20211424 Ver 1_Initial Evaluation Letter Wildlands Cape Fear 02 UMB_20220125

From: Davis. Erin B
To: Baker. Caroline D
Subject: FW: [External] Wildlands Cape Fear 02 UMB, Twin Burros & Flat Rock Sites Initial Evaluation Letter
Date: Friday, February 11, 2022 9:09:45 AM
Attachments: Initial Evaluation Letter Wildlands Cape Fear 02 UMB 20220125.pdf
Laserfiche Upload: Email & Attachment
DWR#: 20211425 v.1 AND DWR#: 20211424 v.1
Doc Type: Mitigation Evaluation
From: Tugwell, Todd J CIV USARMY CESAW (USA)[mailto:[e-mail]]
Sent: Tuesday, January 25, 2022 2:11 PM
To: Angela Allen <[e-mail]>
Cc: Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>; Kim
Browning <[e-mail]>; Haywood, Casey M CIV USARMY CESAW (USA)
<[e-mail]>; Davis, Erin B <[e-mail]>; Wilson, Travis W.
<[e-mail]>; Munzer, Olivia <[e-mail]>;
[e-mail]; Bowers, Todd <[e-mail]>; John Hutton
<[e-mail]>
Subject: [External] Wildlands Cape Fear 02 UMB, Twin Burros & Flat Rock Sites Initial Evaluation
Letter
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Angela,
Attached is the initial evaluation letter for the Wildlands Cape Fear 02 Umbrella Mitigation Bank,
Twin Burros and Flat Rock sites, which includes copies of all the comments received from the public
notice, and minutes from the IRT site meetings. Per the letter, you may proceed with development
of the draft Umbrella Mitigation Banking Instrument and Mitigation Plans.
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://regulatory.ops.usace.army.mil/customer-service-
surve Thank you for taking the time to visit this site and complete the survey.

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
January 25, 2022
Regulatory Division
Action ID Nos. SAW-2021-01308 & SAW-2021-01309
Re: NCIRT Initial Review of Wildlands Cape Fear 02 Umbrella Mitigation Bank
Prospectus, Twin Burros and Flat Rock Sites
Ms. Angela Allen
Wildlands Engineering, Inc.
312 West Millbrook Road, Suite 225
Raleigh, NC 27609
Dear Ms. Allen:
This letter is regarding your prospectus documents for the proposed Wildlands Cape
Fear 02 Umbrella Mitigation Bank. The proposal consists of the establishment and
operation of a commercial mitigation bank, and two associated sites. The Twin Burros
site (SAW-2021-01308) is approximately 55 acres in sized and is located within the
Hughes Mill Creek watershed, off Ross Acres Road, in Burlington, Caswell County, North
Carolina (36.25000 N,-79.32030 W). The Flat Rock site is approximately 166 acres in
sized and is located within the Benaja Creek watershed, off Benaja Road, in Guilford
County, North Carolina (36.24150 N,-79.68860 W). Additional sites may be added to the
umbrella bank in the future once it has received final approval. The proposed bank would
include the restoration, enhancement and preservation of riparian and non -riparian
wetlands and warm water streams within the Cape Fear River Basin (03030002 HUC).
The Corps determined the Prospectus was complete and issued a public notice (P/N
SAW-2021-01308 & SAW-2021-01309) on November 23, 2021. The purpose of this
notice was to solicit the views of interested State and Federal agencies and other
parties either interested in or affected by the proposed work. Attached are comments
received in response to the public notice from the U.S. Fish and Wildlife Service, the
State Historic Preservation Office, and the Catawba Indian Nation Historic Preservation
Office.
The Corps has considered the comments received from the public notice, and from
members of the Interagency Review Team (IRT) who provided comments during the
draft Prospectus review, and information that was discussed during IRT site reviews
conducted on August 4, 2021 (meeting notes attached). We have determined that the
proposed umbrella mitigation bank appears to have the potential to restore and

enhance aquatic resources within the 8-digit HUC 03030002 of the Cape Fear River.
Therefore, you may proceed with preparation of a draft Umbrella Mitigation Banking
Instrument (UMBI) and draft Mitigation Plans for the two sites.
Please be sure to provide responses to the attached comments with your draft UMBI
and Mitigation Plan submittal. We appreciate your interest in restoring and protecting
waters of the United States. If you have questions regarding this letter, please contact
me at the Raleigh Regulatory Field Office by email at Todd.Tugwell(a-usace.army.mil or
telephone [phone].
Sincerely,
Todd Tugwell
Mitigation Project Manager
Regulatory Division
Electronic Copies Furnished:
NCIRT Distribution List

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
551-F Pylon Drive
Raleigh, North Carolina 27606
November 29, 2021
Todd Tugwell
U.S. Army Corps of Engineers, Wilmington District
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re: Wildlands Engineering Cape Fear 02 UMB Twin Burros Mitigation Site/ SAW-2021-01308/ Caswell
Co.
Dear Mr. Tugwell:
The U.S. Fish and Wildlife Service (Service) has reviewed the information concerning the above
referenced project. The project, based on the description in your letter to our office, and other
information, is expected to have minimal adverse impacts to fish and wildlife resources.
In accordance with the Endangered Species Act of 1973, as amended, (ESA) and based on the
information provided, and other available information, it appears the action is not likely to adversely
affect federally listed species or their critical habitat as defined by the ESA. We believe that the
requirements of section 7 (a)(2) of the ESA have been satisfied for this project. Please remember that
obligations under the ESA must be reconsidered if: (1) new information identifies impacts of this action
that may affect listed species or critical habitat in a manner not previously considered; (2) this action is
modified in a manner that was not considered in this review; or, (3) a new species is listed or critical
habitat determined that may be affected by the identified action.
For your convenience a list of all federally protected endangered and threatened species in North
Carolina is now available on our website at http://www.fws.gov/raleigh. Our web page contains a
complete and frequently updated list of all endangered and threatened species protected by the
provisions of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.)(Act), and a list of
federal species of concern' that are known to occur in each county in North Carolina.
Section 7 of the Act requires that all federal agencies (or their designated non-federal representative), in
consultation with the Service, insure that any action federally authorized, funded, or carried out by such
agencies is not likely to jeopardize the continued existence of any federally -listed endangered or
threatened species. A biological assessment or evaluation may be prepared to fulfill that requirement
and in determining whether additional consultation with the Service is necessary. In addition to the
1 The term "federal species of concern" refers to those species which the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their designation
does not necessarily imply that the species will eventually be proposed for listing as a federally endangered or
threatened species. However, we recommend that all practicable measures be taken to avoid or minimize adverse
impacts to federal species of concern.

federally -protected species list, information on the species' life histories and habitats and information
on completing a biological assessment or evaluation and can be found on our web page at
http://www.fws.gov/raleigh. Please check the web site often for updated information or changes.
If your project contains suitable habitat for any of the federally -listed species known to be present
within the county where your project occurs, the proposed action has the potential to adversely affect
those species. As such, we recommend that surveys be conducted to determine the species' presence
or absence within the project area. The use of North Carolina Natural Heritage program data should not
be substituted for actual field surveys.
If you determine that the proposed action may affect (i.e., likely to adversely affect or not likely to
adversely affect) a federally -protected species, you should notify this office with your determination, the
results of your surveys, survey methodologies, and an analysis of the effects of the action on listed
species, including consideration of direct, indirect, and cumulative effects, before conducting any
activities that might affect the species. If you determine that the proposed action will have no effect
(i.e., no beneficial or adverse, direct or indirect effect) on federally listed species, then you are not
required to contact our office for concurrence (unless an Environmental Impact Statement is prepared).
However, you should maintain a complete record of the assessment, including steps leading to your
determination of effect, the qualified personnel conducting the assessment, habitat conditions, site
photographs, and any other related articles.
The Service appreciates the opportunity to review and provide comments on the proposed action.
Should you have any questions regarding the project, please contact Kathy Matthews at [phone],
extension 27.
Sincerely,
kV.
for Pete Benjamin
Field Supervisor
cc: NMFS, Beaufort, NC
EPA, Atlanta, GA
WRC, Raleigh

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
551-F Pylon Drive
Raleigh, North Carolina 27606
November 29, 2021
Todd Tugwell
U.S. Army Corps of Engineers, Wilmington District
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re: Wildlands Engineering Cape Fear 02 UMB Flat Rock Mitigation Site/ SAW-2021-01309/ Guilford Co.
Dear Mr. Tugwell:
The U.S. Fish and Wildlife Service (Service) has reviewed the information concerning the above
referenced project. The project, based on the description in your letter to our office, and other
information, is expected to have minimal adverse impacts to fish and wildlife resources.
In accordance with the Endangered Species Act of 1973, as amended, (ESA) and based on the
information provided, and other available information, it appears the action is not likely to adversely
affect federally listed species or their critical habitat as defined by the ESA. We believe that the
requirements of section 7 (a)(2) of the ESA have been satisfied for this project. Please remember that
obligations under the ESA must be reconsidered if: (1) new information identifies impacts of this action
that may affect listed species or critical habitat in a manner not previously considered; (2) this action is
modified in a manner that was not considered in this review; or, (3) a new species is listed or critical
habitat determined that may be affected by the identified action.
For your convenience a list of all federally protected endangered and threatened species in North
Carolina is now available on our website at http://www.fws.gov/raleigh. Our web page contains a
complete and frequently updated list of all endangered and threatened species protected by the
provisions of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.)(Act), and a list of
federal species of concern' that are known to occur in each county in North Carolina.
Section 7 of the Act requires that all federal agencies (or their designated non-federal representative), in
consultation with the Service, insure that any action federally authorized, funded, or carried out by such
agencies is not likely to jeopardize the continued existence of any federally -listed endangered or
threatened species. A biological assessment or evaluation may be prepared to fulfill that requirement
and in determining whether additional consultation with the Service is necessary. In addition to the
federally -protected species list, information on the species' life histories and habitats and information
1 The term "federal species of concern" refers to those species which the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their designation
does not necessarily imply that the species will eventually be proposed for listing as a federally endangered or
threatened species. However, we recommend that all practicable measures be taken to avoid or minimize adverse
impacts to federal species of concern.

on completing a biological assessment or evaluation and can be found on our web page at
http://www.fws.gov/raleigh. Please check the web site often for updated information or changes.
If your project contains suitable habitat for any of the federally -listed species known to be present
within the county where your project occurs, the proposed action has the potential to adversely affect
those species. As such, we recommend that surveys be conducted to determine the species' presence
or absence within the project area. The use of North Carolina Natural Heritage program data should not
be substituted for actual field surveys.
If you determine that the proposed action may affect (i.e., likely to adversely affect or not likely to
adversely affect) a federally -protected species, you should notify this office with your determination, the
results of your surveys, survey methodologies, and an analysis of the effects of the action on listed
species, including consideration of direct, indirect, and cumulative effects, before conducting any
activities that might affect the species. If you determine that the proposed action will have no effect
(i.e., no beneficial or adverse, direct or indirect effect) on federally listed species, then you are not
required to contact our office for concurrence (unless an Environmental Impact Statement is prepared).
However, you should maintain a complete record of the assessment, including steps leading to your
determination of effect, the qualified personnel conducting the assessment, habitat conditions, site
photographs, and any other related articles.
The Service appreciates the opportunity to review and provide comments on the proposed action.
Should you have any questions regarding the project, please contact Kathy Matthews at [phone],
extension 27.
Sincerely,
k"
for Pete Benjamin
Field Supervisor
cc: NMFS, Beaufort, NC
EPA, Atlanta, GA
WRC, Raleigh

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
December 20, 2021
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
Todd Tugwell todd.j.tu_well e,usace.army.mil
US Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re: Twin Burros Mitigation Site, 36.239494,-79.68927, Pleasant Grove, Caswell County, ER 21-3075
Dear Mr. Tugwell:
Thank you for your letter of November 23, 2021, regarding the above -referenced undertaking. We have
reviewed the submission and offer the following comments.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or environmental.reviewgncdcr.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
�Sincerely,
Ramona Bartos, Deputy
State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
December 20, 2021
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
Todd Tugwell todd.j.tu_well e,usace.army.mil
US Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re: Wildlands Cape Fear 02 Umbrella Mitigation Bank, Flat Rock Mitigation Site, 36.239494,
-79.68927, Reidsville, Guilford County, ER 21-3074
Dear Mr. Tugwell:
Thank you for your letter of November 23, 2021, regarding the above -referenced undertaking. We have
reviewed the submission and offer the following comments.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or environmental.review(a�ncdcr.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
(1� Sincerely,
Ramona Bartos, Deputy
(� State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

Office 803-328-2427
Fax [phone]
December 28, 2021
Attention: Todd Tugwell
Dept. of the Army — Wilmington District
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re. THPO # TCNS # Project Description
2022-56-5 SAW-2021-01309 Wildlands Cape Fear 02 Umbrella Mitigation Bank
Dear Mr. Tugwell,
The Catawba have no immediate concerns with regard to traditional cultural properties,
sacred sites or Native American archaeological sites within the boundaries of the
proposed project areas. However, the Catawba are to be notified if Native American
artifacts and / or human remains are located during the ground disturbance phase
of this project.
If you have questions please contact Caitlin Rogers at 803-328-2427 ext. 226, or e-mail
[e-mail].
Sincerely,
C Gt t
Wenonah G. Haire
Tribal Historic Preservation Officer

w
WILDLANDS
ENGINEERING
MEETING MINUTES
MEETING: Prospectus Review IRT Site Visit
Twin Burros Mitigation Bank
Cape Fear River Basin 03030002; Caswell County, NC
USACE ID: SAW-2021-01308
DATE: On -site Meeting: August 4, 2021
Meeting Notes Distributed: Wednesday August 21, 2021
Attendees
Todd Tugwell, USACE
Kim Browning, USACE
Samantha Dailey, USACE
Casey Haywood, USACE
Erin Davis, NCDWR
Travis Wilson, NCWRC
Olivia Munzer, NCWRC
Jeff Keaton, Wildlands Engineering
John Hutton, Wildlands Engineering
Angela Allen, Wildlands Engineering
Charlie Neaves, Wildlands Engineering
During the meeting, the group discussed mitigation practices proposed in the Twin Burros Mitigation Site
Prospectus. Notes below are intended to summarize Wildlands' interpretation of topics discussed.
Meeting Notes
1. Todd asked if it were possible to move crossings to ends of the conservation easement and if one of the
crossings on Maria Creek could be eliminated. Wildlands stated that crossing location was specifically
requested by the property owner but will investigate feasibility of relocating crossings to easement ends
and reducing the number of crossings. Wildlands indicated that crossings will be internal.
2. Throughout the site visit, the IRT encouraged wider buffers and use of the buffer credit calculation tool.
Wildlands will discuss capturing wider buffers within the conservation easement with the landowner
and implement where feasible. This will be particularly necessary where the easement needs to capture
all of the floodplain or the current easement boundaries make fencing along those lines difficult due to
topography or trees.
3. The IRT asked about expanding the southern easement boundary farther to the south between Martinez
and Vaca Creek to improve easement continuity. Wildlands expects the Landowner will agree to this
change. Wildlands also confirmed that the existing crossing on Jesus Creek at the downstream end of
Wildlands Engineering, Inc. page 1
Twin Burros Mitigation Bank

the current project area will be removed, and that visible vehicle tracks on site are the landowners' ATV
trails.
4. Wildlands plans to contact the downstream landowner on Jesus Creek to discuss stream mitigation
between the current project area and Hughes Mill Creek.
5. The IRT commented on presence of several subdivided parcels to the east of the project areas and asked
about future development pressure. Wildlands explained the landowners' intent to maintain current
ownership of the property for their own residence and cattle farming. The IRT requested that a
discussion of development pressure in the area be included in the mitigation plan.
6. The group discussed whether Martinez Creek was a jurisdictional, intermittent channel or a non -
jurisdictional, erosional, ephemeral channel. Wildlands will collect flow gauge data, trail camera photos,
soil profile descriptions, and analyze precipitation data to support this decision. Sam stated that a
headcut downstream of the origin point currently indicated by Wildlands may be a more appropriate
origin of jurisdiction. The IRT stated that if the channel was shown to be jurisdictional, a bmp was
constructed above the point of jurisdiction, and adequate channel work was proposed to eliminate the
headcuts and stabilize banks, this work would be considered restoration and a ratio of 1:1 or similar
would be appropriate. Erin indicated a flow gauge would be required during the monitoring period if the
channel is used for stream mitigation credit. Travis commented that even if the channel is non -
jurisdictional, it still has a water quality function, but not an aquatic resource habitat function. Wildlands
anticipates submitting a PJD and determining stream jurisdictional status after additional supporting
data is collected.
7. JR Creek, Vaca Creek, and Caballo Creek should be handled similarly to Martinez Creek in terms of
collecting supporting data to determine jurisdictional status, potential BMP implementation, and flow
monitoring during the monitoring phase.
8. Adding wetland mitigation credit was discussed while standing in a broad, flat floodplain area west of
the confluence of Jesus and Panchito Creek. The IRT indicated that areas exhibiting soil -based evidence
of a historic wetland could be claimed for re-establishment credit. Areas lacking soil -based evidence of a
past wetland hydrology regime would qualify for wetland creation credit. The approach in determining
wetland mitigation areas would need to be explained in the mitigation plan. If proposed wetland areas
did not meet hydrology criteria, alternate wetland areas that develop on site could be used for credit.
This should be explained in the Adaptive Management section of the mitigation plan. An LSS report will
be required.
9. The crossing near the confluence of Jesus and Panchito Creek may be moved slightly to a location with
more favorable side slope approaches.
10. Wildlands will try to extend the easement along Panchito Creek to the upstream extent of the
participating landowner's property and try to purchase a conservation easement on the upstream
property. This would require a crossing somewhere on Panchito Creek. Wildlands will construct a BMP
on the erosional channel that forks off of Panchito Creek.
11. The group discussed the proposed restoration approach on Pinto Creek. It was agreed that crediting
should be Enhancement II from the upstream extent to a point approximately 50' upstream of the
existing crossing. Below this point, Pinto Creek will get restoration credit. The group also discussed
whether terminal crossings should be internal or external. Either may be appropriate under certain
scenarios, but internal is preferred for this project.
12. Burro Creek will be enhancement II at a 5:1 credit ratio.
13. Sam, Jeff, and Charlie walked to the origin of Perro Creek. Sam indicated she was comfortable including
this as a jurisdiction stream without additional data since it showed evidence of groundwater discharge.
Wildlands Engineering, Inc. page 2
Twin Burros Mitigation Bank

14. The group discussed an appropriate wetland credit ratio for the wetland up -valley of the Caballo Creek
origin. Wetland enhancement at a 2:1 ratio was agreed upon due to limited ability to affect hydrology of
this wetland.
15. On Maria Creek, John stated that stream credit will begin an appropriate distance downstream of the
off -property pond dam. Wildlands will investigate stabilizing the pond outlet and erosional channels
below the dam, but does not have surveyed property boundaries at this time. Erin asked about property
ownership surrounding the pond. John stated that he thinks the pond is split between multiple parcels
that share a back property line of the creek alignment.
16. Sam and Charlie discussed the occurrence of small wetlands along Maria Creek. These will be delineated
and representative wetland data forms will be included with the PJD request.
17. The group walked downstream along Maria Creek about two-thirds of the way to the northwestern
project terminus. The group agreed that restoration is the best mitigation approach for Maria Creek.
18. During a summary discussion, Todd indicated he feels this is overall a good site but the small tributaries
may present challenges. He suggested using BMPs, where feasible.
19. Erin suggested expanding the project and widening buffers, if possible.
Wildlands Engineering, Inc. page 3
Twin Burros Mitigation Bank

w
WILDLANDS
ENGINEERING
MEETING MINUTES
MEETING: Prospectus Review IRT Site Visit
Flat Rock Mitigation Bank
Cape Fear River Basin 03030002; Guilford County, NC
USACE ID: TBD
DATE: On -site Meeting: August 4, 2021
Meeting Notes Distributed: Tuesday August 10, 2021
Attendees
Todd Tugwell, USACE
Kim Browning, USACE
Samantha Dailey, USACE
Casey Haywood, USACE
Erin Davis, NCDWR
Olivia Munzer, NCWRC
John Hutton, Wildlands Engineering
Angela Allen, Wildlands Engineering
Charlie Neaves, Wildlands Engineering
During the meeting, the group discussed mitigation practices proposed in the Flat Rock Mitigation Site
Prospectus. Notes below are intended to summarize Wildlands' interpretation of topics discussed.
Meeting Notes
1. Todd asked if Wildlands is purchasing an easement or the entire property. John stated Wildlands is
purchasing an easement.
2. Todd provided a brief history of the site's numerous mitigation proposals and prospectuses,
complications due to land use history and manipulation, USACE's decision not to pursue a violation, and
current viability of the property as a stream and wetland mitigation site.
3. Erin asked if the railroad right-of-way shown on the prospectus figures was correct. John stated this was
a GIS approximation and that the true right of way location would be determined with a boundary
survey and deed research.
4. Erin requested a digital elevation model (DEM) be included in the final prospectus.
5. The group had a lengthy discussion regarding likelihood of beaver presence following restoration and
possible beaver mitigation strategies. Wildlands is aware beaver management will likely be required
during the monitoring period and will address this subject in the adaptive management portion of the
mitigation plan.
6. Kim emphasized that they are not requiring providers to design for the potential of beavers accessing
the site after the monitoring period closes out.
Wildlands Engineering, Inc. page 1
Flat Rock Mitigation Bank

7. Erin explained that she would like for the mitigation plan to include discussion on expected different
saturation regimes and varying vegetation communities that result including the possibility that the final
vegetation condition may not be forested in all wetland areas.
8. The IRT indicated plan -view grading figures are very helpful. Wildlands anticipates minor wetland
grading will be required to remove spoil piles and berms, fill floodplain ditches, and remove fill for road
crossings.
9. Erin asked if wetland rehabilitation is expected to affect soils, vegetation and hydrology. Wildlands
indicated areas proposed for rehabilitation will experience functional uplift to all three. John explained
that upon further investigation, Wildlands may elect to propose some areas north of the existing
elevated earthen crossing as enhancement. This is because the stream is less incised through portions of
this area and it is currently unknown if a measurable change in hydrology can be achieved.
10. The group recommended placing wells on site as soon as possible to determine potential enhancement
areas.
11. Sam indicated Fall to be the ideal time for a JD walk of the site.
12. Erin asked about the planting approach for the partially forested areas on the northern third of the
project area. Charlie stated that some level of planting will occur in this area and more about planting
intensity will be decided after determining the construction disturbance footprint.
13. John explained that the design approach for the northern reach of South Trib will be to quickly tie
together the multiple channels draining from an upstream, off -property beaver dam into a single thread
channel. Credit will be based on a single thread channel for the entire length. Priority 1 restoration can
be accomplished to the upstream extend of South Trib.
14. Todd commented that invasive plants are present but appear to be in manageable proportions. Erin
added that they may get worse after cattle are removed and pre-treatment may help.
15. Erin asked about maintenance along the extremities of the railroad right-of-way such as spraying. John
explained that Wildlands has not observed any maintenance activities outside of the clearly maintained
corridor immediately adjacent to the tracks.
16. Erin asked if Benaja Creek and Northwest Trib both enter the project area through culverts. Wildlands
responded that Northwest Trib enters through a culvert and Benaja flows under a bridge and over a rip -
rap apron with 1-2' feet of abrupt drop underneath the railroad trestle.
17. Erin inquired about buffer width on Southeast Trib suggesting consideration of capturing wetlands that
may form. Todd also asked if wetland formation was expected when the pond dam is removed.
18. Erin emphasized that the mitigation plan should include more discussion on vegetation community
types and adaptive management. Erin requested that a nearby vegetation community reference site be
used for this project. Charlie shared the opinion that good vegetation reference sites are difficult to find
and piedmont forested wetlands commonly encountered have a high percentage of red maple or green
ash. Erin and Oliva recommended reviewing other providers' mitigation plans for reference sites or
utilized the NHP database.
19. The group agreed with stream and wetland mitigation approaches and ratios proposed, with the
understanding that the wetland approach may be modified to include enhancement in some areas.
Wildlands Engineering, Inc. page 2
Flat Rock Mitigation Bank