20070156 Ver 2_More Info Received_20071206

LMG
LAND MANAGEMENT GROUP irrc.
Environmental Consultants ~~~: ~ ;`~ ~4~4~`~t~~~ ~~
~~ ,~ ° . ~, ate' ~..._: d.~ ~..._; ~ 1
December 4, 2007 ~~~
u~_C ~ "Z007
TO: Mr. Kyle Barnes
~~~ n~~ - vu.~,i ~~~: ~~t~sMi.~ f't
Division of Water Quality '!+t~~1:~sT~~?r~;~u'.~~~r~tr~n!c~
943 Washington Square Mall
Washington, NC 27889
RE: Additional Information for the 401 Water Quality Certification Application
Cutter Creek Plantation; Greene County, NC; DWQ Project# 07-0156
Mill Run Development Group, LLC
Dear Kyle:
Thank you for your letter dated November 21, 2007 in which you request additional
information regarding the Cutter Creek Plantation Individual Permit application. Below is a response
to each of your comments.
1. Neuse Riparian Buffer Impacts
- Please provide a restoration plan for the riparian buffer for Lake Nina.
Please see the attached map and summary that outlines buffer impacts and restoration
adjacent to Lake Nina.
- Please provide a mitigation plan to be approved by the DWQ for the portion of the riparian
buffer that is eligible for the "Allowable with Mitigation "provision.
Attached is the buffer mitigation plan that discusses proposed off-site mitigation activities.
I hope this response adequately addresses your concerns. Please contact me if you have any
additional questions. Thank you for your assistance with this project.
Sincerely, _.
Kim Williams
Encl.
C: Mr. Ian McMillan, DWQ ,
Ms. Scott Jones, ACOE
Mr. Buzz Shackelford, Mill Run Development, LLC
Mr. Tyndall Lewis
www.lmgroup.net • [e-mail] Phone: [phone] Fax: [phone]
3805 Wrightsville Ave., Suite 15, Wilmington, NC 28403 • P.O. Box 2522, Wilmington, NC 28402

o~-oiSl,
CUTTER CREEK PLANTATION
GREENE COUNTY, NC
RESTORATION PLAN FOR LAKE NINA
Mill Run Development Group proposes to impact 0.61 acre of Zone 1 Buffer in four locations
around the proposed Lake Nina within the Cutter Creek Plantation. These areas will be converted to
turf grass, which is needed to allow adequate visibility to golfers as they play across Holes 9 and 18
on the golf course. Low-lying shrubs will be planted in five separate locations of Zone 1 totaling 0.93
acre (Figure 6). Tall trees will be planted in five locations of Zone 1 totaling 0.92 acre. A minimum
of five species of shrubs and fives species of trees from the tables below will be planted (Tables 1
and 2). Exact species to be planted will be based on nursery availability. Vegetation will be planted
on an 8' spacing and will occur within the first dormant season after 404/401 permits have been
obtained.
Zone 2 will be vegetated with turf grass. It will be graded to provide for diffuse flow and is exempt
from buffer rules. In addition, the proposed dam and associated features to be located at the head of
the lake are also exempt from buffer rules. The applicant proposes to construct a greenway/hiking
trail across the southern section of the pond (Figure 6). This 10' wide trail will be elevated over the
lake but will be an impervious impact to 0.02 acre of Zone 1 buffer. However, because of its
proposed use as a trail, it is exempt from buffer regulations.
There is an existing grassed buffer on the lower half of the stream. Sections of the lake buffer that
fall within this existing corridor will be maintained in grass. This is considered to be a maintained
use and is not subject to buffer regulations.
To mitigate for 0.61 acre of buffer impact within Zone 1, the applicant proposes to restore 5.8
acres of stream buffer in a tract located adjacent to Mussel Run, which is approximately four
miles northeast from the site. This is a 9.5:1 mitigation ratio. Please see the enclosed mitigation
plan for further details.

Table 1. List of tree species that a licant will lant within Zone 1 of Lake Nina (min. of 5).
Common Name Scientific Name
River Birch Betula nigra
Green Ash Fraxinus pennsylvanica
Tulip Poplar Liriodendron tulipifera
Sycamore Platanus occidentalis
Southern Red Oak Quercus falcata
Water Oak Quercz~s nigra
Willow Oak Quercus hellos
Ironwood Carpinus caroliniana
Carolina laurel-cherry Prunus caroliniana
Sassafras Sassafras albidum
Table 2. List of shrub species that applicant will plant within Zone 1 of Lake Nina (min. of 5).
Common Name Scientific Name
Painted Buckeye Aesculus sylvatica
Silverling Baccharis halimifolia
American Beautyberry Callicarpa americana
Strawberry Bush Euonymus americanus
Witch Hazel Hamamelis virginiana
Dog Hobble Leucothoe racemosa
Wax Myrtle Myrica cerifera
Dwarf Azalea Rhododendron atlanticum
Highbush Blueberry Vaccinium corymbosum
Cree ing Blueberry Vaccinium crassifolium
Lowbush Blueberry Vaccinium pallidum

Proposed
Emergency Spillway
^\ Proposed Splllway ~~\\`, /
\ // Drai age S\

i EXISTING MAINTAINED GRASS BUFFER
PRO SED LAKE/POND
- - DWO STREAM LINEATION LIMIT
:A~
~~,~~~..
PROPOSED TURF
i

PROPOSED WOODY BUFFER WITH LOW GROWING
r 1 I PROPOSED WOODY BUFFER WITH TREES

I IU/ J/
j / /_Ll/~L_LLLL~
i PROPOSED BUFFER IMPACTS (0.61 oc)
Buffer Impact fro am:
Exempt
Buffer Impact: 0.19

Buffer Impact: 0.08
r~fl ~'
r ~.~~ a.
O
~x `" ~ FIGURE 6. LAKE NINA
z p
,y "~
>~ ~ ~

.
~~°~~
~
CUTTER CREEK PLANTATION

-~ ~
,
a i,~ o ~o0 200
~ _
40o c~
GREENE COUNTY, NORTH CAROLINA
~' W
~: -~ "
.=.a~~~~_~= = a'~~
~r1~ ~ JULY 2007; revised DECEMBER 2007
,~ ~
=~' ~~

t
Cutter Creek Plantation
Greene County, NC
DWQ Project # 07-0156
Action ID# SAW-2007-02828
Neuse Buffer Mitigation Plan
Prepared by:
Land Management Group, Inc.
Wilmington, NC
Prepared for:
Mill Run Development Group, LLC
Greene County, NC
December 2007

Cutter Creek Development
Neuse Buffer Mitigation Plan
I. Introduction
The proposed Cutter Creek development is located along the southern boundary of Rainbow Creek
in Greene County. The tract is approximately 624 acre and is located within the Neuse River
watershed (HUC# 03020203). Rainbow Creek is a large second order tributary of Contentnea
Creek which drains into the Neuse River approximately 14 miles southeast of the site. A majority
of the land within these watersheds is used for agriculture production which has contributed to the
decline in overall water quality over the past several decades.
At the present time, the applicant has submitted a permit application requesting 2,550 linear feet
(If) of stream impact that would occur as a result of golf course construction which includes a 10.5
acre lake planned for the central portion of the property. Permanent buffer impacts of
approximately 0.61 acres are also proposed as part of the lake construction. Site visits by both the
US Army Corps of Engineers and NC Division of Water Quality have confirmed jurisdiction over the
feature in question. As of a result of this determination, the applicant retained Land Management
Group, Inc. to assist with the development of a buffer mitigation plan that will satisfy current
mitigation guidelines published by both the USACOE and NC DWQ.
II. Current Site Conditions
Overall, a majority of the site 0400 acres) has been actively farmed for the past several decades.
Planted crops included tobacco, soybeans, corn, and cotton. While all of these commodity crops
require regular amendments of fertilizer and herbicide, cotton requires the largest amounts on
average and most likely had the greatest impact on water quality within Rainbow Creek. In
addition to the farming activities, a fertilizer production plant is also currently located within the
property. This plant focuses primarily on nitrogen-based fertilizers and contains large amounts of
the concentrated nutrient and other hazardous chemicals on-site. The applicant will be closing this
facility and relocating production during the course of the proposed development.
The stream feature that would be impacted by the proposed lake is located in the central portion of
the property and is a first order tributary of Rainbow Creek. Approximately 1,200 linear feet (If) of
this proposed impact would take place in areas that have been channelized to improve agriculture
drainage. The areas have no vegetated buffer and likely support little aquatic life during periods of
normal rainfall. The remaining 1,300 If of stream maintains a vegetated buffer of 130'-150' and
more natural plan and profile typical of Coastal Plain streams in this area. As a result of the
existing buffer and limited channelization, this section likely supports a higher degree of ecological
function than the upper portions of the tributary.

III. Proposed Mitigation
a. Neuse Buffer Mitigation
Several parcels throughout the Greene County area were reviewed to determine if any potential
restoration projects could be initiated. A parcel located on the eastern side of Mussel Run was
chosen as a possible restoration site (Figures 1-4). The parcel is approximately 100 acres in size
and contains 2,700 If of farm ditches. These ditches have been dug throughout the floodplain of
Mussel Run to enhance drainage in the surrounding farm fields. According to historic aerial
photography, these ditches have been in existence since the mid 1960's. A majority of this
floodplain is mapped as a Johns sandy loam series by NRCS soil scientists. These soils typically
maintain seasonal high water tables at or near the surface for a significant duration.
These ditches have little to no vegetated buffer (<10') throughout the property. Depths average 4-
6' and widths vary from 3-4', with little to no sinuosity observed. The feature has been channelized
and is directly connected to Mussel Run. According to the property owner, this feature transports
water an average of 6 months a year. This is supported by the existence of bank scour areas and
a normal high water line throughout the reach.
Buffer restoration is proposed in a 200' corridor directly adjacent to the 2,700 linear feet of existing
ditches (Figure 5). Approximately 2,100 of the existing ditch will be filled and relocated to provide a
connection between two small ponds on the property. The relocated feature will vary in depth from
1-2' and will be designed to enhance the biological function of the ponds. At the present time, the
existing ponds are sparsely vegetated and have steeply sloped banks. These banks will be graded
to a more gentle 3:1 slope during construction to provide a more stable bank for planting of bald
cypress (Taxodium distichum) and swamp black gum (Nyssa biflora). These species will be
planted throughout both pond areas, which total 1.2 acres.
Outside of the pond areas, a 50' buffer totaling 5.8 acres, will be planted with a mixture of native
hardwood seedlings including Atlantic white cedar (Chamaecyparis thyoides), river birch (Betula
nigra), and green ash (Fraxinus pennsylvanica) at a density of 600 stems per acre. Grading within
the remaining portions of the agriculture drainage ditch will also take place to create a 3:1 slope
throughout the entire project area. An additional 350' swale will also be created to expand the
planting into frequently flooded portions of the farm field, providing a total of 3,600 If of buffered
channel. Overall, this acreage is designed to provide compensatory mitigation for the buffer
impacts in Zone 1 currently proposed as part of the lake construction process. The restored
acreage represents a final mitigation ratio of greater than 9:1.
While the buffer will be planted with wetland species and will likely experience periods of
inundation, the designed channel will have a lateral drainage effect ranging from 40-75' based on
NRCS guidelines. By providing artificial drainage within this corridor, on-site conditions will remain
consistent with current guidelines regarding buffer restoration projects. These guidelines
differentiate between the hydrology found in restored wetland systems and riparian buffers which
correlate to changes in seasonal high water tables levels.

b. Coastal Plain Headwater Wetland Restoration
In addition to the 7.0 acres, an additional 150' buffer planting totaling 19.4 acres, will also be
established on the property. This area will mimic a Coastal Plain Headwater wetland system which
contains a similar plant assemblage as the initial 50' buffer, but will utilize species such as tulip
poplar (Liriodendron tulipifera) and water oak (Quercus nigra) in areas of higher landscape
position. Headwater systems are typically associated with the upper reaches of the watershed and
contain a mixture of ephemeral and intermittent drainage features. In this project, the drainage will
be established through the realignment of the existing ditch network within the property. The
reestablished channels will vary in depth from 1-2', connecting the restored cypress/gum pond
areas and eventually draining to Mussel Run.
Through the reduction of the cross-sectional area of the existing ditch network, both the frequency
and duration of flooding events will increase throughout the 200' wide buffer area. As a result,
wetland functions will improve, reducing both chemical and sediment pollution within the
watershed.
The final stage of the proposed mitigation plan will establish a 10 ac. plot directly adjacent to the
buffer and Mussel Run which will be planted in characteristic hardwoods as part of the
Conservation Reserve Enhancement Program (CREP) administered by the Farm Service Agency.
This program requires that the land be kept out of cultivation for a minimum of 10 years following
planting.
The project also coincides with a 26 acre buffer restoration project that was supervised by Land
Management Group, Inc. on the western side of Mussel Run. This project was approved the NC
Ecosystem Enhancement Program (NCEEP) and is currently in the second year of annual
monitoring. Hardwood seedlings such as American sycamore and green ash have already
exceeded 12' in height and survivorship throughout the site has exceeded project goals. Plantings
throughout the proposed buffer project will follow a similar methodology and community type.
If implemented, the proposed project will provide tangible benefits to water quality within the
Mussel Run/Contentnea Creek watershed. A majority of this area is currently used for cultivation
of commodity crops that require nutrient amendments in excess of 100 pounds per acre in addition
to large amounts of pesticide. Assuming an uptake of 60% of applied nitrogen and 10% of applied
phosphorus, over 1,000 pounds of fertilizer will be lost to runoff in this area per year. Along with
the reduction in nutrient loading, turbidity will also be reduced through the grading of the ditch
banks and installation of hardwood seedlings.
IV. Construction Plan
Prior to initiating site work, all applicable permits will be secured. These include but are not limited
to a sediment/erosion control plan and a nationwide #27 which will cover the relocation of the
"blue-line" ditches within the property.
Following agency approval, construction is scheduled begin in late January 2008. Construction
and planting 0600 per acre) will take approximately two weeks. Once site work is complete, an

as-built report will be compiled and submitted to both NC DWQ and the US Army Corps of
Engineers.
IV. Project Monitoring and Contingency Plan
All plantings will be monitored for a period of five years to determine the success of the project. A
total of six (6) 0.10 ac. permanent monitoring plots, representing 2% of the project area, will be
established. The success criteria will be based on survivorship totals which meet or exceed 320
woody stems per acre at the end of the five year monitoring period. Hydrology within the site will
be monitored using shallow groundwater monitoring wells. A total of three (3) 40-inch wells will be
established throughout the project area. Each well will take daily readings of the current water
table depth. Well data will then be graphed in addition to rainfall totals from the Kinston airport and
presented in the annual monitoring report. In order to meet the appropriate success criteria these
areas must demonstrate water table depths of less than 12 inches for a consecutive number of
days equal to or greater than 5% of the growing season.
Flow events will also be monitored using guidelines published by the USGS. This method involves
the collection of stream flow in cubic feet per second following different precipitation events (.5, 1 ",
etc.) using a calibrated flow meter and compiling cross-sectional area data. Collected data can
then be used to determine both the total volume of flow for the restored system on an annual basis
as well as its reaction to specific rain events. Given the small watershed size and extensive
hydrologic modifications within the adjacent properties, no specific success criteria for stream flow
is proposed. However, areas of overbank flooding, scour, or wrack line deposition, which attest to
flow within the system, will be documented in the annual report.
Each annual monitoring report will contain a brief narrative discussing the current site conditions,
photo documentation, well/stream flow information, and plot data. Copies of the report will be
provided to both NC DWQ and the US Army Corps of Engineers.
In the event the project does not meet the aforementioned success criteria, a contingency plan will
be developed. This plan will likely include additional plantings in areas that experienced above
average mortality and an extension of the annual monitoring events.
V. Conclusion
Although no in-stream habitat will be restored under this proposal, a total of 13,450 linear feet of
Rainbow Creek have been placed in conservation easement, providing fora 5,2:1 preservation
ratio. The buffer restoration project will provide for improved water quality and wildlife habitat
within the watershed which exceeds the area of proposed impact. By combining this project (26.4
ac.) with the adjacent NCEEP and CREP projects, approximately 60 acres of farmland within the
floodplain of Mussel Run will be removed from cultivation. The proposed project will be designed
to restore the appropriate riparian, hardwood community and will be protected in perpetuity with a
conservation easement.

I 'y',~ ~f
~G~i ~ ~ \
9p
~~,
heat
v
~9p
Il
a

R:
*Boundaries are approximate and are
not meant to be absolute
Map Source: North Carolina Atlas 8~ Gazetteer. Pg 64.2003 SCALE 1" = 1 Mile
Cutter Creek Plantation
Greene County, NC LMG Figure 1
Mill Run Development Group Lnvn cHnxncsMax~~ cxouP ~~~: VlCinity Map
40-06-303P Environmental Cons~tltanrs
May 2007
~: U`
U
f' a ~ .......
cx ~' ~.
1
vay URM(~,~ '~ ~~
-. S .~
`t ` ,?
~Q'
fii Bh'r~~
~~' . ~ ;;.
:,
r~~>rion
>~,
,~1t~
yn
~:
__: .,.
,_ ~~ .
~~~(
.:~~ sr
-- os ~ arF ~o
,K~t. O E~ +t°
~' f ? a
3r iJ ~ LL
4
Q~ vl
c7 ~~~
~ .'Y
i
~~~,` ~ i
tvt r
l
i
~.
~ ;,
+7
~HURG~ flD
'~..
.'

Map Source: Hookerton & Snow Hill Quadrangles 7.5 minute (topographic) 1990
SCALE 1" = 2000'
Cutter Creek Plantation
Greene County, NC LMG Figure 2
Mill Run Development Group LANDMANAGL'MENTGROUPuc USGS Topgraphic Map
40-06-303P Environmental fonsultants
Mav 2007
*Boundaries are approximate and are
not meant to be absolute,

*Boundaries are approximate and are
not meant to be absolute
Map Source: NRCS Soil Survey.
SCALE 1" = 1200'
Cutter Creek Plantation
Greene County, NC LMG Figure 3
Mill Run Development Group LAND MANAGL'ML'N1' GROGY inc SOIIS Ma
40-06-303P E~,~r,~,,,,,P~,«,i c~„s~,r«~„<< p
Mav 2007

*Boundaries are approximate and are
not meant to be absolute.
Map Source: 1998 NAPP aerial photography
SCALE 1" = 1200'
Cutter Creek Plantation Fi ure 4
Greene County, NC LMG 9
Mill Run Development Group ~vnM~A°,;,~~r',°"°~Y"~= Aerial Photograph
40-06-303P Environmeottil Cvnsultrurts
Mav 2007

~"`~..
~` ~ g
a ,
~~ r ~,
r_. ~-,.

~ _`
.. ,.. ~ ,

„, .,
r
j
;v
y
.-
~~ ~ X
:

~~ r
~ ~~ ~_

~~~ '...
~ ~~~~
~..

~~
x
w
~~

.. ,
-
~.

~1t 1 ~ ".
Y.„& ~
. ~7i'~~ g' ~ .~ _ ~Q. ~ 'C
LM.
,} ~ x
! w '~

' «y a.
~
1 ~ ~' '
~ Legend
`'
~~,
` Q ~ Property Boundary
~~
5 ~~~~' ~ Existing Roads

',, a
;, ~ ~ Existing Ditches

< O` Buffer Restoration Area
- ~~
-
50' Neuse Buffer Mitigation (5.8 ac.)
~,
~ Coastal Plain Headwater Wetland Restoration (19.4 ac.)
~
' Y~ Cypress Pond (1.2 ac.)
`~ Proposed Channel Alignment (-3,050 It)
CREP Planting (-10ac.)

N
400 200 0
Scale 1 "= 400'
Cutter Creek Figure 5.
Buffer Restoration Plan
Neuse River Buffer Mitigation Plan
400 Feet LM G
~ Greene County LAND MANAGEMENTGROLTPmr..
Environmental Consultants