20181461 Ver 1_Mitigation Plans_20230914 (2)

Middle Neuse Stream and Wetland Umbrella Mitigation Bank
SAW-2017-02019

Agency Comments (black) – received October 27, 2022
Sponsor Responses (red)

Comments are based on Revision 4 Submitted May 27, 2022 and the follow up May 2023 IRT Site visit.
Submitted with Revision 5 (September 2023).

Prepared by Kimley-Horn (Jason Claudio-Diaz and Tara Allden).

The Sponsor and KH team recognize the length of time between the previous and current submittal. Please note
that the mitigation plan documents have been revised based on comments received and responded to here as well
as additional site visits.

General Comments:
Kim Isenhour, USACE:
1. Please submit a PJD request to the Washington Field Office and submit the revised draft mitigation plan
after the field visit with the Corps. We cannot agree to wetland credit ratios until we have the signed PJD.
Response: Delineation Concurrences have been received for Craven 26 and Craven 30. The Delineation
Concurrence request has been submitted for Beaufort 56.
2. Please ensure that the comments provided in the last draft mitigation plan review (October 2019) are
addressed in the revised draft plan, particularly comments pertaining to long-term management and financial
assurances.
Response: The fee-simple title will be transferred from WY to WNR prior to filing of the conservation
easement. WNR does oversee timber harvest on easement lands, however, there will be no timber production
once the easement is filed.
3. Please expand the section on the Endangered Species Act compliance. Specifically, please provide
documentation on the RCW SLOPES procedures if either of these counties fall within the RCW review area.
Additional information can be found at www.fws.gov/office/eastern-north-carolina/project- planning-and-
consultation, where you will find links to the RCW Project Self-Certification Letter and the Project Review
Letter for the FWS.
Response: The endangered species section for each site has been modified.

Beaufort 56:
Kyle Barnes, USACE:
1) Beaufort 56 - Potentially southern half of the site does not contribute hydraulically. Fig. 7 indicates that
hydrology south of access road is contributing but site drains to a canal system that discharges into the lowest
portion of the restoration area.
Response: Noted, however there is 88 acres of drainage area to the top of the proposed reach and 307 acres
at the road. This is enough drainage area to sustain the proposed streams.
2) According to LiDAR the majority of the hydrology drains away from the southern portion of Reach 1 and
half of Reach 2.
Response: The drainage areas are shown on figure 7 as mentioned in the response above. A lot of the
drainage does drain to the southern portion of the site however, the project is proposed to begin where the JD
call is on reach 1 where there is 88 acres of drainage area.
3) The watershed map needs to be re-evaluated. LiDAR indicates the Northern half of R1 flows off project to
Gorham Swamp along the eastern side of the easement area. Hydraulically the plan loses almost half of the
contributing hydrology which will make stream formation difficult.
Response: I believe you may be interpreting the shading incorrectly. The green color in the lidar indicates a
higher elevation. The higher elevation and the ditching all contribute drainage area to these reaches. The lidar
shading on figure 7 has been flipped to be more intuitive.
4) How is P1 achieved at R3 if the ditch flow is maintained off site according to how the ditch plugs are
designed.
Response: Ditches 1 and 2 are shallow ditches and will connect with the proposed stream without altering the
function of the ditches. Ditch 3 will continue to flow under the road in an existing culvert and will connect to the
constructed stream (reach 3) with a shallow swale. Ditch 4 will continue to flow on the south side of the gravel
road and does not connect to reach 3 and will continue to function as it does currently. Ditch labels and flow
arrows have been added to figure 10 and sheet 17.
Travis Wilson, NCWRC:
• The proposed vegetation community description should reference NHP’s Classification of Natural
Communities (4th approximation). The provider should reference the appropriate community type for the
planting zones with a planting list that matches the community type. Due to availability concerns the provider
may want to include additional appropriate species that may be included in the planting zone.
Response: The vegetative community descriptions have been modified to incorporation the NHP community
descriptions. Species lists have also been modified to provide greater diversity and to incorporate NHP
community species and plant availability.
• The new culvert at approximately Station 51 on Reach 2 is shown at 1% grade. This is significantly steeper
than the upstream and downstream channel slope. For a new replaced culvert it is unclear why the culvert
was not set on the existing channel slope. Oversteepening culverts compared to the channel slope often
results in the lack of bedload retention in the culvert, scour at the outlet, and/or altered flow conditions that can
effect aquatic organism passage.
Response: The culvert slope has been updated to 0.5% which is the minimum suggested for all crossings.
• I did not see a culvert design detail in the plans, that should be provided
Response: A culvert detail has been added to the plans.
• Reach 2 at this location has a channel width of 5’ and flood plain width of almost 23’. The crossing shows a
single CMP of 48”. This size may be adequate for normal flow, however why are floodplain pipes not
included?
Response: Two 18" floodplain culverts have been added to the plan.
Erin Davis, NCDWR:
1. Page 5, Table 1 – The UT2 and UT3 existing and proposed lengths do not match Tables 7 and 12. Please
QAQC.
Response: Tables 1, 7, and 12 have been updated along with table 9.
2. Page 22, Reach 3 – Section 3.6 (page 13) mentions 550 feet of priority 2 restoration. Please QAQC.
Response: The lower 550' of Reach 3 is a transition zone back to the existing channel. The text and figure 10
have been updated.
3. Page 24, Wetland Work Plan -

a. How was a 75-ft setback from proposed wetland credit areas to ditches to remain open determined?
Was hydrologic modeling (e.g., drainmod) performed to support that the setback distance is sufficient to
combat the influence of the ditch drainage effect? If not, DWR recommends looking into it (and including
the data in the plan appendices).
Response: Modeling was not expressly done. The limits of wetland credit areas were placed based on the
presence of hydric soils, topography, and professional judgment. The width of the wetland mitigation area
varies.
b. The text notes that WA-3 is adjacent to a headwater restoration, please identify the headwater reach.
Has any data collection or analysis (e.g., hydrologic modeling) been conducted to support that wetland
hydrologic improvement 800 feet away from the PS-R2 is feasible as indicated for WA-2?
Response: WA-3 is adjacent to Priority 1 restoration; the narrative has been updated. The proposed WA-2
boundary is based on a elevation lower than 52 feet. Eliminating incision in PS-R2 and removing the beds
and rows will restore hydrology in this area that is supported by hydric soils.
4. Page 24, Vegetation Plan -
a. The text mentions three planting zones, but there is no subsection discussion or table for Zone 3.
Please clarify. Sheets 24 & 25 include a Zone 3.
Response: The narrative was updated to match the planting zones shown in the plans.

b. Also, I am confused by the buffer width table be included in this section. I'm assuming Table 10 is
indicating the minimum buffer width per reach and not the actual buffer width provided by the project
easement. And the entire easement should be addressed in the vegetation plan. Based on Design Sheet
25, all areas within the easement are proposed to be planted. Please also note that all planted areas
within the easement should be included in the vegetative monitoring (not just a designated "buffer"
subarea).
Response: Table 9 has been updated to be minimum buffer widths. The actual easement and buffer
widths vary greatly. The entire easement will be planted and included in the vegetative monitoring.
c. DWR was glad to see individual species to be planted capped at 20 percent. However, we would
encourage adding species for greater habitat diversity, including shrub and understory species that can be
exempt from the vigor standard.
Response: The species lists for planting have been updated to incorporate NHP community descriptions
and to provide for greater community diversity.
5. Page 29, Section 8.1 - How was the 74.9-acre planted area determined? Please confirm that all the
headwater reaches are included in proposed vegetation monitoring.
Response: Headwater reaches are included in vegetative monitoring. See question 4.b.
6. Page 32, Table 18 – DWR commented in the June 2020 submittal that we recommend a 10% hydroperiod
threshold for all wetland credit areas. Without a field verification, preferably a soils delineation by a licensed
soil scientist, and specific boundaries of each soil series present within proposed credit areas clearly mapped,
DWR does not support any minimum/target saturation below 10 percent.
Response: The hydroperiod has been updated to be 10%.
10. Page 33, Section 8.5 - Please include a redline comparison of as-built to approved mitigation plan design
sheets indicating any field deviations, including changes to plant species and quantities. Please note any new
species will need to be approved by the IRT to count towards vegetation performance standards. Additionally,
please include soil boring data near wetland gauge locations as per the 2016 NCIRT Guidance (this also
applies to Craven 26 & 30).
Response: This language has been added to the section.
11. Figure 8 - DWR encourages the addition of any existing features or structures that currently impede or
fragment the site and that will be addressed/removed as part of the project (e.g., stream crossings, roads,
ditches, berms).
Response: Only one culvert crossing is proposed to remain as it is the main access for a majority of the
property. Floodplain pipes were added to this crossing to improve its hydraulic function.
12. Figure 11 –
a. It would be helpful to callout ditches proposed to remain open on this figure (or another figure).
Response: A ditch plan is shown on sheet 17 of the mitigation plans. This information has been added to
figure 10 as well.

b. All headwater and intermittent reaches should have flow gauges. Please confirm flow gauges are
located in the upper 1/3 of each reach as previously requested. Additionally, the hydrologic connection
across a headwater valley is important, and in order to demonstrate that functional uplift we have had
providers propose to install and monitor gauge/well transects.
Response: Added gage transects on the headwater reach (Pollard Swamp - Reach 1).
c. Only 11 wetland wells are proposed to represent 51.4 acres of restoration credit at 1:1 ratio. This total is
less than what is proposed at Craven 30 for 13 acres. Please reassess and propose additional wetland
well locations.
Response: 9 additional wells have been proposed. These wells will be placed as shown in Figure 11.
d. DWR will need to review a revised monitoring figure before supporting the number and location of
monitoring stations.
Response: A revised monitoring figure is included.
13. Sheets 9-11– Areas proposed as floodplain depressions appear to overlap wetland credit areas. Please
be cautious with these areas, particularly pools with a 16-inch depth. All wetland restoration credit areas
should meet vegetative and hydrologic performance standards.
Response: All proposed floodplain depressions have been removed or will be limited to less than 16-inch
depths. These areas are meant to mimic microtopography and are not proposed for wetland mitigation credit
specifically. If they are located within a proposed wetland mitigation area, they will be included in the
vegetative and hydrologic performance standards of that wetland.
14. Sheet 12 – What is the setback distance of the proposed easement and credit areas from the roadway? Is
there any risk of impact or encroachment from future road maintenance?
Response: The CE is set at approximately 35' from the edge of the road on both sides to reduce the risk of
impacts from road or ditch maintenance.
15. Sheet 15 – The headwater restoration of UT2 appears to show a bit of sinuosity. Please confirm that the
reach credit total was determined using valley length.
Response: UT2 has been removed from the project per feedback from the recent site visit with the IRT.
16. Sheet 17 – DWR appreciates the inclusion of this plan sheet. Please callout any ditches within, on the CE
boundary and immediately adjacent that are proposed to remain open.
Response: Each ditch has been labeled to indicate proposed condition.
17. Sheet 24 – The plant zone tables do not match tables in the plan narrative. DWR prefers the species
diversity on the Sheet 24 tables, but please make tables consistent. Also, please identify the proposed
temporary seed species/mix.
Response: The narrative was updated to match the planting zones shown in the plans. A temporary seed mix
table has been added to sheet 4 and the permanent riparian seed mix has been labeled.
18. Sheet 25 – Based on this sheet, all areas within the easement will be fully planted. If there are areas
where only supplemental planting is proposed, please add a figure/sheet distinguishing proposed full vs.
supplemental planting.
Response: The existing hardwood areas have been added as supplemental planting areas and are shown on
sheet 25. This zone will be called zone 4 and will be the same species as Zone 2 but with a lower density as
noted in the narrative.
19. Detail Sheets - Please include a typical detail for the proposed culvert crossing.
Response: A culvert detail has been added to the plans.
20. What is the PJD status? Please note DWR's comment from the June 2020 submittal: "DWR will require a
JD or preliminary JD to provide final comments for the draft mitigation plan".
Response: The PJD (or delineation concurrence) is in process. Site visits have been completed and changes
noted in the field have been incorporated.

Craven 26:
Kyle Barnes, USACE:
1) Figure 7 Watershed Map: According to LiDAR the restoration site gets no hydrologic contribution from the
land area south and west of the unnamed road that bisects the Watershed map running from west of the #1 to
the north. This map needs to be revised indicating the reduced watershed.
Response: The figure has been updated and the drainage areas for locations 1, 4, and 6 have been updated.
2) How will the instream pond be addressed at the road between WA-5 and UT-1 Reach 3. Is this a pond that
is utilized for wildfire control and if so will Weyerhaeuser require it to remain?
Response: The pond will be removed and if it is replaced it will be set outside of the CE.
3) The plan needs to be more specific as to where existing ditches will be plugged. I have hydrology concerns
with this site.
Response: Significant ditch plugging is not proposed on this site. Hydrology will be improved by raising stream
beds of incised reaches. The ditch on UT2 - Reach 2 will be plugged as it enters the reach. A plug has been
added to figure 10 and to the plans.

Travis Wilson, NCWRC:
• The proposed vegetation community description should reference NHP’s Classification of Natural
Communities (4th approximation). The provider should reference the appropriate community type for the
planting zones with a planting list that matches the community type. Due to availability concerns the provider
may want to include additional appropriate species that may be included in the planting zone.
Response: The vegetative community descriptions have been modified to incorporation the NHP community
descriptions. Species lists have also been modified to provide greater diversity and to incorporate NHP
community species and plant availability.
• I did not see a culvert design detail in the plans, that should be provided
Response: Culvert details have been added to the plans.
• The new crossing on UT 1 Reach 2/3 at station 30+77 shows a double CMP of 54”. From the channel
cross-section dimensions provided this would appear to significantly over widen the channel. Also the
crossing is not shown on the profile.
Response: The base flow will be directed into one of the 54" pipes. The other pipe will act as an floodplain
pipe. A detail has been added to the plans to clarify.
Erin Davis, NCDWR:
1. Please QAQC the plan narrative. There are multiple carryovers from the previous version that no longer
apply (e.g., page 9 reference of four tributaries).
Response: Pages 9 and 10 were updated to reference 2 existing tributaries.
2. Page 5, Table 2 - The WA-3 and WA-4 acres do not match Table 14 or text on page 24.
Response: Tabel 14 and page 24 have been updated with the current acres/credits.
3. Page 10, Table 3 - Nearly all of the reach lengths have changed from the previous version, shouldn't the
watersheds at each reach break reflect that? All watershed acres are the same as the previous version.
Response: The reach length revisions were mostly driven by updates to the design layout, however, several of
the watershed have been updated due to updated reaches. Figure 7 has been updated.
4. Page 24, Wetland Work Plan -
a. Please bullet WA-2 information. Please add a rationale for WA-6.
Response: W6 description has been added.

b. This section mentions headwater restoration/enhancement multiple times. Please verify that in
accordance with the 2016 NCIRT Guidance, no wetland credit areas are being proposed within the 100-ft
corridor where the headwater stream is expected to develop (e.g., areas of WA-1, WA-2, WA-3, and WA-
4).
Response: No wetland credits will be generated in the 100-foot buffer that wraps headwater systems. All
headwater reaches have been removed from this site based feedback from the March 24, 2023 site visit
with the IRT.
c. Please provide a detailed species list of existing tree composition for any wetland credit areas proposed
only to be supplementally planted.
Response: Planted species will be comprised of those listed with diversity and density determined in the
field. Species planted will be identified in the as-built document.
d. Has any data collection or analysis (e.g., hydrologic modeling) been conducted to support that
hydrologic improvement 500 feet away from the headwater valley is feasible as indicated for WA-2 and
WA-3?

Response: WA-2 is adjacent to restoration where the incised channel will be raised. The proposed WA-2
boundary is based on a elevation lower than 37.75 feet. Eliminating incision in UT2-R2 with priority 1
restoration and removing the beds and rows will restore hydrology in WA-3. The proposed boundary for
WA-3 is based on an elevation lower than 37.5 feet.
e. Based on information provided and proposed improvements from supplemental planting and
headwater/stream restoration, DWR does question whether the functional uplift justifies a 1:1 restoration
ratio.
Response: All headwater restoration reaches have been removed. Wetland enhancement areas are
proposed at 3:1.

5.Page 24, Vegetation Plan -
a. The text mentions three planting zones, but then the buffer and wetland zones are later combined.
Please clarify.
Response: Text updated to reflect 4 planting zones.

b. Also, I am confused by the buffer width table be included in this section. I'm assuming Table 10 is
indicating the minimum buffer width per reach and not the actual buffer width provided by the project
easement. And the entire easement should be addressed in the vegetation plan, either through proposed
planting or supplemental planting, or assessed as already containing an appropriate community/habitat
cover type and identified as not within a proposed planting zone. Based on Design Sheet 27, the entire
easement is proposed to be planted. Please also note that all planted areas within the easement should
be included in the vegetative monitoring (not just a designated "buffer" subarea).
Response: Table updated to be minimum buffer widths. The actual easement and buffer widths vary
greatly. The entire easement will be planted and included in the vegetative monitoring.
c. DWR was glad to see individual species to be planted capped at 20 percent. However, we would
encourage adding species for greater habitat diversity, including shrub and understory species that can be
exempt from the vigor standard.
Response: The species lists for planting have been updated to incorporate NHP community descriptions
and to provide for greater community diversity.
6. Page 29, Section 8.1 - How was the 70-acre planted area determined? Sheet 27 shows the entire 148-acre
easement being planted. It would be helpful to have an additional figure or design sheet showing a breakdown
of full planting, supplemental planting, and no planting areas proposed within the easement.
Response: The full easement will be planted. Planting plans have been included in the drawings. A note was
added to the mitigation plan figure indicating that the full easement area will be planted.
7. Page 30, Section 8.2 - In order to receive wetland restoration credit, hydrologic improvement must be
demonstrated.
Response: The text has been revised.
8. Page 33, Section 8.5 - Please include a redline comparison of as-built to approved mitigation plan design
sheets indicating any field deviations, including changes to plant species and quantities. Please note any new
species will need to be approved by the IRT to count towards vegetation performance standards.
Response: Text added.
9. Figure 7 - Please update subwatersheds based on current proposed tributaries and reaches.
Response: Figure 7 has been updated.
10. Figure 8 - DWR encourages the addition of any existing features or structures that currently impede or
fragment the site and that will be addressed/removed as part of the project (e.g., stream crossings, roads,
ditches, berms).
Response: This site does not have extensive ditching. The two major crossings that exists within the mitigation
area is proposed to be upsized and floodplain culverts will be added.
11. Figure 11 - DWR would like to review a revised monitoring figure based on responses to comments
regarding wetland credit areas and planting zones/areas.
Response: This figure has been updated.
12. Design Sheets - Wetland credit areas and proposed stream areas appear to overlap. Please confirm that
proposed stream and headwater valley credit areas have been subtracted from surrounding proposed wetland
credit areas.
Response: Wetland credits will not be generated the required headwater buffer areas. All figures and
calculations have been updated.
13. Sheet 26 - Please identify the proposed temporary seed species/mix.
Response: The tables have been updated.
14. Detail Sheets - Please include a typical detail for proposed culvert crossing(s).
Response: Culvert details have been added to the plans.

15. What is the PJD status? Please note DWR's comment from the June 2020 submittal: "DWR will require a
JD or preliminary JD to provide final comments for the draft mitigation plan".
Response: The Delineation Concurrence has been approved.

Craven 30:
Kyle Barnes, USACE:
1) Concerned that there is a lot of hydrology dependance placed on the watershed east of Clarks Road.
Response: There is a large culvert under Clarks Road that is not planned to be modified. The upper part of the
watershed will continue to be connected to the mitigation reaches as it is currently.
2) The project involves a lot of P2. Concerned that the area has very little slope and the applicant will only be
creating wetland areas and not stream.
Response: Only UT1 Reach 2 is proposed as Priority 2 and it’s because it is a transition reach after the stream
enhancement. The stream slope will match the valley slope.
Travis Wilson, NCWRC:
• The proposed vegetation community description should reference NHP’s Classification of Natural
Communities (4th approximation). The provider should reference the appropriate community type for the
planting zones with a planting list that matches the community type. Due to availability concerns the provider
may want to include additional appropriate species that may be included in the planting zone.
Response: This change has been made.
• I did not see a culvert design detail in the plans, that should be provided
Response: Culvert details have been added to the plans.
• The new crossing on UT 1 Reach 2/3 shows a single CMP of 54”. This size may be adequate for normal
flow, however why are floodplain pipes not included?
Response: Two 18" floodplain pipes have been added to the crossing.
Erin Davis, NCDWR:
1. Page 5, Table 2 – Please add a credit ratio column to Table 2.
Response: Table 2 has been updated with the credit ratio.
2. Page 19, Reference Wetlands – Please update text based on currently proposed wetland credit areas along
UT1-R2 and UT-R3.
Response: The text has been updated with the correct reaches.
3. Page 23, UT1-Reach 2 – Should the first sentence be rephrased to reference Reach 3 as priority 1
restoration and Reach 2 as priority 2 restoration?
Response: The text was updated. Reach 3 is priority 1.
4. Page 24, Wetland Work Plan -
a. Table 9 – The current standard wetland preservation ratio is 10:1. Please provide additional justification
for a 7:1 ratio. Based on information provided, DWR believes the 10:1 ratio is more appropriate.
Response: The preservation credit ratio has been changed to 10:1.
b. Should the wetland approach description be titled for both enhancement and restoration?
Response: The title has been updated to include restoration.

c. Has any data collection or analysis (e.g., hydrologic modeling) been conducted to support that
hydrologic improvement 200 feet away from the UT1-R3 is feasible as indicated for WA-2? The functional
uplift from full planting and hydrologic improvement must be proposed in order for DWR to support a 1:1
restoration ratio.
Response: The area of WA-2 is low lying and within the topographic break that is wet in areas that are not
affected by deeply incised channels pulling groundwater. The inclusion of this area as restoration is based
on the hydric soils present, adjacent wetland communities, and professional judgment.

d. WA-3 is proposed along the priority 2 stream restoration length of UT1-R2. Will hydric soils be removed
to cut P2 stream benches? Is there a drainage effect concern with proposing wetland credit within or
adjacent to P2 bench cuts? Please show on a figure where P2 benches overlap proposed wetland credit
areas and indicate if/where grading more than 12 inches is proposed. Depending on the extent of soil
manipulation/removal, wetland creation credit may be more appropriate.
Response: UT1 - Reach 2 transitions from Priority 2 to Priority 1 as you move downstream. At the point
where WA-3 begins there will be less than 12 inches of cut required for the stream.
5.Page 24, Vegetation Plan -
a. The text mentions three planting zones, but then the buffer and wetland zones are later combined.
Please clarify.
Response: Text updated to reflect 4 planting zones.

b. Also, I am confused by the buffer width table be included in this section. I'm assuming Table 10 is
indicating the minimum buffer width per reach and not the actual buffer width provided by the project
easement. And the entire easement should be addressed in the vegetation plan. Based on Design Sheet
26, all areas within the easement are proposed to be planted except the wetland preservation area WA-1.
Please also note that all planted areas within the easement should be included in the vegetative
monitoring (not just a designated "buffer" subarea).
Response: Table updated to be minimum buffer widths. The actual easement and buffer widths vary
greatly. The entire easement will be planted and included in the vegetative monitoring.
c. DWR was glad to see individual species to be planted capped at 20 percent. However, we would
encourage adding species for greater habitat diversity, including shrub and understory species that can be
exempt from the vigor standard.
Response: The planting plan has been revised to include greater species diversity.
6. Page 27, Table 14 – Please update table acres and associated credits to reflect what is currently being
proposed.
Response: Table has been updated.
7. Page 29, Section 8.1 - How was the 48.5-acre planted area determined? Please confirm that the planted
buffers of all the headwater reaches are included in proposed vegetation monitoring.
Response: All planted areas will be included in vegetative monitoring.
8. Page 30, Section 8.2 - In order to receive wetland restoration credit, hydrologic improvement must be
demonstrated.
Response: This section has been revised to include hydrologic improvement for areas of restoration.
9. Page 32, Table 18 – Based on Figure 6, it appears that nearly all proposed wetland credit areas are located
within the Masontown (MM) soil series. Without a field verification, preferably a soils delineation by a licensed
soil scientist, and specific boundaries of each soil series present within proposed credit areas, DWR does not
support a minimum/target saturation below 10 percent for years 3-7.
Response: Agreed, target saturation has been changed to 10%.
10. Page 33, Section 8.5 - Please include a redline comparison of as-built to approved mitigation plan design
sheets indicating any field deviations, including changes to plant species and quantities. Please note any new
species will need to be approved by the IRT to count towards vegetation performance standards.
Response: This language has been added to the section.
11. Figure 8 - DWR encourages the addition of any existing features or structures that currently impede or
fragment the site and that will be addressed/removed as part of the project (e.g., stream crossings, roads,
ditches, berms).
Response: This site does not have extensive ditching. The only major crossing that exists within the mitigation
area is proposed to be upsized and floodplain culverts will be added.
12. Figure 11 - DWR would like to review a revised monitoring figure based on responses to comments
regarding wetland credit areas (P2 areas) and planting zones/areas (Headwater reaches).
Response: The monitoring figure has been updated and all headwater reaches have been removed based on
feedback from the March 24, 2023 site visit with the IRT.
13. Sheets 9 & 10 – Areas proposed as floodplain depressions appear to overlap wetland credit areas. Please
be cautious with these areas, particularly pools with a 16-inch depth. All wetland restoration credit areas
should meet vegetative and hydrologic performance standards.
Response: The floodplain depressions have been removed from the plans.
14. Sheet 10 – What is the setback distance of the proposed easement and credit areas from the roadway? Is
there any risk of impact or encroachment from future road maintenance?
Response: The CE was adjusted to be 10' off of the road to allow for road maintenance.
15. Sheet 12 – The headwater restoration of UT2 appears to show some sinuosity. Please confirm that the
reach credit total was determined using valley length.
Response: UT2 has been updated to restoration based on feedback from the March 24, 2023 site visit with the
IRT.
16. Sheet 25 – The Zone 2 plant table does not match Table 12. DWR prefers the species diversity in the
Sheet 25 table, but please make tables consistent. Also, please identify the proposed temporary seed
species/mix.
Response: The narrative was updated to match the planting zones shown in the plans. A temporary seed mix
table has been added to sheet 4 and the permanent riparian seed mix has been labeled.
17. Sheet 26 – Based on this sheet, all areas within the easement except WA-1 will be fully planted. If there
are areas where only supplemental planting is proposed, please add a figure/sheet distinguishing proposed
full vs. supplemental planting.
Response: No supplemental planting zones are proposed for this site.
18. Detail Sheets - Please include a typical detail for proposed culvert crossing(s).
Response: Culvert details have been added to the plans.
19. What is the PJD status? Please note DWR's comment from the June 2020 submittal: "DWR will require a
JD or preliminary JD to provide final comments for the draft mitigation plan".
Response: The Delineation Concurrence has been approved.

Middle Neuse UMBI
Beaufort 56, Craven 26, and Craven 30 Mitigation Sites
SAW-2017-02019
Beaufort & Craven Counties
May 24, 2023 (8:30am – 2:00pm)

ATTENDEES
Todd Tugwell – US Army Corps of Engineers
Erin Davis – US Army Corps of Engineers
Travis Wilson – North Carolina Wildlife Resources Commission
Maria Dunn – North Carolina Wildlife Resources Commission
Tara Allden – Kimley-Horn and Associates, Inc.
Jason Claudio-Diaz – Kimley-Horn and Associates, Inc.

All Sites
• Change symbol for minimum buffer area to not include the black dot hatch on Figure 10.
• Add ratios to notes in Figure 10 and reduce the amount of text.
• Provide actual and ideal buffer maps as separate figures.
• Consider sediment catches on ditches to capture sediment from offsite if the area is
harvested.
• When discussing the hunt club, it was stated that we need to make sure there are no
permanent structures in easement unless they are written into the mitigation plan,
easement, and figures.
• Any headwater restoration is expected to also develop adjacent wetlands; however, no
wetland credit is given for these wetlands within the 100-foot buffer.
• Easement markings will be required.
• Manager, long term steward and easement holder discussion. Split up of duties and
clear separation of duties.
• Any new sites, such as Craven 1, will be added as modifications to the UMBI.

Craven 30
• Verify easement is setback from roads to allow for maintenance of ditches.
• If there are any hydrologic enhancement wetlands, they will need baseline wells. If
baseline hydrology already meets may need to re-assess.
• Check for utility along Clark's road and adjust easement if needed. (Note, no utility was
observed when this area was visited.)
• Plan on adaptive management for re-emergent pine and invasives throughout
monitoring.
• Emphasize in channel structure and wood for enhancement area.
• 14" max depth on depressions in riparian areas.
• Make sure drainage can reach new stream if restoring to one side of existing.
• Add camera to the center valley in upper third to headwater systems set to take a pic
twice a day to document flow.
• If any prescribed burns will occur on adjacent property, include firebreak around
easement.
• Revise UT5 to be enhancement to JD point. Headwater system doesn’t make sense due
to drainage area and existing soils.
• Revise UT2 to restoration (maximize priority 1).
Middle Neuse UMBI
Beaufort 56, Craven 26, and Craven 30 Mitigation Sites
SAW-2017-02019
Beaufort & Craven Counties
May 24, 2023 (8:30am – 2:00pm)

• UT1-R1 to remain enhancement. Will lay back the banks and provide instream structure.
Large benches are not proposed here because of the culvert/road acting as a hydrologic
control and to limit impacts to the existing buffer.

Craven 26
• Verify drainage area for UT1-R1 and drop headwater restoration if less than 100 acres.
Likely start priority 1 restoration at road as currently proposed as UT1-R2.
• Revise UT2-R1 to enhancement and transition to priority 1 restoration as soon as
possible. Check wetland boundary for WA-2 and WA-3 and make sure the grading
doesn’t affect adjacent wetland boundaries.
• Show specific activity for wetland areas on Figure 10.
• WA-6 is shown as wetland restoration with enhanced hydrology and vegetation. There is
concern that the work proposed will have any effect on that entire wetland area. Revise
WA-6 to be vegetation enhancement only.
• Can the road between UT1-Reach 2 and UT1-Reach 3 be removed?
• Check bottom of UT1-R3 for potential wetland restoration where there are currently
hydric soils. May be able to include wetland restoration inside the 50’ buffer and outside
the 150’ buffer.

Beaufort 56
• Revise UT2 and UT3 to remove headwater restoration due to small drainage areas and
include in wetland restoration area.
• Pollard Swamp – Reach 1 is a good headwater restoration reach.
• Update flow gage locations on Pollard Swamp – Reach 1 in headwater restoration to be
across valley and add a camera. Place one well top and bottom of the reach. Also add
one on each side in valley to assess adjacent wetland hydrology.
• We don’t need as many veg plots in areas that we are not fully planting. We should
place more in field areas and add plots in easements areas that may be outside of the
buffer credit areas. Need to document survival in areas within easement but not
providing mitigation credit.
• Try to save as much existing hardwood buffer as possible on headwater reach (Pollard
Swamp – Reach 1).