20181273 Ver 1_Response to IRT Comments_20211201

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WILDLANDS
E N G I N E E R I N G
December 1, 2021
U.S. Army Corps of Engineers
Regulatory Division
Raleigh Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Attention: Kim Browning
Subject: Monitoring Year 0 Report
Bug Headwaters Mitigation Project, Wilkes County
Yadkin River Basin HUC 03040101
USACE Action ID No. SAW-2018-01788/DWR No. 2018-1273
Dear Kim:
We have reviewed the IRT's comments on the Monitoring Year 0 Report for the Bug Headwaters
Mitigation Site that you sent via email on November 23, 2021. Below are responses to each of the IRT's
comments in your email. Your original comments are provided followed by our responses in bold italics.
This letter will also be included with the MY1 Report.
USACE Comments, Kim Browning:
Ground instability in both pond bottoms will likely be something to watch during monitoring
with regard to vegetation establishment. Was the sediment from the pond removed, and were
soil amendments added prior to plating?
For both ponds, sediment was removed from the stream corridor and replaced with stable fill
material for channel construction. Additional sediment was removed from the pond bottom
along Big Bugaboo Reach 3 to reach bankfull and floodplain elevations. Soil amendments
were added during temporary and permanent seeding activities. Herbaceous vegetation has
been established including a variety of pollinator species. The pond bottom along the right
side of Big Bugaboo Creek Reach 3 and both sides of UT3 will receive supplemental plantings
this winter. This will be addressed in the MY1 report.
2. What is the source of sediment covering the riffle at STA 201+36?
Bank settling was an issue in this area due to the surrounding saturated soil in wetlands.
Vegetation has been established and the sediment is expected to clear as the channel and
floodplain continue to stabilize.
3. If the existing wetlands were planted, please capture some of those areas with random veg plots
in future monitoring years.
Wildlands Engineering, Inc. • phone [phone] • fax [phone] • 1430 S. Mint Street, # 104 • Charlotte, NC 28203

The MY1 assessment has captured some existing wetlands with the random vegetation plots
as well as with fixed plots 1, 3, and 4. Wildlands will continue to rotate the random plots
around throughout the monitoring period to capture other existing wetlands.
4. Were planting substitutions made? It's difficult to tell the percent of each species planted from
Table 6.
Tag alder (Alnus serrulata) was not available for the wetland planting zone. This species was
not replaced due to very limited nursery stock availability of appropriate species, but species
percentage was adjusted accordingly in the As -Built Record Drawings Sheet 3.00 Planting
Table.
DWR Comments, Erin Davis:
Overall, DWR was pleased with the level of detail included in the MYO Report. We also
appreciated DMS' comments. And thank you for providing the drone video, it was very helpful
for this review.
Noted, thank you.
UT3 & UT6 — It could simply be a terminology thing, but "stone bank fortification" raises a yellow
flag about riprapping a section of stream. Please provide a brief description of what was done as
part of the stone bank fortification, as well as a brief justification of need.
Similar to much of the site, quarry stone was used at the UT3/UT6 confluence because no
native stone was available. UT6 is not generating any credit. The pre -construction alignment
of UT6 was not altered but required 3'+ of fill to match the proposed UT3 grade. Larger stone
was added to the riffle matrix and extended partially up the banks to deter settling and ensure
stability of the confluence.
Looking at the redline drawing set restoration reaches profiles, many of the as -built pools are
shallower than the design. Are these features expected to deepen over time? Will changes be
captured by the project cross -sections?
Several heavy rain events occurred during construction before vegetation was established
contributing to sediment in the pools. Bank and floodplain vegetation has now been
established and the sediment is expected to flush through the system over time. Cross -sections
will be surveyed during monitoring years 1, 2, 3, 5, and 7, and data will be included in the
annual monitoring reports showing any changes captured in the cross -sections.
4. Based on observations from the video, if channel maintenance is being considered to manage
any vegetation growing within stream channels it should be proposed within the next two years.
In general, DWR does not support channel maintenance beyond MY3 in order to evaluate the
trajectory of a credit feature's functions (stream vs. wetland).
An aggressive in -stream vegetation treatment will occur in 2022 to manage the vegetation
growing within the stream channels and floodplain wetlands. Once the live stakes become
established and an effective treatment has occurred, it is expected that no channel
maintenance will be needed.
EPA Comments, Todd Bowers:
I have performed a cursory review of the Bug Headwaters mitigation site As -Built and MYO Reports
dated October 2021. At this time I do not have any specific comments or concerns with the site as

presented by Wildlands Engineering. The major deviations such as rock sill replacement with log sills, the
realignment of UT 3, brush toe and riffle enhancements, fence realignments, BMP enhancements, and
the replacement of tag alder with other species in the planting plan were all noted and acceptable.
Noted.
Please contact me at 919-851-9986 x103 if you have any questions.
Thank you,
Jeff Keaton, PE
Project Manager

Laserfche Upload: Email & Attachment
DW R, 20181213 v.l
Doc Type: Mitigation Information
From: Leff Keaton [mailto:jkeaton@wildlaMsen&taro]
SBM: Wednesday, December 1, 20215:16 PM
TO: Kim Browning <[e-mail]>; Wiesner, Paul <p I..es o@dode .g—
Cc: Reid, Matthew <mat[[e-mail]>; Cmmblw, Tyk, A CIV USARMY CESAW (USA( <[e-mail],; Shawn Wilkerson <swilkerson[dwildlandserig.com>; Haywood, Casey M CIV USARMY CESAW (USA)<[e-mail]; Tugwell, Todd
1CIV USARMY CESAW(US(<Todd.l.Tugwell@usace.a,my.mil>;Davis, Erin B<erin.davis@ncden,.gov>; Bowers, Todd <bow todd@e g—; Youngman, Holland 1<hol ddyouungm @fws.g ;Wilson, Travis W.<[e-mail]>; Leslie, Andrea1
<[e-mail]>; Harmon, Beth<beth.ha,mon@ncden 9,g;Stanfill,lim<jim.stanfll@ncden,.gov>;Allen, Melanie<[e-mail]>
Subjert [Ertemal( RE: Notice of Initial Cred'R Release/ NCDMS Bug Headwaters Mitigation SRe/ SAW-2018-01)88/ Wilkes County
verity. se tag¢L�ySLym,
Kim—DMS advked me to go ahead and send the responses to the IRT comments on the Bug Headwaters ASBuilt/MYO report to you in response to youremail below. The comments and responses are included in the attached latter. We will also include this response with the MYl
Report. Please let me know if you have anyquertlons orfurther comments. Thanks.
leHKertan,IE I Senor Wob,1Resources Engineer
0:919.851,9986 ­3 M:919.302.6919
Wildlendz Eneineerine.lnc.
312 West Millbrook Road, Suite 225
Raleigh, NC 27609
From: Brown in&Kimbe,lyDCIV USARMY CESAW(USA(<Kimnrrly D.Rrnwnina mib
SeM: Tuesday, Nwember 23, 20214:35 PM
To: Wies r, Paul <oanlw
Cc: Reid, Matthew <marrnPw mridloln v>;Crumblw, Tyler ACIV N4IRMYCE4IW (1141(<TNPlA ('n�mnlrvJM mib; leff Keaton<kratnnlolwildbndzrn�rnm>; Shawn Wilkerson <swilkrrznnlolwildbndzrn�rnm>;Haywood, CaseyM CIV USARMY CE54W (U41(
<Cazrv.M avwnndlolina dl;1Tugwell, Todd1CIV USARMY CESAW(USA(<Tnr41.ITuawrllloluza miI>, cDavis,rEr. B<rrin davit P-d nv>;Bowers,Todd<bnwrrz mrlrllofrna anv>; Youngman, Hollandl <nnllanrly nlol(wz env>;[mviz unlznnlolnrwilAlifP nm;
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Subject Notice of Initial C,edR Release/ NCDMS Bug Headwaters Mitigation SRe/SAW-2018-01)88/Wilkes County
Paul,
The 15-DayA Built/MYOreviewforthe Bug Headwaters Mitigation Site (SAW-2018-01)88(ended Nwember 19,2021.PerSection 332.8(0((9(ofthe 2008 Mitigation Rule,INN reviewfollowedthestreamlined review process. All comments received fromthe NCIRTare incorporated in the
mail below.Please address IRT concerns inthe MYl Reportand providearesponsetofhkemail. The IRT wouldliketo visitthksitein2022duringthecredit release site vkits. There were noobjediomto issuing theinitial30%coedit releaseof2 6.860c 15MUs. Pleasefndattached
the cu„ent signed ledger.
1.1ro rid instabilityin both pond bottoms will likely be something to watchduring monitoring with regard tovegetation establishment. Was the sedimentfromthe pond removed, and were soil amendments added prior to plating?
2. What b the source of se di—dtcwermg the riffle at STA 201r36?
3. If thee ing wetlands were planted, please capture some ofthose areas with random veg plots in future monitoring years.
4. Were planting substitutions made?lt's difficult to tell the percent of each species planted from Table 6.
DWR Comments. Ed. Davis:
1. O+erall, DWR was pleased with the level ofdetail included in the M10 Report. We also appreciated DMS' comments. And thank you for providing the drone video, it was very helpful for this review.
2. UT3&UT6— It could simply be a t,-dology thin&but"stone bank fortif tlon"raises ayellow fag about di ppinga section ofstream. Please providea brief description of what was done as part of the stone bank fortifcation, as well asa bdefj.ARcatlon of need.
3. Looking a[ the redline drawing set rertoratlon reaches p,ofks, many of the as -built pools a re shallower than the design. Are these features expected to deepen over time? Will changes be captured by the projM cross-sMlons?
4. Based on observa ns from the video, if channelm Nbeing considered to manage any vegetation growing within stream channek R should be proposed within the -A two years. In general, DWR does not support channel maintenance beyond MY3 in order to evaluate
the tmjec[nry of a credit features functions (A,,. vs. wetknd(nce
Todd Rnwnrc
Ihove performed a cur- ikwofthe Bug Headwaters mdipti.site-Bulk and MYO Reports dated October 2021.AtINN time I do not have any specifc comments o, concerns withthe sita as presented by Wild!Wds Engineering. The major deviationssuch as rock All replacement
with log sills, the realignment of UT 3, brush toe and riffle enhancements, fence realignments, BMP enhancements, and the replacement of tag alder with other species in the planting plan were all noted and acceptable.
Happy Thanksgm.&
Kim
Kim Browning
Mitigation P,jMMaruge,,Regubtory Divislon I U.S.Army Co,psof Engineers
—Original Message—
From:Haywood,CaseyMCIV USARMY CESAW(USl(<('a=rv.M Havwnndlolinaro ar vmil>
Sent: Thursday, November 04, 202112:33 PM
To: Tugwell, Todd1CIV USARMY CESAW(USA(<Tndd. I Tnawrlllolnza miI>;B,ownin&Kimbedy DCIV USARMY CESAW(USA(<KimnrrlvD.Rrnwnina mib; Davis, Erin B<erin davizlolnrd nv>;Bowers,Todd<nnwrrz mddonrnaen�o; Youngman, HolkndI
<nnlUndv nlol(wz env,,[mviz wilznnlolnrwildlifP ore; andrra lrzli lolnrwilHIfir m
CC Wiesner, Paul <oanl wirznrrloln h; Reid, M.Rhew<marrnPw rridloln n;lanes,MScott(Scott(CIV USARMY CESAW(USA(«rnrclnnr=of)n=a mil>;Cmmblw,Tyle,ACIV USARMY CESAW(USA(<TNrrA Cn�mnlrvJ ofl mib; Boggs, Brandee C CIV
USARMY CESAD(USl(<Bmndrr. C. mil,, L eff Keaton< krainn dwildbndzrn�r.—; Shawn Wilkerson<swilknrznnlolwildbndzrn�rnm>
Sod-: Notice of As -Built & MYO Review/ NCDMS Bug Headwaters V Rig. tion Site/SAW-2018-01)88/ Wilkes County
Oood aRempo. IRT,
The below referenced FINAL Record Drawing (As -Built( Report review has been requerted by NCDMS. PerSMion 332.8(0((9(of the 2008 Mitigation Rule, this rwkw requires an IRT review period of 15 calendar days. Please provide anycommen[s by 5 PM on the 15-daycomment
ea ddline shown below. When providing comments please indicate if your concerns are great enough that you recommend not issuingth, credit release. Comments provided aRerthe 15-daycomment deadline (shown below( may riot be considered. Pease note:lf an IRT site visit is
requerted, comments will be due 15-daYs aRerthe site visit is conducted.
At the conclusion of this comment period, a copy of all comments will be p,wided to NCDMS and the NCIRT alongwith D'atriot Engineer's intent to approve or disapprove this Final Record Drawing and initial credit release.
15-Day Comment Start Date: Novembe,04, 2021
15-Day Comment Deadline: Nov !,b ,19, 2021
45-Day DE Decision: December 19, 2021
ProjM information and location of the FINAL As -Built Baseline Monitoring Report (MYO
Bug Headwaters Mitigation Site
DMS Pooped p 100084
RFPlt 16-007406 Issued 12/)/201)
In4Rution Date: 6/22/2018 Full Delivery
5AW-2018-01)88
MER 20181273
Yadkin Rive, Basin
Cataloging Unit 03040101
Wilkes County, North Carolina
Mitigation Plan Pooped Credits

7,589.5335MUs (coop
As-Built-MYO Project Credits:
J, 589.533 SMUs (cool(
Mitigation Plan Lengths/ Acreages:
8, 760 ft.
As-Built-MYO Lengths/ Acreages:
8,J00 k.
Please Note:
There was a 60-f„tred«ti,ninstream length from Mitigation Plan Footage t, As -Built F«tage throughout the SRe. UT3 hasa 28-foot r,d.di,. ins[ —length, however, this k ,tdue,thealignment change. The,riginally p,po alignment was 810 feet, while the realigned
submitted t, the IRT was 811 feet. The As -Built Plansshow that nreams werec,n—m as designed with-1,minor deviations. The reduction in rtream footagekrelatedWthe typical differe«e between Overall design Mg. —length and the surveyed rtream lengths.
Project adju—ts are detailed in SPdi,n 2.1 As -built/ Record Drawings. 2021 k Monitoring Year 1 far this project.
FD Provider Wildlands Engineerin&Inc Contact Leff KeatOn,'kratnn onwilAland�rn�r�m<maihn�ikratnn onwilAlanA�rn�r�m>,(919(851-9986 PM. 103
NCDEQ- DMS PM: Matthew Reid, matthrwrrid ann maihn�matthrw rrid unnrdrnrenv>,(828(-231-7912
FINAL ACBuilt Baseline Monitoring Report and Record Drawings can be accessed dir ly,. the DIMS Sh,,Pdr site here:
Adr,ne video of[he sRe is available here: httnc//vnntirhr/ MftnVJJmrA<BI«kedhttps://y,utu.be/_p03gV27—
IRT DIMS Sh—P-t Page (Updated):
<BI«kedhttpsf/ncc,nrectsharep,intc,m/sites/IRT-DMS/SRePages/H,me.aspx>
Bug—dwaters 1OB084 MYO 2021.pdf
<Blockedhttps://ncconn.—harepoirk.com/sites/IRT-DMS/ASBuik%20Report%20%20Drawing/Forms/Nlltems.aspxi
id=%2Fsites%2FIRT%2DDMS%2FASBuik%20Report%20%20Drawing%2FB,g%20Headwaters%20%28100080%29%2FBWHeadwaters%5F1000M0 FMYO%5F2021%2Epdf&parerR 2Fsitos%2FIRT%2DDM5%2FASB,iIt%20Report%20%20Drawing%2FB,g%20Headwaters%20%28100080%29>
Bug—dwaters 1OB080 AB 2021.pdf
'Block,dhttps://ncconneR.sharepoirR.coMsites/IRT-DMS/ASBuik%20Report%20%20Drawing/Forms/Nlltems.aspxi
id=%2Fsites%2FIRT%2DDM5%2FASBuik%20Report%20%20Drawing%2FB,g%20Headwaters%20%28MMM%29%2FBWHeadwaters%5F100 M8 FAB%5F2021%2Epdf&parent= 2Fsites%2FIRT%2DDM5%2FASB,iIt%20Report%20%20Drawing%2FBW%20Headwaters%20%28108080%29>
RIBITS:
Mitigation Speciality, BPVI,Wry Division I U.S. Army C,rps,f Engireers
(919(750-J397 work cell
BUILDING STRONG s