20191132 Ver 1_Mitigation Evaluation_20211004

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
October 4, 2021
Regulatory Division
Action ID No. SAW-2019-01296
Re: As-Built/MYO Credit Release associated with the Wildlands Little Tennessee Umbrella
Mitigation Bank — East Buffalo Mitigation Site
Wildlands Engineering, Inc.
Mr. Shawn Wilkerson
swilkerson(at)wildlandsen g. com
Dear Mr. Wilkerson:
This correspondence is in response to your July 26, 2021 request for the As-Built/MYO
credit release for the East Buffalo Mitigation Site, part of the Wildlands Little Tennessee
Umbrella Mitigation Bank. The 259.84-acre site is located within the Little Tennessee River
Basin Hydrologic Unit 06010204, at 1157 East Buffalo Road in Robbinsville, Graham County,
North Carolina. The project was approved to generate 4,432 cold stream mitigation units
(SMU's) through the restoration, enhancement, and preservation of 13,662 linear feet of stream
on East Buffalo Creek and ten unnamed tributaries to East Buffalo Creek. It was also approved
to generate 1.75 wetland mitigation units (WMU's) through the re-establishment, rehabilitation
and enhancement of 2.46 acres of wetland. The purpose of this letter is to confirm the As-
Built/MYO release of credits for this mitigation site.
Pursuant to the Mitigation Banking Instrument (UMBI) entitled, Agreement to Establish
the Wildlands Little Tennessee Umbrella Mitigation Bank, signed November 4, 2020, the site -
specific East Buffalo Final Mitigation Plan dated October 5, 2020 and the December 16, 2020
email with approved plan revisions, fifteen percent (15%) of the sites total restoration and
enhancement credits shall be available for sale immediately upon completion of the required
tasks pursuant to the Mitigation Plan.
By copy of this correspondence, we confirm that you have satisfied the above requirements for
initial release for all parcels within the bank; and 509 SMU's and 0.26 WMU's constituting 15
percent of the mitigation site's total stream restoration and enhancement credits, 3 percent of the
mitigation site's total preservation credits, and 15 percent of mitigation site's total wetland re-

establishment, rehabilitation, and enhancement credits. With this release, 30 percent of the total
stream restoration and enhancement credits (928 SMUs), 30 percent of the total wetland re-
establishment, rehabilitation, and enhancement credits (0.52 WMUs), and 92 percent (1,234.3
SMUs) of the total stream preservation credits will have been released.
During the NCIRT review, comments were made by agency representatives regarding concerns
noted with the As-Built/MYO conditions. These comments are noted below. Please provide a
response and track in future monitoring reports including any actions taken to address them.
Todd Bowers, USEPA
1. Section 1.3 contains much information on the stream
restoration/enhancement/preservation approaches but seems to be missing the
restoration/enhancement/preservation approach for the wetlands. Recommend adding
some more information on the restoration type and approach used for wetlands.
Enhancement and restoration are mentioned without any further details.
2. As far as monitoring reports are concerned, I recommend submitting monitoring reports
well before April 1, even as early as late December. This will allow the IRT the
opportunity to review and provide feedback before any corrective action that may need
to take place can be recommended. Understandably, Wildlands can take certain
corrective actions without IRT approval per the adaptive management plan, however, if
the site needs to undergo substantial replanting, IRT concurrence and/or
recommendations can be obtained well before the end of the dormant season for
planting.
3. Adaptive Management Plan: Recommend conduction supplemental planting no later
than April 1 in any given year as the typical growing season for Graham County starts
around April 2.
4. Vegetation Planting Plan: Excellent information concerning species substitutions,
adjustments, diversity and the percentages for each species. My only recommendation is
to refer to Sheet 2.0 Planting Plan to avoid any confusion with missing percentages. For
example, I added up the live stake percentages in the streambank planting zone and
wondered where/what species the missing 10% was. Sheet 2.0 provided the answer as it
was Elderberry.
Erin Davis, NCDWR
5. Page 13, Section 5.1.2 — What does modified mean? Please explain why and how these
approved design structures were modified.
6. Was soil boring data collected near the installed wetland gauges (as 2016 IRT
Guidance)? Please include this information in the MY1 report.
7. I appreciate the level of detail provided in the redline drawings. Of the species
substitutions requested, DWR only questions the crab apple based on IRT discussions of
other sites in the region. DWR supports the plant list modification as long as WRC
concurs.
Andrea Leslie/Travis Wilson, NCWRC

8. Pleased with many of the substitutions including many additions to diversify the planting
list. Concerned about Eastern Cottonwood which is generally not found in the mountains
of NC (is found in a few places in the French Broad River floodplain).
Steve Kichefski, USACE
9. Do not include Eastern Cottonwood in any future supplemental plantings for this site and
although not required, I recommend removing them as found during project activities
throughout monitoring.
10. Did not see a revised linear footage total for the As -Built compared to the mitigation
plan. Were they different and is Wildlands seeking a different credit amount for the
bank?
Thank you for your time and cooperation. If you have any questions, please contact
Steve Kichefski at [phone] extension 4234.
for
Electronic Copies Furnished:
Erin Davis (NCDWR)
Andrea Leslie (NCWRC)
Travis Wilson (NCWRC)
Byron Hamstead (USFWS)
Todd Bowers (USEPA)
Renee Gledhill -Earley (NCSHPO)
Todd Tugwell (USACE)
Kim Browning (USACE)
Casey Haywood (USACE)
Scott Jones (USACE)
Sincerely,
Scott Jones, Chief
Asheville and Charlotte Regulatory Field Offices

From:
Davis. Erin B
To:
Baker, Caroline D
Subject:
FW: [External] Wildlands Little Tennessee Umbrella Mitigation Bank As-Built/MYO Credit Release for the East
Buffalo Mitigation Site (SAW-2019-01296)
Date:
Wednesday, November 3, 2021 8:49:02 AM
Attachments:
SAW-2019-01296 WildlandsLittleTennesseeUMB-EastBuffalo AsBuiltCreditRelease.ndf
Laserfiche Upload: Email & Attachment
DWR#: 20191132 v.l
Doc Type: Mitigation Evaluation
-----Original Message -----
From: Kichefski, Steven L CIV USARMY CESAW (USA) [mailto:Steven.L.Kichefskikusace.army.mil]
Sent: Monday, October 4, 2021 5:03 PM
To: Jake McLean <[e-mail]>; Andrea Eckardt <[e-mail]>; Shawn
Wilkerson <[e-mail]>
Cc: Davis, Erin B <[e-mail]>; Hamstead, Byron A <[e-mail]>; Bowers, Todd
<[e-mail]>; Leslie, Andrea J <[e-mail]>; Wilson, Travis W.
<[e-mail]>; Tugwell, Todd J CIV USARMY CESAW (US)
<[e-mail]>; Kim Browning <[e-mail]>; Haywood, Casey
M CIV (USA) <[e-mail]>; Jones, M Scott (Scott) CIV USARMY CESAW (USA)
<[e-mail]>
Subject: [External] Wildlands Little Tennessee Umbrella Mitigation Bank As-Built/MYO Credit Release for the East
Buffalo Mitigation Site (SAW-2019-01296)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spam&nc.gov>
Andrea/Jake,
Please find attached the As-Built/MYO Credit Release letter for the Wildlands Little Tennessee Umbrella Mitigation
Bank: East Buffalo Mitigation Site (SAW-2019-01296). As requested, 15% credit is being released for approved
restoration and enhancement activities that satisfy the As-Built/MYO release requirements pursuant to the Mitigation
Banking Instrument (UMBI) entitled, Agreement to Establish the Wildlands Little Tennessee Umbrella Mitigation
Bank, signed November 4, 2020 and the final site -specific mitigation plan dated October 5, 2020 and the December
16, 2020 email with minor plan revisions. In accordance with the plan, 509 cold stream mitigation units and 0.26
wetland mitigation units are now available for the East Buffalo Mitigation Site. Feel free to contact me with any
questions.
This electronic copy is an official Department of the Army Notification.
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
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