HomeMy WebLinkAbout20201095 Ver 1_Initial Evaluation Letter for SAW-2020-01532 SAW-2020-01534_20210430Strickland, Bev
From: Kichefski, Steven L CIV USARMY CESAW (USA) <Steven.L.Kichefski@usace.army.mil>
Sent: Friday, April 30, 2021 5:32 PM
To: Andrea Eckardt; Shawn Wilkerson
Cc: Tugwell, Todd J CIV USARMY CESAW (US); Kim Browning; Haywood, Casey M CIV
(USA); Davis, Erin B; Munzer, Olivia; Wilson, Travis W.; Bowers, Todd; Youngman,
Holland J; Gledhill-earley, Renee; Jones, M Scott (Scott) CIV USARMY CESAW (USA)
Subject: [External] Initial Evaluation Letter for Wildlands Catawba UMB - Double Rock
(SAW-2020-01532) and Firestone (SAW-2020-01534) Mitigation Sites
Attachments: SAW-2020-01532 WildlandsCatawba0l UMB-DoubleRock-
FirestoneMitSites_InitialEvaluation_30Apri12021.pdf
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Good afternoon,
Please find attached the Initial Evaluation Letter for the Wildlands Catawba UMB - Double Rock (SAW-2020-01532) and
Firestone (SAW-2020-01534) Mitigation Sites, including all comments generated during the public notice period and the
minutes from the field IRT visit on September 28, 2020. You may proceed with developing the draft mitigation plan and
feel free to contact me with any questions.
Regards,
Steve Kichefski
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District, Asheville Field Office
151 Patton Avenue, Suite 208
Asheville, NC 28801
(828)-271-7980 Ext. 4234
(828)-933-8032 cell
The Wilmington District is committed to providing the 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://corpsmapu.usace.army.mil/cm apex/f?p=136:4:0 to complete the survey online.
1
April 30, 2021
Regulatory Division
SUBJECT: Initial Evaluation of the proposed Wildlands Catawba Umbrella Mitigation Bank:
Double Rock (SAW-202001532) and Firestone (SAW-2020-01534) Mitigation Sites
Wildlands Engineering, Inc.
Attention: Mr. Shawn Wilkerson
swilkerson@wildlandseng.com
Dear Mr. Wilkerson:
This letter is in regard to your prospectus document dated October 1, 2020, for the proposed
Wildlands Catawba Umbrella Mitigation Bank including the Double Rock and Firestone
Mitigation Sites. The proposal consists of the establishment and operation of a commercial
umbrella mitigation bank in the Upper Catawba Watershed, Hydrologic Unit Code (HUC)
03050101 of the Santee River Basin. The Double Rock Mitigation Site is an 18.4-acre stream
mitigation site located approximately six miles southeast of Taylorsville in Alexander County,
North Carolina (35.8629, -81.0967). The Firestone Mitigation Site is a 15-acre stream mitigation
site located approximately 12 miles northeast of Conover in Catawba County, North Carolina
(35.7637, -81.1661).
The Corps determined the prospectus was complete and issued a public notice (P/N # SAW-
2020-01532) on November 2, 2020. The purpose of this notice was to solicit the views of
interested State and Federal agencies and other parties either interested in or affected by the
proposed work. Attached are the comments received in response to the public notice from the
Cherokee Nation and the NC State Historic Preservation Office (SHPO).
The Corps has considered the information provided in the prospectus document, comments
received in response to the public notice and information that was discussed during on-site
reviews conducted on September 28, 2020. The meeting minutes from the field review and
follow-up IRT comments are attached We have determined that the proposed umbrella
mitigation bank appears to have the potential to restore, enhance and preserve aquatic resources
within the Upper Catawba Watershed, HUC 03050101 of the Santee River Basin. Therefore, the
bank sponsor may proceed with preparation of a draft Umbrella Mitigation Banking Instrument
(UMBI).
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
Please address all comments included in the attached memo with your draft UMBI submittal. If
you have questions concerning the path forward for the proposed mitigation banlc, please do not
hesitate to contact me at 828-271-7980 x4234.
Digital Copies Furnished:
Todd Tugwell, USACE
Casey Haywood, USA CE
Kim Browning, USACE
Erin Davis, NCDWR
Olivia Munzer, NCWRC
Travis Wilson, NCWRC
Todd Bowers, USEPA
Holland Youngman, USFWS
Renee Gledhill-Early, NCSHPO
Scott Jones, USACE
Sincerely,
6\-t,~t:
Steve Kichefski
Regulatory Project Manager
CESAW-RG/Kichefski April 30, 2021
MEMORANDUM FOR RECORD
SUBJECT: Proposed Wildlands Catawba Umbrella Mitigation Bank- Double Rock Mitigation
Site (SAW-2020-01532) and Firestone Site (SAW-2020-01534) Comments Received in
Response to the Public Notice and during the September 28, 2020 site visit reflected in the
meeting minutes provided via email on October 1, 2020.
Project Name: Wildlands Catawba Umbrella Mitigation Bank- Double Rock (SAW-202001532)
and Firestone (SAW-2020-01534) Mitigation Sites, Alexander and Catawba Counties, NC
Elizabeth Toombs, Cherokee Nation, November 30, 2020:
SEE ATTACHED COMMENTS
Renee Gledhill-Earley, NCSHPO, March 25, 2021:
SEE ATTACHED COMMENTS
Olivia Munzer, NCWRC:
SEE ATTACHED MEETING MINUTES AND FOLLOW-UP EMAIL COMMENT
Erin Davis, NCDWR:
SEE ATTACHED MEETING MINUTES
Steve Kichefski & Todd Tugwell, USACE, April 29, 2021
SEE ATTACHED MEETING MINUTES AND COMMENTS BELOW
1. All final credit ratios will be determined at the draft plan stage when a more
comprehensive proposal of all project details is available.
2. In the Prospectus, the service area for the Firestone Mitigation Site is proposed as both
the Catawba 01 and the Catawba 03 based on its location within the Catawba 03 extended
service area. Final agreement of appropriate service area will be determined by the IRT
during the draft plan review considering the current service areas established within
current District Guidance.
3. Efforts to maximize the buffer width between the restored channel of Firestone Tributary
and the existing sewer line should be utilized.
4. In the field a small portion of higher quality buffer was identified along Elk Shoals Reach
1, mainly the downstream right bank within the area of more stable stream channel. Field
discussions included trying to preserve those areas if possible while utilizing the blended
E1 approach.
Steve Kichefski
Regulatory Project Manager
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
November 30, 2020
Steve Kichefski
United States Army Corps of Engineers
151 Patton Avenue, Room 208
Asheville, NC 28801
Re: SAW-2020-01532, Wildlands Catawba Umbrella Mitigation Bank
Mr. Steve Kichefski:
The Cherokee Nation (Nation) is in receipt of your correspondence about SAW-2020-01532, and
appreciates the opportunity to provide comment upon this project. Please allow this letter to serve
as the Nation’s interest in acting as a consulting party to this proposed project.
The Nation maintains databases and records of cultural, historic, and pre-historic resources in this
area. Our Historic Preservation Office reviewed this project, cross referenced the project’s legal
description against our information, and found no instances where this project intersects or adjoins
such resources. Thus, the Nation does not foresee this project imparting impacts to Cherokee
cultural resources at this time.
However, the Nation requests that the United States Army Corps of Engineers (USACE) halt all
project activities immediately and re-contact our Offices for further consultation if items of cultural
significance are discovered during the course of this project.
Additionally, the Nation requests that USACE conduct appropriate inquiries with other pertinent
Tribal and Historic Preservation Offices regarding historic and prehistoric resources not included
in the Nation’s databases or records.
If you require additional information or have any questions, please contact me at your convenience.
Thank you for your time and attention to this matter.
Wado,
Elizabeth Toombs, Tribal Historic Preservation Officer
Cherokee Nation Tribal Historic Preservation Office
elizabeth-toombs@cherokee.org
918.453.5389
North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper Secretary D. Reid Wilson
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: (919) 814-6570/814-6898
March 25, 2021
Steve Kichefski Steven.L.Kichefski@usace.army.mil
U.S. Army Corps of Engineers
Wilmington District - Asheville Regulatory Field Office
151 Patton Avenue, Suite 208
Asheville, NC 28801
Re: Double Rock mitigation site, 35.8629, -81.0967, & Firestone mitigation site, 35.7637,
dddddd-81.1661 Alexander County, ER 21-0644
Dear Mr. Kichefski:
Thank you for your email of March 4, 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 environmental.review@ncdcr.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
Ramona Bartos, Deputy
State Historic Preservation Officer
MEETING MINUTES
Meeting:
Prospectus Field Review with IRT
Catawba Umbrella Mitigation Bank
Wildlands Project No. W45024
Date: September 28, 2020, 11 am
Location: Double Rock Mitigation Site – Stikeleather Road, Hiddenite, NC
Firestone Mitigation Site – Riverbend Road, Clines, NC
Attendees
Shawn Wilkerson, Wildlands Engineering Principal
Andrea Eckardt, Wildlands Engineering Project Manager
Christine Blackwelder, Wildlands Engineering Designer (Double Rock)
Eric Neuhaus, Wildlands Engineering Designer (Firestone)
Todd Tugwell, US Army Corps of Engineers
Steve Kichefski, US Army Corps of Engineers
Olivia Munzer, NC Wildlife Resource Commission
Materials
Wildlands Engineering Catawba Umbrella Mitigation Bank Draft Prospectus dated September 1,
2020
Minutes
The group met at the Double Rock Mitigation Site at 11 am. Christine provided an overview of the site
at the cars. From there, the group walked the site in the following order: Randall Tributary, Elk Shoals
Reach 2, Elk Shoals Reach 1, Stikeleather Tributary to Matheson confluence, Matheson Tributary,
Matheson Tributary A, Matheson Tributary B, and Stikeleather from the Matheson confluence to the Elk
Shoals confluence.
The Double Rock portion of the site visit concluded at 1:30 pm.
The group then traveled to the Firestone Mitigation Site. Eric provided an overview of the site and the
group entered the site along UT1, walked downstream along Firestone Tributary crossed and continued
up UT3, walked back upstream Firestone Creek, and finished by walking up UT2.
At the end of the meeting, the group discussed whether the prospectus can be put out on public notice
as previously submitted or if a revision is needed. A decision was made for Wildlands to revise the
Prospectus to include the additional information the IRT needs to support Enhancement 1 crediting and
to accurately reflect design decisions made during the walk.
Double Rock Mitigation Site
a) Randall Tributary
This stream is incised and eroded and flows through an active cattle pasture. Wildlands secured a
temporary construction access agreement to begin the project at the bedrock knickpoint on the
upstream landowner’s property, allowing for a priority 1 restoration.
The group agreed restoration at 1:1 ratio is appropriate for Randall Tributary.
The BMP proposed in the left floodplain will eliminated, as the group felt it may not be
necessary given the gentle terrain and small drainage area. The group agreed the BMP
proposed in the right floodplain is warranted.
Todd and Steve pulled soil cores near the proposed right floodplain BMP and noted bright soils
with no wetland potential.
Todd asked Wildlands if the Randall stream crossing could be moved to the upstream property
boundary. Wildlands will review this.
b) Elk Shoals Reach 1
This stream has areas of incision, erosion, and tortuous meanders, but also has areas of well‐formed
bankfull benches, stable stream banks, and bedform diversity. Invasive Chinese privet is dense along
this entire reach and will require mechanical removal, which will destabilize much of the reach.
The group agreed that enhancement 1 represents the blended approach that will be necessary
to achieve uplift on this stream while preserving what is functioning. However; the IRT felt,
since the level of work will change across the reach with some areas of full restoration, some
areas of benching and structures, and some with minor bank repair, that they currently do not
have enough data to approve a credit ratio.
Wildlands will revise the Prospectus to break down the level of work throughout the reach into
zones so the IRT may gain a level of comfort with the proposed ratio. This will help the IRT
evaluate the true level of effort across the stream reach.
c) Elk Shoals Reach 2
This stream is incised and eroded and flows through active cattle pasture. A short portion of the
downstream end of this stream is fenced from cattle.
The group agreed restoration at 1:1 ratio is appropriate for Elk Shoals Reach 2, and that
restoration will extend to the confluence with Stikeleather.
The well house near the stream will remain within an internal easement break; this is the well
for the landowner’s house.
Black walnuts line the left bank of this reach, and Olivia and Steve noted IRT concerns over the
allelopathic properties of the plant. Todd noted that these trees are likely near the end of their
lifespan and Shawn noted that, due to the location of these trees along the existing top of bank
and within the active channel, they will likely be impacted by construction anyway. Olivia noted
she would prefer to save a grove or group as opposed to single trees. Wildlands will survey
black walnuts trees with a minimum diameter of 12” as part of the existing conditions survey.
Steve and Olivia discussed the importance of tuning the planting plans to the local communities.
Steve noted that more species with lower percentages may be a way to increase diversity, and
that he would like to see more understory and shrub species proposed. Both noted the
importance of communication during planting when substitutions must occur and making sure
these are documented on the as‐built plans. Shawn discussed some of the challenges with
planting from inefficiencies with holding plants at nurseries to planting contractors making last
minute substitutions. Christine noted that Wildlands’ internal land stewardship team is now
actively researching plant communities for new planting plans and working with our planting
contractors more to try to get ahead of these issues.
d) Stikeleather Tributary
Like Elk Shoals Reach 1, Stikeleather Tributary has areas of incision and erosion, but also has areas with
moderate bedform, bank stability, and bankfull benches. The riparian area is not as dominated with
invasive species streamside as Elk Shoals Reach 1, and Olivia noted the terrestrial community on the
right bank is desirable and should be preserved. Christine noted that the old Stikeleather Road
alignment paralleled the right bank of Stikeleather and the vegetative community in that area is less
desirable.
Based on WRC and USACE’s recommendations, Wildlands will seek to preserve as much of the
right bank vegetation as possible, concentrating benching and enhancement 1 activities on the
left bank.
Steve asked if Stikeleather would be raised with priority 1 restoration in areas. Christine
responded that it may be a possibility in areas that require full restoration, but further existing
conditions assessment and preliminary design is necessary.
As with Elk Shoals Reach 1, the IRT did not feel they have enough information to approve credit
ratios for the enhancement 1 approach at this time, so Wildlands will revise the Prospectus to
break down the level of work throughout the reach into zones.
e) Matheson Tributary, Matheson Tributary A, and Matheson Tributary B
Matheson Tributary, Matheson Tributary A, and Matheson Tributary B are proposed for preservation
with the construction of a BMP at the top of Matheson Tributary A to address the unstable headcut.
The IRT felt that the streams on this portion of the project do not reflect the true intent of
preservation due to an early successional and thus lower quality riparian buffer. The IRT asked
when the buffer was last logged and a field review of aerials placed logging over 10 years ago.
At a 10:1 ratio, these streams will generate approximately 107 credits, which is 2.5% of the
overall proposed credit for the site.
The IRT stated they will think more on this section of the project as they need to consider this in
the context of other projects in similar situations.
Shawn reiterated Wildlands’ desire to capture and protect headwaters whenever possible, and
that a lower credit ratio may potentially impact the financial viability of including these streams
in the project.
Firestone Mitigation Site
a) UT2
UT2 was identified in the field as being incised with areas of active erosion and headcutting. The stream
has numerous locations where tires have been dumped in the stream. Wildlands noted that UT1 will be
restored using a priority 1.5 restoration approach and will be credited at a 1:1 credit ratio. The stream
bed will be raised from existing, but not all the way up to the relic floodplain. A floodplain will be
excavated along the stream based on the new bed elevation to provide adequate floodplain connection.
Wildlands noted that they would stop the conservation easement short of crossing 5 shown in
Figure 9b of the prospectus to eliminate the crossing as part of the project and reduce the
overall number of crossings.
Olivia/Steve asked about the potential wetland/seep area along the right bank near the
upstream extents of UT2. Wildlands noted that this area will be included within the
conservation easement. No credit is being requested for this area.
b) UT3
UT3 is incised and historically straightened for approximately the last 300 linear feet as it enters the
floodplain of Firestone Tributary. Upstream of this area, the stream goes through a series of headcuts
and is in moderate condition before another section of active incision and erosion related to a perched
culvert along the reach. Moving upstream, the reach becomes less incised with some floodplain
benching starting to form but is still generally impacted by adjacent agriculture.
UT3 was proposed with an enhancement I approach at a 1.5:1 credit ratio within the draft
prospectus. Steve and Todd requested Wildlands break the reach into alternating approaches of
Enhancement II and Restoration within the final prospectus to clarify crediting, approach, and
future monitoring protocol.
Steve asked about the agricultural area in the far‐right floodplain of UT3 and if there was
potential to expand the buffer along this area. There was concern based on aerial imagery
within the mapping provided in the prospectus that this area was heavily impacted by
agricultural activity and could be a potential sediment source and risk for the project. Based on
field observations during the meeting, it did not appear that area was a risk for the project.
c) Firestone Tributary
Firestone Tributary was observed in the field as being severely incised and historically straightened, with
multiple areas of actively eroding channel banks and mass wasting. Firestone Tributary is proposed for
priority 1 stream restoration at a 1:1 credit ratio.
Wildlands noted that, given the depth of the existing channel, the upstream section of Firestone
Tributary between River Bend Road and the UT1 confluence will likely be a transition zone to
raise the channel to the relic floodplain and will need to be restored using a priority 2 approach.
The section of Firestone Tributary within the overhead utility easement will be restored but for
no credit as part of the project.
Firestone Tributary will be realigned to the left of the existing channel to provide distance
between the exiting sewer line and the stream channel.
The downstream portion of Firestone Tributary will be transitioned with priority 2 restoration
approach and will be tied to a seam of existing bedrock downstream.
d) UT1
UT1 was observed in the field as being severely incised with some moderate bedform. Like UT2, UT1 will
be restored using a priority 1.5 restoration approach and will be credited at a 1:1 credit ratio. The
stream bed will be raised from existing, but not all the way up to the relic floodplain. A floodplain will be
excavated along the stream based on the new bed elevation to provide adequate floodplain connection.
Steve and Todd asked about the overall earthwork at the site and noted that fill material would
be needed given the size and depth of the existing stream channels. Wildlands noted that the
floodplain excavation along UT1 and UT2, as well as the priority 2 transition zones will be used
to generate earth to fill the old channels. After initial design, if fill material is still needed,
Wildlands will discuss potential alternatives with property owners to generate fill such as
excavating and reshaping a hill slope on site
The upstream extent of UT1 is overrun with invasive bamboo. It was difficult to tell in the field
how much of the bamboo was within the proposed project and how much was upstream off the
project property. Todd noted that if the bamboo continues off property upstream, the IRT
would prefer Wildlands obtain permission from the upstream property owner to
remove/excavate the bamboo to the greatest extent possible to prevent maintenance issues on
the project in the future.
Action Items Based on the Prospectus Site Walk
Wildlands will revise Figure 9A, Figure 9B, and Table 4 based on discussions regarding approach,
crediting, and logistics along the following reaches at the sites:
o Double Rock:
Stikeleather
Elk Shoals Reach 1
o Firestone
UT3
UT1 (Remove Crossing #5)
Wildlands will provide a list of adjacent property owners for both sites along with the Final
Prospectus to be posted to Public Notice.
From:Munzer, Olivia
To:Andrea Eckardt; Kichefski, Steven L CIV USARMY CESAW (USA)
Cc:Tugwell, Todd J CIV USARMY CESAW (USA); Davis, Erin B; Browning, Kimberly D CIV USARMY CESAW (USA)
Subject:[Non-DoD Source] RE: [External] Wildlands Catawba 01 Umbrella Mitigation Bank - Final Prospectus Submittal -
Double Rock and Firestone Mitigation Sites
Date:Monday, October 19, 2020 3:15:09 PM
Good afternoon,
My apologies that I now just reviewed the notes. I don’t remember exactly what I said about the
black walnuts, but I would prefer not having large stands of walnut. We definitely do not want them
on the plant list. I believe I had mentioned that it is always hard for me to justify removing mature,
healthy trees, especially if they provide good stream shading. However, their toxicity will prevent
from many plants from growing around them so we like to avoid or minimize them at a site.
In general, I suggest removing any large stands of walnut and unhealthy individuals. If there is one or
two that are mature, healthy, and provide good shading, then I think it is ok to keep it. The link
below has a list of species that are tolerant to walnut toxicity, including boxelder, persimmon,
pawpaw, and others.
Blockedhttps://www.mortonarb.org/trees-plants/tree-and-plant-advice/horticulture-care/plants-
tolerant-black-walnut-toxicity
My apologies for any confusion. Feel free to contact me if you want clarification.
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
NC Wildlife Resources Commission
From: Andrea Eckardt <aeckardt@wildlandseng.com>
Sent: Thursday, October 1, 2020 9:01 AM
To: Steve Kichefski <Steven.l.kichefski@usace.army.mil>
Cc: Tugwell, Todd J CIV USARMY CESAW (US) <Todd.J.Tugwell@usace.army.mil>; Davis, Erin B
<erin.davis@ncdenr.gov>; Munzer, Olivia <olivia.munzer@ncwildlife.org>; Kim Browning
<Kimberly.D.Browning@usace.army.mil>
Subject: [External] Wildlands Catawba 01 Umbrella Mitigation Bank - Final Prospectus Submittal -
Double Rock and Firestone Mitigation Sites
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov
Steve
Attached is a copy of the final Prospectus for the Wildlands Catawba 01 Umbrella Mitigation Bank.
I have also attached minutes from the 9/28/2020 IRT site visit and the addresses for the adjacent
property owners.
Please let me know if you need anything else for the public notice or have any additional information
you’d like added to the minutes.
Andrea
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Andrea S. Eckardt| Ecological Assessment Team Leader
O: 704.332.7754 x101 M: 704.560.2997
Wildlands Engineering, Inc.
1430 S. Mint St, Suite 104
Charlotte, NC 28203
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.