20171045 Ver 1_RE Notice of Adaptive Management Plan Review_20210607

Strickland, Bev
From: Browning, Kimberly D CIV USARMY CESAW (USA)
<[e-mail]>
Sent: Monday, June 7, 2021 3:25 PM
To: Wiesner, Paul
Cc: Reid, Matthew; Allen, Melanie; Aaron Earley; Kristi Suggs; Haywood, Casey M CIV
(USA); Tugwell, Todd J CIV USARMY CESAW (US); Davis, Erin B; Bowers, Todd; Wilson,
Travis W.; Leslie, Andrea J; Smith, Ronnie D CIV USARMY CESAW (USA); McLendon, C
S CIV USARMY CESAW (USA)
Subject: [External] RE: Notice of Adaptive Management Plan Review/ NCDMS Key Mill
Mitigation Site/ Surry County/ SAW-2017-01504
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Good afternoon
The 15-day comment review period for the NCDMS Key Mill Mitigation Site Adaptive Management Plan (SAW-2017-
01504) closed on June 1, 2021. Per Section 332.8(o)(9) of the 2008 Mitigation Rule, this review followed the streamlined
review process. All comments received during the review process are below.
DWR has some concerns with the completed AMP, particularly the construction of berms and riprap channel in the
conservation easement. Although we originally discussed a site visit in fall, we would like to schedule one sooner and
hold off on the credit release until after our visit. We currently have July 8, 13, 27 and 29 open.
EPA Comments, Todd Bowers:
I have reviewed the Adaptive Management Plan for the Key Mill mitigation site sponsored by Wildlands Engineering
dated April 20, 2021. Following the MY1 Report it was determined that much of the site (5 acres or approximately 51%)
would need supplemental planting in order to meet interim vegetation performance as much of the project was
experiencing high mortality rates due to poor soil conditions, late season planting and multiple flooding events.
Wildlands has proposed a reasonable approach to correct this deficiency and has recommended additional monitoring
and soil amendments to ensure vegetation success. I am curious about the proposed soil amendments going only to the
new bare root plantings (3 ounces to the base of each planted tree in all areas across the Site that were slated for
supplemental planting). If there is a possible sitewide deficiency in soil nutrients, carbon or low cation exchange
capability, what is the contingency to ensure the rest of the site remains in a trajectory towards success? Are only the
areas of concern focused on the storm damage where topsoil was removed exposing poor -quality subsoils? Should we
be expecting continued or excessive mortality in the areas that will not receive the soil amendments? I am all for
improving the soil conditions of the areas of low stem density but will the rest of the site be able to perform as
expected? I suppose this a question that can only be answered as MY2 data is collected.
I have some issues with the planting plan in Section 4.2 and the revised Sheet 2.1. Both the bare root and live stake lists
do not match each other between the narrative and the revised list on Sheet 2.1. For example, the narrative in includes
witch hazel, red mulberry, white oak, boxelder and are missing from this list. Southern red oak (Quercus falcata), paw
paw (Asimina triloba), silver maple (Acer saccharinum), green ash (Fraxinus pennsylvanica), American holly (Ilex opaca)
and American beech (Fagus granfolia (sic)) are not mentioned in the narrative for bare root plantings in Section 4.2.1.
Elderberry (Sambucus canadensis) and button bush (Cephalanthus occidentalis) are not in the narrative for live stakes in
Section 4.2.2.. All the species are appropriate for the site and I don't have any issues with those chosen.
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Excellent pre and post -repair photos. Only item to mention is that for consistency sake the photos should be taken from
the same location. Most of the follow-up post -repair photos I saw, while generally clear, were taken from the opposite
bank as the pre -repair.
Please let us know if any of the dates listed work for a site visit.
Thanks
Kim
Kim Browning
Mitigation Project Manager, Regulatory Division 1 U.S. Army Corps of Engineers
Original Message
From: Haywood, Casey M CIV (USA) <[e-mail]>
Sent: Monday, May 17, 2021 2:13 PM
To: Tugwell, Todd J CIV USARMY CESAW (USA) <[e-mail]>; Browning, Kimberly D CIV USARMY
CESAW (USA) <[e-mail]>; Davis, Erin B <[e-mail]>; Bowers, Todd
<[e-mail]>; Youngman, Holland J <[e-mail]>; Twyla Cheatwood
<[e-mail]>; Wilson, Travis W. <[e-mail]>; [e-mail];
Haywood, Casey M CIV (USA) <[e-mail]>
Cc: Wiesner, Paul <[e-mail]>; Reid, Matthew <[e-mail]>; Allen, Melonie
<[e-mail]>; Aaron Earley <[e-mail]>; Shawn Wilkerson
<[e-mail]>; Kristi Suggs <[e-mail]>; Brandon Romeo
<[e-mail]>; Joe Lovenshimer <[e-mail]>
Subject: Notice of Adaptive Management Plan Review/ NCDMS Key Mill Mitigation Site/ Surry County/ SAW-2017-01504
Good morning IRT,
The below referenced Adaptive Management Plan review has been requested by NCDMS. A copy of this AMP is
attached. Per Section 332.8(o)(9) of the 2008 Mitigation Rule, this review follows the streamlined review process, which
requires an IRT review period of 15 calendar days from this email notification. Please provide any comments by 5 PM on
March 11, 2021. Comments provided after the 15-day comment deadline may not be considered.
At the conclusion of this comment period, a copy of all comments will be provided to NCDMS and the NCIRT along with
District Engineer's intent to approve or disapprove this AMP.
Please note that the repair work has already been completed. At the Monday May 10, 2021 IRT credit release meeting,
the IRT indicated that project credits proposed for release should be put on HOLD until the IRT reviews the project's
AMP. The IRT additionally noted that they would like to complete a site visit in the fall of 2021 but they do not
anticipate holding credits until the site visit is conducted.
*Note to IRT members: Please send comments to the USACE Mitigation Team only.
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15 Day Comment Start: May 17, 2021
15-Day Comment Deadline: June 01, 2021
45-DE Decision: July 01, 2021
Project Information:
Key Mill Site
DMS Project # 100025
USACE # SAW-2017-01504
DWR # 20171045
RFP: 16-006993 — Issued 09/16/2016
Institution Date: 05/25/2017 — Full Delivery
Yadkin River Basin
Cataloging Unit 03040101
Surry County, North Carolina
Project Assets:
6,107.300 SMUs (cool)
FD Provider: Wildlands Engineering, Inc. — Contact: Aaron Earley, PE, CFM, [e-mail]
<mailto:[e-mail]> Office: 704-332-7754 (x109) & Mobile: [phone]
NCDEQ - DMS PM: Matthew Reid; [e-mail] <mailto:[e-mail]>, (828)-231-7912
The Adaptive Management Plan - As -Built/ Record Drawings can be accessed directly on the DMS SharePoint site here:
IRT-DMS SharePoint Page:
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https://ncco n nect.sha repoi nt.com/sites/I RT-DMS/SitePages/Home.aspx
<Blockedhttps://ncconnect.sharepoi nt.com/sites/I RT-DMS/SitePages/Home.aspx>
KeyMill_100025_AMP_May 17, 2021
KeyMiII_100025_AMP_May 17, 2021.pdf <Blockedhttps://ncconnect.sharepoint.com/sites/IRT-
DMS/Misc%20Documents/Forms/Allltems.aspx?id=%2Fsites%2FIRT%2DDMS%2FMisc%20Documents%2FKeyMiII%5F100
025%5FAM P%5FMay%2017%2C%202021%2 Epdf&pa rent=% 2Fsites%2F1 RT%2DDMS%2FMisc%20Docu ments>
Please contact the mitigation team if you have questions.
Thank you,
Casey
Casey Haywood
Mitigation Specialist, Regulatory Division I U.S. Army Corps of Engineers
BUILDING STRONG ®
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