[External] Falcon Ridge Draft Mit Plan Comment Responses

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Good afternoon Jamey. I was able to go through the comment responses that were submitted with the Falcon Ridge final mit plan more thoroughly and discuss the project today with both
Maria and Kim. Below are several comments/questions that need to be addressed in more detail before we can consider the mit plan to be final:

1. In my last email (below), DWR questioned the hydroperiod for the wetlands on the site and requested that it be changed to 12%. I concur with this – based on the new soils information,
it appears that most of the wetlands on the site will fall into the Chewacla/Wehadkee complex. Further, per the soils report “soils within the proposed Wetland Creation are similar
to a Chewacla soil, but appear to be trending toward a Wehadkee soil”. Given this, I think it appropriate that the hydroperiod for the site match the recommended 12%, which is the top
of the range for Chewacla and the bottom of the range for Wehadkee. Please adjust the hydroperiod to 12% for all wetlands on the site.
2. Regarding DWRs comments on the addition of wetland areas to the project after the draft mit plan (see comment 3b below), I explained to Maria that this was based on Corps recommendations
for the addition of creation areas and conversion of enhancement area to rehabilitation.
3. A review of the non-standard buffer calculations has raised some questions. The buffer spreadsheet that was submitted does not appear to include the Enhancement III streams (680
linear feet tallied under 5:1 preservation block on the spreadsheet). Was this intentional? Additionally, the buffer spreadsheet is calculated using 6 terminal ends; however, it appears
that three of the streams terminate at ford crossings on the property, which would not count as terminal ends, and a 4th stream ends at the conservation easement boundary but still
within the underlying property, so this stream would also not count. Please revise the calculations to include only 2 terminal ends, or provide a map and further justification why
more than 2 should be considered.
4. DWR specifically noted that the streamflow performance standard for this project should be 90 days. This was a site-specific request intended to account for concerns associated with
this project due to the fact that several of the steams had low DWR Stream Determination Scores, exacerbated by the fact that the site is located within the slate belt. Additionally,
the Corp expressed concerns with both PR 9 and 10, stating that we expect gauge data for these reaches to be perennial in nature, necessary to justify inclusion of these reaches. While
we acknowledge that the 2016 guidance includes a 30-day standard, it is our continued stance that a 90-day standard is more appropriate for this site. Please revise the stream flow
standard for this project to 90 days as requested.
5. Comment 9b by the Corps regarding pre-gauge data does not appear to be addressed. Even though the project’s wetland approach has been changed, the mitigation plan still states that
hydrologic improvements are part of the anticipated functional uplift to enhancement and rehabilitation wetlands on the site. How do you proposed to demonstrate the anticipated uplift
(and associated credit) without baseline data from pre-construction monitoring?
6. Comment 8 by the Corps asked if reference gauges would be used. We strongly recommend the use of reference gauges to help explain discrepancies or problems with gauge data. Please
note that a lack of reference data may make loss of credit more likely if gauges fail to meet performance standards, even due to drought. (As a side note, the justification for not
having reference gauges was weak – just because this is the first bank in the watershed does not provide a reasonable excuse for not taking this step.)

Please revise your mitigation plan and response to comments to address the issues identified about, particularly items 1-4. Once these concerns have been addressed, we should be able
to move quickly to determine the Final Mitigation Plan as complete, and issue the Corps’ intent to approve.

Thank you and let me know if you have any questions,

Todd Tugwell

Chief, Mitigation Branch

Regulatory Division

Wilmington District, USACE

[phone]

From: Tugwell, Todd J CIV USARMY CESAW (USA)
Sent: Tuesday, January 16, 2024 10:43 AM
To: Jamey Mceachran <[e-mail]>
Cc: Davis, Erin B CIV USARMY CESAW (USA) <[e-mail]>; Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>; Isenhour, Kimberly T CIV USARMY
CESAW (USA) <[e-mail]>; Maria Polizzi ([e-mail]) <[e-mail]>
Subject: RE: Time for a quick catch up on a couple of items?

Good morning Jamey. I apologize for the delay on some projects. As you know we are now operating down two staff members, so as you can imagine it is taking us a little longer to get
through everything. I appreciate your reaching out. Below are the status updates as I am aware of them:

1. Beavertail – I will check with Steve on this. I understand there was some question about the project once the buffer plan was withdrawn, but will get back to you on this.

2. Pantera – We received both the final mitigation plan and PCN. I will be reviewing it hopefully this week, at which point we should be able to notify the IRT of the final decision.
For this project I would like to point out that Kim specifically asked that we be provided with RES’ response to comments prior to receiving the final plan – this was to sure that
our comments were adequately addressed. Unless I was not copied on the emails, I am not aware that this was done, so it is possible that upon our review of your response to comments
we may require additional modifications to the final plan prior to our intent letter. As I indicated, I should be able to provide you with a response soon. Lastly with Pantera, I
am not aware that we ever received a draft UMBI for the Neuse 01 bank. Because this site is proposed as the first site with a new bank, we cannot move forward without the UMBI, which
we will also need to review. Lastly, If you would send us a shapefile of the project site (easement boundary), which would help us rather than having to draw the site in our viewer
manually.

3. Falcon Ridge – As with Pantera, Kim asked for the response to comments prior to receiving the final mitigation plan; however, after the final plan was submitted, we went ahead and
distributed the response to comments and did receive some additional comments from DWR. We have received a draft UMBI, but not a final version and we not received a PCN for this site
as of yet. Please note that we don’t consider the plan as complete yet due to these on-going concerns (primarily regarding the soils on site). I have not done a detail review of your
responses yet, but should be able to review them this week and will follow up with additional comments to those we received from DWR, which are below:

a. Chewacla and Wehadkee soils are described in the soil report as the dominant series in the areas of wetland credit. The soil report also includes the following sentence: "Raising
the local groundwater to improve the hydrology of a Chewacla soil should result in a hydroperiod range more like the Wehadkee." However, the hydroperiod proposed is only 10% which is
the low end of Chewacla's range and below the range of Wehadkee. I would propose that if they want to use only one hydroperiod for the entire site, they should use 12% which is in the
range of both soil series. If they prefer to break out the two series and do 10% for Chewacla and 12% for Wehadkee, that would also be fine with me.
b. I also find it somewhat concerning that their proposed wetland credit total has more than tripled from their draft plan to their final plan (0.478 to 1.538 credits) and this is not
explicitly stated in the response to comments. Obviously, I am still new to this, so perhaps this is more normal than I realize, but I would expect that changes between draft and final
are minor and/or in response to comments. Although Kim mentions allowing restoration credit in some areas previously proposed as enhancement, which would account for some of the increase,
it appears that a lot of new wetland credit areas are proposed as creation. Quietly tripling the wetland credits seems like something that should be highlighted and preferably discussed
before the final plan. Why was wetland creation not proposed in the draft plan? I would appreciate greater discussion from the provider about why these are being proposed now. If all
of this stems from the newly completed soils report, it again stresses to me the importance of this being completed prior to the draft plan submittal.

4. Walnut Wood – I’ve reviewed Ben’s email and will consider that email as RES’ official notification to withdraw the project, so no further communication necessary. Sorry that did
not work out, but I appreciate your letting us know so that we can take that off the books.

5. Newman Ranch – noted and thanks for the update.

Kim will be on detail pretty much through the end of February, so please continue to coordinate with myself and Erin for her projects, but I know she is tracking things so please copy
her as well. If you have any other questions regarding project status regardless of the PM, you can always contact me.

Thank you,

Todd Tugwell

Chief, Mitigation Branch

Regulatory Division

Wilmington District, USACE

[phone]

From: Jamey Mceachran <[e-mail] <mailto:[e-mail]> >
Sent: Monday, January 15, 2024 12:58 PM
To: Tugwell, Todd J CIV USARMY CESAW (USA) <[e-mail] <mailto:[e-mail]> >
Subject: [Non-DoD Source] Time for a quick catch up on a couple of items?

Hi Todd,

I know you are very busy this time of year. I was going to call you but figured I should check your schedule and see when you have some time.

I am curious on the plan for project managers for some of our projects and the timelines to expect.

1. We were expecting Catawba ESA Beaver Tail DRAFT Mitigation Plan comments back at the end of the year and haven’t seen them yet. Just curious on the timeline for those.
2. Pantera (Neuse 01 UMBI) – Final Mitigation Plan was submitted mid December and we never saw any email go out to the IRT so were wondering if that had started its official review.

3. Falcon Ridge (Yadkin 03) – Also the FINAL was submitted mid December and we never saw any email go out to the IRT so were wondering if that had started its official review.
4. Walnut Wood… Just wanted to talk through your thoughts on Ben Carroll’s email and who the PM on that project now is.
5. Newman Ranch update (just let you know we are working on the draft)

I am not sure when Kim is coming back from Detail and the plan for Casey so I figured I would start with you and if you need to pass me off to someone else that is okay too!

Thank you and hope you had a great start to the new year!

Jamey

Jamey McEachran, PMP

Regulatory Manager, North Carolina

RES | res.us <Blockedhttp://www.res.us/>

M: 919.623.9889

Restoring a resilient earth for a modern world

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MIME-Version: 1.0

6. Comment 8 by the Corps asked if reference gauges would be used. We strongly recommend the use of
reference gauges to help explain discrepancies or problems with gauge data. Please note that a lack of
reference data may make loss of credit more likely if gauges fail to meet performance standards, even due to
drought. (As a side note, the justification for not having reference gauges was weak – just because this is the
first bank in the watershed does not provide a reasonable excuse for not taking this step.)

Please revise your mitigation plan and response to comments to address the issues identified about, particularly items 1-
4. Once these concerns have been addressed, we should be able to move quickly to determine the Final Mitigation Plan
as complete, and issue the Corps’ intent to approve.

Thank you and let me know if you have any questions,

Todd Tugwell
Chief, Mitigation Branch
Regulatory Division
Wilmington District, USACE
[phone]

From: Tugwell, Todd J CIV USARMY CESAW (USA)
Sent: Tuesday, January 16, 2024 10:43 AM
To: Jamey Mceachran <[e-mail]>
Cc: Davis, Erin B CIV USARMY CESAW (USA) <[e-mail]>; Kichefski, Steven L CIV USARMY CESAW
(USA) <[e-mail]>; Isenhour, Kimberly T CIV USARMY CESAW (USA)
<[e-mail]>; Maria Polizzi ([e-mail]) <[e-mail]>
Subject: RE: Time for a quick catch up on a couple of items?

Good morning Jamey. I apologize for the delay on some projects. As you know we are now operating down two staff
members, so as you can imagine it is taking us a little longer to get through everything. I appreciate your reaching
out. Below are the status updates as I am aware of them:

1. Beavertail – I will check with Steve on this. I understand there was some question about the project once the
buffer plan was withdrawn, but will get back to you on this.

2. Pantera – We received both the final mitigation plan and PCN. I will be reviewing it hopefully this week, at
which point we should be able to notify the IRT of the final decision. For this project I would like to point out
that Kim specifically asked that we be provided with RES’ response to comments prior to receiving the final plan
– this was to sure that our comments were adequately addressed. Unless I was not copied on the emails, I am
not aware that this was done, so it is possible that upon our review of your response to comments we may
require additional modifications to the final plan prior to our intent letter. As I indicated, I should be able to
provide you with a response soon. Lastly with Pantera, I am not aware that we ever received a draft UMBI for
the Neuse 01 bank. Because this site is proposed as the first site with a new bank, we cannot move forward
without the UMBI, which we will also need to review. Lastly, If you would send us a shapefile of the project site
(easement boundary), which would help us rather than having to draw the site in our viewer manually.

3. Falcon Ridge – As with Pantera, Kim asked for the response to comments prior to receiving the final mitigation
plan; however, after the final plan was submitted, we went ahead and distributed the response to comments
and did receive some additional comments from DWR. We have received a draft UMBI, but not a final version
and we not received a PCN for this site as of yet. Please note that we don’t consider the plan as complete yet
due to these on-going concerns (primarily regarding the soils on site). I have not done a detail review of your
2

responses yet, but should be able to review them this week and will follow up with additional comments to
those we received from DWR, which are below:
a. Chewacla and Wehadkee soils are described in the soil report as the dominant series in the areas of
wetland credit. The soil report also includes the following sentence: "Raising the local groundwater to
improve the hydrology of a Chewacla soil should result in a hydroperiod range more like the
Wehadkee." However, the hydroperiod proposed is only 10% which is the low end of Chewacla's range
and below the range of Wehadkee. I would propose that if they want to use only one hydroperiod for
the entire site, they should use 12% which is in the range of both soil series. If they prefer to break out
the two series and do 10% for Chewacla and 12% for Wehadkee, that would also be fine with me.
b. I also find it somewhat concerning that their proposed wetland credit total has more than tripled from
their draft plan to their final plan (0.478 to 1.538 credits) and this is not explicitly stated in the response
to comments. Obviously, I am still new to this, so perhaps this is more normal than I realize, but I would
expect that changes between draft and final are minor and/or in response to comments. Although Kim
mentions allowing restoration credit in some areas previously proposed as enhancement, which would
account for some of the increase, it appears that a lot of new wetland credit areas are proposed as
creation. Quietly tripling the wetland credits seems like something that should be highlighted and
preferably discussed before the final plan. Why was wetland creation not proposed in the draft plan? I
would appreciate greater discussion from the provider about why these are being proposed now. If all of
this stems from the newly completed soils report, it again stresses to me the importance of this being
completed prior to the draft plan submittal.

4. Walnut Wood – I’ve reviewed Ben’s email and will consider that email as RES’ official notification to withdraw
the project, so no further communication necessary. Sorry that did not work out, but I appreciate your letting us
know so that we can take that off the books.

5. Newman Ranch – noted and thanks for the update.

Kim will be on detail pretty much through the end of February, so please continue to coordinate with myself and Erin for
her projects, but I know she is tracking things so please copy her as well. If you have any other questions regarding
project status regardless of the PM, you can always contact me.

Thank you,

Todd Tugwell
Chief, Mitigation Branch
Regulatory Division
Wilmington District, USACE
[phone]

From: Jamey Mceachran <[e-mail]>
Sent: Monday, January 15, 2024 12:58 PM
To: Tugwell, Todd J CIV USARMY CESAW (USA) <[e-mail]>
Subject: \[Non-DoD Source\] Time for a quick catch up on a couple of items?

Hi Todd,
I know you are very busy this time of year. I was going to call you but figured I should check your schedule and see when
you have some time.

I am curious on the plan for project managers for some of our projects and the timelines to expect.

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1) We were expecting Catawba ESA Beaver Tail DRAFT Mitigation Plan comments back at the end of the year and
haven’t seen them yet. Just curious on the timeline for those.
2) Pantera (Neuse 01 UMBI) – Final Mitigation Plan was submitted mid December and we never saw any email go
out to the IRT so were wondering if that had started its official review.
3) Falcon Ridge (Yadkin 03) – Also the FINAL was submitted mid December and we never saw any email go out to
the IRT so were wondering if that had started its official review.
4) Walnut Wood… Just wanted to talk through your thoughts on Ben Carroll’s email and who the PM on that
project now is.
5) Newman Ranch update (just let you know we are working on the draft)

I am not sure when Kim is coming back from Detail and the plan for Casey so I figured I would start with you and if you
need to pass me off to someone else that is okay too!

Thank you and hope you had a great start to the new year!
Jamey

Jamey McEachran, PMP
Regulatory Manager, North Carolina

RES | res.us
M: 919.623.9889

Restoring a resilient earth for a modern world

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