20171156 Ver 1_Draft Mit Plan Comment Memo_20190712

Strickland, Bev
From:
Browning, Kimberly D CIV USARMY CESAW (US)
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Sent:
Friday, July 12, 2019 1:26 PM
To:
Tugwell, Todd J CIV USARMY CESAW (US); Haupt, Mac; Davis, Erin B; Bowers, Todd;
Wilson, Travis W.; [e-mail]; Homewood, Sue; Steve Kichefski; Leslie,
Andrea J; Wicker, Henry M Jr CIV USARMY CESAW (US); McLendon, C S CIV USARMY
CESAW (US); Merritt, Katie; Jones, M Scott (Scott) CIV USARMY CESAW (US);
Fuemmeler, Amanda J CIV (US)
Cc:
Wiesner, Paul; Reid, Matthew; Kayne Vanstell
Subject:
[External] Notice of Intent to Approve NCDMS Horne Creek Tributaries / Surry County
/ SAW -2017-01510 (UNCLASSIFIED)
Attachments:
Draft Mit Plan Comment Memo -Horne Creek_2017-01510.pdf
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CLASSIFICATION: UNCLASSIFIED
Good afternoon,
We have completed our review of the Draft Mitigation Plan for the NCDMS Horne Creek Tributaries Mitigation Project
(SAW -2017-01510). Please see the attached memo, which includes all NCIRT comments that were posted on the DMS
SharePoint site during the review process along with additional comments provided by Wilmington District staff
following our review of the IRT comments.
We have evaluated the comments generated during the review period, and determined that the concerns raised are
generally minor and can be addressed in the final mitigation plan. Accordingly, it is our intent to approve this Draft
Mitigation Plan (contingent upon the attached comments being addressed in the Final Mitigation Plan) unless a member
of the NCIRT initiates the Dispute Resolution Process, as described in the Final Mitigation Rule (33 CFR Section 332.8(e)).
Please note that initiation of this process requires that a senior official of the agency objecting to the approval of the
mitigation plan (instrument amendment) notify the District Engineer by letter within 15 days of this email (by COB on
July 26, 2019). Please notify me if you intend to initiate the Dispute Resolution Process.
Provided that we do not receive any objections, we will provide an approval letter to NCDMS at the conclusion of the 15 -
day Dispute Resolution window. This approval will also transmit all comments generated during the review process to
NCDMS, which must be addressed in the Final Mitigation Plan to be submitted with the Preconstruction Notification
Application for NWP 27. All NCIRT members will receive a copy of the approval letter and all comments for your records.
Thank you for your participation.
Kim Browning
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers
3331 Heritage Trade Dr, Ste. 105 1 Wake Forest, NC 27587 1 919.554.4884 x60

BUILDING STRONG (r)
CLASSIFICATION: UNCLASSIFIED

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
REPLY TO
ATTENTION OF:
CESAW-RG/Browning
MEMORANDUM FOR RECORD
July 12, 2019
SUBJECT: Horne Creek Tributaries Mitigation Site - NCIRT Comments during 30 -day Mitigation Plan Review
PURPOSE: The comments listed below were posted to the NCDMS Mitigation Plan Review Portal during the
30 -day comment period in accordance with Section 332.8(g) of the 2008 Mitigation Rule.
NCDMS Project Name: Horne Creek Tributaries Mitigation Site, Surry County, NC
USACE AID#: SAW -2017-01510
NCDMS #: 100026
30 -Day Comment Deadline: June 21, 2019
DWR Comments:
1. Section 3.1.4- Benthic Macroinvertebrates- DWR appreciates WLS performing the preconstruction
monitoring for benthic macroinvertebrates. DWR looks forward to the results of post construction
monitoring.
2. Table 14: please explain the differing measurement methodologies referred to in note 2.
3. Section 6.4- DWR likes the attention paid to wetlands on the site even though there are no wetland credits
proposed for this project. In these cases, DWR is mostly concerned with maintaining the current wetland
resources on site and when possible, enhancing or restoring the wetland resources on site.
4. Section 6.7- Water Quality Treatment Features- While DWR appreciates the installation of these features,
their placement above reach R3 may negatively affect the flow for this intermittent stream.
5. In the Monitoring Section, there is no mention of macrobenthic monitoring. Does WLS intend to monitor
macrobenthics during the monitoring phase and if so, what is your general protocol?
6. Design sheet 3- DWR would prefer to see specific bank slopes identified on the typicals. We realize these
slopes may vary, however; we would prefer to see the slopes specified even if they are "on average".
7. DWR believes that reaches R2 and R3 are at a high risk to lose flow or not have enough flow to maintain
stream characteristics.
8. Design sheet 10- DWR would like to seethe flow gauge moved to station 12+00 on reach R2.
9. While DWR will not require a flow gauge on reach R3, this reach should probably have at least a camera
to document flowing conditions.
10. Design sheet 11- is the crossing on this sheet existing? One concern is it shows the crossing going through
a wetland. DWR recommends this crossing be eliminated. In addition, three stream segments (R4, R4a
and R4b) will be constructed in or immediately adjacent to wetlands. DWR recommends installation of a
gauge at station 22+00 on R4 on stream left. If the crossing is not removed, DWR will want a plan on
how the designer will maintain no net loss of wetlands on site.

11. Looking at the photos of reach R4a, particularly at the downstream reach and its confluence with R4, there
does not appear to be a need for any channel construction. Please substantiate why channel construction
is needed in this area.
Kim Browning, USACE:
1. R2 and R3 have very small watersheds, concern about maintaining flow and jurisdiction. Recommend
camera points and flow gauges here.
2. Design Sheet 10: It appears that there are three BMPs within the easement. Please ensure that these
features are not in the jurisdictional areas as it is unclear on the maps and design sheets, and that their
short-term maintenance is discussed in the text, if any is necessary.
3. Even though there are no wetland credits being sought, and existing wetlands are fairly small, the
restoration of reach 4 appears to run through WD. Please ensure that permanent impacts to these wetlands
during construction do not result in loss of function, though it is anticipated that overall wetland function
will improve from increased hydrology in this area. It's recommended that a temporary veg plot be placed
in this area.
4. It would be helpful to depict photo points on Figure 9.
5. Section 4.1.2 Functional Uplift Potential and Table 11: The functional pyramid is cited to show existing
conditions for each category, and was used to describe the functional uplift potential of the project,
which is appreciated. Please note that the functional pyramid and SQT tool have not been approved for
use by the IRT in determining success for mitigation projects. It would be interesting to see the
correlation of the NCSAM assessment compared to the SQT throughout the project. Furthermore, three
of the reaches are already scored as FAR and the proposed condition is also FAR. Please justify the
functional uplift if the conditions are not changing.
6. Table 12 and Table 23: Hydraulics, the BHR goal should read not to exceed 1.2.
7. Page 41, last paragraph and Table 21: please ensure that red maple are not included in the planting plan.
8. Section 7.1: Stream Hydrology—"In addition to the two bankful flow events, two..." is confusing. It
should read four bankful events.
a. Jurisdictional Stream Flow: Please add a statement that intermittent streams should be added
requiring at least 30 -days consecutive flow within a calendar year.
b. Stream Profiles: The ER should be no less than 1.4 for B type channels.
c. Stream Horizontal Stability: It would be beneficial to have a specific measurement parameter, for
example, BHR and ER at any measured riffle cross-section should not change by more than 10%
from the baseline condition during any given monitoring interval.
9. Section 7.3: Please include a vigor standard for vegetation of 7 feet high in year five and 10 feet high in
year 7.
10. Did I miss the section on site constraints or potential risks?
11. Buffer Widths: Portions of R1, R2, and R5 do not meet the minimum buffer width of 30 ft. This is
approximately 11% of the total restored length, which exceeds the guidance allowing no more than 5%
of the total project length. Would the 11% change if you calculated the total project length, verses only
using the restored length? If the result is still over 5%, the buffer tool needs to be used. If the Buffer
Tool is used, please clearly show the loss or addition of credits in the Table 1 and 14.
a. The Buffer calculation table in the appendix, Table 1 and Table 14 all appear to have different
credit totals. Please clarify.
Digitally signed by
BROWN ING.KIMBERLY. BROWN INGXlMBERLY.DANIELLE.
DAN I ELLE.15276835101527683510
Date: 2019.07.12 13:18:06 -04'00'
Kim Browning
Mitigation Project Manager
Regulatory Division