20180182 Ver 1_Mitigation Evaluation_20220707

From: Davis, Erin B
To: Baker, Caroline D
Subject: FW: [External] Red Barn Mitigation Bank MY2 Credit Release and Mitigation Plan Modification Approval (SAW-2017-01927)
Date: Thursday, July 7, 2022 4:35:43 PM
Attachments: SAW-2017-01927 RedBarnMitBank Modification -MY2CreditRelease.pdf
Laserfiche Upload: Email & Attachment
DWR#: 20180182 v.I
Doc Type: Mitigation Evaluation
-----Original Message -----
From: Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, July 7, 2022 11:31 AM
To: Cidney Jones <cjones@eprusanet>; Kevin Tweedy <ktweedy@eprusanet>
Cc: Davis, Erin B <erin.davisgncdenr.gov>; Bowers, Todd <[e-mail]>; Leslie, Andrea J
<andrea.leslie(ancwildlife.org>; Wilson, Travis W. <[e-mail]>; Hamstead, Byron A
<byron [e-mail]>; Tugwell, Todd J CIV USARMY CESAW (US) <[e-mail]>; Kim
Browning <[e-mail]>; Haywood, Casey M CIV MVP <Casey.M.Haywoodgausace.armymil>;
Jones, M Scott (Scott) CIV USARMY CESAW (USA) <[e-mail]>
Subject: [External] Red Barn Mitigation Bank MY2 Credit Release and Mitigation Plan Modification Approval (SAW-2017-
01927)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.<mailto:report.spam&nc.gov>
Cidney/Kevin,
Please find attached the MY2 Credit Release and Mitigation Plan Modification Approval letter for the Red Barn Mitigation
Bank (SAW-2017-01927). As requested, credit is being released for approved stream restoration and enhancement activities
that satisfy the MY2 release requirements pursuant to the Mitigation Banking Instrument (UMBI) entitled, "Agreement to
Establish the Red Barn Mitigation Bank in the Yadkin River Basin (HUC 03040101), Surry County, North Carolina", approved
December 18, 2019 and the final Red Barn Mitigation Plan dated November 2019. Also, reference the Red Barn Mitigation
Bank Site MBI Modification, submitted on February 11, 2022, to remove all wetland mitigation.
The attached letter releases 803.2 SMU's, which are equal to 10% of the mitigation site's total stream restoration and
enhancement credits. The MY1 and MY2 Reports, document that most wetland gauges on the Site are not meeting the
hydroperiod performance criteria. In accordance with section 332.8 of the mitigation rule, EPR submitted an MBI modification
to reflect that WMUs will no longer be a part of the Red Barn Mitigation Bank Site. This MBI modification reflects that EPR
proposes to abandon wetland credits, cancel the WMVs already released to USACE, and perform a wetland assessment at
project closeout to ensure that there has been no loss of wetland function as a result of the bank activities. No wetland credits
were released at this time and per the mitigation plan modification request, all bank wetland credit has been removed.
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/ httP7Hcorpsmapu.usace.a1rny.mil/cmapex/f'? p-1367470 7II1-fYmSToolemRh-
Zc1vU yOviDnajmcUj9srIX6kZyVOJBtNhhNSZ34gUf2FfABxegZmWu6Rs 04xSO kshgIUiA1LxV2NnXelyBdmnu7oLydH$
to complete the survey online.

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
July 7, 2022
Regulatory Division
Action ID No. SAW-2017-01927
Re: MY2 credit release and modification approval of the Red Barn Mitigation Bank
Mr. Kevin Tweedy
Ecosystem Planning & Restoration, PLLC
1150 SE Maynard Rd., Ste 140
Cary, NC 27511
Dear Mr. Tweedy
This correspondence is in reference to the Monitoring Year 2 (MY2) Report and request
for credit release, dated February 10, 2022, for the Red Barn Mitigation Bank. Also, reference
the Red Barn Mitigation Bank Site MBI Modification, submitted on February 11, 2022, to
remove all wetland mitigation. The Red Barn Mitigation Bank Site is located off Ester
Drive/Timeless Trail Road, south of NC 80 and approximately 0.5 miles west of Mount Airy in
Surry County, North Carolina. The 25.4-acre site project entails stream restoration and
enhancement generating cool stream mitigation units (SMU's), as well as, wetland rehabilitation
and creation generating riparian wetland mitigation units (WMU's) along tributaries to Stewarts
Creek, in the Upper Yadkin Watershed of the Upper Pee Dee River Basin (03040101).
Pursuant to the Mitigation Banking Instrument (UMBI) entitled, "Agreement to Establish
the Red Barn Mitigation Bank in the Yadkin River Basin (HUC 03040101), Surry County, North
Carolina", approved December 18, 2019; and the site -specific Red Barn Final Mitigation Plan
dated November 2019, ten percent (10%) of the mitigation site's total stream restoration and
enhancement credits shall be available for sale immediately upon completion of the required
tasks.
The MY and MY2 Reports, document that most wetland gauges on the Site are not
meeting the hydroperiod performance criteria. In accordance with section 332.8 of the mitigation
rule, EPR submitted an MBI modification to reflect that WMUs will no longer be a part of the
Red Barn Mitigation Bank Site. This MBI modification reflects that EPR proposes to abandon
wetland credits, cancel the WMU's already released to USACE, and perform a wetland
assessment atprojectcloseoutto ensure thatthere has been no loss of wetland function as a
result of the bank activities. To date, 0.61 WMUs constituting thirty percent (30%) of site's
wetland rehabilitation and creation credits have been released for sale. According to EPR, none

of the site's WMUs have been withdrawn or sold. EPR provided an updated ledger with their
modification proposal showing that the released WMUs have been deducted from the Site's
credits and those previously released had been cancelled. Written concurrence was received from
NCDWR and the USEPA for the proposed modification to remove wetland credit from the
project. WMUs are NOT approved or available from this bank now or in the future.
By copy of this correspondence, we confirm that you have satisfied the above
requirements for the Year 2 cool stream credit release for all parcels within the bank and 803.2
SMU's are now available for sale. To date, 4,016 SMU's, constituting fifty percent (50%) of the
site's total stream restoration and enhancement credits have been released for sale. In accordance
with the approved modification, no wetland credit is currently being released for MY2 or will be
released in the future in association with this project.
IRT comments based on the MY2 report are notedbelow:
Todd Bowers, USEPA:
I have reviewed the MY2 monitoring report for the Red Barn Mitigation Bank dated
January 2022 (incorrect date on cover page) sponsored by EPR. As noted in the report,
during MY2 most wetland gauges on the Site continue to not meet the hydroperiod
performance criteria. Due to poor performance, EPR is proposing to abandon wetland
credits, return the WMU's already released to USACE, and perform a wetland
delineation atprojectcloseoutto ensure thatthe total wetland areafor the Site was not
reduced. An MBI Modification will be submitted to reflect these changes (submitted to
the Corps on 2/10/22). Additionally, in MY2 three small areas (crossings) were released
from the recorded conservation easement.
Overall, I am very pleased with the report and the work that has been completed at the
site as well as efforts towards adaptive management and corrective actions for stream
repairs and invasive species treatments.
• Supplemental planting on April 6, 2021 noted.
• Additional material added to riffle crossing on UT3 c noted.
• I concur with EPRs plan to abandon the wetland credits on this site due to
abysmal performance of wetland hydrology. However, I recommend continued
monitoring in case the situation drastically improves and to verify no -net -loss of
wetland within the CE boundaries.
• Table 2/Page 10: Vegetation height standard is erroneous. For projects located in
the mountain counties, trees in each plot must average 6 feet in height at year five
and 8 feet in height at year seven.
• Vegetation removal from UT2a following USACE guidance was noted. No
comments.
• 30 days or more of consecutive continuous flow in all channels with the exception
of UT1 c was noted. Device failure of SG6 (UT4) also noted. Flow here is not an
issue.
• Now that wetland credit is removed from the project, all vegetation monitoring
should be combined to summarize the riparian zone for stream credit fulfillment.
• EPRs assessment of dominant vegetation species composition >50% was noted as
little concern at this time. I concur with EPRs plan to plant additional stems in

small low -density areas across the site in early 2022 (this should be complete by
now).
• Very little amounts of invasive species across the site with spot treatments
expected was noted. No comments.
• Conservation easement encroachment issues and corrective action noted. No
comments.
• EPA concurs with EPRs plan to not seek wetland mitigation credit at this site.
Recommend keeping the gauges monitored to see better hydrology develops over
the life of the project.
• Supplemental information contained in the appendices (photos, charts, graphs,
data, monitoring notes, IRT site visit minutes) was excellent and greatly
appreciated.
Having not been on -site, I really appreciated the photos in the report. I am disappointed
that wetland hydrology fell far short of the project goals and the ability to generate credit.
I am pleased that EPR will continue to monitor/delineate the pre -project wetlands to
ensure no -net -loss occurs. I recommend the appropriate credit release for cool stream
SMUs for this monitoring milestone and I concur with EPR's plans of corrective actions
and credit adjustments per the Modification Request n and those outlined in the MY2
report.
Erin Davis, NCDWR:
1. DWR has no comments/questions for the provider. We are ok with the proposed
credit release and the requested project modification. We do not need to
participate in a site visit as part of this review.
2. From memory, some of the stream reaches appeared questionable (stream vs.
wetland) during the last site visit. However, all cross sections appear stable and
minimum flow is being met. I'm flagging UT1 C (71 days flow) to watch. I'm also
a bit surprised by the lack for bankfull events on UT2A and UT3A.
Steve Kichefski, USACE:
1. Continue to watch cross-section fluctuations as noted in Section 2.1.1, especially
cross-section 12 on UT3a. Cross-section 18 was not mentioned in this section but
appears to show aggradation and a shift in ER >10%.
2. Stream Gauge 2 in located in the newly constructed reach UTIc and shows flow
trends as intermittent despite upslope having perennial flow. EPR mentions
vegetation cleanout for this reach as needed. It will be of interest to the IRT if this
reach will be able to maintain its channel during the monitoring period and
establishment of woody vegetation to shade herbaceous vegetation will likely be
important to its success.
3. While vegetation plots 1 and 5 did not meet year 3 density targets (or year 7
targets for Plot 1), several other plots (4, 10, 13,14, 15, 17 and 19) do not meet
dominant species composition. Although EPR does not propose corrective action
at this time, the IRT will be monitoring future diversity progress. In the MY2
report, it is noted that, "EPR will selectively plant additional stems in small low-

stem density areas across the site in early 2022 to replace dead trees. This effort is
expected to be minimal and will address the few areas that could benefit from
some larger trees." Were additional plantings done in veg plots this dormant
season, were they larger in size then typical bare root plantings and did they
follow the original site planting plan composition and density? If planting was
done within veg plots, were they documented the way original veg plots were set
up? Remember that supplemental plantings and volunteer plants must be present
for at least two growing seasons before counting toward meeting performance
standards for monitoring year five and seven. Also, any single species stems in
excess of 50% should still be shown on the monitoring table but cannot be used to
demonstrate success.
4. Glad invasive spot treatments will be done in MY3. Make sure to note this in the
MY3 report.
5. Table 5 and Figure 2C mention and/or depict a site encroachment, however this
should be noted in the reportresults in the future. Since the encroachment has
occurred more than once, increased measures to stop the pattern should be taken.
Please provide more information as to the encroachment and the corrective
actions taken in MY3 report.
Thank you for your time and cooperation. If you have any questions, please contact
Steve Kichefski at [phone] extension 4234.
Sincerely,
for Scott Jones, Chief
Asheville and Charlotte Regulatory Field Offices
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)