20160233 Ver 1_Draft Mitigation Comments_20170119

NM
MOGENSEN MITIGATION, INC
December 6. 2016
Department of the Army
Wilmington District, Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 107
Wake Forest, NC 27587
Attn: Ms. Andrea Hughes, Project Manager
ZeIG[.�z33�
Wry l ....
DEC P d
DIVISI(:)rd '-;F
MITIGATION SERVICES
Re: Tar River Headwaters Wetland Restoration Site, Person County, NC - Response to FINAL
Comments on Draft Mitigation Plan (25 Oct 2016).
USACE AID#: SAW -2016-01101, Person County
NCDMS #: 97071
Dear Ms. Hughes:
Thank you for the most recent final comments. We have revised the Wetland Mitigation Plan per
all comments. The following letter explains how we have addressed each comment.
Comments from: Mac Haunt, NCDWR, November 22,2016:
1. Section 6.1 and 6.2- (Conceptual Approach and Wetland Design) - DWR agrees in principle with the
conceptual approach outlined in the draft Mitigation Plan. Given the jurisdictional call by the Raleigh
office of the Corps of Engineers, DWR agrees with the amount of wetland re-establishment and
rehabilitation proposed. The site has 3 relatively shallow ditches that drain surface water from the site.
The hydrology and soil characteristics on site are driven by episaturation rather than endosaturation found
in most high clayey soils in the Piedmont and upper Coastal Plain of NC.
The Mitigation Plan states the soils on the site are more Wedhakee like than the mapped Iredell. DWR
believes that will these soils do show hydric soil indicators and likely will continue or develop more
indicators; however, DWR believes the series is more like a wetter version of the Iredell given the heavy,
dense clays found on site. DWR recommends that gauge placement be representative of the site, from ar
elevation standpoint and that there are a couple of gauges in the rehabilitation areas.
MMI Response: The 11 existing groundwater gauges in the project area will be reinstalled after
construction to achieve optimal representation of all wetland rehabilitation and re-establishment areas
and landscape features across the project site. See the new Figure 8 for approximate groundwater
gauge and vegetation plot locations. 19 @ O M D
0 ��u;;nllu((
JAN 19 2017 JAN 1 9 >Utl
DENR • WATER RESOURCES
DENR-WATER RESOURCES TRANSPORTATION PERMITTING UNIT
TRANSPORTATION PERMITTING UNIT

2. Section 6.3-Hydroperiod Justification- DWR concurs with the target hydroperiod of 10% for the re-
establishment gauges. (No response required)
3. Section 7.2 -Performance Standards- DWR concurs with the Performance Standards listed in Table 4.
(No response required)
Comments from: Andrea Haeltes, USAGE, December 2 2016
Page 21, Table 3: Please confirm the acreage amounts in the table. Section 1.0 states the
site is approximately 9.98 acres. Table 3 indicates the site, including uplands, is 8.92 acres.
Page 7 indicates the 1.12 acre non -hydric area in the southeast corner of the project site does not
exhibit redoximorphic features and questions whether this area was hydric in the past. Table 3
indicates the upland area (in the southeast corner) is 1.27 acres and page 4 indicates the upland
area is approximately 1.4 acres. According to table 3, the wetland rehabilitation areas in the
center and southwest corner total 1.12 acres. MMI Response: The component acreages
throughout the plan text and tables have been revised for consistency. The as -built plan will
record acreages to the nearest thousandth.
2. Page 21, Section 7.1: Please provide a map of proposed monitoring locations for
vegetation plots. MMI Response: We have added Figure 8 after the Performance
Standards which shows the approximate (proposed) vegetation plot locations and the
approximate groundwater gauge locations.
3. Page 21, Section 7.1: The plan states that groundwater gauges (11) will be removed during
construction and replaced after restoration activities are completed. The table on page 22 states 8 gauges
will be monitored post construction. Since 3 gauges are outside the mitigation site boundaries, we
assume that 8 gauges will be replaced and monitored. Please correct this section for consistency. MMI
Response: The eleven (11) existing gauges will be removed during construction and all will be
reinstalled in the approximate locations shown on the new Figure 8.
4. Page 22, Table 4: How were the growing season dates determined? MMI Response: Language
has been added below Table 4 explaining the growing season duration rationale.
5. Page 22, Table 4: Vegetation performance standards are 320 stems/acre at year 3, 260 stems/acre at
year 5, and 210 stems/acre at Year 7. Please remove the reference to no bare or low-density areas greater
than 0.25 acre. MMI Response: The Table 4 Performance Standards have been updated using the
stem density requirements indicated, and the last sentence was removed.
6. Page 22, Section 8.2: The long term management plan must identify the longterm manager
for the site. Also, the plan states that funding will be supplied by the responsible party until
such time an endowment is established? Please provide additional details including
identification of the "responsible party", the amount of funding that will be provided, the party
receiving the funding, and the timing of the proposed transfer of funds. MMI Response: The
verbiage is template language developed by the Corps and DMS for Full -Delivery mitigation
projects and has not been revised.

7. Other: The mitigation plan does not address financial assurances. The plan must provide a
statement as to the party responsible for default and the mechanism to address the deficiency.
Response: This mitigation site is a full -delivery project with the State of North Carolina (NC
DMS contract DEQ #6746). Performance bonding financial assurance is provided to the State
of North Carolina as a contractual requirement.
I hope these responses clearly explain the revisions and changes we have made to the Final
Mitigation Plan.
Sincerely,
��
Richard K. Mogensen
President, MMI
CC: Gerald Pottern, MMI
Heather Smith, EE
Lindsay Crocker, NC DMS
Mac Haupt, NCDEQ-DWR
3