20120982 Ver 1_Staff Comments_20121101

Strickland, Bev
From: Kulz, Eric
Sent: Thursday, November 01, 2012 8:45 AM
To: Coburn, Chad
Cc: Montgomery, Lori; Strickland, Bev
Subject: FW: Town Creek Headwaters Mitigation Bank (Brunswick Co.)- Onsite Meeting (12 -0982)
Chad
I will be out of town on 11/20, so if you could make this meeting, that would be great.
The prospectus is already on Laserfiche at 20120982.
At this point, issues I have are as follows:
As a whole, the project looks like it would provide a lot of water quality value to receiving waters and the Green Swamp
TNC area, IF the entire project is implemented. It is being proposed in phases based on market demand. I understand
the economics of the situation, but not completing all of the phases would greatly diminish the water quality
improvement values described in the prospectus, and in some cases these improvements would not occur at all if the
entire project is not done.
Several specific items of concern were noted, On page 20, the prospectus states that R. Richardson Road and Old Modes
Island Road through the site will remain open (public safety. Fire control, etc.). It goes on to say that "the removal of
interior forest roads is still under consideration as is the potential for providing direct hydrological connections between
the bank site and the TNC Green Swamp Preserve ".
In my opinion, allowing the forest roads to remain diminishes the value of the site in that altered surface water flow
patterns (culverts and roadbeds) will remain on the site. The value in such a large site is its natural hydrologic
connectivity. Similarly, the prospectus mentions numerous times about the value of the site related to its location
abutting the Green Swamp preserve. Not providing direct hydrologic connection again diminishes the value of the
project.
Finally, I think the proposed service area is excessive and is greatly expanded to what has been allowed for previous
banks. Given the sites location straddling two HUCs (03040206 and 03030005) and its close proximity to another
(03040207), these three HUCs seem to represent a reasonable service area. Adding 03030006 and 03030007 (which of
course includes Wilmington) is excessive and is not consistent with the rationale used by the IRT in permitting other
banks. The additional two HUCs may be proposed as a "secondary service area ", but the adjacent HUC multiplier (x1.5)
should be applied.
If you can make the site visit, try to work some of these concerns into the conversation. If not, can maybe Joanne cover
for you?

E -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties
From: Sugg, Mickey T SAW [ mailto :Mickey.T.SuagCa)usace.army.mil]
Sent: Wednesday, October 31, 2012 4:03 PM
To: Matthews. Kathy a epamail.epa.gov; Fritz Rohde; Jeffrey Garnett; Kulz, Eric; Coburn, Chad; Snider, Holley; Wilson,
Travis W.; Wilson, Debra; Sollod, Steve; Dunn, Maria T.
Cc: Ed Sweeten; Tony Doster; Wayne Plummer; McCrain, Gerald R; Hedman, Craig W; Tugwell, Todd SAW; Amschler,
Crystal C SAW; Hughes, Emily B SAW
Subject: Town Creek Headwaters Mitigation Bank (Brunswick Co.)- Onsite Meeting
Good afternoon-
You should be receiving the Public Notice soliciting comments for the proposed Town Creek Headwaters
Mitigation Bank located in the Green Swamp complex. An onsite meeting /evaluation has been set for Nov.
201h (Tuesday) @9:30 and I would certainly welcome the company to review their proposal. Total acreage is
1,691 and as stated in the prospectus, the bank would be constructed in phases. The Nov. 20th meeting is
being held prior to the Nov. 301h commenting deadline so you can incorporate any onsite observations into your
comments. I realize that this is Thanksgiving week, but that was really the best option the date in order to fit it
within the 30 day commenting period.
Pls let me know if you are interested. Probably will meet in Supply- intersection of Hwy 17 & 211 (will confirm
this with Atkins closer to the date). It's a big site, so I assume —3 hours to go thru the prospectus and recon
the site (pending how much & to what detail of the site we want to review).
In addition to my 10/16 e -mail, the prospectus is being placed on our webpage:
http:// www.saw.usace.army.miI/Wetlands /Notices /Current notices.html . I thought it was being downloaded
today, but look for it sometime tomorrow.
If you needed, pls call me.
- mickey
Mickey Sugg, Project Manager
US Army Corps of Engineers
69 Darlington Avenue
Wilmington NC 28403 -1343
(910) 251 -4811 (o)
(910) 251 -4025 (fax)