20220439 Ver 1_Draft mitigation plan comments_20210608

Strickland, Bev
From: Jessop, Jordan E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, June 8, 2021 3:19 PM
To: Preziosi, Christian; Novak, Corey
Cc: Kim Browning; Tugwell, Todd J CIV USARMY CESAW (US); Davis, Erin B; Haywood,
Casey M CIV (USA)
Subject: [External] SAW-2019-01067 Lower Cape Fear Umbrella Bank - Juniper Tract draft
mitigation plan comments
Attachments: Juniper Tract Draft Mit Plan comment memo.pdf; ER-19-2024.pdf
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Hi Christian and Corey,
Please find the attached comments on the draft mitigation plan for Juniper Tract. Let me know if you have any
questions.
Best regards,
Jordan
Jordan Jessop
Wilmington Regulatory Field Office
U.S. Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403
[phone] (direct line)
[e-mail]
1

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
June 8, 2021
CESAW-RG/Jessop
MEMORANDUM FOR RECORD
Action ID: SAW-2019-01067 Lower Cape Fear Umbrella Bank - Juniper Tract
SUBJECT: Juniper Tract Draft Mitigation Plan IRT Comment Memo
NC Division of Water Resources Comments (Erin Davis):
1. Page 10, Section 4.B— Is it possible to narrow down the year of the "recent thinning" activity?
Or at least before X year based on available aerials? Also, can this area please be called out on
the existing conditions figure. (Similar request for "recent clear cut" activity mentioned on page
19 and "recently logged" area mentioned on page 25.)
2. Page 20, Table 1— Please confirm the proposed entrenchment value is accurate.
3. Page 26, Section 6.A.2— Please include the proposed native riparian seed mix. (Similar request
for native wetland seed mix under Section 6.B.3.)
4. Page 27, Section 6.B.1—DWR appreciates that site -specific baseline groundwater data was
collected. Please indicate whether 2019 was a "typical rainfall year".
5. Page 28, Section 6. B.1— Please confirm the "wetland hydrologic criterion" references the
proposed mitigation credit hydroperiod not just the minimal jurisdictional hydroperiod. The
difference between a 5% and 12% hydroperiod goal may lead to different results on the
effective drainage ditch fill depth.
6. Page 29, Section 6.B.2— DWR is concerned with the proposed headwater streams having
watersheds as small as 39 acres being at risk for maintaining flow and bed and bank features
and end up trending more towards a wetland feature.
7. Page 36, Section 7 —
a. Quantitative data should also include surface flow data for headwater valley and single -
thread stream reaches.
b. DWR requests redline as -built drawings identifying any construction deviations from the
approved mitigation plan, including any changes in planted species and quantities.

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8. Page 39 — To be consistent with the 2016 IRTGuidance, DWR recommends a March 1st growing
season start date for the wetland hydrology success criterion. However, we encourage LMG to
collect February groundwater data for potential monitoring report discussion.
9. Page 40 — DWR supports the requested exception to the 2% vegetative monitoring area
requirement based on the site size and uniformity within proposed community types.
10. Page 45, Table 10 — Is fencing proposed for this site? If not, please update with signage damage.
11. Page 57, Section 9.0 — A copy of the draft conservation agreement, preliminary acceptance
letter by the proposed easement holder and proposed endowment/long-term management
costs were not included in the appendices for I RT review. Please confirm these items will be
included in the Final Mitigation Plan. Are any deviations to the 2020 USACE conservation
easement agreement template language anticipated?
12. Figures — Please confirm that the proposed Mitigation Bank Boundary is consistent with the
proposed conservation easement boundary. Any proposed external easement breaks should not
be included within the bank boundary (e.g. utility easements). Please clearly call out any roads
and/or trails that are proposed to remain (or be added) within the conservation easement.
13. Figures 1— 4 — It was initially very confusing having two boundary legend items considering
Juniper Tract is identified in the mitigation plan as the name of the Mitigation Bank.
Additionally, the boundaries appear to overlap except in the northern area. Since the Tax Parcel
Boundary is identified on Figure 4 and it provides better visibility of where the parcel and bank
boundaries overlap, DWR requests that the Tract Boundary be removed from the other figures.
14. Figure 4 & Appendix D aerials —Should the "Site" call out reference the tax parcel or mitigation
bank boundary?
15. Figure 12 — DWR requests two additional wetland restoration wells adjacent to the first order
stream restoration reach.
16. Watershed delineation figure —Apologies if I missed this information, but please make sure to
include a figure showing the watershed areas associated with UT1, UT2 and Hickman Branch
restoration reaches (39 acres, 275 acres, etc.).
17. Appendix E — Please in a location map for the included eight boring logs representative of the
530 acres of wetland credit area. For future reference, DWR has been requesting that the soil
investigation map include all soil check points to capture the full field assessment effort, not just
the subset of representative boring log (and photo) points.
18. Appendix G — DWR requests a summarytable of the well data growing season hydroperiods %.

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19. Sheet 1— The legend includes a proposed ford crossing icon. I didn't see this feature on the plan
view sheets, please confirm whether ford crossings are proposed for this site. If so, please
include a typical detail for this feature.
20. Sheet 2B—The plan view sheets do not include call out locations for thefloodplain interceptor.
DWR is concerned with hardening of the restored stream banks. Please consider alternative
bank stabilization options before placing riprap. Any areas where riprap is installed during
construction should be identified on the as -built drawings.
21. Sheets 9, 11 & 13 — Please confirm whether the requested stream credit extends through the
proposed 50-100' rock channels on UT1, UT2 and Hickman Branch. DWR does not support
issuing stream restoration credit for proposed rock channels.
22. DWR encourages adding more woody material to stream and wetland credit areas as habitat
enhancement features (e.g. woody riffles, tree throws).
U.S. Army Corps ofEngineers Comments (Casey Haywood):
1. Please confirm that you are measuring the headwater valley by the center of the valley, in a
straight line. Credit must be calculated using valley length, not stream centerline measurements.
This could be included in Section C or annotated on Table 11.
2. It would be helpful to add a note in Section C. Bank Credit Determination and Use: that wetland
credit proposed in conjunction with the zero order stream project, was not generated within the
100-ft corridor where the stream is expected to develop. It looks like this area was indicated on
the maps as "zero order stream corridor". This could also be annotated on Table 11.
3. Figure 12: Wetland gauges appear to be in clusters of smalltransects. Please note that wetland
gauges should be an accurate representation of the different soils, topographic variations, and
vegetation communities on the site. Gauges should also be placed at the center and edges of the
wetlands.
4. Figure 13 indicates the zero order stream corridor as 8 acres; however, the other maps indicate
the area as 7.8 acres. Please update
5. Please include more discussion on grading depths in the Proposed Grading section.
6. February 1" is not appropriate for the start of the growing season and should occur no earlier
than March 1st
U.S. Army Corps of Engineers Comments (Jordan Jessop):
1. Regarding the selected pine removal in the southwest wetland area (discussed on page
34 of the draft mitigation plan), will there be any plantings done in these areas?

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2. Are there any concerns about soil constraints (such as compaction, low -quality soil
conditions) in the borrow pit area that will be planted as a basin cypress wetland, which
may impact planting success?
3. The proposed restored riparian wetland area is mapped as Murville, please revise the
proposed hydroperiod performance standard to 16% for this area.

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper Secretary D. Reid Wilson
March 3, 2021
Jordan Jessop
U.S. Army Corps of Engineers
Wilmington Regulatory Field Office
69 Darlington Avenue
Wilmington, NC 28403
[e-mail]
Re: Add Juniper Tract, Lower Cape Fear Umbrella Mitigation Bank, Bolivia, Brunswick County,
ER 19-2024
Dear Mr. Jessop:
Thank you for your email of February 10, 2021, regarding the above -referenced undertaking. We have
reviewed the submittal and offer the following comments.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or [e-mail]. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
Ramona Bartos, Deputy
State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898