20140869 Ver 1_USACE Correspondence_20160531

REPLY TO
ATTENTION OF:
Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
May 31, 2016
Re: NCIRT Review and USACE Approval of the Vile Creek Mitigation Plan; SAW -2014-01585;
NCDMS Project # 96582
Mr. Tim Baumgartner
North Carolina Division of Mitigation Services
1652 Mail Service Center
Raleigh, NC 27699-1652
Dear Mr. Baumgartner:
The purpose of this letter is to provide the North Carolina Division of Mitigation Services
(NCDMS) with all comments generated by the North Carolina Interagency Review Team (NCIRT) during
the 30 -day comment period for the Vile Creek Mitigation Plan, which closed on April 6, 2016. Several
concerns were noted during the review that required additional coordination and revisions to the mitigation
plan. All comments received in response to the revised mitigation plan are attached for your review.
Based on our review of these comments, we have determined that no major concerns have been
identified with the revised Mitigation Plan, which is considered approved with this correspondence.
However, one minor issue was identified, as described in the attached comment memo, which must be
addressed in the Final Mitigation Plan.
The Final Mitigation Plan is to be submitted with the Preconstruction Notification (PCN)
Application for Nationwide permit approval of the project along with a copy of this letter. Issues identified
above must be addressed in the Final Mitigation Plan. All changes made to the Final Mitigation Plan
should be summarized in an errata sheet included at the beginning of the document. If it is determined
that the project does not require a Department of the Army permit, you must still provide a copy of the
Final Mitigation Plan, along with a copy of this letter, to the appropriate USACE field office at least 30
days in advance of beginning construction of the project. Please note that this approval does not preclude
the inclusion of permit conditions in the permit authorization for the project, particularly if issues
mentioned above are not satisfactorily addressed. Additionally, this letter provides initial approval for the
Mitigation Plan, but this does not guarantee that the project will generate the requested amount of
mitigation credit. As you are aware, unforeseen issues may arise during construction or monitoring of the
project that may require maintenance or reconstruction that may lead to reduced credit.

Thank you for your prompt attention to this matter, and if you have any questions regarding this
letter, the mitigation plan review process, or the requirements of the Mitigation Rule, please call me at
919-846-2564.
Sincerely,
HUGH ES.ANDREA.WADE.125833 DDNi-US!o=U.S.Go ernment,ou-0oDAou=11PKI,ou9U5A,
9165 cn=HUGHES
.ANDREA.WADE.1258339165
Date: 2016.05.31 08:53:58 -04'00'
Andrea Hughes
Mitigation Project Manager
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List

REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 2 8403-1 34 3
CESAW-RG/Hughes May 13, 2016
MEMORANDUM FOR RECORD
SUBJECT: Vile Creek Mitigation Site - NCIRT Comments/Revised Mitigation Plan
PURPOSE: The comments listed below were provided in response to proposed mitigation plan changes
dated May 2, 2016.
NCDMS Project Name: Vile Creek Mitigation Site, Alleghany County, NC
USACE AID#: SAW -2014-01585
I0[�f-T.IM61STM
30 -Day Comment Deadline: April 6, 2016
Travis Wilson, NCWRC, March 24,2016.-
No
4,2016:No additional comments received.
Mac Haupt, NCD WR, March 29, 2016:
No additional concerns.
Todd Bowers, USEPA, April 1, 2016:
No additional comments received.
Marella Buncick, USFWS, April 1, 2016.-
We
016:We are satisfied with the responses to comments. The only additional comment is in regard
to an area on Vile Creek R1 that we feel is already bog habitat (see attached). We prefer to see
this area planted in herbaceous rather than shrub plants.
Andrea Hughes, USACE, April 13, 2016:
No additional concerns.
Andrea Hughes
Mitigation Project Manager
Regulatory Division

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REPLY TO
ATTENTION OF:
CESAW-RG/Hughes
104191051"1" %Z"p
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 2 8403-1 34 3
April 14, 2016
SUBJECT: Vile Creek Mitigation Site - NCIRT Comments During 30 -day Mitigation Plan Review
PURPOSE: The comments listed below were posted to the NCDMS Mitigation Plan Review Portal during
the 30 -day comment period in accordance with Section 332.8(g) of the 2008 Mitigation Rule.
NCDMS Project Name: Vile Creek Mitigation Site, Alleghany County, NC
USACE AID#: SAW -2014-01585
NCDMS #: 96582
30 -Day Comment Deadline: April 6, 2016
Travis Wilson, NCWRC, March 24,2016:
Overall the Vile Creek project looks like a good project. The draft mitigation plan is for the
most part adequate, however WRC does have the following comments.
One of the primary goals of the mitigation plan is to expand Southern Appalachian Bog
Habitat, and WRC supports this goal. The wetland bog habitat is included within an area of
wetland reestablishment, however the actions described in the mitigation plan appear to be
more aligned with creation. WRC understands it is not feasible to determine the historic
presence of a bog at this location, and we support the incorporation of habitat diversity
specifically micro habitats beneficial to sensitive species. WRC is not requesting to adjust the
proposed credits to be more in line with creation however it is important to set a monitoring
approach and target performance standards for these areas aside from those used for the
adjacent wetlands. The adaptive management plan can address the circumstance of not
meeting the bog performance standards but meeting those of the restored wetlands.
Mac Haupt, NCD WR, March 29, 2016:
1. DWR believes this project has excellent potential to restore both stream and wetland
functions.
2. DWR supports the effort to restore bog habitat for the bog turtle (Glyptemys mulenbergii),
however, DWR does not believe the design of the bog cells for all the wetland areas will be
beneficial for the bog turtle or the wetland restoration acreage.
3. DWR has the following concerns and recommendations regarding the design of the bog cells;
a. Extensive construction and manipulation of the floodplain with significant berms that
would likely remove portions of the floodplain from wetland restoration status,
b. The berms would likely result in mostly ponded water, resulting in more standing water
than saturated soil needed to promote and develop the bog habitat. While some open water
may be preferable for bog turtle habitat, DWR believes the current design would yield more
open water and less of a wetland mosaic (saturated areas in addition to some drier areas).

c. DWR would support the design and construction of several bog cells rather than all the
wetland area be dedicated to bog cells.
d. DWR would also recommend lowering the berm height on the design, which may allow
the berms to be included in the wetland restoration (development of hydric soil indicators)
acreage and result in less open water and more saturated soil for the respective bog cell.
4. DWR supports the planting of herbaceous plants and shrubs for the bog cells (if the design is
utilized) or bog habitat areas. DWR recommends a vegetative percent cover performance
criteria for these areas of 80%.
5. Section 11.3 recommends a wetland performance standard of 7.1 % saturation during the
growing season. DWR does not agree with a wetland hydrologic performance standard of
7.1% for a target bog community. DWR will require a wetland performance standard of at
least 12% saturation during the growing season.
6. Section 6.2 discusses the reference wetlands and DWR recommends that a reference gauge be
installed in the reference bog (the verbiage in the mitigation plan stated they may install a
gauge in the bog).
7. DWR recommends the designer be wary of lateral hydrologic "pop -out" on the streambank
where the wetland areas drain into the stream, especially if these areas drain into a meander
bend as shown on design sheet 3.8. DWR recommends supplemental stabilization measures
be considered for these areas.
Todd Bowers, USEPA, April], 2016:
1. General comment: Well-documented goals, objectives, past site activity, site information,
letters and recent progress towards establishing a viable stream and wetland restoration site.
Disclaimer: I have not been on-site or in any discussions with the IRT concerning this
project.
2. P. 7: The goal of restoring habitat that may support bog species should clarify if flora, fauna
or both. If the goal is habitat for bog turtles only then the document should specify this.
Habitat includes vegetation so planting of bog vegetation should be included in the
objectives.
3. P. 8: Add a programmatic goal of providing 5,139 SMUs and 5.82 WMUs for DMS In -Lieu
Fee Program. Associated objective may be as simple as "Restore, enhance and reestablish
streams and wetlands on-site.
4. P. 10: Include valley type (A, B) in description of streams and their alluvial valleys.
5. P. 11: Include estimated bankfull velocities for each reach in Tables 3a and 3b.
6. P. 18: Vile Creek Reach 2 has a moderate sinuosity (>1.25) rather than low.
7. P. 19: UT2 has steep slope (as stated) of greater than 0.04. This would classify UT2 as a 134a
type rather than B4.
8. P. 23: Recommend the use and credit for 50 -foot buffers wherever possible especially with
the type of adjacent land use and the expected nutrient rich and sediment laden runoff
expected with continued use by cattle. I understand that there is an arbitrary change in buffer
width requirements from piedmont to mountain streams but the science behind buffer
effectiveness recommends a minimum of 50 feet for riparian vegetation to be minimally
useful for controlling runoff and pollutant absorption before entering the stream. I applaud
Wildlands for considering and proposing those areas with buffers much greater than the
minimum.
9. P. 23: 1 am troubled by credit being proposed for areas where the minimum riparian buffer
(30') overlaps with wetland area proposed for credit. Perhaps this is negated somewhat by
areas where the riparian buffer proposed is much greater than the minimum?
10. P. 24: Include loss of intermittent stream at head of UT2 for the placement of the BMP in the
impacts listed in the Pre -Construction Notice.

11. P. 25: Bog Turtles "inhabits" wetland areas rather than "inhibits".
12. P. 25: Recommend changing "no effect" to "no negative effect" or "positive effect" since one
of the project goals is to have a net positive effect on habitat.
13. P. 33: Table 8 Component Summation for the streams should read "3014, 1134 and 3807 for
restoration, enhancement I and enhancement II respectively.
14. P. 35: Table 9b should have a footnote relating to the 10% of the site stream credits held in
reserve for two bankfull events. Text was noted in paragraph 8.2.
15. P. 44: Reach 1 of UTI has a small ephemeral channel near the head of the project (Fig. 2.2.1).
Is there a need for a small headwater water quality treatment BMP constructed at this location
similar to that on UT2?
16. P. 45:1 recommend that the sponsor include some sort of vegetation survey for the
constructed bog cells. These cells constitute a significant amount of the restored/enhanced
wetlands on site and other than reference site comparison for hydrology, have no
performance standard to ensure the cells are functioning as intended. I recommend a least one
vegetation monitoring plot per series to ensure that plant survival is quantified and that
performance standards are considered separately from the riparian wetlands (example: > 80
percent survival, > 80 percent FACW, no invasive species). Otherwise these bog cells could
wind up as pools of water with no suitable habitat or plant survival and still get full credit.
17. P. 48: Table 15 See comment on project goals and objectives noted above.
18. P. 48: Table 15 Recommend adding performance standard or contingency for goal of creating
bog habitat. Add "planting bog species" as part of objectives for this goal.
19. Sheet 4.0: The inclusion of Acer saccharinium (silver maple) is notable as it does not appear
in Schafale and Weakley (1990) for Montane Alluvial Forest. Why was this species selected?
Recommend Betula nigra (river birch) to replace.
20. Sheet 4.0: Recommend adding some understory species for consideration such as Carpinus
carolinana (ironwood) or Lindera benzoin (spicebush) in the planting for riparian buffers.
21. Sheet 4.0: Recommend adding Alnus serrulata (tag alder) live stakes in the streamside
planting zone.
22. Sheet 4.0: Recommend adding Cephalanthus occidentalis (buttonbush) in wetland planting.
23. We request that the sponsor provide the IRT with a GIS shapefile polygon for this project.
24. Recommend that the sponsor explore the possibility to have the access road adjacent to UT3
moved to provide a wider riparian buffer.
Marella Buncick, USFn April 1, 2016:
Mountain bogs including Southern Appalachian bogs are a high priority for the USFWS
Asheville Field Office given the rare and endangered species they support and the extensive
loss of this habitat type (>90%) in the Southern Appalachians. We greatly appreciate the
willingness of those involved to try to restore the site to Southern Appalachian bog habitat
and are supportive of the project. With a few adjustments, we believe the project will benefit
bog turtle, which is a high priority species for our office, and help increase mountain bog
habitat.
General
There appears to be a typo in the sections about northern long-eared bats. The document
incorrectly states that northern long-eared bats prefer trees that are 3 inches dbh. Northern
long-eared bats use live trees and/or snags >3 inches dbh that have exfoliating bark, cracks,
crevices, and/or cavities.
Bog Turtles
• The draft plan notes that a pedestrian survey for turtles on 12/02/2013 did not detect any

turtles (p. 25). It should be noted that bog turtles are hibernating in the mud this time of year,
and would be impossible to detect. Bog turtle biologists with Project Bog Turtle and the NC
Wildlife Resources Commission (NCWRC) did conduct a survey for about 3 hours on June 3,
2015. No turtles were found, but bog turtle experts did think it was highly likely turtles are
present based on the existing habitat and proximity to known sites. Bog turtles spend most of
their lives buried in muck and are very difficult to find. Much more survey work would be
needed before we could say bog turtles are currently absent from the site. The wetland
patches that look suitable for bog turtles are labeled B, C, F, N, and O on Figure 3. Gray's
lily and skunk cabbage (both bog associated species) were found on the site. We recommend
that the document be changed to reflect the possibility that bog turtles are already on the site.
As part of this, the current goal related to bog turtles could be changed to "improve and
expand Southern Appalachian Bog wetland habitat for bog turtle."
• Restoration work has the potential to injure or kill turtles and we recommend working with
NCWRC and USFWS to develop a plan to minimize potential impacts to turtles that may
already be on site. We are primarily concerned about the placement of plugs and the use of
heavy equipment near remnant bog patches when turtles are active.
• Please ensure that the matting used along the creek is biodegradable (e.g., coconut fiber, jute
mat).
Hydrology
If the IRT/Wildlands would benefit from Mountain bog hydrologic data to help calibrate
design/success criteria Jeff Wilcox with UNCA currently is collecting data from various
mountain bog sites as part of a characterization project for the USFWS. We can make his
contact info available to whomever if this would be beneficial.
• We have concerns about the current design of the bog cells and the plugs in the ditches to
result in suitable habitat for bog turtles. The remnant wetland habitat that is in the ditches
along Vile Creek RI and Vile Creek R2 currently looks good for bog turtles with appropriate
hydrology and deep, mucky soils. The goal should be to expand this habitat with similar
conditions in these expanded areas. Wetlands preferred by bog turtles are spring -fed with
saturated soils and slow flowing water and are sedge dominated, wet meadows, with little or
no canopy. Bog turtle sites do not have standing water of significant depth. The goal should
be to saturate the ground without producing deep -standing water.
• Please ensure that all springs are depicted on the plan and considered as part of the overall
site hydrology. We have seen a hill side seep/ spring at the base of the hill near areas N and O
and we believe there may also be one at the top of area C.
Vegetation
• Staff with USFWS, NCWRC, and Wildlands Engineering met on site on 10/20/14 to discuss
the bog habitat and bog turtles. As part of the restoration plan for Southern Appalachian bog,
we suggested that the banks of Vile Creek be planted with shrubs and small tree species rather
than large tree species. We have concerns that the dense planting of large trees will
eventually shade out the bog and will also lead to more rapid succession of the bog, making
the habitat unsuitable for bog turtles and eliminating many of the herbaceous species.
Additionally, the area with gray's lily is close to the creek on the north side of Vile Creek R2
and may actually be in the planting area. Planting shrubs/small trees along restored streams
has been successfully done at other bog turtle sites (e.g., UT -Crab Creek in Alleghany Co
NC., Shady Valley in TN, and Sparta Bog in Alleghany Co. NC). We recommend planting
shrubs only in VC Rl and on the north side of VC R2.The south side (with the exception of

area F — see below) could be planted in trees.
• The remnant patch of bog on the south side of Vile Creek R2 (labeled area F on Figure 3) is
not categorized as a "bog cell" and is currently in the zone to be planted as trees. This is one
of the best looking remnant patches of Southern Appalachian bog on the site and we
recommend treating this area accordingly with any disturbed land in the vicinity planted with
herbaceous plants rather than trees.
• We have concerns about the planting stem densities for trees/shrubs and think they should
be lower than other typical mitigation community types since part of what is being restored is
Southern Appalachian bog, which is characterized by a mosaic of shrub thickets and herb
dominated areas. UT to Crab Creek mitigation site used woody shrub densities of <50
stems/acre, Shady Valley (TN) used 320 stems/ac and Sparta Bog also used 320-260
stems/acre.
• In VC R1-2 we recommend creating a mosaic of shrub/herbaceous plants by including some
herbaceous plantings and/or relying on colonization from the seed bed in the areas between
Vile Creek and the bog cells rather than using just densely planted wetland shrubs. We
recommend including native pollinator seed mixes that include milkweeds in the herbaceous
planting areas to gain the added wildlife benefit of helping pollinators including Monarch
butterflies and early succession bird species of concern.
• We think that stockpiling the existing topsoil is an excellent idea. Exotics should be
eliminated before topsoil is removed if it is to be reapplied to the site. In addition,
construction equipment should be decontaminated prior to arriving onsite to eliminate
transferring exotic species from other sites to the Vile Creek site.
• We could not find a species list other than the insets on plan sheets. The tree list is of
concern because there are several species listed that are not native to the mountains of NC or
appropriate for Appalachian bog communities. Specifically, eastern cottonwood, swamp
chestnut oak and silver maple should not be used. Appropriate tree substitutes could be box
elder or black gum. Shrubs also could be substituted including black willow (already found
onsite), silky willow and silky dogwood. We also question the use of green ash given threats
from emerald ash borer.
Long-term Management
• The document indicates that no long term management will be needed for this site.
However, the site may require management if it is to remain suitable for bog turtles.
Accelerated succession as a result of human impacts (e.g., changes in hydrology, increased
nutrients, changes in natural disturbance regimes) is a threat to bog turtles and most bog turtle
sites now require management to keep some areas open. Bog turtles need open areas for
basking and nesting and one of the bog turtle's ultimate limitations is a closed canopy, which
cuts off surface light and warmth.
• We recommend including language in the plan that allows for some management (e.g.,
cutting woody vegetation out of the bog to open areas for bog turtles) by partner
agencies/groups involved in bog turtle conservation (e.g., NCWRC, USFWS, Project Bog
Turtle) if it is needed.
• Bog turtle sites can greatly benefit from occasional grazing by cows. If possible, we
recommend allowing the flexibility to include occasional, low density grazing in the bog cells
to maintain the habitat and eliminate the need for more labor intensive management.
Andrea Hughes, USACE, April 13, 2016:
1. Page 20, Section 4.5: Please provide a copy of the Corps JD approval letter and associated
map of existing resources.

2. Page 22, Section 4.7: Please be aware that credits will be reduced for those areas with stream
buffers of less than 30 feet in width using the most current buffer guidance. For areas with a
buffer of less than 15 feet in width, no credit may be generated. Areas with buffers greater
than 30 feet wide may receive additional credit provided these areas do not overlap wetland
mitigation areas.
3. Page 22, Section 4.7: The plan indicates that a CE cannot be obtained at this time for
approximately 166 linear feet of stream channel located on the Perry property and the
provider intends to relocate the stream channel onto the Crouse property. Please provide
additional information related to permissions/agreements with the current landowner for the
Perry property regarding relocation of this section of Vile Creek.
4. Page 26, Section 5.2.3: Regarding the conclusion that the project would have "no effect" on
the bog turtle, according to the USFWS letter dated August 14, 2016, the project is not likely
to adversely affect the species. Please revise the "no effect" statement.
5. The mitigation plan proposes to modify the wetland rehabilitation/re-establishment activities
to facilitate development of bog turtle habitat. Therefore, the Corps recommends that the
provider coordinate design and construction plans with USFWS and NCWRC to ensure
appropriate habitat for the species. The Corps supports USFWS and NCWRC
comments/suggestions regarding the bog habitat provided above with the exception of cattle
grazing. Also, the provider should propose appropriate vegetation and hydrology monitoring
and performance standards for these areas.
6. Page 53, Section 13.0: Please provide a long-term management strategy/plan for the 6.5
acres of bog turtle habitat.
7. Appendix 1, Site Protection: The site protection instruments for the Edwards and Mason
properties includes a provision under Section III advising the landowners that if they have
livestock, they must restrict livestock access to the easement areas and failure to do so may
result in the state repairing fencing or installing cattle exclusion devices at the landowners
expense. The site protection instrument for the Crouse properties (Areas A and B -
restoration and EII areas) does not include this provision. The Corps believes this provision
should be included in all site protection instruments to ensure that future land use activities on
the property will not result in adverse impacts to the resources. Also, the provision should be
modified to include tenants that may lease the land for agricultural use.
HUGHES.ANDREANA D:
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signed
ND ED DADS=1258339165
DE258339165 Date 2016.04.1412E 07 39 D0400'ADE.1258339165
.1
Andrea Hughes
Mitigation Project Manager
Regulatory Division

W0.*
WILDLANDS
E N G I N E E R I N G
May 2, 2016
Ms. Andrea W. Hughes
Special Projects Manager
Wilmington District, Regulatory Division
U.S. Army Corps of Engineers
11405 Falls of Neuse Road
Wake Forest, NC 27587
RE: Vile Creek Mitigation Project — IRT Comments
Vile Creek Mitigation Site (DMS #96582)
New River HUC 0505001, Alleghany County, NC
Dear Ms. Hughes,
Thank you for compiling and providing comments on the Vile Creek Draft Mitigation Plan dated April 14,
2016. Wildlands has reviewed the comments and developed a response to each, which are outlined
below. We understand that you wish to review the responses before we submit the final mitigation plan.
Please inform us if these responses are acceptable and we will submit the revised mitigation plan. If
there are any additional comments, feel free to contact me to discuss. For your convenience, the
original comments are reprinted below followed by our responses in italics.
Travis Wilson, NCWRC, March 24, 2016:
Overall the Vile Creek project looks like a good project. The draft mitigation plan is for the most part
adequate, however WRC does have the following comments. One of the primary goals of the mitigation
plan is to expand Southern Appalachian Bog Habitat, and WRC supports this goal. The wetland bog
habitat is included within an area of wetland reestablishment, however the actions described in the
mitigation plan appear to be more aligned with creation. WRC understands it is not feasible to
determine the historic presence of a bog at this location, and we support the incorporation of habitat
diversity specifically micro habitats beneficial to sensitive species. WRC is not requesting to adjust the
proposed credits to be more in line with creation however it is important to set a monitoring approach
and target performance standards for these areas aside from those used for the adjacent wetlands. The
adaptive management plan can address the circumstance of not meeting the bog performance
standards but meeting those of the restored wetlands.
Based on the comments of the IRT, we have revised the bog hydrologic success criteria to be free
groundwater surface within 12 inches of the ground surface for 12% of the growing season. The bog
vegetation will be herbaceous and will be based on bog natural community descriptions and
recommendations from agencies (please see the revised planting plan attached). Therefore, we believe it
appropriate to propose vegetation plots within bog areas that are monitored for coverage based on a
percentage of the plot rather than a number of surviving plants. We have added text describing a visual
assessment of the bog vegetation and related success criteria of 80% coverage to the mitigation plan.
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609

Mac Haupt, NCDWR, March 29, 2016:
1. DWR believes this project has excellent potential to restore both stream and wetland functions.
Thank you for the comment. We agree.
2. DWR supports the effort to restore bog habitat for the bog turtle (Glyptemys mulenbergii), however,
DWR does not believe the design of the bog cells for all the wetland areas will be beneficial for the bog
turtle or the wetland restoration acreage.
There was a mistake on the GIS figure showing the proposed conditions submitted with the original
mitigation plan. On that figure, the extent of the wetland reestablishment area was shown to be smaller
than it actually is proposed to be. This figure made it appear that the bog areas took up more of the
wetland area than they actually do. In fact, the bogs are only 30% of the total wetland mitigation area.
The figure has been revised for the final mitigation plan.
3. DWR has the following concerns and recommendations regarding the design of the bog cells;
a. Extensive construction and manipulation of the floodplain with significant berms that would likely
remove portions of the floodplain from wetland restoration status,
We have reduced the number of berms from 14 down to 10. We have also redesigned the berms to be
lower than they originally were — approximately half of the original height. We do think the berms will be
wet and, if successful, will be counted in the acreage of wetland rehabilitation. Please refer to new plan
sheets and revised Figure 10.
b. The berms would likely result in mostly ponded water, resulting in more standing water than
saturated soil needed to promote and develop the bog habitat. While some open water may be
preferable for bog turtle habitat, DWR believes the current design would yield more open water and less
of a wetland mosaic (saturated areas in addition to some drier areas).
With the changes to the design of the berms described above there will be significantly less standing
water on the site.
c. DWR would support the design and construction of several bog cells rather than all the wetland area
be dedicated to bog cells.
Please refer to the response to comment #2 above. While we have not reduced the area of the bogs, they
are only 30% of the total wetland mitigation area.
d. DWR would also recommend lowering the berm height on the design, which may allow the berms to
be included in the wetland restoration (development of hydric soil indicators) acreage and result in less
open water and more saturated soil for the respective bog cell.
Please refer to the response to comment #3a above. The berms have been redesigned to be lower.
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609

4. DWR supports the planting of herbaceous plants and shrubs for the bog cells (if the design is utilized)
or bog habitat areas. DWR recommends a vegetative percent cover performance criteria for these areas
of 80%.
We have added text to the mitigation plan that the success criteria for the bogs will be 80% coverage of
the vegetation plots with planted or volunteer vegetation. For information on the species that will be
planted, please refer to the revised planting plan attached.
5. Section 11.3 recommends a wetland performance standard of 7.1% saturation during the growing
season. DWR does not agree with a wetland hydrologic performance standard of 7.1% for a target bog
community. DWR will require a wetland performance standard of at least 12% saturation during the
growing season.
We agree to the performance standard of 12% for the bog areas. However, we have concerns about a
performance standard that high for the surrounding wetland areas which make up 70% of the site. One
concern is that the bogs will intercept runoff from the surrounding hillslopes. Another issue is that we
have agreed to lower the height of the berms to reduce standing water in the bogs which will also lower
the surrounding water table elevation. Given that the bog areas actually comprise much less of the
wetland area than it appeared on the original Figure 10 (i.e. most of the wetlands are not bog), we are
hoping that the bog performance standard of 12% does not need to apply to all of the wetlands. We
propose 8.5% for the non -bog areas.
6. Section 6.2 discusses the reference wetlands and DWR recommends that a reference gauge be
installed in the reference bog (the verbiage in the mitigation plan stated they may install a gauge in the
bog).
We will install a groundwater gauge in a reference bog near the site. We have discussed using the
Sparta Bog site with USFWS and they have provided contact information for NCDOT. We are in the
process of obtaining permission to install a well at this location.
7. DWR recommends the designer be wary of lateral hydrologic "pop -out" on the streambank where the
wetland areas drain into the stream, especially if these areas drain into a meander bend as shown on
design sheet 3.8. DWR recommends supplemental stabilization measures be considered for these areas.
We have redesigned the Swale to carry overflow into the adjacent channel so that it enters the channel
at the riffle upstream of the meander bend mentioned. The swales will be armored with native rock for
stability. The streambanks where the swales discharge will also be protected from erosion.
Todd Bowers, USEPA, April 1, 2016:
1. General comment: Well-documented goals, objectives, past site activity, site information, letters and
recent progress towards establishing a viable stream and wetland restoration site. Disclaimer: I have not
been on-site or in any discussions with the IRT concerning this project.
We appreciate the comment.
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609

2. P. 7: The goal of restoring habitat that may support bog species should clarify if flora, fauna or both. If
the goal is habitat for bog turtles only, then the document should specify this. Habitat includes
vegetation so planting of bog vegetation should be included in the objectives.
The goal is to restore bog habitat and therefore we propose to plant native bog plant species. We have
revised the planting plan based (attached) on information provided by IRT members. Therefore, we have
changed the goal to include restoring vegetation.
3. P. 8: Add a programmatic goal of providing 5,139 SMUs and 5.82 WMUs for DMS In -Lieu Fee Program.
Associated objective may be as simple as "Restore, enhance and reestablish streams and wetlands on-
site.
DMS prefers not to include providing credits as a project goal and would like to keep the focus of the
goals discussion on project benefits. The credit summations are described in other parts of the mitigation
plan.
4. P. 10: Include valley type (A, B) in description of streams and their alluvial valleys.
While DMS does not generally believe that Rosgen valley type assignments are valid in the Southeastern
US, at your request we have added the Rosgen valley types in addition to the verbal descriptions of the
valleys provided in Section 4.2.
5. P. 11: Include estimated bankfull velocities for each reach in Tables 3a and 3b.
We have added estimated bankfull velocities to Tables 4a — 4c.
6. P. 18: Vile Creek Reach 2 has a moderate sinuosity (>1.25) rather than low.
We have changed the description to "moderate sinuosity."
7. P. 19: UT2 has steep slope (as stated) of greater than 0.04. This would classify UT2 as a 134a type
rather than B4.
The stream type for UT2 has been changed to 84a.
8. P. 23: Recommend the use and credit for 50 -foot buffers wherever possible especially with the type of
adjacent land use and the expected nutrient rich and sediment laden runoff expected with continued
use by cattle. I understand that there is an arbitrary change in buffer width requirements from piedmont
to mountain streams but the science behind buffer effectiveness recommends a minimum of 50 feet for
riparian vegetation to be minimally useful for controlling runoff and pollutant absorption before
entering the stream. I applaud Wildlands for considering and proposing those areas with buffers much
greater than the minimum.
We have planned for wider than 30 foot buffers wherever possible on this site and a large portion of the
site will have buffers of much greater than 30 feet due to extra area included in the easement or
adjacent wetlands. In light of this and the fact that the land acquisition is completed and easement
agreements closed, no changes have been made to buffer widths in the plan.
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609

9. P. 23: 1 am troubled by credit being proposed for areas where the minimum riparian buffer (30')
overlaps with wetland area proposed for credit. Perhaps this is negated somewhat by areas where the
riparian buffer proposed is much greater than the minimum?
According to the IRT, it is acceptable to claim wetland credit within the planted buffer zone of adjacent
stream mitigation. No change has been made to proposed wetland credits.
10. P. 24: Include loss of intermittent stream at head of UT2 for the placement of the BMP in the
impacts listed in the Pre -Construction Notice.
We have included the impacts from the BMP in the PCN.
11. P. 25: Bog Turtles "inhabits" wetland areas rather than "inhibits".
This correction has been made.
12. P. 25: Recommend changing "no effect" to "no negative effect" or "positive effect" since one of the
project goals is to have a net positive effect on habitat.
Biological conclusions for mitigation projects must follow the FHWA-mandated environmental screening
guidance and fall into one of the following categories: a) No Effect, b) Not likely to adversely affect, c)
Likely to adversely affect. Written concurrence from USFWS is required for outcomes (b) and (c). USFWS
has concurred with outcome (b) and we have updated the text to "Not likely to adversely affect".
13. P. 33: Table 8 Component Summation for the streams should read "3014, 1134 and 3807 for
restoration, enhancement I and enhancement 11 respectively.
These corrections have been made.
14. P. 35: Table 9b should have a footnote relating to the 10% of the site stream credits held in reserve
for two bankfull events. Text was noted in paragraph 8.2.
This footnote has been added.
15. P. 44: Reach 1 of UT1 has a small ephemeral channel near the head of the project (Fig. 2.2.1). Is
there a need for a small headwater water quality treatment BMP constructed at this location similar to
that on UT2?
There is a channel that discharges to UT1 at the upstream end of the project. This stream is jurisdictional
and is partially on another landowner's property. The landowner was contacted but declined to
participate. We cannot put a BMP in this location.
16. P. 45: 1 recommend that the sponsor include some sort of vegetation survey for the constructed bog
cells. These cells constitute a significant amount of the restored/enhanced wetlands on site and other
than reference site comparison for hydrology, have no performance standard to ensure the cells are
functioning as intended. I recommend a least one vegetation monitoring plot per series to ensure that
plant survival is quantified and that performance standards are considered separately from the riparian
wetlands (example: > 80 percent survival, > 80 percent FACW, no invasive species). Otherwise these bog
cells could wind up as pools of water with no suitable habitat or plant survival and still get full credit.
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609 5

We have added text to the mitigation plan that the success criteria for the bog areas will be 80%
coverage of the vegetation plots with planted or volunteer vegetation. Please review the revised planting
plan attached for more detailed information on species. We propose that two percent of the bog
acreage be monitored following the standard for planted area. Invasives will be managed on the site.
Text describing these issues has been added to the mitigation plan.
17. P. 48: Table 15 See comment on project goals and objectives noted above.
The same addition will be made to Table 15 as Table 2.
18. P. 48: Table 15 Recommend adding performance standard or contingency for goal of creating bog
habitat. Add "planting bog species" as part of objectives for this goal.
We have added bog performance standards to Table 15.
19. Sheet 4.0: The inclusion of Acer saccharinium (silver maple) is notable as it does not appear in
Schafale and Weakley (1990) for Montane Alluvial Forest. Why was this species selected? Recommend
Betula nigra (river birch) to replace.
We have revised the planting plan including the removal of silver maple.
20. Sheet 4.0: Recommend adding some understory species for consideration such as Carpinus
carolinana (ironwood) or Lindera benzoin (spicebush) in the planting for riparian buffers.
There is existing canopy along portions of UT3 and Vile Creek Reach 3. We have added some understory
species to these areas.
21. Sheet 4.0: Recommend adding Alnus serrulata (tag alder) live stakes in the streamside planting zone.
We prefer not to add tag alder to the streambank planting for the following reasons: 1) We have not
had good success using tag alder as live stakes. 2) Tag alder can take over a streambank planting zone
and create a dense thicket, which can affect bankfull cross sectional area. We try to avoid creating this
situation on small streams. As with other recently constructed DMS projects in Alleghany County, there
may be advantageous tag alder transplant opportunities identified and strategically implemented during
construction.
22. Sheet 4.0: Recommend adding Cephalanthus occidentalis (buttonbush) in wetland planting.
We have added buttonbush to the wetland shrub zone.
23. We request that the sponsor provide the IRT with a GIS shapefile polygon for this project.
We will provide the GIS shapefile(s).
24. Recommend that the sponsor explore the possibility to have the access road adjacent to UT3
moved to provide a wider riparian buffer.
Moving the road would require a significant cut into the adjacent hillslope and removal of trees. Because
of these issues, the landowner requested that the road not be moved. We discussed this with the IRT
chair prior to submitting the mitigation plan and understood that this existing road location would be
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609

acceptable. Due to the location of the road and the related issue of a narrow buffer in this location, there
is a credit reduction included in the credit summation.
Marella Buncick, USFWS, April 1, 2016:
Mountain bogs including Southern Appalachian bogs are a high priority for the USFWS Asheville Field
Office given the rare and endangered species they support and the extensive loss of this habitat type
(>90%) in the Southern Appalachians. We greatly appreciate the willingness of those involved to try to
restore the site to Southern Appalachian bog habitat and are supportive of the project. With a few
adjustments, we believe the project will benefit bog turtle, which is a high priority species for our office,
and help increase mountain bog habitat.
Thanks for the acknowledgement of our efforts.
General
There appears to be a typo in the sections about northern long-eared bats. The document incorrectly
states that northern long-eared bats prefer trees that are 3 inches dbh. Northern long-eared bats use
live trees and/or snags >/= 3 inches dbh that have exfoliating bark, cracks, crevices, and/or cavities.
This correction has been made.
Bog Turtles
• The draft plan notes that a pedestrian survey for turtles on 12/02/2013 did not detect any turtles (p.
25). It should be noted that bog turtles are hibernating in the mud this time of year, and would be
impossible to detect. Bog turtle biologists with Project Bog Turtle and the NC Wildlife Resources
Commission (NCWRC) did conduct a survey for about 3 hours on June 3, 2015. No turtles were found,
but bog turtle experts did think it was highly likely turtles are present based on the existing habitat and
proximity to known sites. Bog turtles spend most of their lives buried in muck and are very difficult to
find. Much more survey work would be needed before we could say bog turtles are currently absent
from the site. The wetland patches that look suitable for bog turtles are labeled B, C, F, N, and O on
Figure 3. Gray's lily and skunk cabbage (both bog associated species) were found on the site. We
recommend that the document be changed to reflect the possibility that bog turtles are already on the
site. As part of this, the current goal related to bog turtles could be changed to "improve and expand
Southern Appalachian Bog wetland habitat for bog turtle."
These revisions have been made. We have amended the text to state that it is possible that bog turtles
exist on the site. We have changed the goal to improve and expand Southern Appalachian Bog habitat.
• Restoration work has the potential to injure or kill turtles and we recommend working with NCWRC
and USFWS to develop a plan to minimize potential impacts to turtles that may already be on site. We
are primarily concerned about the placement of plugs and the use of heavy equipment near remnant
bog patches when turtles are active.
We recognize this concern and will take precautions to protect existing bog turtle habitat. We are open
to recommendations on how to avoid harming bog turtles that may be present. As we discussed by
phone on April 28, we agree that avoidance and minimization measures such as specific locations for
crossing existing bog habitat can be discussed and agreed upon without documentation in the mitigation
plan. No additional text has been added to the plan.
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609 7

• Please ensure that the matting used along the creek is biodegradable (e.g., coconut fiber, jute
mat).
We plan to use coconut fiber matting for the project.
Hydrology
If the IRT/Wildlands would benefit from Mountain bog hydrologic data to help calibrate design/success
criteria Jeff Wilcox with UNCA currently is collecting data from various mountain bog sites as part of a
characterization project for the USFWS. We can make his contact info available to whomever if this
would be beneficial.
This information may be helpful at some point. Please provide the contact information to Wildlands.
• We have concerns about the current design of the bog cells and the plugs in the ditches to result in
suitable habitat for bog turtles. The remnant wetland habitat that is in the ditches along Vile Creek R1
and Vile Creek R2 currently looks good for bog turtles with appropriate hydrology and deep, mucky soils.
The goal should be to expand this habitat with similar conditions in these expanded areas. Wetlands
preferred by bog turtles are spring -fed with saturated soils and slow flowing water and are sedge
dominated, wet meadows, with little or no canopy. Bog turtle sites do not have standing water of
significant depth. The goal should be to saturate the ground without producing deep -standing water.
We have altered the design to reduce the amount and height of berms. This will reduce the amount of
standing water significantly. We do want to keep some berms within the existing ditches to slow the
movement of water through the ditches and promote a higher groundwater table for surrounding
wetlands. The area of the bogs will be significantly expanded. Please refer to new plan sheets and revised
Figure 10.
• Please ensure that all springs are depicted on the plan and considered as part of the overall site
hydrology. We have seen a hill side seep/ spring at the base of the hill near areas N and O and we
believe there may also be one at the top of area C.
We have depicted all of the springs that we are aware of on Figure 3.
Vegetation
• Staff with USFWS, NCWRC, and Wildlands Engineering met on site on 10/20/14 to discuss the bog
habitat and bog turtles. As part of the restoration plan for Southern Appalachian bog, we suggested that
the banks of Vile Creek be planted with shrubs and small tree species rather than large tree species. We
have concerns that the dense planting of large trees will eventually shade out the bog and will also lead
to more rapid succession of the bog, making the habitat unsuitable for bog turtles and eliminating many
of the herbaceous species. Additionally, the area with gray's lily is close to the creek on the north side of
Vile Creek R2 and may actually be in the planting area. Planting shrubs/small trees along restored
streams has been successfully done at other bog turtle sites (e.g., UT -Crab Creek in Alleghany Co NC.,
Shady Valley in TN, and Sparta Bog in Alleghany Co. NC). We recommend planting shrubs only in VC R1
and on the north side of VC R2. The south side (with the exception of area F — see below) could be
planted in trees.
We prefer to plant the stream side buffers with tree species as an element of the stream restoration to
create stability and shade. However, as we discussed by phone, in areas where there are bogs, we will
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609

reduce the riparian planting zone where tree species will be planted to a width of approximately 10 feet.
In addition, there will be a zone of wetland shrubs between the trees and the bog areas. On the opposite
sides of most bog areas there will be open pasture. We will avoid planting trees in the area where Gray's
lily was identified. We have created a new planting plan figure to clearly show the planting zones (Figure
12).
• The remnant patch of bog on the south side of Vile Creek R2 (labeled area F on Figure 3) is not
categorized as a "bog cell" and is currently in the zone to be planted as trees. This is one of the best
looking remnant patches of Southern Appalachian bog on the site and we recommend treating this area
accordingly with any disturbed land in the vicinity planted with herbaceous plants rather than trees.
We will adjust the plan to include area F as a bog area. Refer to the revised Figure 10.
• We have concerns about the planting stem densities for trees/shrubs and think they should be lower
than other typical mitigation community types since part of what is being restored is Southern
Appalachian bog, which is characterized by a mosaic of shrub thickets and herb dominated areas. UT to
Crab Creek mitigation site used woody shrub densities of <50 stems/acre, Shady Valley (TN) used 320
stems/ac and Sparta Bog also used 320-260 stems/acre.
We have adjusted the planting plan including the stems per acre. The riparian buffer planting zone stem
density will remain 605 plants per acre and the success criteria will remain unchanged from the draft
mitigation plan. The wetland shrub zone density will be 320 plants per acre and the success criteria will
be 160 surviving plants at year 3, 130 at year 5, and 105 at year 7. There will be no height requirement
for shrubs.
• In VC R1-2 we recommend creating a mosaic of shrub/herbaceous plants by including some
herbaceous plantings and/or relying on colonization from the seed bed in the areas between Vile Creek
and the bog cells rather than using just densely planted wetland shrubs. We recommend including
native pollinator seed mixes that include milkweeds in the herbaceous planting areas to gain the added
wildlife benefit of helping pollinators including Monarch butterflies and early succession bird species of
concern.
We have reduced the planting density in the wetland shrub zone. We have added native pollinators
including milkweed to the seed mix which will be applied to the wetland shrub zone. In addition, we
believe goldenrod and cardinal flower, among others, will volunteer on the site since they are currently
well established.
• We think that stockpiling the existing topsoil is an excellent idea. Exotics should be eliminated before
topsoil is removed if it is to be reapplied to the site. In addition, construction equipment should be
decontaminated prior to arriving onsite to eliminate transferring exotic species from other sites to the
Vile Creek site.
We will treat exotics on site prior to construction. We will ask the chosen contractor to decontaminate
their equipment to the best of their ability prior to arriving on site.
• We could not find a species list other than the insets on plan sheets. The tree list is of concern because
there are several species listed that are not native to the mountains of NC or appropriate for
Appalachian bog communities. Specifically, eastern cottonwood, swamp chestnut oak and silver maple
w Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609 9

should not be used. Appropriate tree substitutes could be box elder or black gum. Shrubs also could be
substituted including black willow (already found onsite), silky willow and silky dogwood. We also
question the use of green ash given threats from emerald ash borer.
We have revised the planting lists. The lists are now included in the mitigation plan as well as on the plan
sheets. For your convenience, we have included the revised planting lists along with this letter.
Long-term Management
• The document indicates that no long term management will be needed for this site. However, the site
may require management if it is to remain suitable for bog turtles. Accelerated succession as a result of
human impacts (e.g., changes in hydrology, increased nutrients, changes in natural disturbance regimes)
is a threat to bog turtles and most bog turtle sites now require management to keep some areas open.
Bog turtles need open areas for basking and nesting and one of the bog turtle's ultimate limitations is a
closed canopy, which cuts off surface light and warmth.
We have amended the document to state that long-term management may be needed to maintain the
bog habitat but that any post -closure maintenance will need to be performed by a third party.
• We recommend including language in the plan that allows for some management (e.g., cutting woody
vegetation out of the bog to open areas for bog turtles) by partner agencies/groups involved in bog
turtle conservation (e.g., NCWRC, USFWS, Project Bog Turtle) if it is needed.
While we are agreeable to this possibility, one or more of the suggested agencies/groups will need to be
responsible for the bog maintenance. We have added text to the mitigation plan that states that a)
agencies other than DEQ and Wildlands will perform any potential bog maintenance, b) any third party
activities therein that may affect success criteria prior to regulatory close out will not result in credit loss
at closeout, and c) that any post -closeout bog management will need to be pre -approved by the DEQ
Stewardship Program.
• Bog turtle sites can greatly benefit from occasional grazing by cows. If possible, we
recommend allowing the flexibility to include occasional, low density grazing in the bog cells
to maintain the habitat and eliminate the need for more labor intensive management.
We discussed allowing cows within the easement with the USACE. We were informed that this would not
be allowed.
Andrea Hughes, USACE, April 13, 2016:
1. Page 20, Section 4.5: Please provide a copy of the Corps JD approval letter and associated
map of existing resources.
This is included with the revised mitigation plan.
2. Page 22, Section 4.7: Please be aware that credits will be reduced for those areas with stream
buffers of less than 30 feet in width using the most current buffer guidance. For areas with a
buffer of less than 15 feet in width, no credit may be generated. Areas with buffers greater
than 30 feet wide may receive additional credit provided these areas do not overlap wetland
mitigation areas.
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609 10

We have already calculated the credit reductions using the buffer guidance and factored those into the
credit summary in Table 8. Figure 9 shows areas where the buffer is less than or greater than 30 feet. In
addition, we will provide a table of the buffer widths for areas where it will be less than or more than 30
feet and the associated credit reductions/increases for those areas.
3. Page 22, Section 4.7: The plan indicates that a CE cannot be obtained at this time for
approximately 166 linear feet of stream channel located on the Perry property and the
provider intends to relocate the stream channel onto the Crouse property. Please provide
additional information related to permissions/agreements with the current landowner for the
Perry property regarding relocation of this section of Vile Creek.
We have obtained a temporary construction easement to perform the work on the Perry property. We
have added text to describe the arrangement to the mitigation plan.
4. Page 26, Section 5.2.3: Regarding the conclusion that the project would have "no effect" on
the bog turtle, according to the USFWS letter dated August 14, 2016, the project is not likely
to adversely affect the species. Please revise the "no effect" statement.
We have made this revision (see previous comment and response above).
5. The mitigation plan proposes to modify the wetland rehabilitation/re-establishment activities
to facilitate development of bog turtle habitat. Therefore, the Corps recommends that the provider
coordinate design and construction plans with USFWS and NCWRC to ensure appropriate habitat for the
species. The Corps supports USFWS and NCWRC comments/suggestions regarding the bog habitat
provided above with the exception of cattle grazing. Also, the provider should propose appropriate
vegetation and hydrology monitoring and performance standards for these areas.
We believe that we understand and have addressed all of the USFWS and WRC concerns with the revised
mitigation plan and construction plans.
6. Page 53, Section 13.0: Please provide a long-term management strategy/plan for the 6.5 acres of bog
turtle habitat.
The bog turtle habitat is only approximately 1.96 acres. We apologize for the confusion related to this
acreage. See previous response to USFWS's comment regarding long-term management above.
7. Appendix 1, Site Protection: The site protection instruments for the Edwards and Mason properties
includes a provision under Section III advising the landowners that if they have livestock, they must
restrict livestock access to the easement areas and failure to do so may result in the state repairing
fencing or installing cattle exclusion devices at the landowners expense. The site protection instrument
for the Crouse properties (Areas A and B - restoration and Ell areas) does not include this provision. The
Corps believes this provision should be included in all site protection instruments to ensure that future
land use activities on the property will not result in adverse impacts to the resources. Also, the provision
should be modified to include tenants that may lease the land for agricultural use.
We understand the Corps' concern. This difference is that the Crouse parcels are used for livestock and
will be fenced (with exception of the western most parcel along UT1). The Mason property is fenced and
Wildlands plans to fence the Edwards and Miles properties. There should be no livestock access to the
streams. We typically would not add this clause to a property where livestock are grazed and fencing is
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, INC 27609 11

planned. It is a special provision used when fencing is not planned. At this point, we have closed on the
properties and the easements are final.
Please let me know if you have any additional comments.
Sincerely,
� ��-k
Jeff Keaton, Project Manager
Enclosure
w Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609 12

100%
RIPARIAN PLANTING ZONE
Common Name
Indiv.
Spacing
Species
Common Name
Spacing
Min. Caliper
Percentage
Alnus serrulate
Tag Alder
12ft x Eft
0.25"
10%
Carpinus caroliniana
American Hornbeam
12ft x 6ft
0.25"
10%
Liriodendron tulipifera
Tulip Poplar
12ft x 6ft
0.25"
15%
Platanus occidentalis
Sycamore
12ft x 6ft
0.25"
15%
Betula nigra
River Birch
12ft x 6ft
0.25"
15%
Quercus pagoda
Cherrybark Oak
12ft x 6ft
0.25"
15%
Fraxinus pennsylvanica
Green Ash
12ft x 6ft
0.25"
10%
Diospyros virginiana
Persimmon
12ft x 6ft
0.25"
10%
100%
100%
UNDERSTORY PLANTING ZONE
Common Name
Indiv.
Spacing
Species
Common Name
Spacing
Min. Caliper
Percentage
Carpinus caroliniana
American Hornbeam
12ft x 6ft
0.25"
25%
Aronia arbutifolia
Red Chokeberry
12ft x 6ft
0.25"
25%
Ilex verticillata
Winter Berry
12ft x 6ft
0.25"
25%
Lindera benzoin
Spicebush
12ft x 6ft
1 0.25" 1
25%
100%
100%
STREAM BANK PLANTING ZONE - Livestakes
WETLAND SHRUB PLANTING ZONE
Common Name
Indiv.
Spacing
Species
Common Name
Spacing
Min. Caliper
Percentage
Aronia arbutifolia
Red Chokeberry
12ft x 6ft
0.25"
15%
Ilex verticillata
Winter Berry
12ft x 6ft
0.25"
15%
Lindera benzoin
Spicebush
12ft x 6ft
0.25"
15%
Sambucus nigra
Elderberry
12ft x 6ft
0.25"
10%
Vaccinium corymbosum
Highbush Blueberry
12ft x 6ft
0.25"
15%
Cephalanthus occidentalis L.
Common Buttonbush
12ft x 6ft
0.25"
15%
Cornus amomum
Silky Dogwood
12ft x Eft
0.25
15%
100%
STREAM BANK PLANTING ZONE - Livestakes
Species
Common Name
Indiv.
Spacing
Min. Caliper
Percentage
Cornus amomum (Iivestake)
Silky Dogwood
3-6 ft
0.5"
20%
Cephalanthus occidentalis L.
Common Buttonbush
3-6 ft
0.5"
20%
Salix sericea (Iivestake)
Silky Willow
3-6 ft
0.5"
20%
Physocarpos opulifolius
Ninebark
3-6 ft
0.5"
20%
Alnus serrulata
Tag Alder
3-6 ft
1 0.5"
1 20%
100%

STREAM BANK PLANTING ZONE - Herbaceous Plugs
Species
Common Name
Indiv.
Spacing
Percentage
Juncus effusus
Common Rush
3-6 ft
40%
Carex alata
Broadwing Sedge
3-6 ft
40%
Ponicum virgatum
Switchgrass
3-6 ft
20%
100%
HERBACEOUS PLANTING ZONE
Species
Common Name
Indiv.
Spacing
Percentage
Juncus effusus
Common Rush
4 ft
15%
Carex alata
Broadwing Sedge
4 ft
15%
Carex lurida
Shallow Sedge
4 ft
15%
Carex crinita
Fringed Sedge
4 ft
15%
Scirpus cyperinus
Woolgrass
4 ft
20%
Sagittaria latifolia
Broadleaf Arrowhead
4 ft
20%
100%

Wetland Shrub Planting Zone—
Herbaceous Planting Zone
Enhancement I
4 `
Enhancement 11
Restoration
Existing Streams
Project
/ \ 25' culverted crossing !
external to easement !~
liocro j Little River
\ 3 _
.�
\ Glee �" \\
Vile Creek R2
\
- 25' Ford crossing
1 (no cattle access)
2040 Aerial Pho graphy