20140338 Ver 1_IRT Response Letter - 8-3-15_20150825

Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609 1
August 20, 2015

Ms. Andrea W. Hughes
Special Projects Manager
Wilmington District, Regulatory Division
U.S. Army Corps of Engineers
11405 Falls of Neuse Road
Wake Forest. NC 27587

RE: Maney Farm Mitigation Project – IRT Comments
Maney Farm Mitigation Site (DMS #96314)
Cape Fear 03030002, Chatham County, NC

Dear Ms. Hughes,
Thank you for compiling and providing comments on the Maney Farm Draft Mitigation Plan dated May
1, 2015. Wildlands has reviewed the comments, revised the plan and enclosed the Final Mitigation Plan.
We have provided a response to several of the comments below. For your convenience, the comments
are reprinted with our response in italics.
General Comments
Ginny Baker, DWR: Overall DWR found the planting plan to be appropriate for this site. DWR
recommends removing red maple (Acer rubrum) from the planting plan as this species will recolonize
easily on its own. DWR also recommends diversifying the one mid-story species proposed for the
supplemental understory planting plan as American hornbeam (Carpinus caroliniana) is currently
proposed at 50%. Perhaps this could be reduced by 10% and another mid-story species such as
American holly (Ilex opaca), Dogwood (Cornus florida), hop hornbeam (Ostrya virginia), or red cedar
(Juniperus virginia) which already occurs on the site, could be added.
The percentage of American hornbeam has been reduced to 40%. American holly (Ilex opaca),
Dogwood (Cornus florida), hop hornbeam (Ostrya virginia) and red cedar (Juniperus virginia) typically
have low survival rates when planted. For this reason, these species were not utilized in the planting
plan for the Maney Farm Mitigation Site. Red buckeye (Aesculus pavia) was included in the planting
list to increase plant diversity.
Ginny Baker, DWR: During the April 11, 2014 field meeting there was discussion about planting
understory species in the areas under mature canopy that had been damaged by cattle however there
was understandable concern about survival rates. The proposal calls for planting understory species at a
lower rate; 300 stems/acre which is logical. It would be helpful to mention in the mitigation plan and
future monitoring reports that the planted understory species are not expected to have the same
success rate of 320 stems/acre at year three and 260 stems/acre at year 7 (or average height of 10 feet)
as was discussed at the field meeting. It would also be helpful to indicate which vegetation plots on
Figure 11 will occur in the shrub/mid-story planting zone area.
We appreciate this comment and reviewed the meeting summary from the IRT field site visit from
April 11 2014. That summary indicated that the group agreed that project success should not be tied

Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609 2
to survival of planted understory species. Wildlands will monitor the understory species but no
success criteria are proposed for these species. The monitoring will be for informational purposes
only. We have changed the mitigation plan accordingly.
Andrea Hughes, USACE (Appendix 7 - Jurisdictional Determination): Please provide a map depicting all
wetlands located within the boundaries of the mitigation site.
Appendix 8 (PCN) has been updated to include a figure that illustrates on-site wetlands and a figure
that illustrates impacted wetlands.
Andrea Hughes, USACE: A surface water gauge should be installed on all intermittent reaches to
document at least 30 days of continuous flow.
As we discussed by phone on July 23, your intent is not that we install gauges to verify intermittent
status but to verify that intermittent flow is not disrupted by restoration activities. Since we are only
raising the beds of the very downstream portions of UT3 and UT4 (and therefore should not affect the
inflow from groundwater), we prefer to only install gauges on restoration reaches (UTSF and UT5),
including the intermittent reach (Reach 1) of UTSF, as described in the response to a similar comment
under Section 4 below.
Andrea Hughes, USACE: Temporary and permanent impacts to existing wetlands and streams must be
accounted for in the PCN and the loss or conversion of those waters must be replaced on-site. Please
include a map depicting the location of all impacts with the PCN.
A PCN and supporting information and figures have been included with the Final Mitigation Plan.
Appendix 8 (PCN) has been updated to include a figure that illustrates on-site wetlands and a figure
that illustrates impacted wetlands. While there are minor wetland impacts (0.2 acres), these impacts
primarily consist of minor floodplain grading within wetland areas that have already been
significantly impacted due to cattle trampling and grazing. These impacts will be more than offset by
the creation of floodplain wetlands and vernal pools on the site.
Andrea Hughes, USACE: Please submit a map depicting the approximate locations of monitoring
stations with the final mitigation plan.
Figure 11 has been updated with all of the monitoring stations.
Section 1.0 Restoration Project Goals and Objectives
No comments provided for this section.
Section 2.0 Project Site Location and Selection
Andrea Hughes, USACE (Page 2, Section 2): Please provide latitude/longitude (decimal degrees) with the
site location.
The Mitigation Plan has been updated to include the latitude and longitude associated with this site.
Section 3 Site Protection Instrument
Andrea Hughes, USACE (Appendix 2): Please provide a copy of the site protection instrument with the
final mitigation plan.
A copy of the site protection instrument template and recorded plat has been enclosed with the Final
Mitigation Plan. Closing on the easement is scheduled for August and we will provide the final site
protection instrument once the closing is complete.

Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609 3
Section 4 Baseline Information – Project Site and Watershed Summary
Ginny Baker, DWR (Section 4.8): The restoration reaches along UT to South Fork Cane Creek (UTSF) are
described as having more lateral damage from cattle trampling as opposed to vertical incision although
page 33, Section 9.6.1, paragraph 1 did say the stream beds would be raised through Priority 1
restoration to reconnect the stream with the floodplain. The upper section of UTSF is rated as
intermittent and has the potential to lose existing baseflow if the stream bed is raised too much. One
monitoring well should be installed at the upper end of the thalweg of Reach 1 UTSF if the streambed is
raised during stream construction. Baseflow should be recorded for a minimum of 30 days during a
normal precipitation year.
As discussed above under General Comments, a monitoring gauge station (pressure transducer
affixed to stream bed and crest gauge) will be installed within the intermittent reach of UTSF to verify
that baseflow occurs for a minimum of 30 days following construction activities and to record the
occurrence of bankfull events. Section 12.1.4 has been revised to reflect monitoring of the
intermittent reach of UTSF following construction.
Section 5 Regulatory Considerations
No comments provided for this section.
Section 6 Reference Sites
Andrea Hughes, USACE (Page 20, Section 6.2): The second paragraph states that reference site UT to
Cane Creek is classified as a Rosgen E4 stream type. This is not consistent with the information provided
in Table 10.
Thank you for catching this. Table 10 has been updated to reflect the Rosgen E4 classification.
Section 7 Determination of Credits
No comments provided for this section.
Section 8 Credit Release Schedule
Andrea Hughes, USACE (Page 18, Section 5.2): The reserve credit percentage stated in this section (15%)
is not consistent with Table 12.
The Mitigation Plan has been revised to reflect that 10% of the site’s total stream credits will be
reserved and not released until two bankfull events have been recorded in separate years, the channel
has been documented as stable and the performance criteria have been met.
Section 9 Project Site Mitigation Plan
Andrea Hughes, USACE (Page 26, Section 9.2): According to the Technical Document dated October 30,
2013, and field notes from the April 11, 2014 site visit, Reaches UT 1, UT2, UT3, and UT4 were
determined to be stable and proposed for enhancement (E2) at a ratio of 2:5 to 1. The draft mitigation
plan indicates that a total of 633 linear feet of these tributaries will be changed to E1 at a ratio of 1:5 to
1 in order to “stabilize these reaches and connect them to UTSF”. E1 ratios should not be applied to
stable reaches for activities associated with the restoration of UTSF.
The reaches identified as E1 are proposed along degraded portions of channels that flow into UT to
South Fork Cane Creek. These tributaries do have stable reaches upstream of the reaches now

Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609 4
designated as E1. These more stable sections (E2 reaches) will benefit from cattle exclusion and
planting. The proposed E1 approach was developed during the assessment and design process along
reaches that could benefit from restoration activities (plan, profile and section improvements). These
E1 reaches are moderately incised, trampled by cattle and exhibit instability in the form of headcuts
and unstable banks. Restoration of these reaches is necessary to support stable confluences with the
restored UT to South Fork Cane Creek. As you agreed during our phone conversation on July 23, these
restoration activities will require more work and therefore justify a 1.5 to 1 credit ratio.
Andrea Hughes, USACE (Page 35, Section 9.6.2): Please note that typically we do not recommend
inclusion of Red Maple in planting plans as this species may currently be present onsite. At this time we
are not asking that the species be removed from the planting plan, however please be aware that
adaptive management may be required if Red Maple is determined to be a dominant species at any time
during the monitoring period.
Red Maple has been removed from the planting list in Table 16 and within the construction
documents. River Birch will be planted at a higher density (+5%) to account for the removal of Red
Maple.
Section 11 Performance Standards
Andrea Hughes, USACE (Page 36, Section 11.0): The mitigation plan states: “If all performance criteria
have been successfully met and two bankfull events have occurred during separate years, Wildlands
may propose to terminate stream and/or vegetation monitoring.” This statement must be amended to
indicate that this may only be proposed after Year 5 monitoring.
The Mitigation Plan has been amended to allow Wildlands to terminate stream and vegetation
monitoring only if the stated conditions are met and following the conclusion of the fifth monitoring
year.
Andrea Hughes, USACE (Page 37, Section 11.1.6): The plan states that areas within the riparian zone
which currently support mature overstory will be enhanced through a supplemental planting of shade
tolerant shrub species spaced at an initial density of 300 plants per acre. Please provide a vegetation
performance standard for these areas.
As we discussed during the July 23 call, the shade tolerant understory species will be monitored but
results will not be tied to project success. Therefore, no performance standard has been proposed.
Section 12 Monitoring Plan
Andrea Hughes, USACE (Page 40, Section 12.1.6): The plan indicates that 14 monitoring plots will be
installed within the restoration and enhancement areas to monitor the survival of the planted trees. In
the areas that will be enhanced through supplemental planting of shrub species, we recommend
monitoring of the existing tree species as well as planted shrub species.
Supplemental plantings will be monitored through similar methods used to monitor typical canopy
species. Visual assessments of the surrounding ecosystem will document the condition of the existing
vegetation communities within these areas. No additional monitoring of existing tree species is
proposed.
Section 13 Long-Term Management Plan
Andrea Hughes, USACE (Page 40, Section 13.0): This section should include a list of long-term
management activities required for site sustainability, annual cost for each activity, the party

Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609 5
responsible for conducting these activities, and details regarding the funding of these activities. If no
long-term management activities are anticipated for this site, please include a statement to this effect in
the mitigation plan along with an explanation.
The following text has been added to the mitigation plan: “The design of UT to South Fork Cane
Creek and associated tributaries have been modeled after natural, functioning, and self-sustaining
stable stream systems using natural materials to reinforce stability. This design approach along with
the best available construction methods will provide for stability while on-site vegetation matures.
This approach is intended to promote a self-sustaining stream system and eliminate the need for
long-term management activities. Thus, no long-term management activities are anticipated for this
site. The mitigation site will remain in private ownership and will be protected with a conservation
easement based on the Full Delivery Conservation Easement model dated July 2011. The State will
serve as the Grantee and will be responsible for inspecting and enforcing the CE following approval of
the Final Mitigation Plan.”
Section 14 Adaptive Management
Andrea Hughes, USACE (Page 41, Section 14.0): In the event that a component of the mitigation site
fails to achieve performance standards, DMS should notify the Corps and work with the Corps and the
IRT to develop contingency plans and remedial actions. Nationwide 27 permit general conditions do not
specify USACE notification for corrective actions. Please remove this statement from Section 14.0.
This section of the Mitigation Plan has been updated to remove reference to the Nationwide 27
permit.
Please let me know if you have any additional comments.
Sincerely,

Jeff Keaton, Project Manager