20141149 Ver 1_Other Agency Correspondence_20150113

Homewood, Sue
From: Matthews, Kathryn <kathryn_matthews @fws.gov>
Sent: Tuesday, January 13, 2015 1:49 PM
To: David.E.Bailey2 @usace.army.mil; Tugwell, Todd SAW; bowers.todd @epa.gov;
Homewood, Sue; Karoly, Cyndi; Wilson, Travis W.; Bryant, Shari L.; Merritt, Katie; Baker,
Virginia; Kathryn Matthews; Emily Jernigan; Hall, Dolores; Gledhill - earley, Renee
Cc: Adam Riggsbee; Grant Lewis; Worth Creech; Leigh Mann
Subject: USFWS comments to Cape Fear 02 UMB Final prospectus (SAW -2014- 006570)
Dear Dave,
Thank you for the opportunity to review the Final Prospectus for the proposed Cape Fear 02 Umbrella
Mitigation Bank. Kathy Matthews and Emily Wells participated in a field meeting on December 16, 2014 at
several of the proposed stream mitigation sites. We have the following comments for your consideration.
1. The Service agrees with the proposed Geographic Service Area (GSA) and Credit release schedule.
2. Based on our field meeting at 3 of the 8 proposed Phase 1 mitigation sites, the Service also recognizes that
the project sponsor, Restoration Systems, has done a good job of locating acceptable mitigation sites, and we do
not have any significant objections to the inclusion of those sites in the proposed mitigation bank. We look
forward to seeing site - specific mitigation plans for these sites.
3. Based upon our site visits, below are comments on specific preliminary mitigation plans for Motes Creek,
Orphan Creek, and Maple Hill sites.
a. Motes Creek — all of the preliminary plans for the stream reaches on this site were acceptable. During
the December 16, 2014 meeting, the agencies recommended that the number of proposed crossings be
reduced, or that crossings be moved to result in less impact to the stream project.
b. Orphan Creek — It was unclear whether UTIB is perennial. Gauges should be placed in the stream to
determine whether the stream is perennial or intermittent. The agencies also recommended that the
number of proposed crossings on this site be reduced.
c. Maple Hill — the agencies determined that the proposal to move UT back to the old channel location
is acceptable. Debris should be carefully removed from the historic channel. For UT2, there was a
question as to whether the stream was jurisdictional, and because it seems to be in good condition, the
functional lift of doing work in UT2 is questionable. According to the Corps, most of UT2A and UT213
are not jurisdictional streams (may be linear wetlands). Finally, for UT3, the agencies agreed that
returning the stream back to the historic channel or through the middle of the valley /field would be
acceptable.

4. Section 10.3 of the prospectus provides general information concerning restoration and enhancement
methods. We are pleased that Section 10.3.1 states that removal of existing deeply- rooted vegetation will be
avoided in the belt -width corridor.
5. Section 14 includes a discussion of potential impacts to Federally- listed species. The Service agrees that
work on the proposed sites is not likely to adversely affect Federally- listed species at all of the sites currently
proposed under this umbrella mitigation bank, except for Slingshot Creek. For Slingshot Creek, we would
suggest that surveys be performed for the Smooth Coneflower (Echinacea laevigata) prior to beginning earth
work to determine presence of the species. We agree with the prospectus that habitat is potentially present at
this site. Surveys for smooth coneflower should be done in late May through October.
http: / /www.fws.gov /raleigh/ pdfs /Optimal_Survey_Windows_for_ listed plants.pdf
Please contact the Service with the survey results and an updated determination of effect after completing the
surveys.
More information on this species can be found here:
http: / /www.fws.gov /raleigh/ species /es_smooth_coneflower.html
6. The Service has reviewed the comments from National Marine Fisheries Service and USEPA, and agrees
with/supports their comments.
Thanks for the opportunity to comment on this final prospectus. Please let us know if you have any questions.
Kathy Matthews and Emily Wells
Kathy Matthews
Fish and Wildlife Biologist
Raleigh Ecological Services
U.S. Fish and Wildlife Service
P.O. Box 33726
Raleigh, NC 27636 -3726
Phone [phone] x27
Email [e-mail]