20190862 Ver 1_Notice of Initial Credit Release-NCDMS Nesbit Mitigation Site_20221021

Baker, Caroline D
From: Davis, Erin B
Sent: Monday, November 7, 2022 4:50 PM
To: Baker, Caroline D
Subject: FW: [External] Notice of Initial Credit Release/ NCDMS Nesbit Mitigation Site/
SAW-2019-00832/ Union County
Attachments: Nesbit Site_100121_CT 03_STR_RW_Initial Release KTI.pdf
Laserfiche Upload: Email & Attachment
DWR#: 20190862 v.1
Doc Date: 10/21/22
Doc Type: Mitigation —Mitigation Evaluation
Doc Name: General topic of email title
From: Isenhour, Kimberly T CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, October 21, 2022 2:38 PM
To: Phillips, Kelly D <[e-mail]>
Cc: 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]>; Munzer, Olivia <[e-mail]>;
Youngman, Holland J <[e-mail]>; Wiesner, Paul <[e-mail]>; Harmon, Beth
<[e-mail]>; Stanfill, Jim <[e-mail]>; Allen, Melonie <[e-mail]>;
Crumbley, Tyler A CIV USARMY CESAW (USA) <[e-mail]>; Fennel, Tommy E CIV USARMY
CESAW (USA)<Tommy.E.Fennel @usace.army.miI>; Ray Holz <[e-mail]>
Subject: [External] Notice of Initial Credit Release/ NCDMS Nesbit Mitigation Site/ SAW-2019-00832/ Union County
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Hi Kelly,
The 15-Day As-Built/MYO review for the Nesbit Mitigation Site (SAW-2019-00832) ended October 4, 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 1,559.618 warm SMUs and 1.941 riparian WMUs. Please find attached the current signed
ledger. The IRT is not requesting a site visit at this time.
Kim Isenhour, USACE:
1. The As -Built Table 1 shows 5,096.800 total stream credits but the ledger shows 5,198.736 total gross credits.
Please clarify which is correct and let me know if the ledger should be adjusted.
2. Please add mobile vegetation plots to the wetland reestablishment areas near wetland gauge 2 and the wetland
enhancement area north of gauge 1 during monitoring.
3. The growing season is unclear. It's not appropriate to have the dates changing from year to year. Of particular
concern is if you begin the growing season as early as March 15Y, it should also be extended at the end of
monitoring past October 22nd. If you would like to use a modified growing season that is not listed in the WETS
tables, you will need to measure the soil temperature using a continuous monitoring device, and document
vegetative indicators such as bud burst and leaf drop. Ideally, this data would be collected prior to submitting
the final mitigation plan so you have accurate dates, similar to collecting pre -data for hydroperiods. If you

decide to use a modified growing season, once you establish the dates (assuming it's a normal year), you will
need to stick with those dates throughout the life of the project for consistency. A lot of inconsistencies can
occur when documenting bud burst and leaf senescence, such as which species are selected, the location of the
vegetation, shading, etc., so that's why it's best to only measure the vegetative indicators once and stick with
those dates.
Erin Davis, NCDWR:
1. DWR is concerned with DMS' observation of scalloping and crop planting within the easement. We recommend using
horse tape between boundary posts as a clearly visible limit for the landowner.
2. DWR would like to reiterate DMS' comments and recommend being proactive on addressing observed exposed soil,
tall grasses and limited live stake growth.
3. Multiple IRT members specifically requested photo points at all stream crossings, including the top and bottom of the
project, in our draft mitigation plan comments. These photo points should've been shown on the CCPV and included in
this report. While the drone photos do provide some coverage of these areas, please correct for future monitoring
reports and make a note for other projects' as-builts.
4. If you opt not to redline changes in plant species/quantities, DWR requests that the design and as -built plant tables
list the species in the same order for easier comparison.
5. DWR requests green ash not be included in any potential supplemental planting efforts for this project.
6. 1 did not see any floodplain interceptor callouts on the as -built drawings, was this proposed design treatment not
utilized for this project?
7. DWR appreciates the inclusion of the construction photos, including planting and drone images. All were very helpful
for this review. Please continue this practice.
8. DWR values the included benthic data sheets. Thank you for collecting and providing this information.
Please reach out with any questions.
Regards,
Kim
Kim Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers 1 919.946.5107