Notice of Final Prospectus Review Four Hills Mitigation Site

Baker, Caroline D
From: Davis, Erin B
Sent: Tuesday, January 10, 2023 8:40 AM
To: Baker, Caroline D
Subject: FW: [External] RE: Notice of Final Prospectus Review/ Wildlands Yadkin 05 UMB - Four
Hills Mitigation Site/ SAW-2021-02378/ Anson County
Laserfiche Upload: Email & Attachment
DWR#: 20211706 v.1
Doc Date: 12/6/22
Doc Type: Mitigation — Mitigation Information
Doc Name: General topic of email title
From: Bowers, Todd <[e-mail]>
Sent: Tuesday, December 6, 2022 12:03 PM
To: Kim Browning <[e-mail]>; 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]>; Merritt, Katie <[e-mail]>; Munzer, Olivia
<[e-mail]>; Hamstead, Byron A <[e-mail]>; Gledhill-earley, Renee
<[e-mail]>; McHenry, David G <[e-mail]>
Cc: Crumbley, Tyler A CIV USARMY CESAW (USA) <[e-mail]>; Aaron Earley
<[e-mail]>
Subject: [External] RE: Notice of Final Prospectus Review/ Wildlands Yadkin 05 UMB - Four Hills Mitigation Site/ SAW-
2021-02378/ Anson County
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Kim,
Thank you for the opportunity to provide feedback and comments on the Four Hills Mitigation Site (the Site or
Project) Prospectus as the primary location for the Wildlands Yadkin 05 Umbrella Mitigation Bank (UMB).
Wildlands Holdings IX, LLC (Wildlands), has presented a potentially suitable plan to provide compensatory
mitigation for jurisdictional stream impacts associated with the US Army Corps of Engineers Clean Water Act
Section 404 permit program. The Project will include restoration of streams and wetlands along Little Creek, its
fourteen unnamed tributaries and associated floodplains. Wildlands proposes stream mitigation including 8,311
linear feet (If) of restoration, 870 if of enhancement I, 9,005 of enhancement II and 608 if of preservation.
Proposed wetland mitigation includes 4.0 acres of reestablishment and 4.4 acres of rehabilitation. The Site will,
upon successful completion of performance and closeout, will include 12,277 warm water stream credits and
6.178 riparian wetland credits to compensate for impacts within the Yadkin 05 geographic service area
(Hydrologic Unit 03040105).
Note: It is understood that site visits have been made by IRT members during the development ofsite feasibility
to provide mitigation credit. In that regard, I feel it necessary to denote that I have not been on -site during this
process and that my comments may reflect a lack of on -site observation and evaluation.

The EPA Region 4 Ocean, Wetlands and Stream Protection Branch offers the following site -specific comments
as they pertain to the Four Hills Prospectus dated November 1, 2022. Page numbers refer to the entire pdf
document offered for review:
1. General:
o I am attempting to understand the rationale for the thin conservation easement along Little
Creek. Is this to allow for cattle exclusion fencing only? Little to no riparian buffer is being
protected along the right bank of Little Creek.
o In the future, please provide documents that are searchable for terms. The pdf of the Prospectus
either used a non-standard font or other format mechanism that prevented me from performing
document searches.
o I am almost certain that this bank is formally called the "Wildlands Yadkin 05 Umbrella
Mitigation Bank". If this is the case, please refer to it as such in all future documents.
o I would have liked to see some discussion of the constraints in project parameters, mainly in the
arena of crossings and culverts. Understandably this can be presented in the mitigation plan for
the Four Hills site but some rationale for crossing locations, aside from current culvert placement
should be provided in the prospectus and the mitigation plan going forward.
o Happy to see some in -line ponds being removed. However, many of the tributaries that originate
inside the conservation easement are receiving substantial runoff from the adjacent pastures
without any BMPs (aside from minimum width buffers) to treat the nutrient flux. Does
Wildlands have a strategy to deal with concentrated runoff from adjacent pastures?
o Happy to see that the conservation easement boundaries were expanded by 27% to provide
larger/wider riparian buffer; a feature this project could use more of due to the adjacent active
livestock operation and pastures.
2. Section 3.1.1/Page 10: Is there a strategy to locate and remove the buried creosote treated poles in the
Little Creek floodplain?
3. Section 4.1/Page 18: Is the impoundment on UT7 Reach 2 caused by a dam or a clogged culvert?
(culvert shown on Figure 4b)
4. Section 8.2/Page 27: Recommend adding thresholds (aside from "minor" or "major") for notification of
the Corps/IRT and/or undergoing corrective action.
5. Section 8.3/Page 27: Has a long-term site steward been identified?
Thank you for the opportunity to provide feedback, comments, and concerns with the draft prospectus for the
Four Hills Mitigation Site in Anson County, NC. Wildlands has provided a potentially suitable plan to offset
impacts and provide compensatory stream and wetland credits within the Yadkin River 05 watershed
geographic service area. If you or the sponsor have any questions or need clarification on any of the comments
stated above, please contact me at 404-562-9225 or at bowers.todd(cr�,epa.gov.
Best Regards,
Todd Bowers
Todd Allen Bowers
US EPA Region 4 Oceans, Wetlands and Streams Protection Branch
61 Forsyth St. SW
Atlanta, GA 30303

919.523.2637 cell/telework
404.562.9225 office
Bowers.todd&epa.gov
"Do unto those downstream as you would have those upstream do unto you."
— Wendell Berry
From: Isenhour, Kimberly T CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, November 3, 2022 2:39 PM
To: Tugwell, Todd J CIV USARMY CESAW (USA)<[e-mail]>; Haywood, Casey M CIV USARMY
CESAW (USA) <[e-mail]>; [e-mail]; 'Wilson, Travis W.
([e-mail])' <[e-mail]>; Bowers, Todd <[e-mail]>; Merritt, Katie
<[e-mail]>; Munzer, Olivia <[e-mail]>; byron [e-mail]; renee.gledhill-
[e-mail]; McHenry, David G <[e-mail]>
Cc: Crumbley, Tyler A CIV USARMY CESAW (USA) <[e-mail]>; Aaron Earley
<[e-mail]>
Subject: Notice of Final Prospectus Review/ Wildlands Yadkin 05 UMB - Four Hills Mitigation Site/ SAW-2021-02378/
Anson County
Good afternoon IRT,
Wildlands Engineering has provided us with a Final Prospectus for a new Umbrella Mitigation Bank in the Yadkin 05. The
Four Hills Mitigation Site is included in the submittal as the first site for the bank. The site includes 18,794 linear feet of
streams and 8.8 acres of wetlands in a 57.8 ac conservation easement. The Prospectus has been uploaded to RIBITS and
is attached. Per section 332.8(d)(3), we are initiating the 30-day review of the Draft Prospectus with this
email. Information about the proposed bank is below:
Umbrella Bank Name: Wildlands Yadkin 05 UMB
Sponsor: Wildlands Engineering, Inc. (Contact: Aaron Earley)
Location: 35.142190,-80.147810, Anson county
HUC: 03040105 Yadkin 05
USACE Action ID: SAW-2021-02378
USACE Bank PM: Kim Isenhour
30-Day Comment Deadline: December 5, 2022
*As you may recall, we conducted an IRT site visit January 11, 2022. The public notice for this stie will be posted next
week.
RIBITS Link to Wildlands Yadkin 05 UMB — Four Hills Mitigation Site:
httos://ribits.00s.usace.armv.mil/ords/f?o=107:10:1498817033766::::P10 BANK ID:6203
Please reach out with any questions.
Thanks

Kim
Kim Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers 1 919.946.5107