 leaving a vast estate including 250 slaves
A few years later Orton was bought by a wealthy local merchant, Richard
Quince A lady diarist writing about 1775 mentions Quince and includes a
reference to the pre - Revolutionary tenor of the times
We got safe on shore and tho' quite dark landed from the boat with
little trouble, and proceeded thro' rows of tar and pitch to the house
of a mercht to whom we had been recommended These [houses] are
inhabited by merchants of whom Mr Quince, our host, is first in con-
sequence He is deeply engaged in the new system of politicks] in
which they are all more or less, tho' Mr Dry the Collector of Customs,
is the most zealous and talks treason by the hour
A year after these words were penned, British soldiers burned William Dry's
home, Russellborough, the former governor's residence Its ruins are one-
half mile from the entrance to Orton
In 1796, Richard Quince, Jr , sold Orton to Benjamin Smith, an aide to
General George Washington in the Revolution and a grandson of King Roger Moor(
Smith was one of the first trustees of the University of North Carolina and
became its first benefactor when in 1789 he gave it land warrants for 20,000
acres Smith Hall, built in 1850 as hall for literary societies and now
serving as the Playmakers Theater, was named for him He was fifteen times a
state senator and was serving as such when he was elected governor of North
Carolina in 1810 Though an able man, Smith suffered financial reverses that
forced the sale of Orton In 1821 it was advertised as
the late residence of Governor Benjamin Smith, containing 4,975 acres,
more or less Of this track between 400 and 500 acres is swamp land
of a strong and fertile soil, which, it is believed will produce at
least 1,000 lbs of cotton or four times of rice to the acre
Included in the premises is a very superior and never failing mill
stream with an e3wellent dam, wanting only flood gates The rice
machine mill and gin having been recently destroyed by fire The pond
may be used at all times as a reservoir of water to flow the low lands,
thus rendering Orton one of the most valuable rice plantations in the
c ountry
In 1826, Dr Frederick Jones Hill bought Orton Hill was a state sena
in 1835, and a representative the succeeding three legislative sessions, it
was his education ball, passed in 1839, that put into operation a public Be]
system for the state During Hill's ownership Orton house was enlarged and
6P0 921 724

Fo m 10 300 UNITED STATES DEPARTMENT OF THE INTERIOR STATE
Q iy 19691 NATIONAL PARK SERVICE North Cal olina
NATIONAL. REGISTER OF HISTORIC PLACES COUNTY
INVENTORY NOMINATION FORM Brunswick
FOR NPS USE ONLY
(Continuation Sheet) ENTRY NUMBER DATE
(Numb II nI I )
8 B
the central block took on its present rather typical antebellum appearance
with a full Doric portico
Thomas CaleWce Miller bought Orton in 1851 According to the census
of 1860 he had 417 acres in cultivation and 8,276 unimproved or fallow There
were 561,000 pounds of rice on the lantation, indicating it wa still the
chief crop The estate contained 1 slaves and was valued at X2,500 The
Civil War apparently caused the abandonment of Orton It is said to have been
used around that tame as a hospital for smallpox victims An auctioneer's
handbill of 1872 advertised Orton and "Lands adjacent thereto, 9,026 acres by
actual survey " Among other particulars listed are its two -mile front on the
river, water power from a pond seven miles in length, ten -room dwelling house,
and houses for 200 hands
About 1880 Orton became the property of Colonel K M Murchison, a former
Confederate officer who after the war had built a successful cotton and naval
stores trade in New York Murchison built the first hotel of any note in
Wilmington and called it "The Orton" He restored the decayed Orton Plantatio
and spent his winters there, where hunting on its vast acreage was his frequen
pastime When Colonel Murchison died in 1901, his son -in -law James Sprunt
bought the estate Like most of Orton's owners, James Sprunt was a noted
figure During the Civil War, when a youth of seventeen, he went to sea as
purser on ships running the Federal blockade of Wilmington While so employed
he was captured and imprisoned for some months After the war, he was a membe
of his father's cotton export firm and become a well civic leader
and philanthropist His interest in history led him to become a knowledgeable
writer on historical events and to endow the publication of historical studies
by the University of North Carolina Mr Sprunt lavished care on Orton and
undertook the addition of wings to the main structure in 1910 Orton remains
in the Sprunt family In the mid- twentieth century Orton has come to be the
state's most widely recognized example of "Southern" architecture, its romanti
facade amid lush gardens is widely pictured on travel posters, wallpaper) and
most recently, represents the South on boxes of Scotties Tissues in the
"Rediscover America" series (see enclosure)
GPO 921 724

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19 hIAJOR BIBLIOGRAPHICAL REFERENCES
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Research by Charles Blume, survey specialist, architectural description by
Janet Seapker, survey specialist
New Hanover County Records, New Hanover County Courthouse, Wilmington,
North Carolina, Office of the Register of Deeds (Subgroups Deeds,
Wills)
New Hanover County Records, State Department of Archives and History,
Raleigh, North Carolina (Subgroups Deeds, Wills)
Brunswick County Records, Brunswick County Courthouse, Wilmington, North
Carolina, Office of the Register of Deeds (Subgroups Deeds, Wills)
�Q fGFOGRAPHICAL DATA > z ` i r
LATITUDE AND LONGITUDE COORDINATES LATITUDE AND LONGITUDE COORDINATES
DEFINING A RECTANGLE LOCATING THE PROPERTY O DEFINING THE CENTER POINT OF A PROPERTY
R OF LESS THAN TFN ACRES
CORNER LATITUDE LONGITUDE LATITUDE LONGITUDE
D 9 M 1 S d D gre Mn t Sc d D 9 e MI t S o d D 9 Mi 1 Se d
NW 34- 03 54 77 57 02• 0
NE 34' 03 54 77° 56 25
SE 77° 56
SW 34 0 03 09 02
APPROXIMATE ACREAGE OF NOMINATED PROPERTY 12 acre _
(LIST ALL STATES AND COUNTIES FOR PROPERTIES OVERLAPPING TATE OR COUNTY BOUNDARIES
STATE
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��FORM PREPA) 6,Z k �� v n � �. a �s r
NAME AND TITLE
Planning Unit Staff
ORGANI 2A TION
DATE
S to Department of Archives and History
13 December 1
STREET AND NUMBER
CITY OR TOWN
STATE
CODE
North Carolina
�z TXTE PAISON OFFICER t`r 75 WICC1 09'tip'
� fiIATIONXt'RI r4l': r ER'YERlf]CATVN
As the designated State Liaison Office fo the Na-
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tional Historic P eservat On Act of 1966 (Publ c Lou
I he eby ce tify that this P Operty Is included in the
89 -665) I he eby —Mate th s P operty fo -Iclus on
Not onai Registe
in the Not onal Register and ce t fy that t has been
evaluated acco ding to the triter a and P ocedu es s t
forth by the National Park Service The recommended
—
Chief Off ce of Archeology and H storlc P eservalion
level of s gin f cane of this noaunation is
National 0 State (D Local 0
�
Date
Name i X
ATTEST
H. G Jone6
L
IKeeper
Title State Historian /Adnanistrator
D tc 13 December 1972
of The Nat ona! Reg eta
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Historic Rice Field Protection and Restoration Protect
Appendix E
Olsen Associates Memorandum

MEMORANDUM
Date April 11 2012
To Steve Morrison LMG
From Christo her G Creed P E /`��
o p associates inc
Coastal Engineenng
Re Orton Plantation Front Rice Field River Dike Rehabilitation and Stabilization Project
Additional Information Regarding Technical Justification for Coastal Wetland Impacts
This memo addresses DCM s March 30 2012 request for additional information regarding the technical
justification for coastal wetland impacts associated with the riverfront dike
Rvverfront Dike The proposed plan calls for the riverfront dike to be raised to a uniform elevation of +9
ft NAVD ( +11 5 ft MLW) with side slopes of IV 1 5H Where the dike is to be revetted the river side slope
will be IV 2H
Existing elevations along the dike vary between +4 5 and +6 ft NAVD ( +7 to +8 5 ft MLW)
Observations indicate that the existing dike is frequently overtopped by ship induced waves These waves can
be as large as 4 to 5 feet depending upon ship size and water levels at the time of ship passage Overtopping
from the ship waves contributes to erosion of the upper elevations of the dike and saltwater intrusion into the
adjacent Orton Plantation front nce fields Depending upon the timing of high tide and the ships passage in the
Cape Fear River such overtopping events can occur daily
Based upon observations of ship wave effects (i e overtopping and dike crest erosion) the size of ship
waves in the Cape Fear River and the protection afforded by temporary dike repairs at Orton Plantation crest
elevations between 8 and 9 feet it has been determined that a dike crest elevation of +9 ft NAVD ( +11 5 ft
MLW) is necessary to reduce the potential for ship wave induced overtopping and dike crest erosion Although
this elevation may not completely eliminate the potential for ship and storm induced overtopping it is expected
that it will reduce the amount and frequency of overtopping to manageable levels
The proposed river side revetment slope of IV 2H is required for armor stability under the existing tides
currents waves (wind and ship) and seabed elevations (ref USACE Shore Protection Manual 1984) The dike
side slope of IV 1 5H was selected as the minimum slope necessary to maintain a stable earthen slope
Effects of Rvverfront Revetment to Coastal Marsh There are two areas along the riverfront dike where
all marsh area is eroded away completely or remaining marsh is eroded to the point that it cannot provide
sufficient protection to the enhanced dike even if stabilized with marsh edge armoring It is along these two
areas where the riverfront revetment is proposed (see Concept Pan Sheet 2 of 15)
2818 H- r-,chel Stre -t
Jacksonv Ile FL 32204
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V Oise -I assOc to corn

Page Two of Two
Steve Morrison LMG
April 11 2012
The two revetments will impact five discrete areas of coastal marsh along the Orton riverfront shoreline
(see Concept Plan Sheets 6 through 9 of 15) These five areas include the four revetment `transition areas and
one area of coastal marsh that is highly eroded less than 10 feet in width and is located along the areas of
shoreline that is exposed to the highest erosional stress where a revetment is the preferred engineering solution to
provide adequate stability to the riverfront dike (see Concept Sheet 8 of 15) The impact to this one area of
coastal marsh is unavoidable
As discussed in the March 12 2012 memo transitions are required between the revetment and the
adjacent dike enhancement area to provide stability to the revetment and enhanced dike The transitions consist
of narrowing revetment material between the full revetment section and the adjacent un revetted dike (i e
enhanced dike) Given revetment enhanced dike and marsh conditions the transitions are required to be located
across limited areas of the fringe coastal marsh immediately adjacent to the revetment areas The revetments
cannot be terminated with a blunt end nor can they be terminated in areas where the marsh is completely
eroded away Neither of these approaches would provide reliable or sufficient protection to the un revetted
enhanced dike area immediately adjacent to the revetment
To minimize the effect of the transitions to the coastal marsh the transitions were limited to areas where
the width of the marsh fringe adjacent to the revetments areas is less than 30 feet measured as the distance
between the existing dike toe and marsh edge Based on the tenuous stability of rapidly eroding narrower marsh
fringe areas it was determined that a marsh width less than 30 feet would not provide sufficient protection to the
enhanced dike even with marsh edge stabilization This criterion was selected from field observations of ship
wave influences and marsh edge erosion conditions The estimated spatial extent of the transition impacts to the
coastal marsh is based upon consideration of the required geometry of the transitions and the mapped
configuration of the coastal marsh fringe
Given the location and configuration of the revetment transitions and coastal marsh, variations of the
proposed enhanced dike and revetment elevation within a range that would still meet the project objective of
reduced overtopping and increased stability would not alter the amount of expected impacts to the coastal
wetlands Also the seaward slope of the revetment cannot be altered A steeper revetment slope would
contribute to structure instabilities (USACE Shore Protection Manual 1984)
Marsh Edge Stabilizattom The marsh edge stabilization will be rip rap or equivalent hydraulically
stable armoring material The crest of the marsh edge stabilization will be uniform at an elevation of +3 5 ft
NAVD ( +6 0 ft MLW) This elevation is 1 8 ft above MHW and 15 ft above MHHW at the site
Recommendations based upon observation of marsh edge stabilization in high energy wave climates indicate
successful applications exist where the crest elevation is 1 to 2 feet above MHW (VIMS 2006) We have chosen
a value on the upper end of this range due to the extremely large and long period waves that impact the Orton
Plantation river shoreline The existing marsh edge elevation varies from +1 to +3 ft NAVD ( +3 5 to +5 5 ft
MLW) As such the crest of the marsh edge armoring will vary from 0 5 to 2 5 above the marsh edge
elevations Given the wave climate along this shoreline a uniform crest elevation of the marsh edge armoring is
essential for the hydraulic stability of the marsh edge stabilization Circulation between the river and the coastal
marsh along areas where the marsh edge stabilization is located will be maintained by flows around the terminal
ends of the structures as well as through the interstitial voids within the armoring material

Historic Rice Field Protection and Restoration Protect
Appendix F
Shoreline Erosion Aerial

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Historic Rice Field Protection and Restoration Project
Appendix G
Avoidance and Minimization Proposal

AVOIDANCE AND MINIMIZATION PROPOSAL
ORTON PLANTATION
U S ARMY CORPS OF ENGINEERS ACTION ID # SAW 2011 00624
Submitted 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 further avoid and minimize impacts to waters of the United States The
modifications consist of areas within the historic nee 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 functional 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 nee fields and the wildlife habitat provided in the areas of nee cultivation
• The degree of disturbance of or intrusion into the visual landscape component of the historic
value of the historic nee plantation
• The degree to which cultivation of nee 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 nee field to the efficient functioning of the water
management system
Wetland Functional Value
The overwhelming majority of the nee fields were rated as overall Low functional value due in
large part to the fact that the hydrology of the nee 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 nee fields have particularly in the back
nee 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 nce fields Consequently,
these soils are generally not physically capable of supporting trees which would form a mature
closed canopy typical of a forested rverne 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 #9 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 Value Enhancement
Presently there are a number of types of wildlife habitat provided within and along the fringes
of the nce fields In some areas along the fringes of the historic field a forested canopy of
mature trees can be found Other areas of the nce fields have been allowed through disuse or
mismanagement over the years to grow into a shrub scrub habitat Additionally large areas of
the nce fields have suffered infestation by Phragmites australis a noxious weed
Each of these vegetation assemblages provide habitat of greater or lesser value and diversity In
general soil conditions in the nce 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 functional 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 nce 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 nce fields once they are
returned to rice cultivation Protection of the visual landscape can be accomplished by
maintaining and cultivating rice in the intact nce fields in their entirety The visual landscape
could be significantly impaired by taking substantial portions of the intact nce 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 constructed 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 protect 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
Operational Efficiency
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
3

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 #1 are infested by Phragmates australas The elimination
of Phragmates 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 1 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
Race Field Exclusion Area A
Rice Field Exclusion Area A is 3 8 acres in size and adjoins Rice Field #9 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 18'' 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 structures) 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
1 Infestation by Phragmates australas has been detected in Rice Field #9 and in the Back
Rice Field , though to a less significant degree than in the Front Rice Fields or Rice Field #1
However domination by Phragmates australas 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
Phragmates australas and the resultant loss of significant wetland functions and values in all rice
fields
El

Additionally, Rice Field Exclusion Area A is somewhat visually isolated from the remainder of
Rice Field #9 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
Race 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 fnnge 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
Race 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 function between the
Back Rice Field and Rice Field #1 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 #1
Additionally Rice Field Exclusion Area C is bounded on the west and south by a mayor
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 further impact waters of the United States, counterbalancing
its size from the perspective of agriculture operational efficiency
5

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 nce 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
Race 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 construction of the water management system at Orton Pond Reserve and adjacent
nce fields in the 18'h 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 structures) hydrologically isolated from the remaining nce 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 nce field system makes it an appropriate candidate for exclusion
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