20191132 Ver 1_Mitigation Evaluation_20220505

From: Davis, Erin B
To: Baker, Caroline D
Subject: FW: [External] Wildlands Little Tennessee Umbrella Mitigation Bank MY1 Credit Release for the East Buffalo
Mitigation Site (SAW-2019-01296)
Date: Wednesday, May 18, 2022 1:16:43 PM
Attachments: SAW-2019-01296 WildlandsLittleTennesseeUMB-EastBuffalo MY1CreditRelease.odf
Laserfiche Upload: Email & Attachment
DWR#: 20191132 v.I
Doc Type: Mitigation Evaluation
-----Original Message -----
From: Kichefski, Steven L CIV USARMY CESAW (USA) <Steven.LKichefski(ousace.army.mil>
Sent: Thursday, May 5, 2022 3:46 PM
To: Jake McLean <[e-mail]>; Andrea Eckardt <[e-mail]>
Cc: Davis, Erin B <erin.davis(0ncdenr.gov>; Hamstead, Byron A <byron [e-mail]>; Bowers, Todd
<[e-mail]>; Leslie, Andrea J <[e-mail]>; Wilson, Travis W.
<travis.wilson(oncwildlife.org>; Tugwell, Todd J CIV USARMY CESAW (US)
<Todd.J.Tugwell(ousace.army.mil>; Kim Browning <Kimberly.D.Browning(ousace.army.mil>; Haywood, Casey
M CIV USARMY CESAW (USA) <[e-mail]>; Jones, M Scott (Scott) CIV USARMY
CESAW (USA) <Scott.Jones(0usace.army.mil>
Subject: [External] Wildlands Little Tennessee Umbrella Mitigation Bank MY Credit Release for the East Buffalo
Mitigation Site (SAW-2019-01296)
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Andrea/Jake,
Please find attached the MYl Credit Release letter for the Wildlands Little Tennessee Umbrella Mitigation Bank:
East Buffalo Mitigation Site (SAW-2019-01296). As requested, 10% credit is being released for approved
restoration and enhancement activities that satisfy the MY release requirements pursuant to the Mitigation Banking
Instrument (UMBI) entitled, Agreement to Establish the Wildlands Little Tennessee Umbrella Mitigation Bank,
signed November 4, 2020 and the final site -specific mitigation plan dated October 5, 2020 and the December 16,
2020 email with minor plan revisions. In accordance with the plan, 324.3 SMU's and 0.18 WMU's constituting ten
percent (10%) of the mitigation site's total stream restoration and enhancement credits, one percent (1%) of the
mitigation site's total preservation credits, and ten percent (10%) of mitigation site's total wetland re-establishment,
rehabilitation, and enhancement credits are now available for the East Buffalo Mitigation Site.
Feel free to contact me with any questions.
This electronic copy is an official Department of the Army Notification.
Regards,
Steve Kichefski
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District, Asheville Field Office
151 Patton Avenue, Suite 208
Asheville, NC 28801
(828)-271-7980 Ext. 4234
The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete the Customer Satisfaction Survey located at our website at
https://urldefense.com/v3/ http://corpsmapu.usace.armv.mil/cm_apex/f7

12=136:4:0 :I I HYmSToo 1 c9Osy8vQVDT4BtcbEFlHsSiEXuOiiyAO-
kmOD3_FerpXiERr3zYmgKAkeVpLQRgFgP2ZHyDOzUs8791nGxh4Uj2JmnD2HAig4rwlS to complete the
survey online.

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
May 5, 2022
Regulatory Division
Action ID No. SAW-2019-01296
Re: MY1 Credit Release associated with the Wildlands Little Tennessee Umbrella Mitigation
Bank — East Buffalo Mitigation Site
Wildlands Engineering, Inc.
Mr. Shawn Wilkerson
swilkerson(awildlandseng.com
Dear Mr. Wilkerson:
This correspondence is in response to your February 15, 2022 request for the Monitoring
Year 1 (MY1) credit release for the East Buffalo Mitigation Site, part of the Wildlands Little
Tennessee Umbrella Mitigation Bank. The 259.84-acre site is located within the Little
Tennessee River Basin Hydrologic Unit 06010204, at 1157 East Buffalo Road in Robbinsville,
Graham County, North Carolina. The project was approved to generate 4,432 cold stream
mitigation units (SMU's) through the restoration, enhancement, and preservation of 13,662 linear
feet of stream on East Buffalo Creek and ten unnamed tributaries to East Buffalo Creek. It was
also approved to generate 1.75 wetland mitigation units (WMU's) through the re-establishment,
rehabilitation and enhancement of 2.46 acres of wetland. The purpose of this letter is to confirm
the MY release of credits for this mitigation site.
Pursuant to the Mitigation Banking Instrument (UMBI) entitled, Agreement to Establish
the Wildlands Little Tennessee Umbrella Mitigation Bank, signed November 4, 2020, the site -
specific East Buffalo Final Mitigation Plan dated October 5, 2020 and the December 16, 2020
email with approved plan revisions, ten percent (10%) of the sites total restoration and
enhancement credits shall be available for sale immediately upon completion of the required
tasks pursuant to the Mitigation Plan.

By copy of this correspondence, we confirm that you have satisfied the above requirements for
initial release for all parcels within the bank; and 324.3 SMU's and 0.18 WMU's constituting ten
percent (10%) of the mitigation site's total stream restoration and enhancement credits, one
percent (1%) of the mitigation site's total preservation credits, and ten percent (10%) of
mitigation site's total wetland re-establishment, rehabilitation, and enhancement credits. With
this release, 40 percent of the total stream restoration and enhancement credits, 40 percent of the
total wetland re-establishment, rehabilitation, and enhancement credits, and 93 percent of the
total stream preservation credits will have been released.
During the NCIRT review and the field visit on February 24, 2022, comments were made by
agency representatives regarding concerns noted with the MY 1 conditions. These comments are
noted below, and within the meeting minutes you provided via email on March 3, 2022 (attached
below). Please provide a response and track in future monitoring reports including any actions
taken to address them.
1. The IRT is concerned by the lack of vegetative success for woody stems throughout the
site and previously approved the supplemental planting plan proposed for the site. We
appreciate that this was coordinated and planted prior to the start of the growing season,
however continued monitoring of vegetative success will be of interest throughout these
areas and credits may be withheld for future performance deficiencies.
2. As Wildlands Engineering, Inc (WEI) noted, no bankfull events were recorded despite
Table 11, in Appendix D, showing above average rainfall for 2021. We see that
monitoring equipment has been shifted to a shorter recording time interval and the IRT
has suggested documenting secondary indicators of bankfull events. Continue to monitor
and update the IRT on this in MY2.
3. During our field visit, we discussed groundwater gage 2 in Wetland K not meeting
success criteria and WEI's proposed adaptive management approach to roughen and
plug the several drainage rills that have formed. Ground gage 3 in Wetland D was well
below hydrology criteria despite a year of above average rainfall and no adaptive
management solutions were offered. The MY 1 report mentions that it "may represent
more marginal wetland areas in Wetland D and will be closely monitored for wetland
hydrology in MY2." Further adaptive management solutions are likely needed if WEI
believes this area should meet rehabilitation performance criteria. Additional
groundwater gages are recommended to help delineate successfully functioning areas if
it is believed that portions of this wetland will not meet criteria.
4. During the MY 1 field visit, the IRT expressed concern regarding the amount of
hydrology contained and transported thru a vernal pool area in the old stream channel of
East Buffalo Creek. There were also indicators of concentrated flow entering this vernal
pool area from the wetland reestablishment area (Wetland K) upslope. Ithad justrained
prior to our site visit and WEI felt no adaptive management was needed at this time other
than the methods proposed in the adaptive management for slowing the flow (plugging
the rills) of the wetland reestablishment area. Please monitor this area for continued
concerns of overabundant storage or concentrated flows that might alter the function as
designed and update the IRT in the MY2 report.
5. The IRT appreciates the detailed meeting minutes provided after the IRT field visit on
February 24, 2022 and the response to IRT As -Built comments in Appendix G. The field
visit minutes are attached to this letter below.

Thank you for your time and cooperation. If you have any questions, please contact
Steve Kichefski at [phone] extension 4234.
for
Electronic Copies Furnished:
Erin Davis (NCDWR)
Andrea Leslie (NCWRC)
Travis Wilson (NCWRC)
Byron Hamstead (USFWS)
Todd Bowers (USEPA)
Todd Tugwell (USACE)
Kim Browning (USACE)
Casey Haywood (USACE)
Scott Jones (USACE)
Sincerely,
Scott Jones, Chief
Asheville and Charlotte Regulatory Field Offices

WILDLANDS
ENGINEERING
MEETING SUMMARY
Meeting: MY1IRTSite Walk
USACE Action ID No. SAW-2019-01296
Date: February 24, 2022 at 10:00 am
Location: East Buffalo Mitigation Site
ATTENDEES
Jake McLean —Wild lands Project Manager
Jessica Waller — Wild lands Monitoring Lead
Joe Love nshimer—Wild lands Stewardship Lead
Steve Kichefski-USACE
Erin Davis — NCDEN R
DISCUSSIONS
1. Tree replanting wasdiscussed and is planned for later in the week.
2. Walked along East Buffalo Road and observed English Ivy treatment area (treatmentwas chemical,
preconstruction).
3. Powerline easementwas discussed. Wildlands should plan on coordinating with Duke to make sure
long-term stewardship considerations were understood by all parties. Wild lands suggested that mowing
the travel way along the maintenance corridor everyyearor two maybe one way to provide a "guide"
for Duke and stewardship coordinator. Access needs are very minimal and IRT was reminding Wild lands
to facilitate mutual understanding of long-term use. Wildlands indicated they would reach outto Duke
to discuss this matter furtheras a proactive way to facilitate appropriate manage mentofthe access.
4. Walked old logging roads across UT2 and along UT3 to view a representative section of the condition of
the preservation areas, crossingwork (stream restoration), and road decommissioning and erosion
control strategies. Erin & Steve agreed on the value of the preservation areas in protecting the
watershed, providingwide buffers, and preserving mature forest. No concerns were raised about any of
the work completed.

5. Visited forested area between UT2 R2 and UT1 to view mechanical and chemical treatments of dense
privet/mu ltiflora infestations, conducted preconstruction and in MYO and MY1. Wild lands is continuing
follow-up treatments..
6. Walked through wetland adaptive management section in reestablishment area toobserve area that did
not meet wetland hydrology criteria in MY1. Preferred flow paths were present, and waterwasflowing
from rainfall preceding site visit. Erin and Steve approved of plans to roughen and plug rills to attempt to
increase retention in the lower half of the reestablishment area. Erin and Steve emphasized that any
more invasive measures to address nonperformance should be undertaken early in monitoring process
to minimize impacts to maturing vegetation. They also indicated that at some point efforts would need
to betaken to isolate any persistent non -performing areas (e.g. additional well installation).
7. Visited remnants of the old East Buffalo Creek channel (receives overflow from wetland reestablishment
area). Erin and Steve discussed the possible concerns associated with this feature —that it may pull base
flow from East Buffalo Creek (decided that this is not a big concern given drainage area), that it could
result in avulsion (Jake explained that it is much higherthan the stream and that the nature of the
colluvial B-type valley flooding is such that avulsion would be highly unlikely), that vernal pools maybe
predated by fish or otherwildlife (it was agreed that predation by fish during high flows would not
apply).
Some general concern about the amount of flow entering old channel, but recognition that it had just
rained. Wildlands explained that the waterflowinginto the old channel remnant is both sheet flow
runoffandalso relict hydrology from a stream that likely ran through the reestablishment wetland but
which was previously diverted upgradient. After limited segment, the old creek bed was plugged to
promote sheet flow across the site and eventually into the new EBC channel.
Everyone recognized thatthe channel could be affecting drawdown in the downstream part of the
wetland reestablishment area. Wildlands indicated they don't anticipate doing any channel plugging to
address the issue.
Of the possible concerns, it was generally agreed that most were not major concerns but that it was
rather a review of potential concerns. No actions were requested except to monitorthe stability of that
area.
8. Visited UT3 R2 and noticed some excess sediment in pools and riffles. The potential source of this
sedimentwas discussed, and Wildlands reminded IRTof the higher levels of legacy sediment in the
contributing preservation streams (potentiallya result of historic logging and/or landslide activity). Erin
and Steve were not too concerned considering it is MY1 and the reported cross sections showed little
sign of change from MYO to MY1.
9. Erin suggested lookingfor and documenting secondary bankfull indicators instead of relying solely on
the automated crest gages. Jess agreed to take photos if indicators were observed during MY2site visits.
10. The IRT expressed satisfaction with channel design, stability, and functionality in all observed reaches
The IRT liked the use of more natural rock configurations in structures stating the benefits of irregular
structures forfish passage.
Wildlands Engineering, Inc. page 2