20131087 Ver 1_USACE Comments_20131203

Strickland, Bev
From: Kulz, Eric
Sent: Thursday, December 05, 2013 7:57 AM
To: Strickland, Bev
Subject: FW: Approval Letter: NCEEP Mitigation Plan- Poplin Ridge / Union County / SAW 2012 -01079 / EEP#
95359 (UNCLASSIFIED)
Attachments: EEP Approval Letter-Poplin Ridge_2012- 01079.pdf
13 -1087
Eric W. Kulz
Environmental Senior Specialist
401 and Buffer Permitting Unit
NCDENR - Division of Water Resources -
1650 MSC
Raleigh, NC 27699 -1650
Phone: [phone]
Water Quality Permitting Section
E -mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
- - - -- Original Message---- -
From: Crumbley, Tyler SAW [ mailto: Tyler.Crumbley(@usace.army.mil]
Sent: Tuesday, December 03, 2013 3:41 PM
To: bowers.todd(@epa.gov; Karoly, Cyndi; Kulz, Eric; Burkhard, Michael W; Krebs, Rob; Sollod,
Steve; Cox, David R.; Wilson, Travis W.; ]ones, Scott SAW; Kichefski, Steven L SAW; Wicker,
Henry M ]R SAW; Marella Buncick ( Marella Buncick(@fws.gov); Pearce, Guy; fritz.rohde(@noaa.gov;
Mcdonald, Mike; Wiesner, Paul; Baumgartner, Tim; Norton Webster (norton(@ebxusa.com); Ward
Marotti; Elliott, William A SAW; Kichefski, Steven L SAW
Cc: Crumbley, Tyler SAW; Tugwell, Todd SAW
Subject: Approval Letter: NCEEP Mitigation Plan- Poplin Ridge / Union County / SAW 2012 -01075
/ EEP# 95359 (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Mr. Baumgartner,
Attached is the approval letter for the Poplin Ridge Stream mitigation project, along with
all the comments that were generated during the IRT's review of the project on the Mitigation
Plan Review Portal.
*Please note that this approves the Draft mitigation plan, but also identifies concerns with
the plan that should be addressed in the Final mitigation plan.
When the permit application is submitted for Nationwide Permit #27 authorization, a copy of
this letter should be included along with a copy of the Final Mitigation Plan. Also, please
ensure that the Final mitigation plan is posted to NCEEP's documents portal so that all
members of the IRT have access to the Final plan.
Please let me know if you have any questions about the process or the attached letter.
Sincerely,
-Tyler
1

Tyler Crumbley
Regulatory Division
Wilmington District
U.S. Army Corps of Engineers
11405 Falls of Neuse Road
Wake Forest, NC 27587
(919) 846 -2564
Classification: UNCLASSIFIED
Caveats: NONE

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403 -1343
REPLY TO
ATTENTIONOF: 3 December, 2013
Regulatory Division
Re: NCIRT Review and USACE Approval of the Poplin Ridge Stream Mitigation Plan; (SAW 2012-
01079; EEP IMS 495359)
Mr. Tim Baumgartner
North Carolina Ecosystem Enhancement Program
1652 Mail Service Center
Raleigh, NC 27699 -1652
Dear Mr. Baumgartner:
The purpose of this letter is to provide the North Carolina Ecosystem Enhancement Program
(NCEEP) with all comments generated by the North Carolina Interagency Review Team (NCIRT)
during the 30 -day comment period for the Poplin Ridge Draft Mitigation Plan, which closed on 2
December, 2013. These comments are attached for your review.
Based on our review of these comments, we have determined that no major concerns have been
identified with the Draft Mitigation Plan. However, the minor issues with the Draft as discussed in the
attached comment memo must be addressed in the Final Mitigation Plan.
The Final Mitigation Plan is to be submitted with the Preconstruction Notification (PCN) Application
for Nationwide permit approval of the project along with a copy of this letter and a summation of the
addressed comments. If it is determined that the project does not require a Department of the Army
permit, you must still provide a copy of the Final Mitigation Plan, along with a copy of this letter, to the
appropriate USACE field office at least 30 days in advance of beginning construction of the project.
Please note that this approval does not preclude the inclusion of permit conditions in the permit
authorization for the project, particularly if issues mentioned above are not satisfactorily addressed.
Additionally, this letter provides initial approval for the Mitigation Plan, but this does not guarantee that
the project will generate the requested amount of mitigation credit. As you are aware, unforeseen issues
may arise during construction or monitoring of the project that may require maintenance or
reconstruction that may lead to reduced credit.

Thank you for your prompt attention to this matter, and if you have any questions regarding this
letter, the mitigation plan review process, or the requirements of the Mitigation Rule, please call me at
919- 846 -2564.
Sincerely,
Tyler Lrumbley
Regulatory Specialist
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
CESAW -RG /Wicker, Henry
CESAW- RG- A /Kichefski, Steven
CESAW- RG- A/Elliot, William
NCEEP /McDonald, Mike
NCEEP /Wiesner, Paul
Digitally signed by
CRU MBLEY.TYLER.AUTRY.100750
9975
Date: 2013.12.03 15:33:59 - 05'00'

REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403 -1343
CESAW- RG /Crumbley 15 November, 2013
MEMORANDUM FOR RECORD
SUBJECT: Poplin Ridge- NCIRT Comments During 30 -day Mitigation Plan Review
PURPOSE: The comments listed below were posted to the NCEEP Mitigation Plan Review Portal
during the 30 -day comment period in accordance with Section 332.8(g) of the 2008 Mitigation
Rule.
NCEEP Project Name: Poplin Ridge Stream Mitigation Site, Union County, NC
USACE AID #: SAW- 2012 -01079
NCEEP #: 95359
30 -Day Comment Deadline: 14 November, 2013
1. Paul Wiesner, NCEEP, 17 October, 2013:
• 1 missed this in the initial review, but it needs to make it into the final document. The
credit release schedule in document is incorrect. The Poplin Ridge project was
instituted after Nov. 7, 2011. The final Poplin Ridge mitigation plan should utilize the
credit release schedule for projects instituted after Nov. 7, 2011 per the most recent
EEP template: NCEEP Mitigation Plan Template_version 2.2—adopted 8 June 2012
2. Eric Kulz, NCDWR, 14 November, 2013:
• 1) The report states that utility (electric) easement crossings will be planted with shrub
and herbaceous vegetation. In addition, these easements will be mowed or treated
with herbicide periodically by the utility. As such, the streams within these corridors will
never meet performance standards for vegetation, and will have degraded function
(thermoregulation, nutrient input, LWD input). Credit should be adjusted for each of
these stream segments to reflect the reduced functional uplift, as consistent with
IRT /USACE adjustments on other similar sites.
• 2) Figure 23 identifies the utility crossing over the northern portion of UT2 -4 as a 30-
foot ROW claimed by Union Power Cooperative. The crossing over the lower portion of

UT2 -4 is labeled as "Unknown right -of -way claimed by Union Power Cooperative ". The
width of the ROW should be verified by the utility company to ascertain that it is indeed
a 30 -foot easement and not a wider area which can be maintained.
• 3) A utility easement enters the conservation easement along UT1 -4. The width of the
remaining area that will be forested is unclear in the plans. While buffer /conservation
easement width was added on the opposite side of the stream, the functional uplift to
this portion of the stream may be affected depending on the forested width. Please
provide the width from top of bank of the area to be planted in trees at this location.
3. T. Crumbley and T. Tugwell, USACE, 14 November, 2013:
• A brief discussion on impacts to existing wetlands is presented in the Draft plan, but any
impacts (eg. filling, draining, converting) to current waters of the U.S. (streams,
wetlands and open waters) must be accounted for and discussed in the Pre -
Construction Notification (PCN) and the loss or conversion of those waters must be
replaced on -site. (the conversion of ponds to stream is considered an impact, but the
functional uplift provided allows for this conversion to be conducted under NWP 27.
These impacts do, however need to be accounted for in the PCN).
• Please discuss in further detail any required maintenance of the diffuse flow structures
shown on Design Drawing #s 12, 15, 23, and 24.
• Section 9, pg. 67. Performance Standards: It is stated that the Performance Standards
will be consistent with published federal rules, but additional District /EEP guidance must
also be adhered to. Specifically the "Ecosystem Enhancement Program Monitoring
Requirements and Performance Standards for Stream and Wetland Mitigation" Dated
November 7, 2011. (Section IV C.) *All monitoring and performance standard
requirements need to comply with this EEP /District guidance unless the project was
instituted prior to the release of this guidance*
• Under normal project review processes, a Jurisdictional Determination would have been
submitted concurrently with the Draft mitigation plan. Since no determination was
submitted, please be advised that linear footage and credit amounts may be subject to
change, dependent upon the results of said determination.
• The upstream reach of UT1 and UT1 -13 are proposed for Preservation. In areas where
work conducted will result in functional uplift (eg. wider buffers, stabilization, or
invasive control) the mitigation plan should identify these areas as Enhancement at a
5:1 ratio. If none of these activities will occur then the Preservation ratio should be
reduced, unless justification for Preservation at a 5:1 ratio, with consideration of factors
mentioned in the District stream preservation guidance, is provided.

isi
Tyler Crumbley
Regulatory Specialist,
Regulatory Division
Digitally signed by
CRUMBLEY.TYLER.AU
TRY.1007509975
Date: 2013.12.03
15:33:39 - 05'00'

M E M O R A N D U M WMWK
t'„O N
community infrastructure consultants
616 Colonnade Drive Charlotte, North Carolina 28205 704.334.5348 tel. [phone] fax
TO: David Godley, EBX
FROM: Ward Marotti, WKD
DATE: 17 September 2013
RE: 20120118.00.RA Poplin Ridge Stream Restoration Project: Draft
Mitigation Plan and Preliminary Plan Set (NCEEP Project # 95359)
Listed below are the comments provided by EEP regarding the Poplin Ridge Stream Restoration
Project: Draft Mitigation Plan and WKD's responses.
1. General: Please include the EEP project # (95359) and the Contract # (004672) on the cover of the
revised mitigation plan and all future project deliverables. In addition, the EEP project number
should be used in the document as applicable.
Revised per comment.
2. General: The habitat assessments in this plan were an excellent assessment of existing condition
and an excellent component for setting characterizing uplift potential.
No revisions needed.
3. General: Please confirm that the stream length associated with project area located beneath the
power lines on UT 2 has been removed from the project credits. In addition, any proposed credits
(reduced) beneath power lines or areas resulting in a reduced buffer width should be discussed in
detail in the executive summary and in the report verbiage. For example, please describe (in
detail) the reduced buffer on UT -1 -R4. Please discuss and explain the provider's rational for
seeking full credit on this reach. Additional measures taken in an effort to receive full credit on this
reach should also be discussed in detail.
Revised per comment.
4. General - Reach Designations: EEP is not asking WKD to change the reach breakdowns given the
amount of revision that would generate, but for EEPs internal data management needs it would be
better if UT1 -R1 and UT1 -B would be broken into distinct reaches given the change in the
restoration level between the 2 distinct segments. Also, what was the basis for separating UT1 -R2
and UT1 -R3? It would seem these could have been combined into a single reach. The same
question applies for UT2 -R3 and R4. Please indicate the basis for the reach separation in these
cases. This is just for the purpose of establishing how EEP would like this to be done for future
reference.
Reaches UT 1 -R2 and UT 1 -R3 are separate reaches because there is a difference in channel
condition between the two reaches, and there is a distinct break at the confluence with UT 1 -B
where drainage area is significantly increased. UT1 -R2 exhibits a slight pattern in some areas and

has a very thin buffer of trees along top of bank, while UT 1 -R3 is relatively straight and has no
buffer.
5. General - Dimension and Pattern: It has been EEPs experience that many channels which possess
a significant mismatch between the W/D ratio and the sinuosity (i.e. E channels with a sinuosity of
1.1), especially in the absence of a mature buffer, demonstrate a significant amount of lateral
migration. Significant entrenchment ratios can alleviate some of this concern or reduce the rate,
but ER estimates were not observed in the document. Please comment and update the report as
necessary.
The proposed design parameters (E -type channel with low sinuosity) are based on a stable
reference reach that exhibits similar characteristics (landuse, slope, valley width, drainage area,
etc.) to the project site. Given the narrow valley widths, a channel design with a medium to high
sinuosity would not be ideal and did not appear to be commonplace when performing a
reference reach search. Proposed ERs are greater than 2.2 (typically range between 4.5 and 8.0)
for the restoration reaches, and flood -prone widths range from 70 to over 100 feet. The ERs are
provided within the morphological table in Appendix C.
6. General - Sediment Transport: While the permissible shear and velocity analysis was completed,
there wasn't any explicit comparison of the particle distribution to the particle size that will be
mobilized at the design discharge. Does WKD have an understanding of the sediment supply and
the continuity of stream power between the reaches above the project and the design reaches?
Please comment and update the report as necessary.
Sediment Transport Analysis section revised per comment.
7. General - Monitoring Plan: Given the good work completed on the habitat assessments, EEP would
recommend including similar assessments one or two times during the monitoring period. This
need not be part of the success criteria, but would be of great use to demonstrate project uplift to
the IRT at project closeout.
One habitat assessment will be conducted during the project's final monitoring year and included
in the final monitoring report.
8. Executive Summary: Page 2; Paragraph 4 — It might be a good location to also mention the cattle
exclusion as a component of uplift.
Revised per comment.
9. Section 1: The Lake Twitty - Stewarts Creek 14 -digit HUC is not located within a Local Watershed
Planning area (LWP). Please update the first paragraph accordingly. This 14 digit HUC is, as
stated, a Targeted Local Watershed (TLW). In the second paragraph, please define the acronym
LWP as a Local Watershed Planning area.
Revised per comment.
10. Table 1: The drop in project footage for the project reaches should be explained to the reader. For
example, please explain why the proposed length for the project preservation reaches is less than
the existing length. This should be explained for all of the applicable reaches.
Revised per comment.
11. Table 1 & Table 16: In regards to the project components; please either generate a separate map
clearly showing the separate project component reaches; or reference figures 11A and 11 B in the
tables. The reader should have a clear understanding of the location of each referenced project
reach. In addition, please add a foot note to the tables describing why restoration on UT 2 -3 will
receive a mitigation ration of 1.5:1.
Revised per comment.

12. Table 2: This was a good concise chronology. EEP would encourage reuse of this feature and
format in future submissions. Figure 4 is an excellent exhibit for existing conditions and uplift
opportunity /potential.
No revisions needed.
13. Table 6: Is UT2A really in a type VIII valley? Please comment or revise accordingly.
Revised per comment.
14. Section 4.1.1: Please describe the watershed's future land use trend.
Revised per comment.
15. Section 4.1.3: Please briefly discuss the USFWS' designated critical habitat for the Carolina Heel
splitter in Union County. In addition, please discuss the project's impact/ effect (if any) in regards
to this designated habitat.
Document revised per comment.
16. Section 4.2: Existing Conditions: The degree of incision was not properly characterized. Please
revise this section accordingly.
Document revised to include degree of incision where applicable.
17. Section 4.2.3: Please provide a brief prediction of channel evolution when describing existing
conditions and channel morphology.
Revised per comment.
18. Section 4.2.3.1: UT 1 -Reach 2 — This indicates a 30 foot forested buffer around reach UT1 -R2,
however, Figure 4a indicates a disturbed herbaceous condition. Please comment or revise as
necessary.
Revised document text and figure per comment.
19. Section 4.2.4: In the text, please provide a brief description of what elements are considered when
evaluating "watershed characteristics" in the CSA method.
Revised per comment.
20. Section 4.3.1: Is any ditch plugging anticipated in the floodplain as part of the wetland
enhancement?
No ditch plugging is proposed for wetland enhancement; wetland mitigation is not a component
of this project.
21.
22. Section 4.3.1: EEP highly recommends initiating a USACE jurisdictional determination to confirm
the wetland delineation and survey conducted on the project site. In addition, and potential
wetland impacts from the project should be discussed in detail in this,section. Please include an
impact acreage and associated map showing the proposed impact areas.
JD request sent to USACE.
Wetland impacts are described in the newly added Section 4.3.2 and shown in the newly added
Figure 6a.
23. Section 4.4.2: Please make sure to obtain a floodplain development permit from Union County.
EEP Floodplain Requirement Checklist and summary letter sent to Union County floodplain
administrator (Lee Jenson). Upon confirmation of requirements (i.e. either No Rise or CLOMR), a
floodplain development permit will be requested.

24. Section 4.4.2 & Section 7.2.3: In the revised report, please confirm that the diffuse flow structures
associated with the project will not be located within or impact jurisdictional (intermittent or
perennial) stream channels.
Revised per comment.
25. Section 7.1.5: The reference in this section for a more detailed description of the hydrologic
analysis performed for the project is incorrect. Please revise as necessary.
Revised per comment.
26. Section 7.3.1.2: In Table 24, the proposed shear stresses for UT1 -2 and UT1 -3 did not fall within
the critical and the allowable limits as presented in the document on page 58. Please explain and
revise as necessary.
Sediment Transport Analysis section revised per comment.
27. Table 10: The percent of study area does not equal 100 %. Please update accordingly.
Table corrected and revised per comment.
28. Table 15: The RE credits should only include the preservation SMUs. The R column is the sum of
all credits in the enhancement and restoration categories.
Table revised per comment.
29. Table 16: Restoration; El; and Eli are considered in the Restoration category or (R). Preservation is
considered in the Restoration Equivalent category (RE). For each reach, please list (R) or (RE) in the
fifth column. In addition, please add an eighth column at the end of the table that lists the
proposed SMUs based on the applicable mitigation ratio.
Table revised per comment.
30. Table 26: Indicate under the boundary section that the entire boundary will be checked annually
as part of monitoring. In addition, please include a section that indicates beaver will be managed
during monitoring as necessary.
Table revised per comment.
31. Section 9.3 — Please change mitigation plan to "monitoring baseline document" and cite the
appropriate document/template version number.
Document revised per comment.
32. Section 10.1 — Please indicate that the As -built drawings will be generated and will conform with
the most recent EEP digital drawings guidance.
Document revised per comment.
33. Appendix B — Please make sure the FEMA floodplain checklist is signed in the revised report.
Signed checklist included.
34. Appendix C - Morphological Table — Most of design's dimensionless parameters fall into the low
end of common design ratios for E4 stream types. Please comment and address this in the revised
report text.
The proposed design parameters (E -type channel with low sinuosity) are based on a stable
reference reach that exhibits similar characteristics (landuse, slope, valley width, drainage area,
etc.) to the project site. Given the narrow valley widths, which would not allow for the design of
a highly sinuous channel, some of the dimensionless parameters did fall within the lower end of
common ratios which appears appropriate for the design site. Because these design channels are

low- gradient and have lower energy than pre - project channels, the potential for channel failure is
low.
35. Plan Sheets: Please show the flood feature on the proposed cross - sections.
Bankfull stage /top of bank is labeled on the proposed cross - sections. Also, there is a general note
on each plan sheet that describes how to tie in the channel (cross- section) into existing grade and
references the "Typical Cross - Section Grading" detail on Sheet 32.
36. Plan Sheets: Project structures should be kept within the proposed conservation easement. For
example, Sheet 8 &9 - Reach UT1 -2 station 25 +00 (riffle grade control).
Plans revised per comment.
37. Plan Sheets: The plan set should include a note /s indicating that earthwork should be staged such
that no more channel will be disturbed than can be stabilized by the end of the work day or
before flow is diverted into a new channel segment.
Plans revised per comment.