20170073 Ver 1_More Info Received - Email_20170418

Burdette, Jennifer a
From: Dana Lutheran <[e-mail]>
Sent: Tuesday, April 18, 2017 8:50 PM
To: 'Dooley, Brennan J CIV USARMY CESAD (US)'
Cc: Burdette, Jennifer a
Subject: RE: info request for Camp Davis
Attachments: Camp Davis Industrial Park Response to USACE RFAI 4-18-17.pdf
Hello, Brennan.
I hope you had a nice Easter. Please find attached the response to your RFAI. As always, if you have any
questions or concerns, please call me at 910.228.1841.
Thanks a bunch,
Dana
Dana A. Lutheran
Southern Environmental Group, Inc.
5315 South College Road, Suite E
Wilmington, NC 28412
Office 910.452.2711
Mobile [phone]
-----Original Message -----
From: Dooley, Brennan J CIV USARMY CESAD (US)
[mailto:[e-mail]]
Sent: Tuesday, April 11, 2017 7:24 AM
To: Dana Lutheran
Subject: info request for Camp Davis
Hi Dana,
I hope you are doing well. I just wanted to make sure you received the info
request that I sent last week and make myself available if you have any
questions.
Regards,
Brennan Dooley
Regulatory Specialist
U.S. Army Corps of Engineers
Wilmington District (SAW)
69 Darlington Avenue
1

Wilmington, NC 28403
[phone]
"The Wilmington District is committed to providing the highest level of
support to the public. To help us ensure we continue to do so, please
complete the Customer Satisfaction Survey located at:
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15outkern rInvironmental Group, Inc.
531 5 5outi, College Road, Suite r_ - Wilmington, Nortk Carolina 2841 2
910.452.271 1 - Fax: [phone] - office@-egi.
wwws gi-
18 April 2017
Electronic Mail [SEGi Project #06-092.011
Mr. Brennan Dooley
Wilmington Regulatory Field Office
US Army Corps of Engineers (USACE)
69 Darlington Avenue
Wilmington, NC 28403
Brenan.j .dooleykusace. army.mil
Re: Response to USACE Request for Additional Information (RFAI)
Camp Davis Industrial Park, Holly Ridge, Onslow County, North Carolina
USACE Action ID: SAW -2013-02417
Dear Brennan,
Southern Environmental Group, Inc. (SEGi) is in receipt of your 31 March 2017 request for additional
information. Within this correspondence, SEGi is submitting the following response:
1. Avoidance: Please provide additional information describing why this particular site was selected for your
project. The application references the presence, quantity and quality or function of wetlands and/or waters of
the US, the presence of any federally -listed threatened or endangered species or their critical habitat, state
listed species, or other natural or regionally important ecosystem resource factors that may be significantly
impacted. Please provide information about these factors for each alternative site considered, including the
preferred site. Discuss these factors in combination with the other factors listed in your application to describe
why each site was not found to be a practicable alternative, and/or the least environmentally damaging
alternative, and describeljustify the geographic scope used to determine potentially suitable sites.
Site Selection: The subject property was purchased by the Applicant as part of a larger tract of land (see
Attachment 1) in 2005, for the main purpose of expanding his Gulf Stream Steel and Supply business, which
does business with the US Marine Corps, in Jacksonville, NC. The primary reasons for purchasing this
property are that it was close to Jacksonville; it had access to US Highway 17; there were utilities, such as
water and sewer, available; the existing building was sized adequately (i.e. 175,000 square foot warehouse
space and 5,000 square foot of office space) and it was already zoned industrial. The 130 -acres of
undeveloped land, where the proposed industrial park is to be situated, were an added bonus.
Since purchasing the property, the Applicant has been in talks with the Jones -Onslow Economic Development
(JOED), to discuss grant potentials for the proposed industrial park. JOED, provides an array of support for
businesses seeking to start, expand or relocate to the eastern North Carolina. The support comes in the way of
energy audit services; lighting audit services; flexibility in rate design; power quality services and loan and
grant assistance. The Duke Energy Site Readiness Grant Program team has evaluated the site and is
recommending support for the project. The JOED and Duke Energy have committed to help market the
development, which will attract new employers and businesses to the industrial park.
Alternative Site Anal: Alternative site screening criteria consisted of evaluating properties that are close to
Holly Ridge, utilities, such as water and sewer, are available, access to US Highway 17, are appropriately
zoned (i.e. commercial/industrial) and are similar in size.

Camp Davis Industrial Park — Response to USACE RFAI F C, i
The three sites that met, at the least, the location, size and access criteria, were eliminated from further review
based on the property either not being on the market for sale or not having adequate utilities. Therefore,
further investigation into the presence of threatened or endangered species and/or critical habitat, as well as
other natural or regionally important ecosystem resource factors, were not investigated. The table below
summarizes the screening process of the preferred site and the three alternative sites:
Practicability
Factor
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Category
Preferred Site
Available
Available for Acquisition
Applicant owns the
Multi Listed
Not Listed —
Not Listed—
parcel
Failed screen
Failed screen
Logistics
Sufficient Parcel Size
159 Acres
Yes
NA
NA
Appropriate Zoning or
Yes — The property is
Yes
NA
NA
Able to Change
zoned for this type of
project
Availability of Utilities
Yes - ONWASA
No — Failed Screen
NA
NA
Adequate Access
Yes — Access off
NA
Hwy 17
Technology
Topography and Other
Yes —
NA
NA
NA
Site Conditions for Devel-
opment
Cost
Reasonable Acquisition
Applicant owns the
NA
NA
NA
Cost
property
Threatened and Endangered Species and Critical Habitat: Threatened and endangered species and/or critical
habitat within the project area were further analyzed by using the Natural Heritage Program database. Twenty-
nine (29) species were identified within the Holly Ridge Topographic Quad. Of those twenty-nine, ten (10)
were listed as a State or Federally ranked Endangered or Threatened. Habitat within the project area supported
the potential for three (3) of the species to be present. Of those three (3), none were federally listed as
threatened or endangered but were further evaluated due to their state ranking. The three species are as
follows:
1. Crotalus admananteus — Eastern Diamondback Rattlesnake
2. Lachnocaulon minus — Brown Bogbutton
3. Lechea torreyi var conjesta — Torry's Pinweed
Eastern Diamondback Rattlesnake — The Eastern Diamondback rattlesnake is restricted to the Lower Coastal
Plain of the Southeast, from southern North Carolina to eastern Louisiana, although the stronghold of their
range is in Florida and southern Georgia. This species usually inhabits dry sandy areas, palmetto or wiregrass
flatwoods, pinewoods, coastal dune habitats, or hardwood hammocks. They generally avoid wet areas but
sometimes live along the edges of swamps. This species is rare even in the listed habitats and move about
frequently in search of prey. This site does not exhibits habitat, in which the Eastern Diamondback
Rattlesnake would be found. Therefore, the proposed impact development is not anticipated to have an effect
on the species.
Brown Bogbutton — The Brown Bogbutton is favorite habitat of Brown Bogbutton is the fluctuating shores of
karsts (landscape underlain by limestone that has been eroded by dissolution, producing ridges, towers,
fissures, sinkholes, and other characteristic landforms) ponds, where it may be aspect dominant along the
edge of the maximum pool. On 7 April 2017, SEGi evaluated the impact areas for evidence of the species.
None were found.
2

Camp Davis Industrial Park — Response to USACE RFAI F C,i
Torry's Pinweed — This plant is found in the sandhills and pine flatwoods. Due to the routine mowing of the
site, it is not anticipated that Torry's Pinweed would be found within the project boundaries. On 7 April 2017,
SEGi evaluated the impact areas for evidence of the species. None were found.
2. Minimization: Minimization includes alternate site plans and other steps which would reduce impacts to on-
site waters of the United States (WOUS). Please further describe other site plans and minimization steps
considered to further minimize the impact of your project on aquatic resources. This includes information
regarding alternate site configurations that were considered such as reducing the size of the associated
infrastructure so that more impacts are avoided, and/or reconfiguring the location of the proposed
infrastructure. Specifically, the economic, public interest, and environmental implications of each alternative
site plan should be provided. The analysis should document that the wetland and surface water area to be filled
is the minimum area required for the project to be practicable. The combined off-site and on-site alternatives
analysis should provide information specific enough to determine if the project is the least environmentally -
damaging, practicable alternative that meets the project purpose.
Beyond evaluating construction alternatives, alternative site configurations, to avoid and minimize wetland
impacts, were assessed during the design period. The following alternative site plans were considered:
1. Preferred site configuration: This site plan consists utilizing the majority of the available uplands,
within Phases I and II, and impacting the lowest quality WOTUS and the RPW, while minimizing
wetland impacts to the greatest extent practicable. This site plan configuration was determined to be the
least environmentally damaging practicable alternative (LEDPA).
2. Utilization of the entire tract: While this site plan would result in greater income for the Applicant, it
would consist of filling all of the WOTUS (2.74 -acre) and RPWs (4.14 -acre) within the property
boundaries. This plan requires an additional 2.33 -acre of WOTUS impacts, over what is being proposed
with the preferred site plan. Therefore, this alternative site configuration was not determined to be the
LEDPA.
3. Utilization of all land within Phase IL This site plan would also result in greater income for the
Applicant but would consist of filling an additional 1.01 -acres of WOTUS, over what is being proposed
with the preferred site plan. Therefore, this alternative site configuration was not determined to be the
LEDPA.
4. Utilization of all land within Phase L This site plan would also result in greater income for the
Applicant but would consist of filling an additional 1.39 -acres of WOTUS, over what is being proposed
with the preferred site plan. Therefore, this alternative site configuration was not determined to be the
LEDPA.
3. Compensatory Mitigation: An appropriate compensatory mitigation plan is required to fully offset
unavoidable impacts to WOUS in accordance with 33 CFR 332 — Compensatory Mitigation for Losses of
Aquatic Resources. The application states that preservation of 2.44 acres of wetlands and 0.12 acre of RPWs /
Tributaries is proposed to offset impacts to aquatic resources. As described in 33 CFR 332.3 (h), preservation
may be used to provide compensatory mitigation for activities authorized by DA permits WHEN ALL of the
following criteria are met. (i) The resources to be preserved provide important physical, chemical, or biological
functions for the watershed; (ii) The resources to be preserved contribute significantly to the ecological
sustainability of the watershed. In determining the contribution of those resources to the ecological
sustainability of the watershed, the district engineer must use appropriate quantitative assessment tools, where
available; (iii) Preservation is determined by the district engineer to be appropriate and practicable; (iv) The
resources are under threat of destruction or adverse modifications; and (v) The preserved site will be
permanently protected through an appropriate real estate or other legal instrument (e.g., easement, title
transfer to state resource agency or land trust). Pleaseprovide information that shows these criteria are met for
the proposed preservation. Once the final mitigation proposal is determined by the Corps to be appropriate, the
mitigation plan must contain the elements described at 33 CFR 332.4(c)(2) through (c)(14). Additionally,
please note the preference for purchasing mitigation bank credits to offset impacts at 33 CFR 332.3(b). If
mitigation bank credit purchase is not proposed, the justification for utilizing other forms of mitigation should
3

Camp Davis Industrial Park — Response to USACE RFAI F C,i
be provided. Finally, the application states that the aquatic resources to be impacted are low quality. Please
provide information in the form of NCWAMINCSAM to support this conclusion.
It is SEGi's understanding that mitigation is not required for tributaries determined to be manmade ditches, as
these features are water conveyances that do not provide any functional value (i.e. habitat, physical or
chemical processes that would improve water quality, flood storage, etc.). Therefore, mitigation is not being
offered to offset the filling of these features.
Upon further consideration, the Applicant has decided to withdraw the proposal to place all remaining
WOTUS into preservations and submits that payment to the Northeast Cape Fear Umbrella Mitigation Bank
(NECFUMB) for non -riparian wetland restoration credit, to offset the impacts to WOTUS.
The waters of the US (WOTUS) wetlands, denoted on the site plan to be impacted (0.41 -acre), are not
naturally occurring but rather formed as a result of the property being used to treat "greywater", which was
generated by the industrial plant that has since relocated. These WOTUS provide little functional value (i.e.
water quality, hydrology and/or habitat), as is demonstrated in the attached NC Wetland Assessment Method
(NCWAM) form, which scores the overall functional value of the feature as LOW (see Attachment 2). The
Applicant intends to offset the proposed impact to these low valued wetlands with payment to the
NECFUMB, for 0.40 -acre of non -riparian wetland restoration credit, a .98 to 1 mitigation to impact ratio.
While the project site is not within the NECFUMB's dedicated service area, it is within the Cape Fear River
Basin and it abuts the NECFUMB service area (see Attachment 3). Therefore, the NECFUMB is the most
appropriate bank for this project. Due to the low quality of the WOTUS to be impacted, the purchased credits
are sufficient to offset the loss of function resulting from the proposed fill. The NECFUMB credit reservation
letter has been secured (see Attachment 4).
4. A water quality certification is required for the project pursuant to Section 401(a)(1) of the Clean Water Act.
A copy of the State's water quality certification should be sent to the Corps after it has been obtained
A copy of the permit application has been submitted to the NC Division of Water Resources, for their review
and processing.
It is SEGi's hope that the information found within and attached to this correspondence is sufficient to address the
USACE's request for additional information. However, should you have questions or concerns regarding the
presented information, please feel free to contact me at 910.228.1841.
Thank you, for your time and assistance with this project.
Sincerely,
Dana A. Lutheran
SEGi Regulatory Specialist
cc: Ms. Karen Higgins — NC DWR 401 and Buffer Unit Raleigh
Mr. Robb Mairs — NC DWR 401 and Buffer Unit WiRO
Enclosures: Attachment 1 — Onslow County Parcel Boundary Map
Attachment 2 — NC Wetland Assessment Method Results
Attachment 3 — Northeast Cape Fear Umbrella Mitigation Bank Service Area Map

Camp Davis Industrial Park — Response to USACE RFAI F C,i
Attachment 1
Onslow County GIS Parcel Boundary Map

Camp Davis Industrial Park — Response to USACE RFAI F C, i
Attachment 2
NC Wetland Assessment Method Results

NC WAM Wetland Rating Sheet
Accompanies User Manual Version 4.1
Rating Calculator Version 4.1
Wetland Site Name Camp Davis Industrial Park Date 5 April 2017
Wetland Type Non -Tidal Freshwater Marsh Assessor Name/Organization Dana Lutheran - SEGi
Notes on Field Assessment Form (Y/N)
NO
Presence of regulatory considerations (Y/N)
YES
Wetland is intensively managed (Y/N)
YES
Assessment area is located within 50 feet of a natural tributary or other open water (Y/N)
NO
Assessment area is substantially altered by beaver (Y/N)
NO
Assessment area experiences overbank flooding during normal rainfall conditions (Y/N)
NO
Assessment area is on a coastal island (Y/N)
NO
Sub -function Rating Summary
Function Sub -function Metrics Rating
Hydrology Surface Storage and Retention Condition NA
Sub -Surface Storage and Retention Condition NA
Water Quality Pathogen Change Condition NA
Vegetation Composition Condition HIGH
Function Rating Summary
Function
Condition/Opportunity
NA
Hydrology
Opportunity Presence? (Y/N)
NA
Particulate Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Soluble Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Physical Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Pollution Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Habitat Physical Structure
Condition
LOW
Landscape Patch Structure
Condition
LOW
Vegetation Composition Condition HIGH
Function Rating Summary
Function
Metrics/Notes
Rating
Hydrology
Condition
MEDIUM
Water Quality
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence? (Y/N)
NO
Habitat
Conditon
LOW
Overall Wetland Rating LOW

NC WAM WETLAND ASSESSMENT FORM
Accompanies User Manual Version 4.1
Wetland Site Name Camp Davis Industrial Park Date 5 April 2017
Wetland Type Non -Tidal Freshwater Marsh Assessor Name/Organization Dana Lutheran - SEGi
Level III Ecoregion Middle Atlantic Coastal Plain Nearest Named Water Body Flat Swamp
River Basin Cape Fear USGS 8 -Digit Catalogue Unit 03003005
Yes ___ No Precipitation within 48 hrs? Latitude/Longitude (deci-degrees) 34.494622, -77.563711
Evidence of stressors affecting the assessment area (may not be within the assessment area)
Please circle and/or make note on last page if evidence of stressors is apparent. Consider departure from reference, if
appropriate, in recent past (for instance, approximately within 10 years). Noteworthy stressors include, but are not limited
to the following.
• Hydrological modifications (examples: ditches, dams, beaver dams, dikes, berms, ponds, etc.)
• Surface and sub -surface discharges into the wetland (examples: discharges containing obvious pollutants, presence of nearby
septic tanks, underground storage tanks (USTs), hog lagoons, etc.)
• Signs of vegetation stress (examples: vegetation mortality, insect damage, disease, storm damage, salt intrusion, etc.)
• Habitat/plant community alteration (examples: mowing, clear -cutting, exotics, etc.)
Is the assessment area intensively managed? Yes No
Regulatory Considerations (select all that apply to the assessment area)
F- Anadromous fish
F- Federally protected species or State endangered or threatened species
F_ NCDWQ riparian buffer rule in effect
F_ Abuts a Primary Nursery Area (PNA)
F7, Publicly owned property
F_ N.C. Division of Coastal Management Area of Environmental Concern (AEC) (including buffer)
F_ Abuts a stream with a NCDWQ classification of SA or supplemental classifications of HQW, ORW, or Trout
F_ Designated NCNHP reference community
F_ Abuts a 303(d) -listed stream or a tributary to a 303(d) -listed stream
What type of natural stream is associated with the wetland, if any? (check all that apply)
Blackwater
Brownwater
F- Tidal (if tidal, check one of the following boxes) Lunar Wind Both
Is the assessment area on a coastal island? 1- Yes : No
Is the assessment area's surface water storage capacity or duration substantially altered by beaver?
Does the assessment area experience overbank flooding during normal rainfall conditions?
,' — Yes ,i No
,' — Yes r: No
Ground Surface Condition/Vegetation Condition — assessment area condition metric
Check a box in each column. Consider alteration to the ground surface (GS) in the assessment area and vegetation structure
(VS) in the assessment area. Compare to reference wetland if applicable (see User Manual). If a reference is not applicable,
then rate the assessment area based on evidence of an effect.
GS VS
A A Not severely altered
B B Severely altered over a majority of the assessment area (ground surface alteration examples: vehicle tracks, excessive
sedimentation, fire -plow lanes, skidder tracks, bedding, fill, soil compaction, obvious pollutants) (vegetation structure
alteration examples: mechanical disturbance, herbicides, salt intrusion [where appropriate], exotic species, grazing,
less diversity [if appropriate], hydrologic alteration)
2. Surface and Sub -Surface Storage Capacity and Duration — assessment area condition metric
Check a box in each column. Consider surface storage capacity and duration (Surf) and sub -surface storage capacity and
duration (Sub). Consider both increase and decrease in hydrology. Refer to the current NRCS lateral effect of ditching guidance for
North Carolina hydric soils (see USACE Wilmington District website) for the zone of influence of ditches in hydric soils. A ditch
<_ 1 foot deep is considered to affect surface water only, while a ditch > 1 foot deep is expected to affect both surface and ditch
sub -surface water. Consider tidal flooding regime, if applicable.
Surf Sub
{ A A Water storage capacity and duration are not altered.
B B Water storage capacity or duration are altered, but not substantially (typically, not sufficient to change vegetation).
(: C : C Water storage capacity or duration are substantially altered (typically, alteration sufficient to result in vegetation
change) (examples: draining, flooding, soil compaction, filling, excessive sedimentation, underground utility lines).
3. Water Storage/Surface Relief —assessment arealwetland type condition metric (answer for non -marsh wetlands only)
Check a box in each column for each group below. Select the appropriate storage for the assessment area (AA) and the wetland
type (WT).
AA WT
3a. ,' — A A Majority of wetland with depressions able to pond water > 1 foot deep
B {' B Majority of wetland with depressions able to pond water 6 inches to 1 foot deep
C {: C Majority of wetland with depressions able to pond water 3 to 6 inches deep
D {' D Depressions able to pond water < 3 inches deep

3b. (-A Evidence that maximum depth of inundation is greater than 2 feet
{ B Evidence that maximum depth of inundation is between 1 and 2 feet
{: C Evidence that maximum depth of inundation is less than 1 foot

4. Soil Texture/Structure - assessment area condition metric
Check a box from each of the three soil property groups below. Dig soil profile in the dominant assessment area landscape
feature. Make soil observations within the 12 inches. Use most recent National Technical Committee for Hydric Soils guidance for
regional indicators.
4a. ,: A Sandy soil
` B Loamy or clayey soils exhibiting redoximorphic features (concentrations, depletions, or rhizospheres)
C Loamy or clayey soils not exhibiting redoximorphic features
t D Loamy or clayey gleyed soil
{� E Histosol or histic epipedon
4b. A Soil ribbon < 1 inch
f" B Soil ribbon >_ 1 inch
4c. f: A No peat or muck presence
{� B A peat or muck presence
5. Discharge into Wetland - opportunity metric
Check a box in each column. Consider surface pollutants or discharges (Surf) and sub -surface pollutants or discharges (Sub).
Examples of sub -surface discharges include presence of nearby septic tank, underground storage tank (UST), etc.
Surf Sub
A A Little or no evidence of pollutants or discharges entering the assessment area
B B Noticeable evidence of pollutants or discharges entering the wetland and stressing, but not overwhelming the
treatment capacity of the assessment area
C C Noticeable evidence of pollutants or discharges (pathogen, particulate, or soluble) entering the assessment area and
potentially overwhelming the treatment capacity of the wetland (water discoloration, dead vegetation, excessive
sedimentation, odor)
6. Land Use -opportunity metric
Check all that apply (at least one box in each column). Evaluation involves a GIS effort with field adjustment. Consider sources
draining to assessment area within entire upstream watershed (WS), within 5 miles and within the watershed draining to the
assessment area (5M), and within 2 miles and within the watershed draining to the assessment area (2M). Effective riparian buffers
are considered to be 50 feet wide in the Coastal Plain and Piedmont ecoregions and 30 feet wide in the Blue Ridge Mountains ecoregion.
WS 5M 2M
F_ A r A r A >_ 10% impervious surfaces
F-1 B r B r B < 10% impervious surfaces
F_ C r C r C Confined animal operations (or other local, concentrated source of pollutants)
F_ D r D r D >_ 20% coverage of pasture
F_ E r E r E >_ 20% coverage of agricultural land (regularly plowed land)
F_ F r F r F >_ 20% coverage of maintained grass/herb
F_ G r G r G >_ 20% coverage of clear-cut land
F_ H r H r H Little or no opportunity to improve water quality. Lack of opportunity may result from hydrologic alterations
that prevent drainage or overbank flow from affecting the assessment area.
Wetland Acting as Vegetated Buffer - assessment area/wetland complex condition metric
7a. Is assessment area within 50 feet of a tributary or other open water?
Yes : No If Yes, continue to 7b. If No, skip to Metric 8.
Wetland buffer need only be present on one side of the water body. Make buffer judgment based on the average width of the wetland.
Record a note if a portion of the buffer has been removed or disturbed.
7b. How much of the first 50 feet from the bank is weltand? Descriptor E should be selected if ditches effectively bypass the buffer.
f- A >_ 50 feet
( B From 30 to < 50 feet
( C From 15 to < 30 feet
( D From 5 to < 15 feet
{� E < 5 feet or buffer bypassed by ditches
7c. Tributary width. If the tributary is anastomosed, combine widths of channels/braids for a total width.
,'.- <_ 15 -feet wide '` > 15 -feet wide ,'` Other open water (no tributary present)
7d. Do roots of assessment area vegetation extend into the bank of the tributary/open water?
`- Yes i,-- No
7e. Is tributary or other open water sheltered or exposed?
` Sheltered - adjacent open water with width < 2500 feet and no regular boat traffic.
Exposed - adjacent open water with width >_ 2500 feet or regular boat traffic.
Wetland Width at the Assessment Area - wetland type/wetland complex metric (evaluate for riparian wetlands only)
Check a box in each column. Select the average width for the wetland type at the assessment area (WT)
and the wetland complex at the assessment areas (WC). See User Manual for WT and WC boundaries.
WT
WC
(' A
{' A
>_ 100 feet
C B
( B
From 80 to < 100 feet
C C
( C
From 50 to < 80 feet
(' D
( D
From 40 to < 50 feet
(' E
r E
From 30 to < 40 feet
( F
{ F
From 15 to < 30 feet
( G
G
From 5 to < 15 feet
. H
: H
< 5 feet

9. Inundation Duration — assessment area condition metric
Answer for assessment area dominant landform.
is A Evidence of short -duration inundation (< 7 consecutive days)
` B Evidence of saturation, without evidence of inundation
C Evidence of long -duration inundation or very long -duration inundation (7 to 30 consecutive days or more)
10. Indicators of Deposition — assessment area condition metric
Consider recent deposition only (no plant growth since deposition).
(: A Sediment deposition is not excessive, but at approximately natural levels.
(' B Sediment deposition is excessive, but not overwhelming the wetland.
( C Sediment deposition is excessive and is overwhelming the wetland.
11. Wetland Size — wetland type/wetland complex condition metric
Check a box in each column. Involves a GIS effort with field adjustment. This metric evaluates three aspects of the wetland area: the
size of the wetland type (WT), the size of the wetland complex (WC), and the size of the forested wetland (FW) (if applicable, see User
Manual). See the User Manual for boundaries of these evaluation areas. If assessment area is clear-cut, select "K" for the FW column.
WT WC FW (if applicable)
C' A C A { A >_ 500 acres
C B B B From 100 to < 500 acres
( C C C From 50 to < 100 acres
( D D D From 25 to < 50 acres
( E E E From 10 to < 25 acres
( F ( F ( F From 5 to < 10 acres
( G ( G ( G From 1 to < 5 acres
( H ( H ( H From 0.5 to < 1 acre
( I ( I ( I From 0.1 to < 0.5 acre
( J ( J ( J From 0.01 to < 0.1 acre
(: K K K < 0.01 acre or assessment area is clear-cut
12. Wetland Intactness — wetland type condition metric (evaluate for Pocosins only)
C A Pocosin is the full extent (>_ 90%) of its natural landscape size.
r— B Pocosin is < 90% of the full extent of its natural landscape size.
13. Connectivity to Other Natural Areas — landscape condition metric
13a. Check appropriate box(es) (a box may be checked in each column). Involves a GIS effort with field adjustment. This
evaluates whether the wetland is well connected (Well) and/or loosely connected (Loosely) to the landscape patch, the contiguous
metric naturally vegetated area and open water (if appropriate). Boundaries are formed by four -lane roads, regularly maintained utility
line corridors the width of a four -lane road or wider, urban landscapes, fields (pasture open and agriculture), or water > 300 feet wide.
Well Loosely
{ A t`' A >_ 500 acres
C` B B From 100 to < 500 acres
(` C C From 50 to < 100 acres
{ D D From 10 to < 50 acres
{ E E < 10 acres
C` F 4- F Wetland type has a poor or no connection to other natural habitats
13b. Evaluate for marshes only.
C" Yes No Wetland type has a surface hydrology connection to open waters/stream or tidal wetlands.
14. Edge Effect — wetland type condition metric (skip for all marshes)
May involve a GIS effort with field adjustment. Estimate distance from wetland type boundary to artificial edges. Artificial edges include
non -forested areas >_ 40 feet wide such as fields, development, roads, regularly maintained utility line corridors and clear -cuts.
Consider the eight main points of the compass.
C A No artificial edge within 150 feet in all directions
C B No artificial edge within 150 feet in four (4) to seven (7) directions
f: C An artificial edge occurs within 150 feet in more than four (4) directions or assessment area is clear-cut
15. Vegetative Composition — assessment area condition metric (skip for all marshes and Pine Flat)
[: A Vegetation is close to reference condition in species present and their proportions. Lower strata composed of appropriate
species, with exotic plants absent or sparse within the assessment area.
C B Vegetation is different from reference condition in species diversity or proportions, but still largely composed of native species
characteristic of the wetland type. This may include communities of weedy native species that develop after clearcutting or
clearing. It also includes communities with exotics present, but not dominant, over a large portion of the expected strata.
C' C Vegetation severely altered from reference in composition. Expected species are unnaturally absent (planted stands of non -
characteristic species or at least one stratum inappropriately composed of a single species). Exotic species are dominant in
at least one stratum.
16. Vegetative Diversity— assessment area condition metric (evaluate for Non -tidal Freshwater Marsh onl)4
A Vegetation diversity is high and is composed primarily of native species (<10% cover of exotics).
B Vegetation diversity is low or has > 10% to 50% cover of exotics.
C Vegetation is dominated by exotic species (>50% cover of exotics).

17. Vegetative Structure — assessment arealwetland type condition metric
17a. Is vegetation present?
is Yes - No If Yes, continue to 17b. If No, skip to Metric 18.
17b. Evaluate percent coverage of assessment area vegetation for all marshes only. Skip to 17c for non -marsh wetlands.
A >_ 25% coverage of vegetation
B < 25% coverage of vegetation
17c. Check a box in each column for each stratum. Evaluate this portion of the metric for non -marsh wetlands. Consider structure
in airspace above the assessment area (AA) and the wetland type (WT) separately.
0 C C i': C Shrub layer sparse or absent
{' A A Dense herb layer
{: B : B Moderate density herb layer
_ { C C Herb layer sparse or absent
18. Snags — wetland type condition metric
C- A Large snags (more than one) are visible (> 12 -inches DBH, or large relative to species present and landscape stability).
,': B Not A
19. Diameter Class Distribution — wetland type condition metric
C A Majority of canopy trees have stems > 6 inches in diameter at breast height (DBH); many large trees (> 12 inches DBH) are
present.
B Majority of canopy trees have stems between 6 and 12 inches DBH, few are > 12 -inch DBH.
C Majority of canopy trees are < 6 inches DBH or no trees.
20. Large Woody Debris — wetland type condition metric
Include both natural debris and man -placed natural debris.
C A Large logs (more than one) are visible (> 12 inches in diameter, or large relative to species present and landscape stability).
(: B Not A
21. Vegetation/Open Water Dispersion — wetland typelopen water condition metric (evaluate for Non -Tidal Freshwater
Marsh only)
Select the figure that best describes the amount of interspersion between vegetation and open water in the growing season. Patterned
areas indicate vegetated areas, while solid white areas indicate open water.
=A B =C D
Rr� `~ � �\ f � �, lam•-� -� /r `�'' .-, �` ,� \
22. Hydrologic Connectivity— assessment area condition metric (evaluate for riparian wetlands only)
Examples of activities that may severely alter hydrologic connectivity include intensive
ditching, fill, sedimentation, channelization, diversion, man-made berms, beaver dams, and stream incision.
` A Overbank and overland flow are not severely altered in the assessment area.
` B Overbank flow is severely altered in the assessment area.
r- C Overland flow is severely altered in the assessment area.
C D Both overbank and overland flow are severely altered in the assessment area.
Notes
AA
WT
CL
C' A
= A
Canopy closed, or nearly closed, with natural gaps associated with natural processes
o
m
C` B
= B
Canopy present, but opened more than natural gaps
U
C: C
C
Canopy sparse or absent
$
C` A
= A
Dense mid-story/sapling layer
C` B
= B
Moderate density mid-story/sapling layer
(: C
C
Mid-story/sapling layer sparse or absent
C` A
C- A
Dense shrub layer
C` B
C- B
Moderate density shrub layer
0 C C i': C Shrub layer sparse or absent
{' A A Dense herb layer
{: B : B Moderate density herb layer
_ { C C Herb layer sparse or absent
18. Snags — wetland type condition metric
C- A Large snags (more than one) are visible (> 12 -inches DBH, or large relative to species present and landscape stability).
,': B Not A
19. Diameter Class Distribution — wetland type condition metric
C A Majority of canopy trees have stems > 6 inches in diameter at breast height (DBH); many large trees (> 12 inches DBH) are
present.
B Majority of canopy trees have stems between 6 and 12 inches DBH, few are > 12 -inch DBH.
C Majority of canopy trees are < 6 inches DBH or no trees.
20. Large Woody Debris — wetland type condition metric
Include both natural debris and man -placed natural debris.
C A Large logs (more than one) are visible (> 12 inches in diameter, or large relative to species present and landscape stability).
(: B Not A
21. Vegetation/Open Water Dispersion — wetland typelopen water condition metric (evaluate for Non -Tidal Freshwater
Marsh only)
Select the figure that best describes the amount of interspersion between vegetation and open water in the growing season. Patterned
areas indicate vegetated areas, while solid white areas indicate open water.
=A B =C D
Rr� `~ � �\ f � �, lam•-� -� /r `�'' .-, �` ,� \
22. Hydrologic Connectivity— assessment area condition metric (evaluate for riparian wetlands only)
Examples of activities that may severely alter hydrologic connectivity include intensive
ditching, fill, sedimentation, channelization, diversion, man-made berms, beaver dams, and stream incision.
` A Overbank and overland flow are not severely altered in the assessment area.
` B Overbank flow is severely altered in the assessment area.
r- C Overland flow is severely altered in the assessment area.
C D Both overbank and overland flow are severely altered in the assessment area.
Notes

Camp Davis Industrial Park — Response to USACE RFAI F C, i
Attachment 3
NE Cape Fear Umbrella Mitigation Bank Service Area Map

,
Google
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Camp Davis Industrial Park — Response to USACE RFAI F C, i
Attachment 4
NE Cape Fear Umbrella Mitigation Bank Credit Reservation Letter

NORTHEAST CAPE FEAR UMBRELLA MITIGATION BANK
Agent: Land Management Group, Inc.
3805 Wrightsville Avenue, Suite 15
Wilmington, NC 28403
Credit Reservation Letter
April 18, 2017
Dana Lutheran
Southern Environmental Group, Inc.
5315 South College Road, Suite E
Wilmington, INC 28412
Project: Camp Davis Industrial Park — Highway 17 Holly Ridge, INC
Dear Dana:
The Northeast Cape Fear Umbrella Mitigation Bank (Bank) is providing preliminary acceptance to supply
mitigation credits for impacts to non -riparian and riparian wetlands associated with the project located at
the Camp Davis Industrial Park site off of U.S. Highway 17 in Holly Ridge (Onslow County, North Carolina).
Please refer to the table below depicting the type and quantity of credits requested and reserved for your
project.
Mitigation Type F Credits ReSE
[Stream 7_
Non -Riparian Wetland
Fiparian Wetland T_
I
_F_
0
0.4
0.0
The Bank will reserve the credits outlined above for a period of up to 90 days from the date of this letter.
Please contact us if you need a reservation to extend beyond the 90 -day period. Requests to reserve
credits beyond 90 days may require a deposit. Upon request for credit transfer, the Bank will issue an
invoice in the amount of $20,568.80. Upon receipt of payment, the Bank will provide an executed Transfer
of Credit Certificate for the total amount of credits invoiced and paid for. If you have any questions or need
additional information, please contact me by phone at [phone] or by email at
[e-mail].
Sincerely,
Northeast Cape Fear Umbrella Mitigation Bank
Christian Preziosi
Land Management Group, Inc. (agent)
Northeast Cape Fear Umbrella Mitigation Bank
c/o Land Management Group, Inc.
3805 Wrightsville Avenue, Suite 15
Wilmington, NC 28403
1
Fee Per Unit
F
Fee
$391.00
7
$0.00
$51,422.00
7
$20,568.80
$71,273.00
$0.00
Total Fee
$20,568.80
The Bank will reserve the credits outlined above for a period of up to 90 days from the date of this letter.
Please contact us if you need a reservation to extend beyond the 90 -day period. Requests to reserve
credits beyond 90 days may require a deposit. Upon request for credit transfer, the Bank will issue an
invoice in the amount of $20,568.80. Upon receipt of payment, the Bank will provide an executed Transfer
of Credit Certificate for the total amount of credits invoiced and paid for. If you have any questions or need
additional information, please contact me by phone at [phone] or by email at
[e-mail].
Sincerely,
Northeast Cape Fear Umbrella Mitigation Bank
Christian Preziosi
Land Management Group, Inc. (agent)
Northeast Cape Fear Umbrella Mitigation Bank
c/o Land Management Group, Inc.
3805 Wrightsville Avenue, Suite 15
Wilmington, NC 28403
1