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HomeMy WebLinkAbout20171041 Ver 1_Mitigation Information_20211012fires October 5, 2021 Paul Wiesner NC DEQ Division of Mitigation Services 5 Ravenscroft Drive, Suite 102 Asheville, NC 28801 360o Glenwood Avenue, Suite ioo Raleigh, NC 27612 Corporate Headquarters 6575 W Loop S #300 Bellaire, TX 77401 Main: 713.520.5400 RE: Little Sebastian Mitigation Site: Mitigation Plan Addendum and Baseline Report and As -Built Drawings (NCDMS Project ID #100027) Listed below are comments provided by IRT on October 4, 2021 regarding the Little Sebastian Mitigation Site: Mitigation Plan Addendum and Baseline Report and As -Built Drawings and RES' responses. USACE Addendum Comments, Kim Browning: 1. Were stream and wetland impacts evaluated with the addition of reach JN-7, and were they accounted for in the 404/401 permit? This reach was not included in the PCN or 404/401 permit. 2. Is JN-7 perennial or intermittent? If flow is a concern, the IRT may request a flow gauge be installed. Based on drainage area (30 acres), RES believes this reach is intermittent. However, it was not included in the JD. RES will install a flow gauge on it. 3. What was the condition of JN-7 prior to construction, and was the design incorporated into the final design? Were there stability issues with the channel? The condition of JN-7 prior to construction was a ditch -like channel connecting the pond outlet to JN-3. This channel was about 75-feet long, incised, and a straight line from the pond outlet to JN-3. A design was incorporated into the final design, after Final Mitigation Plan submittal, to create a 150-foot stable channel from the pond outlet to the newly constructed JN3-B. 4. If JN-7 serves as an outlet for the adjacent pond, are there any concerns with stability or sediment loads if the spillway fails or the dam breaches? RES does not anticipate a dam failure considering the small drainage acre of the pond. However, if it were to fail, there would likely be minor impacts, but the system should be able to handle the relatively minor influx of sediment. res.us DWR MY-0 Comments, Erin Davis: 1. DWR appreciate DMS' request for crossing photos in future reports. Those photos would've been helpful for this review. Crossing photos will be included in future reports. 2. DWR is ok with the plant species substitutes. We were glad to see the reduction in percent green ash planted. 3. Please confirm that all areas were planted, including any supplemental/understory planting, as proposed in the approved mitigation plan. Confirmed. 4. DWR is ok with the extra stage recorder not being installed on BS1-C. However, when we recently visited the downstream Gideon Site we observed the presence of drift lines mid -slope up the bank but not on the floodplain. Therefore, in lieu of the stage recorder being installed along MC1-C as specified in the approved mitigation plan, DWR requests photo documentation of evidence of overbank events be provided for this reach. RES will provide photo documentation of overbank events on MC1-C. USACE MY-0 Comments, Casey Haywood: 1. Concur with DWR's comments. It was noted that two veg plots were moved (both on JN2); however, a random plot was also added. Mitigation Project Name DMS ID River Basin Cataloging Unit County Little Sebastian Site 100027 Yadkin 03040101 Surry USACE Action ID DWR Permit Date Project Instituted Date Prepared Stream/Wet. Service Area Signature of Official Approving Credit Release 2017-01507 2017-1041 5/25/2017 10/11/2021 Yadkin 03040101 1 - For NCDMS, no credits are released during the first milestone (Site Establishment). 2 - For NCDMS projects, the initial credit release milestone occurs when the as -built report (baseline monitoring report) has been approved by the NCIRT and posted to the NCDMS Portal, provided the following criteria are met: 1) Approval of Final Mitigation Plan; 2) Recordation of the preservation mechanism, as well as a title opinion acceptable to the USACE covering the property; 3) Completion of all physical and biological improvements to the mitigation site pursuant to the mitigation plan; 4) Receipt of necessary DA permit authorization or written DA approval for projects where DA permit issuance is not required. 3 - A 10% reserve of credits is to be held back until the bankful event performance standard has been met. Credit Release Milestone Cool Stream Credits Project Credits Scheduled Releases % Estimated Scheduled Release # Proposed Released # Not Approved #Releases Approved Credits Anticipated Release Year Approved Release Date 1 - Site Establishment N/A NA N/A N/A N/A N/A N/A 2 - Year 0 / As -Built 30.00% 1,366.290 1,366.290 0.000 1,366.290 2021 10/11/2021 3 - Year 1 Monitoring 10.00% 455.430 2022 4 - Year 2 Monitoring 10.00% 455.430 2023 5 - Year 3 Monitoring 10.00% 455.430 2024 6 - Year 4 Monitoring 5.00% 227.715 2025 7 - Year 5 Monitoring 10.00% 455.430 2026 8 - Year 6 Monitoring 5.00% 227.715 2027 9 - Year 7 Monitoring 10.00% 455.430 2028 Stream Bankfull Standard 10.00% 455.430 2025 Totals 1,366.290 Total Gross Credits 4,554.300 Total Unrealized Credits to Date 0.000 Total Released Credits to Date 1,366.290 Total Percentage Released 30.00% Remaining Unreleased Credits 3,188.010 Notes Contingencies (if any) Project Quantities Mitigation Type Restoration Type Physical Quantity Cool Stream Restoration 2,721.000 Cool Stream Enhancement I 597.000 Page 1 of 2 Little Sebastian Yadkin 03040101 Mitigation Project Name DMS ID River Basin Cataloging Unit County Little Sebastian Site 100027 Yadkin 03040101 Surry USACE Action ID DWR Permit Date Project Instituted Date Prepared Stream/Wet. Service Area Cool Stream Enhancement II 4,332.000 Cool Stream Preservation 418.000 2017-01507 2017-1041 5/25/2017 10/11/2021 Yadkin 03040101 Debits Cool Stream Restoration Credits Cool Stream Restoration Equivalent Credits Beginning Balance (mitigation credits) 4,512.500 41.800 Released Credits 1,353.750 12.540 Unrealized Credits 0.000 0.000 Converted Credits 0.000 0.000 Owning Program Req. Id TIP # Project Name USACE Permit # DWR Permit # DCM Permit # Remaining Balance (Released credits) 1,353.750 12.540 Remaining Balance (Unreleased credits) 3,158.750 29.260 Total Remaining Balance (Released and Unreleased credits) 4,512.500 41.800 Little Sebastian Page 2 of 2 Yadkin 03040101 From: Kim Browning To: Wiesner, Paul Cc: Tuawell, Todd J CIV USARMY CESAW (US); Haywood. Casey M CIV (USA); Davis, Erin B; Wilson, Travis W.; Leslie, Andrea J; Bowers, Todd; Ryan Medric; Bradley Breslow; Daniel Ramsav Subject: As -Built & Mitigation Plan Addendum Review/ NCDMS Little Sebastian Mitigation Site/ SAW-2017-01507/ Surry County Date: Wednesday, October 6, 2021 3:23:09 PM Attachments: Little Sebastian 100027 Response To IRT Comments 10-5-2021.pdf NWP27 Little Sebastian SAW-2017-01507 Surry Co.pdf JN-7,JPG Good afternoon Paul, Thank you for sending the response to IRT comments for the proposed NCDMS Little Sebastian Addendum on October 5, 2021 (attached). Per Section 332.8(o)(9) of the 2008 Mitigation Rule, this review followed the streamlined review process. The IRT raised several concerns during this review; outlined below. Based on these concerns, the Corps' decision is to disapprove this addendum for the addition of reach JN-7 which proposed an upward adjustment of the project's stream assets (+19.660 Cool SMUs) for 37 linear feet of restoration. The Corps approves the initial 30% credit release of the approved mitigation plan project credits (4,554.300 cool SMUs), which totals 1,366.290 SMUs. Please send me the credit ledger that reflects this amount. Additionally, please address the IRT concerns below. 1. Reach JN-7 was included on the PJD completed by William Elliott on May 22, 2018, as UN-7,-80.855351 36.394343, 55 LF." It appears that the JN-7 that was included on the PJD was on the Gideon Mitigation Bank easement, which caused confusion with two reaches having the same name. It appears that the restored reach JN-7 that exits the pond and ties in with JN-3B on the Little Sebastian easement was not evaluated during the JD visit, nor was it evaluated during the IRT site visit. For future jurisdictional determination submittals, please keep each project separate and use a consistent naming convention for each reach/wetland. 2. Design plans submitted with the PCN as well as all special, general and regional conditions must be strictly adhered to in order for the attached NWP-27 verification letter/authorization to remain valid. Table 1 of the NWP-27 lists all authorized discharge of fill material into waters of the U.S., and the impacts associated with the restoration of reach JN-7 were not accounted for with this authorization. Since RES states that this reach is intermittent, impacts to this reach will need to be accounted for. Please re -submit the 404 permit application to include any stream and wetland impacts that were associated with the restoration of JN-7 so the Corps can re -authorize the NWP-27 and verify these additional impacts under an After -The -Fact permit verification. (Reach photo attached.) If RES feels that JN-7 was not jurisdictional, there will still be impacts to account for with the tie-in with JN-313.. The IRT would not support issuing stream credit on a non jurisdictional reach. 3. Large-scale deviations, including adding a restoration reach, from the approved final mitigation plan and design should be proposed to the IRT PRIOR to conducting the work. The IRT did not have the opportunity to evaluate this reach to determine the appropriate mitigation approach or potential functional uplift, and therefore do not think it is appropriate to allow stream credit; however, we would like you to monitor flow and stability of the reach during monitoring since work was completed on it, and if other reaches on the approved project are not meeting success standards towards the end of monitoring, the IRT may consider allowing these credits to be potential back-up credits (assuming reach JN-7 is successfully meeting performance standards). 4. DWR may require additional 401 permits for any additional impacts. Please contact Erin Davis to confirm. Moving forward, please contact the IRT prior to completing any major deviations from the approved mitigation plan or design. Feel free to reach out with any questions. Respectfully, Kim Kim Browning Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers -----Original Message ----- From: Wiesner, Paul <paul.wiesner@ncdenr.gov> Sent: Tuesday, October 05, 2021 1:38 PM To: Browning, Kimberly D CIV USARMY CESAW (USA) <Kimberly.D.Browning@usace.anmy.mil> Cc: Tugwell, Todd J CIV USARMY CESAW (USA) <Todd.J.Tugwell@usace.army.mil>; Haywood, Casey M CIV (USA) <Casey.M.Haywood@usace.army.mil>; Davis, Erin B <erin.davis@ncdenr.gov>; Wilson, Travis W. <travis.wilson@ncwildlife.org>; Leslie, Andrea J <andrea.leslie@ncwildlife.org>; Bowers, Todd <bowers.todd@epa.gov>; Ryan Medric <rinedric@res.us>; Bradley Breslow <bbreslow@res.us>; Daniel Ramsay <dramsay@res.us> Subject: [Non-DoD Source] RE: [External] Additional Information Request for Mitigation Plan Addendum/ NCDMS Little Sebastian Mitigation Site/ SAW-2017-01507/ Surry County Good afternoon Kim, RES's responses to the IRT questions and comments from yesterday (10-4-2021) are attached for your review. Please let us know if you have any additional questions, comments or concerns. Thanks Paul Wiesner Western Regional Supervisor North Carolina Department of Environmental Quality Division of Mitigation Services 828-273-1673 Mobile paul.wiesner@ncdenr.gov <mailto:paul.wiesner cnre ncdenr.gov> Western DMS Field Office 5 Ravenscroft Drive Suite 102 Asheville, N.C. 28801 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Browning, Kimberly D CIV USARMY CESAW (USA) <Kimberly.D.Browning@usace.army.mil> Sent: Monday, October 4, 2021 3:59 PM To: Wiesner, Paul <paul.wiesner@ncdenr.gov> Cc: Tugwell, Todd J CIV USARMY CESAW (US)<Todd.J.Tugwell@usace.army.mil>; Haywood, Casey M CIV (USA) <Casey.M.Haywood@usace.army.mil>; Davis, Erin B <erin.davis@ncdenr.gov>; Wilson, Travis W. <travis.wilson@ncwildlife.org>; Leslie, Andrea J <andrea.leslie@ncwildlife.org>; Bowers, Todd <bowers.todd@epa.gov>; Ryan Medric <rinedric@res.us>; Bradley Breslow <bbreslow@res.us>; Daniel Ramsay <dramsay@res.us> Subject: [External] Additional Information Request for Mitigation Plan Addendum/ NCDMS Little Sebastian Mitigation Site/ SAW-2017-01507/ Surry County 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 e,nc.gov> Hi Paul, The review period for the NCDMS Little Sebastian Mitigation Site Addendum and As -Built ended September 25, 2021. The addendum requested an upward adjustment of the project's stream assets (+19.660 Cool SMUs) for 37 linear feet of restoration on JN-7. I would like to request additional information prior to approving the addendum. The IRT has concerns regarding the addition of reach JN-7 since it was not discussed or evaluated during the August 2017 IRT site visit, and a modification request was not submitted prior to construction. The PJD completed by William Elliot on May 22, 2018 does identify reach JN-7; however, this reach is listed on the Gideon Mitigation Bank Site on the last page of the PJD (attached). Additionally, the PJD does not specify whether this reach is perennial or intermittent. The DWQ Stream Identification Forms do not contain any information on this reach either. It's difficult to assess functional uplift, and whether restoration was appropriate, without baseline information. USACE Addendum Comments, Kim Browning: 1. Were stream and wetland impacts evaluated with the addition of reach JN-7, and were they accounted for in the 404/401 permit? 2. Is JN-7 perennial or intermittent? If flow is a concern, the IRT may request a flow gauge be installed. 3. What was the condition of JN-7 prior to construction, and was the design incorporated into the final design? Were there stability issues with the channel? 4. If JN-7 serves as an outlet for the adjacent pond, are there any concerns with stability or sediment loads if the spillway fails or the dam breaches? Please provide any additional information that may be helpful for this review. Moving forward, please notify the IRT if reaches that have not been evaluated are proposed to be added. DWR MY-0 Comments, Erin Davis: 1. DWR appreciate DMS' request for crossing photos in future reports. Those photos would've been helpful for this review. 2. DWR is ok with the plant species substitutes. We were glad to see the reduction in percent green ash planted. 3. Please confirm that all areas were planted, including any supplemental/understory planting, as proposed in the approved mitigation plan. 4. DWR is ok with the extra stage recorder not being installed on BSI-C. However, when we recently visited the downstream Gideon Site we observed the presence of drift lines mid -slope up the bank but not on the floodplain. Therefore, in lieu of the stage recorder being installed along MCI-C as specified in the approved mitigation plan, DWR requests photo documentation of evidence of overbank events be provided for this reach. USACE MY-0 Comments, Casey Haywood: Concur with DWR's comments. It was noted that two veg plots were moved (both on JN2); however, a random plot was also added. Please reach out with any questions. Regards, Kim Kim Browning Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers U.S. ARMY CORPS OF ENGINEERS WILMINGTON DISTRICT Action ID: SAW-2017-01507 County: Surry U.S.G.S. Quad: NC -Bottom GENERAL PERMIT (REGIONAL AND NATIONWIDE) VERIFICATION Permittee:NC Division of Mitigation Services Attn: Mr. Tim Baumgartner Address: 217 West Jones Street, Suite 3000A Raleigh, North Carolina 27603 Telephone:919-707-8319 Size (acres) 25.91 acres Nearest Waterway Mill Creek USGS HUC 03040101 Permittee:RES Attn: Bradley Breslow Address: 3600 Glenwood Ave -Ste 100 Raleigh, NC 27612 Telephone:919-209-1062 Nearest Town Dodson River Basin Upper Yadkin Latitude: 36.39654°N Longitude:-80.8584°W Location description: The NCDMS Little Sebastian Mitigation Site is located on Ed Nixon Road, near Thurmond, in Surry County, North Carolina. This protect is adjacent to the Gideon Mitigation Site (SAW-2017-01462). PIN: 495600199069, 495600282159, 495600581103. Description of projects area and activity: The co -applicants, NCDMS and Resource Environmental Solutions, LLC., have requested a Department of the Army permit authorization to discharge dredged and/or fill material into waters of the United States associated with the NCDMS Little Sebastian Mitigation Site. Implementation of the proposed restoration and enhancement activities will result in the discharge of fill material into 0.61 acres of wetlands, and 3,042 linear feet of stream channel associated with mechanized land clearing, excavation, placement of fill material, and stream relocation activities for the mitigation site. Compensatory mitigation is NOT required in conjunction with the aforementioned activities. Refer to the enclosed Table 1 for a detailed summary of impacts. Applicable Law: ®Section 404 (Clean Water Act, 33 USC 1344) ❑ Section 10 (Rivers and Harbors Act, 33 USC 403) Authorization: Regional General Permit Number and/or Nationwide Permit Number: NWP 27 — Aquatic Habitat Restoration, Enhancement, and Establishment Activities SEE ATTACHED RGP or NWP GENERAL, REGIONAL AND SPECIAL CONDITIONS Your work is authorized by the above referenced permit provided it is accomplished in strict accordance with the attached conditions and your submitted application and attached information dated March 3, 2020. Any violation of the attached conditions or deviation from your submitted plans may subject the permittee to a stop work order, a restoration order, a Class I administrative penalty, and/or appropriate legal action. This verification will remain valid until the expiration date identified below unless the nationwide and/or regional general permit authorization is modified, suspended or revoked. If, prior to the expiration date identified below, the nationwide and/or regional general permit authorization is reissued and/or modified, this verification will remain valid until the expiration date identified below, provided it complies with all requirements of the modified nationwide permit. If the nationwide and/or regional general permit authorization expires or is suspended, revoked, or is modified, such that the activity would no longer comply with the terms and conditions of the nationwide permit, activities which have commenced (i.e., are under construction) or are under contract to commence in reliance upon the nationwide and/or SAW-2017-01507 regional general permit, will remain authorized provided the activity is completed within twelve months of the date of the nationwide and/or regional general permit's expiration, modification or revocation, unless discretionary authority has been exercised on a case -by -case basis to modify, suspend or revoke the authorization. Activities subject to Section 404 (as indicated above) may also require an individual Section 401 Water Quality Certification. You should contact the NC Division of Water Resources (telephone 919-807- 6300) to determine Section 401 requirements. For activities occurring within the twenty coastal counties subject to regulation under the Coastal Area Management Act (CAMA), prior to beginning work you must contact the N.C. Division of Coastal Management in Morehead City, NC, at (252) 808-2808. This Department of the Army verification does not relieve the permittee of the responsibility to obtain any other required Federal, State or local approvals/permits. If there are any questions regarding this verification, any of the conditions of the Permit, or the Corps of Engineers regulatory program, please contact Kimberly Browning, 919.554.4884 x60. Corps Regulatory Official: Expiration Date of Verification: March 18, 2022 SPECIAL CONDITIONS Date: April 22, 2020 1. The permittee understands and agrees that the document entitled "Final Mitigation Plan — Little Sebastian Stream Mitigation Site" dated November 2018, and received March 5, 2020, is incorporated and made part of this permit. Execution of the work and terms given in the approved mitigation plan are a condition of this permit. 2. This Nationwide Permit verification does not imply suitability of this property for compensatory mitigation for any particular project. The use of any portion of this site as compensatory mitigation for a particular project will be determined during the permit review process for that project. SAW-2017-01507 Table 1. Authorized discharge of fill material into waters of the United States in association with the NCDMS Little Sebastian Stream Mitigation Site (SAW-2017-01507). Fill Fill Impact Length acreage Duration Regulated Number Classification of w(alc)d of Fill Discharge of Fill Stream Material Material Activity (If) Bottomland Ecological W-1 Hardwood 0.08 Permanent Restoration Bottomland Ecological W 2 Hardwood 0.21 Temporary p ry Restoration Bottomland Permanent Ecological W-3 Hardwood 0.07 Restoration W-4 Bottomland Temporary Ecological Hardwood 0.25 Restoration TOTAL WETLAND 0.61 IMPACTS S1/JN2-C River/Stream-PER Permanent Ecological 24 Restoration S2/JN2-C River/Stream-PER Temporary Ecological 10 Restoration S3/JN2-D River/Stream-PER Permanent Ecological 24 Restoration S4/JN2-D River/Stream-PER Temporary Ecological 10 Restoration S5- River/Stream-PER Ecological 6/JN3-B 1148 Permanent Restoration River/Stream-PER Ecological S7/JN3-B 28 Temporary Restoration S8/Mill River/Stream-PER Permanent Ecological Creek 545 Restoration S9/BS1 River/Stream-PER Permanent Ecological 1202 Restoration S10/BS1 River/Stream-PER Temporary Ecological 10 Restoration S11/Mill River/Stream-PER Ecological Creek 41 Permanent Restoration TOTAL STREAM IMPACTS 3042 *Impacts are associated with aquatic resource restoration and enhancement activities and are expected to result in a net gain in Waters of the US. SAW-2017-01507 COMPLIANCE CERTIFICATION Action ID Number: SAW-2017-01507 County: Surry Permittee: NC Division of Mitigation Services Resource Environmental Solutions, LLC Attn: Mr. Tim Baumgartner Attn: Mr. Bradley Breslow Project Name: NCDMS Little Sebastian Stream Mitigation Site Date Verification Issued: April 22, 2020 Project Manager: Kimberly Browning Upon completion of the activity authorized by this permit and any mitigation required by the permit, sign this certification and return it to the following address: US ARMY CORPS OF ENGINEERS WILMINGTON DISTRICT Regulatory Division Mitigation Office Attn: Kim Browning 3331 Heritage Trade Drive, Suite 105 Raleigh, NC 27587 Please note that your permitted activity is subject to a compliance inspection by a U. S. Army Corps of Engineers representative. Failure to comply with any terms or conditions of this authorization may result in the Corps suspending, modifying or revoking the authorization and/or issuing a Class I administrative penalty, or initiating other appropriate legal action. I hereby certify that the work authorized by the above referenced permit has been completed in accordance with the terms and condition of the said permit, and required mitigation was completed in accordance with the permit conditions. Signature of Permittee Date W North Carolina Regulatory Viewer 11 2859,35397 X Q Shw ....h M"ImforN859�36 7 From: Davis. Erin B To: Baker, Caroline D Subject: FW: [External] Notice of Initial Credit Release/ NCDMS Little Sebastian Mitigation Site/ SAW-2017-01507/ Surry County Date: Wednesday, November 3, 2021 9:37:14 AM Attachments: Little Sebastian 100027 YD 101 STR Initial Release KB.odf As -Built Mitiaation Plan Addendum Review NCDMS Little Sebastian Mitigation Site SAW-2017-01507 Surry County.msg Laserfiche Upload: Email & Attachment DWR#: 20171041 v.1 Doc Type: Mitigation Information From: Browning, Kimberly D CIV USARMY CESAW (USA) [mailto: Kimberly. D.Browning@usace.army.mil] Sent: Tuesday, October 12, 20214:52 PM To: Ryan Medric <rmedric@res.us>; Wiesner, Paul <paul.wiesner@ncdenr.gov> Cc: Tugwell, Todd J CIV USARMY CESAW (US) <Todd.J.Tugwell@usace.army.mil>; Haywood, Casey M CIV (USA) <Casey.M.Haywood@usace.army.mil>; Davis, Erin B <erin.davis@ncdenr.gov>; Wilson, Travis W. <travis.wilson@ncwildlife.org>; Leslie, Andrea J <andrea.leslie@ncwildlife.org>; Bowers, Todd <bowers.todd@epa.gov>; Bradley Breslow <bbreslow@res.us>; Daniel Ramsay <dramsay@res.us>; Crumbley, Tyler A CIV USARMY CESAW (USA) <Tyler.A.Crumbley2@usace.army.mil>; Jones, M Scott (Scott) CIV USARMY CESAW (USA) <Scott.Jones@usace.army.mil>; Harmon, Beth <beth.harmon@ncdenr.gov> Subject: [External] Notice of Initial Credit Release/ NCDMS Little Sebastian Mitigation Site/ SAW- 2017-01507/ Surry County CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Greetings, Per Section 332.8(o)(9) of the 2008 Mitigation Rule, the 15-Day As-Built/MYO review for the Little Sebastian Mitigation Site (SAW-2017-01507) ended September 25, 2021. All comments received from the NCIRT are incorporated in the email below. Please address IRT concerns in the MY1 Report. There were no objections to issuing the initial (30% ) credit release. Please find attached the current signed ledger. The IRT would like to schedule a site visit in 2022. As stated in the email dated October 6, 2021 (attached), based on concerns raised by the IRT, the Corps' decision is to disapprove the proposed addendum for the addition of reach JN-7 which proposed an upward adjustment of the project's stream assets (+19.660 Cool SMUs) for 37 linear feet of restoration. Erin Davis and I have been in contact with RES regarding the amended aquatic resources and how to account for the additional impacts on the 401/404 permits. Please forward the additional information to us so we can re -authorize the permit and update the aquatic resources. Additionally, please include all correspondence related to this review in the MY1 report. As a reminder, the IRT requests that reach JN-7 be monitored for flow and stability throughout the life of the project. DWR MY-0 Comments, Erin Davis: 1. DWR appreciate DMS' request for crossing photos in future reports. Those photos would've been helpful for this review. 2. DWR is ok with the plant species substitutes. We were glad to see the reduction in percent green ash planted. 3. Please confirm that all areas were planted, including any supplemental/understory planting, as proposed in the approved mitigation plan. 4. DWR is ok with the extra stage recorder not being installed on BS1-C. However, when we recently visited the downstream Gideon Site we observed the presence of drift lines mid -slope up the bank but not on the floodplain. Therefore, in lieu of the stage recorder being installed along MC1-C as specified in the approved mitigation plan, DWR requests photo documentation of evidence of overbank events be provided for this reach. USACE MY-0 Comments, Casey Haywood: 1. Concur with DWR's comments. 2. It was noted that two veg plots were moved (both on JN2); however, a random plot was also added. Please contact me with any questions. Respectfully, Kim Kim Browning Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers