20140332 Ver 1_Application_20160203

Environmental
Quality
February 1, 2016
Karen Higgins, 401 & Buffer Permitting Unit Supervisor
Division of Water Resources
401 & Buffer Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699 - 1617
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
Re: Permit Application- Browns Summit Creek Restoration Project, Guilford County (DMS
Full Delivery Project)
Dear Ms. Higgins:
Attached for your review is 404/401 permit application package for the subject project. Another
copy has been sent to the Winston-Salem Regional Office for review. A memo for the permit
application fee is also included in the package. Please feel free to contact me with any questions
regarding this plan (919-707-8319).
Thank you very much for your assistance.
Sincerely
Lin Xu
Attachment: 404/401 Permit Application Package
Final Mitigation Plan
Permit Application Fee Memo
CD containing all electronic files
!'`Nothing Compares
State of Noith Carolina j Environmental Ouality
1601 Mail Service Center 1 Raleigh, North Carolina 27699-1601
919-707-8600

Environmental
Quality
MEMORANDUM:
TO:
FROM:
SUBJECT:
DATE:
Sharon Jones
Lin Xu LX
Payment of Permit Fee
401 Permit Application
February 1, 2016
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
The Division of Mitigation Services (DMS) is implementing a mitigation project for
Browns Summit Creek Site in Guilford County (DMS IMS # 96313). The activities
associated with this restoration project involve stream and wetland restoration related
temporary stream and wetland impact. To conduct these activities the DMS must
submit a Pre -construction Notification (PCN) Form to the Division of Water Resources
(DWR) for review and approval. The DWR assesses a fee of $570.00 for this review.
Please transfer $570.00 from DMS Fund # 2984, Account # 535120 to DWR as
payment for this review. If you have any questions concerning this matter I can be
reached at 919-707-8319. Thanks for your assistance.
cc: Karen Higgins, DWR
Cindy Perry, DMS
!>^ Nothing Compares_
State of North Carolina i EnvironmentalQuGlity
1601 Mail Service Center : Raleigh, North Carohna 27699-1601
919.707-3600

Environmental
Quality
February 1, 2016
Corey Basinger, Surface Water Protection Supervisor
NC DENR Winston-Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
PAT MCCRORY
DONALD R. VAN DER VAART
Secretary
Re: Permit Application- Browns Summit Creek Restoration Project, Guilford County (DMS
Full Delivery Project)
Dear Mr. Basinger:
Attached for your review is 404/401 permit application package for the subject project. Please
feel free to contact me with any questions regarding this plan (919-707-8319).
Thank you very much for your assistance.
Attachment: 404/401 Permit Application Package
Final Mitigation Plan
Cc: Karen Higgins
Sincerely
Lin Xu
!"-'Nothing Compares.
State of North Carolina j EIIVir0tiI77Gntal Q1161ity
1601 Mail Service Center i Raleigh, North Carolina 27699-1601
919 707-8500

Office Use Only:
Corps action ID no.
DWQ project no.
Form Version 1.4 January 2009
Pre -Construction Notification (PCN) Form
A. Applicant Information
1. Processing
1 a. Type(s) of approval sought from the Corps:
❑X Section 404 Permit ❑ Section 10 Permit
1 b. Specify Nationwide Permit (NWP) number: 27 or General Permit (GP) number:
1 c. Has the NWP or GP number been verified by the Corps?
❑ Yes ❑X No
1 d. Type(s) of approval sought from the DWQ (check all that apply):
❑X 401 Water Quality Certification — Regular ❑ Non -404 Jurisdictional General Permit
❑ 401 Water Quality Certification — Express ❑ Riparian Buffer Authorization
1 e. Is this notification solely for the record
because written approval is not required?
For the record only for DWQ
401 Certification:
❑ Yes ® No
For the record only for Corps Permit:
❑ Yes ❑X No
1f. Is payment into a mitigation bank or in -lieu fee program proposed for
mitigation of impacts? If so, attach the acceptance letter from mitigation bank
or in -lieu fee program.
❑ Yes ❑X No
1g. Is the project located in any of NC's twenty coastal counties. If yes, answer lh
below.
❑ Yes ❑X No
1 h. Is the project located within a NC DCM Area of Environmental Concern (AEC)?
❑ Yes © No
2. Project Information
2a. Name of project:
Browns Summit Creek Restoration Project
2b. County:
Guilford
2c. Nearest municipality / town:
Browns Summit
2d. Subdivision name:
N/A
2e. NCDOT only, T.I.P. or state project no:
N/A
3. Owner Information
3a. Name(s) on Recorded Deed:
See attached document
3b. Deed Book and Page No.
See attached document
3c. Responsible Party (for LLC if
applicable):
N/A
3d. Street address:
See attached document
3e. City, state, zip:
See attached document
3f. Telephone no.:
See attached document
3g. Fax no.:
N/A
3h. Email address:
N/A
Page 1 of 10
PCN Form — Version 1.4 January 2009

4. Applicant Information (if different from owner)
4a. Applicant is:
❑ Agent X❑ Other, specify: In-Lieu Fee (ILF)
4b. Name:
Tim Baumgartner
4c. Business name
(if applicable):
NC
-b"Pi n e M�� st/✓t
4d. Street address:
217 West Jones St., Ste. 3000A
4e. City, state, zip:
Raleigh, NC 27603
4f. Telephone no.:
1919-707-8543
4g. Fax no.:
919-218-2557
4h. Email address:
[e-mail]
5. Agent/Consultant Information (if applicable)
5a. Name:
Katie McKeithan
5b. Business name
(if applicable):
Michael Baker Engineering, Inc.
5c. Street address:
8000 Regency Parkway, Suite 600
5d. City, state, zip:
Cary, NC 27518
5e. Telephone no.:
919-487-5703, 919-805-1750 cell
5f. Fax no.:
919-463-5490
5g. Email address:
[e-mail]
Page 2 of 10
es CUU-)

B. Project Information and Prior Project History
1. Property Identification
1a. Property identification no. (tax PIN or parcel ID):
See attached document
1 b. Site coordinates (in decimal degrees):
Latitude: 36.234622 Longitude: -79.747469
1 c. Property size:
19 acres
2. Surface Waters
2a. Name of nearest body of water to proposed project:
Browns Summit Creek
2b. Water Quality Classification of nearest receiving water:
C; NSW
2c. River basin:
Cape Fear (HUC 03030002-010020)
3. Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
The current land use consists of managed pasture for cattle grazing, agriculture crop land, forest land, and residential development. The riparian
buffer within the project area has been cleared in multiple areas to increase pasture production. On-site stream channels are actively eroding, incised,
and disconnected from the floodplain. Both stream channels and riparian wetlands are degraded from cattle access and lack of riparian vegetation.
3b. List the total estimated acreage of all existing wetlands on the property: 4.44
3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property: 6,299
3d. Explain the purpose of the proposed project:
The purpose is to restore ecological function to an impaired riparian system that discharges to the Haw River. See the Brown's Summit Mitigation Plan.
3e. Describe the overall project in detail, including the type of equipment to be used:
See attached document.
4. Jurisdictional Determinations
4a. Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /
project(including all priorphases) in thepast?
❑X Yes ❑ No ❑ Unknown
Comments: SAW -2014-01642
4b. If the Corps made the jurisdictional determination, what type
of determination was made?
E] Preliminary MX Final
4c. If yes, who delineated the jurisdictional areas?
Name (if known): Scott King & Dwayne Huneycutt
Agency/Consultant Company:
Other: Michael Baker Engineering, Inc.
4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation.
September 15, 2014; See the approved Jurisdictional Determination (SAW -2014-01642) included in the Mitigation Plan.
5. Project History
5a. Have permits or certifications been requested or obtained for
this project (including all prior phases) in the past?
Yes E9 No El Unknown
5b. If yes, explain in detail according to "help file" instructions.
6. Future Project Plans
6a. Is this a phased project?
❑ Yes ❑X No
6b. If yes, explain.
Page 3 of 10
PCN Form — Version 1.4 January 2009

C. Proposed Impacts Inventory
1. Impacts Summary
1a. Which sections were completed below for your project (check all that apply):
❑X Wetlands ❑X Streams — tributaries ❑ Buffers ❑ Open Waters ❑ Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a.
2b.
2c.
2d. '
2e.
2f.
Wetland impact
Type of impact
Type of wetland
Forested i
Type of jurisdiction
Area of
number
Corps (404,10) or
impact
Permanent (P) or
DWQ (401, other)
(acres)
Temporary T
W1 T
Restoration
Piedmont Alluvial Forest
No
Corps
4.44
W2
Choose one
Choose one
Yes/No
W3
Choose one
Choose one
Yes/No
-
W4
Choose one
Choose one
Yes/No
-
W5
Choose one
Choose one
Yes/No
N/g
Choose one
Choose one
I Yes/No
-
2g. Total Wetland Impacts:
4.44
2h. Comments:
See attached page for additional impact information. Total Permanent Wetland Impacts = 0.0035 acres. Total Temporary Wetland Impacts = 0.0215
acres. W2 — W7 were categorized as headwater forest wetlands, while W1 and WPond were categorized as floodplain pools. These wetland types
are based on the NC WANT and the field investigators best professional judgment. A!I existing wetland areas are degraded either by frequent cattle
access and!or brush management practices. Impacts to wetland areas are necessary for project success and long term ecological benefit.
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site. then complete this
question for all stream sites impacted.
3a.
3b.
3c.
3d. 3e. 3f.
3g.
Stream impact
Type of impact
Stream name
Perennial (PER) ori Type of Average
Impact
number
intermittent (INT)? jurisdiction I stream
length
Permanent (P) or
width
(linear
Temporary (T)
(feet)
feet)
S1 T
Restoration
UT to the Haw River
Both
Corps
10
6,592
82
Choose one
S3
Choose one
S4
Choose one
S5
Choose one
S6
Choose one
3h. Total stream and tributary impacts
6,592
3i. Comments:
Existing channels are significantly degraded from channelization, frequent cattle access, lack of riparian buffer, and erosion. Impacts to channels are
necessary to stabilize stream banks, improve hydrology; and restore aquatic habitat; therefore promoting proper riparian function for project success
and long term ecological benefit. See Mitigation Plan for additional information.
Page 4 of 10
PCN Form - Version 1.4 January 2009

4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U.S. then individually list all open water impacts below.
4a.
Open water
impact number
Permanent (P) or
Temporary T
4b.
Name of waterbody
(if applicable)
4c.
Type of impact
4d.
Waterbody
type
4e.
Area of impact (acres)
01
Choose one
Choose
O2
Choose one
Choose
03
Choose one
Choose
04
Choose one
Choose
4f. Total open water impacts
4g. Comments:
5. Pond or Lake Construction
If pond or lake construction proposed, the complete the chart below.
5a.
Pond ID number
5b.
Proposed use or
purpose of pond
5c. 5d. 5e.
Wetland Impacts (acres) Stream Impacts (feet) Upland
(acres)
Flooded
Filled Excavated Flooded Filled
Excavated
P1
Choose one
P2
Choose one
5f. Total:
5g. Comments:
5h. Is a dam high hazard permit required?
❑ Yes ❑ No If yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If any impacts require mitigation, then you MUST fill out Section D of this form.
6a. Project is in which protected basin?
❑ Neuse ❑ Tar -Pamlico ❑ Catawba ❑ Randleman ❑ Other:
6b.
Buffer Impact
number —
Permanent (P) or
Temporary T
6c.
Reason for impact
6d.
Stream name
6e.
Buffer
mitigation
required?
6f.
Zone 1
impact
(square
feet)
6g.
Zone 2
impact
(square
feet
61
Yes/No
B2
Yes/No
B3 -
Yes/No
B4 -
Yes/No
B5 -
Yes/No
B6 -
Yes/No
6h. Total Buffer Impacts:
6i. Comments:
Page 5 of 10

D. Impact Justification and Mitigation
1. Avoidance and Minimization
1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
The proposed impacts are required to restore stream and wetland functions, as described in the Mitigation Plan. As the intent of the project is to
restore the overall stream and wetland complex, design efforts were taken to minimize impacts to the existing channel and wetlands wherever
possible. Construction access routes were carefully selected to try to minimize wetland crossings. All disturbed areas will be planted with native seed,
live stakes, and bare root seedlings to re-establish the riparian wetland community upon completion of disturbance.
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
Construction practices will follow guidelines from the NC Erosion and Sediment Control Planning and Design Manual. NC Erosion and Sediment
controls will be implemented. Wetland mats will be laid down to help minimize impacts to wetland areas where only no work is to be performed.
Stream bank grading will be conducted from the channel where possible to avoid compaction of the floodplain wetlands. The construction activities will
also be phased so that the contractor only disturbs as much stream banks as s/he can stabilize by the end of the day.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for
impacts to Waters of the U.S. or Waters of the State?
❑ Yes ❑X No
2b. If yes, mitigation is required by (check all that apply):
❑ DWQ ❑ Corps
2c. If yes, which mitigation option will be used for this
project?
❑ Mitigation bank
El Payment to in -lieu fee program
❑ Permittee Responsible Mitigation
3. Complete if Using a Mitigation Bank
3a. Name of Mitigation Bank:
3b. Credits Purchased (attach receipt and letter)
Type: Choose one
, Type: Choose one
Type: Choose one
Quantity:
Quantity:
Quantity:
3c. Comments:
4. Complete if Making a Payment to In -lieu Fee Program
4a. Approval letter from in -lieu fee program is attached.
❑ Yes
4b. Stream mitigation requested:
linear feet
4c. If using stream mitigation; stream temperature:
Choose one
4d. Buffer mitigation requested (DWQ only):
square feet
4e. Riparian wetland mitigation requested:
acres
4f. Non -riparian wetland mitigation requested:
acres
4g. Coastal (tidal) wetland mitigation requested:
acres
4h. Comments:
5. Complete if Using a Permittee Responsible Mitigation Plan
5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
I
Page 6 of 10
PCN Form — Version 1.4 January 2009

6. Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWQ
6a. Will the project result in an impact within a protected riparian buffer that requires
buffer mitigation?
Yes ❑X No
6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.
Zone
6c.
Reason for impact
6d.
Total impact
(square feet)
Multiplier
6e.
Required mitigation
(square feet)
Zone 1
3 (2 for Catawba)
Zone 2
1.5
6f. Total buffer mitigation required:
6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in -lieu fee fund).
6h. Comments:
Page 7 of 10

E.
Stormwater Management and Diffuse Flow Plan (required by DWQ)
1.
Diffuse Flow Plan
1 a.
Does the project include or is it adjacent to protected riparian buffers identified
❑ Yes ® No
within one of the NC Riparian Buffer Protection Rules?
1 b.
If yes, then is a diffuse flow plan included? If no, explain why.
❑ Yes ❑ No
I
a
2.
Stormwater Management Plan
2a.
What is the overall percent imperviousness of this project?
0
2b.
Does this project require a Stormwater Management Plan?
❑ Yes ❑X No
2c.
If this project DOES NOT require a Stormwater Management Plan, explain why:
The project involves work in the stream corridor only. No work will be performed outside the stream corridor
and the only impervious areas include 2
culverts that will be replaced; therefore, this section is not applicable.
2d.
If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan:
2e.
Who will be responsible for the review of the Stormwater Management Plan?
NIA
3.
Certified Local Government Stormwater Review
3a.
In which local government's jurisdiction is this project?
N/A
❑ Phase II
❑ NSW
3b.
Which of the following locally -implemented stormwater management programs
❑ USMP
apply (check all that apply):
❑ Water Supply Watershed
❑ Other:
3c.
Has the approved Stormwater Management Plan with proof of approval been
❑ Yes ❑ No
attached?
4.
DWQ Stormwater Program Review
❑Coastal counties
❑HQW
4a.
Which of the following state-implernented stormwater management programs apply
❑ORW
(check all that apply):
❑Session Law 2006-246
❑ Other:
4b.
Has the approved Stormwater Management Plan with proof of approval been
❑ Yes ❑ No
attached?
5.
DWQ 401 Unit Stormwater Review
5a.
Does the Stormwater Management Plan meet the appropriate requirements?
❑ Yes ❑ No
5b.
Have all of the 401 Unit submittal requirements been met?
❑ Yes ❑ No
Page 8 of 10
PCN Form — Version 1.4 January 2009

F. Supplementary Information
1. Environmental Documentation (DWQ Requirement)
1 a. Does the project involve an expenditure of public (federal/state/local) funds or the
N Yes ❑ No
use of public (federal/state) land?
1 b. If you answered "yes" to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State
OYes ❑ No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1 c. If you answered "yes" to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
letter.) See the approved Categorical Exclusion (CE) Document in Mitigation Plan for
®Yes ❑ No
Comments: additional information.
2. Violations (DWQ Requirement)
2a. Is the site in violation of-DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H.1300), DWQ Surface Water or Wetland Standards,
❑Yes 0 No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b. Is this an after -the -fact permit application?
❑Yes 0 No
2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s):
3. Cumulative Impacts (DWQ Requirement)
3a. Will this project (based on past and reasonably anticipated future impacts) result in
[]Yes 0 No
additional development, which could impact nearby downstream water quality?
3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
This is a stream and wetland mitigation project that includes a conservation easement over the entire project area which will aid to improve
downstream water quality. The easement is being held by the State of North Carolina and restricts any future development within the project area.
4. Sewage Disposal (DWQ Requirement)
4a. Clearly detail the ultimate treatment methods and disposition (non -discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
This project is a stream and wetland mitigation project and will not generate wastewater, but will instead serve as a natural treatment for non -point
pollution from the surrounding drainage areas.
Page 9 of 10
PCN Form — Version 1.4 January 2009

5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or
❑X Yes ❑ No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act
Yes ❑ No
impacts?
5c. If yes, indicate the USFWS Field Office you have contacted.
Raleigh
5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
A review of federally listed species in Guilford County was conducted. A field survey was conducted within the project area and no populations and/or
suitable habitat were found. USFWS was contacted and informed. On 9/2/2014, FHWA concurred with a biological conclusion of "no effect".
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat?
❑ YesX❑ No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
There are no marine or estuarine habitats located with the Piedmont Physiographic Region of North Carolina. In addition the NCNWRC was contacted
and they responded stating that they did not anticipate that the project would pose any significant adverse impacts to aquatic resources.
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation
❑%� Yes No
❑
status (e.g., National Historic Trust designation or properties significant in +
North Carolina history and archaeology)?
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
Requested review and comment from the NC SHPO. On 5/2912014, we received comment from the State HPO, stating that no historic resources
would be affected by the project.
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA -designated 100 -year floodplain?
❑ Yes ❑X No
8b. If yes, explain how project meets FEMA requirements:
8c. What source(s) did you use to make the floodplain determination?
A review of Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) for Guilford County and its unincorporated areas
(Map Number 3710797000.1) indicates the project site is not located within a FEMA -identified flood zone.
Tim Baumgartner
Applicant/Agent's Printed Name
Date
Applicant/Agent's Signature
(Agent's signature is valid only if an authorization
letter from the applicant isprovided.)
Page 10 of 10

I N T E R N A T 1 0 N A L
September 17, 2015
Jeff Schaffer
NCDENR, Division of Mitigation Services
1652 Mail Service Center
Raleigh, NC 27699-1652
Michael Baker Engineering, Inc.
797 Haywood Road, Ste. 201 1 Asheville, North Carolina 28806
Office: 828.350.1408 1 Fax: [phone]
Subject: Response to IRT Comments for Revisions to Final Mitigation Plan
Browns Summit Creek Mitigation Project, Guilford County
Cape Fear Cataloging Unit 03030002
USACE AID SAW 2014-01642, DMS Project # 96313
Dear Mr. Schaffer:
Please find enclosed our responses to the Inter -Agency Review Team (IRT) review comments dated
July 14th and July 30th of 2015 in reference to the Browns Summit Creek Mitigation Project -Draft
Mitigation Plan in Guilford County, NC. We have revised Final Draft Mitigation Plan document in
response to the referenced review comments and have included those revisions for review. Each
comment/response has been grouped per the NCIRT reviewer and is outlined below.
Todd Bowers, USEPA. 16 July 2015
1. Table 1; Page 2-1: R1 Drainage area is listed as 438 acres. This is not consistent with other values
such as Table 4.1 (448 acres)
Response: Drainage area discrepancies throughout the Mitigation Plan have been checked and
revised where needed and are as follows in acreage: R1 = 438, R2 = 299, R3 = 242, R4 =138, R5 = 24,
R6 = 61, T1 = 55, T2 = 47, T3 = 41, and T4=10.
2. Page 1-2: Recommend adding "restore stream and floodplain connectivity" in list of bulleted
primary goals especially since wetland hydrology performances are depending on it.
Response: As requested, we have included "restore stream and wetland connectivity" in the primary
goals of both the Executive Summary and in Section 1.0.
3. Page 1-2: Stated objectives should be measurable (as well as specific, attainable, reasonable and
trackable). Improvement, as well as degradation, in water quality is measurable. If this is the case
then Baker should be measuring water quality for at least some parameter to demonstrate that this
objective has been achieved. Performance standards relating to water quality, especially if tied to
the BMPs (116 and T4), should be developed accordingly.
Response: The stated goals and objectives listed in both the Executive Summary and Section 1.0 have
been revised to reflect the method (implementation ofstandard best management practices) proposed
for the reduction of non -point source loads instead of a vague statement for improving water quality.
Because the methods chosen for the reduction of non -point source loading are commonly used for their
effectiveness, we feel that additional monitoring of such parameters and development of performance
standards are not needed. The revisions are as follows:
MICHAEL BAKER INTERNATIONAL
Global Innovation... Done Right
oma KASEMM ///SALLYPORT *+*+PMSI

Michael Baker Michael Baker Engineering, Inc.
797 Haywood Road, Ste. 201 1 Asheville, North Carolina 28806
1 N T E R N A T 1 Q N A L Office: 828.350.1408 1 Fax: [phone]
Goals:
Address known and obvious water quality and habitat stressors present on site.
Objectives:
Construct a wetland BMP on the upstream extent of'R6 to capture and retain stormwater run-off
from the adjacent cattle pastures to allow for the biological removal of nutrient pollutant loads
and for sediment to settle out of the water column
Construct a step pool BMP channel to capture and disperse stormwater volumes and velocities
by allowing discharge from a low density residential development to spread across the
floodplain of Reach 4 thereby diffusing energies and promoting nutrient uptake within the
riparian buffer
The credit ratios for both BMPs were established during a site visit on June 4, 2014. During that site
visit, IRT members and Baker staff agreed that the implementation of the following BMPs and
associated enhancement measures would yield a 1.5:1 credit ratio for the valley length of the entire
BMP:
1) The conversion of the existing farm pond along R6 to a wetland type feature with a low -
maintenance weir outlet, the stabilization of the channel upstream and downstream of the BMP,
2) The stabilization of a migrating headcut along T4 by implementing a rock lined step -pool
channel that will dissipate into a plunge pool that will detain the runoff and allow for dissipation
into the floodplain,
3) The exclusion of cattle from the entirety of the reach within the easement,
4) The treatment of invasive species, and/or
5) The replanting of the riparian buffer.
Currently there are no performance criteria for BMPs and none were specified by the IRT during this
meeting or during following site visits or subsequent conversation; therefore, no performance criteria
were developed. See the attached meeting minutes for reference. Please note that the meeting
minutes will also be included in Appendix D of the Mitigation Plan.
4. Page 2-2; last paragraph: R2 and R1 are not second -order streams, especially if R3 and R4 are
considered first -order. The inclusion of T-2 (zero order) does not change the stream order of the
main stem.
Response: The stream order error has been corrected and revised as follows: "The zero -order streams
include Reaches R5, R6, T1, T2, T3, and T4. The first -order streams include Reaches R1, R2, R3 and R4."
S. 2.2.1; Page 2-3 first paragraph: Land use percentages of the "watershed" are not consistent with
those listed on Page 1-1 and Table 4.1. The "watershed" in question changes from an 83 -square
mile HUC to the project watershed with differing percentages in one comparison and same
percentages in another comparison. Recommend making this clearer in the document.
Response: To more clearly define that we are discussing the Browns Summit project drainage area
and not the entire watershed, we have revised the paragraph to read as follows: "Land use within the
project's drainage area (438 acres) is approximately 79 percent agricultural, 14 percent forested, and
5 percent developed, with approximately 90 percent of stream reaches lacking adequate riparian
buffers."
6. 4.0 Baseline information: Some water quality parameter(s) should be included in order to
demonstrate that 1) the water quality is impaired and needs improvement and 2) that
improvements to water quality, a stated objective, has been achieved. Fecal coliform or E. coli might
be a suitable parameter in this case since we are dealing with cattle exclusion.
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Response: Baker understands the reasoning behind the request to include baseline measurements for
water quality parameters to show existing impairments to water quality and validate improvements
to water quality from the project's implementation; however, we feel that these measures are
unnecessary. We feel that the visual evidence of environmental stressors such as unrestricted cattle
access to the project tributaries, eroding and degraded stream banks, lack of riparian buffer, and
manure deposition does provide sufficient documentation that degradation in the form of excess
sedimentation and fecal contamination is highly probable. Thereby the removal of these stressors and
implementing common restoration practices that fence cattle out of the stream, stabilize eroding
stream banks, and vegetate the riparian corridor will result in the reestablishment of a healthy and
productive ecosystem that will provide bank stability and will allow for natural nutrient removals
through biological processes.
7. Table 4.1: Project Drainage Area does not match R1 Drainage Area and 2.2.1
Response: Please see our response to Comment No. 1, above.
8. Table 4.1: Missing 7 percent of land use classification?
Response: The Cape Fear River Basin Restoration Priorities 2009 Report does not classify the
remaining 7% of the drainage basin. However, in order to clarify, we have added the following text to
Section 1.0, "The designated land use of the remaining seven percent subwatershed remains
unclassified" and have also updated Table 4.1 to reflect this clarification.
9. Table 5.1: BMP Elements. Both Elements state that improvement in water quality is part of the
Purpose/Function. How do we know that this will be achieved successfully?
Response: To better articulate the purpose/function of the BMPs, Table 5.1 has been revised as
follows:
Element
Location
Purpose / Function
Detain runoff to reduce discharge velocities,
SW
Reach R6
allow for sediment to settle out of the water
column and to allow for the uptake of nutrient
loads from biological processes
Detain runoff to disperse stormwater volumes into
NI
Reach T4
the floodplain of Reach 4, reduce discharge
velocities, and promote nutrient uptake within the
riparian buffer
10. 7.1.3, Page 7-2: Live stake density appears erroneous. "40 stakes per 1,000 square feet" should read
"400 stakes per 1,000 linear feet" This will achieve the spacing required.
Response: This error has been corrected and we have revised the live stake density to correctly state
"400 stakes per 1,000 linearfeet". This correction was also updated throughout the remainder of the
document.
11. Page 7-5, last paragraph: "Reducing streambank sediment loading and removing cattle will provide
ecological uplift by improving water quality..." Once again a water quality objective is stated with
no baseline data or plans to collect data to support this statement. Recommend collecting baseline
water quality data to provide evidence that ecological lift has (or has not) been achieved. The
statement in the following paragraph does provide for removing the inputs via cattle exclusion but
that does not present measurable data that water quality itself is better and if so by how much.
Response: Please see our response to Comment No. 6, above. Baker has also revised sentence four in
paragraph 8 and removed sentence three in paragraph 9 of Section 7.3 on pages 7-5 and 7-6, to
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eliminate unsubstantiated references to water quality improvements. Sentence 4 of paragraph 8
reads as follows:
"Stabilizing streambanks, revegetating riparian buffers, and removing cattle along project reaches
will provide ecological uplift by reducing nonpoint source loading to the receiving waters and
promoting the restoration of diverse aquatic and terrestrial habitats appropriate for the piedmont
ecoregion and landscape setting."
12. 9.0, Page 9-1 and 9.2, Page 9-3: No performance standard is given for tree heights at 5 years (7')
and 7 years (10'). Recommend adding this performance standard unless Baker can justify why this
cannot be achieved.
Response: We recognize that average height recommendations are listed as performance standards
for success criteria in Year 5 and 7 in draftguidelines circulated by the IRT in 2011; however an
official revision to the 2003 stream mitigation guidelines has not been produced. Approximate heights
by species will be recorded as part of an overall assessment of vigor to determine whether the buffer
appears to be on an acceptable trajectory, butgiven uncertainties in precipitation, variations in
species growth rates and soil heterogeneity the assignment of an arbitrary blanket average is
inadvisable.
13. 9.2, Page 9-3: First paragraph mentions R7. Remove R7
Response. R3 should have been included instead of R7; therefore, we have replaced R7 with R3. The
revised text is stated as follows: 'No monitoring quadrants will be established within the undisturbed
wooded areas of Reaches R3, R4, R5, and R67
.
14. 9.2, Page 9-3: Vegetation monitoring addresses riparian buffer monitoring and plot density. It is
unclear how wetland vegetation monitoring will be conducted. Recommend at least one plot per
wetland type/area in addition to monitoring riparian buffer vegetation.
Response: Vegetation monitoring was inadvertently specified for riparian buffer areas. Instead it
should have been stated that vegetation monitoring would be conducted within randomly placed
vegetation plots throughout the planted buffer, therefore, the reference to "riparian" has been deleted
and currently reads as follows: "...within the planted buffer areas..." In order to ensure
representative monitoring of vegetation within riparian, upland, and wetland communities, the
vegetation plots have been relocated to encompass the different community types throughout the
planted easement area, as needed. Figure 9.1 has been revised to depict the updated vegetation plot
locations.
15. 17.1.1.1, Page 17-1: R3 and R2 drainage areas do not match Table 1 in Site Selection
Response: Please see our response to Comment No. 1, above.
16. Tables 17-7 and 17-8: Design Estimates and Proposed Bankfull Velocities for R1, R2, R3 and R4 do
not match.
Response: We have revised bankfull velocities in Table 17-7 to match those in Table 17-8.
17. 17.5.1, Page 17-46: Are three automated groundwater wells enough coverage for monitoring five
wetland types? It appears that six stations are going to be installed per Figure 9.1 on page 9-6
Response: Section 17.5.1 is describing pre -construction condition analysis within the proposed
project wetland areas; however, the number of pre -construction groundwater wells was incorrectly
stated. The number of wells should be five, not three. Section 17.5.1 has been renumbered and is now
listed as Section 17.5.4 and the text has been revised as follows: 'Five automated groundwater wells
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were installed within project area to evaluate the pre -construction hydrologic conditions of the site".
Post -construction ground water data collection is discussed in Section 9.3.1.
18. 17.7.2, Page 17-51: Live stake density appears erroneous. "40 stakes per 1,000 square feet" should
read "400 stakes per 1,000 linear feet" This will achieve the spacing required.
Response: Please see our response to Comment No. 10, above.
19. Tables 17.10 -12: Planting plan appears excellent for both riparian buffer and wetlands.
Response: Thankyou very much.
Ginny Baker/Sue Homewood, NCDWR. 1 June 2015
1. Monitoring wells should be installed along intermittent reaches that are proposed for priority 1
restoration to ensure a minimum of 30 consecutive days of base flow is maintained during a normal
growing season. One well should be installed in the upper part of the reach for R4 (in the
intermittent section if this overlaps with P1 restoration), reach T1 and reach T3.
Response: Baker will install one pressure transducer within the thalweg of T1, T3, and the
intermittent portion of R4. In addition, a flow camera will be installed with each in -stream transducer
to collect a continuous series of remote photos over time and an on-site rain gage will document
rainfall. This data will be used to subjectively evaluate channel flow conditions throughout the year.
These devices will be inspected on a quarterly/semi-annual basis to document surface hydrology and
provide a basis for evaluating general flow response to rainfall events and surface runoff during
various water tables levels throughout the monitoring period. See Figure 9.1 for the approximate
location of the additional devices. A sub -section called 'Flow Documentation" has been added to
Section 9.1 to reflect this addition. This sub -section is now listed as 9.1.2 and the remainder sub-
sections within this section have been renumbered accordingly.
2. The hydrology success criteria proposed for wetlands located in the lower end of the project along
reaches 1 and 2 are inconsistent. The 12% success standard for a normal precipitation year
proposed for the wetland type 2 (degraded) and wetland type 3 (partially functioning) seems
appropriate for a riverine/riparian associated wetland.. The 6% hydrology success standard
proposed just upstream for wetland type 4 (filled), which is the same type of wetland, does not
seem appropriate, especially as a 1:1 credit ratio is proposed. In addition, a 9% hydrology standard
(which NC DWR finds acceptable for a headwater wetland associated with a first order stream) is
proposed further upstream closer to the headwaters along Reach 4 in wetland type 5 (filled). NC
DWR understands Baker is concerned that only removing fill and using the E1 approach rather than
P1 restoration which would raise the channel and increase flooding may not result in the same level
of hydrological uplift as along Reach 1 where P1 restoration is proposed. Perhaps the 1:1 ratio
should be adjusted if only a partial hydrological uplift for wetland type 3 is achieved.
Response: The hydrologic success criteria for Wetland Type 4 has been revised to 12% so that all the
wetland areas along both Reach 1 and 2 are consistent. The second and third sentences in paragraph
two of Section 9.3.2 have been revised as follows: "The success criteria for wetland hydrology will
follow a range from 9-12 percent, depending on the specific wetland location and the mitigation
activity proposed. The wetland areas along Reach R1 and the large bend of Reach 2 will meet success
criteria for wetland hydrology when the soils are saturated within 12 inches of the soil surface for 12
percent of the growing season or twenty eight (28) or more consecutive days during the growing
season (229 days)." The third paragraph in Section 9.3.2 has been removed.
3. Please add a vegetation plot to Wetland type 5, which is already established with mature
successional species.
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Response: A vegetation plot has been located in Wetland Type 5 within the riparian corridor
adjacent to the newly aligned Priority I channel. Figure 9.1 has been revised to show the vegetation
plot in Wetland Type S.
4. NC DWR would like more design specifications to be provided in in the final mitigation plan for the
two proposed BMPs. For the Constructed Wetlands, reference has been made to the BMP manual.
The plans should clearly identify all key elements of the design with regards to requirements in
either the BMP manual or the new MDC for Constructed Wetlands with explanations for any
deviations from the typical design requirements. The BMP Supplement Form may provide
guidance for what details to provide in future design documents. Regenerative Stormwater
Conveyances (RSCs) as proposed for T4 on Table 7.1, page 7-4, are not in the NC BMP Manual so it
is unclear what design standard will be used for the RSC NC DWR would recommend that RSC
designs adhere to the Anne Arundel County, MD or the West Virginia design standards for RSCs,
available at http://www.aacounty.org/DPW/Watershed/StepPoolStormConveyance.cfm and/or
http//www.dep.vvv.gov/WWE/Programs/stormwater/MS4/Documents/Specification 4.2.7 Rege
nerative Stormwater Conveyance WV-SW-Manual-11-2012.pdf.
Response: Two stormwater BMPs will be implemented within the project extents. A constructed
headwater wetland will be implemented along Reach R6 and a rock lined step pool channel
stormwater control measure will be implemented along Reach T4. Design elements within the
Mitigation Plan have been revised to include the following documentation.
The constructed wetland was designed to detain discharge quantities from the 1 -inch rainfall event. A
V -notched weir will be implemented to slowly release discharges over a 48 hour period thereby
reducing downstream discharge velocities. The extended draw down time will also allow for
sediments to settle out of the water column and for the uptake of nutrients from wetland plantings.
The constructed wetland was designed to meet stormwater pollutant removal rates using the design
parameters outlined in the NCDENR BMP Manual. Design elements for the constructed wetland will
include the following wetland zones:
Deep Pools:
o Non-Forebay: 18-36" (include one at the outlet structure for proper drawdown).
o Forebay: 18-36" plus additional depth for sediment accumulation (deepest near inlet to
dissipate energy, more shallow near the exit).
Shallow Water (low marsh): 3-67.
Shallow Land (high marsh): Up to 12". This is the depth of the temporary pool.
Upland: Up to 4 feet above the shallow land zone.
The BMP along Reach T4 was incorrectly labeled as a regenerative stormwater control measure. It
should have been listed as a rock lined step pool channel stormwater control measure as agreed upon
during onsite meetings on April 14 and June 20, 2014. The BMP will be created to stabilize a
migrating headcut on Reach T4 that is located at the outfall of a 30 -inch stormwater culvert which
drains much of the Broad Ridge Court subdivision. The rock -lined step -pool channel will be
constructed to bring the stormwater runoff from the outlet to the floodplain elevation. A properly -
sized basin will capture the runoff, diffuse its energy, and allow water to spread across the vegetated
floodplain, promoting nutrient uptake within the buffer. A stable outlet channel will be constructed to
deliver the runoff to the project reach.
Both BMPs will be included in the project conservation easement and its fencing perimeter. Design
details are included in the plan set. BMP design calculations for the constructed wetland are included
in Appendix E.
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Office: 828.350.1408 1 Fax: [phone]
5. The BMP success standards and objectives for R6 and T4 need further description in Section 9.4.
Please describe what performance standards will be used to document that the BMPs are providing
functional uplift to the mitigation project.
Response: As discussed in Comment No. 3 (above) under the heading 'Todd Bowers, USEPA, 16 July
2015" the credit ratios for both BMPs were established during a site visit on June 4, 2014. During that
site visit, IRT members and Baker staff agreed that the implementation the BMPs and associated
enhancement measures would yield a 1.5:1 credit ratio for the valley length of the entire BMP for
which performance criteria was not stipulated. Currently there are no performance criteria for BMPs
and since none were specified by the IRT during this meeting or during following site visits or
subsequent conversation, no performance criteria were developed. See the attached meeting minutes
for reference. Please note that the meeting minutes have been included in Appendix D of the
Mitigation Plan.
6. How will the two BMPs be maintained in perpetuity after the site is closed out?
Response: Baker understands that the long term maintenance for the proposed BMPs can be a
concern; therefore, they have been designed and located to eliminate the need for long term
maintenance needs by:
1. Stabilizing channel erosion
2. Installation of a low maintenance weir.
3. Extending the conservation easement and buffer plantings approximately 15 - 30 feet beyond the
footprint of the BMP to allow the buffer vegetation to act as pre-treatment feature for both
suspended sediment and nutrient loads,
4. Implementing permanent fencing outside the easement to ensure permanent livestock exclusion,
5. Providing a stable outlet mechanism/spillway for the BMPs
6. Provide stormwater draw down for the constructed wetland in R6 to maintain downstream
stream functions while maintaining a storage capacity only to support the permanent pool.
In addition, Baker will be providing post -construction monitoring and maintenance, as needed, during
the monitoring years thereby facilitating the wetland and riparian vegetation to become established
and functioning as intended prior to project closeout.
Andrea Hughes, USACE, 26 July 2015
1. Section 2.2: The mitigation plan indicates that another category of wetlands has been added to the
plan during mitigation plan development. During mitigation plan development, the Corps made
numerous visits to the Brown's Summit site and held several discussions regarding changes to the
mitigation plan associated with proposed mitigation activities and determination of mitigation
credits. The intent of on-site meetings and discussions is to resolve concerns or issues associated
with the mitigation proposal prior to submitting the draft mitigation plan. At no time during the
course of these meetings was the proposal to add another category of wetlands to the mitigation
plan in order to generate additional credits discussed with the Corps and/or the IRT. Please
remove from the mitigation plan those areas located adjacent to Reach 4 and identified as "5 -
hydrologic Reestablishment, 1:1 credit ratio" on Figure 9.1. No mitigation credits will be generated
for these areas.
Response: Baker's intent for inclusion of Wetland Type 5 was to help us meet our contracted amount
of WMUs for the project. On 8/6/2015, Scott King (Baker) contacted Andrea Hughes (USACE) to
discuss the reasoning for Baker's inclusion of the Wetland Type S. Mr. King explained that:
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"We are not seeking to expand our contracted WMU credit payment. We are only trying to ensure
that we fulfill our contracted amount. Only after credit ratio negotiations for the bulk of wetland
areas located at the bottom of the project were concluded did we fully realize we would be slightly
short (0.08 credits) of our contracted amount" ...."we are only seeking 0.08 acres of paid credit
from 0.27 acres of restored wetlands." - per follow-up email from Mr. King to Ms. Hughes on
8/6/2015 summarizing the noted phone conversation.
Upon the close of this conversation, Ms. Hughes understood the basis for the inclusion and found the
approach acceptable. A copy of the email will be included in Appendix D of the Mitigation Plan.
2. Section 8.1: Regarding the proposed BMPs, Table 8.1: Routine Maintenance Components states that
the stormwater management devices will be monitored and maintained per the protocols and
procedures defined by the NCDWR Stormwater BMP Manual (BMP manual). Please list the routine
maintenance activities as specified in the BMP manual or reference the page number/table from the
manual that lists the specific maintenance activities that will be performed. The frequency of
maintenance inspections should be consistent with the BMP manual.
Response: Routine maintenance components outlined in Table 8.1 for the Stormwater Management
Devices have been revised as follows: 'Stormwater Management Devices will be monitored semi-
annually and maintenance measures will be implemented as needed during the monitoring period.
Measures may include replacing dead vegetative material and removing excess sedimentation from
the forebay of the constructed wetland and its permanent pool, as well as the plunge pools along
Reach T4 during the monitoring period. Should the outlet of the constructed wetland become unstable
during the monitoring period, corrective measures will be implemented to rectify the instability issues
during the monitoring period."
3. Section 9.2: The NCDMS Monitoring Requirements and Performance Standards for Stream and/or
Wetland Mitigation dated November 7, 2011 stipulates that planted vegetation must average 10
feet in height in each plot at year 7. Please include this requirement in the vegetation performance
standards.
Response: We recognize that average height recommendations are listed as performance standards
for success criteria in Year 5 and 7 in guidelines circulated by the IRT in 2011. It is also true that DMS
released an update to its monitoring guidelines with the understanding that the 2011 IRT document
was an official update to the 2003 document. It was later learned that that was not the case or the
intent of the IRT and therefore an official revision to the 2003 stream mitigation guidelines has not
been produced. Approximate heights by species will be recorded as part an overall assessment of vigor
to determine whether the buffer appears to be on an acceptable trajectory, butgiven uncertainties in
precipitation, variations in species growth rates and soil heterogeneity the assignment of an arbitrary
blanket average is inadvisable.
4. Section 9.3.2 Wetland Hydrology: The mitigation plan states that performance standards for
wetland hydrology will follow a range from 6-12%, depending on the specific wetland location and
the mitigation activity proposed. Wetland areas receiving credit for restoring or enhancing wetland
hydrology should demonstrate saturation within 12 inches of the soil surface for a minimum 8.5%
of the growing season for Guilford County.
Response: Please see our response to Comment No. 2 (above) under the heading "Ginny Baker/Sue
Homewood, NCDWR, 1 June 2015".
5. Section 9.0: Please provide performance standards for the constructed wetland (116) and the
regenerative stormwater control device (T4). In addition, please provide appropriate monitoring
protocols that demonstrate compliance with the proposed performance standards.
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Office: 828.350.1408 1 Fax: [phone]
Response: As discussed in Comment No. 3 (above) under the heading '"Todd Bowers, USEPA, 16 July
2015'; the credit ratios for both BMPs were established during a site visit on June 4, 2014. During that
site visit, IRT members and Baker staff agreed that the implementation of the BMPs and associated
enhancement measures would yield a 1.5:1 credit ratio for the valley length of the entire BMP for
which performance criteria was not stipulated. Currently there are no performance criteria for BMPs
and since none were specified by the IRT during this meeting or during following site visits or
subsequent conversation, no performance criteria were developed. See the attached meeting minutes
for reference. Please note that the meeting minutes will also be included in the Appendix of the
Mitigation Plan. Please note that the BMP implementation along Reach T4 was incorrectly labeled as
a regenerative stormwater measure. It should have been listed as a rock lined step pool channel
stormwater control measure. Monitoring text for the stormwater BMPs have been updated in Section
9.4 to reflect this error and the protocols for monitoring have been revised as follows:
"This project includes the implementation of two stormwater BMPs. A constructed wetland, which will
function as a headwater wetland, will be installed along Reach R6, and a rock lined step -pool channel
stormwater control measure will be installed along Reach T4. Both BMPs will be visually monitored
semi-annually for vegetative survival, outlet stability, and storage capacity using photo
documentation during the 7 -Year monitoring period. A vegetation plot will also be established along
the planted portion of Reach R6 and will be included as part of the vegetation monitoring outlined in
Section 9.2. Maintenance measures will be implemented during the monitoring period to replace dead
vegetative material and to remove excess sedimentation, as needed, from the forebay of the
constructed wetland and its permanent pool, as well as the plunge pools along Reach T4. Should the
outlet of the constructed wetland become unstable during the 7 -Year monitoring period, corrective
measures will be implemented to rectify the instability issues."
6. Section 10.0: Post -construction profile data should be provided for the entire length of all
Restoration/ Enhancement I stream components.
Response: Table 10.1 has been revised to correctly reflect the post -construction monitoring
requirements for the channel profile parameter as follows: "For Restoration or Enhancement I
activities, a baseline survey (Year 0) will be conducted for the entire length of the channel. Survey will
only be conducted in subsequent monitoring years if the channel is experiencing vertical instability, in
which case survey will be collected within the area of concern."
7. Section 10.0: The Table 1: Monitoring Requirements chart should include a section for wetland
hydrology monitoring requirements.
Response: Table 10.1 has been updated to include wetland hydrology monitoring requirements as
follows:
Required
Parameter
Quantity
Frequency
Notes
Appropriate to
encompass the array of
Continuously
Ground water gage data will be
X
Ground Water
conditions across the
throughout the
collected in each Wetland Type
Hydrology
different wetland
growing season of
(1 - 5) to document wetland
types.
Monitoring Years 1 - 7
hydrology within the area.
8. Section 11.0: The Long -Term Management Plan should include a list of long-term management
activities required for site sustainability, the party responsible for conducting these activities, and
details regarding the funding of these activities. According to the BMP manual, BMPs require
routine inspections on at least a quarterly basis and after each large storm event. Please provide
additional information regarding the annual costs associated with BMP maintenance and repair;
funding for maintenance and repair activities, and the party responsible for these activities. If the
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conservation easement holder will assume responsibility for these annual maintenance activities
and any associated emergency maintenance and repair costs, please provide written confirmation
from the conservation easement holder. For those areas where no longterm management activities
are anticipated (stream and wetland restoration/enhancement), please include a statement to this
effect in the mitigation plan along with an explanation.
Response: Section 11.0 has been revised to include language from Mitigation Plan Template - version
2.2 - adopted 8 June 2012, which describes the nature and transfer of the conservation easement to
the NCDENR Stewardship Program after close out.
9. Temporary and permanent impacts to existing wetlands and streams must be accounted for in the
PCN and the loss or conversion of those waters must be replaced on-site. Please include a map
depicting the location of all impacts with the PCN.
Response: A temporary and permanent impacts map will be included with the PCN as part of the
permit request package for the project's 404/401 submittal.
Please do not hesitate to contact me should you have any questions regarding our response submittal.
Sincerely,
Christopher Tomsic, P.E.
Project Manager
Enclosures
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I N T E R N A T 1 0 N A L
January 29, 2016
Jeff Schaffer
NCDENR, Division of Mitigation Services
1652 Mail Service Center
Raleigh, NC 27699-1652
Subject: Response to NCIRT Review and USACE Approval Letter dated November 3, 2015
Browns Summit Creek Mitigation Project, Guilford County
Cape Fear Cataloging Unit 03030002
USACE AID SAW 2014-01642, CMS Project #96313
Dear Mr. Schaffer:
Please find enclosed our responses to the Inter -Agency Team (IRT) review and USACE approval letter
dated November 3, 2015 in reference to the Browns Summit Creek Mitigation Project. We have revised
the Final Mitigation Plan document in response to this review. Comments receiving "response
acceptable" are not included below; however, comment numbers match previous correspondence for
easier cross reference.
Ginnv Baker, NCDWR, 15 October, 2015:
3. Response acceptable. Correction - NCDWR will require 30 days of consecutive baseflow for monitoring
wells installed in T1 and T3 during a normal rainfall year (not a during normal growing season).
Response., Flow documentation is covered under 9.1.2 (page 9-2), including how a normal rainfall year will
be evaluated and the 30 day consecutive baseflow requirement.
4. NCDWR found the detailed description and calculations of the proposed BMPs for R6 and T4 to provide
the needed information required to better understand the design and function of the BMPs.
Response: Previous response appears acceptable, thus no further changes required.
5. The BMPs are proposed to generate a 1.5:1 credit ratio as was agreed to in the field. Since these BMPs
are credit generating assets a success standard is required, as it is for all other credit generating assets at
mitigations sites, even if this issue was not specifically discussed during field visits. Please consider that it
is not possible to review every aspect of a proposed mitigation plan during the field visit which is why the
request for more information in regards to a success standard was made during the draft plan review
process. NCDWR recommends the following additions to the draft mitigation plan.
a. The step -pool channels (116 outlet and T4) will be considered successful if stability has been attained as
agreed upon by the IRT at closeout.
b. Constructed Wetland (116) — Vegetation should be monitored yearly to determine the percent coverage
of the constructed wetland. A success standard of 70 percent of native vegetation as defined in the
NCDWR BMP manual (page 9-21 of the NCDWR BMP manual) will be required. This should be a visual
Michael Baker Engineering, Inc.
I? Irma ALM rsALLYPORT MBAKERINTL.COM 8000 Regency Parkway, Suite 600, Cary NC 27518
Office: 919.463.5488 1 Fax: [phone]

Innovation Done Right... We Make a Difference
estimate of overall coverage of the pool area, native volunteers can be included. The plot in the buffer
area of the BMP with planted stems should have the same standard success criteria as other veg plots.
All yearly maintenance and repairs, photopoints, replantings, and invasive treatments will be
documented in the monitoring reports. Sediment buildup should be minimal and not require repeated
maintenance at closeout as agreed upon by the IRT for the constructed wetland to be considered
successful.
c. NCDWR BMP field inspection - One field visit by NCDWR should be conducted between years 2-5 to
inspect the BMPs. It will be up to Baker to schedule this. Annual monitoring may be requested by Baker
instead of bi-annual monitoring for the BMPs after five years until closeout if the stormwater control
measure structures are stable and have not required maintenance in the past year.
d. In Section 9.0 Performance Standards: Success criteria for the BMPs should be added since they are not
included in any of the referenced documents.
e. In Table 10.1 Monitoring Requirements: Change the frequency of stormwater BMP inspections to semi-
annually to be consistent with the earlier text.
Response: Stormwater Management Monitoring is addressed in 9.4 (page 9-6) including visual
monitoring for vegetative survival, outlet stability and storage capacity using photo documentation
during the 7 -year monitoring period, vegetation plot establishment along R6, and maintenance
measures. Success criteria as described above has been added to this section. Table 10.1 has been
revised to reflect semi-annual monitoring.
Andrea Hu¢hes, USACE, 19 October, 2015:
3. According to the Technical Proposal, the Browns Summit Creek Mitigation Project is subject to applicable
guidance associated with RFP 16-005568 (Monitoring Requirements and Performance Standards for
Stream and/or Wetland Mitigation dated November 7, 2011). The performance standards in the guidance
document provide height requirements for planted vegetation.
Response: Vegetative Monitoring is addressed in 9.2 (page 9-4) including species density and height
methodologies. Additional height monitoring methodologies were added to this section as discussed
between Jake Byers and Andrea Hughes on November 5, 2015. Certain native species, which are
appropriate to plant on-site to provide a diverse vegetation community, do not typically grow to these
heights in 7 years and will be excluded from the height performance standard. These excluded species
composed primarily of understory species are Persimmon, American Hornbeam, American Holly,
Witchhozel, Strawberry Bush, Black Gum, and Winterberry.
S. See NCDWR #5 response above. The Corps concurs with NCDWR comments regarding monitoring
protocols and performance standards for the proposed BMPs.
Response: Please see response above.
7. Recommend groundwater hydrology data collection on a 12 month basis as opposed to monitoring only
during the growing season.
Response: Section 9.3.2 Hydrology states, "automated groundwater -monitoring stations will be
installed across the restored site and monitored year-round."

Innovation Done Right... We Make a Difference
8. We do not anticipate a need for long-term management of the proposed BMP structures provided they
remain stable and functioning throughout the 7 -year monitoring period. In the event the BMPs fail to
meet the standards noted above (NCDWR #5 response), mitigation credits may be adjusted accordingly.
Response: Please see response above.
If you have any questions concerning the Final Mitigation Plan, please contact me at 919-805-1750 or via
email at Katie.McKeithanPmbakerintl.com.
Sincerely,
'; D
Kathleen McKeithan, PE, CPESC, CPSWQ CFM
Michael Baker Engineering, Inc.

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
REPLY TO
ATTENTION OF: November 3, 2015
Regulatory Division
Re: NCIRT Review and USACE Approval of the Browns Summit Creek revised Draft Mitigation Plan;
SAW -2014-01642; DMS Project #96313
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 review period for the Browns Summit Creek Mitigation Project. These comments are
attached for your review.
Based on our review of these comments, including the provider's response, and comments
generated during the revised plan review, we have determined that no major concerns have been
identified with the revised Draft Mitigation Plan dated September 2015, which is considered approved
with this correspondence. However, several minor issues were identified, as described in the attached
revised plan 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,Digitaly signed by
`n'
HUGHES.ANDREA.VV HUGHIESAND EAWADE.1258339165
DN: =US, o=U.S. Government, ou=DoD, ou=PKI,
ADE.1258339165 Date: 2015.11.309:2235_05100'ADE.1258339165
Andrea Hughes
Mitigation Project Manager
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
Jeff Schaffer, NCDMS

REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
CESAW-RG/Hughes October 19, 2015
MEMORANDUM FOR RECORD
SUBJECT: Brown's Summit Creek - NCIRT Comments/Revised Mitigation Plan Review
PURPOSE: The comments listed below were received in response to the revised Mitigation Plan
dated September 2015.
NCDMS Project Name: Browns Summit Creek Mitigation Project, Guilford County, NC
USACE AID#: SAW -2014-01642
NCDMS #: 96313
Initial Comment Deadline: 15 July 2015
Revised Mitigation Plan Posted to Portal: 21 September 2015
Ginny Baker, NCDWR, 15 October, 2015:
1. Response acceptable.
2. Response acceptable.
3. Response acceptable. Correction - NCDWR will require 30 days of consecutive baseflow
for monitoring wells installed in T1 and T3 during a normal rainfall year (not a during
normal growing season).
4. NCDWR found the detailed description and calculations of the proposed BMPs for R6
and T4 to provide the needed information required to better understand the design and
function of the BMPs.
5. The BMPs are proposed to generate a 1.5:1 credit ratio as was agreed to in the field.
Since these BMPs are credit generating assets a success standard is required, as it is for
all other credit generating assets at mitigations sites, even if this issue was not
specifically discussed during field visits. Please consider that it is not possible to review
every aspect of a proposed mitigation plan during the field visit which is why the
request for more information in regards to a success standard was made during the

draft plan review process. NCDWR recommends the following additions to the draft
mitigation plan.
a. The step -pool channels (R6 outlet and T4) will be considered successful if stability
has been attained as agreed upon by the IRT at closeout.
b. Constructed Wetland (136) — Vegetation should be monitored yearly to determine
the percent coverage of the constructed wetland. A success standard of 70 percent
of native vegetation as defined in the NCDWR BMP manual (page 9-21 of the
NCDWR BMP manual) will be required. This should be a visual estimate of overall
coverage of the pool area, native volunteers can be included. The plot in the buffer
area of the BMP with planted stems should have the same standard success criteria
as other veg plots. All yearly maintenance and repairs, photopoints, replantings, and
invasive treatments will be documented in the monitoring reports. Sediment build-
up should be minimal and not require repeated maintenance at closeout as agreed
upon by the IRT for the constructed wetland to be considered successful.
c. NCDWR BMP field inspection - One field visit by NCDWR should be conducted
between years 2-5 to inspect the BMPs. It will be up to Baker to schedule this.
Annual monitoring may be requested by Baker instead of bi-annual monitoring for
the BMPs after five years until closeout if the stormwater control measure
structures are stable and have not required maintenance in the past year.
d. In Section 9.0 Performance Standards: Success criteria for the BMPs should be
added since they are not included in any of the referenced documents.
e. In Table 10.1 Monitoring Requirements: Change the frequency of stormwater BMP
inspections to semi-annually to be consistent with the earlier text.
Andrea Hughes, USACE, 19 October, 2015:
1. Response acceptable.
2. Response acceptable.
3. According to the Technical Proposal, the Browns Summit Creek Mitigation Project is
subject to applicable guidance associated with RFP 16-005568 (Monitoring
Requirements and Performance Standards for Stream and/or Wetland Mitigation dated
November 7, 2011). The performance standards in the guidance document provide
height requirements for planted vegetation.
4. Response acceptable.
5. See NCDWR #5 response above. The Corps concurs with NCDWR comments regarding
monitoring protocols and performance standards for the proposed BMPs.
6. Response acceptable.

7. Recommend groundwater hydrology data collection on a 12 month basis as opposed to
monitoring only during the growing season.
8. We do not anticipate a need for long-term management of the proposed BMP
structures provided they remain stable and functioning throughout the 7 -year
monitoring period. In the event the BMPs fail to meet the standards noted above
(NCDWR #5 response), mitigation credits may be adjusted accordingly.
9. Response acceptable.
HUGHES.ANDREA.
WADE.1258339165
Digitally signed by
HUGH ES.ANDREA.WADE.1258339165
DN: c=US, o=U.S. Government, ou=DoD,
ou=PKI, ou=USA,
cn=HUGHES.ANDREA.WADE.1258339165
Date: 2015.10.19 12:03:49 -04'00'
Andrea Hughes
Mitigation Project Manager
Regulatory Division

REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
CESAW-RG/Hughes July 29, 2015
MEMORANDUM FOR RECORD
SUBJECT: Browns Summit Creek Mitigation Project - 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: Browns Summit Creek Mitigation Project, Guilford County, NC
USACE AID#: SAW -2014-01642
NCDMS #: 96313
30 -Day Comment Deadline: 16 July 2015
Todd Bowers, USEPA, July 14, 2015:
1. Table 1; Page 2-1: R1 Drainage area is listed as 438 acres. This is not consistent with
other values such as Table 4.1 (448 acres)
2. Page 1-2: Recommend adding "restore stream and floodplain connectivity" in list of
bulleted primary goals especially since wetland hydrology performances are depending
on it.
3. Page 1-2: Stated objectives should be measurable (as well as specific, attainable,
reasonable and trackable). Improvement, as well as degradation, in water quality is
measurable. If this is the case then Baker should be measuring water quality for at least
some parameter to demonstrate that this objective has been achieved. Performance
standards relating to water quality, especially if tied to the BMPs (136 and T4), should be
developed accordingly.
4. Page 2-2; last paragraph: R2 and R1 are not second -order streams, especially if R3 and
R4 are considered first -order. The inclusion of T-2 (zero order) does not change the
stream order of the main stem.
5. 2.2.1; Page 2-3 first paragraph: Land use percentages of the "watershed" are not
consistent with those listed on Page 1-1 and Table 4.1. The "watershed" in question
changes from an 83 -square mile HUC to the project watershed with differing

percentages in one comparison and same percentages in another comparison.
Recommend making this clearer in the document.
6. 4.0 Baseline information: Some water quality parameter(s) should be included in order
to demonstrate that 1) the water quality is impaired and needs improvement and 2)
that improvements to water quality, a stated objective, has been achieved. Fecal
coliform or E. coli might be a suitable parameter in this case since we are dealing with
cattle exclusion.
7. Table 4.1: Project Drainage Area does not match R1 Drainage Area and 2.2.1
8. Table 4.1: Missing 7 percent of land use classification?
9. Table 5.1: BMP Elements. Both Elements state that improvement in water quality is part
of the Purpose/Function. How do we know that this will be achieved successfully?
10. 7.1.3, Page 7-2: Live stake density appears erroneous. "40 stakes per 1,000 square feet"
should read "400 stakes per 1,000 linear feet" This will achieve the spacing required.
11. Page 7-5, last paragraph: "Reducing streambank sediment loading and removing cattle
will provide ecological uplift by improving water quality..." Once again a water quality
objective is stated with no baseline data or plans to collect data to support this
statement. Recommend collecting baseline water quality data to provide evidence that
ecological lift has (or has not) been achieved. The statement in the following paragraph
does provide for removing the inputs via cattle exclusion but that does not present
measurable data that water quality itself is better and if so by how much.
12. 9.0, Page 9-1 and 9.2, Page 9-3: No performance standard is given for tree heights at 5
years (7') and 7 years (10'). Recommend adding this performance standard unless Baker
can justify why this cannot be achieved.
13. 9.2, Page 9-3: First paragraph mentions R7. Remove R7
14. 9.2, Page 9-3: Vegetation monitoring addresses riparian buffer monitoring and plot
density. It is unclear how wetland vegetation monitoring will be conducted. Recommend
at least one plot per wetland type/area in addition to monitoring riparian buffer
vegetation.
15. 17.1.1.1, Page 17-1: R3 and R2 drainage areas do not match Table 1 in Site Selection
16. Tables 17-7 and 17-8: Design Estimates and Proposed Bankfull Velocities for R1, R2, R3
and R4 do not match.
17. 17.5.1, Page 17-46: Are three automated groundwater wells enough coverage for
monitoring five wetland types? It appears that six stations are going to be installed per
Figure 9.1 on page 9-6
18. 17.7.2, Page 17-51: Live stake density appears erroneous. "40 stakes per 1,000 square
feet" should read "400 stakes per 1,000 linear feet" This will achieve the spacing
required.
19. Tables 17.10 -12: Planting plan appears excellent for both riparian buffer and wetlands.
Ginny Baker, DWR, 1 June 2015:
1. Monitoring wells should be installed along intermittent reaches that are proposed for
priority 1 restoration to ensure a minimum of 30 consecutive days of base flow is
maintained during a normal growing season. One well should be installed in the upper

part of the reach for R4 (in the intermittent section if this overlaps with P1 restoration),
reach T1 and reach T3.
2. The hydrology success criteria proposed for wetlands located in the lower end of the
project along reaches 1 and 2 are inconsistent. The 12% success standard for a normal
precipitation year proposed for the wetland type 2 (degraded) and wetland type 3
(partially functioning) seems appropriate for a riverine/riparian associated wetland.. The
6% hydrology success standard proposed just upstream for wetland type 4 (filled),
which is the same type of wetland, does not seem appropriate, especially as a 1:1 credit
ratio is proposed. In addition, a 9% hydrology standard (which NC DWR finds acceptable
for a headwater wetland associated with a first order stream) is proposed further
upstream closer to the headwaters along Reach 4 in wetland type 5 (filled). NC DWR
understands Baker is concerned that only removing fill and using the E1 approach rather
than P1 restoration which would raise the channel and increase flooding may not result
in the same level of hydrological uplift as along Reach 1 where P1 restoration is
proposed. Perhaps the 1:1 ratio should be adjusted if only a partial hydrological uplift
for wetland type 3 is achieved.
3. Please add a vegetation plot to Wetland type 5, which is already established with
mature successional species.
4. NC DWR would like more design specifications to be provided in the final mitigation plan
for the two proposed BMPs. For the Constructed Wetlands, reference has been made
to the BMP manual. The plans should clearly identify all key elements of the design with
regards to requirements in either the BMP manual or the new MDC for Constructed
Wetlands with explanations for any deviations from the typical design requirements.
The BMP Supplement Form may provide guidance for what details to provide in future
design documents. Regenerative Stormwater Conveyances (RSCS) as proposed for T4 on
Table 7.1, page 7-4, are not in the NC BMP Manual so it is unclear what design standard
will be used for the RSC NC DWR would recommend that RSC designs adhere to the
Anne Arundel County, MD or the West Virginia design standards for RSCs, available at
http://www.aacounty.org/DPW/Watershed/StepPoolStormConveyance.cfm and/or
http://www.dep.wv.gov/WWE/Programs/stormwater/MS4/Documents/Specification_4.
2.7_Regenerative_Stormwater_Conveyance_WV-SW-Manual-11-2012.pdf.
5. The BMP success standards and objectives for R6 and T4 need further description in
Section 9.4. Please describe what performance standards will be used to document that
the BMPs are providing functional uplift to the mitigation project.
6. How will the two BMPs be maintained in perpetuity after the site is closed out?
Andrea Hughes, USACE, 26 July 2015:
1. Section 2.2: The mitigation plan indicates that another category of wetlands has been
added to the plan during mitigation plan development. During mitigation plan
development, the Corps made numerous visits to the Brown's Summit site and held
several discussions regarding changes to the mitigation plan associated with proposed
mitigation activities and determination of mitigation credits. The intent of on-site
meetings and discussions is to resolve concerns or issues associated with the mitigation
proposal prior to submitting the draft mitigation plan. At no time during the course of

these meetings was the proposal to add another category of wetlands to the mitigation
plan in order to generate additional credits discussed with the Corps and/or the IRT.
Please remove from the mitigation plan those areas located adjacent to Reach 4 and
identified as "5 -Hydrologic Reestablishment, 1:1 credit ratio" on Figure 9.1. No
mitigation credits will be generated for these areas.
2. Section 8.1: Regarding the proposed BMPs, Table 8.1: Routine Maintenance
Components states that the stormwater management devices will be monitored and
maintained per the protocols and procedures defined by the NCDWR Stormwater BMP
Manual (BMP manual). Please list the routine maintenance activities as specified in the
BMP manual or reference the page number/table from the manual that lists the specific
maintenance activities that will be performed. The frequency of maintenance
inspections should be consistent with the BMP manual.
3. Section 9.2: The NCDMS Monitoring Requirements and Performance Standards for
Stream and/or Wetland Mitigation dated November 7, 2011 stipulates that planted
vegetation must average 10 feet in height in each plot at year 7. Please include this
requirement in the vegetation performance standards.
4. Section 9.3.2 Wetland Hydrology: The mitigation plan states that performance
standards for wetland hydrology will follow a range from 6-12%, depending on the
specific wetland location and the mitigation activity proposed. Wetland areas receiving
credit for restoring or enhancing wetland hydrology should demonstrate saturation
within 12 inches of the soil surface for a minimum 8.5% of the growing season for
Guilford County.
5. Section 9.0: Please provide performance standards for the constructed wetland (R6) and
the regenerative stormwater control device (T4). In addition, please provide
appropriate monitoring protocols that demonstrate compliance with the proposed
performance standards.
6. Section 10.0: Post -construction profile data should be provided for the entire length of
all Restoration/ Enhancement I stream components.
7. Section 10.0: The Table 1: Monitoring Requirements chart should include a section for
wetland hydrology monitoring requirements.
8. Section 11.0: The Long -Term Management Plan should include a list of long-term
management activities required for site sustainability, the party responsible for
conducting these activities, and details regarding the funding of these activities.
According to the BMP manual, BMPs require routine inspections on at least a quarterly
basis and after each large storm event. Please provide additional information regarding
the annual costs associated with BMP maintenance and repair; funding for maintenance
and repair activities, and the party responsible for these activities. If the conservation
easement holder will assume responsibility for these annual maintenance activities and
any associated emergency maintenance and repair costs, please provide written
confirmation from the conservation easement holder. For those areas where no long-
term management activities are anticipated (stream and wetland
restoration/enhancement), please include a statement to this effect in the mitigation
plan along with an explanation.

9. Temporary and permanent impacts to existing wetlands and streams must be accounted
for in the PCN and the loss or conversion of those waters must be replaced on-site.
Please include a map depicting the location of all impacts with the PCN.
H U G H ES.A N D R EA.Digita ly signed by
HUGHES.AND EA.WADE.1258339165
DN: r -US, .—U.S. Government, ou=DOD, Ou-PKI,
WADE.1258339165 Date: 2015.07 911164233D0400'ADE 1258339165
Andrea Hughes
Mitigation Project Manager
Regulatory Division