FalconRidge_IRT_CommentResponse_Memo_FINAL_revised

MEMORANDUM

3600 Glenwood Avenue, Suite 100 Raleigh, North Carolina 27612 919.770.5573 tel. [phone] fax
TO: Todd Tugwell – IRT
FROM: Ryan Medric – RES
DATE: January 26, 2024
RE: Response to Draft Mitigation Plan Comments – RES Yadkin 03 Umbrella Mitigation
Bank, Falcon Ridge Mitigation Project, (SAW-2022-00424), Yadkin River Basin
03040103; Randolph County, NC

In response to Draft Mitigation Plan comments DWR #1 and #7 and USACE #9 and #10, RES
contracted a North Carolina Licensed Soil Scientist to produce a detailed hydric soils report for the
site. The hydric soils report presented opportunities to perform Wetland Rehabilitation and
Creation in addition to the Wetland Enhancement that was presented in the Draft Mitigation Plan.
Minor stream profile and limits of grading adjustments were made to accommodate wetland
changes, and stream reach PR11 was added to the project (no credit), and Wetland G was added
to the project (section as Rehabilitation) as a result of the hydric soils investigation. In the Final
Mitigation Plan, Section 3.3.6 and 7.7.2 were included to discuss new information. Additionally,
stream Reach PR9 (Enhancement III) has been shortened based on jurisdictional determination
origin: Upon further review, RES noticed that the stream length of PR9 was projected higher
upslope than the jurisdictional origin point. PR9 reduced from 60 feet to 33 feet and SMUs have
been revised accordingly. As a result of these changes, project credits were updated as follows:
Draft Mitigation Plan Final Mitigation Plan
Stream Credits (SMU) 9,841.600 9,800.370*
Wetland Credits (WMU) 0.478 1.543
*SMUs decreased due to NSBW reduction from additional wetlands + length of PR9 was shortened.
Additionally, on January 19, 2024, the IRT provided comments on the Final Mitigation Plan which
are listed at the bottom of this memo under “Todd Tugwell, USACE”.
Mac Haupt, NCDWR:
1. Section 3.2.3- Existing Wetlands- did a North Carolina Licensed Soil Scientist verify the hydric
soils on site?
Note that sections were revised/reformatted, so Section 3.2.3 no longer exists in Final Mitigation
Plan and the respective information is now within Section 3.5.

Originally RES did not have a soil scientist evaluate the site as RES was only seeking
enhancement credit on the jurisdictional wetlands and typically has not needed a soil report

for this type of credit generation. However, after coordination with the USACE on this site RES
decided that there was potential to generate additional wetland credits, so RES contracted a
North Carolina Licensed Soil Scientist to perform a Hydric Soil Investigation. The sealed Soil
Report is included in Appendix D. In accordance with the soil scientist’s conclusions and
recommendations, the Project now proposes Wetland Rehabilitation, Enhancement, and
Creation. The Final Mitigation Plan has been updated and revised accordingly.

2. Section 3.4 – Reach Summary Information- DWR likes the fact that there will be no crossings
on this project.
RES appreciates the feedback.

3. What previous RES projects have utilized engineered sediment packs? How do they
promote surface flow?
Previous RES projects that have utilized Engineered Sediment Packs (ESP) include*:
 Tull Wooten III (SAW-2017-00847, DWR # 2008-1268, Lenoir County)
 Groundhog Hollow (SAW-2018-00450, DWR # 2018-0666, Alexander County)
 Catbird (SAW-2017-01506, DWR # 2017-1039, Davie County)
 Dead Oak (SAW-2018-00095, DWR # 2018-0066, Buncombe County)
 Bucher (SAW-2016-01988, DWR # 2016-0977, Durham County)
 Cowford (SAW-2019-00487, DWR # 2019-0495, Onslow County)
*This is not an exhaustive list of RES projects utilizing ESPs but demonstrates a variety of regions throughout NC
where ESPs have been implemented.
RES installs ESPs in locations where stormwater runoff is concentrated, typically within swales
or ditches that originate outside of the project area. The concentrated flow gets detained
behind the ESP and slowly leaks back through the structure into the channel. Additionally, the
detained water can move through the soil to help locally raise the groundwater, thus
promoting surface flow. Ultimately, this helps to slow and filter flow coming into the project,
and at the same time traps sediment and other contaminants.

4. Table 6 Summary of Stream Parameters- shows that a number of these reaches scored low
intermittent for the DWR Stream Determination Scores. This project being located in the Slate
Belt further exacerbates the flow issue. In addition, DWR will be requiring more days of
consecutive flow than in years past, therefore, careful attention will need to be paid to this
issue for this project.
RES appreciates this comment and will keep a close eye on flow patterns throughout the
Project; however, RES will follow the Wilmington District Stream and Wetland Compensatory
Mitigation Guidance for stream hydrology performance standards, which states that
“Continuous surface water flow within the tributaries must be documented to occur every year
for at least 30 consecutive days during the prescribed monitoring period. This 30-day period can
occur at any point during the year.” All intermittent reaches will be monitored with automatic-
logging pressure transducers with data loggers. If after the first few years on monitoring, any
intermittent reach is not meeting the performance standards for sufficient flow, additional
monitoring measures, such as flow camera installation, will take place.

5. Section 6.2.3- Wetland Mitigation Approach- in the Wetland Enhancement paragraph it is
stated that the listed wetlands have sufficient hydrology. Are wetland gauges present? It is
further stated that, “wetlands may also benefit from improved hydrology, as a byproduct of
stream restoration and enhancement activities; however, hydrology will not be monitored, nor
will their success depend on it.” DWR strongly disagrees with the previous statement. DWR
will require that gauges be present and will require wetland hydrology monitoring. Not only
should the wetlands be monitored to document the “sufficient” hydrology but also to make
sure the constructed stream channels don’t impact or affect the wetlands by drainage. In
addition, the removal of the pond on reach PR7-A will likely cause some wetland hydrology
changes that need to be documented.
The Project’s wetland approach has been updated and revised to now incorporate Wetland
Rehabilitation, Enhancement, and Creation. Hydrology will be documented across wetland
features via 11 wetland gauges. The Final Mitigation Plan has been revised accordingly.

6. Section 7.1.2- Performance Standards- Surface Flow- DWR will require that reaches must
maintain surface flow for a period of no less than 90 days for anytime during the year.
Please refer to the response for Comment #4.

7. Section 7.2 – Vegetation and Wetlands Success Criteria- for the wetlands please see #5.
Moreover, a North Carolina Licensed Soil Scientist needs to verify hydric soils on site and
recommend or identify the soil series so the appropriate wetland performance hydrology can
be assigned as per the October 2016 Mitigation Update.
In accordance with the soil scientist’s conclusions and recommendations, the Project now
proposes Wetland Rehabilitation, Enhancement, and Creation. The soils within proposed
Project wetland features vary between Chewacla and Wehadkee; therefore, the target
hydroperiod will be 10%. The Final Mitigation Plan has been updated and revised accordingly.

8. Section 8.3- Stream Hydrology Events- since flow will likely be an important factor in the
success of this project, more flow gauges or different placement may be recommended after
the first or second monitoring year.
RES understands the risks and uncertainties and is open to adapting flow monitoring in future
years.

9. Design sheets- general comments:
a. DWR likes the format of RES’ design sheets.
RES appreciates the feedback.

b. There will be a lot of construction through wooded areas, DWR hopes that care will be
taken to conserve as many trees as possible, DWR did note the v erbiage relative to the
amount of invasive plants on site and realizes there may be con siderable cleared areas.
The proposed alignments were located in a manner to avoid larger specimen trees
where feasible. Once construction begins, RES staff will work with the contractor to
mark trees that should remain while not drastically impeding the constructability of
the channels. Given that much of the existing buffer is comprised of invasives, primarily
privet, RES plans to save as many hardwoods as possible so as not to leave the buffer
devoid of woody vegetation once construction is complete.

c. Since there will be a large number of structures installed on this site, DWR urges RES
to obtain most of the stone needed for the construction on site. The photos of many
of tributaries showed a lot of stone for the bed material. DWR much prefers on site
material to rip rap.
RES strongly agrees with harvesting onsite stone/outcrops and existing channel
substrate for use as riffle material and proposed in-stream structures. RES plans to only
bring in stone for use as backfill material and larger stone (boulders) if such materials
are not harvestable onsite. Notes have been added to Sheets E1 & D5 to emphasize
the harvesting and use of onsite materials.

10. Design sheets S1 and S3- for the channel construction on these sections please have the
appropriate engineer on site for structure inspections.
RES will ensure that design staff is onsite prior to construction to confirm and/or adjust the
locations and elevations of the in-stream structures located on Reach PR1-A. For Reaches PR1-
B, design staff will be onsite for frequent inspections, especially at the beginning of the project
and when construction starts on individual reaches.

11. Design sheet S9- DWR requires a wetland monitoring gauge stream right at station 6+00.
A proposed wetland monitoring gauge has been added to the location. Note, that this wetland
(WA) is now proposed for Rehabilitation. The Final Mitigation Plan and Figure 12 have been
updated accordingly.

12. Design sheet S10- does PR10 initiate upstream of the wetland? W as this reach seen on the IRT
site visit?
PR10 originates as a rocky seep, upstream of Wetland C. This reach was not seen on the IRT
site visit as it was discovered during the wetland delineation.

13. Design sheet S15- DWR requires two gauges, one 20-30 feet above the jurisdictional
determination point and “stream” left at approximately station 0+75. DWR questions the
decision to construct a channel in the wetland.
Two proposed wetland monitoring gauges have been added to the recommended locations.
Note, that this wetland (WF) is now proposed for Rehabilitation. The Final Mitigation Plan and
Figure 12 have been updated accordingly. RES acknowledges the concern to construct
channel through the wetland. However, in combination with the embankment and debris
removal associated with the stream and wetland, RES believes that starting stream restoration
at the jurisdictional determination stream origin and carrying it through the embankment
removal area ensures the most stable outcome for the system.

14. Design sheets S18 and S19- DWR requires the placement of wetland monitoring gauges at
stream left of PR7-A at station 11+25 and station 12+50.
Two proposed wetland monitoring gauges have been added to the recommended locations.
Note, that this wetland (WE) is now proposed for Rehabilitation. The Final Mitigation Plan and
Figure 12 have been updated accordingly.

15. Design sheet S20- at station 19+00 the graded floodplain is narrow, approximately 35-40 feet.
DWR would like to see the graded floodplain be at least 50-60 feet or more.
The floodplain near STA 19+00 is located within the existing dam footprint and is intentionally
narrow to tie-in to existing topography just downstream of the dam where the
floodplain/valley is naturally narrow; approximately 30 feet wide. To widen the proposed
floodplain much more than is designed would require cutting into the steep valley walls that
are currently stable. Also, widening the floodplain significantly would create a more abrupt
transition moving from restoration through the pond bed to the enhancement reach.

16. Design sheet S23- DWR requires two wetland gauges, one stream right of PR8 at station 4+50
and the other on PR7A? on stream left at 635 grading marker.
The recommended locations in this comment seem duplicative to the locations mentioned in
above Comment #14. Therefore, the wetland monitoring gauge recommended on the right
stream bank of PR8 at station 4+50 was combined with the wetland gauge recommended on
the left stream bank of PR7-A at station 11+25. The wetland mon itoring gauge recommended
on the left stream bank at grading marker 635 was combined with the wetland monitoring
gauge recommended on the left stream bank of PR7-A at station 12+50.

17. Design sheet D5- riffle grade control- DWR requests that the designer use on site material
(stone) as much as possible for the structures.
See comment response to 9.c. above.

Olivia Munzer, NCWRC:
1. There are no specifics on the culvert type. CMP or RCP should be used for pipe culverts.
No new culverts will be installed as part of the Project. Existing culverts within the proposed
conservation area will either be removed or replaced with ford crossings.

2. Please separate the seed mix by habitat type. Also, RES states they will use a pollinator-friendly
seed mix, but there are only 3 flowering species in the mix - 1 FACU, 1 OBL, and 1 UPL species.
I recommend adding more native flowering herbaceous species in the mix for each of the
habitat types (wetland, upland, riparian).
An additional column has been included in Table 14. Permanent Seed Mix to separate the
species list by habitat type. Thank you for your recommendation to add more pollinator
species to the seed mix; however, when making our tree planting and seeding lists, we are
careful to consider many factors such as pollinator species, erosion and sediment control
measures, and cost per acre. Specifically, our erosion and sediment control requirements limit
the ability to incorporate several showy, flowering species, in order to comply with providing
the proper amount of erosion-control-specific grasses. In addition to the pollinator-friendly
herbaceous species proposed, there are also a number of pollinator-friendly woody species
proposed in the bare root planting lists, including: tulip poplar, persimmon, northern
spicebush, silky dogwood, flowering dogwood, buttonbush, and eastern redbud.

Kim Isenhour, USACE:
1. Page 1: Please check the linear feet listed in the first paragr aph against Table 1 for consistency.
This typo in the first paragraph has been corrected.

2. Page 7 and Sheet S15: Will wetland hydrology in WF be altered when the rock dam on PR6 is
removed? The Corps will require a wetland gauge above 0+00.
Hydrology could be altered, but natural discharge along the valley toe-of-slope should
maintain wetland hydrology. Regardless, a proposed wetland monitoring gauge has been
added above 0+00. Note that Wetland WF is now proposed for Rehabilitation. The Final
Mitigation Plan and Figure 12 have been updated accordingly.

3. Page 8: In reference to the NCDOT planned work in the 2029 STIP plans, will roads or bridges
adjacent to the project be affected? Please clarify in the text.
Roads, bridges, and other infrastructure adjacent to the Project and throughout the Project’s
drainage area will not be impacted by NC DOT planned work accor ding to the 2024-2033 STIP
plans (released in June 2023, following the draft submission of this mitigation plan). This has
been clarified in the text.

4. Page 13 and Table 6: The data presented indicates that PR10 is more of a linear wetland rather
than a channel. When using perennial stream indicator taxa to determine whether a channel
is ephemeral, doesn’t the manual require both fish and specific macrobenthos? I don’t recall
reviewing this tributary during the IRT site visit. I think it is acceptable to propose this reach
for stream credit; however, we will expect gauge data to reflect perennial flow since that is the
justification used for including this ephemeral reach. Since you’re proposing enhancement at
5:1, I don’t expect the flow data to change like it would if stream restoration were conducted.
I think it would have been prudent to include flow data in the draft mitigation plan to
supplement the request to include ephemeral channels.
The NC DWR Methodology for Identification of Intermittent and Perennial Streams and
their Origins v. 4.11 defines a stream as perennial if any of three criteria are met…In
this instance, Criteria #3 is met. Criteria #3 is:
“More than one benthic macroinvertebrate that requires water for their entire
life cycles are present as later instar larvae…”
Dragonfly and damselfly larvae are both taxa that require water for their entire life
cycle. Under Criteria #3, presence of fish is not a requirement.
Reach PR10 originates as a rocky seep, with hydrology fed from continuous
groundwater discharge and displays several indicators of continuous flow, including
the perennial taxa found (dragonfly and damselfly larvae), overall bedform of the
channel, and varying substrate composition and patterns. Due to the discharge nature
of the stream, it has always been observed to be flowing, even during drought
conditions when other stream channels onsite have been dry. With that said, a flow
gauge will be installed at the upstream portion of this reach to monitor consistency of
flow days; however, the minimum performance standard for flow will be 30 days of
consecutive flow. RES’ stance is that even if this stream were to exhibit intermittent
flow, it would still be a viable, mitigatable stream feature. If additional monitoring
measures need to be taken (e.g. installing a flow camera alongside the data logger),
they will be addressed in the early monitoring stages of the project. Additionally, RES
would be open to monitoring for presence of perennial macrobenthos via annual grab
samples if requested by IRT. RES would expect dragonfly and dam selfly larvae to persist
throughout the monitoring period, especially since there is no construction proposed
for this reach.
a. I have the same concerns with PR9.
Please see discussion above as it also applies to PR9.

5. Page 14, Section 3.5.3: Please run iPaC again to ensure that there will be no effect on the
Tricolored Bat. Please include the species conclusion table in the final mitigation plan.
IPaC was run again in November 2023 and the results are unchanged. The official species list
still includes the tricolored bat, but the iPaC review process did not generate any
determination keys to evaluate for Tricolor bat. Nonetheless, a species conclusion table was
updated and included in Appendix B noting that potential habitat may be present and project
construction may affect potential existing populations. Ultimately, restoring a native
hardwood riparian buffer, eliminating competition from invasive species, as well as
establishing a protected conservation easement to over 60 acres of land will improve habitat
for potential populations in the future. Section 3.7.3 has been revised with the updated
information regarding tricolored bat.

6. Page 14 & Figure 11: Three ford crossings are being installed/improved at the top of PR4A,
PR3 and PR2A. The IRT would prefer that these crossings be internal to the easement for
maintenance concerns. You do not need to re-run the buffer tool since these crossings are at
parcel lines.
RES is still exploring the overarching possibility of internal crossings on our mitigation projects
in the future, and it is a work in progress. However, we are not prepared to implement them
on this Project.

7. With the number of intermittent channels on this site, I would caution against using too many
log structures. The IRT has noted numerous rotting log structures on intermittent channels,
particularly in the Slate Belt.
RES understands this concern and has adjusted the placement and number of log structures
in some locations to significantly minimize potential channel degradation resulting from
structure failures due to rotting.

8. Section 6.1.1: Do you have any reference wetland sites available?
Because the existing conditions of the Project wetlands are so highly impacted, suitable
reference wetlands do not exist onsite. The wetlands proposed for Rehabilitation are highly
degraded by absence of vegetation and cattle impacts while hydrology alterations vary but
include impacts from cattle and/or stream incision. Streams proposed for Enhancement are so
small and have historically been impacted by tree clearing and cattle – also, two of the three
small Enhancement wetland are “Seeps” which are a different wetland type than those
proposed for Rehabilitation and Creation. Also, because this is the first RES stream-wetland
mitigation bank in this watershed, we do not have any viable reference wetlands that we are
aware of.

9. Section 6.2.3:
a. The text in the last paragraph of page 32 states that wetland e nhancement will improve
hydrology, soils, and vegetation. The Corps will require groundwater gauges in WE and
WF in order to demonstrate hydrology uplift.
The Project’s wetland approach has been updated and revised to now incorporate
Wetland Rehabilitation, Enhancement, and Creation. Hydrology will be documented
across wetland features via 11 wetland gauges. The Final Mitigation Plan has been
revised accordingly.

b. Pre-gauge data should be collected as well to help demonstrate uplift. The text states
that sufficient hydrology exists, but how do you know this without capturing hydrology
data?
RES understands the language is misguiding. The assumption was that hydrology is
assumed to be “sufficient” since the wetlands are jurisdictional, but obviously this was
not quantified. Regardless, the Project’s wetland approach has been updated and
revised to now incorporate Wetland Rehabilitation, Enhancement, and Creation.
Hydrology will be documented across wetland features via 11 wetland gauges. The
Final Mitigation Plan has been revised accordingly.

c. If you anticipate that wetlands will be present after the pond on PR7-B is removed, you
will need to provide gauge data there as well.
The Project’s wetland approach has been updated and revised to now incorporate
Wetland Rehabilitation, Enhancement, and Creation. Hydrology will be documented
across wetland features via 11 wetland gauges. The Final Mitigation Plan has been
revised accordingly. For the pond specifically, only the upper section of the pond
footprint is being proposed for wetland Creation (C3): A wetlan d gauge will be installed
here to document hydrology.

d. If the proposed wetlands are currently jurisdictional but are impacted by agriculture,
you may propose them as rehabilitation at 1.5:1 rather than enhancement. I’m open to
discuss crediting options.
The Project’s wetland approach has been updated and revised to now incorporate
Wetland Rehabilitation, Enhancement, and Creation. Wetlands WA, WE, WF, and WG
(newly added) are proposed for Rehabilitation at 1.5:1 while wetlands WB, WC, and
WD remain proposed as Enhancement at 2:1. The Final Mitigation Plan has been
revised accordingly.

e. My recollection of onsite wetlands, particularly WE & WF, were that they could benefit
from both vegetation and hydrology functional uplift so it’s un clear why they are being
proposed for enhancement. The LOW NCSAM ratings also make me question why
rehabilitation is not proposed.
Refer to comment response 9.d. above.

10. Section 7.2:
a. Please include a detailed soils report that verifies the areas proposed for wetland credit.
A licensed soil scientist conducted a detailed hydric soil study and the final report is
included in Appendix C of the Final Mitigation Plan. In accordance with the soil
scientist’s conclusions and recommendations, the Project now proposes Wetland
Rehabilitation, Enhancement, and Creation. The Final Mitigation Plan has been revised
accordingly.

b. A separate performance standard for wetland success criteria should be included, to
include documenting uplift in vegetation and hydrology.
A performance standard has been added for wetland success to include both
vegetation and hydrology criteria. The hydrology success criter ia will be 10% minimum
hydroperiods for all wetland rehabilitation and creation. Sections 7.2 and 8.5 have
been updated and revised accordingly.

11. Section 7.2.1: Please include mortality data of planted understory species as well. This
information is helpful in determining the success of understory planting.
Six random vegetation plots will be placed specifically throughout the understory planting
area (Zone 3) each monitoring year. Suggested as-built locations for said random plots can
be found on Figure 12 - Monitoring Plan. There will be the same minimum survival criterion
as the other vegetation plots, however, the total count for each monitoring event will be
composed of both planted and non-planted, existing native stems. This will document the
long-term stability and survival of both the established vegetation and the newly planted
vegetation, post-invasive removal.

12. Page 43: The second sentence reads, “Longitudinal images should NOT indicate the absence
of developing bars…” Please QA this sentence.
The sentence has been revised to now say: “Longitudinal images should not show mid-channel
bars within the channel or an excessive increase in channel depth.”

13. Figure 13: Please confirm that you excluded all wetlands that will receive credit from the wider
buffer credit calculation. The map appears to only remove portions of WE and WF. Please
update Table 15 accordingly.
Note that the wider buffer credit calculation (via buffer tool) was re-performed for the Final
Mitigation Plan due to addition of wetland features. In doing so, areas of wetland credit vs
NSBW additional credit have been confirmed to not overlap. The only wetland crediting area
that extends past the 0–50-foot stream buffer is Wetland F (WF) and has been deemed
ineligible (black crosshatch) and is not included in the wider buffer credit calculation.

14. Figure 12: Please add random veg plots where old pond dams are being removed throughout
monitoring.
Random vegetation plots will be placed where old pond dams are being removed throughout
monitoring. The as-built random plot locations can be seen in Figure 12. During as-built,
random plots are being proposed on the removed dam along PR6, within the pond bottom
(PR7-A) near the dam removal location, and at the downstream end of PR1-D where the dam
was removed. Random vegetation plots will be captured along the remaining dam removal
areas in the following monitoring years.

15. Planting Plan, Design Sheet P1: Please add wetland indicator status to each species.
Plan Sheet P1 has been revised per comment.

16. Please include the JD Concurrence email.
RES sent an email to Kim Isenhour with revised JD materials on October 17, 2023. The revised
JD and email are included in Appendix B in the Final Mitigation Plan.

Todd Tugwell, USACE:
1. 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.
The hydroperiod for all wetlands on site has been changed to 12%.

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.
Thanks for the clarification.

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.
Thank you for bringing this to our intention, as these do appear to be errors. RES has re-run
the NSBW tool and updated the spreadsheet calculator accordingly with two exempt terminal
ends and the Enhancement III category checked “yes” to being included in the calculations.

RES also wants to highlight an additional change: Reach PR9 (Enhancement III) has been
shortened based on jurisdictional determination origin. Upon further review, RES noticed that
the stream length of PR9 was projected higher upslope than the jurisdictional origin point.
PR9 reduced from 60 feet to 33 feet and SMUs have been revised accordingly. Further, the re-
run of the NSBW tool accounts for this update as well.

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 expec t 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. Pleas e revise the stream flow standard
for this project to 90 days as requested.
The stream flow standard has been changed from 30 days to 90 days. RES expects if this
standard is to be met, it will be between November and April, potentially crossing calendar
years. This was added to Section 10.1.

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 propose to dem onstrate the anticipated uplift
(and associated credit) without baseline data from pre-construction monitoring?
RES will install pre-construction gauges in the rehabilitation wetlands in the locations
proposed in the monitoring figure. Any reference to hydrologic improvements in the
enhancement have been removed. This was added to Section 8.5.

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.)
RES will install a reference wetland gauge in Wetland A at the RES Cape Fear 03 Feed and Seed
Mitigation Site. This site is located 6.5 miles from Falcon Ridge. The wetland was confirmed by
the Corps in September 2019 and is located in the floodplain of RD1-B and RD2. The NCWAM
wetland type is Headwater Forest which is the same as Falcon Ridge wetlands WA, WD, WE,
and WF. The soil series is mapped as Wilkes-Pointdexter-Wynott complex which are not hydric.
However, the soil series mapped for Falcon Ridge was also not mapped as hydric. RES would
expect the soil series to be similar to the floodplain soils that the LSS found at Falcon Ridge.
This was added to Section 8.5.