20171156 Ver 1_USACE Correspondence_20190729

Strickland, Bev
From:
Browning, Kimberly D CIV USARMY CESAW (US)
<[e-mail]>
Sent:
Monday, July 29, 2019 12:29 PM
To:
Baumgartner, Tim
Cc:
Kayne Vanstell; Wiesner, Paul; Reid, Matthew; 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); Gledhill-earley, Renee
Subject:
[External] eApproval NCDMS Horne Creek Tributaries / Surry County /
SAW -2017-01510 (UNCLASSIFIED)
Attachments:
Draft Mit Plan Comment Memo -Horne Creek_2017-01510.pdf, eApproval
Letter -Horne Creek Tribs_SAW-2017-01510.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
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CLASSIFICATION: UNCLASSIFIED
Mr. Baumgartner,
Attached is the Horne Creek Tributaries Mitigation Plan approval letter and copies of all comments generated during
the project review. Please note that this letter approves the Draft Mitigation Plan provided that the Final Mitigation
Plan adequately addresses all comments on the attached memo. Please provide a copy of the Final Mitigation Plan
when you submit the Preconstruction Notice for the NWP 27. If no permit is required to construct the project, please
submit a copy of the Final Mitigation Plan to our office at least 30 days prior to beginning construction. Also, please
ensure that a copy of the Final Mitigation Plan is posted to the NCDMS project documents so that all members of the IRT
have access to the Final plan.
Please let me know if you have any questions about the process or the attached letter.
V/ R,
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

Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
July 29, 2019
Re: NCIRT Review and USACE Approval of the Horne Creek Tributaries Mitigation Plan; SAW -2017-
01510; NCDMS Project # 100026
Mr. Tim Baumgartner
North Carolina Ecosystem Enhancement Program
1652 Mail Service Center
Raleigh, NC 27699-1652
Dear Mr. Baumgartner:
The purpose of this letter is to provide the North Carolina Division of Mitigation Services
(NCDMS) with all comments generated by the North Carolina Interagency Review Team (NCIRT) during
the 30 -day comment period for the Horne Creek Tributaries Mitigation Plan, which closed on June 21,
2019. These comments are attached for your review.
Based on our review of these comments, we have determined that no major concerns have been
identified with the Draft Mitigation Plan, which is considered approved with this correspondence.
However, several minor issues were identified, as described in the attached comment memo, which must
be addressed in the Final Mitigation Plan.
The Final Mitigation Plan is to be submitted with the Preconstruction Notification (PCN)
Application for Nationwide permit approval of the project along with a copy of this letter. Issues identified
above must be addressed in the Final Mitigation Plan. All changes made to the Final Mitigation Plan
should be summarized in an errata sheet included at the beginning of the document. If it is determined
that the project does not require a Department of the Army permit, you must still provide a copy of the
Final Mitigation Plan, along with a copy of this letter, to the appropriate USACE field office at least 30
days in advance of beginning construction of the project. Please note that this approval does not preclude
the inclusion of permit conditions in the permit authorization for the project, particularly if issues
mentioned above are not satisfactorily addressed. Additionally, this letter provides initial approval for the
Mitigation Plan, but this does not guarantee that the project will generate the requested amount of
mitigation credit. As you are aware, unforeseen issues may arise during construction or monitoring of the
project that may require maintenance or reconstruction that may lead to reduced credit.

Thank you for your prompt attention to this matter, and if you have any questions regarding this
letter, the mitigation plan review process, or the requirements of the Mitigation Rule, please call me at
919-554-4884, ext 60.
Sincerely,
BROWN ING.KIMBERL Digitally signed by
Y.DANIELLE.1527683 BROWN ING.KIMBERLY.DANIELLE
.1527683510
510 Date: 2019.07.29 12:25:52 -04'00'
Kim Browning
Mitigation Project Manager
for Henry Wicker
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
Paul Wiesner– NCDMS
Matthew Reid—NCDMS
Kayne VanStell—WLS