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Home My WebLink About20140189 Ver 1_USACE Revised Mit Plan Comment Memo_20151105Baker, Virginia From: Sent: To: Cc: Subject: Attachments: Classification: UNCLASSIFIED Caveats: NONE 0 Hughes, Andrea W SAW <Andrea.W.Hughes @usace.army.mil> Thursday, November 05, 2015 4:03 PM Kathryn_Matthews @fws.gov; Emily_Jernigan @fws.gov; Fritz Rohde (Fritz. Rohde @noaa.gov); Baker, Virginia; Haupt, Mac; Scarbraugh, Anthony; bowers.todd @epa.gov; Wilson, Travis W. Tugwell, Todd SAW; Daniel Ingram; Biddlecome, William J SAW Notice of Intent to Approve Arrington Bridge III Mitigation Site (Neu -con UMBI modification) / Wayne County / SAW - 2015 -00360 (UNCLASSIFIED) Revised Mit Plan Comment Memo-Arrington Bridge III Mitigation Site (Neucon UBMI Modification )_SAW - 2015- 00360.pdf Attached are comments received in response to the revised Arrington Bridge III Mitigation Plan dated September 2015 and provided to IRT members on or about September 17, 2015. Following review of the Draft Mitigation Plan dated June 2015, we received comments from IRT members as well as the Seymour Johnson Air Force Base. The Corps worked with Resource Environmental Solutions (RES) to address the comments which were incorporated into the revised Mitigation Plan. We have evaluated the comments generated during the review period for the revised Mitigation Plan, and determined that the concerns raised during the review are generally minor. Accordingly, it is our intent to approve the Arrington Bridge III Mitigation Site as a modification to the existing Neucon UMBI unless a member of the NCIRT initiates the Dispute Resolution Process, described in the Final Mitigation Rule (33 CFR Section 332.8(e)). Please note that initiation of this process requires that a senior official of the agency objecting to the approval of the mitigation plan (instrument amendment) notify the District Engineer by letter within 15 days of this email (by COB on November 20, 2015). Please notify me if you intend to initiate the Dispute Resolution Process. Provided that we do not receive any objections, we will provide an approval letter to Resource Environmental Solutions (RES) at the conclusion of the 15 -day Dispute Resolution window. This approval will also transmit comments generated during the review process to RES, and indicate comments that must be addressed in the Final Mitigation Plan. All NCIRT members will receive a copy of this letter and all comments for your records. Thanks for your participation, Andrea Hughes Mitigation Project Manager Regulatory Division U.S. Army Corps of Engineers 11405 Falls of Neuse Road Wake Forest, NC 27587 Classification: UNCLASSIFIED Caveats: NONE DEPARTMENT OF THE ARMY WILMINGTON DISTRICT, CORPS OF ENGINEERS 69 DARLINGTON AVENUE WILMINGTON, NORTH CAROLINA 28403-1343 REPLY TO ATTENTION OF: CESAW-RG/Hughes November 5, 2015 MEMORANDUM FOR RECORD SUBJECT: Arrington Bridge III Revised Mitigation Plan (Neucon Umbrella Mitigation Bank Instrument Modification); NCIRT Comments During Mitigation Plan Review PURPOSE: The comments listed below were received during the 30-day comment period in accordance with Section 332.8(g) of the 2008 Mitigation Rule. Project Name: Neucon Umbrella Mitigation Banking Instrument Modification, Arrington Bridge III Wetland Mitigation Site, Wayne County, NC USACE AID#: SAW-2015-00360 30-Day Comment Deadline: October 19, 2015 Mac Haupt, NCDWR, 13 October 2015: 1. There are three soils series mapped on site which are hydric; Coxville (Typic Paleaquult), Pantego (Umbric Paleaquult), and Weston (Typic Paleaquult). Other soils series while not hydric may have hydric inclusions, however, a number of these soils are quite sandy and therefore usually moderately to well drained. The wetland hydrologic success criterion of 8% is acceptable given the soil series on the site. 2. There are several areas in the wetland restoration shaded areas that have significant non-hydric polygons and other areas which will be susceptible to drainage given the surrounding land use and soils types. These areas of concern were supported by several borings in the 2015 Hydric Soil Assessment in the document (boring #s: 222, 228, 229, and 235). I recommend placing a gauge in these noted polygons. In addition, they may want to consider placing a couple of gauges near the boundaries of the wetland restoration shaded areas which are located near borrow pits. Andrea Hughes, USACE, 5 November 2015: 1. Page 16, Section 6: If performance standards are not met, it may require adaptive management or if the site is trending toward success or the issues are minor in nature, then the Corps, in consultation with the IRT, may approve the credit release. I recommend deleting the two sentences that discuss not meeting performance or state that adaptive management may be required. 2. Page 16, Credit Release Schedule: The wetland credit release schedule should reflect: 15% for site establishment, 15% for post-construction, and 10% for monitoring years 1- 7. 3. Page 16, Section 6.1 Initial Allocation of Credits: Please include the requirements listed below: 1) Approval of the final Mitigation Plan; 2) Mitigation bank site must be secured; 3) Delivery of the executed financial assurances described in the Mitigation Plan; 4) Delivery of a copy of the recorded long-term protection mechanism as specified in the Mitigation Plan, as well as a title opinion covering the property acceptable to the USACE; and 5) Issuance of any DA permits necessary for site construction, if required 4. Page 21, Table 11. Please remove Red Maple from planting list. 5. Page 28: Since Section 10.2 is labeled Vegetative Success Criteria, should Section 11.2 be labeled Vegetative Monitoring? Also, the sentence "If necessary, RES will develop a species-specific control plan" is stated twice. 6. Page 30: Site protection and long-term management are two separate Rule requirements and should be listed under separate sections. The information provided in Section 12 relates to site protection. The long-term management section should state that the conservation easement holder, NCWHF, will act as long term manager for the mitigation site; provide a list of annual long term management activities and associated annual costs; and describe the funding arrangements . 7. Page 31: Adaptive management: Recommend removal of statement concerning tree mortality. 8. Page 32, First sentence, please replace "to the USACE" with "payable to the NCWHF, acting as surety". 9. Please provide a copy of the jurisdictional determination approval letter. Andrea Hughes Mitigation Project Manager Regulatory Division HUGHES.ANDREA. WADE.1258339165 Digitally signed by HUGHES.ANDREA.WADE.1258339165 DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, cn=HUGHES.ANDREA.WADE.1258339165 Date: 2015.11.05 15:39:53 -05'00'