20201279 Ver 1_Mitigation Plan Review_20211214

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
December 14, 2021
Regulatory Division
Re: NCIRT Review and USACE Approval of the NCDMS Cool Springs Mitigation Site / Harnett
Co./ SAW-2020-01400/ NCDMS Project # 100166
Lindsay Crocker
North Carolina Division of Mitigation Services
217 West Jones St.
Raleigh, NC 27603
Dear Mrs. Crocker:
The purpose of this letter is to provide the North Carolina Division of Mitigation Services
(NCDMS) with all comments generated by the North Carolina Interagency Review Team
(NCIRT) during the 30-day comment period for the Cool Springs Draft Mitigation Plan, which
closed on October 12, 2021. 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, which is considered approved with this
correspondence. However, several minor issues were identified, as described in the attached
comment memo, which 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. Issues
identified above must be addressed in the Final Mitigation Plan. All changes made to the Final
Mitigation Plan should be summarized in an errata sheet included at the beginning of the
document. 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
USACE Mitigation 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 contact me at Kim berly.d.brown ing(a-)usace.army.mil or [phone].
Sincerely,
Kim Browning
Mitigation Project Manager
for Tyler Crumbley, Deputy Chief
USACE Regulatory Division
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
Jeff Keaton—WEI

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
REPLY TO
ATTENTION OF:
CESAW-RG/Browning
MEMORANDUM FOR RECORD
November 22, 2021
SUBJECT: NCDMS Cool Springs Mitigation Project - NCIRT Comments during 30-day Mitigation
Plan Review, Harnett County, NC
PURPOSE: The comments listed below were received during the 30-day comment period in
accordance with Section 332.8(g) of the 2008 Mitigation Rule in response to the Notice of NCDMS
Mitigation Plan Review.
USACE AID#: SAW-2020-01400
NCDMS #: 100166
30-Day Comment Deadline: October 12, 2021
DWR Comments. Erin Davis.-
1 . Table of Contents — In the final mitigation plan please add an appendix for the design plans.
2. Page 6, Table 4 — Figures 2 and 6 show T2 as an intermittent reach. Please update the
table/figures to be consistent.
3. Page 8, Section 3.8.1 — Please update the LSS site investigation date to match Appendix 4.
4. Page 8, Table 8 — Please update the Gage 4 total days to match the graph in Appendix 4.
5. Page 11, Table 11 — Second Row: Are there existing or proposed vernal pools onsite? Sixth
Row: Are livestock proposed to be relocated as part of this project?
6. Page 12, Section 6.1; Page 16, Sections 6.6; Page 20, Section 7.0 — Please add enhancement
I as a proposed approach.
7. Page 13, Section 6.3 — DWR appreciates the site specific design discharge analysis discussion.
Are the larger design channels still expected to achieve the bankfull event performance standard
and support abutting wetland reestablishment and rehabilitation credit areas?
8. Page 18, T4 — DWR appreciates the note that existing trees with be preserved and we fully
support this effort in the larger project buffer. However, we have some concerns that trees along
the channel may be stressed during construction and could possibly result in localized channel
instability post -construction. Was direct and/or indirect construction impacts to critical root zones
a consideration in determining which streamside trees to preserve?
9. Page 20, Section 6.9.1 — How will onsite soil compaction be addressed?
10. Page 20, Section 6.10 — Please elaborate briefly on the statement that "activities that might take
place in the watershed will have little to no impact on the site streams".
11. Page 20, Section 7.0 — Please note that wetland restoration credit areas must also meet
vegetation performance criteria. Also, please remove the "up to" phrase from the last sentence.
12. Page 21, Section 7.0 — DWR does not support a hydroperiod below 8% for the identified Aquic
Kanhapludult. Please see comment 15 regarding multiple hydroperiods.

13. Page 22, Table 18 — Please add the minimum 30 consecutive flow days' performance standard
for each intermittent restoration reach (T2, T4 & T5 based on Figures 6 & 9).
14. Page 28, Table 21 —
15. DWR believes a 2.5.1 wetland enhancement credit ratio is more appropriate for Wetlands A, B,
D, E, H, I & J due to the lack of proposed monitoring within credit areas.
16. DWR believes a 2.1 wetland enhancement credit ratio is more appropriate for Wetlands C and
G based on baseline groundwater data indicating at least a 24.6% hydroperiod (entire duration
of monitoring period) unless a higher hydroperiod is proposed to demonstrate hydrologic uplift.
17. Figure 10 —
18. None of the proposed Wetland Enhancement credit areas have monitoring stations. Without veg
plots or groundwater gages, how will the proposed hydrologic and/or vegetative functional uplift
be measured? Without monitoring data to demonstrate success, DWR believes a 2.5.1 ratio for
wetland enhancement credit is more appropriate.
19. DWR is ok with the three hydroperiod criterion only if additional gages are installed to properly
cover each hydroperiod criteria within each wetland credit area, which means adding a gage in
the Wetland 1 - 12% area, Wetland 4 - 10% area, Wetland F - 10% area and Wetland F - 8%
area (see comment 12 on the Aquic Kanhapludult % change).
20. DWR request an additional veg plot at least partially within Wetland 3 and another veg plot within
the Wetland 4/5/G complex.
21. DWR understands the benefit of collocating monitoring stations. However, since the flow gauges
on T6 or T8 do not appear to be in the upper 1 /3 of the reach, DWR may request additional flow
data be collected during monitoring if concerns arise.
22. Figures — DWR appreciates that contour lines derived from UDAR data were included on multiple
figures. However, DWR requests a separate UDAR map be added in the final mitigation plan. A
colored UDAR map is very helpful in showing basic site and surrounding area information,
including general floodplain extents, confined valleys and ephemeral drainages in an image that
DWR can easily and quickly review. DWR would like to see a UDAR map included at the
proposal stage, but at minimum we will continue to request a map in our draft mitigation plan
comments on every project moving forward.
23.Appendix 4 — The soil investigation figure shows one to two soil borings per proposed wetland
credit area. Please explain how the extents of the different credit areas were determined. Were
there additional soil sample locations?
24.Appendix 6 — Please include IRT meeting minutes as agency correspondence (this is another
item DWR will always request if it's not initially included).
25. Sheet 0.2 — Are rock outlets proposed for this project? If so, please include a detail and show
approximate locations on the plan view sheets.
26. Sheets 1.1 — 1.9 — Will the old channel be filled to match the surrounding grade? Are any
channel/ditch plugs proposed?
27. Sheet 1.3.1 — The first 250 feet of T2 is proposed to be raised 3-5 feet. Are there any concerns
about this altering the flow regime?
28. Sheet 3.0 — It appears that the buffer planting zone table is missing (unless everywhere beyond
the streambank zone is considered the wetland planting zone). DWR requests that an updated
version of this sheet be provided for review prior to formally submitting the final mitigation plan.
29. Sheet 3.1 — The planting overview does not show any planting zones or extents (full vs.
partial/shaded). This sheet does not have sufficient information for a draft mitigation plan review.
DWR requests that an updated version of this sheet be provided for review prior to formally
submitting the final mitigation plan.
30. Sheet 5.1 — Is it possible to shift the fence line to along existing forest edge between Sta. 104+00
— 107+00? The proposed conservation easement presented to the IRT at the post -contract
included this wooded buffer within the project site.
31. DWR appreciates efforts made to enhance the overall project, including capturing stream origins
and ephemeral drainages, adding BMP water quality features, and minimizing crossings.

USACE Comments, Kim Browning:
1. Section 3.3: Please add a statement regarding the use of proper setbacks from the conservation
easement when chicken litter is spread on the adjacent pastures.
2. Table 18: The Aquic Kanhapludult soils are best represented by the Helena series in the 2016
IRT Guidance, which requires a wetland saturation range of 6-8%. The revised draft IRT
Guidance lists this soils series with a saturation range of 8-10%; while this guidance is not
currently available for use, an 8% hydroperiod is more appropriate for wetland 4 and the
rehabilitation portion of wetland F. Please update Table 18.
3. Figure 10:
a. Please include photos of the BMPs at as -built and at least once during monitoring.
b. Veg plots should be added to capture a portion of wetland 3 and wetland G/4/5.
c. Please add photo points to the crossing on T3 and to the crossing on UT to Cedar Creek.
d. It is unclear how you propose to monitor the three different hydroperiods in Wetland F
without groundwater gauges in each of the three areas (rehabilitation 8%, rehabilitation
10%, and rehabilitation 12%). I concur with DWR's comment #19 that additional gauges
need to be added to wetland F and wetland 1.
4. Section 3.7 & 3.8: I appreciate the detail provided that describes existing stream and wetland
conditions. This is very helpful for the review and to demonstrate the potential functional uplift.
I would welcome the inclusion of existing wetland photos.
5. Section 3.8.2, page 9: Baseline gauge data in existing wetlands proposed for rehabilitation is
24.6%, which exceeds the proposed performance standard of 10% for wetland G and 12% for
wetland C. In general, an area with the presence of hydric soils and hydrology would be
appropriate for wetland enhancement credit at 2:1; however, at the September 29, 2020 IRT
site visit, it was agreed that rehabilitation would be applicable to those areas without current
woody vegetative cover. Therefore, the Corps accepts the 1.5:1 ratio, as proposed. Please
document functional uplift in wetlands C and G throughout monitoring.
6. Figure 9: Please label the wetlands on the concept map.
7. Section 4.2 and Appendix A: The Corps received correspondence from USFWS on October 20,
2020, stating that the action is not likely to adversely affect federally listed species or critical
habitat. Please contact me if you do not have this letter, and be sure to include it in the final
mitigation plan.
8. Appendix 7: I appreciate the detail in the invasive species management plan.
9. Section 6.6: Please include the areas along UT to Cedar Creek that are being supplementally
planted in random transects at least twice during monitoring and show which areas were planted
on the final as -built.
10. Design Sheet 2.6: BMP 5 appears to be placed in an existing wetland. Treatment areas should
not be placed in jurisdictional waters. It appears that logs will be placed in wetland D. Please
confirm that the BMP is not being placed in a wetland.
11. Design Sheets 3.0 and 3.1: Please provide a more detailed planting zone overview. It's difficult
to discern which areas will be planted in the wetland zone, especially since several of the
permanent riparian herbaceous species are FACU. Providing a figure with the planting zones
would be helpful for the review.
12. Section 7.0: Please note that seven years of monitoring will be required. Language should be
removed that references terminating monitoring after five years.
13. Sections 7.0 and 3.8.2: If you intend on using the regional supplement to document vegetative
indicators and soil temperature at the beginning of the growing season, you must also take
these measurements at the end of the growing season to determine the end -date. If you intend
on using the WETS table for establishing November 19 as the end of the growing season, you
must also use what is listed in the WETS table to establish the beginning of the growing season.
Only one method for determining the growing season dates should be used.

14.Table 18: Given the recent Technical Workgroup Discussion regarding pebble counts, do you
want to include the substrate performance standard?
15. Table 19: The monitoring criteria should be tied to the performance standards in Table 18, and
as written, it's unclear which performance standard addresses fencing the conservation
easement to exclude livestock. A narrative of performance standards with an accompanying
monitoring table, as presented in past mitigation plans, is less confusing.
16. Table 19: The Goal "Restore Wetland Function and hydrology" should reference Table 18, not
19.
17. Since none of the proposed Wetland Enhancement credit areas are proposed for monitoring,
how do you propose to demonstrate functional uplift? Fencing will certainly provide a benefit to
the quality of the wetlands, but since vegetative and hydrologic monitoring is not proposed, a
2.5.1 ratio for wetland enhancement credit is more appropriate. I would support a 2.1 ratio only
if vegetative monitoring was proposed.
Kim Browning
Mitigation Project Manager
Regulatory Division

From: Davis, Erin B
To: Baker, Caroline D
Subject: FW: [External] Approval Letter/ NCDMS Cool Springs Mitigation Site/ SAW-2020-01400/ Harnett County
Date: Tuesday, December 21, 2021 11:19:37 AM
Attachments: Approval Letter NCDMS Cool Springs SAW-2020-01400.Ddf
Draft Mit Plan Comment Memo NCDMS Cool SDrinas SAW-2020-01400.Ddf
Laserfiche Upload: Email & Attachments
DW R#: 20201279 v.1
Doc Type: Mitigation Plan Review
From: Browning, Kimberly D CIV USARMY CESAW (USA)
[mailto:[e-mail]]
Sent: Tuesday, December 14, 2021 8:32 AM
To: Crocker, Lindsay <[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]>;
[e-mail]; Bowers, Todd <[e-mail]>; Merritt, Katie
<[e-mail]>; fritz.rohde <[e-mail]>; Garrison, Gabriela
<[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW (USA)
<[e-mail]>; Corson, Kristie <[e-mail]>; Jeff Keaton
<[e-mail]>; Hair, Sarah E CIV USARMY CESAW (USA)
<[e-mail]>; Mickey Sugg <[e-mail]>
Subject: [External] Approval Letter/ NCDMS Cool Springs Mitigation Site/ SAW-2020-01400/ Harnett
Cou my
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Good morning Lindsay,
Attached is the NCDMS Cool Springs Draft Mitigation Plan approval letter and copies of all comments
generated during the project review. This review was conducted in accordance with Section
332.8(g) of the 2008 Mitigation Rule. Please note that this letter approves the Draft Mitigation Plan
provided that the Final Mitigation Plan adequately addresses all comments on the attached memo.
Please provide a copy of the Final Mitigation Plan when you submit the Preconstruction Notice for
the NWP 27. Additionally, please ensure that a copy of the Final Mitigation Plan is posted to the
NCDMS projects page 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.
Respectfully,
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers