[External] Notice of Credit Release and As-Built Approval/ WLS Catawba 01 UMB - Starker/ SAW-2020-01540/ Catawba County

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Good afternoon Catherine,

This correspondence is in reference to the monitoring report and credit release request submitted for the WLS Catawba 01 Umbrella Mitigation Bank, Starker Mitigation Site, Action ID
SAW-2020-01540. The purpose of this letter is to transmit comments provided by the NC Interagency Review Team (NCIRT) during the review of the monitoring report and to confirm the
annual credit release. The review of the annual monitoring report followed procedures outlined in Section 332.8(o)(9) of the Mitigation Rule. The comments listed below were provided
by the NCIRT during this process. While it is not necessary to provide a response to specific comments at this time, please be sure to address the issues raised in future monitoring
report submittals.

Andrew Friedman-Herring / Maria Polizzi, NCDWR

1. All of the vegetation data looks very good and is organized in a very easy to read way, which is appreciated.
2. The only cross section that appears to have adjusted significantly is XS-11 deepening considerably. However, the photos of XS-11 and XS-12 immediately downstream appear stable. This
is an area to watch closely in future years. Otherwise, geomorphology appears stable and on track.
3. On figure 1a of MY1 and figure 9 of the Final MP, S101, 102, and 103 are shown as P2 restoration, but section 6.2.1 of the Final MP described the proposed work as P1 with small sections
of P2. In Comment 8 from DWR on the Final MP, a concern was voiced about losing flow along S101, S102, and S103 from raising the channel bed. Can you clarify what restoration approach
was constructed on these reaches and update figure 1a accordingly if needed?
4. The flow gauge on S103 is very concerning, as there are only 3 days of consecutive flow. It appears that no flow has been recorded since 8/27/23, despite this channel being assessed
as intermittent. Be prepared to address this issue with an adaptive management plan in Year 2 if conditions do not significantly improve.

Steve Kichefski, USACE

1. Thank you for a thorough project status discussion, SPA photo and drone photos in the MY1 report.

2. Make sure invasives, particularly Kudzu, receive persistent treatment in order to prevent problems. Is the Kudzu present in treatable areas outside the CE that may
benefit the project long-term by including in treatments?

3. XS14 problem noted although visually it does not stand out on the cross-section graph. XS-11 shows pool deepening. What is happing in this location?

4. Zooming in or possibly vertical exaggeration may help long term review of cross section graphs. As currently presented, it will be difficult to assess in later monitoring
years with the additional lines.

5. Low flow is noted on S103 and concerning. Only 1 stream flow response recorded from rain events after July. Was this believed to be from low water table during that
time of year? Continue to ensure gauge is functioning properly and update IRT in MY2 as recommended.

6. Multiple bankfull events noted. Were physical bankfull flow indicators found in the field and documented. Photos with dates are helpful to support crest gauge data
and the descriptions could be added to Table 7a/7b. Example…during site visit on 12/6/2023, bent vegetation, wracking and sediment on vegetation were documented near CG-1 (see photo).

7. The inclusion of previous IRT comments with responses in the report is appreciated. Please continue to build this record of correspondence in future report submittals.

8. CCPV legend – As random veg plots begin this monitoring year make sure to display (along with success status) on the CCPV. Keep in mind, it is helpful to see previous
years’ random veg plot locations.

Based on our review of the monitoring report and the results of the NCIRT review, we confirm that you have satisfied requirements included in the approved banking instrument and mitigation
plan for this site. Accordingly, with this correspondence we confirm the release of credits as shown on the attached credit release schedule. The district leger on the Regulatory
In-lieu Fee and Bank Information Tracking System has been updated to reflect this transaction.

Thank you for your interest in restoring and protecting waters of the United States. Please note that this electronic copy is an official Department of Army notification regarding this
transaction. If you have questions regarding this email, please contact me by email at [e-mail] <mailto:[e-mail]> or telephone (828)
933-8032.

Steve Kichefski

Regulatory Project Manager

U.S. Army Corps of Engineers

Wilmington District, Mitigation Branch

(828)-271-7980 Ext. 4234

(828)-933-8032 cell

Enclosure

cc (by email):

NCIRT Distribution List

From: Davis, Erin B CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, January 5, 2024 9:04 AM
To: Tugwell, Todd J CIV USARMY CESAW (USA) <[e-mail]>; Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>; Isenhour, Kimberly T CIV USARMY
CESAW (USA) <[e-mail]>; Haywood, Casey M CIV USARMY CESAW (USA) <[e-mail]>; Bowers, Todd <[e-mail]>; Hamstead, Byron <[e-mail]
v>; Polizzi, Maria <[e-mail]>; Merritt, Katie <[e-mail]>; Friedman-Herring, Andrew <[e-mail]>; Wilson, Travis W. <[e-mail]
>; Munzer, Olivia <[e-mail]>; Dave McHenry <[e-mail]>
Cc: Catherine Roland <[e-mail]>; [e-mail]
Subject: Notice of Year 1 Monitoring Report Review/ WLS Catawba 01 UMB - Starker/ SAW-2020-01540/ Catawba County

Good morning IRT,

The below referenced bank Sponsor has submitted an Annual Monitoring Report for NCIRT review and is requesting a release of credits. The Annual Monitoring Report has been posted to
the RIBITS Cyber Repository.

This review will follow the process outlined for Credit Release Approval in the 2008 Mitigation Rule (Section 332.8(o)(9)), which requires an IRT review period of 15 calendar days from
the date listed in this email notification. Please provide any comments by 5 PM on the comment deadline shown below. Comments provided after the 15-day comment deadline may not be
considered. Within 30 days of the conclusion of the IRT review period (comment deadline), a copy of all comments will be provided to the bank Sponsor and the IRT along with District
Engineer's intent to approve or disapprove this credit release.

15-Day Comment Start Date: January 9, 2024

15-Day Comment Deadline: January 24, 2024

45-Day Credit Release Approval Deadline: February 23, 2024

NOTE: Deadlines will be extended if an on-site meeting is requested, and comments will be due 15-days following the site visit.

Project Information:

Sponsor: Water & Land Solutions, LLC

Bank Name: WLS Catawba 01 Umbrella Mitigation Bank

Site Name: Starker Mitigation Site

USACE ID: SAW-2020-01540

River Basin: Catawba

HUC: 03050101

County: Catawba

Sponsor POC: Catherine Roland, [e-mail] <mailto:[e-mail]>

USACE PM: Steve Kichefski, [e-mail] <mailto:[e-mail]>

USACE Mit Specialist: Erin Davis, [e-mail] <mailto:[e-mail]>

Credit Release Activities: Year 1 Annual Monitoring

Credit Release Requested: 10% of the total warm water stream credits = 965.67

RIBITS Cyber Repository Link: https://ribits.ops.usace.army.mil/ords/f?p=107:278:174265996168:::RP,278:P278_BANK_ID:5790 <https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fribits.ops.
usace.army.mil%2Fords%2Ff%3Fp%3D107%3A278%3A174265996168%3A%3A%3ARP%2C278%3AP278_BANK_ID%3A5790&data=05%7C02%7Cmaria.polizzi%40deq.nc.gov%7C9bbbc1ff5ea546be228c08dc4920ac3d%7C7a7681dcb9d0449a85c3ecc2
6cd7ed19%7C0%7C0%7C638465652178248742%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C&sdata=qdky8PeArRoLWE3oKD9cBA7xKe6Mqu%2FgwijvSh0ViLA%3D&re
served=0>

Please note that you must be logged in to access documents in the cyber repository.

When submitting comments please indicate if you are requesting a site visit. Please reach out if you have any questions.

Thank you,

Erin

Erin B. Davis

Mitigation Specialist, Regulatory Division

U.S. Army Corps of Engineers, Wilmington District

[phone] work cell

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4. Zooming in or possibly vertical exaggeration may help long term review of cross section graphs. As currently
presented, it will be difficult to assess in later monitoring years with the additional lines.
5. Low flow is noted on S103 and concerning. Only 1 stream flow response recorded from rain events after
July. Was this believed to be from low water table during that time of year? Continue to ensure gauge is
functioning properly and update IRT in MY2 as recommended.
6. Multiple bankfull events noted. Were physical bankfull flow indicators found in the field and documented.
Photos with dates are helpful to support crest gauge data and the descriptions could be added to Table
7a/7b. Example…during site visit on 12/6/2023, bent vegetation, wracking and sediment on vegetation were
documented near CG-1 (see photo).
7. The inclusion of previous IRT comments with responses in the report is appreciated. Please continue to build
this record of correspondence in future report submittals.
8. CCPV legend – As random veg plots begin this monitoring year make sure to display (along with success
status) on the CCPV. Keep in mind, it is helpful to see previous years’ random veg plot locations.

Based on our review of the monitoring report and the results of the NCIRT review, we confirm that you have satisfied
requirements included in the approved banking instrument and mitigation plan for this site. Accordingly, with this
correspondence we confirm the release of credits as shown on the attached credit release schedule. The district leger
on the Regulatory In-lieu Fee and Bank Information Tracking System has been updated to reflect this transaction.

Thank you for your interest in restoring and protecting waters of the United States. Please note that this electronic copy
is an official Department of Army notification regarding this transaction. If you have questions regarding this email,
please contact me by email at [e-mail] or telephone [phone].

Steve Kichefski
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District, Mitigation Branch
(828)-271-7980 Ext. 4234
(828)-933-8032 cell

Enclosure

cc (by email):
NCIRT Distribution List

From: Davis, Erin B CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, January 5, 2024 9:04 AM
To: Tugwell, Todd J CIV USARMY CESAW (USA) <[e-mail]>; Kichefski, Steven L CIV USARMY
CESAW (USA) <[e-mail]>; Isenhour, Kimberly T CIV USARMY CESAW (USA)
<[e-mail]>; Haywood, Casey M CIV USARMY CESAW (USA)
<[e-mail]>; Bowers, Todd <[e-mail]>; Hamstead, Byron
<[e-mail]>; Polizzi, Maria <[e-mail]>; Merritt, Katie <[e-mail]>;
Friedman-Herring, Andrew <[e-mail]>; Wilson, Travis W. <[e-mail]>;
Munzer, Olivia <[e-mail]>; Dave McHenry <[e-mail]>
Cc: Catherine Roland <[e-mail]>; [e-mail]
Subject: Notice of Year 1 Monitoring Report Review/ WLS Catawba 01 UMB - Starker/ SAW-2020-01540/ Catawba
County

Good morning IRT,

2

The below referenced bank Sponsor has submitted an Annual Monitoring Report for NCIRT review and is requesting a
release of credits. The Annual Monitoring Report has been posted to the RIBITS Cyber Repository.

This review will follow the process outlined for Credit Release Approval in the 2008 Mitigation Rule (Section 332.8(o)(9)),
which requires an IRT review period of 15 calendar days from the date listed in this email notification. Please provide
any comments by 5 PM on the comment deadline shown below. Comments provided after the 15-day comment
deadline may not be considered. Within 30 days of the conclusion of the IRT review period (comment deadline), a copy
of all comments will be provided to the bank Sponsor and the IRT along with District Engineer's intent to approve or
disapprove this credit release.

15-Day Comment Start Date: January 9, 2024
15-Day Comment Deadline: January 24, 2024
45-Day Credit Release Approval Deadline: February 23, 2024

NOTE: Deadlines will be extended if an on-site meeting is requested, and comments will be due 15-days following the
site visit.

Project Information:
Sponsor: Water & Land Solutions, LLC
Bank Name: WLS Catawba 01 Umbrella Mitigation Bank
Site Name: Starker Mitigation Site
USACE ID: SAW-2020-01540
River Basin: Catawba
HUC: 03050101
County: Catawba

Sponsor POC: Catherine Roland, [e-mail]
USACE PM: Steve Kichefski, [e-mail]
USACE Mit Specialist: Erin Davis, [e-mail]

Credit Release Activities: Year 1 Annual Monitoring
Credit Release Requested: 10% of the total warm water stream credits = 965.67

RIBITS Cyber Repository Link:
https://ribits.ops.usace.army.mil/ords/f?p=107:278:174265996168:::RP,278:P278_BANK_ID:5790
Please note that you must be logged in to access documents in the cyber repository.

When submitting comments please indicate if you are requesting a site visit. Please reach out if you have any questions.

Thank you,
Erin

Erin B. Davis
Mitigation Specialist, Regulatory Division
U.S. Army Corps of Engineers, Wilmington District
[phone] work cell

3