20161036 Ver 1_Corps of Engineer Correspondence_20161115

Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
Action ID. SAW -2016-02026
KCI Technologies, Inc.
Attn: Mr. Joe Pfeiffer
4601 Six Forks Road, Suite 220
Raleigh, North Carolina 27609
Dear Mr. Pfeiffer:
November 14, 2016
This letter confirms the initial evaluation of your prospectus detailing the establishment of a
wetland and stream mitigationbank, known as the Rough Horn Swamp Mitigation Bank (Bank),
within a 31.7 -acre tract located at the intersection of SR 1506 (Old Boardman Road) and SR 1508
(CCC Road), adjacent to a tributary of the Lumber River, near the community of Boardman,
Columbus County, North Carolina. Also, please reference our October 26, 2016 onsite meeting,
with attendees Mr. Chad Coburn and Mr. Mac Haupt of North Carolina Division of Water
Resources, Mr. Todd Tugwell and Ms. Kimberly Browning of the Corps Office, and Tim Morris and
Steve Stokes of KCI.
Pursuant to 33 CFR Part 332.8(d)(5) Compensatory Mitigation For Losses of Aquatic
Resources, our office is providing our initial evaluation as to the potential of your proposed Bank
for providing appropriate compensatory mitigation for activities authorized by Department of the
Army (DA) permits. Based on our review of the prospectus and other supporting documentation,
coordination with the Interagency Review Team (IRT), and the onsite inspection, it is our
position that the Bank site has potential for appropriately providing compensatory mitigation for
DA authorizations. Consequently, our office, along with the IRT, confirms proceeding with the
development of a draft mitigation banking instrument (MBI). Please be aware that a mitigation
plan must be approved prior to the release of any credits, and it is recommended that the plan be
submitted prior to the MBI.
With respect to the development of the proposed bank and the mitigation plan, several of
the following items were discussed during the October 26" onsite meeting: the banks functional
design and construction with the adjacent NC Division of Mitigation Service Rough Horn
Swamp tract; application of NC WAM for credit determination on existing wetland areas and
proposed type (riparian vs non -riparian); use of the October 24, 2016 Wilmington District Stream
and Wetland Compensatory Mitigation Update guidance; scheduled credit release percentages;
establishment of an appropriate Geographical Service Area; use of a reference area; and

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identifying appropriate success criteria, specifically hydrology percentage for the growing season
and identifying the growing season. Other components were also covered during the meeting and
all discussed topics should be incorporated in your bank planning and development of the
mitigation plan.
If you have any questions regarding the banking process or moving forward with the
establishment of your proposal, please do not hesitate to contact me at the Wilmington
Regulatory Field Office, telephone [phone].
Copies Furnished:
Mr. Tim Morris
KCI Technologies, Inc.
4601 Six Forks Road, Suite 220
Raleigh, North Carolina 27609
Mr. George Allen Sanderson
3001 Old Boardman Road
Evergreen, North Carolina 28438
Ms. Gabriele Garrison
North Carolina Wildlife Resources
Commission
Sandhills Depot
P.O. Box 149
Hoffman, North Carolina 28347
Mr. Todd Bowers
U.S. Environmental Protection Agency
Wetland Section- Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
Sincerely,
Mickey Sugg, Project Manager
Wilmington Regulatory Field Office
Mr. Chad Coburn
Division of Water Resources
North Carolina Department of
Environmental Quality
127 Cardinal Drive Extension
Wilmington, North Carolina 28405
Mr. Chad Turlington
North Carolina Division of Water Resources
225 Green Street (Systel Building)
Suite 714
Fayetteville, North Carolina 28301-5094
Mr. Mac Haupt
North Carolina Division of Water Resources
NCDEQ- 1650 Mail Service Center
Raleigh, North Carolina 27699-1650
Ms. Kathy Matthews
U.S. Fish and Wildlife Services
Post Office Box 33726
Raleigh, North Carolina 27636-3726

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Dr. Ken Riley
National Marine Fisheries, NOAA
Habitat Conservation Division
Pivers Island
Beaufort, North Carolina 28516
Mr. Travis Wilson
North Carolina Wildlife Resource
Commission
1718 Highway 56 West
Creedmor, North Carolina 27522