Response to comments WEI Tar-Pam 01_Great Meadow Mitigation Plan_FINAL

Wildlands Engineering, Inc.  phone [phone]  fax [phone]  1430 S. Mint Street, # 104  Charlotte, NC 28203

August 22, 2024

U.S. Army Corps of Engineers
Regulatory Division
Raleigh Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587

Attention: Erin Davis

Subject: IRT Comment Response – Second Response
Wildlands Tar-Pamlico 01 Umbrella Mitigation Bank
Great Meadow Mitigation Site, Nash County
Tar-Pamlico River Basin HUC 03020101
USACE Action ID No. SAW-2021-01714
DWR No. 2021-1423

Dear Erin:

At the IRT’s request, we are responding to the second round of comments issued in an email from you
dated July 26, 2024. The comments in the email were a follow-up to the original IRT comments on the
mitigation plan issued April 9, 2024. We also had a conference call with IRT members to discuss the
remaining comments on August 2, 2024. Below are responses to each of the remaining comments
included in the July 26 email. The original comment, Wildlands’ original response, and follow up
comments are all included below. Final responses from Wildlands are included in bold text. We are also
providing additional information with this letter to support these comment responses as you have
requested.

DWR comment a. Are two crossings needed on Shard Branch? It seems like access could still be
provided with one. Additionally, the northern crossing will impact wetlands which could be avoided if
the crossing was eliminated or moved south where there are no wetlands. (This wetland, BB, scores with
a SAM score of Medium).
Wildlands response: The landowner requires the two crossings in the location where the existing
crossings are. They are needed and located to provide access to different areas of pasture.
USACE follow-up comment: Please provide additional information on coordination efforts made with the
landowner to reduce the number of crossings on Shard Branch, and please elaborate on the need for
multiple access points (e.g., topographic constraints, landlocked property). Since this is a full restoration
reach, the rationale that the crossings are in existing locations isn’t as applicable as if it were an
enhancement reach. Multiple crossings on a single tributary are prone to have adverse effects on a
project’s functional uplift due to fragmentation, as well as potential long-term maintenance and
encroachment issues. Recently, the IRT evaluated a project justification for multiple crossings on a single
2

tributary and determined that one of the crossings was redundant, which resulted in a credit reduction
to account for the fragmentation impact.
DWR follow-up comment: DWR agrees with the USACE comment above. In general, more justification
regarding the number and location of crossings would be helpful. DWR Comment m also inquired about
the positioning of southern crossing on Shard branch, which was revised from the draft prospectus
location due to the exclusion of the Boy Scout tract from the easement. However, since the location of
this crossing has already been adjusted once, it is unclear why it is not possible to adjust its proposed
orientation/positioning now.
Wildlands revisited the issue with the landowner following the comments from the IRT members. The
landowner remains adamant that both crossings on Shard Branch are needed. She provided an email
response to explain her position, which is attached to this letter.

DWR comment g. Section 3.3.3 states that the LSS report is included in Appendix 1. I couldn’t find it in
the hard copy, or the digital version submitted to Laserfiche. I see a soils map (Figure 7), which I am
assuming is based on the NRCS Soil Survey data, but not a full soils report or even a map with the soil
boring locations. Please provide this report and associated map in the final plan.
Wildlands response: Wildlands originally proposed wetlands mitigation on this site but decided not to
move forward with claiming credits for wetlands so that buffer/nutrient offset credits could be
generated. Section 3.3.3 will be revised to better reflect this and will not refer to the LSS report. The LSS
report should no longer be needed in the appendix. However, it was submitted with the prospectus.
USACE follow-up comment: Please include all supporting documentation in the final plan appendices.
The data collected as part of the LSS report is still applicable to the proposed floodplain connectivity and
associated stream functional uplift. It could also be useful information for future reference if there are
any vegetative establishment concerns where soils may be a factor post construction.
The LSS report will be included in the appendix as requested.

USACE comment h. Page 14, Section 6.8 – While Section 4.3 notes that flood modeling is not expected
to be required for floodplain compliance, have you considered modeling to evaluate the risk of
hydrologic trespass if/when beavers dam project reaches after site closeout? How susceptible could the
open fields along easement boundaries be to flooding if beaver dams raise water levels above what is
calculated for proposed Priority 1 restoration?
Wildlands response: We have not performed any hydraulic modeling for this project. We assume the risk
to flooding from beaver dams is similar to other projects with similar site conditions.
USACE follow-up comment: Due to the current presence of beaver onsite, assuming that the risk of
flooding is similar to other projects without modeling or conducting a site-specific assessment does not
sufficiently address our concern about the potential for future hydrologic trespass. As the project
approving agency, we need to ensure that potential risks associated with a project based on existing and
proposed conditions have been adequately identified, sufficiently evaluated, and appropriately
3

addressed in the approved plan. Please provide site-specific data to support your risk assumption
concerning beaver related hydrologic trespass.
DWR follow-up comment: DWR agrees with the USACE that the provided response is insufficient.
Additionally, some similar projects in the past have had issues with hydrologic trespass, which is the
reason for IRT concern.
We analyzed the potential for flooding outside the conservation easement due to beaver dams at
several locations along the restoration reaches. We assumed that the beaver dams would cause a
one-foot rise on the floodplain (which is likely more than would occur from a dam contained within a
channel and not built across the floodplain). We looked at valley cross sections for each of these
locations and found that a one-foot rise would not flood areas outside of the easement. Valley cross
sections showing the extent of flooding from the one-foot rise and the easement boundaries are
shown on an attachment to this letter. A map of the locations of the cross sections is also attached.
None of the cross sections show flooding beyond the easement boundary. Please let us know if this is
sufficient evidence to assume that beaver dams will not cause hydrologic trespass in adjacent
pastures.
USACE comment i.b. Pages 24-24, Section 7.0, Table 11 - Based on the current conditions and the level
of functional uplift proposed for Fisher Branch Reach 2, we support a 4:1 enhancement ratio.
Wildlands response: The final prospectus indicated a 2.5:1 ratio for this reach. The treatments for this
reach will include bank stabilization, cattle exclusion, invasives removal, and buffer planting. Wildlands
will add a random vegetation plot to monitor the success of planted trees in the area where privet is
removed.
USACE follow-up comment: Please note that credit ratios are not approved at the prospectus stage.
Stream enhancement reach ratios are evaluated based on the proposed level of work and associated
functional uplift (e.g., full reach planting vs. partial/one-sided reach planting). Please provide a
breakdown of the treatments proposed for this reach for IRT review, including the total length of bank
stabilization and percentage of bank stabilization out of the entire reach bank length, and the total area
of planting and percentage of planting out of the entire reach buffer area.
DWR follow-up comment: DWR supports the request for additional information in order to determine
the credit ratio for this reach. It would also be helpful if reach breaks are shown on the design and
planting plans, and that bank stabilization measures are shown on the design plans as well (I did not see
any on the plans for this reach).
A breakdown of the treatments proposed for this reach is provided below. Based on this plan for
Fisher Branch Reach 2, we propose a 2.5:1 credit ration.
• Treatments proposed for this reach include bank grading, brush toes, cattle exclusion,
invasives removal, and buffer planting.
• Total length of bank stabilization and brush toes for Reach 2: 95.5 LF
• Percentage of bank to be stabilized for Reach 2: 21.5%
• Total area of buffer planting for Reach 2: 0.67 acres
• Total percentage of riparian buffer within easement to be planted for Reach 2: 48% of Reach 2
will be planted. The rest of the reach buffer is wooded.
4

USACE comment l.a Figure 12 - Several of the fixed veg plots do not appear to be located within
designated planting areas based on Sheets 4.2 – 4.9 (two on Fisher Branch, one on Shard Branch Reach
2, and two on Fox Branch Reach 2), please confirm and update as necessary. Please add a fixed veg plot
to Fisher Branch Reach 3.
Wildlands response: After revising the planting zones based on the grading plan and GPS tree line, the
number of planted acreage reduced from 26 to 20. The vegetation plots were reduced from 21 to 16 (10
fixed and 6 random). Vegetation plot numbers and locations will be updated to reflect the accurate
planting zones in the final Mit Plan.
USACE follow-up comment: Please provide a copy of the updated monitoring Figure 12 for us to review
the referenced changes.
An updated monitoring map (Figure 12) is attached.
Please contact me at 919-302-6919 if you have any questions.
Thank you,
Jeff Keaton, PE
Project Manager

Attachments
1. Landowner email about crossings on Shard Branch
2. Information regarding hydrologic trespass from beaver dams
3. Updated monitoring map (Figure 12)

From: fisherfarmsnc <[e-mail]>
Sent: Monday, July 29, 2024 9:50 PM
To: Chris Roessler <[e-mail]>
Subject: RE: FW: upper Shard crossing
This crossing location was used historically. It was a piped crossing with a path when I moved ro the
farm in 1985.
Although the pipe has since crushed ,
the entrance and exit i have never seen rutted or mired.
This approach is the most practical one because it is already in existance, the grade is the best for
truck travel going up the hill, it is already packed from 200 years of use by traffic, and the exit of
cattle from this field will be the most natural flow toward the barn .
This is one of the oldest farmsteads in the county. The settlers here chose reliable crossings to get to
their fields and neighbors. I trust their building sites and road sites to be sound.
Linda Fisher
Sent from my U.S.Cellular© Smartphone
165
170
175
180
165
170
175
180
1+75 2+00 2+50 3+00 3+50 4+00
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

3
+
6
9
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

1
+
8
5
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

1

-

F
i
s
h
e
r

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
1
160
165
170
175
180
160
165
170
175
180
1+00 1+50 2+00 2+50 3+00 3+50
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

3
+
4
6
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

1
+
3
4
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

2

-

F
i
s
h
e
r

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
2
160
165
170
175
160
165
170
175
0+00 0+50 1+00 1+50 2+00 2+50 2+83
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
1
4
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

2
+
7
5
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

3

-

F
i
s
h
e
r

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
3
160
165
170
175
160
165
170
175
0+50 1+00 1+50 2+00 2+50 2+75
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

2
+
7
1
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
8
4
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

4

-

F
i
s
h
e
r

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
4
160
165
170
175
160
165
170
175
0+00 0+50 1+00 1+50 2+00 2+50 2+75
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
5
6
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

2
+
5
3
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

5

-

F
i
s
h
e
r

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
5
155
160
165
170
155
160
165
170
0+00 0+50 1+00 1+50 2+00 2+36
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
2
0
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

2
+
1
5
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

6

-

F
i
s
h
e
r

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
6
155
160
165
170
155
160
165
170
0+00 0+50 1+00 1+50 2+00 2+50
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

2
+
4
4
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
1
7
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

7

-

F
i
s
h
e
r

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
7
140
145
150
155
160
165
140
145
150
155
160
165
0+00 0+50 1+00 1+50 2+00 2+50 3+00 3+50 4+00 4+12
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

3
+
2
7
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
5
1
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
40
0
7
0
JA
G
808
-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

8

-

F
i
s
h
e
r

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
Beaver Dam
175
180
185
190
175
180
185
190
0+00 0+50 1+00 1+50 2+00 2+50
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
1
2
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

2
+
1
1
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

9

-

S
h
a
r
d

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
9
175
180
185
190
175
180
185
190
0+00 0+50 1+00 1+50 2+00 2+50
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
3
1
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

2
+
1
6
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

1
0

-

S
h
a
r
d

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
10
170
175
180
185
170
175
180
185
0+50 1+00 1+50 2+00 2+50
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

1
+
9
4
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

1
1

-

S
h
a
r
d

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
11
170
175
180
170
175
180
0+00 0+50 1+00 1+50 2+00 2+50
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
4
3
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

2
+
1
0
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

1
2

-

S
h
a
r
d

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
12
165
170
175
180
165
170
175
180
0+50 1+00 1+50 2+00 2+50 3+00
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

1
+
2
8
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

2
+
7
7
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

1
3

-

S
h
a
r
d

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
13
160
165
170
175
180
160
165
170
175
180
0+00 0+50 1+00 1+50 2+00 2+50 3+00 3+50
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

3
+
0
1
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
0
7
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

1
4

-

S
h
a
r
d

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
14
155
160
165
170
155
160
165
170
0+00 0+50 1+00 1+50 2+00
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

0
+
0
8
CO
N
S
E
R
V
A
T
I
O
N

E
A
S
E
M
E
N
T
ST
A

=

1
+
8
8
X:
\
S
h
a
r
e
d
\
P
r
o
j
e
c
t
s
\
W
4
0
0
7
0
_
G
r
e
a
t
_
M
e
a
d
o
w
\
C
a
d
d
\
E
x
h
i
b
i
t
s
\
B
e
a
v
e
r

D
a
m

E
x
h
i
b
i
t
.
d
w
g
Au
g
u
s
t

2
3
,

2
0
2
4
Sh
e
e
t
Ch
e
c
k
e
d

B
y
:
Jo
b

N
u
m
b
e
r
:
Dr
a
w
n

B
y
:
Pr
o
j
e
c
t

E
n
g
i
n
e
e
r
:
Da
t
e
:
Re
v
i
s
i
o
n
s
:
31
2

W
.

M
i
l
l
b
r
o
o
k

R
d
,

S
u
i
t
e

2
2
5
Ra
l
e
i
g
h
,

N
C

2
7
6
0
9
Te
l
:

9
1
9
.
8
5
1
.
9
9
8
6
Li
c
e
n
s
e

N
o
.

F
-
0
8
3
1
40
0
7
0
JA
G
8-
2
0
-
2
0
2
4
Gr
e
a
t

M
e
a
d
o
w

M
i
t
i
g
a
t
i
o
n

S
i
t
e
XS

1
5

-

S
h
a
r
d

B
r
a
n
c
h
Be
a
v
e
r

D
a
m

A
n
a
l
y
s
i
s
Beaver Dam
15
Beaver Dam Exhibit
Great Meadow Mitigation Site
Nash County, NC
August 21, 2024
2021 Aerial Photography
!P
!P
!P
XS 1
XS 8
XS 6
XS 5
XS 4
XS 2
XS 10
XS 13
XS 12
XS 11
XS 14
XS 3
XS 7
XS 9
XS 15
Fi
s
h
e
r

B
r
a
n
c
h
Sh
a
r
d

B
r
a
n
c
h
S
w
i
f
t

C
r
e
e
k
Reach 2
Reach 3
Reach 2
Reach 1Reach 1
¹0 200 400 Feet
Project Location
Conservation Easement
Internal Crossing
Cross Sections
Proposed Stream Approach
Restoration 1:1
Enhancement I 1.5:1
Enhancement II 2.5:1
Enhancement II 4.5:1
No Credit
Non-Project Stream
Figure 12. Monitoring Components Map
Great Meadow Mitigation Site
Wildlands Tar Pamlico 01 Umbrella Mitigation Bank
Tar-Pamlico River Basin (03020101)
Nash County, NC
2021 Aerial Photography
Fi
s
h
e
r

B
r
a
n
c
h
Sh
a
r
d

B
r
a
n
c
h
Fo
x

B
r
a
n
c
h
Gi
d
e
o
n

S
w
a
m
p
S
w
i
f
t

C
r
e
e
k
!A
!A
!A
GF
GF
GF
GF
GF
GF
GF
GF
GF
GF
GF
GF
GF GF
GF
GF
GF
GF
GF
GF
GF
GF
GF
GF
GF
GF
Reach 2
Reach 3
Reach 2
Reach 1
Reach 2
Reach 1Reach 1
Reach 1
[[
[[[
[
[
[
[
[[
[[[
[[
[[
[[
[[
[[
[[
[[
[[
[[
[[
[[
[[
[[
[[
[[
[[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[[[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[[[
[
[
[
[
[
[
[
[[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[[[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[[[[[[[
[
[
[
[[
[
[
[
[
[
[[
[
[
[
[
[
[
[
[
[
[
[[
[
[
[
[
[
[
[
[[
[[
[[
[[
[[
[[
[[
[[[[
[[
[[
[[
[[
[[
[[
[[
[[
[[[
[
[[[[
[[
[[
[[
[[
[
[
[[[[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
[
!P
!P
!P
!P
!A
!A
Project Location
Conservation Easement
Internal Crossing
Existing Wetlands
Open Water
Utility Easement
Fixed Vegetation Plot
Random Vegetation Plot
Proposed Stream Approach
Restoration 1:1
Enhancement I 1.5:1
Enhancement II 2.5:1
No Credit
Cross-Section
[Proposed Fencing
ROW
Utility
Non-Project Stream
Topographic Contours (2')
!A Crest Gauge
!A Flow Gauge
!A Groundwater Gauge (Not
for Credit)
GF Photo Point
!P Reach Breaks
¹0 300 600 Feet

Wildlands Engineering, Inc.  phone [phone]  fax [phone]  1430 S. Mint Street, # 104  Charlotte, NC 28203

July 9, 2024

U.S. Army Corps of Engineers
Regulatory Division
Raleigh Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587

Attention: Todd Tugwell

Subject: IRT Comment Response
Wildlands Tar-Pamlico 01 Umbrella Mitigation Bank
Great Meadow Mitigation Site, Nash County
Tar-Pamlico River Basin HUC 03020101
USACE Action ID No. SAW-2021-01714
DWR No. 2021-1423

Dear Todd:

We have reviewed the IRT’s comments on the draft mitigation plan for the Great Meadow Mitigation
Site under the Wildlands Tar-Pamlico 01 Umbrella Bank. A memorandum with mitigation plan review
comments from IRT members was sent in an email on April 9, 2024. At the IRT’s request, we are
responding to the comments with this letter prior to submitting the final mitigation plan. Below are
responses to each of the IRT’s comments. Your original comments are provided below followed by our
responses in bold italics.
Maria Polizzi, NCDWR
a. Are two crossings needed on Shard Branch? It seems like access could still be provided with one.
Additionally, the northern crossing will impact wetlands which could be avoided if the crossing
was eliminated or moved south where there are no wetlands. (This wetland, BB, scores with a
SAM score of Medium)
The landowner requires the two crossings in the location where the existing crossings are.
They are needed and located to provide access to different areas of pasture.
b. Is the crossing needed on Fox Branch? No crossing is currently shown on the existing conditions
map, so further discussion about the need for this crossing would be helpful. This crossing is also
not mentioned in Section 3.5 (Site Constraints). In general, please provide more detail about the
necessity of crossings in the report.
There is a crossing existing in this location. It is needed to access a large area of the
landowner’s property east of Fox Branch.
c. DWR appreciates the diversity of structure types proposed in this project.
Noted, thanks.
2

d. Please include at least 2 wetland gauges on Fisher Branch and Shard Branch to monitor the effect
of stream restoration on wetland hydrology.
We will install a gauge on Fisher Branch and a gauge on Shard Branch to monitor the effect of
stream restoration on wetland hydrology.
e. More photos of Gideon Swamp would be appreciated, there is only one included. Photos of
other reaches are very helpful.
Additional photos of Gideon Swamp will be added.
f. I do not have as much background on this project as some other IRT members, but I want to
make sure that I understand everything correctly, so my apologies for any repeated
questions/discussion. I see that in the 9/23/22 correspondence from Samantha Daily a 2.5:1
credit ratio for Gideon Swamp was agreed upon. Was this wider buffer area proposed for buffer
credit and nutrient offsets at that time? If not, I want to make sure we are not double dipping.
Additionally, the removal of a crossing is described as an additional enhancement measure, but
I don’t see a crossing on the existing conditions map, and based on other sections of the plan it
sounds like this was a proposed crossing, not an actual crossing to be removed. Am I
understanding that correctly? Depending on the answers to the above questions, it may be
worth having an updated discussion about the credit ratio for this area. DWR is in support of a
higher-than-normal credit ratio due to the existence of the T&E species in the reach and does
not wish to disrupt previously agreed upon ratios, so clarity on this topic would be most helpful.
The approach for Gideon Swamp and the credit ratio of 2.5:1 was developed through
correspondence with the IRT which is documented in Appendix 4. The option that was chosen
(Option 4) includes the following:
• Remove crossing from project.
• Buy additional land (2.8 ac) to put under conservation easement.
• Fence out cattle.
• Treat invasives.
• Remove beaver dam and trap beavers.
• Beaver management will continue through the life of the project.
• Do no other instream work.
The buffer mitigation plan has been updated so that there is no double dipping in the extra-
wide buffer of Gideon Swamp.
There is an old, existing crossing on Gideon Swamp that is still sometimes used by cattle.
Wildlands had originally planned to improve this crossing so that the landowner could utilize
it. Wildlands and the landowner agreed to remove the proposed crossing to protect the
habitat within Gideon Swamp.
g. Section 3.3.3 states that the LSS report is included in Appendix 1. I couldn’t find it in the hard
copy, or the digital version submitted to Laserfiche. I see a soils map (Figure 7), which I am
assuming is based on the NRCS Soil Survey data, but not a full soils report or even a map with
the soil boring locations. Please provide this report and associated map in the final plan.
Wildlands originally proposed wetlands mitigation on this site but decided not to move
3

forward with claiming credits for wetlands so that buffer/nutrient offset credits could be
generated. Section 3.3.3 will be revised to better reflect this and will not refer to the LSS report.
The LSS report should no longer be needed in the appendix. However, it was submitted with
the prospectus.
h. DWR appreciates that invasive management will begin prior to construction and sees benefit to
starting early on this.
Noted, thanks.
i. There are multiple symbols for existing trees. Do each of these symbols represent a different type
of tree? If so, can they be labeled?
The tree symbology is intended to represent different species of trees but we find that the
determinations that the surveyors make are highly inaccurate and we do not use that
information.
j. Would it be possible to increase the easement size slightly to include entire wetland units? If
cattle have access to a wetland that extends from the stream to the pasture, this can become a
source of water quality impairment. Excess nutrients, fecal coliform, turbidity, and other
pollutants will have a direct input to the system, minimizing the uplift that can be achieved by
the project.
The easement has been expanded to protect wetlands where possible, for example, along
Reach 2 of Shard Branch, Reach 3 of Fisher Branch, and Reach 2 of Fox Branch. Other wetland
areas that have been left out of the easement are in areas where the landowner would not
agree to expand the easement. The larger area west of Fisher Branch Reach 1 will be closed
off to livestock access by the fenced easement.
k. Multiple maps (including Figures 8, 9, 12 & 13) show Shard Branch Reach 1 as “Restoration
2.5:1”, while Table 11 lists the credit ratio as 1:1. Please ensure that all figures and/or tables are
up-to-date.
The mitigation ratio indicated on the concept map (Figure 8) was incorrect and will be
corrected. The proposed approach on Shard Branch Reach 1 is restoration, which was agreed
to during the prospectus site visit, at a typical ratio of 1:1.
l. The design plans show several woody structures (log vanes, woody riffles, etc.) along Shard
Branch Reach 1, which is intermittent. Is there concern about these structures decomposing over
time? If not, why not? If so, are there alternatives that can be utilized?
Wood structures are appropriate for this stream system and we have used them on
intermittent streams many times in the past. These structures may decay over a long period of
time, but the channels will be stabilized with large tree roots and functioning by that point.
m. Can the lower (southern) crossing on Shard Branch be straightened? Typically, it is preferable for
crossings to be as close to 90 degrees as possible. This minimizes the length of stream impact,
the width of buffer impact, and is also more stable. Is it possible to straighten the farm road
slightly allowing for an improved crossing?
The landowner needs to keep the designed orientation of this crossing as it is currently shown
4

on the plans. It follows the property line and is as close as possible (without encroaching on
the Boy Scout property) to her existing main road through the property. This road is used by
tractor-trailers and needs to be oriented as designed.
n. Is any supplemental planting planned for this project in areas that are already forested or
partially forested?
There is no supplemental planting planned for partially forested areas. However, the riparian
buffer planting zone will include planting areas that are currently stands of dense privet that
will be treated prior to or during construction.
o. DWR feels that the enhancement II ratio for Fox Branch Reach 2 should be lower. Typically, a 2.5:1
ratio involves spot bank shaping/repairs, some in-stream structures, full easement planting, and
potentially the addition of BMPs. Since no stream work is proposed and minimal planting, this
leaves cattle exclusion as the primary uplift, which would more closely align with a 4-5:1 ratio.
The final prospectus indicated a 4.5:1 ratio for this reach, so we will revert to that. The
treatments for this reach will include cattle exclusion, invasives removal, and buffer planting.
p. DWR appreciates the 3’ fencing offset from the CE.
Noted, thanks.
q. Design Sheet 5.6-5.7: The proposed fencing through the internal crossing appears to overlap with
the crossing itself for the crossing Fox Branch and lower Shard Creek. It is somewhat difficult to
tell as the crossings are not specifically shown on these figures, but based on station numbers
and comparison to other figures it appears that there may be overlap. Please clarify the plan for
the fencing in these areas.
The fencing is offset one foot from the edge of the roads in both cases. The roads are not
centered within the easement breaks.
r. Is there a reason why boulder toes were selected? These are a pretty hefty feature to use on an
intermittent reach of an almost coastal plain project. I understand the need to avoid a structure
that may rot, but since this is for bank stabilization rather than grade control, it seems like there
may be a better alternative than armored banks. I am open to discussion on this, as I am not an
engineer, but additional justification would be helpful if an alternative is not viable.
This site is hilly and rocky; we think that rock and wood structures are both appropriate here.
We prefer to use a variety of structures and revetments where appropriate.
s. Section 6.7.2 Land Management: I would be interested in what soil amendments are selected
and what soil testing is performed. I understand that this information is not available at this point
but would appreciate if it could be included in the as- built report or monitoring reports, if
additional soil amendments are added at a later point. Soil is a critical component of plant
viability and since this occurs later in the process, we do not often see these details. But it would
be useful to understand the standard practices and any variability in approaches across
landscape types, etc. I would also recommend incorporating organic matter however possible
(onsite mulching could potentially be a good source). Additionally, consider ripping the pasture
area in addition to roadbeds and construction-impact areas.
5

We will conduct soil testing (Mehlich-3 Extraction, predictive) across the site prior to
construction. This will inform any potential prescription of soil amendments which would
include an organic matter component. Description of amendments will be included in as-
built/monitoring reports. We will rip compacted areas such as haul roads and additional
pasture areas as needed to promote tree growth.
t. Are the sinuosity values, provided in Table 10 and the appendix tables, correct? For example,
Shard Branch Reach 1 in the appendix shows that minimum sinuosity is 7.5 and the max is 0.47.
Besides being listed backwards, these values are quite extreme and therefore make it difficult
to assess what a realistic average for the reach would be. Note that other reaches have similar
numbers, so this is not limited to Shard Branch. If these values are correct, please provide more
context on what these numbers mean and/or how they were calculated.
Unfortunately, the sinuosity values in the table were incorrect. The tables have been updated
with the correct values.
Kathy Matthews, USFW
a. I recommend that a schematic of the proposed double row of silt fence be added to the
construction plans, to make those requirements clear to the contractor(s). For example, the
plans should indicate the maximum distance between each row of silt fence (we recommend a
maximum of 5 feet), and a minimum offset for the silt fence outlets (we recommend a minimum
of 20 feet between outlets where possible). The construction plans and/or other contract
specification documents should include a requirement to follow all of the enhanced
sedimentation and erosion control measures that we provided in our February 9, 2023 letter to
Tasha King. In recent months, we have realized that these conditions often do not get passed on
to the construction contractor, and compliance has been an issue. Ensuring that the contract
specifications and construction plans explicitly include them as requirements will assist with
compliance.
Wildlands will follow these recommendations for the construction documents.
b. I also recommend that the Corps include implementation of these measures as a condition of
the permit:*
• Conduct work in Fisher Branch, Shard Branch, and Fox Branch in the dry, as much as
possible.
• Avoid aerial drift of herbicides or pesticides by utilizing only target application, such as
spot spraying, hack-and-squirt, basal bark injections, cut stump, or foliar spray on
individual plants.
Note that in Section 6.7.2 we proposed treating dense mats of pasture grasses
chemically before reseeding with native species involving methods such as boom
spraying. To comply with the intent of conditional measures agreed to, we propose
this be completed through the use of aquatic-safe formulations of herbicide such as
Round-Up Custom®, spraying when wind conditions are calm and risk of volatilization
is low, and by not conducting this treatment in close proximity to Gideon Swamp.
• Utilize a double row of silt fence, to ensure that erosion is captured effectively.
• Silt fence and other erosion control devises should not include outlets that discharge
6

closer than 50 feet to the top of Swift Creek.
• Silt fence outlets for each row of silt fence should be offset to provide additional
retention of water and sediment in the outer row.
• Conduct twice-weekly inspections of all erosion and sedimentation controls. In addition
to twice-weekly inspections, inspect also within 24-hours of rain events (including a 1-
inch total rain event or an event where rainfall rates are 0.3 inch/hour or greater).
Inspect all of the erosion and sedimentation controls to ensure the integrity of the
devices.
• Maintain all controls as necessary to ensure proper installation and function. Repair and
replace sections of controls as needed to minimize the potential for failure.
• Revegetate with native species as soon as possible.
• Any spills of motor oil, hydraulic fluid, coolant, or similar fluids into the riparian wetlands
or floodplain must be reported to the Corps and Service immediately.
• Educate the construction crew about the presence of sensitive species by providing
information or installing signs on the silt fence.
c. With the commitment to include the stringent erosion control measures from our February
9, 2023 letter in the permit conditions and contract specifications, the Service can concur
with a species determination of Not Likely to Adversely Affect for the Neuse River waterdog,
Carolina madtom, yellow lance, Atlantic pigtoe, and Tar River spinymussel.
Noted, thanks.
Erin Davis, USACE
a. Please QAQC any errors noted in the Table of Contents.
The Table of Contents will be updated.
b. Page 10, Section 3.5 –
a. Similar to the background given on Gideon Swamp in Section 4.2.1, it would be helpful if
you would provide a narrative that discusses the removal of the Boy Scouts property from
the proposed project since this change occurred after the final prospectus was public
noticed and the initial evaluation letter was issued. In response to this modification request
the IRT had identified concerns that needed to be addressed in order to support the project
moving forward, please include this email correspondence from June 2022 in Appendix 4.
We will provide a summary of the situation with the Boy Scout property. The email
correspondence will be included in Appendix 4.
b. With the removal of the Boy Scouts property from the project, please provide
justification for having two crossings on Shard Branch.
i. In the final prospectus the easement boundary extended from the property line at the
top of Shard Branch down to Swift Creek, and downstream easement break was
oriented to provide access from the Boy Scouts property to the Fisher property east of
Shard Branch. In the draft mitigation plan, this crossing has been repositioned to be
solely on the Fisher property and widened from a proposed 60-ft to 88-ft easement
7

break. The IRT asked for this crossing to be made internal to the easement, but the
necessity for this second crossing still needs to be explained.
Wildlands discussed eliminating the upstream crossing on Shard Branch with the
landowner. She was not open to eliminating it and needs the additional crossing to
access a pasture immediately west of Shard Branch. The location of this crossing has
shifted somewhat to the north from the prospectus and is now where the landowner
needs it to be.
ii. During the 2021 IRT site walk we discussed the possibility of relocating the Shard
Branch upstream crossing to the top of the easement boundary. Why wasn’t it feasible
to relocate this crossing?
The landowner requires the crossing to stay in its currently proposed location. In
addition, the easement is narrower in the currently proposed location and there will
be less wetlands impacts in this location.
c. It would be helpful to note in this section the utility right-of-way break in the conservation
easement area west of Gideon Swamp.
This will be noted in the final mitigation plan.
d. Page 16, Section 6.2 – Was distance from the project site a factor when selecting reference
sites? Given that the site is located at the edge of the Eastern Piedmont physiographic
province in the Eastern Slate Belt, please explain how Boyd Branch is a suitable reference
reach.
Distance from project site was not used to rule out potential reference reaches. As
described in Table 5, Boyd Branch is a low-slope alluvial stream with a similar landscape
position and slope to the project streams.
e. Page 20, Section 6 – What is the current use of Pond A? Is the pond remaining an open
water feature within the easement? If so, is there any intent for continued use of the pond?
Please confirm whether any allowable maintenance activities are being proposed.
Pond A is currently occasionally used as a water source for cattle. Water sources within
the proposed easement will be replaced with a livestock watering system. The landowner
will not use the pond going forward, so no maintenance activities are proposed.
f. Page 22, Section 6.7.1 – Was the coastal plain vegetative community selected based on a
local reference site? All of the stream reference sites are located in the piedmont and
mountain ecoregions.
Coastal plain small stream swamp was selected as the vegetative community based on the
existing species and physiographic characteristics of Great Meadow Mitigation Site while
considering the Site’s location in relation to the ecoregion boundary.
g. Page 23, Section 6.7.2 – Inclusion of this section is appreciated. Based on the IRT site walk
the privet coverage is significant, is any supplemental planting proposed in understory areas
where the privet will be removed? Please consider lessons learned from dealing with marsh
dewflower on other Wildlands’ projects.
8

There are some areas which will require additional planting when privet is removed prior
to/during construction. These areas will be mapped and added to the adjacent riparian
buffer planting zones and planted with the appropriate species.
h. Page 14, Section 6.8 – While Section 4.3 notes that flood modeling is not expected to be
required for floodplain compliance, have you considered modeling to evaluate the risk of
hydrologic trespass if/when beavers dam project reaches after site closeout? How
susceptible could the open fields along easement boundaries be to flooding if beaver dams
raise water levels above what is calculated for proposed Priority 1 restoration?
We have not performed any hydraulic modeling for this project. We assume the risk to
flooding from beaver dams is similar to other projects with similar site conditions.
i. Pages 24-24, Section 7.0, Table 11
a. Based on the current conditions and level of functional uplift proposed for Fox Branch
Reach 2, we support a 4:1 enhancement ratio.
The final prospectus indicated a 4.5:1 ratio for this reach, so we will revert to that. The
treatments for this reach will include cattle exclusion, invasives removal, and buffer
planting.
b. Based on the current conditions and the level of functional uplift proposed for Fisher
Branch Reach 2, we support a 4:1 enhancement ratio.
The final prospectus indicated a 2.5:1 ratio for this reach. The treatments for this
reach will include bank stabilization, cattle exclusion, invasives removal, and buffer
planting. Wildlands will add a random vegetation plot to monitor the success of
planted trees in the area where privet is removed.
j. Page 27, Section 10, Table 16 – The total annual funding of $967.37 does not match the sum
of the annual monitoring costs listed in the table, please confirm.
This error will be corrected.
k. Figures – Please include a figure showing all mitigation credit types on one map, including all
proposed stream and buffer/nutrient offset assets.
Figure 8b. Concept Design Map with Nutrient and Buffer Mitigation Credits will be added.
l. Figure 12 –
a. Several of the fixed veg plots do not appear to be located within designated planting
areas based on Sheets 4.2 – 4.9 (two on Fisher Branch, one on Shard Branch Reach 2,
and two on Fox Branch Reach 2), please confirm and update as necessary. Please add a
fixed veg plot to Fisher Branch Reach 3.
After revising the planting zones based on the grading plan and GPS tree line, the
number of planted acreage reduced from 26 to 20. The vegetation plots were reduced
from 21 to 16 (10 fixed and 6 random). Vegetation plot numbers and locations will be
updated to reflect the accurate planting zones in the final Mit Plan.
9

b. The Appendix 10 BPDP Plan Figure 9 shows additional veg plots not shown on Figure
12, please include these monitoring stations on Figure 12 and provide associated data
collection in the stream project annual monitoring reports.
After updating the planting zones, there are now 16 vegetation plots (10 fixed and 6
random) for the Great Meadow Mitigation Plan and 12 vegetation plots (10 fixed and
2 random) for the Nutrient Offset and Buffer Mitigation Plan. All 12 vegetation plots
will be shared with the Mitigation Plan.
c. Please add fix photo points at all crossing locations.
We have proposed photo points at each crossing as shown in Table 14. However, they
are not shown on the map.
m. Sheets 1.1.1 & 1.1.2 – Is there any concentrated flow entering the easement through the
two wetland areas that also have top of bank features surveyed? If so, is long-term stability
a concern (head cutting, sediment source)? How will flow be directed into the project
stream (grading, tie-in)? Similar questions for the drainages shown on Sheets 1.1.5 & 1.1.6
on Fisher Branch.
The draw on Sheet 1.1.1 will be regraded. We do not expect any concentrated flow from
these areas. However, if concentrated flow is observed after grading, a floodplain outlet
will be installed to direct the flow into the stream and maintain stability.
n. Sheet 1.2.5 – What is the use/purpose of the concrete pad? Is there any concentrated runoff
from the pad into the project? Is there an adequate setback from the easement for
maintenance or removal of the structure without disturbing the project site?
The concrete pad no longer serves any purpose. If necessary, we will remove the portion
of the concrete pad nearest the easement to ensure the fence can be installed and
maintained.
o. Sheet 4.0 – Is it possible to replace the proposed 10% black willow canopy stems with
another native wetland subcanopy or shrub species?
Black willow is an important early successional species included to assist with wetland
habitat establishment. However, we propose reducing Salix nigra to 5% and replacing the
remaining 5% with Sambucus canadensis.
p. Sheets 5.3, 5.6, 5.11 & 5.12 – In response to the removal of the Boy Scouts property from
the project, the IRT commented that Shard Branch and Fisher Branch should be fenced to
their confluences with Swift Creek to reduce risk of further degradation of stream sections
that would no longer be protected within the project easement. Please show existing fence
lines referred to in the plant callouts to demonstrate that this concern has been addressed.
The existing fence and tie-ins will be shown on the fencing plan.
q. Appendix 7 is missing. Please make sure to use the updated bank instrument template
posted on RIBITS. When you submit the draft Instrument for review, please be sure to send
a pdf copy and a redline version that shows all the changes made to the template.
The site protection instrument will be included with the final mitigation plan.
10

r. While we did not reiterate all concerns noted by the IRT, we support their comments
included above.
Noted, thanks.
Please contact me at 919-302-6919 if you have any questions.

Thank you,

Jeff Keaton, PE
Project Manager
From:Jeff Keaton
To:Haywood, Casey M CIV USARMY CESAW (USA)
Cc:Tugwell, Todd J CIV USARMY CESAW (USA); Polizzi, Maria; Davis, Erin B CIV USARMY CENAE (USA); John
Hutton
Subject:[Non-DoD Source] Re: IRT Review Request of Revised Mitigation Plan / Wildlands Tar-Pamlico 01 UMB- Great
Meadow / SAW-2021-01714/ Nash County
Date:Wednesday, October 9, 2024 3:29:22 PM
Hello - I have uploaded the final version of the Great Meadow mitigation plan to RIBITS and
Laserfiche. I created a new folder in RIBITS called Final Mitigation Plan with the final plan and
the UMBI. I uploaded a version to the Draft Mitigation Plan folder that should be deleted. All
of the comments, including those in the email below have been addressed. The PCN will be
submitted in the next few days. Please let me know if you have any questions. Thanks.
Jeff Keaton, PE | Senior Water Resources Engineer
O: 919.851.9986 x103 M: 919.302.6919

Wildlands Engineering, Inc.
312 West Millbrook Road, Suite 225
Raleigh, NC 27609

From: Haywood, Casey M CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, September 10, 2024 10:08 AM
To: Jeff Keaton <[e-mail]>
Cc: John Hutton <[e-mail]>; Tugwell, Todd J CIV USARMY CESAW (USA)
<[e-mail]>; Davis, Erin B CIV USARMY CENAE (USA)
<[e-mail]>; Dunnigan, Emily E CIV USARMY CESAW (USA)
<[e-mail]>; Kichefski, Steven L CIV USARMY CESAW (USA)
<[e-mail]>; Matthews, Kathryn ([e-mail])
<[e-mail]>; Causey, Caroline F <[e-mail]>;
[e-mail] <[e-mail]>; Polizzi, Maria <[e-mail]>;
Friedman-Herring, Andrew <[e-mail]>; Merritt, Katie
<[e-mail]>; Bowers, Todd <[e-mail]>; Wilson, Travis W.
<[e-mail]>
Subject: IRT Review Request of Revised Mitigation Plan / Wildlands Tar-Pamlico 01 UMB- Great
Meadow / SAW-2021-01714/ Nash County

Good morning, Jeff,
We have completed our review of the revised mitigation plan for the Wildlands Tar-Pamlico
01 UMB- Great Meadow Mitigation Site (SAW-2021-01714) located in Nash County. You
may proceed with developing the final mitigation plan provided you adequately address the
remaining comments/concerns listed below. Please submit one (1) electronic copy of the Final
Mitigation Plan to me via RIBITS and I will distribute to the IRT. Additionally, please upload
the final plan to DWR’s Laserfiche. Please submit your Nationwide Permit 27 application to
me directly for review and approval prior to discharging fill material into waters of the United
States.
Maria Polizzi, NCDWR:
1. I also want to note that if this comment (USACE Comment I.a) had not been made and
WEI had not addressed the decrease in planting area and monitoring plots, this should
be highlighted upon submittal of the final report. The draft review is where DWR is
doing a deep dive and spending a lot of time going through all the details in the report.
If significant changes are made between the draft plan and final plan that are not a result
of IRT comments, it would be helpful to include a cover letter describing these changes.
Typically, the draft report is where credit ratios are being determined, etc. and planting
area is one of the factors that can determine the appropriate ratio. Decreasing the
planting area by 6 acres between draft and final plan stage is a significant change, and
not one that I would necessarily be expecting to occur at this stage without clarification.
Erin Davis & Casey Haywood, USACE:
1. I’m ok with the crossing. During the call we had a long discussion about crossing
impacts, fragmentation and function, justification, and documenting landowner
engagement, etc.
2. I’m ok with the site assessment. The approach appears similar to a previous DMS
project, setting hypothetical dam heights and locations to calculate the flood elevation
risk to surrounding land.
3. I’d recommend a 3:1 ratio for Fisher Branch Reach 2 based on the work/uplift proposed.
4. On Figure 12, I recommend two changes to achieve better coverage and distribution of
veg monitoring stations. Please swap the random plot in the wetland area east of Shard
Branch with the middle fixed plot on the west side of the branch near the reach break,
and swap the random plot on Fox Branch Reach 2 with the upstream fixed plot on
Reach 1.
5. Currently there are three vegetation plots on Gideon Swamp (2 permanent and 1
random). Please be sure to keep the random transect located in the wetland area
throughout monitoring.
6. Please confirm via email that the listed comments will be addressed in the final plan.

Please let me know if you have any questions or if you would like to set up a call to discuss.

Regards,

Casey Haywood
Mitigation Project Manager
US Army Corps of Engineers I Wilmington District I Regulatory Division
3331 Heritage Trade Dr., Suite 105 I Wake Forest, NC 27587
Work Cell: 919-799-0536 I Email: [e-mail]