epa comments Four Hills prospectus 12.06.22

Memorandum to the Record
December 6, 2022
Agency Comments for the Four Hills Mitigation Site (SAW-2021-02387)
Prospectus Associated with the Wildlands Yadkin 05 Umbrella Mitigation
Bank in Anson County, North Carolina.
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 (lf) 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 of
site 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 [e-mail].
Best Regards,
Todd Bowers
Comments submitted to Kimberly Isenhour (SAW -PM) via email on December 6, 2022.