20180181 Ver 1_Mitigation Evaluation_20211214

DEPARTMENT OF THE ARMY
WLMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WLMINGTON, NORTH CAROLINA28403-1343
December 14, 2021
Regulatory Division
Action ID No. SAW-2017-02527
Re: Year 1 Monitoring Report Review and Credit Release associated with WLS Neuse
02 Umbrella Mitigation Bank, Scarborough Mitigation Site
Ms. Cara Conder
Water & Land Solutions
7721 Six Forks Road, Suite 130
Raleigh, North Carolina 27615
Dear Ms. Conder:
This correspondence is in reference to the WLS Neuse 02 Umbrella Mitigation Bank,
Scarborough Mitigation Project, located near the intersection of Arrington Bridge Road
and Casey Mill Road, in Goldsboro, Wayne County, North Carolina. The mitigation site is
adjacent to and within the Neuse River Basin, Hydrologic Unit Code (HUC) 03020202.
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 1 credit release for this mitigation site.
Pursuant to the Umbrella Mitigation Banking Instrument entitled, Agreement to
Establish the WLS Neuse 02 Umbrella Mitigation Banking Instrument Within The State of
North Carolina, approved on February 18, 2020; and the site -specific Final Mitigation
Plan, Scarborough Mitigation Project dated November 2019; and the Monitoring Report —
MY 1 Scarborough Mitigation Project dated October 2021, 10 percent of the mitigation
site's total restoration and enhancement credits shall be available for sale provided the
Year 1 monitoring report demonstrates interim performance standards are being met.
Based on a review of the data provided for the restoration on the site, we confirm that
you have satisfied the above requirements for the Year 1 Monitoring credit release, and
1,086.3 stream mitigation units (SMUs) and 10.97 wetland mitigation units (WMUs) are
now available for sale. To date, 4,345.2 SMUs and 43.87 WMUs (40 percent of the total
restoration credits) have been released for sale.

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(o)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 December 14, 2021
MEMORANDUM FOR RECORD
SUBJECT: Action ID # SAW-2017-02527 NCIRT Review Comments on WLS Neuse 02
Umbrella Mitigation Bank, Scarborough Mitigation Site Year 1 Monitoring Report
Erin Davis, NCDWR:
1. 1 appreciated the level of detail provided in the monitoring report narrative, as
well as the inclusion of the Figure 6 soil data. Also, the photo comparisons were
helpful both to show the veg establishment over time and infer what the flow
paths/channels looks like beneath the veg obstructing view.
2. Regarding the single -thread restoration UT1 reaches, if channel maintenance is
being considered to manage any vegetation growing within the channel 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
feature's functions (stream vs. wetland).
3. The number of gauge malfunctions was a bit concerning. DWR's glad corrective
actions were taken, as substantial data loss/gaps can affect our ability to properly
review and support a proposed credit release.
4. It's a bit concerning that nine of the random veg plots/transects didn't meet.
Additionally, plots R34 and R35 have low diversity with only two species present.
In Table 5b, what is the different between random transects 27 — 36 and
transects 1 — 5? If transects 1 — 5 were just added for MY1, DWR requests that
they also be surveyed for MY2 based on data results.
5. DWR acknowledges that eight of the 26 wetland gauges didn't meet the
performance standard. But given that it's only MY1, we still support the requested
wetland credit release.
Casey Haywood, USACE:
1. Gauges 5, 7, & 8 indicated inundation for majority of the year and had
hydroperiods at approximately 90% of the growing season. In MY2, recommend
a random transect near one of the gauges to document survivability of
vegetation.
2. The comparison photos from MYO to MY1 helped with the review. Please keep in
mind that it will be important to provide photo documentation of channel
formation for the headwater streams. If some of the cross-section photos are
impeded by vegetation it is recommended to add additional photos as needed to
show field indicators.

-z-
3. Table 5a/b: Were transects 1-5 added for MY1 only? Based on 9 out of 15
random transects failing, it is recommended to continue monitoring these in MY2.
4. Appreciate the immediate action being taken to remove the kudzu on upper UT2.
Todd Tugwell, USACE:
1. The number of wetland gauges that are not meeting success is concerning,
particularly given that the other gauges that are meeting the criteria are well
above the required performance standard. These areas need to be watched
closely over the next year to see if this trend changes or if there are certain
portions of the site that need to be considered at risk. At this point, 40% of the
credits have been released.
Todd Tugwell
Mitigation Project Manager
Regulatory Division

From: Davis, Erin B
To: Baker, Caroline D
Subject: FW: [External] RE: SAW-2017-02527 / WLS Neuse 02 UMB - Scarborough Site / Year 1 Annual Monitoring Report Review and Credit Release Request
Date: Tuesday, December 21, 2021 11:12:17 AM
Attachments: 2017-02527 Scarborouah Year 1 Monitorina Credit Release.odf
Laserfiche Upload: Email & Attachment
DWR#: 20180181 v.1
Doc Type: Mitigation Evaluation
-----Original Message -----
From: Tugwell, Todd J CIV USARMY CESAW (USA)[mailto:Todd.J.Tugweflkusace.army.mil]
Sent: Tuesday, December 14, 2021 5:41 PM
To: [e-mail]; Cara Conder <[e-mail]>
Cc: Merritt, Katie <[e-mail]>; Kim Browning <[e-mail]>; Haywood, Casey M CIV USARMY CESAW
(USA) <[e-mail]>; Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>; Davis, Erin B
<[e-mail]>; Wilson, Travis W. <[e-mail]>; Bowers, Todd <[e-mail]>; kathryn [e-mail]
Subject: [External] RE: SAW-2017-02527 / WLS Neuse 02 UMB - Scarborough Site / Year 1 Annual Monitoring Report Review and Credit Release
Request
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
<mailto:rgport. sl2am&nc. gov>
Apologies - there was an error in the previous credit release. The attached version is correct. It's been a long day
Thank you,
Todd
-----Original Message -----
From: Tugwell, Todd J CIV USARMY CESAW (USA)
Sent: Tuesday, December 14, 2021 5:24 PM
To: '[e-mail]' <[e-mail]>; Cara Conder <[e-mail]>
Cc: 'Merritt, Katie' <[e-mail]>; Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>; Casey
Haywood <[e-mail]>; Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>; Erin Davis
<[e-mail]>; Travis Wilson <[e-mail]>; Todd Bowers <[e-mail]>; Kathryn Matthews
<Kathryn [e-mail]>
Subject: RE: SAW-2017-02527 / WLS Neuse 02 UMB - Scarborough Site / Year 1 Annual Monitoring Report Review and Credit Release Request
Good afternoon,
Please find attached the Year 1 monitoring report comments and credit release for the WLS Neuse 02 UMB, Scarborough Mitigation Site.
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:
https://urldefense.com/v3/ hMs://regulatory_ops.usace.army.mil/customer-service-
survgy/:!1HYmSToo!PRSw2JMvbmVBFH_sAYtar6M5BUbstL6y9hH82hiVLYAxGONPEGoie5vlK]-_RK-sTAO$ Thank you for taking the time to
visit this site and complete the survey.
-----Original Message -----
From: Tugwell, Todd J CIV USARMY CESAW (USA)
Sent: Tuesday, October 26, 2021 2:14 PM
To: Erin Davis <[e-mail]>; Travis Wilson <[e-mail]>; Todd Bowers <[e-mail]>; Kathryn Matthews
<Kathryn [e-mail]>
Cc: Merritt, Katie <[e-mail]>; Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>; Casey
Haywood <[e-mail]>; Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>; Cara
Conder <[e-mail]>; '[e-mail]' <[e-mail]>
Subject: SAW-2017-02527 / WLS Neuse 02 UMB - Scarborough Site / Year 1 Annual Monitoring Report Review and Credit Release Request
Good afternoon,
The below reference bank Sponsor has submitted an Annual Monitoring Report for NCIRT review, and is requesting a release of credits. The Annual
Monitoring Report has been posted to the RIBITS Ober Repository for the bank site (see link and instructions provided below). If you are unable to access
the document or prefer to have a hard copy mailed to you, please let me know as soon as possible, and I will arrange to get you a copy of the report.

This review will follow the process outline for Credit Release Approval in the 2008 Mitigation Rule (Section 332.8(o)(9)), which requires an IRT review
period of 15 calendar days from the date of this email notification. Please provide any comments by 5 PM on the 15-day comment deadline shown below.
Comments provided after the 15-day comment deadline may not be considered. If you would like to request a site visit prior to submitting comments,
please notify me as soon as possible but prior to the 15-day comment due date. If a site visit is required, the due date for IRT comments will be extended to
15 days after the date of site visit. Once I have received a request for a site visit, I will coordinate with the IRT and Sponsor to arrange for the on -site
meeting; however, please note that due to workload it may take a month or longer to arrange the meeting. Within 30 days of the conclusion of the IRT
review period (comment deadline), a copy of all comments will be provided to the bank Sponsor and the IRT along with District Engineer's intent to
approve or disapprove this credit release.
Sponsor:
Water Land Solutions
Bank Name:
WLS Neuse 02 Umbrella Mitigation Bank
Site Name:
Scarborough Site
USACE ID:
SAW-2017-02527
River Basin:
Neuse
HUC:
03020202
County: Wayne
Requested Credit Release: Year 1 Annual Monitoring
10% of the total stream restoration and enhancement credits: 1,086.3 Warm Water Stream Credits
10% of the total wetland restoration and enhancement credits: 10.97 Riparian Riverine Wetland Credits
15-Day Comment Start Date: October 26, 2021
15-Day Comment Deadline: November 10, 2021
45-Day Credit Release Approval Deadline: December 10, 2021
NOTE: Deadlines will be extended if an on -site meeting is requested.
Please be sure to log on to RIBITS before following the link below. Once in the Ober Repository, select the arrow beside appropriate folder to view and/or
download the documents.
Ober Repository Link: httos://urldefense.com/v3/ https://ribits.ops.usace.army.mil/ords/f?
v=107:10:13113093974702:SAVE:::PIO BANK ID:4886 ;!!HYmSToo!PRSw2JMvbmVBFH_sAYtar6M5BUbstL6y9hH82hiVLYAxGONPEGoic5vlK1-
C12e4H80$
Thank you and please contact me with 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

b-qs://urldefense.com/v3/ https://reeulatory_ops.usace.army.miUcustomer-service-
survey/:!!HYmSToo!PRSw2JMvbmVBFH_sAYtar6M5BUbstL6y9hH82hiVLYAxGONPEGoic5v1K1- RK-sTAO$ Thank you for taking the time to
visit this site and complete the survey.