20180665 Ver 1_Mitigation Plan Review_20190819

Strickland, Bev
From:
Browning, Kimberly D CIV USARMY CESAW (US)
<[e-mail]>
Sent:
Monday, August 19, 2019 10:28 AM
To:
Tugwell, Todd J CIV USARMY CESAW (US); Haupt, Mac; Davis, Erin B; Steve Kichefski;
Matthews, Monte K CIV USARMY CESAW (US); Wicker, Henry M Jr CIV USARMY
CESAW (US); McLendon, C S CIV USARMY CESAW (US); Crumbley, Tyler A CIV
USARMY CESAW (USA); Jones, M Scott (Scott) CIV USARMY CESAW (USA); Munzer,
Olivia; Wilson, Travis W.; Bowers, Todd; [e-mail]; Johnson, Alan
Cc:
Wiesner, Paul; Tsomides, Harry; [e-mail]; Aaron Earley
Subject:
[External] Notice of Intent to Approve/ Alexander Farm Site / Alexander County/
SAW -2018-00451 (UNCLASSIFIED)
Attachments:
Draft Mit Plan Comment Memo -Alexander Farm_2018-00451.pdf
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CLASSIFICATION: UNCLASSIFIED
Good morning all,
We have completed our review of the Draft Mitigation Plan for the NCDMS Alexander Farm Mitigation Project (SAW -
2018 -00451). Please see the attached memo, which includes all NCIRT comments that were received during the review
process.
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
September 2, 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
August 19, 2019
SUBJECT: Alexander Farm Mitigation Site - NCIRT Comments during 30 -day Mitigation Plan Review
PURPOSE: The comments listed below were received during 30 -day comment period in accordance with
Section 332.8(g) of the 2008 Mitigation Rule in response to the Notice of NCDMS Mitigation Plan Review.
NCDMS Project Name: Alexander Site, Alexander County, NC
USACE AID#: SAW -2018-00451
Q nyZA1 11 Ian
30 -Day Comment Deadline: August 16, 2019
DWR Comments, Mac Haupt and Erin Davis:
1. DWR accepts the credit ratios proposed in the April 16, 2018 Memorandum.
2. There are numerous wetland areas on site and DWR would propose to Wildlands that they extend out the
easement to contain rest of wetland `B" and all of wetland "P".
3. In addition, there are two areas where the designed stream is being built through wetlands and DWR
requires a wetland gauge at the following locations:
a. Design sheet 2.1.4 - station 116+00 stream right, and
b. Design sheet 2.1.10 —station 142+25 stream right
4. DWR appreciates the work done on reach UTIA, Design Sheet 2.2.1, and the rock cascade on Design
sheet 2.3.1.
5. Were drain tiles found at the downstream end on the left floodplain? And if so, were the drain tiles
eliminated?
USACE Comments, Kim Browning:
1. The USACE ID for the cover page and page (i) is SAW -2018-00451.
2. It was noted that future logging adjacent to the preservation area is planned and that an additional 30'-50'
buffer setback will be implemented to filter runoff. Please provide more information and analysis
regarding potential future development and possible encroachment around the site (such as easement or
culvert maintenance), and how you propose to address these concerns, and how they may affect the
easement.
a. Who will be responsible for the culvert maintenance? Please specify in LTM plan.
3. Section 5.3 and Table 7: There are several reaches of stream restoration proposed (1B, 4A, 413) that will
impact existing wetlands. Please describe how you will ensure that no functional loss/loss of waters
occurs. Specifically, will the 0.17 acres of permanent impacts be recuperated adjacent to the newly raised

stream channel through Priority 1 restoration? Additionally, there appear to be several more wetlands
shown on the JD Map that are not captured on Figure 9.
a. It would be beneficial to add some coarse woody debris to the depressional areas and throughout
the adjacent wetlands for habitat, and to help store sediment, increase water storage/infiltration,
and absorb water energy during overbank events.
4. The IRT site walk indicated that several pockets of adjacent wetlands were present and should be included
within the easement. It appears that there are a few small wetlands that are not included in the easement
boundary, please explain, especially if cattle will have access to these areas and cause potential future
runoff impacts to the buffer.
a. The IRT also noted that wetland gauges should be installed to collet pre -data. Was this conducted?
If so please explain and note on the monitoring map (figure 10).
5. Design Sheets: Regarding stream crediting, the USACE Mitigation Credit Calculation Memo released
October 5, 2017, states "When existing stream length measurements are conducted for the purposes of
determining credit during mitigation plan development (e.g., measuring existing enhancement or
preservation reaches), the center of the wetted perimeter (using base flow conditions) should be
used....For restoration reaches or any other approach where the stream will be built in a new location,
credit amounts should be based on the center of the designed channel as shown in the plan sheet."
a. It's difficult to discern at the scale shown, but for the restoration reaches downstream of the
preservation reach, it appears that the thalweg was used. The restoration reaches should be based
on the center of the newly designed channel, not on the thalweg as currently shown on the plan
maps.
b. Stream lengths and credit calculations should be revised based on the above.
6. It would be helpful to depict photo points/digital image stations on Figures 10. If the fixed cross-section
locations are to be used, please describe that in the text.
7. Section 4.4 and 7.6.7: An agricultural BMP is planned within the easement; please describe any
maintenance required, if applicable.
8. Please discuss how fescue will be treated in conjunction with buffer establishment.
9. Section 8.2: Please remove the statement regarding terminating veg monitoring if performance standards
are met early. Monitoring should occur for 7 years. Also, please list the proposed planting timeframe in
Section 7.7.
10. General comment: In the future, when NCSAM or other functional assessment methods are used, please
describe the results summary in the text.
11. Appendix 5: It is beneficial to review the categorical exclusion documents prior to receiving the final
mitigation plan. Please include an estimate of trees to be cleared in the PCN in relation to NLEB habitat.
12. Appendix 11: NCDMS has recently requested that all previously mentioned As -Built reports will now be
referred to as Record Drawing. Please verify this with DMS and correct as advised.
13. ATV paths were mentioned in the text on UTI Reach 3. I understand that the landowner was advised that
these paths will not be accessible for ATV use, but will these paths remain and be maintained? If so, please
describe, and depict on Figure 9/10.
BROWNING.KIMBER Digitally signed by
LY.DANIELLE.15276 BROWNING.KIMBERLY.DANIELLE.
1527683510
83510 Date: 2019.08.19 10:19:16 -04'00'
Kim Browning
Mitigation Project Manager
Regulatory Division