20191132 Ver 1_MY2 Credit Release_20230512

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON. NORTH CAROLINA 28403-1343
May 12, 2023
CESAW-RGM/Kichefski
Action ID No. SAW-2019-01296
Re: MY2 Credit Release associated with the Wildlands Little Tennessee Umbrella
Mitigation Bank — East Buffalo Mitigation Site
Wildlands Engineering, Inc.
Ms. Andrea Eckardt
aeckardt(o).wildlandseng.com
Dear Ms. Eckardt:
This correspondence is in response to your February 16, 2022 request for the
Monitoring Year 1 (MY1) credit release for the East Buffalo Mitigation Site, part of the
Wildlands Little Tennessee Umbrella Mitigation Bank. The 259.84-acre site is located
within the Little Tennessee River Basin Hydrologic Unit 06010204, at 1157 East Buffalo
Road in Robbinsville, Graham County, North Carolina. The project was approved to
generate 4,432 cold stream mitigation units (SMU's) through the restoration,
enhancement, and preservation of 13,662 linear feet of stream on East Buffalo Creek and
ten unnamed tributaries to East Buffalo Creek. It was also approved to generate 1.75
wetland mitigation units (WMU's) through the re-establishment, rehabilitation and
enhancement of 2.46 acres of wetland. The purpose of this letter is to confirm the MY2
release of credits for this mitigation site.
Pursuant to the site's Umbrella Mitigation Banking Instrument and the site -specific
Mitigation Plan, the following mitigation credits shall be available for sale provided the
annual monitoring report demonstrates interim performance standards are being met:
• ten percent (10%) of the mitigation site's total stream restoration and
enhancement credits, one percent (1 %) of the site's total preservation credits,
and 10% of the site's total wetland re-establishment, rehabilitation, and
enhancement credits associated with year 2 annual monitoring (324.3 Cold
Water SMUs and 0.18 WMUs)
Based on a review of the data provided for the stream enhancement and/or
restoration on the site, we confirm that you have satisfied the above requirements, and

324.3 Cold Water SMUs and 0.18 WMUs are now available for sale. With this release
50% of the total stream restoration and enhancement credits, 50% of the total wetland
reestablishment, rehabilitation, and enhancement credits, and 94% of the total stream
preservation credits will have been released.
Please review the comments provided by the NCIRT during their review of the
monitoring report. While it is not necessary to provide a response to specific comments
at this time, please be sure to address the issues raised in future monitoring report
submittals.
Thank you for your interest in restoring and protecting waters of the United States. If
you have questions regarding this letter, please contact Mr. Steve Kichefski at
steven.I.kichefski(@usace.army. miI or telephone [phone].
Sincerely,
Steve Digitally signed by
Steve Kichefski
Kichefski 1703101-04'00'2
Steve Kichefski
for Todd Tugwell
Mitigation Branch Chief
Regulatory Division
Electronic Copies Furnished:
Sue Homewood (NCDWR)
Mac Haupt (NCDWR)
Andrea Leslie (NCWRC)
Travis Wilson (NCWRC)
Byron Hamstead (USFWS)
Todd Bowers (USEPA)
Todd Tugwell (USACE)
Kim Browning (USACE)
Casey Haywood (USAGE)
Erin Davis (USACE)

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
CESAW-RGM/Kichefski
MEMORANDUM FOR RECORD
May 12, 2023
SUBJECT: Action ID # SAW-2017-01921, NCIRT Review Comments on the Wildlands
Yadkin Valley Umbrella Mitigation Bank, White Buffalo Year 3 Monitoring Report
Todd Bowers, USEPA (March 9, 2023):
I have reviewed the MY2 monitoring report for the Wildlands Little Tennessee UMB -
East Buffalo Site dated February 2023. At this time, for milestone 4 associated with
MY2, Wildlands is requesting 324.30 stream mitigation units (SMUs) and 0.18 wetland
mitigation units (WMUs) be released.
According to Wildlands, in Year 2, site assessments were conducted between January
2022 and November 2022. Project streams are in good, stable condition and functioning
as intended, with no areas of concern. Three of five GWGs met criteria for wetland
hydrology. Additional gages will be installed in marginal wetlands to aid in potential
adjusted wetland boundary determinations. No bankfull events were recorded in MY2
on any restoration or enhancement 1 reaches. Crest gages will be lowered in these
channels in MY3 to better emphasize near-bankfull events. As supplementally planted
stems were not counted toward the formal MY2 vegetation assessment, per IRT
requirements, nine vegetation plots failed to meet criteria. However, MY2 supplemental
planting was successful and is projected to significantly increase overall stem density in
MY3 when added to the formal stem count. Pockets of invasive species across the site
were successfully treated in MY2 to reduce new and persistent populations. One minor
easement encroachment was observed.
The following items or highlights from the MY2 Report were noted:
1. The low stem density areas identified in MY1 and supplementally planted in MY2
will continue to be closely monitored. Noted.
2. Adaptive management actions had little effect on improving Wetland K hydrology.
No action was taken in MY2 to assess Wetland D represented by failed GWG 3
and an at -risk area will be delineated in MY3. Additional groundwater gages will
be installed in Wetland D and K to aid in potential adjusted wetland boundary
determinations. Noted.
3. There were no bankfull events recorded for any restoration or enhancement I
streams at the Site in MY2. It is likely that the normal bankfull criteria may need
to be relaxed on this Site, given the amount of forested acreage in the site
watershed and channel and valley morphology. Wildlands plans to enhance their
gage setup on the smaller tributary streams to better understand and report on
the rainfall -runoff response experienced by Site streams in MY3. Noted.

-2-
4. A section of Chinese privet (Ligustrum sinense) resprouts in forested areas along
UT5, UT7, and East Buffalo Creek will receive chemical treatment in MY3 as a
scheduled follow-up to MY1 treatment. Noted.
As per last year's recommendation, due to the amount of planting required across the
site and subsequent monitoring, I continue to recommend that 33% of the stream
credits due for MY 2 release (Milestone 4) be withheld until the vegetation performance
criteria is met; possibly as soon as Milestone 5/MY3 credit release. In other words I
recommend that only 216.2 of the requested 324.3 SMU be released at this time
especially since all credits scheduled for release last year were released. The trend is
encouraging when the supplemental plants are counted but even with supplementally
planted species, the mobile plots failed to meet the vegetation performance criteria.
Erin Davis, USACE (April 7, 2023):
1. An encroachment area was mentioned in the cover letter and shown on the
CCPV. It was identified as observed. This encroachment was not described in
the report narrative. What type of encroachment occurred? Has it been
addressed? If so, how?
2. Please provide a description of the crest gauge adjustment, including old and
new elevation levels, in the MY3 report.
3. The GWG2/Wetland K at -risk area is shown on the CCPV, but the delineated
acreage is not provided in the report. Please include this information in the MY3
report.
4. If approximate locations of the two new wetland gauges were known it would've
been helpful to show them as pending installations on the CCPV.
5. Overall, the report provided a nice level of detail, including items on the CCPV,
supplemental planting tables, good photos, and responses to previous report
comments.
Steve Kichefski
Mitigation Project Manager
Regulatory Division