Notice of IRT Adaptive Management Plan Review_ NCDMS Mud Lick Creek Mitigation Site (2)

From: Davis, Erin B
To: Baker, Caroline D
Subject: FW: [External] RE: Notice of IRT Adaptive Management Plan Review/ NCDMS Mud Lick Creek Mitigation Site/
Chatham County/ SAW-2014-00736
Date: Monday, December 12, 2022 2:26:36 PM
Attachments: MudLickCreek IRT Ada otiveManaaementReauestMemo 2022.odf
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Doc Date: 11/29/22
Doc Type: Mitigation —Mitigation Information
Doc Name: General topic of email title
From: Dow, Jeremiah J <[e-mail]>
Sent: Tuesday, November 29, 2022 3:55 PM
To: Kim Browning <[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CESAW (US) <[e-mail]>; Haywood, Casey M
CIV USARMY CESAW (USA) <[e-mail]>; Davis, Erin B
<[e-mail]>; Wilson, Travis W. <[e-mail]>;
[e-mail]; Allen, Melonie <[e-mail]>; Bowers, Todd
<[e-mail]>; Crocker, Lindsay <[e-mail]>; Crumbley, Tyler A CIV
USARMY CESAW (USA) <[e-mail]>
Subject: RE: [External] RE: Notice of IRT Adaptive Management Plan Review/ NCDMS Mud Lick Creek
Mitigation Site/ Chatham County/ SAW-2014-00736
Please see response to comments in red below.
Thank you,
Jeremiah
From: Isenhour, Kimberly T CIV USARMY CESAW (USA) <Kimberly.D.Browning(@usace.army.miI>
Sent: Tuesday, November 22, 2022 1:27 PM
To: Dow, Jeremiah J <jeremiah.dowCcDncdenr.g_ov>
Cc: Tugwell, Todd J CIV USARMY CESAW (US) <Todd.J.Tugwell(@usace.army.mil>; Haywood, Casey M
CIV USARMY CESAW (USA) <Casey.M.Haywood(@usace.army.mil>; Davis, Erin B
<erin.davis @ncdenr.gov>; Wilson, Travis W.<travis.wilson(@ncwildlife.org>;
kathryn matthews(@fws.g_ov; Allen, Melonie <melonie.allen(@ncdenr.g_ov>; Bowers, Todd
<bowers.todd(@epa.gov>; Crocker, Lindsay <Lindsay.Crocker @ncdenr.gov>; Crumbley, Tyler A CIV
USARMY CESAW (USA) <[e-mail]>
Subject: [External] RE: Notice of IRT Adaptive Management Plan Review/ NCDMS Mud Lick Creek
Mitigation Site/ Chatham County/ SAW-2014-00736
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Good afternoon,

The 15-day comment review period for the NCDMS Mud Lick Creek Mitigation Site Adaptive
Management Plan (SAW-2014-00736) closed on November 12, 2022. Per Section 332.8(o)(9) of the
2008 Mitigation Rule, this review followed the streamlined review process. NCDMS requested to
supplementally plant 2.04 acres of 9.6 total acres or 21% of the planted area this winter at Mud Lick
Creek. The MY4 report indicated 4 vegetation plots failed due to herbaceous competition and
sweetgum. Additionally, during the 6/4/2021 credit release site visit, the IRT noted several areas of
low stem densities and/or low vigor and many plots had evidence of deer browse. All comments
received during the review process are below.
1. Erin Davis, DWR: DWR concurs with all of EPA's comments below. Additionally, we request
green ash be removed from that supplemental planting list. Please either include an
additional species or adjust quantities of other species listed. Green Ash was removed from
the supplemental planting list and replaced with Black Gum and American Elm. An updated
version of the AMP memo is attached with the new planting list.
2. Todd Bowers, EPA: The need and approach for supplemental planting with mitigation
plan approved species is well demonstrated. The only issue I have is coming up with an
new monitoring scheme for the Mud Lick Creek site. I recommend an annual monitoring
plan that contains a couple more veg plots in the larger of the supplementally planted
areas to ensure the additional trees along with those established are progressing
toward success; at least to the third year criteria before final closeout. If interim success
is not met then additional monitoring (beyond MY7) and possibly another round of
planting and additional monitoring may be needed.
• Proposed species are approved.
• Recommend additional veg plots (2) to monitoring larger areas that received
supplemental planting. DIMS will monitor random veg transects in the 2 larger
supplemental planting areas (large area south of VP4 and the area near VP3).
• Monitor new areas/veg plots for 3 years to include MY5, 6, and 7. The site is in
MY5 now and will not be planted until the start of MY6 but transects or veg plots
in the supplemental planting areas will be monitored in MY6 through project
closeout.
• Full closeout if performance standards in new veg plots meet third year
performance (>320 stems/acre) at MY7. Understood.
• If trend is not towards success at MY7, extend monitoring period and do not
close out until all areas/veg plots are meeting performance criteria. Understood.
3. Travis Wilson, WRC: WRC requests an additional year of vegetation monitoring. Understood,
please see response to USACE below.
4. Kim Isenhour, USACE:
a. Was the beaver dam removed, and did it affect the vegetation in plot 10? DMS has
managed beaver with APHIS throughout this project and will continue to do so if
beaver are active. Currently the small dam is not affecting VP10. It is not clear that it is
an active dam.
b. What are the pink lines on the stream bank near veg plot 3? That was included in

error. It is the location of a stream problem area that was identified in MY1 and has
been shown on the CCPV since as an area to closely monitor.
c. Why is the area around plot 10 not being replanted? This is the area with extremely
dense Sweet Gum (102 stems in VP10 in MY4) that has since been thinned, but at the
time it was nearly impossible to assess an accurate stem density for the area. The
latest draft monitoring report for MY5 shows zero (0) Sweet Gum and sufficient planted
stems (323/acre) to meet success criteria. The plot has 607 stems/ acre counting
Green Ash and Sycamore volunteers.
d. Are soil amendments needed? It's difficult to know the source of the low stem density
without more information. Soil amendments are not proposed. Herbaceous
competition is the primary cause of low stem density.
e. It would have been helpful to include the reach names on the map and a soils map. For
future submittals, please follow the attached Adaptive Management Plan Guidance. In
the future we will closely follow the Adaptive Management Plan Guidance.
f. When deer browse has been an issue on past projects, such as Vile Creek, alternative
species were proposed that seemed to survive. Was this considered? The initial
planting list was very diverse, and although we didn't select species to address deer
browse, there are at least 2 species on the current list that are deer resistant (River
Birch & Tulip Poplar).
g. The Corps concurs that an additional year of vegetation monitoring should occur in
MY6, to include two additional plots. Prior to close-out, the Corps requests transect
data in several of the replanted areas to assess overall vegetation success. In MY6, we
will do veg monitoring in the 2 large areas as described above. In MY7 we propose to
monitor 3 areas (areas near VP1, VP2, & VP11) in addition to the 2 veg transects to be
monitored in MY6, for a total of 5 transects in MY7.
Please reach out with any questions.
Have a nice Thanksgiving,
Kim
Kim Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers 1 919.946.5107