Draft Mit Plan Comment Memo_Middle Neuse UMB_Oct 27_2022

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA28403-1343
REPLY TO
ATTENTION OF:
CESAW-RG/Isenhour
MEMORANDUM FOR RECORD
October 27, 2022
SUBJECT: The Middle Neuse Stream and Wetland Umbrella Mitigation Bank- Draft Mitigation Plan Review,
Beaufort and Craven Counties, NC
PURPOSE: The comments listed below were received from the NCIRT during the 30-day comment period in
accordance with Section 332.8(g) of the 2008 Mitigation Rule.
USACE AID#'s: SAW-2017-02019 Beaufort 56; SAW-2019-00254 Craven 26; SAW-2019-00255 Craven 30
30-Day Comment Deadline: September 11, 2022
Kim Isenhour, USACE:
1. Please submit a PJD request to the Washington Field Office and submit the revised draft mitigation plan
after the field visit with the Corps. We cannot agree to wetland credit ratios until we have the signed
PJD.
2. Please ensure that the comments provided in the last draft mitigation plan review (October 2019) are
addressed in the revised draft plan, particularly comments pertaining to long-term management and
financial assurances.
3. Please expand the section on the Endangered Species Act compliance. Specifically, please provide
documentation on the RCW SLOPES procedures, if either of these counties fall within the RCW review
area. Additional information can be found at www.fws.gov/office/eastern-north-carolina/project-
planning-and-consultation , where you will find links to the RCW Project Self -Certification Letter and
the Project Review Letter for the FWS.
Kvle Barnes. USACE:
Beaufort 56:
1) Beaufort 56- Potentially southern half of the site does not contribute hydraulically. Fig. 7 indicates that
hydrology south of access road is contributing but site drains to a canal system that discharges into the
lowest portion of the restoration area.
2) According to LiDAR the majority of the hydrology drains away from the southern portion of Reach 1
and half of Reach 2.
3) The watershed map needs to be re-evaluated. LiDAR indicates the Northern half of R1 flows off project
to Gorham Swamp along the eastern side of the easement area. Hydraulically the plan loses almost half
of the contributing hydrology which will make stream formation difficult.
4) How is PI achieved at R3 if the dich flow is maintained off site according to how the ditch plugs are
designed.

Craven 26:
1) Figure 7 Watershed Map: According to LiDAR the restoration site gets no hydrologic contribution from
the land area south and west of the unnamed road that bisects the Watershed map running from west of
the 91 to the north. This map needs to be revised indicating the reduced watershed.
2) How will the in stream pond be addressed at the road between WA-5 and UT-1 Reach 3. Is this a pond
that is utilized for wildfire control and if so will Weyerhaeuser require it to remain?
3) The plan needs to be more specific as to where existing ditches will be plugged. I have hydrology
concerns with this site.
Craven 30:
1) Concerned that there is a lot of hydrology dependance placed on the watershed east of Clarks Road.
2) The project involves a lot of P2. Concerned that the area has very little slope and the applicant will only
be creating wetland areas and not stream.
Kathy Matthews, USFWS:
1. The Draft Mitigation Plans state that there is no suitable habitat for Neuse River Waterdog (NRWD) on
the sites. I wouldn't disagree with that assessment, based on the locations of these sites in the watershed
(relatively high). However, it will be important to prevent sediment from moving downstream, especially for
the Craven sites, as there are NRWD elemental occurrences downstream. Overall, the projects should benefit
aquatic species, including the NRWD.
2. The Draft Mitigation Plans also state that there is no suitable habitat for the various bat species listed in
Table 4 (Beaufort 56 site) and Table 5 (Craven 26 and Craven 30 sites). Northern long-eared bat (NLEB) is
not listed in Table 4 for the Beaufort 56 site, though there are records of NLEB in Beaufort County. Further,
the information in the table concerning suitable habitat is not correct. In the coastal plain of NC, SC, and VA,
NLEB roost in trees year-round and are active on warm days year-round. NLEB roost under loose bark, in
cracks and crevices, as well as in cavities. NLEB have been documented in pine monoculture stands, though it
is most likely to be an area where single males roost during the warm season, and winter roosts or maternity
roosts are less likely. Roosts are not limited by size (greater than 3 inches dbh) or tree species. Therefore, the
site does appear to have suitable habitat. As you may know, the NLEB has been proposed for uplisting to
endangered, and if the uplisting becomes final, the 4(d) rule will no longer apply. The Service is working to
figure out a path forward for NLEB in the coastal plain in the event it is uplisted, to address tree removal. There
is a current National Programmatic BO for forestry activities, and there is the potential that the activity could
fall under that programmatic BO and be covered, since Weyerhaeuser is the bank sponsor. I will see what I can
find out.
3. The timing of the permit will play into what consultation is needed. If the permit is issued before the
species is uplisted, we can formally recognize the previous consultation and compliance with the 4(d) rule at the
time of permit issuance. If the permit is issued after it is uplisted, then we will have to do something different.
4. As you may know, the Service announced that tomorrow we will propose to list the tricolored bat
(Perimyotis subflavus) as endangered. hllps://www.federalre isg ter.gov/public-inspection/2022-
18852/endangered-and-threatened-speci es-status-for-tricolored-bat
5. If the permit is issued and trees removed prior to final listing of the tricolored bat, then it should not
become an ESA Section 7 issue for this project. This bat species is not mentioned in the Draft Mitigation Plans,
though it is present in both counties (Beaufort and Craven). Tricolored bat is also present and active year-round
in the coastal plain. In warmer months, tricolored bats roost in live and dead leaf clusters of live or recently
dead deciduous hardwood trees, Spanish moss, Usnea trichodea lichen, pine needles, and artificial roosts (e.g.,
barns, beneath porch roofs, bridges, culverts, concrete bunkers). During the winter, tricolored bats in the
mountains hibernate predominately in caves and mines, although in the southern United States, where caves are
sparse, tricolored bat often hibernate in road -associated culverts. In the coastal plain, it is our assumption that

some of them roost in trees year-round though there appear to be fewer present in the winter than NLEB. The
Service is also working to figure out a path forward for this species in the coastal plain, to include addressing
tree removal activities. There may be National Programmatic BOs that come into play for forestry, which
would potentially smooth the way.
Travis Wilson, NCWRC:
Beaufort 56:
• The proposed vegetation community description should reference NHP's Classification of Natural
Communities (4t' approximation). The provider should reference the appropriate community type for
the planting zones with a planting list that matches the community type. Due to availability concerns the
provider may want to include additional appropriate species that may be included in the planting zone.
• The new culvert at approximately Station 51 on Reach 2 is shown at 1% grade. This is significantly
steeper than the upstream and downstream channel slope. For a new replaced culvert it is unclear why
the culvert was not set on the existing channel slope. Oversteepening culverts compared to the channel
slope often results in the lack of bedload retention in the culvert, scour at the outlet, and/or altered flow
conditions that can effect aquatic organism passage.
• I did not see a culvert design detail in the plans, that should be provided
• Reach 2 at this location has a channel width of 5' and flood plain width of almost 23'. The crossing
shows a single CMP of 48". This size may be adequate for normal flow, however why are floodplain
pipes not included?
Craven 30:
• The proposed vegetation community description should reference NHP's Classification of Natural
Communities (4t' approximation). The provider should reference the appropriate community type for
the planting zones with a planting list that matches the community type. Due to availability concerns the
provider may want to include additional appropriate species that may be included in the planting zone.
• I did not see a culvert design detail in the plans, that should be provided
• The new crossing on UT 1 Reach 2/3 shows a single CMP of 54". This size may be adequate for normal
flow, however why are floodplain pipes not included?
Craven 26:
• The proposed vegetation community description should reference NHP's Classification of Natural
Communities (4t' approximation). The provider should reference the appropriate community type for
the planting zones with a planting list that matches the community type. Due to availability concerns the
provider may want to include additional appropriate species that may be included in the planting zone.
• I did not see a culvert design detail in the plans, that should be provided
• The new crossing on UT 1 Reach 2/3 at station 30+77 shows a double CMP of 54". From the channel
cross-section dimensions provided this would appear to significantly over widen the channel. Also the
crossing is not shown on the profile.

Erin Davis, NCDWR:
Craven 26
1. Please QAQC the plan narrative. There are multiple carryovers from the previous version that no longer
apply (e.g., page 9 reference of four tributaries).
2. Page 5, Table 2 - The WA-3 and WA-4 acres do not match Table 14 or text on page 24.
3. Page 10, Table 3 - Nearly all of the reach lengths have changed from the previous version, shouldn't the
watersheds at each reach break reflect that? All watershed acres are the same as the previous version.
4. Page 24, Wetland Work Plan -
a. Please bullet WA-2 information. Please add a rationale for WA-6.
b. This section mentions headwater restoration/enhancement multiple times. Please verify that in accordance
with the 2016 NCIRT Guidance, no wetland credit areas are being proposed within the 100-ft corridor where
the headwater stream is expected to develop (e.g., areas of WA-1, WA-2, WA-3, and WA-4).
c. Please provide a detailed species list of existing tree composition for any wetland credit areas proposed only
to be supplementally planted.
d. Has any data collection or analysis (e.g., hydrologic modeling) been conducted to support that hydrologic
improvement 500 feet away from the headwater valley is feasible as indicated for WA-2 and WA-3?
e. Based on information provided and proposed improvements from supplemental planting and
headwater/stream restoration, DWR does question whether the functional uplift justifies a 1:1 restoration ratio.
5.Page 24, Vegetation Plan -
a. The text mentions three planting zones, but then the buffer and wetland zones are later combined. Please
clarify.
b. Also, I am confused by the buffer width table be included in this section. I'm assuming Table 10 is indicating
the minimum buffer width per reach and not the actual buffer width provided by the project easement. And the
entire easement should be addressed in the vegetation plan, either through proposed planting or supplemental
planting, or assessed as already containing an appropriate community/habitat cover type and identified as not
within a proposed planting zone. Based on Design Sheet 27, the entire easement is proposed to be planted.
Please also note that all planted areas within the easement should be included in the vegetative monitoring (not
just a designated "buffer" subarea).
c. DWR was glad to see individual species to be planted capped at 20 percent. However, we would encourage
adding species for greater habitat diversity, including shrub and understory species that can be exempt from the
vigor standard.
6. Page 29, Section 8.1 - How was the 70-acre planted area determined? Sheet 27 shows the entire 148-acre
easement being planted. It would be helpful to have an additional figure or design sheet showing a breakdown
of full planting, supplemental planting, and no planting areas proposed within the easement.
7. Page 30, Section 8.2 - In order to receive wetland restoration credit, hydrologic improvement must be
demonstrated.

8. Page 33, Section 8.5 - Please include a redline comparison of as -built to approved mitigation plan design
sheets indicating any field deviations, including changes to plant species and quantities. Please note any new
species will need to be approved by the IRT to count towards vegetation performance standards.
9. Figure 7 - Please update subwatersheds based on current proposed tributaries and reaches.
10. Figure 8 - DWR encourages the addition of any existing features or structures that currently impede or
fragment the site and that will be addressed/removed as part of the project (e.g., stream crossings, roads,
ditches, berms).
11. Figure 11 - DWR would like to review a revised monitoring figure based on responses to comments
regarding wetland credit areas and planting zones/areas.
12. Design Sheets - Wetland credit areas and proposed stream areas appear to overlap. Please confirm that
proposed stream and headwater valley credit areas have been subtracted from surrounding proposed wetland
credit areas.
13. Sheet 26 - Please identify the proposed temporary seed species/mix.
14. Detail Sheets - Please include a typical detail for proposed culvert crossing(s).
15. What is the PJD status? Please note DWR's comment from the June 2020 submittal: "DWR will require a
JD or preliminary JD to provide final comments for the draft mitigation plan".
Craven 30
1. Page 5, Table 2 — Please add a credit ratio column to Table 2.
2. Page 19, Reference Wetlands — Please update text based on currently proposed wetland credit areas along
UT 1-R2 and UT-R3 .
3. Page 23, UT1-Reach 2 — Should the first sentence be rephrased to reference Reach 3 as priority 1 restoration
and Reach 2 as priority 2 restoration?
4. Page 24, Wetland Work Plan -
a. Table 9 — The current standard wetland preservation ratio is 10:1. Please provide additional justification for a
7:1 ratio. Based on information provided, DWR believes the 10:1 ratio is more appropriate.
b. Should the wetland approach description be titled for both enhancement and restoration?
c. Has any data collection or analysis (e.g., hydrologic modeling) been conducted to support that hydrologic
improvement 200 feet away from the UT1-R3 is feasible as indicated for WA-2? The functional uplift from full
planting and hydrologic improvement must be proposed in order for DWR to support a 1:1 restoration ratio.
d. WA-3 is proposed along the priority 2 stream restoration length of UT1-R2. Will hydric soils be removed to
cut P2 stream benches? Is there a drainage effect concern with proposing wetland credit within or adjacent to P2
bench cuts? Please show on a figure where P2 benches overlap proposed wetland credit areas and indicate
if/where grading more than 12 inches is proposed. Depending on the extent of soil manipulation/removal,
wetland creation credit may be more appropriate.
5.Page 24, Vegetation Plan -
a. The text mentions three planting zones, but then the buffer and wetland zones are later combined. Please
clarify.

b. Also, I am confused by the buffer width table be included in this section. Pm assuming Table 10 is indicating
the minimum buffer width per reach and not the actual buffer width provided by the project easement. And the
entire easement should be addressed in the vegetation plan. Based on Design Sheet 26, all areas within the
easement are proposed to be planted except the wetland preservation area WA-1. Please also note that all
planted areas within the easement should be included in the vegetative monitoring (not just a designated
"buffer" subarea).
c. DWR was glad to see individual species to be planted capped at 20 percent. However, we would encourage
adding species for greater habitat diversity, including shrub and understory species that can be exempt from the
vigor standard.
6. Page 27, Table 14 — Please update table acres and associated credits to reflect what is currently being
proposed.
7. Page 29, Section 8.1 - How was the 48.5-acre planted area determined? Please confirm that the planted
buffers of all the headwater reaches are included in proposed vegetation monitoring.
8. Page 30, Section 8.2 - In order to receive wetland restoration credit, hydrologic improvement must be
demonstrated.
9. Page 32, Table 18 — Based on Figure 6, it appears that nearly all proposed wetland credit areas are located
within the Masontown (MM) soil series. Without a field verification, preferably a soils delineation by a licensed
soil scientist, and specific boundaries of each soil series present within proposed credit areas, DWR does not
support a minimum/target saturation below 10 percent for years 3-7.
10. Page 33, Section 8.5 - Please include a redline comparison of as -built to approved mitigation plan design
sheets indicating any field deviations, including changes to plant species and quantities. Please note any new
species will need to be approved by the IRT to count towards vegetation performance standards.
11. Figure 8 - DWR encourages the addition of any existing features or structures that currently impede or
fragment the site and that will be addressed/removed as part of the project (e.g., stream crossings, roads,
ditches, berms).
12. Figure 11 - DWR would like to review a revised monitoring figure based on responses to comments
regarding wetland credit areas (P2 areas) and planting zones/areas (Headwater reaches).
13. Sheets 9 & 10 — Areas proposed as floodplain depressions appear to overlap wetland credit areas. Please be
cautious with these areas, particularly pools with a 16-inch depth. All wetland restoration credit areas should
meet vegetative and hydrologic performance standards.
14. Sheet 10 — What is the setback distance of the proposed easement and credit areas from the roadway? Is
there any risk of impact or encroachment from future road maintenance?
15. Sheet 12 — The headwater restoration of UT2 appears to show some sinuosity. Please confirm that the reach
credit total was determined using valley length.
16. Sheet 25 — The Zone 2 plant table does not match Table 12. DWR prefers the species diversity in the Sheet
25 table, but please make tables consistent. Also, please identify the proposed temporary seed species/mix.

17. Sheet 26 — Based on this sheet, all areas within the easement except WA-1 will be fully planted. If there are
areas where only supplemental planting is proposed, please add a figure/sheet distinguishing proposed full vs.
supplemental planting.
18. Detail Sheets - Please include a typical detail for proposed culvert crossing(s).
19. What is the PJD status? Please note DWR's comment from the June 2020 submittal: "DWR will require a
JD or preliminary JD to provide final comments for the draft mitigation plan".
Beaufort 56
1. Page 5, Table 1 — The UT2 and UT3 existing and proposed lengths do not match Tables 7 and 12.
Please QAQC.
2. Page 22, Reach 3 — Section 3.6 (page 13) mentions 550 feet of priority 2 restoration. Please QAQC.
3. Page 24, Wetland Work Plan -
a. How was a 75-ft setback from proposed wetland credit areas to ditches to remain open determined?
Was hydrologic modeling (e.g., drainmod) performed to support that the setback distance is sufficient to
combat the influence of the ditch drainage effect? If not, DWR recommends looking into it (and
including the data in the plan appendices).
b. The text notes that WA-3 is adjacent to a headwater restoration, please identify the headwater reach.
Has any data collection or analysis (e.g., hydrologic modeling) been conducted to support that wetland
hydrologic improvement 800 feet away from the PS-R2 is feasible as indicated for WA-2?
4. Page 24, Vegetation Plan -
a. The text mentions three planting zones, but there is no subsection discussion or table for Zone 3.
Please clarify. Sheets 24 & 25 include a Zone 3.
b. Also, I am confused by the buffer width table be included in this section. Pm assuming Table 10 is
indicating the minimum buffer width per reach and not the actual buffer width provided by the project
easement. And the entire easement should be addressed in the vegetation plan. Based on Design Sheet
25, all areas within the easement are proposed to be planted. Please also note that all planted areas
within the easement should be included in the vegetative monitoring (not just a designated "buffer"
subarea).
c. DWR was glad to see individual species to be planted capped at 20 percent. However, we would
encourage adding species for greater habitat diversity, including shrub and understory species that can
be exempt from the vigor standard.
5. Page 29, Section 8.1 - How was the 74.9-acre planted area determined? Please confirm that all the
headwater reaches are included in proposed vegetation monitoring.
6. Page 32, Table 18 — DWR commented in the June 2020 submittal that we recommend a 10%
hydroperiod threshold for all wetland credit areas. Without a field verification, preferably a soils
delineation by a licensed soil scientist, and specific boundaries of each soil series present within
proposed credit areas clearly mapped, DWR does not support any minimum/target saturation below 10
percent.
10. Page 33, Section 8.5 - Please include a redline comparison of as -built to approved mitigation plan
design sheets indicating any field deviations, including changes to plant species and quantities. Please
note any new species will need to be approved by the IRT to count towards vegetation performance

standards. Additionally, please include soil boring data near wetland gauge locations as per the 2016
NCIRT Guidance (this also applies to Craven 26 & 30).
11. Figure 8 - DWR encourages the addition of any existing features or structures that currently impede
or fragment the site and that will be addressed/removed as part of the project (e.g., stream crossings,
roads, ditches, berms).
12. Figure 11 —
a. It would be helpful to callout ditches proposed to remain open on this figure (or another figure).
b. All headwater and intermittent reaches should have flow gauges. Please confirm flow gauges are
located in the upper 1/3 of each reach as previously requested. Additionally, the hydrologic connection
across a headwater valley is important, and in order to demonstrate that functional uplift we have had
providers propose to install and monitor gauge/well transects.
c. Only 11 wetland wells are proposed to represent 51.4 acres of restoration credit at 1:1 ratio. This total
is less than what is proposed at Craven 30 for 13 acres. Please reassess and propose additional wetland
well locations.
d. DWR will need to review a revised monitoring figure before supporting the number and location of
monitoring stations.
13. Sheets 9-11— Areas proposed as floodplain depressions appear to overlap wetland credit areas.
Please be cautious with these areas, particularly pools with a 16-inch depth. All wetland restoration
credit areas should meet vegetative and hydrologic performance standards.
14. Sheet 12 — What is the setback distance of the proposed easement and credit areas from the
roadway? Is there any risk of impact or encroachment from future road maintenance?
15. Sheet 15 — The headwater restoration of UT2 appears to show a bit of sinuosity. Please confirm that
the reach credit total was determined using valley length.
16. Sheet 17 — DWR appreciates the inclusion of this plan sheet. Please callout any ditches within, on
the CE boundary and immediately adjacent that are proposed to remain open.
17. Sheet 24 — The plant zone tables do not match tables in the plan narrative. DWR prefers the species
diversity on the Sheet 24 tables, but please make tables consistent. Also, please identify the proposed
temporary seed species/mix.
18. Sheet 25 — Based on this sheet, all areas within the easement will be fully planted. If there are areas
where only supplemental planting is proposed, please add a figure/sheet distinguishing proposed full vs.
supplemental planting.
19. Detail Sheets - Please include a typical detail for the proposed culvert crossing.
20. What is the PJD status? Please note DWWs comment from the June 2020 submittal: "DWR will
require a JD or preliminary JD to provide final comments for the draft mitigation plan".
Kimberly T Digitally signed by Kim Isenhour
• KimberlyT. Isenhour Mitigation Project Manager
Date: 2022.10.27 Wilmington District
Isenhour
15:27:04-04'00' US Army Corps of Engineers