P15115.1 Draft Prospectus 91317

SINCE 1959

CAMP GRIER MITIGATION BANK
PROSPECTUS

CATAWBA RIVER BASIN
HUC: 03050101
MCDOWELL COUNTY
NORTH CAROLINA

Prepared For:

CAMP GRIER 501(c)(3)

Prepared By:

Quible & Associates, P.C.
Engineering * Environmental Sciences * Planning * Surveying
P.O. Drawer 870
Kitty Hawk, North Carolina 27949
[phone] FAX [phone]
Quible.com

Project Number P15115.1
September 13, 2017
Camp Grier Mitigation Bank September 13, 2017
Prospectus

P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
Telephone [phone] ▪ Fax [phone]
______________________________________
1
1.0 INTRODUCTION

1.1 SITE LOCATION & SUMMARY
The Camp Grier Mitigation Bank (CGMB) will be located at Camp Grier, a youth wilderness
camp situated north of the town of Old Fort in McDowell County, North Carolina. The
CGMB contains headwater streams of the upper Catawba River Basin. The project area
lies just outside a Targeted Local Watershed (TLW) by NC Department of Environmental
Quality. The CGMB will serve TLWs in the Catawba basin. The site entrance is at 985 Old
US 70, Old Fort, 28762. The center of the project area is roughly centered at Latitude
35.64397 N and 82.19258 N Longitude. A site location map can be found within Exhibit A,
the Camp Grier Conceptual Mitigation Plan for the project area. The property and project
area slope generally south from the southeast side of the Black Mountains range and
makes up part of the boundary between the mountain and piedmont physiographic regions
on the flank of the Blue Ridge escarpment. Streams that do not originate within the project
area flow from more than 27,000 acres of undeveloped USDA National Forest land. Jarrett
Creek flows through the property, and southern portion of the project area. Padgett
Branch, its tributaries and its confluence with Jarrett creek, make up the remainder of the
project area. Jarrett creek flows in to Mill Creek just south of the property. Mill Creek is a
major tributary, and trout fishery, of the South Fork of the Catawba River.

The Camp Grier property and project area are surrounded to the west, north, and east by
USDA Forrest Service Land. This site is bordered on its remaining southwest, south and
southeast sides by private undeveloped and residential properties. The 14-digit Hydrologic
Unit Code (HUC) for the site is 03050101010010. The CGMB will presumably serve the
area within the eight-digit HUC: 03050101 which extends to the South Carolina state line.
The project area will occupy approximately 109 acres within the 650-acre Camp Grier
property. Much of the project area has been impacted by logging before 1960 and is
currently suffering repetitive and ongoing impacts from camp activities and camp
development. Streams within the project appear to have been degraded from their current
NC DWR water quality classification by historic excavation, channelization, filling, and
stormwater, sediment, and nutrient impacts.

The Camp’s current administration recognizes the habitat and water quality need,
educational opportunity, and the potential that a mitigation bank could bring to the camp.
The board members for the Camp Grier 501 (c) (3) non-profit organization are currently
committed to the CGMB project.
Camp Grier Mitigation Bank September 13, 2017
Prospectus

P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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Based on preliminary site investigations, the project provides the opportunity to restore
approximately 6,833 linear feet of stream and 0.1 acre of wetlands, create another
approximately 0.4 acres of wetlands from the restoration of the existing Upper Padgett
Branch and creation of stormwater control measures, enhance approximately 5,810 linear
feet of stream, and preserve approximately 8,000 linear feet of headwater stream.
Preservation of headwater streams is proposed above the restored, created and enhanced
streams and wetlands thereby protecting the restored environment. The project will result
in more than 20,000 linear feet of stream, approximately 0.5 acres of wetlands, and 109
acres of stream and wetland buffer being protected in perpetuity by a conservation
easement and Mitigation Banking Instrument (MBI) for the project area. The conservation
easement is to be held by a nationally accredited, non-profit regional land trust, that serves
North Carolina’s eastern Blue Ridge Mountains and Foothills.

1.2 WATERSHED CHARACTERIZATION AND SERVICE AREA
Camp Grier lies within the headwaters of the upper Catawba River Basin (HUC:
03050101010010) and is proposed to serve the entire Catawba River Watershed (HUC:
03050101) in North Carolina, an area of 3,300 square miles that covers 11 counties. Per
information found on the NC Department of Mitigation Services website, the population in
the watershed is expected to nearly double in size from 1.8 million to 2.7 million residents
between the years of 2006 and 2030.

The NC Department of Environmental Quality (NC DEQ) 2007 Lower Catawba River Basin
Restoration Priorities and 2009 Upper Catawba River Restoration Priorities documents,
supplements to the original 2004 Catawba River Basin Watershed Restoration Plan,
highlight the 40 current TLWs within the Catawba Basin. The TLWs are selected based on
three criteria: Problems, Assets, and Opportunities. The Camp Grier Mitigation Bank
project area appears to lie just outside a current TLW for the Upper Catawba Basin and will
help meet Upper Catawba restoration goals outlined below and in the 2009 basin
Restoration Priorities:

· “Restoration of nutrient- and sediment-impaired waters (including tributary
streams) of the Catawba River mainstem lakes (water supply reservoirs),
including Lake James, Lake Rodhiss, Lake Hickory and Lookout Shoals
Lake.”
· “Protection of riparian buffers and aquatic habitat within the headwater
reaches of asset-rich watersheds of the upper Catawba River basin,
including the upper Linville River, North Fork Catawba River, Wilson Creek,
Mulberry Creek, Johns River and Lower Little River.”
· “Implementation of stormwater assessment and management efforts,
including stormwater BMP projects, within urban and suburban
subwatersheds in the Linville, Marion, Lenoir, Morganton, Hickory and
Taylorsville areas.”
· “Increased implementation of agricultural BMPs within heavily agricultural
sub-watersheds of TLWs, including North and South Muddy Creeks, Silver
Creek, lower Lower Creek, Lower Little River, Jumping Run Creek and Elk
Shoal Creek.”
Camp Grier Mitigation Bank September 13, 2017
Prospectus

P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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1.3 PROJECT PURPOSE
The project will utilize the environmental stewardship goals of Camp Grier’s current
administration to create a general use mitigation bank on approximately 109 acres of the
650-acre parcel. The purpose of the project is to compensate for losses of Waters of the
State permitted by State and Federal regulatory agencies through the restoration,
enhancement, creation and preservation of more than 20,000 linear feet of stream and
approximately 0.5 acres of wetlands. The project will provide measurable water quality
benefits to Padgett Branch and its tributaries, Jarrett Creek, Mill Creek and the Upper
Catawba River by restoring impacted and unstable stream reaches and by reducing
nutrient, sediment, and bacterial impacts conveyed to project area streams by stormwater,
agriculture, and erosion. Ongoing stormwater impacts will be mitigated through
implementation of a Stormwater Management Plan for the entire developed area of the
parcel through stormwater and livestock Stormwater Control Measures (SCMs, formerly
referred to as BMPs) and establishment and enhancement of wide and diverse native
riparian buffers.

The project will limit future impacts from camp related activities and create, improve and
extend habitat from USDA National Forest land and unimpacted areas of the property and
surrounding properties by increasing shade and supply of beneficial organic material (e.g.
leaf pack) resulting in a reduction in water temperature and increase in dissolved oxygen
levels in the streams.

1.4 FUTURE SITE DEVELOPMENT
The Camp Grier property has suffered land and water quality impacts associated first with
historic logging in the 1950’s, subsequently by agriculture, aquaculture, and lake building
circa 1960. More recently impacts from increased camp development, related recreational
activities and gravel and soil roads and trails are contributing most heavily to water quality
impacts at the site. Roads and trails currently provide the conduit for sediment, nutrient,
and biological water quality impacts.

The demonstrable treat of future camp development is evident as new camp leadership
has been successful in acquiring additional funding, developing new camp programs, and
soliciting additional camp users of the property. New camp activities include an equestrian
program, increased hiking trails, mountain biking trails and additional lake infrastructure
and activities. More roads, trails and additional horse and livestock pasture are currently in
the planning stages. Additionally, traditional mowing and vegetation management
techniques used within riparian areas are contributing to nutrient, pollutant, sediment, and
temperature impacts to Jarrett Creek and Padgett Branch within the project area and
downstream. Without the establishment of the Camp Grier Mitigation Bank and its
associated covenants and easement, that will permanently protect streams, impacts to
wetlands and riparian buffers and water quality will continue and worsen. Additionally,
future camp administrations may not have the foresight or interest to consider and pursue
the mitigation banking and conservation option. Finally, if the camp were to ever become
non-viable, as it nearly did several years ago, the owners of the property may consider sale
of the property for development to fund church and mission related efforts.

As planned, the CGMB will restore, enhance and preserve streams, wetlands and their
buffers within the 109-acre area most heavily impacted by historic logging, lake creation,
and past, present, and future camp and maintenance activities. Through the establishment
of the CGMB, the site will likely continue to operate only as a wilderness camp with a new
water and land quality educational component and awareness. Current impacts and new
Camp Grier Mitigation Bank September 13, 2017
Prospectus

P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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Camp development will be managed and relocated outside established riparian buffers
where possible and access to areas with stream buffers will be restricted by signage and
exclusionary fencing. The only currently foreseen use of the Camp Grier Parcel is as a
wilderness camp and recreation area.

2.0 BASELINE CONDITIONS

2.1 COMMUNITY TYPES
The CGMB lies in the “Blue Ridge Level III Ecoregion” of the US and the “Eastern Blue
Ridge Foothills Level IV Ecoregion” according to the Ecoregions Map of North Carolina
(Griffith, G.E., Omernik, J.M., Comstock, J.A., Schafale, M.P., McNab, W.H., Lenat, D.R.,
and MacPherson, T.F., 2002, Ecoregions of North Carolina, U.S. Environmental Protection
Agency, Corvallis, OR, (map scale 1:1,500,000)). Natural Communities within the project
area included altered Rich Cove and Acidic Cove Forrest (Schafale, M.P. and A.S.
Weakley. 1990. CLASSIFICATION OF THE NATURAL COMMUNITIES OF NORTH
CAROLINA THIRD APPROXIMATION. NC Natural Heritage Program, Raleigh, NC.)

2.2 VEGETATION
Dominant vegetation within the riparian corridor includes, tulip poplar (Liriodendron
tulipifera), black locust (Robinia pseudoacacia), various oak (Quercus var.), red maple
(Acer rubrum), shellbark hickory (Carya laciniosa), rhododendron (Rhododendron var.),
mountain alder (Alnus viridis), box elder (Acer negundo), Christmas fern (Polystichum
acrostichoides) , New York fern (Thelypteris noveboracensis), jewel weed (Impatiens
capensis), poison ivy (Toxadendron radicans) and stinging nettle (Urtica dioica) .
Significantly large portions of the project area, where riparian buffers are to be restored and
enhanced, are currently vegetated with maintained turf grasses. Some riparian areas, due
to current vegetation management, are mostly bare soil. Exotic invasive plant species
observed within the project area include but may not be limited to Japanese knot weed
(Polygonum cuspidatum), multiflora rose (Rosa multiflora), Chinese grass (Boehmeria
nivea) and Chinese privet (Ligustrum sinense).

2.3 SOIL CHARACTERIZATION
The CGMB project area consists of slopes that range from nearly flat to steep,
approximately 3% to nearly 100% slope. The project area is predominantly comprised of
Chestnut-Ashe complex and Dillard loam soils. Chestnut-Ashe soils are classified as
having slopes ranging from 50 to 95 percent, are well drained with a high runoff class, and
a depth to restrictive feature greater than 80 inches. Dillard loam soils are classified as
having slopes ranging from 1 to 5 percent, are moderately well drained, with a low runoff
class, and a depth to restrictive feature greater than 80 inches. A USDA soil map for
McDowell County and project area is included as Exhibit B.

2.4 HYDROLOGY AND HYDRAULIC CHARACTERISTICS
The sub-basins and contributing watersheds for both Jarrett Creek and Padgett Branch
extend beyond the CGMB project boundary and Camp Grier property boundary. Jarrett
Creek, upstream of the project area to the Town of Old Fort water supply intake (which sits
adjacent to the property boundary), is classified by NC Department of Environmental
Quality (NC DEQ) as “C:HQW”. Jarrett Creek originates approximately 4.5 miles upstream
of the Camp Grier property boundary entirely within USDA National Forest land at an
elevation of approximately 4,000 feet on the southeast slope of Glass Rock Knob.
Interestingly, Jarrett Creek within the Camp Grier property extending downstream to its
confluence with Mill Creek has a water quality classification set by NC DEQ of “C”. Mill
Camp Grier Mitigation Bank September 13, 2017
Prospectus

P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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Creek, downstream of Jarrett Creek, is classified as “C:Tr”. Jarrett Creek is a third order
stream as it flows through Camp Grier Property and the project area.

Padgett Branch above Camp Grier Lake is classified as a “B;Tr” while Padgett Branch
below Camp Grier Lake is classified as “C:Tr” water. About half of the unnamed tributaries
to Padgett Brach originate on Camp Grier property within the project area. Padgett Branch
is a second order stream. Several of the goals of the CGMB project will be to:
1. Return the water quality classification of Jarrett Creek within the Camp Grier
property and project boundary to a NC DWR Water Quality Classification of C:Tr or
higher;
2. Restore Padgett Branch and its tributaries to B:Tr classification standards or higher.

Reclassification of Padgett Branch to a standard representative of its current water quality
may be beneficial to the CGMB project.

The contributing watershed for Jarrett Creek is entirely undeveloped except for soil roads,
infrastructure, and the inline impoundment related to the historic Town of Old Fort Water
Supply (minimal), until the stream reaches the confluence of Padgett Branch and Camp
Grier Road (located within 50 feet of one another). At this point warm, sediment, nutrient
and bacterial laden stream water and stormwater enter Jarrett Creek which is causing
visible and apparently measurable impacts to water quality. Downstream of the Padgett
Branch/Jarrett Creek confluence the riparian buffer for Jarrett Creek narrows significantly
and runoff from Camp Grier Road is impacting water quality through sediment, nutrient, and
temperature inputs. As part of the CGMB project, Camp Grier has secured an option to
purchase an approximately 100-feet wide, 4-acre strip of undeveloped land adjacent to
Jarrett Creek in order to permanently protect Jarret Creek within the Camp Grier Boundary
and project area. The average stream slope of Jarrett Creek was measured using existing
topographic data to be approximately 9% and its contributing watershed above the project
area is approximately 2,780 acres.

The lower reach of Padgett Branch from it confluence with Jarrett Creek upstream to the
Camp Grier Lake dam has been impacted historically by the building of Camp Grier Road
and filling of the stream channel and associated floodplain with blasted rock debris fill.
Large volumes of sediment are entering the Lower Padgett Branch through unmitigated
stormwater flowing from Camp Grier Road. Sediment entry points were observed and
noted at multiple distinct locations along the road/streambank. Unnatural upland sediment
deposits are visible throughout the Lower Padgett Branch. Photos of unnatural sediment
deposits as well as other portions of the project area are included as Exhibit C.

The culvert that conveys Lower Padgett Branch beneath Camp Grier Road (approximately
100 feet below Camp Grier Lake Dam) is a barrier to aquatic passage. Padgett Branch
does not appear to have a volume or depth of flow to support trout; however, should
apparently support species of minnows and macro-invertebrates that support trout and
other fauna. Interestingly, the Camp Grier Lake Dam appears as though it may impose
less of an aquatic barrier than the referenced culvert due to its spillway design and the
continual flow of water down the non-vertical dam face. This spillway structure appears
that it may allow macro invertebrates to crawl up and over into Camp Grier Lake and
continue upstream. The lake also provides an opportunity for restoration and/or
enhancement through installation of a cool water release structure to Lower Padgett
Branch.

Camp Grier Mitigation Bank September 13, 2017
Prospectus

P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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The average stream channel slope of Padgett branch from Camp Grier Lake Dam to its
confluence with Jarrett Creek was measured using existing topographic data to be
approximately 11%. The contributing watershed for all of Padgett Branch to the confluence
of Jarrett Creek is approximately 460 acres.

The main stem of Padgett Branch above Camp Grier Lake (Upper Padgett Branch) has a
shallower slope than the lower reach downstream of the lake. Tributaries predominantly
enter the upper reach from the north and from Camp Grier property. The slope of the main
stem of the upper reach of Padgett Branch was measured to be approximately 3%-5%. Its
tributaries, T1-T11 steepen significantly up valley. Much of the riparian buffer along the
main stem of Padgett Branch is maintained using traditional non-environmentally sensitive
mowing and vegetation management techniques. The main stem of Upper Padgett Branch
and several of the downstream ends of its tributaries appear to have been historically
relocated toward the edge of their natural valleys and appear to have been straightened
and deepened. Four small impoundments have been observed and noted in Upper
Padgett Branch and its tributaries, one along the main stem (reportedly historically used to
fill the swimming pool), one in Tributary T1A (apparently to help regulate flow in trout ponds
constructed in the riparian buffer), one in T2A (also associated with trout pisciculture) and a
fourth in Tributary T2 for an unknown purpose (see Exhibit A). Finally, an apparent .01-
acre wetland area at the upstream end of Tributary T2A has been historically impacted by
excavation and water conveyance infrastructure. A United States Army Corps of Engineers
(USACE) NC Wetland Assessment Methodology (NC WAM) form has been completed for
this area and is included Exhibit D-Stream & Wetland Data Forms.

2.5 PRELIMINARY STREAM CLASSIFICATION
Nearly all of the approximately 20,000 linear feet of stream within the CGMB project area
have been observed on multiple occasions prior to preparation of this prospectus
document. Photographic documentation of representative areas of streams are included
as Exhibit C. USACE North Carolina Stream Assessment Methodology (NC SAM) forms
have been completed for both Jarrett Creek and the main stem of Padgett Branch (Exhibit
D). Preliminary cross-sections on the main stem of Padgett Branch were measured using
non-survey grade techniques with conventional measuring tapes. Measurements were
converted to cross-sections and measured dimensions were applied to the Key to Rosgen
Classification of Natural Rivers. Cross-sections, current Rosgen Classifications, and
proposed conditions are included as Exhibit E-Cross-Sections & Rosgen Classification.
Jarrett Creek within the project reach has a lower slope (estimated to be 4%) than the
reach above the Padgett Branch confluence. Jarrett Creek within the project area is
preliminarily classified as a classic, minimally impaired “B4a-B5a” stream by the Rosgen
Classification of Natural Rivers, however is suffering from the impacts discussed above.
Lower Padgett Branch below Camp Crier Lake at Cross-Section 1 is preliminarily classified
as an impaired “A5” stream. The main stem of Upper Padgett Branch above Camp Grier
Lake at Cross-section 2 was preliminary assessed as an impaired “B6” stream with low
sinuosity due to historic straightening and dredging. Further upstream above the swimming
pool on Upper Padgett Branch at Cross-section 3, Padgett Brach was classified as an
impaired G6 stream (Exhibit E).

3.0 CONCEPTUAL RESTORATION PLAN

3.1 OVERVIEW
Mitigation within the project area will consist of Restoration (Levels 1-4), Enhancement
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Prospectus

P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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(Levels 1 & 2) and Preservation of streams and their buffers upstream of restored and
enhanced areas. Riparian Buffer Restoration, and a holistic Stormwater Management Plan
will contribute to the CGMB project and improvements in water quality and habitat. The
Conceptual Mitigation Plan is attached as Exhibit A.

3.2 RESTORATION AND ENHANCEMENT
Restoration of streams and wetlands within the project area is being conducted based on
industry standard assessment techniques established by Rosgen/Wildland Hydrology,
North Carolina State Stream Restoration Institute and United States Army Corps of
Engineers. Assessment of channel dimension, pattern, and profile and natural channel
design concepts are being used for streams within the project area. Streams will be
designed to resemble and function as stable and natural streams and “reference”
conditions.

Wetland assessment and restoration is being conducted using the US Army Corps of
Engineers three parameter approach and restored wetlands will be designed to possess
wetland soils, a dominance of wetland plants, wetland hydrology and will mimic “reference”
wetlands found in similar settings on the Camp Grier property and nearby. Wetlands within
the project area have or will be delineated and flagged in the field before a formal Mitigation
Plan is submitted for the CGMB project. Confirmation of jurisdictional boundaries for
wetlands within the project area is requested before survey grade data is collected for the
project by a NC Licensed Surveyor.

It is assumed, based on observations made with in the project area that locations and
lengths of streams are not accurately portrayed as “blue lines” on USGS maps of the area
and other readily available sources of information. North Carolina Division of Water
Resources, Stream Identification Forms have been filled out for many of the streams within
the project area and the upstream jurisdictional extent of streams have been flagged in the
field for these streams (Exhibit D). Confirmation of the jurisdictional boundary for streams
within the project area is requested before survey grade data is collected for the project by
a NC Licensed Surveyor.

A large component of the restoration of streams that originate and flow through Camp Grier
property will be a holistic Stormwater Management Plan that will address developed
impervious surfaces within Camp Grier including gravel and soil roads and trails.
Preliminary assessment of the site suggests that many of the impacts to streams within the
project area and downstream are resulting from unmitigated stormwater inputs.

Approximately 6,800 linear feet of stream is proposed to be restored within the CGMB
project area. Stream restoration will include Priority 1, 2, 3, and 4 Options for restoring
incised and impaired channels. Restoration and Enhancement of CGMB streams will be
augmented by stormwater, sediment and erosion control, and agricultural Best
Management Practices/Stormwater Control Measures (SCMs) that will significantly reduce:
· Peak flows resulting from impervious surface runoff
· Warm water temperature inputs
· Sediment, nutrient, and biological inputs

Riparian buffers within the project area will be restored, enhanced, and preserved to a
minimum average width of 30 feet and much greater in many areas.

Undisturbed riparian buffers and streams above the project area are proposed to be placed
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Prospectus

P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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into permanent conservation and protected by the conservation easement for the project.
The conceptual plan for the entire project area is visible in Exhibit A.

JARRETT CREEK
Jarrett Creek from the Camp Grier property line to the confluence with Padgett Branch is
proposed to be restored by completing the following list of activities that are assumed to fall
within the Enhancement Level I category. Specifically, enhancement of Jarrett Creek is
proposed to include but may not be limited to:
· Installation of an in-stream structure that will reduce hydraulic stress on the river-
right streambank at the downstream bridge;
· Removal of historic concrete and piping debris from the stream channel and
streambanks near the upstream bridge;
· Enhancement of the riparian buffer, including purchase of adjacent property so that
the buffer can be expanded to greater than 150 feet width;
· Installation of engineered SCMs along Camp Grier Road;
· Adjustment to camber along Camp Grier Road to direct stormwater to SCMs.

The conceptual plan for Jarrett Creek and surrounding project area is visible on Sheet 2 of
Exhibit A. Jarrett Creek and Camp Grier Road are apparently located within a FEMA FIRM
Zone. Proposed enhancement activities are not anticipated to require a FEMA No-rise
Certification at this time in part because if this project is approved, the conservation
easement for the project will encompass the entire FIRM zone and will preclude further
encroachment and development.

LOWER PADGETT BRANCH
The lower reach of Padgett Branch (approximately 835 feet) is proposed to be restored by
what is best described as Priority 3 Restoration in combination with stormwater and
sediment and erosion control SCMs and riparian buffer enhancement (Sheet 3-Exhibit A).
Lower Padgett Branch is a steep “A” stream type with natural bedrock and boulder grade
control throughout (Exhibit E). A majority of Lower Padgett Branch is clogged with rock
debris from road building activities associated with Camp Grier Road. The clogged
channel appears to have increased hydraulic stress on the river-right side streambank
which is causing erosion and bank failure (Exhibit C). The stream is further impaired by
warm, unmitigated, sediment laden stormwater that originates from Camp Grier Road.

The section of Camp Grier Road that produces stormwater flowing to and impacting Lower
Padgett Branch will be modified to adjust camber, reduce its slope and direct stormwater to
multiple, sequenced SCMs designed to mitigate stormwater for the design
storm/precipitation event with an emphasis on infiltration. Rock debris is proposed to be
relocated to failing and higher stress areas of streambanks and strategically placed to
reduce near-bank hydraulic stress. Rock debris may also be carefully placed high on the
river-left streambank (talus slope from road building) or be removed from the channel and
project area altogether. The suspended culvert beneath Camp Grier Road is proposed to
be addressed to improve aquatic passage. A cool water release structure is proposed to
be installed in Camp Grier Lake. Please refer to Exhibit A for additional details about each
restoration area. Exhibit E contains preliminary existing condition cross-sections of Lower
Padgett Branch and Exhibit C contains photographs of this area.

TRIBUTARIES T1, T1A, T1B, T1C & T1D
Tributary T1 as it approaches Camp Grier Lake is proposed to be modified to include a
forebay to trap sediment before it enters Camp Grier Lake. Proposed forebays may be
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P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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held out of the project area depending on feedback from USACE, NC DWR, and the IRT.
Fencing along the northeast side of the Horse Pasture (river-right side T1) and other
development and infrastructure within a minimum 30-feet riparian area will be relocated
outside the buffer to allow buffer enhancement and restoration. Priority 2 and 3 restoration
options will be used in this area in combination with agricultural and stormwater SCMs.
Historic trout farming infrastructure, construction and landscaping debris, and a small dam
and sediment filled impoundment will be removed from Tributary T1A. Finally, a
suspended culvert will be addressed at the upper road crossing over Tributary T1A to allow
for improved aquatic passage. Above restoration areas, streams associated with Tributary
T1 will be enhanced (Level 2) and preserved through the establishment of permanent trail
crossings through stream buffers and over streams, installation of stormwater SCMs
associated with the trails and historic soil roads, and recordation of the conservation
easement and MBI for the CGMB project. Please refer to Sheets 8 and 9 in Exhibit A.

UPPER PADGETT BRANCH AND TRIBUTARIES T2, T2A & T2B
The riparian buffer is proposed to be restored and enhanced along Upper Padgett Branch
these tributaries to a minimum width of 30 feet. The main stem of Upper Padgett Branch is
proposed to be addressed using Priority 1 and 2 Restoration Options. Implementation of
stormwater and Sediment and Erosion Control SCMs, realignment and camber/sloping of
Camp Grier Road, and riparian buffer creation and enhancement will contribute to the
restoration and presumably qualify as Enhancement Level 2 for areas upstream of
restoration areas. A forebay is proposed just upstream of Camp Grier Lake in order to trap
sediment before it enters the lake. Additionally, historic, sediment filled, impoundments
and small dam structures will be removed from the main stem and tributaries of Upper
Padgett Branch. Impoundment locations are shown on Sheets 4 and 5 of Exhibit A and in
the photos within Exhibit C.

Priority 2 and 4 Restoration Options are proposed along Tributaries T2, T2A and T2B (See
Sheets 4 and 10-Exhibit A). Suspended culverts located beneath Camp Grier Road and
access roads to the Maintenance Building and Caretakers House are proposed to be
addressed by the restoration. Removal of a small dam structure and impoundment are
proposed from Tributary T2. Stormwater SCMs are proposed for the Caretaker Cabin,
Maintenance Building, Camp Grier Road and the other impervious areas that drain to the
area. Wetland restoration is proposed at the upstream end of Tributary T2A in an area
impacted by historic trout farming infrastructure. Above the restoration areas streams are
proposed to be enhanced (Enhancement Level 2) and preserved through the establishment
of permanent trail crossings, installation of stormwater SCMs, and recordation of the
conservation easement and MBI for the project.

UPPER PADGETT BRANCH AND TRIBUTARIES T3 & T3A
Tributary T3 is proposed to be restored using a Priority 2 Restoration Option from its
confluence with Padgett Branch upstream for approximately 300 feet to the access road for
Main Camp (Sheets 5 and 12-Exhibit A). Two suspended culverts beneath Camp Grier
Road and the Main Camp access road are proposed to be addressed as part of the
restoration. Stormwater SCMs associated with the buildings, roads and infrastructure on
the east side of Main Camp will contribute to the restoration.

The reach of Tributary T3 extending upstream from the restoration area to a location just
upstream of a cabin visible on Sheet 12 of Exhibit A is proposed to be enhanced (Level 1)
through riparian buffer restoration and stormwater SCMs associated with impervious
infrastructure. Above the cabin, Tributary T3 is proposed to be enhanced (Level 2) and
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P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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preserved by establishment of permanent trail crossings, installation of stormwater SCMs
for trails, and the conservation easement and MBI for the project.

TRIBUTARIES T4, T4A, AND T5
Tributaries T4 and T5 are proposed to be restored using a Priority 2 Restoration Option in
combination with riparian buffer establishment and stormwater SCMs. Restoration is
proposed from the tributaries’ confluences with Padgett Branch upstream to Camp Grier
Road. Enhancement Level 2 is proposed on Tributary T5 from Camp Grier Road to the
jurisdictional stream boundary. Enhancement Level 2 is proposed on Tributary 4 from
Camp Grier Road to the furthest upstream trail crossing. Preservation is proposed from
this trail crossing to the jurisdictional boundary for the stream and is shown on Sheet 13 of
the Camp Grier Conceptual Mitigation Plan.

UPPER PADGETT BRANCH AND TRIBUTARIES T6, T7, AND T8
The upstream end of Padgett Branch appears to flow near to and possibly beyond the east
property line with USDA forest service land. Until surveyed boundary information is
available for this area, it is unclear whether the entire reach of Padgett Branch, or enough
of its stream buffer exists on Camp Grier property for this area to be included in the project.
Regardless, Enhancement Level 2 of Tributaries T6, T7, and T8, through the stormwater
management associated with cabins, roads and trails that drain to the tributaries, are
proposed as part of the CGMB project. Reaches of stream above enhancement areas are
proposed to be preserved by the conservation easement and Mitigation Banking Instrument
(MBI) for the project.

TRIBUTARIES T9, T10, & T11
Tributaries T9, T10 and T11 that drain to Camp Grier Lake and Padgett Branch from the
east from USDA National Forest land will be preserved by the conservation easement and
Mitigation Banking Instrument for the project.

3.2.1 WETLAND RESTORATION AND CREATION
Restoration of wetlands within the project area will include restoration of the wetland area
associated with Tributary T2 described above. Creation of wetlands within the project area
will consist of stormwater SCMs associated with impervious roads, buildings and
infrastructure that drain to the Camp Grier Mitigation Bank project area, and the restoration
of the existing Upper Padgett Branch.

4.0 PROPOSED MONITORING PLAN
The Monitoring Plan for Camp Grier Mitigation Bank will be developed to demonstrate that
the site is trending toward success and will meet the goals of the Mitigation Plan. The
Monitoring Plan will adhere to the Monitoring and Performance Standards for
Compensatory Mitigation in North Carolina document produced by the North Carolina
Interagency Review Team-February 8, 2013 or more recent guidance specified by the
Interagency Review Team (IRT) for this project as triggered by the submittal of this
prospectus document in order to meet 33 CFR part 332 (Mitigation Rule).

4.1 GENERAL REQUIREMENTS
Site monitoring will occur for a period of seven years. It is understood that if performance
standards have not been met by year seven additional monitoring may be required.
Monitoring reports will be completed annually for all seven years and will be submitted to
USACE by April 1 of the year following the monitoring. Monitoring reports will be prepared
and formatted per Regulatory Guidance Letter (RGL 08-03).
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As-built surveys and information will be completed within 60 days following construction of
the CGMB project in order to document baseline conditions. As-builts will include but may
not be limited to: photo documentation of all cross-sections and structures, plan view
diagrams, longitudinal profiles, vegetation information, and the location of all monitoring
activities. As-builts will not be provided for Preservation-only portions of the project area.

4.2 Planted VEGETATION MONITORING
Vegetation plots will be monitored for seven years with monitoring events on years 1-3, 5
and 7. Vegetation planting and replanting will be conducted between November 15 and
March 15. Vegetation monitoring will be conducted between July 1 and leaf drop. Planted
vegetation will be in the ground for no less than 180 days before the first year of monitoring
on Year 1.

Vegetation plots will be randomly located across the site to provide random sampling of all
the vegetation community types reestablished at the site. Vegetation monitoring will follow
the 16-step procedure outlined in the Monitoring and Performance Standards for
Compensatory Mitigation in North Carolina requirements specified in Section V, A-
Vegetation Planting and Monitoring Requirements and Section V B-Planted Vegetation
Performance Standards

4.3 STREAM CHANNEL STABILITY AND HYDROLOGY MONITORING
Stability and Hydrology Monitoring will be conducted per the Monitoring and Performance
Standards for Compensatory Mitigation in North Carolina Section VI in order to show that
proposed in-stream work has corrected channel bed and bank instability for areas of the
site where instability is identified as a primary objective in the Mitigation Plan and for areas
where instream work changes channel dimension below bankfull elevation.

Channel stability will be monitored for seven years. Reference stakes marking surveyed
stations and corresponding as-built survey and longitudinal profile will be installed in the
buffer near the stream bank every 100 feet along the stream.

Permanent, monumented cross-sections will be installed at an approximate frequency of
one per 20 bankfull widths measured along the thalweg.

Monitored cross-sections located in stream bends will include an array of bank pins per the
referenced guidance. Lateral movement of the streambanks as indicated by pin exposure
will be reported in all monitoring reports.

Crest gauges will be installed to document bankfull events. At least one gauge will be
installed on each tributary greater than 500 feet in length. One gauge will be installed for
every 5,000 feet of length on each tributary.

Stream Channel Stability and Stream Hydrology Performance Standards outlined in Section
VI ,B of the referenced guidance will be followed. Jurisdictional stream determinations will
be requested before the Mitigation Plan is complete.

4.3 STREAM WATER QUALITY AND MACROINVERTEBRATE MONITORING
As with other stream monitoring described above water quality and macro-benthos
monitoring will comply with Monitoring and Performance Standards for Compensatory
Mitigation in North Carolina and specifically with Section VII of the referenced standards.
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P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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Water quality sampling will be conducted prior to construction and twice a year throughout
the monitoring period. Sampling will include measurements of pH, temperature, dissolved
oxygen, and conductivity. Biological and nutrient monitoring will also be monitored in an
effort to show a reduction in coliforms and nutrients.

Each tributary longer than 500 feet will be sampled at two locations, one near the upstream
and one near downstream end of the reach.

Water quality sampling will be conducted during normal flow conditions 48 hours or longer
after any precipitation event totaling one inch or greater as determined by nearby weather
stations or on-site rain gauges.

Macroinvertebrate sampling will be conducted prior to construction and once a year during
monitoring years three, five, and seven. Sampling will be conducted on tributaries greater
than 1000 feet in length. Sampling points will be located on riffles with the first point located
on the lowest riffle of the tributary.

A reference location will be sampled for comparison and will be located in an on-site
preservation reach or upstream of the project area. All samples will be collected in
accordance with the Qual 4 protocol described in Standard Operation Procedures for
Collection and Analysis of Benthic Macroinvertebrates by a qualified professional. Water
quality and macroinvertebrate sampling will be conducted during the same time of year and
within the index period specified in the NC DWR Small Streams Biocriteria Development
document (May 29, 2009). Samples will be identified to the lowest practical taxonomic level
by a NC DWR certified laboratory for macroinvertebrates.

5.0 BANK OPERATION
The subject property is currently owned by Camp Grier 501(c) (3) and the project area has
not been encumbered by a conservation easement. A conservation easement does exist
on Camp Grier Property to the west of the project area (Exhibit A-Sheet 1). The existing
conservation easement in combination with the proposed CGMB conservation easement
will protect all jurisdictional water on the 650 acre parcel with the exception of Camp Grier
Lake. Camp Grier will serve as the legal entity and Bank Sponsor for the purposes of the
CGMB project. Camp Grier, the Town of Old Fort, and the USDA Forest Service are the
only entities that have any control of streams, wetlands, and infrastructure affecting the
hydrology of the site. The CGMB project team, consists of licensed geologists, professional
engineers, planners, and surveyors who have extensive experience in water resource and
riparian restoration projects. In addition, the Sponsor employs staff that hold degrees in and
have professional experience with business, finance, law ecology, forestry, and natural
resource management. Together, the project team possess the necessary credentials to
execute the proposed project such that it meets the goals that will be further outlined in the
Mitigation Plan for the project. Some of the site evaluations (e.g. soil survey, stream and
wetland delineations, and conceptual planning and design) have been completed for the
site. However, a more detailed stream assessment, additional survey, design, and
engineering work will be necessary for the development of the Mitigation Plan. A MBI will
also be developed and submitted prior to completion of the Mitigation Plan and project
construction.

Upon acceptance of the final Mitigation Plan by the IRT, the Bank Sponsor will initiate
proposed construction activities for the development of the CGMB site. Mitigation bank
Camp Grier Mitigation Bank September 13, 2017
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P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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credits are proposed to be calculated using the following standard:

Mitigation Type Unit Unit of Treatment:Credits

Stream Restoration feet 1:1

Wetland Restoration/Creation 0.25 acre 1:1

Stream Enhancement (Level I) feet 1.5:1

Stream Enhancement (Level II) feet 2.5:1

Stream Preservation feet 4:1

Mitigation credits generated by CGMB will be used to offset wetland and stream impacts
authorized by federal permits or state water quality certifications that are in compliance with
the Clean Water Act, Section 404 (b)(1) guidelines and other applicable federal and state
legislation, regulations, and policies. Prior to release of CGMB credits, the following
requirements will be met: (1) approval of the final Mitigation Plan and execution of the MBI;
(2) securing the bank site; and (3) establishment of appropriate financial assurances.

Assuming the aforementioned ratios for stream and wetland: restoration, enhancement,
and preservation are accepted and considering BCF adjustments, it is estimated that at
least approximately 11,906 stream credits and 2 wetland credits will be generated through
the establishment of the Camp Grier Mitigation Bank. It is assumed that the Bank Sponsor
may choose to initiate construction of the project in two separate phases if market demand
is deemed to be insufficient during the initial stages of development. A tentative Schedule
for establishment of the bank site is outlined below.

Upon execution of the MBI, a conservation easement deed for the site will conveyed to an
appropriate public land trust organization such as Foothills Conservancy. The terms and
conditions of the conservation easement will ensure the protection of the site in perpetuity.
The ownership of the Bank will reside with the Sponsor until completion of the debiting of
the Bank. The Sponsor is currently negotiating with several registered and/or certified land
trust organizations to serve as the holder of the conservation easement. The holder of the
conservation easement will be responsible for long-term protection and management of the
site. The easement will prohibit any activities (e.g. timbering, farming, building, etc.) that
would alter the environmental state of the Bank site. Conditions of the easement are
proposed to not restrict passive recreational, educational, and/or research activities.

The Bank Sponsor will be responsible for securing appropriate financial assurances in the
form of construction, monitoring, and maintenance bonds to cover contingency measures in
the event of Bank default or failure. Performance monitoring will be conducted for a 7-year
period subsequent to project construction. Annual monitoring will evaluate the
development of stream function and document site performance relative to established
success criteria. In addition, monitoring activities will identify any site deficiencies that may
warrant remedial action. Monitoring reports documenting site success and/or failure will be
submitted to the IRT each year. Upon submittal of annual monitoring reports
demonstrating the fulfillment of site success criteria, stream credits will be released
according to an approved credit release schedule. The table below outlines proposed
information on project timeline and credit release schedule.
Camp Grier Mitigation Bank September 13, 2017
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P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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Proposed Credit Release Schedule
Task Percentage of Credits
Released
(cumulative)
Date of Completion
Execution of MBI;
Approval of Final
Mitigation Plan;
Recordation of
Conservation
Easement
15 (15) December 2017
Completion of all
Restoration
Activities
15 (30) December 2018
Monitoring Plan
Year 1 Monitoring
(post-construction)
10 (40) September 2019
Year 2 Monitoring
(post-construction)
10 (50) September 2020
Year 3 Monitoring
(post-construction)
10 (60) September 2021
Year 4 Monitoring
(post-construction)
10 (70) September 2022
Year 5 Monitoring
(post-construction)
10 (80) September 2023
Year 6 Monitoring
(post-construction)
10 (90) September 2024
Year 7 Monitoring
(post-construction)
10 (100) September 2025
TOTAL 100

The Sponsor shall develop accounting procedures for maintaining accurate records of
debits made from be Bank that is acceptable to the IRT. Such procedures shall include
the generation of a debit report by the sponsor documenting all credits used at the time
they are debited from the bank. Debit reports shall be provided to each member of the
IRT within 30 days of the date of credit sale. In addition, the Sponsor shall prepare an
Annual Report to be provided to each IRT member within thirty (30) days of each
anniversary of the date of execution of the MBI, showing all credits used and the balance
of credits remaining. The Sponsor's reporting obligations hereunder shall end upon the
sale of all credits or termination of the MBI, whichever event first occurs.

6.0 CONCLUSION
The proposed restoration, enhancement, and preservation activities at CGMB will
provide tangible benefits to both water quality and habitat within a watershed that has
Camp Grier Mitigation Bank September 13, 2017
Prospectus

P.O. Drawer 870 ▪ Kitty Hawk, NC 27949
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been degraded by decades of silvicultural and poor land management. These benefits
will be realized through:
· Implementation of an engineered holistic Stormwater Management Plan and
installation of Stormwater Control Measures for the entire developed area of the
property;
· Stabilization and restoration of streams and streambanks;
· Restoration of riparian corridors within the project area;
· Stewardship of the land by an accredited Land Trust or Conservancy.

8.0 SOURCES OF INFORMATION
· Ecoregions Map of North Carolina (Griffith, G.E., Omernik, J.M., Comstock, J.A.,
Schafale, M.P., McNab, W.H., Lenat, D.R., and MacPherson, T.F., 2002,
Ecoregions of North Carolina, U.S. Environmental Protection Agency, Corvallis,
OR, (map scale 1:1,500,000))
· CLASSIFICATION OF THE NATURAL COMMUNITIES OF NORTH CAROLINA
THIRD APPROXIMATION (Schafale, M.P. and A.S. Weakley. 1990, NC Natural
Heritage Program, Raleigh, NC.)
· CUSTOM SOIL RESOURCE REPORT FOR MCDOWELL COUNTY, NORTH
CAROLINA (Natural Resources Conservation Service, September 13, 2017)
· Additional sources as listed on Exhibits.

Camp Grier Mitigation Bank September 13, 2017
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9.0 EXHIBITS

A Camp Grier Conceptual Mitigation Plan, Sheets 1 through 15, dated
September 13, 2017
B Custom Soil Resource Report for McDowell County, North Carolina
C Prospectus Photos of Existing Conditions, dated August 28, 2017
D Stream and Wetland Data Forms
E Existing Stream Classification Exhibit, Sheets 1 through 2, dated September
13, 2017