IRT Comment Response_Cross Creek Ranch

WILDLANDS
E N G IN E E R I N G
November 8, 2022
Ms. Kim Isenhour
Mitigation Project Manager
USACE — Regulatory Division
Subject: [External] Notice of Initial Credit Release/ NCDMS Cross Creek Ranch Mitigation Site/ SAW-
2020-00051/ Montgomery County
Yadkin River Basin — CU# 03040104
Montgomery County
DMS Project ID No. 100138
Dear Ms. Isenhour:
On October 12, 2022, Wildlands Engineering received comments from the North Carolina Interagency
Review Team (IRT) regarding the 15-Day As-Built/MYO review for the Cross Creek Ranch Mitigation Site
(SAW-2020-00051) in accordance with Section 332.8(o)(9) of the 2008 Mitigation Rule. The following
letter documents DMS feedback and Wildlands' corresponding responses and additions to the
Monitoring Year 1 Annual Report.
Casey Haywood, USACE:
1. Several adjustments were made during construction to save trees. Please note visual observations of
tree survival in these areas in future monitoring reports; the IRT is interested in tree survival on
mitigation sites following construction.
Response: Wildlands will visually observe tree survival and note this in future monitoring reports.
2. Vegetation plot data indicates the site is on a trajectory for success. When was the site planted? Table
10 shows it was planted in March 2022 but does not specify the day.
Response: As stated in Table 6 found in Appendix B of the Monitoring Year 0 Annual Report, the planting
date is March 10, 2022. Wildlands will include this in Table 14, Project Activity and Reporting History,
found within Appendix E of the Monitoring Year 1 Annual Report.
3. Concur with DWR's comment 3. In addition, please make sure to capture the wetland rehabilitation
areas with a random veg plot in future monitoring reports.
Response: Wildlands will work to capture the wetland rehabilitation areas in future random vegetation
plots. However, wetland rehabilitation zones are small, and may be difficult to fully represent using
random vegetation plots. Both wetland re-establishment and rehabilitation zones were planted with the
some species.
Todd Bowers, USEPA:
1. There is a lack of, or at least I expected, a comprehensive summary of the work performed in the
opening paragraphs that outlines the length of streams and acres of wetlands
restored/enhanced/preserved and any additional features (monitoring devices etc.) of the site that were
implemented.
Response: In an effort to keep reports concise, information regarding work performed, length of streams
and acres of wetlands restored/enhanced/preserved is outlined in Tables 1 and 2 of the Monitoring Year
Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609

0 Annual Report, rather than within the text. Additional features, including monitoring devices
implemented on the site, are portrayed in Figures la-c of the Monitoring Year 0 Annual Report.
2. The 19.57 acres of mechanically treated Chinese privet will receive a follow up chemical treatment in
MY1. Noted.
3. One random veg plot has a dominant species (Eastern cottonwood) but this is a random plot so there
is no expectation that this result will be repeated. Noted.
4. The photo of the culverts from the stream perspective are great but I would like to see some
additional photos of the crossing from the at -grade perspective to illustrate the crossing width.
Response: Wildlands will include additional culvert photos from the at -grade perspective in AppendixA
of the Monitoring Year 1 Annual Report. However, the width of the crossing is detailed in the as -built
plans, and is best observed by scaling from the plans.
Erin Davis, NCDWR:
1. As per the 2016 NCIRT guidance, please provide soil boring descriptions near all groundwater
monitoring gauges.
Response: Wildlands will include soil boring descriptions in Appendix F of the Monitoring Year 1 Annual
Report.
2. CCPV —The groundwater gauges in the two larger wetland reestablishment areas appear to have
shifted a bit more interior. DWR has mentioned in the past that the sections of wetland credit areas we
are most concerned with meeting the minimum hydroperiod threshold are near the credit boundary,
close to the upland transition and close to the stream. If during monitoring, vegetation establishment
and soils aren't consistent across a wetland credit area, DWR may request another gauge be installed for
better representation.
Response: If requested in the future, Wildlands will install additional gauges for better representation of
the credit boundary and upland transition of the two larger wetland reestablishment areas.
3. CCPV — Most of the permanent veg plots are close to the stream, which is helpful to capture any
Priority 2 cuts that we're concerned about. However, there's limited representation of the outer buffer
near the easement boundary by permanent veg plots. Please use a few of the random plots each year to
cover this zone, as well as, paying specific attention during the visual assessment.
Response: Wildlands will use a few of the random plots each year to represent vegetation in the outer
buffer near the easement boundary.
4. Sheet 1.3.8 — Is the additional riprap shown lining the pool downstream of the culvert or did it replace
the pool as more of a riffle?
Response: There is a pool downstream of the culvert. It was lined with riprap for outlet protection, which
may have given the appearance of a riffle.
5. Sheet 1.4.1— Of all the added riprap reinforcement areas, the only one that appears to extend along
the stream credit area is the top of UT1B. Does maintenance of this riprap area need to be added as an
allowable activity by Stewardship? With the culvert ending on the easement boundary, what is the
likelihood that future crossing maintenance/replacement may impact the easement area?
Response: Wildlands does not anticipate the riprap reinforcement area at the top of UT1B to require
maintenance.
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The culvert that ends on the easement boundary of UT1B is a box culvert, which is unlikely to fail and
likely won't need future maintenance, nor will maintenance impact the easement area.
6. Many of the construction changes are tied to attempts to save trees. Does the project engineer work
with the project ecologist on these decisions? Is tree health assessed? Are construction shifts away from
trees far enough not to impact critical root zones?
Response: Most alignment shifts during construction are made by the construction manager when the
project ecologist is not on site. Tree health is a key factor in these decisions.
Construction shifts are made as for away from the design alignment as possible, but there is no
guarantee that critical root masses won't be impacted.
7. Photo Point 34, UT3 R2 — Were there any field indicators that the right bank shown in the photo is
actively eroding?
Response: Photo Point 34 at UT3 R2 shows a vertical, stable bank that has experienced erosion in the
past. There are no signs of active or recent erosion. Additionally, there are trees present with root masses
in place to further stabilize the bank. Wildlands will include additional photos of the bank in Appendix F
of the Monitoring Year 1 Annual Report.
8. DWR appreciated the planted species diversity.
Response: Thank you, we are pleased with vegetation survival and diversity thus for.
Thank you for your review and providing comments on this submittal. If you have any further questions,
please contact me at [phone], or by email ([e-mail]).
Sincerely,
Jason Lorch, Monitoring Coordinator
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