20181271 Ver 1_Mitigation Information_20211124

From:
Davis, Erin B
To:
Baker. Caroline D
Subject:
FW: [External] RE: Notice of Initial Credit Release/ NCDMS Honey Mill Mitigation Site/ SAW-2018-01789/ Surry
County
Date:
Monday, November 29, 2021 7:40:44 AM
Laserfiche Upload: Email
DWR#: 20181271 v.1
Doc Type: Mitigation Information
From: Aaron Earley[mailto:[e-mail]]
Sent: Wednesday, November 24, 2021 9:02 AM
To: Kim Browning <[e-mail]>; Phillips, Kelly D
<Kelly.PhiIli [e-mail]>; Wiesner, Paul <[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CESAW (US) <[e-mail]>; Haywood, Casey M
CIV USARMY CESAW (USA) <[e-mail]>; Davis, Erin B
<[e-mail]>; Wilson, Travis W. <[e-mail]>; Leslie, Andrea J
<[e-mail]>; Bowers, Todd <[e-mail]>; Merritt, Katie
<[e-mail]>; Youngman, Holland J <[e-mail]>; Harmon, Beth
<[e-mail]>; Allen, Melonie <[e-mail]>; Shawn Wilkerson
<[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW (USA)
<[e-mail]>; Jones, M Scott (Scott) CIV USARMY CESAW (USA)
<[e-mail]>; Stanfill, Jim <[e-mail]>; Hajnos, Edward A
<edward. [e-mail]>; Horton, Jeffrey <[e-mail]>; Kristi Suggs
<[e-mail]>
Subject: [External] RE: Notice of Initial Credit Release/ NCDMS Honey Mill Mitigation Site/ SAW-
2018-01789/ 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.
Please see responses to your comments below in red. We will include these responses in letter
format in the MY1 report.
Aaron Earley, PE, CFM
Wildlands Engineering, Inc.
From: Browning, Kimberly D CIV USARMY CESAW (USA) <Kimberly.D.Browningla�usace.army.mil>
Sent: Friday, October 29, 2021 12:53 PM
To: Phillips, Kelly D <Kelly.Phillips(@ncdenr.gov>; Wiesner, Paul <[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CESAW (USA) <Todd.J.TugwellCo�usace.army.mil>; Haywood, Casey
M CIV USARMY CESAW (USA) <Casey.M.HaywoodCa�usace.army.mil>; Davis, Erin B
<[e-mail]>;'Wilson, Travis W. (travis.wilsonco�ncwildlife.org)'
<travis.wilsonCo�ncwildlife.org>; [e-mail]; 'Bowers, Todd
([e-mail])' <[e-mail]>; Merritt, Katie <katie.merritt(@ncdenr.gov>;
Youngman, Holland J <hollandyouungman(@fws.gov>; Aaron Earley <aearley1(@wildlandseng.com>;

Beth. Harmon (@ncdenr.gov; Allen, Melonie (melonie.allenccDncdenr.gov)
<melonie.allen(@ncdenr.gov>; Shawn Wilkerson<swilkersonCcDwildlandseng.com>; Crumbley, Tyler A
CIV USARMY CESAW (USA) <Tyler.A.Crumble)[e-mail]>; Jones, M Scott (Scott) CIV
USARMY CESAW (USA) <Scott.JonesCcDusace.army.mil>; Stanfill, Jim <iim.stanfill(@ncdenr.gov>;
Hajnos, Edward A <edward.hainos(@ncdenr.gov>; Horton, Jeffrey <ieffrey.hortonCCDncdenr.gov>
Subject: Notice of Initial Credit Release/ NCDMS Honey Mill Mitigation Site/ SAW-2018-01789/ Surry
County
Good afternoon Kelly and Paul,
The 15-Day As-Built/MYO review for the Honey Mill Mitigation Site (SAW-2018-01789) ended
October 26, 2021. This review was done in accordance with Section 332.8(o)(9) of the 2008
Mitigation Rule. All comments received from the NCIRT are incorporated in the email below. Please
address IRT concerns by replying to this email and document your responses in the MY1 Report.
There were no objections to issuing the initial (30% ) credit release of 1438.030 cool SMUs. Please
find attached the current signed ledger. The IRT is not requesting a site visit at this time.
USACE Comments, Kim Browning:
1. USACE concurs with DWR's comments, particularly #3. The Mitigation Goals and Objectives in
the final mitigation plan state that existing forested riparian buffers will be enhanced and
protected. The project implementation portion of the final mit plan states that along each
restoration and enhancement reach, cattle will be excluded and open areas of the buffer will
be planted. Removing supplemental planting is a modification to what was agreed upon and
changes the overall functional return. The IRT requires that the originally agreed upon
planting plan be implemented or credit ratios on UT2, UT2A and UT5 will be adjusted prior to
the next credit release.
During construction, several pockets of non -forested areas within the wooded buffer were
identified. Wildlands took the approach of redistributing the bare roots to focus on these
areas using denser spacing (12' vs. 25'). The total number of bare roots planted matched the
quantity in the mitigation plan. While we understand that this is a modification to the
approved mitigation plan, the approach we took addressed several open areas within the
established wooded buffer. Wildlands can plant additional bare roots in the remainder of the
shaded buffer if the IRT desires.
2. The legend on Figure 3 shows the same symbols for permanent and mobile veg plots.
The legend on Figure 3 will be revised to differentiate the types of veg plots.
3. The 10-ft farm path should be shown on the figures in future monitoring reports.
The farm path will be shown on all future monitoring reports.
4. Do the allowable activities in the easement exceptions allow for maintenance of the farm
path? The IRT would have preferred for the farm path to be excluded from the easement.
While we understand that ideally the path should be outside the easement, Wildlands
agreed with DIMS in this instance to leave the path in the easement as an exception. The
easement exemptions do allow for maintenance of the farm path. The landowner is aware of

the limits of the path within the easement.
The farm path located inside the conservation easement and the crossing that extends
outside of the internal crossing cutout were reviewed by DMS, NC DEQ Stewardship and NC
SPO. Both areas were added to the DEQ Stewardship GIS infrastructure geodatabase and
were documented in the DEQ Stewardship project file. The landowner will be able to
maintain the crossing and farm path as constructed. The landowner should notify DEQ
Stewardship prior to conducting maintenance work inside the conservation easement.
NCDWR Comments, Erin Davis:
1. Section 1.3.2 (UT5) —The narrative states that pre -construction the downstream channel's
flow disconnected from the original stream alignment and during construction the
disconnected portion of channel was abandoned and backfilled and the flow was reconnected
with its natural flow path. Why was this not shown as a deviation on the Sheet 1.33 redline?
Wildlands realizes the description of UT5 in section 1.3.2 is misleading and
will revise it for clarity.
2. Section 5.1.6 — Please elaborate on the data point based alignment change for the upstream
portion of UT5 (Enhancement II reach).
The alignment along the upstream portion of UT5 wasn't actually changed. It is in the
original location as mapped on the preliminary jurisdictional delineation (pJD). The
alignment shown in design plans was incorrect, but unfortunately this discrepancy wasn't
caught until the record drawings were being created. At the time, Wildlands redrew the
alignment based on the pJD and decided to show it as a red line because it deviated from the
design plans.
Section 5.1.7 —The statement, "Some areas of supplemental planting were removed at the
engineer's discretion", is not a valid justification for altering the planting plan that was
submitted and approved in the Final Mitigation Plan. It appears that no supplemental
planting was completed in the riparian buffers along UT2, UT2A, UT5. Additionally, only half
of the riparian buffers along UT3, UT4, UT6 and sections of Venable Creek were supplemental
planted. Based on the redline drawings this appears to be a substantial modification to the
approved Plan. Please provide a percent area of the Shaded Supplemental Planting Zone that
was not planted. DWR is recommending that supplemental plantings in these areas be
implemented in accordance with the approved Plan during the next dormant season or
adjustments to credit ratios be considered.
Please refer to USACE comment 1 response.
4. Section 5.1.8 — For the section of fence line removal, what was the adjacent land use changed
to?
Cattle were removed from that parcel and land use is now open agricultural field. The fence
was not installed so that the landowner could timber outside the easement. The landowner
understands that if cattle are reintroduced in the future, fence must be installed.
5. Section 5.2.2 —Are there any long term management concerns with having the culvert extend
beyond the internal crossing? Will it require additional coordination with Stewardship on any

pipe maintenance/replacement?
A letter was mailed to the landowner explaining the allowable limits of culvert maintenance.
The farm path located inside the conservation easement and the crossing that extends
outside of the internal crossing cutout were reviewed by DMS, NC DEQ Stewardship and NC
SPO. Both areas were added to the DEQ Stewardship GIS infrastructure geodatabase and
were documented in the DEQ Stewardship project file. The landowner will be able to
maintain the crossing and farm path as constructed. The landowner should notify DEQ
Stewardship prior to conducting maintenance work inside the conservation easement.
6. Sheet 1.8 — Please confirm that the pre -construction profile as shown resulted in no changes
with ford crossing installation.
Wildlands was on -site during construction and ensured that the ford was installed at grade.
7. Table 9 — It's very nice to see a good species diversity across all of the veg plots.
Noted.
USEPA Comments, Todd Bowers:
1. 1 noted all (very few) redline changes in the plan diagrams and concur with all changes. My
only comment is that structures update in red for the plan views should also appear in the
stream profile to help illustrate differences in the planned or designed grade and the actual
grade of either the thalweg or banks.
Wildlands does not normally show structure invert elevations or structure type deviations on
the record drawing profile. We do show significant changes in the profile as red in the record
drawings. Since the structures were installed within acceptable tolerances, no elevation
deviations were shown on the profile.
Figures 3.3, 3.4 and Sheet 1.5: What happened to the fence that seems to end around UT2B
and begins again around the top of UT5? It appears open ended but is this suitable even with
the change in land use (livestock removal) of the adjacent (former) pasture?
Please refer to NCDWR comment 4 response.
3. Very pleased to see additional land fenced off on the north side of Venable Creek to provide
more buffer between the pasture and the riparian zone within the conservation easement.
Noted.
4. Encroachment of CE due to requested landowner access road noted with no corrective action
needed.
Noted.
5. Planting followed the plan very closely with just a few minor substitutions; all appear suitable
and maintains a diverse mix of species and habits.
Noted.
6. UT2B does not appear on the Planting Plan sheets 2.2 and 2.5.

See response to USACE comment 1 above.
7. All the photos of the streams, veg plots, and mature trees are excellent.
Noted.
Please reach out with any questions.
Regards,
Kim
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers