20190865 Ver 1_Laurel Springs_Response to IRT MY0 Comments_2022-11-30_20221130

Restoration Systems, LLC
1101 Haynes St. Suite 211
Raleigh, North Carolina
Ph: [phone]
Fx: [phone]
Response to IRT Comments — MY 0, Baseline Report
Laurel Springs Mitigation Site —Avery County
DMS Project ID No. 100122
Full Delivery Contract No. 7890
RFP No. 16-007725 (Issuance Date 11/13/2018)
USACE Action ID No. SAW-2019-00835
DWR Project No. 2019-0865
Comments Received (Black Text) & Responses (Blue Text)
Casev Havwood. USACE:
1. QAQC of the Vegetation tables need to be addressed in the report. Looking back at the Mitigation Plan, Table
18 Planting Plan does not match the listed species on the L5 Plan Sheet. It appears that some of the
discrepancies listed below are likely a result of this. Please ensure these tables reflect the same information in
future submittals.
You are correct. The final Mitigation Plan, submitted with the permit application(s), was updated based on IRT
comments, including updates to Table 18 — Planting Plan. However, the Planting Plan table within the
construction drawings (Sheet L5) was not updated. Steps were taken to ensure this oversight does not occur
in the future. Our sincere apologies for this lack of quality control.
a. Table A lists yellow birch (Betula alleghaniensis) as a species that was not planted; however, Table B shows
it was planted but had it listed as swamp birch (Betula alleghaniensis). Plan Sheet L5 also indicates it was
planted. Please clarify.
Response: Betula alleghaniensis was planted. The use of two different common names for Betula
alleghaniensis (yellow birch and swamp birch) resulted in it being listed in Table A as a non -planted
species. The row containing this species was deleted from Table A, and the common name listed in Table
B was updated to yellow birch.
b. Table A should reflect all species that were not planted to include elderberry and buttonbush as shown
on Table 18 of the Final Mitigation Plan.
Response: Elderberry and buttonbush were live -staked in the stream -side assemblage area. They have
been included in Table B as such.
c. Sheet L5 lists Scarlet Oak as an added species, however this is shown in Table B (and Table 18 in the
Mitigation Plan) as an approved species. Table B lists Red Spruce as an added species, whereas Sheet L5
has it listed as an approved species. Please update.
Response: Scarlett oak was planted and was included in the original mitigation plan planting plan;
however, the species was incorrectly listed in the mitigation plan as Quercus imbricaria. This has been
corrected in the redline Recording Drawings planting plan (Sheet L5) and is not considered a species
substitution. Red spruce was not included in the mitigation plan. The redline Recording Drawings planting
plan (Sheet L5) and Table F (As -Built Planted Species and Stems) of the Baseline Report were updated
accordingly.
d. Based on the information provided, it appears the modification request includes the addition of three
species: arrowwood viburnum (Viburnum dentatum), bitternut hickory (Carya cordiformis) and American
hazelnut (Corylus americana). Is this accurate? If so, I am okay with the inclusion of the replacement
species, however, please provide an updated redline planting table to reflect Plan Sheet L5 and Table 18
of the Final Mitigation Plan to include consistency between common species names and planting numbers.
Updating this table will be beneficial to use as a reference for potential replanting efforts in the future.
Response: The modification request includes the addition of four species: arrowwood viburnum
(Viburnum dentatum), bitternut hickory (Carya cordiformis), American hazelnut (Corylus americana), and
Red Spruce (Picea rubens). Although no red spruce was counted during MYO permanent vegetation plot
monitoring, the species was planted, and RS requests its consideration for inclusion in the event it is
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492

counted in temporary vegetation plots during the monitoring period. Additionally, common ninebark was
included in the stream -side assemblage but was planted via live stake. This species is not being proposed
for IRT consideration since live -stakes do not count toward planted stem success criteria. The redline
Recording Drawings planting plan (Sheet L5) and Table F (As -Built Planted Species and Stems) of the
Baseline Report were updated accordingly.
2. With the possibility of a replant in 2023, 1 concur with EPA's comment to include random vegetation plots and
would support the replacement of 3 permeant plots to random plots (recommend plots 3, 5, and 13).
Response: RS will continue monitoring all permanent vegetation plots and will add three additional plots within
the 2023 proposed replant areas. Three random temporary vegetation plots will be monitored for the
remainder of the monitoring period or until otherwise requested by the IRT.
3. When comparing the MYO CCPV (Figure 1) to the updated Monitoring Map (Figure 9) provided on August 26,
2021, some of the veg plots and groundwater gauge locations appear to be flipped and are no longer located
in creditable wetland reestablishment areas (GWG 1, 6, & 9). While it's beneficial to have some groundwater
gauges located in non -credited wetlands, please ensure creditable wetland reestablishment areas have
adequate monitoring wells to document hydrologic uplift.
Response: During the 2022/2023 dormant season, RS plans to move gauges 6, 9, 11, and 12 into creditable
wetland reestablishment areas. Also, gauge 1 will be moved into the wetland enhancement area, as depicted
in Figure 9 of the approved Mitigation Plan. Please advise if the IRT would like additional changes to the
locations of monitoring features.
4. Appreciate the efforts made to work with the landowner to remove the shed located in the easement near
UT3. To help prevent future encroachments (such as mowing), were additional boundary markers or horse
tape added to this area when the surveyor visited the site on 9/2022? When the new shed is constructed,
please be sure to have the structure located far enough off the easement boundary to prevent any future
encroachments.
Response: Yes, 6-inch treated fence posts were used to delineate the easement boundary in this area. The new
shed was erected approximately 15 feet from the easement.
Andrea Leslie. WRC:
1. The as -built and final mitigation plan do not match when it comes to planting. The numbers/percentages of
what was planned (in black) to plant are not what is in the final plan. The planned percentages are also different
from the as -built (e.g., hemlock at 2-3% in final plan, but in the as -built as planned at 8% and actually planted
at 6%). The MYO report does note that a number of species were not planted (but it is inaccurate, as it fails to
include a number of those that were in the final plan and includes Betula alleganiensis, which was planted).
Please include me in a discussion with RS; I'd like to have input on the supplemental planting.
Response: Based on species availability and surrounding natural communities, several substitutions were
made between the mitigation plan and the as -built planting. The addendum to the mitigation plan has been
updated to indicate that Betula alleghaniensis was planted.
RS has ordered trees to replant 2.67 acres at a density of 670 stems per acre within observed low stem density
areas, which includes the 0.107-acre area of encroachment. These areas are within the Acidic Cove Forest
Association. The following species and quantities were secured for Q1-2023 planting.
Targeted Vegetation Associations: Acidic Cove Forest
Area of Replant: 2.67 Acres
Species
Indicator Status
Number of Stems
American elm (Ulmus americana)
FACW
600
White Oak (Quercus alba)
FACU
600
Persimmon (Diospyros virginiana)
FAC
600
Total
1,800
Page 2 of 5

These species were listed within the approved Mitigation Plan but were not planted within the Acidic Cove
vegetation association during initial planting. These three species will add to the six species planted during
initial planting for a total of nine species within the Acidic Cove vegetation association. A formal Remedial
Planting Plan letter is provided after RS's Mitigation Plan Modification Request (request to count replacement
tree species towards site success criteria) — immediately following these comment responses.
RS recognizes that additional "diversity plantings" may be desired by the IRT, and we welcome the opportunity
to discuss a diversity planting effort with the IRT. RS will plan to reach out to Andrea Leslie and Erin Davis in
Q1-2023 to discuss this effort.
Todd Bowers, EPA:
1. Table 8: Post Mitigation Plan dominant species composition needs to be recalculated for all plots.
Response: Post Mitigation Plan dominant species composition was recalculated.
2. Were there no random vegetation plots installed? If not, I recommend adding 3 random plots in place of fixed
plots for future vegetation monitoring.
Response: 3 random vegetation plots will be measured annually in addition to the 16 permanent plots.
3. Modifications and red line changes in As -Built plans such as floodplain culvert features, added rock sills and
log vanes, j-hooks, replacement of a box culvert with a bridge span, and the modified planting plan are all
noted with no comment.
Response: Noted.
4. Sheet L5.00: Recommend breaking down each species component (stem counts) into each vegetation
community.
Response: The revised redline planting table has broken down species stem counts by vegetation community.
5. 1 think the Corps (and IRT) should have been notified much earlier than concurrently with the MYO Report of a
modification request with changes or modifications to the planting plan.
Response: Noted. Apologies for the lack of notice — RS has implemented new QA/QC procedures regarding
ordering bare -root species from nurseries to prevent this situation from occurring on future sites.
6. Table 5: 16.5% of the site's planted acreage has low stem density based on visual assessment. Recommend
placing some of the recommended random plots in areas of concern. If an adaptive management plan for
supplemental planted is anticipated, please submit to the IRT as soon as possible so that the site can be
replanted no later than March 2023.
Response: Temporary plots will be measured in this area during MY1 monitoring, although RS plans to replant
these areas in Q1-2023 — see WRC comment 1 response.
7. Overall, I am very satisfied with the report and the work that RS has completed at the site. Having not been
able to visit this location, I really appreciated the detailed ground -level and drone level wetland, vegetation
and stream feature photos to illustrate the grading, planting and features implemented.
Response: Noted.
Erin Davis, DWR:
DWR appreciated DMS' report review and site visit comments.
Response: Noted.
2. The inclusion of additional photos, particularly the drone images, were very helpful for this review. Thank you.
Response: Noted.
Page 3 of 5

3. 1 was confused about the addition of 29 rock sills that weren't engineered and installed to act as grade control.
In hindsight, is there a better term to depict adding cobble to support a constructed riffle as described in
Section 2.1?
Response: RS agrees that the label "Rock Sills" is not appropriate for what occurred. "Rock Sills" was used by
the surveyor and, in turn, by the Engineer of Record on the Recording Drawing Plan Set. We feel the description
provided in Section 2.1 of "large cobble" is more appropriate. In hindsight, within the Recorded Drawing Plan
Set, "Large Cobble Added" would have been more appropriate than "Rock Sill Added."
4. Once all straw wattles with plastic netting have been removed from the site, please add a note in the
corresponding monitoring report narrative.
Response: Will do. We expect all straw wattles to be removed during the spring/summer of 2023 and will
report their removal in the MY2 (2023) monitoring report.
5. The mowing and shed encroachment should be identified in Table 5.
Response: The two areas of encroachment have been depicted on the CCPV and are quantified in Table 5.
6. An additional five stormwater culverts were installed within project easement breaks. Throughout the
monitoring period, please pay particular attention to associated easement areas that receive discharge from
these structures for any evidence of wetland/floodplain instability or erosion.
Response: All easement areas receiving discharge from stormwater culverts will be monitored throughout the
monitoring period for erosion/instability.
7. DWR is very disappointed with the planted species list. First, looking back at the final mitigation plan, DWR
reviewed and supported the Table 18 and Figure 8 plant list, which took into account the several IRT draft
mitigation plan comments. It appears that Table 18/Figure 8 was not correctly updated in the associated
construction plan sheets and that the draft mitigation plan plant list was used for construction planting.
Additionally, it does not appear that the IRT comments were reviewed when making plant quantity
adjustments as both WRC and DWR requested a cap for Eastern hemlock at 5 percent.
Response: IRS sincerely apologizes for the planted species issue — it was not intentional. IRS has implemented
new QA/QC procedures regarding the ordering of bare -root species from nurseries to prevent this situation
from occurring again. Please see WRC comment response 1 and the Remedial Planting Plan included with this
submittal. IRS recognizes that additional "diversity plantings" may be desired by the IRT, and we welcome the
opportunity to discuss a diversity planting effort with the IRT. IRS will contact Andrea Leslie and Erin Davis in
Q1-2023 to discuss this effort.
DWR understands that species availability is a common constraint during the construction phase. However,
had DWR been notified and engaged on this issue we could have discussed and agreed upon an adaptive
planning approach such as phased planting to ultimately ensure that appropriate species and appropriate
species quantities were planted across the project.
Response: Understood. We hope our new QA/QC procedures around bare -root species ordering will ensure
appropriate species are ordered. If species are unavailable, we will know early enough to allow for
collaboration with the DWR and other IRT members ahead of finalizing bare -root orders.
Please provide a supplemental list of species and quantities for the proposed supplemental planting effort. In
addition to the proposed 18 percent supplemental planting area (total 16.2 acres), DWR recommends sitewide
supplemental planting of understory/shrub species as specified in the approved Final Mitigation Plan Figure 8.
Response: Please see the response to WRC comment 1 regarding the Q1-2023 replanting effort. Regarding the
sitewide understory/shrub species planting, IRS will reach out to DWR and WRC early in 2023 to discuss this
planting and additional "diversity" planting efforts.
10. DWR recommends conducting random plots/transects in proposed supplemental planting areas, with at least
one survey area within the UT3 decommissioned farm road footprint.
Response: 3 temporary vegetation plots were measured within the supplemental planting areas as part of our
response to these comments. Data is included in Table 8 of this submittal. IRS plans to monitor 3 random
Page 4 of 5

temporary vegetation plots for the remainder of the monitoring period or until otherwise requested by the
IRT. Josh Merritt of RS walked the former soil path along UT3 and observed living planted stems. No mowing
or vehicular access occurred along the decommissioned soil path in 2022, and planted stems are establishing.
Josh oversaw the planting of two rows along the soil path during site planting. RS will continue to visually
monitor this area. If planted stems do not survive into year two (2023) monitoring, RS will propose replanting
the decommissioned road with potted trees/shrubs during the 2023/2024 dormant season.
11. Please provide wetland indicator status for proposed species additions to the approved plant list.
Response: Wetland indicator status has been provided in Tables A and B in the Mitigation Plan Addendum and
in the redline Recording Drawing planting plan on Sheet L5.
12. DWR respectfully disagrees with RS' response to DMS that there were no significant changes in monitoring
device locations from the approved mitigation plan. As noted in the August 2021 correspondence, DWR was
ok with relocating one groundwater gauge (#4) to a non -crediting area. However, the MYO monitoring figure
shows several gauges have been shifted outside of wetland credit generating areas. In order to demonstrate
performance standard success there needs to be sufficient number and representative cover of monitoring
devices across proposed credit areas. If gauge locations remain as -is, DWR may request additional gauge
installation during the monitoring period.
Response: Understood. During the 2022/2023 dormant season, RS plans to move gauges 6, 9, 11, and 12 into
creditable wetland reestablishment areas. Also, gauge 1 will be moved into the wetland enhancement area,
as depicted in Figure 9 of the approved mitigation plan. Please advise if the IRT would like additional changes
to the locations of monitoring features.
Page 5 of 5

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November 30, 2022
Kimberly Isenhour
Mitigation Project Manager, Regulatory Division
U.S. Army Corps of Engineers
Restoration Systems, LLC
1101 Haynes St. Suite 211
Raleigh, North Carolina
Ph: [phone]
Fx: [phone]
Subject: Laurel Springs Mitigation Site - request to count replacement tree species towards site success criteria
DMS Project ID No. 100122
Full Delivery Contract No. 7890
RFP No. 16-007725 (Issuance Date 11/13/2018)
USACE Action ID No. SAW-2019-00835
DWR Project No. 2019-0865
Mrs. Isenhour,
Restoration Systems, LLC (RS), Sponsor of the Laurel Springs Mitigation Site (Site), is requesting a modification of the
Site's Mitigation Plan to include planted tree/shrub species that were not included in the Site's approved Mitigation
Plan. A lack of availability from nurseries of approved Mitigation Plan tree/shrub species required IRS to adjust the
number of stems planted for some approved species and include five additional species not included in the approved
Mitigation Plan — four bare -root and one live -stake species. Table A below is a list of tree/shrub species detailed in
the approved Mitigation Plan that were not planted at the Site due to lack of availability.
Table A. Non -planted Species Specified in the Mitigation Plan
Species (Mitigation Plan)
Wetland Indicator
Mit. Plan Stems
Basswood (Tilia americana)
FACU
300
White Ash (Fraxinus americana)
FACU
400
Black Gum (Nyssa sylvatica)
FAC
1,200
Persimmon (Diospyros virginiana)
FAC
500
Shadbush (Amelanchier arborea)
FAC
500
American elm (Ulmus americana)
FACW
1,200
Hackberry (Celtis laevigata)
FACW
1,100
Swamp Chestnut Oak (Quercus michauxii)
FACW
1,000
Tag alder (Alnus serrulata)
FACW
700
Total =
6,900
Species summarized in Table A, as with others in the approved Mitigation Plan, were selected based on Reference
Forest Ecosystem (RFE) data, on -site observations, and community descriptions from Classification of the Natural
Communities of North Carolina (Schafale and Weakley 1990) — Montane Alluvial and Acidic Cove Forests.
Of the 6,900 bare -root stems detailed in Table A, 2,450 were supplemented by four species not included in the
approved Mitigation Plan: Arrowwood viburnum, Bitternut hickory, American hazelnut, and Red spruce. IRS selected
these species based on their availability and that they were observed in nearby forest communities. The additional
4,450 stems needed to complete the targeted planting density were comprised of Mitigation Plan approved species.
An extra 2,500 stems were live -staked in the stream -side assemblage area, including 300 stems of common ninebark,
a species not included in the approved Mitigation Plan. Since live -staked species primarily provide stream -bank
stability and do not count toward the stem density performance standard, IRS is not proposing common ninebark to
be considered for IRT approval. Table B summarizes planted species and their individual quantities within each
planting zone and in total.
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492

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November 30, 2022
Restoration Systems, LLC
1101 Haynes St. Suite 211
Raleigh, North Carolina
Ph: [phone]
Fx: [phone]
IRS included all planted species in the data collection for the MYO Monitoring Report. Table 8 within the MYO
Monitoring Report, the DMS vegetation tool, requires providers to select from five options regarding the species
status for inclusion in meeting performance standards, "Performance Standard Approval" column:
1. Approved Mit Plan
2. Approved Post Mit Plan
3. Proposed
4. Not Approved — Not Invasive or Exotic
5. Not Approved — Invasive or Exotic
The four additional bare -root species detailed in Table B (Arrowwood viburnum, Bitternut hickory, American
hazelnut, and Red spruce) were included in the MY 0 Report as "Proposed" species for inclusion in meeting
performance standards — Vegetation Plot Data Table from Vegetation Data Entry Tool, MY 0 Report Table 8,
Appendix B.
IRS requests the IRT allows these four species to be counted toward the Site's success criteria.
If the IRT concurs that these species may be included to count toward the Site's performance standards, IRS will
update the four species as "Approved Post Mit Plan" in the MY1 (2022) report.
Please let me know if you have any questions or if I can provide any additional information.
Sincerely,
Raymond Holz
Operations Manager
Restoration Systems, LLC
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492

November 30, 2022
Kimberly Isenhour
Mitigation Project Manager, Regulatory Division
U.S. Army Corps of Engineers
Restoration Systems, LLC
1101 Haynes St. Suite 211
Raleigh, North Carolina
Ph: [phone]
Fx: [phone]
Subject: Laurel Springs Mitigation Site — Remedial Planting Plan (Q1-2023)
DMS Project ID No. 100122; Full Delivery Contract No. 7890; RFP No. 16-007725 (Issuance Date 11/13/2018)
USACE Action ID No. SAW-2019-00835; DWR Project No. 2019-0865
Mrs. Isenhour,
During the 2022 growing season, Restoration Systems (RS) has observed areas of low stem densities at the Laurel
Springs Mitigation Site (Site). Observed areas total 2.67 acres, which includes a 0.107-acre area of encroachment —
see attached remedial planting figure. The encroachment area was partially due to a storage shed left within the
easement used by the adjacent landowner. IRS worked with the neighbor to remove the shed and cleared the area
of all debris. Additionally, 6-inch treated fence posts were used to delineate the easement boundary in this area.
A new shed was erected approximately 15 feet from the easement.
IRS has ordered trees to replant the 2.67 acres at a density of 670 stems per acre. The replant areas are within the
Acidic Cove Forest Association. The following species and quantities were secured for Q1-2023 planting.
Targeted Vegetation Associations: Acidic Cove Forest
Area of Replant: 2.67 Acres
Species
Indicator Status
Number of Stems
American elm (Ulmus americana)
FACW
600
White Oak (Quercus alba)
FACU
600
Persimmon (Diospyros virginiana)
FAC
600
Total
1,800
These species were listed within the approved mitigation plan but not planted within the Acidic Cove vegetation
association during initial planting. These three species will add to the six species planted during initial planting for
nine total species within the Acidic Cove vegetation association.
IRS recognizes that additional "diversity plantings" may be desired by the IRT, and we welcome the opportunity to
discuss a diversity planting effort with the IRT. IRS will contact Andrea Leslie and Erin Davis in Q1-2023 to discuss
this effort.
Please let me know if you have any questions or if I can provide any additional information.
Sincerely,
Raymond Holz
Operations Manager
Restoration Systems, LLC
Attachment — Remedial Planting Plan Figure
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492

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