20210536 Ver 1_Notice of REVISED Draft Mitigation Plan Review_20221031

Strickland, Bev
From: Davis, Erin B
Sent: Monday, November 7, 2022 4:21 PM
To: Baker, Caroline D
Subject: FW: [External] Notice of REVISED Draft Mitigation Plan Review/ RES Cape Fear 02 UMB
- Tobacco Road Mitigation Site/ SAW-2021-00489/ Orange County
Attachments: Revision Cover Letter_TobaccoRoad_SAW-2021-00489.pdf; RES Response to
Comments_TobaccoRoad_SAW-2021-00489_RevisedDraftPlan.pdf
Laserfiche Upload: Email & Attachments
DWR#: 20210536 v.1
Doc Date: 10/31/22
Doc Type: Mitigation — Mitigation Information
Doc Name: General topic of email title
From: Isenhour, Kimberly T CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, October 31, 2022 3:40 PM
To: Tugwell, Todd J CIV USARMY CESAW (US)<[e-mail]>; Haywood, Casey M CIV USARMY
CEMVP (USA) <[e-mail]>; Davis, Erin B <[e-mail]>; Wilson, Travis W.
<[e-mail]>; Bowers, Todd <[e-mail]>; [e-mail]; Munzer, Olivia
<[e-mail]>
Cc: Benton Carroll <[e-mail]>; Jamey McEachran <[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW
(USA) <[e-mail]>
Subject: [External] Notice of REVISED Draft Mitigation Plan Review/ RES Cape Fear 02 UMB - Tobacco Road Mitigation
Site/ SAW-2021-00489/ Orange County
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Hello IRT,
On October 31, 2022, Environmental Banc & Exchange, LLC, provided a REVISED draft mitigation plan for the RES Cape
Fear 02 Umbrella Mitigation Bank, and Tobacco Road Mitigation Site (SAW-2021-00489), located in Orange County. The
revised draft mitigation plan request is based on key missing information such as a section on wetland success criteria
and preliminary crossing design details, as well as the introduction of a new design and crediting approach not discussed
during the prospectus stage. The attached cover letter outlines the revisions that were made, and I've also attached the
response to IRT comments for your convenience.
With this email, we are initiating the NCIRT review of these documents as outlined in Section 332.8(d)(6) of the
Mitigation Rule. If you would like to receive a hard copy, please let me know and one will be provided to you. Please
reach out if you have any questions.
30-Day IRT Review Start: November 7, 2022
30-Day Comment Deadline: December 7, 2022
90-Day DE Deadline: February 5, 2023
1

The REVISED draft mitigation plan can be found on the RIBITs website at the following
link: https://ribits.ops.usace.army.mil/ords/f?p=107:10:5404304503427::::P10 BANK ID:6178
Please note that you must be logged in to access documents in the cyber repository. If you have any trouble accessing
the link please let me know.
RES Contact: Ben Carroll
Direct: 919.209.1077 Mobile: [phone]
*I will be the bank manager for this site moving forward, so please send comments/concerns to me.
Thanks,
Kim
Kim Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers I 919.946.5107
2

fires
October 31, 2022
Samantha Dailey
U.S. Army Corps of Engineers
Regulatory Division
3331 Heritage Trade Dr., Suite 105
Wake Forest, NC 27587
3600 Glenwood Ave., Suite 100
Raleigh, NC 27612
Corporate Headquarters
6575 West Loop South, Suite 300
Bellaire, TX 77401
Main: 713.520.5400
Subject: Cape Fear 02 Instrument Modification Tobacco Road Revised Draft Mitigation Plan Submittal
(SAW-2021-00489)
Dear Ms. Dailey,
On behalf of Resource Environmental Solutions (RES) & Environmental Banc & Exchange, LLC (a RES affiliate), I
am pleased to submit the Revised Draft Mitigation Plan for the Tobacco Road Site, an Instrument Modification for
the RES Cape Fear 02 Umbrella Mitigation Bank. An Instrument Modification was submitted in March 2021, put on
public notice on June 25,2021, and issued an initial evaluation letter on August 17, 2021. A draft Mitigation Plan was
submitted on June 3, 2022; and comments were received on August 17, 2022.
The attached plan addresses the draft mitigation plan comments provided by the IRT and includes minor modifications
to the easement and alignments. The alterations and updates are summarized below and detailed in the Mitigation
Plan:
• The revised draft mitigation plan presents 8,311.010 SMUs (8,305.740 SMUs in the draft mitigation plan),
through stream restoration, enhancement, and preservation. This increase in SMUs was driven by minor
tweaks in alignment and stationing.
• The revised draft mitigation plan presents 2.096 WMUs (2.771 WMUs in the draft mitigation plan). This
decrease in WMUs is primarily driven by the exclusion of created wetland Cl, which was removed due to
an inconsistency in deed language that required RES to adjust the easement to avoid any potential issues in
the future.
• Additional information about Layered Riffles has been provided in Appendix C
• The Draft Riparian Buffer and Nutrient Offset Mitigation Plan was submitted as part of the appendices of the
Draft Stream and Wetland Mitigation Plan; comments were received from NCDWR on October 12, 2022.
These will be addressed and submitted as Appendix A in the Final Stream and Wetland Mitigation Plan. It is
not included as part of the appendices in the Revised Draft Steam and Wetland Mitigation Plan.
Thank you for your time and consideration for this Project and we look forward to our continued work together as this
Project progresses. Please contact me at 336-514-0927 or [e-mail] if you have any questions or require any
additional information.
Sincerely,
Ben Carroll, P.E.
Engineer / Project Manager
res.us

MEMORANDUM
res
3600 Glenwood Avenue, Suite 100 Raleigh, North Carolina 27612 919.770.5573 tel. [phone] fax
TO: Kim Browning — IRT
FROM: Benton Carroll — RES
DATE: October 31, 2022
RE: Response to Draft Mitigation Plan Comments — RES Cape Fear 02 Umbrella
Mitigation Bank, Tobacco Road Mitigation Project, (SAW-2021-00489), Cape Fear
03030002; Alamance County, NC
Please note in addition to your comments, wetland creation area "C1" was removed from this
submittal and the adjacent easement was revised due to an inconsistency RES discovered in the
Greeson Deed language. RES adjusted the easement in this location to avoid any potential issues
at easement closing.
NCDWR Comments, Erin Davis:
1. Page 9, Section 3.3 — Please confirm you have consulted with NCDOT and local government
planning web resources or contacted agency staff regarding potential future projects in the
project vicinity (e.g., DOT highway road widening or culvert maintenance/replacement,
Dominion Energy gas line maintenance/expansion, Alamance County and/or local municipal
comprehensive land use or community master plans, etc.). DWR appreciates that future land
use was a consideration in sizing proposed crossings.
No projects in the Project vicinity are shown on the NCDOT 2020-2029 State Transportation
Improvement Plan Projects Map, and RES met onsite with gas company representatives to
make sure future encroachment is prevented to the extent practical. The most recent land use
plan for the Project area, the Alamance County 2020 Land Development Plan, projects that the
Project and its drainage area will remain in agriculture and rural residential. Additional
language has been added to this section describing the above.
2. Page, 10, Section 3.4 — Has any evidence of beaver been observed onsite?
During baseline data collection and subsequent site visits, evidence of beaver has not been
observed. If beaver activity is observed during site preparation or the monitoring period,
appropriate management activities will be initiated. All beaver management activities will be
documented and included in annual monitoring reports.
3. Page 11, Table 6 — It would be helpful to have columns included for reach drainage areas and
NCSAM scores.

Columns for drainage areas, in acres, and NCSAM ratings have been included in Table 6.
4. Page 11, Section 3.4.1 — Please note if the project captures any of the stream origins. Based
on Sheets E2 & E3, it appears that the project captures the origins of MN4-A, MN5-A, MN6-
A, MN9, and TR2.
The project captures the origins of MN2-A, MN5-A, MN6-A, MN7, and MN9. Language has
been added to those reach descriptions to indicate as such.
5. Page 11, Section 3.4.1, Reach TR1-A — How is the impoundment connected to the project
stream? If by an outlet, does the outlet structure appear stable and maintained?
The pond upstream of the Project outlets into TR1-A through two 24" CMPs. The CMPs were
found to be in good condition.
6. Page 19, Section 3.5.1 — Given the significant number of proposed crossings and easement
breaks, please include a table summarizing pertinent information (e.g., location/reach,
need/justification, easement break width, external vs. internal break, crossing type). Please
explain why the TR1-C reach landowner access easement break cannot be collocated within
the utility easement break. Please explain why the MN4 reach easement break and crossing
cannot be shifted upstream beyond the project boundary. If the TR1-C and MN4 crossings
cannot be eliminated, can they become internal easement crossings?
A table has been made outlining the details of each crossing, Table 8. RES worked with the
landowner to minimize the number and impact of the proposed crossings. Unfortunately, the
landowner was adamant that all crossings be located as shown.
7. Page 19, Section 3.5.3 — DWR appreciates the discussion of the monarch butterfly and the
inclusion of swamp milkweed in the proposed permanent seed mix.
Thank you.
8. Page 26, Section 6.1 — Please map the locations of the selected reference streams. One of the
two reference reaches is a sand bed system, does that change how the reference data is
applied? Also, both reference reaches have larger drainage areas than many of the project
tributaries and identified as Rosgen Class E stream types whereas project reaches are
proposed as Class C. How does this affect the way the reference data is applied?
The locations of the reference reaches have been included as Figure 11. Having reference
reaches with larger DAs is not a problem if scaling factors are employed to translate to the
design reaches. Typically, E-type streams maintain their stability through established riparian
vegetation and would be less stable immediately post -construction. C-type reaches, which,
with their higher width -to -depth ratios and lower sinuosity, have a lower risk of developing
bed and bank issues in the transition period between construction and vegetative -community
maturity. As bank vegetation matures and bank roughness increases C-type channels may
move toward E-type channels. RES used the sand bed stream to provide an additional
reference to help bracket the lower end of appropriate channel dimensions to ensure our
design falls in the appropriate range.

9. Page 27, Section 6.2 - Log sills are the only listed grade control structure for intermittent
reaches MN3, MN4, MN7, and MN8. DWR has observed log sills on intermittent reaches,
particularly in the slate belt region, breaking down before the end of the monitoring period.
Are there any concerns with long-term stream stability?
Rock structures have been added to these reaches to provide long-term grade control.
10. Page 29, Section 6.2, MN2-A — Please add livestock exclusion to the list.
Livestock exclusion has been added to the list of mitigation activities.
11.
Page 34, Section 6.2.3 —
a. The narrative discusses ditches and seeps plural; however, Figure 7 only shows one
ditch and one seep within the project area, please confirm. Also, please callout
"plugging surrounding drainage features" on corresponding design sheets.
Figure 7 shows two seeps and one ditch, which are not adjacent to existing or
proposed wetlands and which will not be plugged as part of the Project. The verbiage
"plugging surrounding ditches and seeps" in paragraph two has been revised to
"plugging surrounding drainage features." The features in question are primarily the
old stream channels which are being plugged as part of the stream restoration
activities; however, there is also one floodplain ditch which is being plugged in the
wetland creation area C3, as shown on sheet S10.
b. What are the max. depths for proposed shallow depression and pools? Will these
features be designed to dry seasonally?
The max. depths will be 14", as shown in the Channel Fill detail on Sheet D2, and some
of these depressions will be connected back to the proposed channel to assist in
seasonal drying.
c. Wetland rehabilitation requires the function uplift of multiple characteristic (e.g.,
hydrology and vegetation). However, based on Sheets W2 and P2, wetland credit areas
WO, WQ and WR are not proposed to be planted (even supplementally). Therefore,
DWR supports hydrologic enhancement at 2:1 as a more appropriate ratio for these
wetland credit areas.
Thank you for your comment. Based on the proposed design approach, wetland areas
WO, WQ, and WR, which currently have high quality riparian areas and will not undergo
any planting, have been revised to enhancement at a ratio of 2:1. These areas may
undergo invasive species treatment as necessary throughout the life of the project.
d. DWR encourages the placement of woody debris as habitat enhancement in project
wetland and floodplain areas.
RES will keep this in mind during the construction of the project.
12. Page 36, Section 6.2.4.1 — In the prospectus there was a 254-foot section of Reach TR1-C
proposed as "uncredited", likely due to fragmentation by two easement breaks. This change
was not mentioned in this section. If both external easement breaks are proposed to remain,
DWR does not support the change in crediting for this fragmented reach section. Additionally,

DWR cannot support the requested TR1-C and TR1-D credit change without reviewing
additional information on the proposed Layered Riffle treatment. Please see DWR comment
#49.
The portion of TR1-C in question was proposed as uncredited in the prospectus due to a lack
of minimum buffer along that portion, not because of the easement breaks:
"Stream mitigation along Reach TR1-C will involve 1,125 linear feet of Enhancement II;
however, only 871 linear feet of the total reach will be creditable due to a lack of
minimum riparian buffer (less than 50 feet out from the left top of bank to the
easement boundary)."
The current easement shape and surveyed TOB allow for more than 50' buffers through this
section, which, along with the uplift projected from the new Enhancement I approach,
informed the change in crediting. The paragraph has been updated to clarify.
13. Page 38 Section 6.3 and Page 41 Section 6.4 — Two natural community types were identified
as references and combined into one of two planting zones. What is the vegetative reference
for the second planting zone?
The second planting zone, referencing aspects of a Piedmont Bottomland/Swamp Forest
(Schafale, 2012), was created based on a few reasons; one reason being the species currently
present throughout the site including, but not limited to, white oak, red maple, sweet gum,
green ash, ironwood, winged elm, etc. The Chewacla soils evident throughout the site, typical
of a Piedmont Bottomland Forest, were also referenced when choosing the second planting
zone. Finally, second planting zone was based on industry experience with species that have
previously done well among other project sites with similar floodplain and wetland
characteristics in the Piedmont region. The species chosen do not directly follow any one
specified natural community, but rather take into account a combination of factors. The
species on this list all indicate that they are either facultative wetland or obligate wetland
species in the Piedmont region. That being said, a few additional species, more characteristic
of Piedmont Alluvial and Piedmont Bottomland Forests, have been included to both planting
zones; composition percentages of species that aren't directly referenced in the listed natural
community types have been adjusted.
14. Page 39, Table 12 — Black willow is listed in planting zone 2 as a canopy tree to be installed as
live stakes. Are you proposing to count live stake stems in your vegetation performance
standard monitoring? Also, was another wetland understory species considered to enhance
diversity (e.g., buttonbush, spicebush, serviceberry, elderberry)?
Yes, planted black willow livestakes that are proposed in Zone 2 planting areas only (excluding
those livestaked along the stream banks) will be counted in the vegetative performance
standard monitoring. The composition percentage of black willow livestakes has been lowered
from 10% to 5%, and additional understory wetland species, including northern spicebush
(Lindera benzoin), possumhaw (Ilex decidua), buttonbush (Cephalanthus occidentalis), and
elderberry (Sambucus canadensis) livestakes, have been included to enhance diversity.

15. Page 40, Section 6.3.2 —
a. Will fescue be treated prior to or during construction?
Yes, fescue and other nuisance pasture grasses will be treated prior to construction
completion. This has been added to Section 6.3.2.
b. Murdannia keisak was identified in the existing wetlands. This species has caused
significant issues in wetland credit areas on other mitigation projects. What is your
treatment approach?
Murdannia keisak was observed in one small area of existing Wetland C. Because it
was observed in such a small population, this area will be targeted and treated with a
selective, wetland -safe herbicide, e.g. triclopyr plus a non-ionic surfactant. Monitoring
for this species will continue throughout the life of the project and treated as necessary.
c. Please confirm that the initial invasive species treatment will occur during the
construction phase for the entire easement area.
The sentence, "Initial treatment for invasive species will occur during the construction
phase of the Project throughout the entire easement area," has been added to the
beginning of Section 6.3.2.
16. Page 40, Section 6.3.3 — Will existing site topsoil be stockpiled for reuse? DWR is particularly
concerned with treatment of poor soils in Priority 2 cut areas, steep slopes, and floodplain to
upland transition slopes.
RES will stockpile topsoil where feasible and will apply soil amendments as needed to ensure
tree success.
17. Page 41, Section 6.5 — Should there be a subsection discussion and/or table for proposed
wetland credits?
A wetland crediting table has been added to Section 6.5 below the stream crediting table.
18. Page 43, Section 7 — Please provide a Wetland Success Criteria subsection, including the
minimum proposed hydroperiod and determination of growing season.
A Wetland Success Criteria subsection has been added as Section 7.2 and can also be found
in the Wetland Mitigation Approach, Section 6.2.3.
19. Page 43, Section 7.1.2 — Based on the slate belt location and very small drainage areas, DWR
is concerned with flow on multiple tributaries. 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.
RES understands the flow requirements and will monitor flow on all intermittent streams
generating restoration and enhancement credits through the monitoring period, as discussed
in Section 8.3.
20. Page 45, Section 8.5 —
a. Please identify the proposed growing season start and end dates and source/method
of determination.

According to an NRCS WETS table, recording data from a station at the Burlington-
Alamance Regional Airport, the growing season extends from March 21 to November
8 and is based on a daily minimum temperature greater than 28 degrees Fahrenheit
occurring in five of ten years. This text has been added to Section 8.5.
b. Please identify if a rain gauge will be installed onsite. If not, please explain why and list
source location(s) for rainfall data, including distance from project site.
A rain gauge will not be installed on -site due to the proximity of a National Weather
Service Cooperative Observer Data Station situated along the Cane Creek reservoir
(station ID 311429) in Saxapahaw, NC, approximately four miles southeast of the
Project. The data is provided by the North Carolina State Climate Office, through the
Station Scout application. This text has been added to Section 8.5.
c. DWR requests soil data be collected during MY7 near the eight wetland creation
gauges for comparison to soil data collected at MYO (as required by the 2016 NCIRT
Guidance) to check for development of hydric soil characteristics.
The request for soil data during MY7 has been added to Section 8.5. This will include
borings, horizon information, and wetland gauge/water measurements.
d. As noted in Section 10.1, re -delineation of wetland credit areas may be required if
areas are not meeting the minimum hydroperiod and/or clearly exhibiting wetland
habitat indicators.
Thank you for this comment; we understand the importance of this measure if wetland
indicators are not otherwise being exhibited.
21. Page 45, Section 8.7 — The baseline monitoring report should also include verification of the
installation of conservation easement boundary markers/signage.
Verification of conservation easement installation has been included in Section 8.7
22. Page 47, Table 16 — There is no mention of wetland monitoring metrics or performance
standards. Understanding that the stream functions pyramid framework is the presenting
format, please integrate wetland information into this monitoring requirements table if
wetland credit is proposed.
Wetland performance and monitoring criteria have been added to Sections 7 and 8, as well as
the Monitoring Requirements Table (now Table 17).
23. Page 50, Table 17 — The stream component description ends with an "and", is there more
information to be included?
No; this typo has been corrected.
24. Page 51, Section 10.1 — Were encroachment risks evaluated based on current land use and
property owner(s)? How would future development surrounding the site potentially affect the
project? What are the risks associated with the proximity to a DOT highway and utility gas
transmission line? If the large Dutchy Airpark impoundment upstream breaches, what is the
risk to the project?

RES worked closely with the landowners to ensure that the appropriate accommodations
(fencing, wells, waterers, crossings, etc) are provided to prevent future encroachment issues.
We reviewed the NCDOT STIP and met onsite with gas company representatives to make sure
future encroachment is prevented to the extent practical. Future development is always a risk
but with appropriate floodplain connections and vegetative success this risk can be
significantly reduced. RES has designed this project to promote long-term success. The flood
wave from a failure of the Dutchy Airpark Dam would encounter HWY 54 before reaching
much of our site. This would drastically reduce the impact of a breach on the majority of our
project. TC1-A would likely see some impact, but it is also generating credit at a 7.5:1 ratio so
the number of credits impacted would be limited.
25. Page 53, Section 12.1 — Please add a bullet for "documentation of the establishment of the
long-term endowment/escrow account".
This bullet point has been added to the list.
26. Page 55, Section 13 — Please correct the total endowment funding amount to match the UP2S
spreadsheet in Appendix B, $41,840. There are no five percent returns.
The number in Section 13 has been updated to $41,840.
27. Figures —
a. Please add a figure showing all assets proposed for the site, including stream, wetland,
buffer and nutrient offset.
A series of asset maps have been added to the figure set as Figure 16.
b. A color LiDAR map would be helpful for this review.
A LiDAR map has been added to the figure set as Figure 7a.
28. Figures 5 — The Project Parcels do not appear to perfectly align with the Adjacent Parcels. Are
these features from different data sources or do they reflect proposed changes to existing
parcel boundaries?
The original parcel boundaries were derived from tax parcel data sourced from the Alamance
County interactive GIS database, which was likely out of data or had projection errors, causing
misalignment when placed over adjacent parcel data. A partial boundary survey was
completed, and the figure has been updated to show aligned parcel boundaries for both
project and adjacent parcels.
29. Figure 13 —
a. This is a very busy figure. Given the scale and size of proposed wetland credit areas,
please consider presenting with multiple figures.
Thank you for the suggestion, the map figure is now presented as multiple figures.
b. Please show the stage recorder along TR1-B as specified in Section 8.3.
The stage recorder along TR1-B was covered up by cross section symbology. Now
that the map figure is presented in multiple figures, it will be more visible.

c. Please add a wetland gauge to rehab area WK. And please see requested gauge
location shifts within WQ and C3 on attached figure mark-up.
The wetland gauges have been edited/added accordingly.
d. Please dedicate one random veg plot to shift between planted wetland rehab credit
areas throughout monitoring.
A sentence has been added to Section 8.6 Vegetation Monitoring, detailing that one
of the five random plots will shift between planted wetland rehabilitation crediting
areas throughout the monitoring life of the Project.
30. Appendix B — Please note that the federal mileage rate is not 0.625. Also, have you adjusted
for inflation?
The Endowment Calculator was completed before the federal milage rate was adjusted. RES
reached out to UP2S and they confirmed that the original calculated total is sufficient to
protect the project. Per UP2S, inflation is not accounted for in the calculator but is anticipated
to be offset by the investment of the endowment.
31. Sheet S1 —
a. Does the easement station number called out on the profile correspond to the start of
project reach credit? Is this the case on all plan sheets?
The station number called out on the profile on sheet S1 is meant to be the start of
project reach credit but contained a typo, which has been corrected to 0+44. This is
now the case on all plan sheets; MN1-A and MN3 were also updated to start credit
stationing at the easement.
b. There appears to be an access path/road within the proposed easement, please call
out if this path/road will be removed.
This path will be removed, and a callout has been added to the sheet.
32. Sheet S3 — Please callout the DOT road easement/ROW.
The road label on sheet S3 has been updated to "NC HWY 54, (120' NCDOT ROW)". The line
type for the ROW has been updated to differentiate it from other property lines.
33. Sheet S4 — Please include a typical detail for the proposed stormwater swale feature (including
swale dimensions with max. depth, matting, seeding/planting). Will stone be used in any form
(e.g., outlet protection)? Are there any stability concerns with directing concentrated flow over
the abandoned channel plug?
A typical detail has been added to sheet D6. The goal for the swale is to direct water from the
old channel path into the new channel to prevent preferential flow of either surface or
groundwater through the old path. As such, it has a small drainage area and won't receive
much flow, so stone will not be necessary for long-term stability, and stability of the channel
plug is not a concern.
34. Sheet S5 — Are there any concerns that the proposed stormwater swales within the abandoned
channel may inadvertently create preferential flow paths back within the abandoned channel

in the future? Are there any concerns that connecting a stormwater swale just upstream of a
log sill may erode the bank anchoring the structure?
As stated in the previous response, the goal of the swales is to redirect flow from the old
channel path into the new channel to prevent the formation of a longer flow path within the
abandoned channel. The swale tie-in has been moved upstream to avoid potential stability
issues with the log sill.
35. Sheet S6 — Please callout the utility easement/ROW on all applicable sheets.
Callouts have been added to all applicable sheets to call out the gas easement and its width.
Further, the gas -easement linetype has been updated to differentiate it from other property
lines.
36. Sheet S10 —
a. Please provide a callout description for the isolated plug in the floodplain.
The indicated plug is interrupting a ditch which runs parallel to TR1-D along the
southern floodplain toe of slope. A callout has been added to clarify.
b. Is the jurisdictional feature where the stormwater swale is proposed expected to
remain jurisdictional post -construction (i.e., not backfilled or plugged)? If so, please
confirm with USACE that BMPs are allowed within jurisdictional features.
The swale on sheet S10 is not within a jurisdictional feature and is not proposed to be
maintained as a BMP.
37. Sheet S14 — Please include a typical detail for the proposed engineered sediment pack.
The ESP is no longer proposed.
38. Sheet S16 — Does any concentrated flow from the pond just east of the project enter the
easement?
The outflow from the pond in question dissipates into wetland WB before entering the Project
easement.
39. Sheet 19 — Sediment and erosion control measures to stabilize the steep slope while
groundcover establishes will be critical along the proposed cascade, as well as other floodplain
to upland transition slopes. Based on past project review observations, these slopes are
susceptible to become veg problem areas.
RES will use appropriate measures to stabilize these slopes.
40. Sheet 23 - There appears to be an access path/road within the proposed easement, please call
out if this path/road will be removed.
A callout has been added defining the removal work for the existing path.
41. Sheet 26 — Please callout Reach MN5-A.
A callout has been added.

42. Sheet S29 — The proposed realignment of MN6-B extends the reach length by 150 feet and
parallels Reach TR1-D. Please provide a justification for the extension and explain why an
earlier tie-in is not appropriate.
The proposed alignment of MN6-B follows the low point in the valley prior to its tie in, and
tying into proposed channel on TR1-D will be more stable than tying into the existing,
oversized channel upstream.
43. Sheet S32 — Please add the easement line and station number callout to the profile.
The easement -limits line and station callout have been added to the profile.
44. Sheets W1-W3 — If not included on the stream plan sheets, please show proposed grading
within wetland credit areas, noting any areas to be excavated greater than 12 inches.
No grading is proposed in Project wetlands that is not shown on the stream plan sheets.
45. Sheet P1 — Please confirm that planting notes are consistent with plan narrative. Also, please
identify the proposed temporary seed species.
Note #6 has been updated to reference the correct detail sheet (D4). Note #13 has been
updated to call for permanent seed in all proposed planting areas in addition to any disturbed
areas within the easement. Further, bare root and live stake species have been updated as
noted in other comments.
Temporary seed species are chosen from the NCDEQ handbook and typically include rye,
winter wheat, and German millet, depending on the season. RES is proposing an alternate
species list for this Project, based on the NCWRC initial review letter, to at least reduce the
allelopathic qualities of the temporary seed, especially compared to cereal rye. This new list
includes sterile triticale, winter wheat, spring oats, browntop millet, and partridge pea; an
erosion control notes page (sheet EC1) has been added to the plan set outlining those details.
However, this list may need to be adjusted for construction permitting based on NCDEQ
review, or for seed availability.
46. Details — Typical crossing details were missing. Preliminary culvert details should be included
in the draft mitigation plan for IRT review.
Culvert dimensions and materials were included in callouts on the respective stream plan
sheets where the crossings are proposed (Sheets S3, S6, S11, S19, and S23). However, crossing
sheets (X1-X3) have been added to expand upon the installation details of the culvert
crossings.
47. Sheet D2, Channel Abandonment and Backfill — The plan narrative mentions shallow
depressions and pools. Are these features only proposed within the abandoned channels? If
not, please show/callout on plan sheets and add a typical detail.
These features are proposed within the abandoned channels, but have also been added to
wetland creation areas C3 and C4, as outlined in Section 6.2.3. A detail for the shallow
depressions outside of the channel abandonment has been added to sheet D4, and
approximate locations for these depressions have been added to the plan sheets.

48. Sheets D4 & D5 - Please consider aquatic passage in the max. drop depth design and
construction of proposed log sill and rock sill/vane structures. This has become a concern
based on observations at recent project as -built site walks.
Drops over grade -control structures have been revised to no more than 0.4' on all reaches,
and drops over cascade features have been revised to no more than 0.6' on all applicable
reaches, based on this comment and similar discussions on previous projects.
49. Sheet D6 - Regarding the proposed Layered Riffle, DWR is unfamiliar with this design and will
need to review additional information before we can support the proposed approach and
crediting change for TR1-C and TR1-D.
A document titled Layered Riffle Detailed Design Approach and Risk Summary has been
added to Appendix C.
a. We are concerned about the long-term sustainability of these structures and question
whether they are suitable for a slate belt stream system. Please provide more
information about this technique (including photos over time) and multiple examples
of where it has been successfully implemented. Examples should be situations similar
to the proposed setting and purpose.
Based on the baseflow observed during all site visits, RES is confident that there is
sufficient baseflow at this site to make these structure appropriate. Layered Riffles are
a new approach, so RES does not have long-term photos to provide; however, a more
in-depth discussion of the structure and planned solutions to potential problems can
be found in Appendix C.
b. Please provide a reach specific performance standard to demonstrate that the
functional uplift of increased overbank flow and floodplain connectivity is achieved.
Please include reach and structure specific monitoring measures.
The performance of these structures will be evaluated using flow cameras, as discussed
in Appendix C
c. Please address concerns about inhibiting aquatic passage if flow starts piping through
the brush layers.
This is addressed under Potential Problem #1 in Appendix C Layered Riffle Detailed
Design Approach and Risk Summary.
d. Please provide adaptive management strategies for dealing with potential stream
instability issues in these proposed treatment areas for this site.
This is addressed in Appendix C Layered Riffle Detailed Design Approach and Risk
Summary.
e. Figure 12 shows the proposed five-year inundation with the layered riffles extending
beyond the project easement. This appears to show potential hydrologic trespass.
Please discuss your hydrologic trespass risk analysis and potential corrective measures.
The increase in inundation outside the Project easement is caused by the installation
of the new culvert crossings rather than the layered riffles. RES has preformed extensive
modeling of this area and are confident that this approach combined with the

proposed easement shape will not lead to hydrologic trespass. As always should issues
arise we will work with the landowner to address them.

Olivia Munzer, WRC:
1. Piedmont Alluvial Forests/Headwater Streams — According to Schaefle, this community does
not typically have river birch, hackberry or sycamore (these percentages should be reduced or
species removed and replaced with other species that typically occur within this community).
While Piedmont Headwater Stream forests have a lowered occurrence of alluvial species with
a higher occurrence of upland species, Piedmont Alluvial Forests have a mixed composition of
alluvial species such as sycamore, river birch, and hackberry, according to Schafale and
Weakley. The first planting zone is referencing aspects from the combination of both natural
communities. Additionally, the species in the planting zones are chosen based on a number
of factors, not just to identically mimic a specific natural community. Other characteristics that
are considered when creating the planting plans are wetland indicator status, growth rate,
soils, existing vegetation on -site and along reference project streams, water -logging
tolerability, and general industry experience. The percentages have been adjusted accordingly
and additional species have been added to both lists to increase diversity.
2. Similarly, they should look at the species list for the Piedmont Bottomland/swamp forest
community.
See above comment concerning the process of making planting plans. The composition
percentages and species have been adjusted.
3. This community is not dominated by sycamore, river birch or hackberry. I recommend
reducing the percent composition. Consider adding the following species: American holly,
hickories, American hornbeam, other oaks.
Thank you for your suggestion; see above comments.
4. I have concerns for the large percent of eastern cottonwood — they use a large amount of
water and is more common in larger streams. I recommend other lives stakes, like elderberry,
buttonbush, ninebark, or other species appropriate for the community.
Eastern cottonwood has been removed from the live stakes list and replaced with elderberry.
5. For permanent seed mix, I would like to see one or two more flowering species added to the
list, such as goldenrod.
Thank you for your comment. When making our tree planting and seeding lists, we are careful
to consider many factors such as pollinator species, erosion and sediment control measures,
and cost per acre. Specifically, our erosion and sediment control requirements limit the ability
to incorporate several showy, flowering species, in order to comply with providing the proper
amount of erosion -control -specific grasses. While it may seem like there are only a few
flowering, herbaceous species (e.g., black-eyed Susan, oxeye sunflower, and swamp
milkweed), please also consider the number of flowering trees within the other planting lists
(e.g., elderberry, silky dogwood, buttonbush, persimmon, northern spicebush, and tulip
poplar). An additional flowering species, smooth goldenrod (Solidago gigantea), has been
added to the seeding list.

6. For the livestock fencing, we would prefer there is no barbed wire.
RES consults with Project landowners on what fencing will best fit their needs. In this specific
case, the landowner requested woven wire but does not need barbed wire on top of that. The
reference to barbed wire has been removed from the Fence detail on Sheet D2.
7. We recommend leaving some woody debris in small piles or individually throughout the
project to provide wildlife habitat.
RES will consider this during the construction of the project.