20090565 Ver 1_SAW-2009-00832_DAHLQUIST_20170324

Regulatory Division
VINISIMMIRRVAW1111011113N
Weyerhaeuser NR Company
Attn: Mr. Scott Dahlquist
33663 Weyerhaeuser Way South
Federal Way, Washington 98003
Dear Mr. Dahlquist:
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
March 24, 2017
This letter serves to confirm our evaluation of the February 2017 Year 3 monitoring report
for the Bachelors Delight Stream Mitigation Bank located on the east side of Gum Branch Road
(SR 1308), within Bachelors Delight Swamp watershed, north of Jacksonville, Onslow County,
North Carolina. Please reference the July 9, 2012 executed Mitigation Banking Instrument
(MBI) and the Amended MBI executed on January 21, 2015; and our March 14, 2017 onsite
inspection with Mr. Wes Fryar of Land Management Group (LMG) Inc. Also present during the
inspection was Ms. Maria Dunn and Mr. Travis Wilson of North Carolina Wildlife Resource
Commission and Mr. Eric Reusch, Mr. Tyler Crumbley, and Ms. Rachel Capito of our office.
Reference should also be made of our May 5, 2016 response letter to the second year monitoring
report and release of credits.
In the May 5, 2016 letter, our office disclosed concerns regarding the abundant presence of
loblolly pines (Pinus taeda) within portions of the bank site and the signs of degradation along
the grade control structures at the outfall of stream segment HM. As stated in the monitoring
report and in conversations with LMG staff, you have implemented, or are in the process of
implementing, remedial measures to help correct these issues. To date, manual clearing of the
volunteer pines took place on January 29, 2017 along the entire segment of HE. Your current
plans are to herbicide much of the wet pine flat and stream head pocosin areas of segment BD -
4A and BD5-A sometime this spring. Treatment, and/or manual removal, of pines and sweet
gum (Liquidambar styracii lua) must also be implemented along the lower part of segment HM as
discussed during our onsite meeting. For the HM grade control structures, corrective measures
have been delayed due to the heavy rains throughout 2016 and plans are to initiate the work
sometime this spring.
For the hydrology success criteria, there is some confusion for the percent of growing
season that applies to the BD—GW monitoring wells. Table 7A have Wells 4, 5, 6, and 7 being

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subject to a hydrology standard that requires inundation or saturation in the upper 12 inches of
the surface for 10% of the growing season (or 30 days), whereas Wells 1, 2, 3, and 8 have to
meet a 6% (or 18 days) standard as depicted in Table 8. In comparing this with Figure 9 in the
October 2010 Mitigation Plan, all of these BD_GW wells are located in approximately 76 acres
of designated wet pine flats, which according to the established performance standards for this
non -riparian wetland type have a 6% standard. Only the non -riparian pocosin has a 10%
requirement and it appears none of the BD_GW are located in this wetland community type. It
was pointed out by LMG that the planting regime may have mistakenly dictated the percentage of
the growing season for the wells instead of using the established hydrology regime described in
the 2010 mitigation plan. With that said, our office will be applying the 6% performance
standard for all these wells as it was approved in the mitigation plan.
The 2017 monitoring report shows that all but one well (BD_GW4) has met the established
success criteria for hydrology and this well malfunctioned thin the crucial month of March and
again thm September and early October. In review of the report, our office continues to have
concerns with several of the BD wells. This concern has been expressed in our review of both
the Bankes Year 1 and 2 monitoring reports. It is shown in the Summary of Precipitation section
of the Year 3 report that the Palmer Hydrologic Drought Index maps of 2016 for Onslow County
considered the month of January very -moist, February extremely -moist, March and April
moderately -moist, October extremely -moist, and November very moist. Additionally in the
report, data from the NC Drought Status Monitoring Program, which compares existing data to
long-term (1965-2013) conditions, considered January normal, February above -normal, March
and April below normal, and October above -normal. In review of the BD_GW wells, we concur
that Wells 1, 2, 3, and 7 have conclusively met the performance standards. Even though Well 4
malfunctioned late February thru April, its readings follow similar patterns of both Wells 2 and 3.
However, Wells 5, 6, and 8 do not conclusively meet the standards. The only period during the
growing season when water levels were shown for any length of time to be within the upper 12
inches fell in February, and this was during the above normal precipitation conditions. This
stretch of February received over 8 inches of rain, with approximately 6.5 inches occurring
within the first week. The distance between Well 8 and the major outfall canal located along the
southern boundary is not known at this time. However, it appears that the canal may have a
wider zone of drainage influence than originally expected, which may have resulted in lower
water levels for this well and the surrounding area. If low readings persist for Well 8 during the
next monitoring cycle, a credit adjustment along this canal is likely.
Another area of interest is the segment of HE -1, particularly the upper reach of the stream.
Concerns include the vigor of the planted riparian zone along the stretch west of the intersection
with the main access road. It is aclamowledged that the planted stems in plots HEW 1-3 are
meeting the survival performance; however, the stems growth rate are slower in comparison with
other planted riparian zones in the Bank. Compaction and soil types appear to be the major
contributing factors for the lower rate. As mentioned above, manual removal of volunteer

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species has been conducted to reduce competition and to assist in the continual survival of the
planted stems. Observations confirm that wetland herbaceous cover are persistent throughout the
targeted riparian area. In addition to the planted trees, there are concerns with the results of Well
HE—RIP 1 only meeting the success criteria (12.5% of the growing season) during February's
above normal rainfall conditions. This well also had water levels below 12 inches during the
month of January. Even though this is outside of the growing season, it is concerning that levels
dipped that low, especially when comparing to reference wells (HE REFI). This well
consistently displays sharp peaks throughout the year, not retaining stormwater for longer periods
as would be expected.
With the listed concerns above, our office has made the determination to withhold 5% of
the potential riparian and non -riparian wetland credits. The remaining 5% wetland credits and
the 10% stream credits, as depicted in Task 4.0 of Tables 4A and 4B of the MBI are being
released for mitigation use. Using the As -Built survey adjusted totals (as disclosed in our
December 17, 2013 letter), the mitigation credit release is 5% of riparian, non-riverine wetland
credits (or 4.18 credits), 5% of non -riparian wetland credits (or 4.35 credits), and 10% of stream
credits (or 2,653.5 linear feet of credits). The remaining 5% of riparian wetland credits (or 4.18
credits) and 5% of non -riparian credits (or 4.35 credits) will be withheld until further evaluation.
To date, this brings the total release to 93.85 wetland credits (consisting of 46 riparian, non-
riverine credits and 47.85 non -riparian credits) and 15,914 linear feet of stream credits.
Please notify our office on the status of the remediation work regarding herbicide treatment
and grade control corrective measures. Also, please be reminded of your obligations pursuant to
the July 9, 2012 MBI and January 21, 2015 Amended MBI; and to continue maintenance
inspections of the Bank in order to evaluate the condition and stability of all streams, ford
crossings, and plug structures in perpetuity. Should you have any questions, please do not
hesitate to contact me at the Wilmington Regulatory Field Office, telephone [phone].
SincerclN
Mickey S gg, Pro?j ect Manager
Wilmington Regulatory Field Office
Copies Furnished:
Land Management Group, Inc.
Attn: Mr. Christian Preziosi and Mr. Wes Fryar
Land Management Group, Inc.
3805 Wrightsville Avenue, Suite 15
Wilmington, North Carolina 28403

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Mr. David Ashcraft
North Carolina State
Natural Resources Foundation, Inc.
Campus Box 8010
Room 3060, Biltmore Hall
Raleigh, North Carolina 27695
Mr. Glenn Catts
Hofmann Forest Liaison
College of Natural Resources
North Carolina State University
2023 Biltmore Hall
Post Office Box 8002
Raleigh, North Carolina 27695
Weyerhaeuser NR Company
Attn: Mr. Doug Hughes
211 Armstrong Road
Columbia, Mississippi 39429
Weyerhaeuser NR Company
Attn: Mr. Taylor Downey
Post Office Box 12768
New Bern, North Carolina 28561
Mr. Todd Bowers
U.S. Environmental Protection Agency
Wetland Section- Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
Mr. Robb Mairs
Division of Water Resources
North Carolina Department of
Environmental Quality
127 Cardinal Drive Extension
Wilmington, North Carolina 28405

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Ms. Cyndi Karoly
NC Division of Water Resources
Program Development Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Mr. Mac Haupt
Division of Water Resources
North Carolina Department of
Environmental Quality
Stream and Wetland Mitigation Coordinator
401 & Buffer Permitting Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Ms. Maria Dunn
North Carolina Wildlife Resource Commission
943 Washington Square Mall
Washington, North Carolina 27889
Ms. Debbie Wilson, Manager
Division of Coastal Management
North Carolina Department of
Environmental Quality
127 Cardinal Drive Extension
Wilmington, North Carolina 28405
Mr. Roy Brownlow
Morehead City Regional Office
NC Division of Coastal Management
400 Commerce Avenue
Morehead City, North Carolina 28557-3421
Ms. Kathy Matthews
U.S. Fish and Wildlife Service
Post Office Box 33726
Raleigh North Carolina 27636-3726

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Mr. Ken Riley
National Marine Fisheries Service
Pivers Island
Beaufort, North Carolina 28516
Mr. Ryan Davenport
Morehead City Regional Office
NC Division of Coastal Management
400 Commerce Avenue
Morehead City, North Carolina 28557-3421
BCF (e-mail):
CESAW-RG-L/Shaver
CESAW-RG-L/Dooley
CESAW-RG-L/Reusch
CESAW-RG-L/Sugg
CESAW-RG-WBiddlecome
CESAW-RG/Tugwell