20190049 Ver 1_Notice of Initial Credit Release/ NCDMS Carpenter Bottom Mitigation Site/ SAW-2018-02062/ Gaston County_20220726

Hamilton, Ryan
From:Davis, Erin B
Sent:Wednesday, September 7, 2022 12:27 PM
To:Hamilton, Ryan
Subject:FW: \[External\] RE: Notice of Initial Credit Release/ NCDMS Carpenter Bottom
Mitigation Site/ SAW-2018-02062/ Gaston County
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DWR#: 20190049 v.1
Doc Date: 7/26/22
Doc Type: Mitigation Information
Doc Name: Same as email subject

From: Eric Neuhaus <[e-mail]>
Sent: Tuesday, July 26, 2022 2:19 PM
To: Kim Browning <[e-mail]>; Wiesner, Paul <[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CESAW (US) <[e-mail]>; Davis, Erin B <[e-mail]>;
Bowers, Todd <[e-mail]>; Youngman, Holland J <[e-mail]>; Merritt, Katie
<[e-mail]>; Wilson, Travis W. <[e-mail]>; Munzer, Olivia
<[e-mail]>; Reid, Matthew <[e-mail]>; Shawn Wilkerson
<[e-mail]>; Fennel, Tommy E CIV USARMY CESAW (USA) <[e-mail]>;
Crumbley, Tyler A CIV USARMY CESAW (USA) <[e-mail]>; Stanfill, Jim
<[e-mail]>; Harmon, Beth <[e-mail]>; Allen, Melonie <[e-mail]>;
Kristi Suggs <[e-mail]>; Jeff Turner <[e-mail]>
Subject: \[External\] RE: Notice of Initial Credit Release/ NCDMS Carpenter Bottom Mitigation Site/ SAW-2018-02062/
Gaston County

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Kim/Paul,

Please see WEI’s responses in blue to the As-Built/MY0 review comments of the Carpenter Bottom Mitigation Site (SAW-
2018-02062). Comments and the below responses will be included with the MY1 submittal within the Appendices. If
there are questions, please advise.

Thanks,
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Eric Neuhaus, PE | Water Resources Engineer
O: 828.774.5547 x105 M: 865.207.8835

Note: IRT is not requesting a site visit at this time, but has requested to schedule a site visit late MY2.

USACE Comments, Kim Isenhour:
1. How deep are the floodplain pools where the relic channel meander features were located? On recent site visits,
we’ve noted several instances of floodplain pools being left as open water in areas where the mitigation plans
1


calls for planted buffers. The majority of these pools have been deep enough that they will not dry seasonally
and allow for herbaceous or woody vegetation establishment.
At the location of the relic channel meander features, the floodplain pool is around 1.5’ deep. The
floodplain pools were designed with a max depth of 2.0’ and were intended to draw down seasonally.
Vegetation growth will be monitored in floodplain pools and reported on in the MY1 report.
2. In future monitoring years, please capture some of the wetland rehabilitation areas with mobile veg plots.
Mobile veg plots will be positioned to capture wetland rehabilitation areas starting in MY2 as mobile
vegetation plots are typically stationary between MY1 and MY2.
3. Thank you for including the soil profile descriptions at each groundwater gauge. It would have been helpful to
include a table with the pre-construction gauge data.
A summary table of pre-construction gage data will be included in future monitoring reports.
4. Pebble counts were included in the data. Do you plan to keep this as a performance standard through
monitoring?
Pebble counts were included in the MY0 report because they were documented in the mitigation plan.
However, pebble counts will not be collected for the MY1-MY7 reports. This is documented in Section
3.3 (Stream Assessment) of the MY0 report.
5. Photo Point 12, outside the easement, appears to be a source of offsite sediment/nutrients.
Sediment in photo point 12 is from recent fencing work at the Site. Upstream of UT4 is wooded and
stable.
NCDWR Comments, Erin Davis:
1. DWR would like to reiterate DMS’ comments/questions on the high riffles and gauge bentonite seals. WEI’s responses
were fine, but please closely observe these areas during MY1 and address as needed.
These items/concerns will be noted in future monitoring reports.
2. What are the max. depths of the floodplain pools? (may include response in MY1 report)
The floodplain pools were designed with a max depth of 2.0’ and were intended to draw down seasonally.
Vegetation growth will be monitored in floodplain pools and reported on in the MY1 report.
3. DWR appreciated that invasives were inventoried and treated pre-construction. And we were glad to see woody
debris was added to the floodplain pools.
DWR is ok with the proposed credit release. No site visit requested.

USEPA Comments, Todd Bowers:
*All 13 vegetation plots met the interim success criteria and are on track to meet the final success criteria required for
MY7, and no species dominance per plot was greater than 50%.
*Morphological surveys conducted throughout the Site show all streams as stable and functioning as designed.
*Eleven groundwater wells were established at baseline conditions to monitor wetland hydrology within both wetland
re-establishment and rehabilitation areas. Wetland hydrologic data will be collected and reported during MY1.
*No adaptive management plan needed at this time.
*No issues of conservation easement encroachment.
*Table 2a: I recommend adding a visual confirmation that the objective of excluding livestock from the conservation
easement is being met. Visual confirmation can include no sign of hoof shear or cattle excrement within the project
boundaries. Trampled streams and vegetation, broken fence, destroyed banks from hooves and excrement would be
positive indications of that objective not meeting standards.
A visual confirmation of cattle exclusion will be added to Table 2A in the MY1 report.
*Overall, I am very satisfied with the report and the work that Wildlands has completed at the site. Having not been
able to visit this location, I really appreciated the detailed ground-level stream and veg plot photos to illustrate the
amount of work implemented. I recommend the appropriate credit release (Milestone 2) for warm stream and riparian
wetland mitigation units for this monitoring milestone. I have no other substantial comments at this time.

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From: Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, July 7, 2022 4:07 PM
To: Wiesner, Paul <[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CESAW (USA) <[e-mail]>; Davis, Erin B
<[e-mail]>; Bowers, Todd <[e-mail]>; Youngman, Holland J
<[e-mail]>; Merritt, Katie <[e-mail]>; Wilson, Travis W.
<[e-mail]>; [e-mail]; Reid, Matthew <[e-mail]>; Eric
Neuhaus <[e-mail]>; Shawn Wilkerson <[e-mail]>; Fennel, Tommy E CIV
USARMY CESAW (USA) <[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW (USA)
<[e-mail]>; [e-mail]; [e-mail]; Allen, Melonie
<[e-mail]>
Subject: Notice of Initial Credit Release/ NCDMS Carpenter Bottom Mitigation Site/ SAW-2018-02062/ Gaston County

Good afternoon Paul,

The 15-Day As-Built/MY0 review for the Carpenter Bottom Mitigation Site (SAW-2018-02062) ended June 29, 2022. This
review was done in accordance with Section 332.8(o)(9) of the 2008 Mitigation Rule. All comments received from the
NCIRT are incorporated in the email below. Please address IRT concerns in the MY1 Report. There were no objections to
issuing the initial (30% ) credit release of 920.349 warm SMUs and 2.503 Riparian WMUs. Please find attached the
current signed ledger. The IRT is not requesting a site visit at this time, but would like to put it on the list for late in MY2.

USACE Comments, Kim Isenhour:
1. How deep are the floodplain pools where the relic channel meander features were located? On recent site visits,
we’ve noted several instances of floodplain pools being left as open water in areas where the mitigation plans
calls for planted buffers. The majority of these pools have been deep enough that they will not dry seasonally
and allow for herbaceous or woody vegetation establishment.
2. In future monitoring years, please capture some of the wetland rehabilitation areas with mobile veg plots.
3. Thank you for including the soil profile descriptions at each groundwater gauge. It would have been helpful to
include a table with the pre-construction gauge data.
4. Pebble counts were included in the data. Do you plan to keep this as a performance standard through
monitoring?
5. Photo Point 12, outside the easement, appears to be a source of offsite sediment/nutrients.

NCDWR Comments, Erin Davis:
1. DWR would like to reiterate DMS’ comments/questions on the high riffles and gauge bentonite seals. WEI’s
responses were fine, but please closely observe these areas during MY1 and address as needed.
2. What are the max. depths of the floodplain pools? (may include response in MY1 report)
3. DWR appreciated that invasives were inventoried and treated pre-construction. And we were glad to see woody
debris was added to the floodplain pools.
DWR is ok with the proposed credit release. No site visit requested.

USEPA Comments, Todd Bowers:
* All 13 vegetation plots met the interim success criteria and are on track to meet the final
* success criteria required for MY7, and no species dominance per plot was greater than 50%.
* Morphological surveys conducted throughout the Site show all streams as stable and functioning as designed.
* Eleven groundwater wells were established at baseline conditions to monitor wetland hydrology within both
wetland re-establishment and rehabilitation areas. Wetland hydrologic data will be collected and reported during MY1.
* No adaptive management plan needed at this time.
* No issues of conservation easement encroachment.
* Table 2a: I recommend adding a visual confirmation that the objective of excluding livestock from the
conservation easement is being met. Visual confirmation can include no sign of hoof shear or cattle excrement within
3

the project boundaries. Trampled streams and vegetation, broken fence, destroyed banks from hooves and excrement
would be positive indications of that objective not meeting standards.
* Overall, I am very satisfied with the report and the work that Wildlands has completed at the site. Having not
been able to visit this location, I really appreciated the detailed ground-level stream and veg plot photos to illustrate the
amount of work implemented. I recommend the appropriate credit release (Milestone 2) for warm stream and riparian
wetland mitigation units for this monitoring milestone. I have no other substantial comments at this time.

Please let me know if you have any questions.
Respectfully,
Kim

Kim (Browning) Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers l 919.946.5107

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