20140705 Ver 1_Corps of Engineer Correspondence_20150416

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Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
Washington Regulatory Field Office
2407 W 5`h Street
Washington, North Carolina 27889
April 10, 2015
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Action ID No SAW - 2015- 00710, Neu —Con Umbrella Stream Mitigation Bank
(Resource Environmental Solutions, LLC), Selma Mill Stream Restoration Site
Mr Daniel Ingram
Resource Environmental Solutions, LLC
909 Capability Drive, Suite 3100
Raleigh, North Carolina 27606
Dear Mr Ingram
[j@[ROY2 D
APR 1 6 2015
DENR - WATER RESOURCES
TRANSPORTATION PERMITTING UNIT
Please reference the North Carolina Interagency Review Team (IRT) meeting of March 18,
2015, during which we discussed the Selma Mill stream mitigation project which is located west
of NC Highway 96 (North Summer Street), and north of West Elizabeth Street, on the north side
of the Town of Selma, along an unnamed tributary to the Neuse River, Johnston County, North
Carolina The proposed project is a traditional stream restoration site with a Best Management
Practice (BMP) component The discussion dealt specifically with a request by Resource
Environmental Solutions to propose construction of a BMP (2 74 acre on -line storm water
wetland) as part of the stream restoration project to address water quality issues while being able
to generate enough SMU's to cover the cost of construction and long term maintenance of the
site The Selma Mill site is located in the 8 -digit hydrologic unit 03020201
Please find the enclosed correspondence from IRT members Mr Travis Wilson, Ms Cyndi
Karoly, Ms Kathy Matthews, and Mr Todd Bowers concerning the BMP proposal It is our
opinion that you are requesting too many SMU credits for your BMP proposal given the
unproven functional uplift your BMP may generate Without adequate performance measures or
monitoring requirements and your request to fiont load credit release contingent on submittal of
design plans rather than performance standards is not consistent with other mitigation proposals
and places all risk on the Corps rather than the sponsor The BMP represents 40% of the overall
mitigation credits for the site and the SMU determination is based entirely on the cost of
constructing and maintaining the BMP rather than the functional uplift provided by the BMP
It is our recommendation based on comments from the IRT members that you either modify or
propose an alternative mitigation plan as the current BMP proposal part of the mitigation plan is
currently not acceptable to the IRT

Thank you for your time and cooperation The Wilmington District is committed to providing
the highest level of support to the public To help us ensure we continue to do so, please
complete the Customer Satisfaction Survey located at http HieQulatoiy usacesuivey com/ If you
have any questions, please contact me at the Washington Regulatory Field Office, telephone
(910) 251 -4558
Sincerely,
William J Biddlecome
Chief, Washington Regulatory Field Office
Enclosure
Copies Furnished Without Enclosure
Mr Todd Bowers
USEPA, Region 4
61 Forsyth Street, SW
Mail Code. 9T25
Atlanta, Georgia 30303 -8960
Ms Emily Jernigan Wells
U S Fish and Wildlife Service
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh, North Carolina 27636 -3726
Mr Fritz Rhode
National Marine Fisheries Service
101 Pivers Island Road
Beaufort, North Carolina 28516
Ms Virginia Baker
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699 -1617
3

Mr Travis Wilson
Eastern Region Highway Project Coordinator
Habitat Conservation Program
North Carolina Wildlife Resources Commission
1718 Hwy 56 West
Creedmoor, North Carolina 27522
Todd Tugwell
Special Projects Manager
Wilmington District, US Army Corps of Engineers
11405 Falls of the Neuse Road
Wake Forest, North Carolina 27587