20200002 Ver 1_Draft Mit Plan Comments_20220614

From: Davis, Erin B
To: Baker. Caroline D
Subject: FW: [External] Notice of Draft Mitigation Plan IRT Comments/ EcoTerra Three Creeks Farm Mitigation Bank/
SAW-2019-02341 / Davidson County
Date: Wednesday, June 15, 2022 3:07:20 PM
Attachments: Draft Mit Plan Comments Three Creeks Farm SAW-2019-02341.odf
Laserfiche Upload: Email & Attachment
DWR#: 20200002 v.1
Doc Type: Mitigation Information
From: Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, June 14, 2022 2:31 PM
To: Norton Webster <[e-mail]>
Cc: Heather Smith ([e-mail]) <[e-mail]>; Tugwell, Todd J CIV USARMY CESAW
(US) <[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW (USA)
<[e-mail]>; Fennel, Tommy E CIV USARMY CESAW (USA)
<[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]>; Hamstead, Byron A
<[e-mail]>
Subject: [External] Notice of Draft Mitigation Plan IRT Comments/ EcoTerra Three Creeks Farm
Mitigation Bank/ SAW-2019-02341 / Davidson County
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Norton,
Attached are the Eco Terra Three Creeks Mitigation Bank Draft Mitigation Plan IRT comments. Due
to IRT concerns, we request a revised draft mitigation plan, which addresses the attached comments
prior to proceeding with development of the final mitigation. Please provide an errata sheet with
responses to IRT comments along with the revision. Please notify me when you upload the revision
to RIBITS and DWR's laser fiche.
Feel free to contact me with questions as you preparing the revision. This electronic copy is your
official Department of the Army Notification; no paper copy will be mailed.
Respectfully,
Kim (Browning) Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers 1 919.946.5107

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
June 14, 2022
SUBJECT: Eco Terra Three Creeks Farm Mitigation Bank Draft Mitigation Plan Review, Davidson
County, NC
PURPOSE: The comments listed below were received from the NCIRT during the 30-day comment
period in accordance with Section 332.8(d)(7) of the 2008 Mitigation Rule.
USACE AID#: SAW-2019-02341 30-Day Comment Deadline: March 30, 2022
Todd Bowers, USEPA:
Note: It is understood that site visits have been made by IRT members during the development of
site feasibility to provide mitigation credit. In that regard, I feel it necessary to denote that I have
not been on -site during this process and that my comments may reflect a lack of on -site
observation and evaluation.
1. General:
o Generally pleased to see that the number of crossings was kept to a minimum and that
historic floodplains of Little Brushy Fork and UT1 are included for functional uplift.
o Having not been onsite to see UT3 for myself, I am curious if the head of the stream
could benefit from a BMP within or without the conservation easement.
2. Section 8.7.1 /Pages 42-43:
o I understand the reason for a crossing in this location on Little Brushy Fork, but 85 feet
wide seems excessive to move farm equipment and/or cattle egress. Please justify the
rationale for such an apparently overwide crossing.
o UT3 Reach 1 is within the CE but has no riparian zone for approximately half it's length.
3. Table 14/Page 44:
o Wetland 5 is between and reconnecting to the floodplains of LBF and UT4, not UT1 as
listed in Table.
4. Table 16/Page 46:
o Please add wetland indicator status to the Table per the Planting Plan Sheets.
5. Section 9.2/Page 48:
o Eight groundwater wells are proposed to cover hydrology monitoring of Wetlands 1, 3-5.
Recommend adding two more gauges to monitor Wetland 2, which currently does not
have groundwater wells designated.
6. Section 9.3/Page 48:
o Recommending clarifying the height requirement as the average of 7 feet or greater at
Year 5 and an average of 10 feet or greater at Year 7.
7. Table 17/Page 50:

o Eight groundwater gauges (recommend 10) are listed for W1, 2, 4, and 5. This is
inconsistent with figures that show no gauges for Wetland 2. Recommend monitoring all
wetlands generating credit.
o Final vegetation standard should be 210 stems per acre at Year 7.
8. Section 10.3/Page 51:
o Recommend 10 monitoring wells to provide coverage of all credit generating wetland
assets.
9. Section 10.5/Page 51:
o Will any of the 31 vegetation plots be set up for random placement?
10. Section 10.6/Page 51:
o I recommend much earlier MY reporting especially if corrective action that may require
IRT approval is needed. Feb 4 is recommended (approximately 90-days post growing
season) for latest submission.
11. Table 21 /Page 55:
o Recommend removing approximately half of the credit for UT3 Reach 1 as the riparian
buffer is essentially absent on the uppermost 100 feet.
12. Table 22/Page 56:
o Missing values for Wetland 3.
13. References/Page 59:
o Recommend using Schafale 2012. Guide to the Classification of the Natural
Communities of North Carolina (4th Approximation)
14. Sheet PSH-04/Page 145:
o Wetland 5 appears to be absent in the vicinity of the LBF and UT4 floodplains.
Erin Davis, NCDWR:
1. Page 4, Section 3.2 — Please include a discussion of projected future watershed and adjacent
area land use. Section 5.1 notes that population growth in the watershed is expected to
continue. Section 8.5.1 notes residential development and continued heavy agricultural
presence are expected to continue. DWR encourages the consultation with local/county
planning agencies and NCDOT, as well as review of available planning documents (e.g.,
comprehensive land use plan, community master plan) as due diligence in assessing potential
future watershed and adjacent land use changes that may affect the long-term success of the
project (e.g., risks of utility/roadway encroachments and influx of sediment/nutrient inputs).
2. Page 6, Table 2 — It would be helpful to have the DWQ stream scores and NCSAM ratings
included in this table or section.
3. Page 8-9, Sectio 3.4 — Other than perched, what's the condition of existing road culverts?
Please check whether NCDOT has any future roadwork/culvert maintenance planned.
4. Page 15, Section 5.7 — Design Sheet PSH-03.d lists four ford crossings and a permanent
culverted stream crossing, which is not consistent with the narrative of this section or Section
8.10. Please update to make consistent the number and type of stream crossings, and number
and width of easement breaks. Please describe all crossings proposed for installation during
the project construction phase, including those located outside of the easement. Additionally,
DWR has concerns about the long-term stability of the proposed at -grade crossings within this
large sand bed system. As noted in the IRT site walk meeting minutes, "all stream crossings
should consist of culverts or pipes". If you believe at -grade crossings to be the most suitable
option, DWR will require a more thorough justification and examples of stable at -grade
livestock stream crossings within sand bed systems (years out from installation) to review.
5. Page 19, Table 7 — Please confirm that the anticipated temporary impacts for UT3
enhancement reaches only involves top of bank stabilization. Any work below OHWM (e.g.,

instream structures, bank toe treatments, fill/excavation) will need to be listed as permanent
impacts.
6. Page 31, Section 8.6.2 — When was the onsite soils investigation completed? Were the 75
borings mapped? If so, please provide. Please include a selection of representative soil boring
logs with location map. Boring photos are also encouraged.
7. Page 33, Section 8.6.4 — Was the Wetbud model run with the general jurisdictional
hydroperiod (5%) or the proposed mitigation hydroperiod (10%)? Not being very familiar with
Wetbud, is it possible to get a list of all the inputs and assumptions added to Appendix F?
8. Page 34, Section 8.6.4 — Please list the total number and installation date of the pre -
construction baseline groundwater gauges.
9. Page 34, Section 8.7.1 — As valued habitat, please confirm that all vernal pools have been
designed to be seasonally dry. And please confirm the vernal pools will be planted/seeded with
species tolerant of saturated soils and inundation.
10. Page 35, Section 8.7.1 — Please provide more information on why the UT1 and UT4
confluence is proposed to shift approximately 150 feet downstream with a vernal pool between
them? Are there any concerns about the long-term stability of these parallel channels?
11. Page 36, Table 14 — For Wetland 3, please add the removal of clay drainage pipes.
12. Page 37, Section 8.8 —
a. Please describe proposed soil restoration. DWR is concerned with compaction from site
land use (including existing farm paths) and proposed construction equipment use, as
well as unfavorable growing properties (e.g., pH, lack of organics) within proposed
excavation/bench cut areas.
b. Please include a description of all invasive and nuisance species currently onsite and
proposed management or reference Appendix G.
c. Will fescue be treated prior to or during construction?
13. Page 38, Table 16 — Please add a column for the species wetland indicator status.
14. Page 38, Section 8.9 —
a. DWR appreciates the discussions noted in this section. Since Appendix G appears to
supplement this section, please add a reference to that appendix.
b. As listed, early flooding is a concern, and we were pleased to read the construction plan
general notes regarding phased seeding to establish cover as quickly as possible.
c. In addition to the risk that sand movement has on constructed structures, DWR is
concerned that the smaller tributaries may lose channel features within the larger, flatter
floodplains of UT1 and LBF and trend toward becoming wetland features. Please
consider this concern in your risk analysis and adaptive management planning. And
please note that channel maintenance (e.g., instream vegetation treatment/removal,
hand grading) should be limited to early monitoring (pre-MY3) in order for the IRT to
properly evaluate how these systems are trending.
15. Page 39, Section 9.0 — DWR does not support early termination of the monitoring period.
16. Page 39, Section 9.1.3 — Please add photo points at all proposed stream crossings.
17. Page 39, Section 9.1.4 — Bankfull events are a performance standard for all restoration
reaches, including intermittent. Please update. Additionally, DWR has some flow concerns with
the proposed work and small drainages of UT2 and UT5. As a reminder, the 30 consecutive
days flow is the very minimum threshold to meet the performance standard and not a target to
demonstrate success.
18. Page 40, Section 9.2 — DWR is glad an onsite rain gauge is proposed. Please provide the
distances to the listed offsite rain stations. Also, what years were used for the WETS Table
growing season dates determination?

19. Page 40, Section 9.3 —
a. Please update the vigor standard to 7 feet in Year 5 and 10 feet in Year 7.
b. Please clarify your performance standard exemption request. DWR is ok with an
exemption for existing forest riparian and wetland areas that are only proposed to be
supplementally planted. If requesting a specific vigor standard exemption for individual
shrub and/or slow growing tree species, please identify which species and provide a
justification.
c. Please be aware that competition from colonizing pine, sweet gum and/or red maple
may require thinning during the monitoring/maintenance period.
20. Page 41, Table 17 — Please note four bankfull events "in separate years" within the monitoring
period (on perennial and intermittent restoration reaches). Please update the final rate of tree
survival from 5 to 7 years and add the vigor standard.
21. Page 43, Section 10.5 — DWR requests that at least 10 of the 31 veg plots are random rather
than fixed. At least one fixed plot should be located within each wetland credit area, except
Wetland 2 Successional. Please also make sure that all Priority 2 and onsite soil borrow areas
are sampled by fixed or random veg plots during the monitoring period.
22. Page 43, Section 10.6 — Please include redline drawings in the MYO Report. Redline drawings
should show actual boundaries of all vernal pools and floodplain interceptors.
23. Pages 47-48, Tables 21 & 22 — Restoration equivalent (RE) is no longer used by DWR. Please
use mitigation types: restoration/reestablishment/rehabilitation (R/Reest/Rehab), enhancement
(E), and/or preservation (P). Also, please add/update ratios in Table 22 to be consistent with
Table 14 and Figure 9.
24. Figures — DWR encourages the inclusion of a colored UDAR map and individual tributary
watershed map. This information is helpful for our review.
25. Figure 4 — Please add the following features/callouts : surrounding property boundaries, pre -
construction groundwater gauge locations, DWQ/SAM/WAM/delineation sample points,
existing ford and culvert stream crossings, existing clay drainage pipes, existing swales and
ditches, and the selected reference wetland site.
26. Monitoring Figures 1 OA-C —
a. Please differentiate between crest and flow gauges.
b. All flow gauges should be located within the upper one-third of the reach. Please shift
the flow gauges upstream on UT3 Reach 1, UT2 and UT5.
c. Please make sure that no groundwater gauges are installed over filled existing ditches
or stream channels.
d. DWR requests that one of the groundwater gauges from Wetland 3 be relocated to near
the photo point in Wetland 4 as we are concerns about the proposed ditch drainage
effect on the reestablishment credit area. Also, please relocate the Wetland 1 right/east
groundwater gauge to be next to the right/east veg plot. DWR can provide a figure
markup upon request.
27.Appendix A — Typically, a Long-term Steward engagement/preliminary agreement letter is
included for the IRT to review in which the proposed entity outlines the specific activities they
intend to be responsible for in perpetuity. DWR appreciates the opportunity to review this
document as evidence of clear communication about the project between the Sponsor and
proposed Long-term Steward. Please make sure to include this information in the final
mitigation plan.
28.Appendices C — Please include NCSAM and NCWAM rating sheets.
29.Appendix E — Please include the 2020 IRT site walk meeting minutes.

30.Appendix G — DWR was glad to see the zero tolerance of Kudzu reiterated, as well as the 5%
max. threshold of invasive cover sitewide.
31. Sheet PSH-02.g — Constructed Riffle Micro Pool Log — The callout states to bury log into bank
4' minimum, but Note #8 states 3' minimum. Please update.
32. Sheet PSH-02.h — Please identify on the as -built redline if/which structures were not installed
with footer logs.
33. Sheet PSH-02.i —Stream Plugs — Plug details typically include an impervious core. Will an
impervious material (e.g., clay) be used in proposed channel plugs? If so, is this material
expected to be sourced onsite? Please confirm this detail also applies to proposed ditch plugs.
34. Sheet PSH-02.i — Floodplain Interceptor — Please briefly describe the function of proposed
floodplain interceptors. Will these features be seeded and planted? The minimum length is
listed at 6 feet; what is the maximum length?
35. Sheet PSH-02.j — DWR has some concerns about the long-term stability of proposed at -grade
crossings. Please see DWR comment #14.
36. Sheet PSH-02.k — Rock Cross Vane — What is the proposed max. drop? Please consider
aquatic passage with all drop structure designs and installations (e.g., 1-foot or less perch).
37. Sheet PSH-02.I — Fill Channel & Vernal Pool — Lines appear to be missing. Please provide a
maximum depth for partially filled channels. DWR has concerns with the proposed 3-feet deep
vernal pools. Please consider a max. depth that will seasonally dry for added wildlife habitat
value. Will vernal pools connect to proposed stream channels? If so, please include details on
the outlet structure. If not, please provide the minimum distance between vernal pools and
stream meander bends.
38. Sheet PSH-02.q — Please identify on the plan sheets where the Headwater Channel design is
being proposed. This design was not noted in the plan narrative. If it is being proposed, please
provide more information on why this design has been selected and how it will be monitored.
39. Sheet PSH-03.e — Note #16 — Non-native vegetation should be removed within the entire
easement. Treatment of existing invasives located outside of construction areas but within the
project easement should not be delayed to MY1.
40. Sheet PSH-03.h — Note #40 — Please confirm that "installation" of the Floodplain Wetland
along UT1 refers to grading the Wetland 4 reestablishment area. Please confirm that proposed
grading will not be greater than 12 inches.
41. Sheet PSH-04 —
a. Please show the NCDOT right-of-way/easement line. What is the setback distance from
the NCDOT culvert to the proposed conservation easement and beginning of stream
credit? Is this distance sufficient for potential future NCDOT culvert maintenance?
b. Please confirm that no proposed vernal pool areas overlap with proposed wetland credit
areas. Also, should vernal pool areas be located within proposed grading limits?
c. Please callout reach breaks on all plan sheets.
42. Sheet PSH-05 —
a. Please explain why construction of a ditch network is necessary. Why can't the access
road ditch transition through a BMP to diffuse flow within the conservation easement?
How will the ditch tie into the stream over the meander brush toe stabilization?
b. For all "end construction" callouts on the tributaries, please make sure that credit stops
at the bank and not the centerline of the confluence.
43. Sheet PSH-06 — What is the length of the Priority 2 section along LBF Reach 3? How will any
bench cutting affect the hydrology of the adjacent wetland enhancement credit area?
44. Sheet PSH-07 & 08 (UT1 & UT2) — Please confirm that stream crediting does not start outside
of the project conservation easement.

45. Sheet PSH-08 —
a. Please show NCDOT and utility right-of-way/easement lines. What is the setback
distance from the NCDOT culvert to the proposed conservation easement and
beginning of stream credit? Is this distance sufficient for potential future NCDOT culvert
maintenance?
b. Please callout the roadway ditches that connect to UT1. During the IRT site walk, we
discussed either including these features in the easement or creating BMPs (see page 1
of the meeting minutes). Please discuss how flow from these ditches will be stabilized
and treated prior to entering the project stream.
46. Sheet PSH-10 —
a. Why is the buffer width so drastically reduced at the top 50-foot section of UT3? Can
this buffer area be expanded? Is there a different credit ratio proposed for this section?
b. Other than for the headcut repair, is any bank grading proposed for stabilization and/or
floodplain connection along UT3?
c. Since full buffer planting isn't necessary and no stream work is shown for UT3 Reach 3,
DWR believes that a 3.1 ratio is more appropriate.
47. Sheet PSH-11 — Related to the above DWR comment #42. Why is installation of a ditch
network necessary? Is there a concern about hydrologic trespass from the proposed wetland
grading? How will this affect the hydrology of the adjacent proposed wetland reestablishment
area? Was this "outflow" included in the Wetbud modelling? Discussion of new ditches within
the easement needs to be added to Section 8.7.
48. Sheet PLT-01 — Reforestation — DWR appreciates the proposed species diversity and that
species quantities are capped at 15 percent. Please update Table 16 to be consistent with this
table (e.g., sugarberry, tag alder, hackberry, hickory, white oak).
49. Sheet PLT-01 — Seeding — Please add the wetland indicator status to the seed mix species.
Given the acreage of wetland and vernal pool areas, please consider adding a few more wetter
species to the mix or adding a separate wetland/pool/floodplain seed mix.
50. Sheet PLT-02 — Please note that all planting should occur by March 15t". Any late planting
extension requests need to be approved by the IRT and may involve a postponement of the
MY1 monitoring period.
51. Design Sheets — Please include an overall fencing concept plan with approximate locations of
existing (to remain) and proposed fencing. Please ensure there is adequate safe access points
for regulatory agency and long-term steward representatives to walk the site.
52. General design note — DWR encourages placement of woody debris within wetland and
floodplain areas as habitat enhancement.
53. DWR appreciates efforts made to enhance the proposed project including reducing the number
of crossings, enriching species diversity, and capturing stream origins where feasible.
Olivia Munzer, NCWRC:
1. In the permanent seed mix, I would like to see another species or two of flowering herbaceous
species.
2. In the Planting Details, there is no differentiation between permeant seed mix between upland,
wetland, or riparian habitats. In the Streambank Reforestation Table, I recommend
differentiating between species planted in wetland vs. the streambank since certain species
have different hydrologic tolerances.
3. In the temporary riparian seed mix, we recommend not using Sudangrass.
4. Access Road to LBF Stream Crossing has a 30" HDPE. NCWRC does not prefer HDPE.

Travis Wilson, NCWRC:
WRC prefers crossing to be included within the recorded conservation easements. Doing so
helps to assure those crossings will not be modified in the future without proper coordination or
go unrepaired if damaged.
2. This system was predominately a sand bed system, at grade crossing are typically not
appropriate for this type of system unless there is underlying bedrock. Even with larger
stone/boulders placed under the crossing the substructure will be vulnerable to destabilizing
with even moderate use by larger equipment or vehicles.
3. UT 3 (approx. station 16) crossing shows the symbology for an at grade crossing but labels the
crossing as a culverted crossing. Please confirm
4. UT 1 (approx. station 30) crossing shows the symbology for an at grade crossing but does not
indicate using the (AG detail). Please confirm and see note #2
5. LBF (approx. station 30+50) crossing shows the symbology for an at grade crossing but does
not indicate using the (AG detail). Please confirm and see note #2
6. LBF (approx. station 30+50) access road: the 100-year floodplain at this location is
approximately 300' wide. The plans include an access road elevated across the floodplain for a
length of over 200'. Looking at the detail (AR) there will be one 30" pipe to pick drainage
toward the toe of slope, the road will be elevated 2+ feet above the natural floodplain elevation,
and a berm will be constructed to further separate overbank flow from portions of the floodplain.
Placing an elevated road across the floodplain is counterproductive to stream and watershed
restoration efforts, specifically a causeway that is not vented to allow flood flow through the
causeway and across the majority of the floodplain. Furthermore, elevating the access road
only to go to an at grade crossing leads to the question are there already plans to improve this
crossing in the future. Please see note #1. An explanation should be provided for the design
of the access road.
Kim Browning, USACE:
1. Figure 4: Please add the following: Existing ditches/swales, existing crossing types,
existing pre -data groundwater gauges, property boundaries, NCSAM/WAM locations,
existing stream conditions (i.e., incised, hoof shear, etc.).
2. Sheet PSH-05: It's unclear why the confluence of UT4 and Little Brushy Fork extends
approximately 150 feet downstream of the current confluence. I still question the need
for parallel channels due to the ridge between the two channels. I do not agree that the
proposed locations are where the channels occurred naturally. I think there is evidence
that the system has been highly manipulated throughout the years, and that the streams
were likely straightened and relocated to the edges of the floodplain to accommodate
farming and agriculture, as is the case with many floodplain stream systems across the
state. If you have a reference stream system with similar characteristics that you feel
justifies your approach, please let us know so that we may reconsider our comments. I
have a concern that this approach would actually increase the risk of problems
occurring with these two reaches, not only because there is more overall length of
channel to be concerned with, but also because one system would dominate the
floodplain and overwhelm the tributary with the smaller watershed. I would question
whether the two channels can be tied -in much further upstream.

3. Crossings: Crossings that are added for landowner access (e.g., cattle crossings, farm
equipment crossings, other maintenance roads or trails) should be located within the
conservation easement. These crossings are subject to the restrictions of the
conservation easement and oversight by the long-term steward. They must also be
identified in the conservation easement description and/or map so that the allowed
activity (e.g., 60' wide gravel path) and extents of the easement exception are clear.
4. Figure 9: Without a detailed soils report, we cannot agree to proposed wetland
approaches or ratios. Please submit the soils report, along with a map of the boring
locations.
5. Figure 10C:
a. An additional wetland gauge should be added to the re-establishment wetland
(W4) near the edge to help determine the limits of jurisdiction.
b. Since UT1 R2 is being raised to access the floodplain, do you not anticipate
wetlands to form adjacent to the channel? This may be an opportunity to add
wetland creation, or even additional re-establishment, depending on the soils
report.
c. What does the label "Wetland 2 Field" mean? Is it currently a field? It should be
labeled with the proposed wetland restoration approach. Or simply label each
wetland by number and use the colors in the legend to differentiate functional
uplift approach.
d. I believe the label UT4 R2 should actually read UT3 R4.
e. Please show random veg plot locations.
6. Figure 1013:
a. The legend colors used for wetland enhancement at different ratios should
remain consistent throughout the document. This figure is different than Figure 9.
b. How wide is the buffer at the top of UT3 R1? Is it possible to obtain the required
50'?
7. Figure 10D: Does Trib A originate in the easement, or continue off site? I think I recall
this being a larger, stable channel. Is this proposed for restoration only for the tie-in?
a. A flow gauge should be placed in the upper 1/3 of UT2.
8. General design questions:
a. What is the purpose of the standard ditch networks being installed? This seems
counterproductive to wetland restoration.
b. Will the access path be within the conservation easement? This should be shown
on Figures 9 and 10. Placing a road in the floodplain seems counterproductive to
the intent of this project.
9. Figures: Please add figures for the following: Lidar, a watershed map that shows the
drainage acres for each reach, and show the location of the reference site on one of the
figures.
10. Page 5, Section 3.3: Additional information on existing vegetation should be provided.
11. UT3: At the IRT site visit we discussed a portion of UT3 only needing one side of the
channel planted and fencing, which would yield a 3.5:1 ratio for those areas already
vegetated on one side. Since you included wetland 2 in the easement, we are more
amenable to the proposed ratios; however, the text should include clear discussion on
whether the entire buffer is being planted, or only one side, and explain why there is no
buffer at the top.
12. UT4: At the IRT site visit you proposed enhancement 11 for about 420 linear feet.
Restoration was not discussed on this reach. Is the entire reach proposed for
restoration on this parcel? It appears to be outside the easement boundary on the JD
map. Lastly, Table 3 does not contain information on this reach; further justification for
restoration on this reach should be provided. I also question whether UT4 and Little
Brushy fork can be tied -in much further upstream in the floodplain. Parallel channels

seem unnecessary now since you are planning to capture the upper end of UT4. It
seems like the channels could be tied in above UT3 in the flood plain. Lidar would be
helpful for this review.
13. Page 9: Please add the NCSAM summary table to this section.
14. Sections 5.0 & 5.6: The functional pyramid is cited to describe the functional uplift
potential of the project, which is fine; however, these principles of the Pyramid
Framework are tied to the goals and objectives of this mitigation plan. Additionally, the
pyramid was designed as a functional assessment for streams, not wetlands. The text
states that it's not practical or feasible to directly measure the physiochemical or
biological uplift, and that these benefits are assumed. It's unclear why NCSAM and
NCWAM were not addressed in this section, nor were their functional assessments
used to target areas for functional uplift. This would be particularly beneficial for the
wetlands on -site.
15. Section 5.3: Did you perform the SQT on this site? This section indicates that the
streams are "not functioning" according to the Simon Channel Evolution Model, which
may be the case, but without completing the SQT, it appears speculative that the
streams will be restored to "functioning." The results from NCSAM/NCWAM should be
used to help demonstrate the specific functional areas where improvements may be
made; however, these tools do not replace the need to conduct more thorough
assessments and measurements of existing conditions.
16. Sections 5.4 & 5.5: It should be stated that while physiochemical and biological uplift
are implied, they will not be directly measured.
17. Section 5.7: The first sentence of this section states that this is an active cattle farm
and crossings will allow access to areas outside the easement. With proposed at -grade
ford crossings, there is little confidence that cattle will not affect the crossing, particularly
with a sand -bed system. The use of culverts in the system is preferable.
18. Page 16, Table 5: the 404/401 have not yet been resolved. Please update table.
19. Page 17: There is a No Effect list in this section for Schweinitz's sunflower; however,
Table 6 lists MA-NLAA. Please confirm which is correct. Additionally, the survey was
conducted in September 2020, which is current for 2 years. If the 404 permit is not
completed by September 2022, another survey, during the appropriate season, will be
required prior to issuing the 404 permit.
20.Table 7: When submitting the ePCN, the impacts for crossings will need to be
separated out from the stream restoration lengths. Will Wetland 2 have temporary
impacts for construction?
21. Section 8.6.3 and 8.8: The updated version of Schafale and Weakley should be used;
the Fourth Approximation, dated March 2012. Please list some of the species found at
the reference site.
22. Page 33, Section 8.6.4: A summary of existing groundwater gauge data for all wetlands
should be provided, as well as included in the appendix. This is especially important to
show room for functional uplift in Section 9.2.
23. Section 8.7.1: A lot of vernal pools appear to be planned. Are these your source of
channel fill material? These areas should be no deeper than 14 inches so that they dry
seasonally, and not be so numerous that they fragment the riparian buffer.
24. Section 8.7.1: I'm glad to see that mostly wood structures are proposed. Although there
is some clay in the banks, this sand bed system is risky to work in, from a stability
standpoint, and rock will likely wash out.
25. Page 36, Table 14: Please elaborate in the narrative on page 37 how you will fill two
drainage ditches while still allowing flow under Norman Shoaf Road. The flow from
under the road should be directed into the newly restored channel.
a. What is the likelihood that the adjacent fields will become too wet with the
increased overbank flow? A contingency for the adjacent landowner constructing

ditches adjacent to the easement should be added to the risks and uncertainties
sections.
26. Page 37, Section 8.8: Soil compaction is a concern, especially in areas of old haul
roads and livestock feeding areas, as these areas can take much longer to recover a
typical wetland soil profile, which increases the temporal lag for functional replacement.
Pasture grass eradication is recommended to alleviate vegetation establishment
competition.
27. Table 16 and Sheet PLT-01 do not match. Tag alder was omitted from Table 16 for the
low stream zone and several inconsistencies occur with the upland zone. Please
update.
28. Section 9.0: Please remove the sentence about termination of monitoring after five
years. Particularly with wetlands, monitoring will be required for 7 years.
29. Section 9.1.4: The bankfull standard applies to all restored stream channels, perennial
and intermittent.
30. Section 9.1.4: The 30-day metric was established to show success in the Coastal Plain
Headwater guidance and was not intended to demonstrate success for intermittent
flow. Intermittent streams only dry seasonally and therefore should have flow or the
presence of water for periods much longer than 30 days. It is recommended that
cameras are also used to monitor flow for both consecutive days and cumulative days, if
flow is questionable.
31. Section 9.3:
a. The vegetative performance standards apply to the entire conservation
easement, not just the first 50-feet from top of bank.
b. The veg height average should be stated as 7 feet at year 5 and 10 feet at year
7.
c. The vigor/height standard will apply to all vegetation on site. Since all the
wetlands are proposed to be planted as bottomland hardwoods, they are
expected to be composed of hardwood species. We welcome the inclusion of
herbaceous and shrub layers as well. Please remove the statement "except for
forested wetlands." Table 14 states that you will supplementally plant the
successional wetland.
d. If you intend for any of the wetlands to be more herbaceous or shrub/scrub,
please propose a separate performance standard for those areas; for example,
composed of at least 4 species with no one species comprising more than 50%
of the total stems.
32. Table 17:
a. The four bankfulls should be in separate years on all restored channels.
b. The final survival rate of 210 stems/ac after 7 years.
33. Section 10.3: We would recommend downloading wetland hydrology data at least
quarterly, as we've experienced many gauge failures and lost data due to lack of
knowledge that the gauges malfunctioned.
34. Section 11.0, Long -Term Management: A signed obligation letter from Southern
Conservation Trust should be included in the appendix, which directly references this
project and the endowment required for long-term management.
35. Table 18:
a. Does Southern Conservation Trust intend to install the fence along the easement
boundary and at crossings? If so, fence expenditures should be included in the
funding amount.
b. Inspection of the integrity of crossings should also be included, as well as
encroachment review and signage replacement.
36. Table 19: This table should be broken down to include specific line -item expenditures
for:

a. Annual Monitoring: including staff time to prepare file review, travel time, on -site
time, post visit report time, staff time needed for minor violations, mileage, meal
costs, travel costs, and inflation. If fence removal or installation are anticipated
activities, these costs should be included, which will significantly increase the
endowment amount. If trash removal is anticipated, a cost should be associated
with that.
b. Accepting and Defending the Easement in Perpetuity:
i. Aside from addressing minor violations, the cost for major violations
should be significantly increased.
ii. Staff time for major violations should be included (approx. 80 hours).
iii. Legal counsel of at least $10,000.
iv. Sign replacement and other incidentals should be added.
v. Stewardship complexities if more than one owner. I would suggest this be
added unless the easement will have a subdivision clause.
37. Section 13.0: What percent of the buffers are less than 50'? Also, the actual mitigation
approach should be listed (e.g., restoration, enhancement, etc.) rather than RE.
38.Table 22, page 48: The acres and ratio are missing/incorrect for Wetland 2
(successional) and wetland 3 (enhancement).
39. Section 14.0: Please reference Appendix I for the financial assurance breakdown.
40.Appendix I: Is the MY-0 report included in the first line item for Monitoring Costs? Does
the maintenance and contingency include supplemental planting and/or repairs?
41.Appendix G: Thank you for including this section. We welcome this inclusion of site -
specific risks and uncertainties in future submittals.
42. Why is the crossing on LBF 85' wide?
43. Please confirm that the stream crossings lengths are not credit generating.
Kim Browning
Mitigation Project Manager
USACE — Wilmington District