20170537 Ver 1_Year 3 Monitoring Credit Release_20211119

DEPARTMENT OF THE ARMY
WLMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WLMINGTON, NORTH CAROLINA28403-1343
November 19, 2021
Regulatory Division
Action ID No. SAW-2015-01799
Re: Year 3 Monitoring Report Review and Credit Release associated with Neu -Con
Umbrella Mitigation Bank, Hannah Bridge Stream and Wetland Mitigation Site
EBX-Neuse, LLC
3600 Glenwood Avenue, Suite 100
Raleigh, North Carolina 27612
Dear Mr. Breslow:
This correspondence is in reference to the Neu -Con Umbrella Mitigation Bank,
Hannah Bridge Stream and Wetland Mitigation Site located in eastern North Carolina.
Specifically, the site is located along Green Pasture Road, near Four Oaks, Johnston
County, North Carolina, within the Hannah Creek watershed of the Upper Neuse
Cataloging Unit (03020201). The purpose of this letter is to transmit comments provided
by the NC Interagency Review Team (NCIRT) during the review of the monitoring report
(see attached) and to confirm the Year 3 credit release for this mitigation site.
Pursuant to the Mitigation Banking Instrument (UMBI) entitled, Neu -Con Umbrella
Wetland Mitigation and Stream Restoration Bank, approved April 2, 2001 and amended
April 10, 2009; the site -specific Hannah Bridge Stream and Wetland Final Mitigation Plan
dated March 2018 (with supplemental information received May 2018) and approved
June 27, 2018; and the Hannah Bridge Stream and Wetland Mitigation Site Year 3
Monitoring Report dated September 2021, 10 percent of the mitigation site's total stream
restoration and enhancement credits and 15 percent of the site's total wetland restoration
and enhancement credits shall be available for sale provided the Year 3 Monitoring
Report demonstrates interim performance standards are being met.
Based on a review of the data provided for the stream restoration and enhancement
on the site, we confirm that you have satisfied the above requirements for the Year 3
Monitoring credit release, and 446.6 stream mitigation units (SMUs) are now available for
sale. To date, 2,856.6 SMUs (60 percent of the total restoration and enhancement credits
and 100 percent of the total preservation credits) have been released for sale.

Following a review of the wetland data, it is clear that the site is not performing as
expected. Thus far, 6 of the 13 gauges have failed to meet the performance standard in
any of the three monitoring years. Three additional gauges have only met the
performance standard for one of the three years. At this point, we have released 5.73
WMUs of the 10.73 potential WMUs (50 percent of the total restoration and enhancement
credits and 100 percent of the total preservation credits) and most of those credits (5.18
WMUs) have already been sold. Based on this information, we will not release any
further wetland credits until gauge data demonstrates that the wetland areas are meeting
performance standards.
The cover letter included with the monitoring report indicates that RES is exploring the
option of converting wetland areas to buffer/nutrient credit. Unfortunately, it appears that
the failing gauges are located across the site, which makes it difficult to identify a specific
area where adverse conditions are preventing development of appropriate wetland
hydrology. As such, it would be difficult to identify a specific area that could be removed
from wetland credit and converted to another credit type. Additionally, because so many
of the gauges on the site are failing to meeting the performance standards and more than
50 percent of the site's wetland credits have already been released, any proposal to
modify the instrument to remove wetland credit at this point would potentially lead to a
wetland deficit based on the trajectory of the wetlands on site, therefore, we would not be
willing to consider conversion of wetland areas to buffer/nutrient credit at this time.
Finally, please review the comments provided by the NCIRT during their review of the
monitoring report. While it is not necessary to provide a response to specific comments
at this time, please be sure to address the issues raised in future monitoring report
submittals.
Thank you for your interest in restoring and protecting waters of the United States. If
you have questions regarding this letter, please contact me at
todd.tugwell(a)usace.army.mil or telephone [phone].
Sincerely,
Todd Tugwell
Mitigation Project Manager
Regulatory Division
Electronic Copies Furnished:
NCIRT Distribution List

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON. NORTH CAROLINA28403-1343
CESAW-RG/Tugwell November 19, 2021
MEMORANDUM FOR RECORD
SUBJECT: Action ID # SAW-2015-01799, NCIRT Review Comments on the Neu -Con
Umbrella Mitigation Bank, Hannah Bridge Stream and Wetland Mitigation Site Year 3
Monitoring Report
Erin Davis, NCDWR:
1. Figure 2 CCPV — Moving forward, please show/callout areas of work completed
during monitoring year and proposed for the upcoming year (e.g. January 2021
supplemental planting area). Also, please show the approximate extents of any
"at -risk" credit areas.
2. What species were used in the January 2021 supplemental planting effort?
3. In addition to the three wetland credit areas identified around groundwater wells
GW6, 8 and 13, DWR also considers GW1 "at risk". Have any adaptive
management or additional data collection (e.g. soil samples, supplemental wells)
options been considered for the eight wetland credit areas around the wells not
yet meeting the project performance standard?
Todd Tugwell, USACE:
1. I have significant concern regarding wetland hydrology on the site. Problems
appear to be scattered across the site and not localized, which makes it difficult
to identify a problem area. No credit should be released until there is substantial
improvement in data.
2. It appears that some of the gauges that were listed as meeting performance may
have dropped below 12-inches from the soil surface. In particular, gauges 3, 7
and 12 appear to dip close to or below 12 inches, but it is difficult to determine
what period on the graph was considered for success. On all future monitoring
reports please be sure to call out the longest period of continuous days where
the water table is continuously within 12 inches of the soil surface on the
hydrology graphs. This is helpful because it is not possible to verify the length of
time that the water table is continuously within 12 inches of the soil surface on
the graphs due to the compressed appearance of the days on the x-axis of the
graph.

-z-
3. Vegetation plot data showed that annual means for black willow dropped from 89
stems in years 1 and 2 to 19 stems in year 3. Additionally, 31 winged elms were
present in Year 2, but none were present in Year 3. Lastly, no plots had any
loblolly pine, which is good but surprising. In future monitoring reports, it would
be helpful to get explanations for data anomalies.
Todd Tugwell
Mitigation Project Manager
Regulatory Division

From: Davis, Erin B
To: Baker. Caroline D
Subject: FW: [External] RE: SAW-2015-01799 / EBX-Neuse I, LLC / Neu -Con UMBI / Hannah Bridge Year 3 Monitoring Report
Date: Monday, November 22, 2021 7:54:26 AM
Attachments: 2015-01799 Hannah Bridge Year 3 Monitoring Credit Release.odf
Laserfiche Upload: Email & Attachment
DWR#: 20170537 v.l
Doc Type: Mitigation Evaluation
-----Original Message -----
From: Tugwell, Todd J CIV USARMY CESAW (USA)[mailto:Todd.J.Tugwell(&_usace.anny.mil]
Sent: Friday, November 19, 2021 2:38 PM
To: Brad Breslow <[e-mail]>; Daniel Ramsay <[e-mail]>; Jamey Mceachran <[e-mail]>
Cc: Dailey, Samantha J CFV USARMY CESAW (USA) <Samantha.J.Dailey(a,usace.army.mil>; Kim Browning
<Kimberly.D.Browning(c,usace.army.mil>; Haywood, Casey M CFV USARMY CESAW (USA) <Casey.M.Haywood(cbusace.anny.mil>; Davis,
Erin B <erin.davis@a,ncdenr.gov>; Wilson, Travis W. <travis.wilsongncwildlife.org>; Bowers, Todd <boweis.todd@a,epa.gov>
Subject: [External] RE: SAW-2015-01799 / EBX-Neuse I, LLC / Neu -Con UMBI / Hannah Bridge Year 3 Monitoring Report
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
<m aihwreport. spam(&_nc. gov>
Good afternoon,
Please find attached the Year 3 monitoring report comments and credit release for the EBX, Neuse I, LLC - Hannah Bridge Stream and Wetland
Mitigation Project. Please note that we have not released any wetland credits this year due to on -going concerns regarding the hydrology data for
wetlands on the site. The letter provides more detail about this. I also expect that this will be a site we may want to review next year if wetland
success continues to be an issue.
Thank you and please let me know if you have any questions.
Todd Tugwell
Mitigation Project Manager
Wilmington District, US Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
[phone]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is located at:
httns://urldefense.com/v3/ https://re ue latory.ol2s.usace.army.mil/customer-service-
survey/:!!HYmSToolMcKOG9ikxGyS6fNfDJRdmogVbUblocIVMhgl60GciVOGacOBtixSuFxaLBiJhCRnLUS Thank you for taking the time
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-----Original Message -----
From: Tugwell, Todd J CFV USARMY CESAW (USA)
Sent: Friday, October 08, 2021 3:55 PM
To: Davis, Erin B <erin.davis@a,ncdenr.gov>; Wilson, Travis W. <travis.wilson&cwildlife.org>; Bowers, Todd <bowers.todd@a,epa.gov>
Cc: Dailey, Samantha J CFV USARMY CESAW (USA) <Samantha.J.Dailey(a,usace.army.mil>; Browning, Kimberly D CFV USARMY CESAW
(USA) <Kimberly.D.Browning(cbusace.army.mil>; Haywood, Casey M CFV (USA) <Casey.M.Haywood(cbusace.army.mil>; Jamey Mceachran
<jm ceachran@,,res.us>
Subject: SAW-2015-01799 / EBX-Neuse I, LLC / Neu -Con UMBI / Hannah Bridge Year 3 Monitoring Report
Good afternoon,
The below referenced Year 3 Monitoring Report review has been requested by EBX-Neuse I, LLC. 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 the 15-day comment deadline shown below. When providing comments please indicate if your concerns
are great enough that you intend to request a site visit prior to the credit release. Comments provided after the 15-day comment deadline (shown
below) may not be considered.
At the conclusion of this comment period, a copy of all comments will be provided to EBX-Neuse I, LLC and the NCIRT along with District
Engineer's intent to approve or disapprove this credit release.

Sponsor:
EBX-Neuse I, LLC
Name:
Neu -Con UMBI / Hannah Bridge
USACE ID:
SAW-2015-01799
River Basin:
Neuse
HUC:
03020201
County:
Johnston
YEAR 3 CREDIT RELEASE:
10% of the total stream credits: 446.6 stream mitigation units
15% of the total wetland credits: 1.5 wetland mitigation units
15-Day Comment Start Date: October 8, 2021
15-Day Comment Deadline: October 23, 2021
45-Day Credit Release Approval Deadline: November 22, 2021
*NOTE: If a site visit is request by the IRT, comments are due 15 days after the site visit is complete and the approval deadline is 30 days after the
site visit.
Link to Hannah Bridge Year 3 Monitoring Report can be found on RIBITs in the Cyber Repository for the site:
httns://urldefense.com/0/ https://ribits.ops.usace.anny.mil/ords/f
12=107:10:2303344102322::::P10 BANK ID:4413:!!HYmSToo!McKOG9jkxGyS6fNfDJRdmogVbUbloclVMhgl60GciVOGacO8tixSuFxaL8i3j-
5GIs
Please select the arrow beside Year 3 Monitoring Report to expand the folder and view and/or download the documents.
Thank you,
Todd Tugwell
Mitigation Project Manager
Wilmington District, US Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
[phone]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is located at:
httns://urldefense.com/v3/ hops://reug latofy.ol2s.usace.army.mil/customer-service-
survey/:!!HYmSToo!McKOG9jkxGyS6fNfDJRdmogVbUblocIVMhgl60GciVOGacO8tixSuFxaL8iJhCRnLU$
<h!Ws://urldefense.com/v3/ h=s://reeulatoxy.ol2s.usace.anny.mit/customer-service-

survey/:!!HYmSToo!McKOG9ikxGyS6fNfDJRdmogVbUbloclVMhgl60GciVOGacO8tixSuFxaL8iJhCRnLU$> Thank you for taking the
time to visit this site and complete the survey.