20180665 Ver 1_ eApproval SAW-2018-00451_20190905

Strickland, Bev
From:
Browning, Kimberly D CIV USARMY CESAW (US)
<[e-mail]>
Sent:
Thursday, September 05, 2019 2:23 PM
To:
Baumgartner, Tim
Cc:
Wiesner, Paul; Tsomides, Harry; Aaron Earley; Shawn Wilkerson; Tugwell, Todd J CIV
USARMY CESAW (US); Haupt, Mac; Davis, Erin B; Steve Kichefski; Matthews, Monte K
CIV USARMY CESAW (USA); McLendon, C S CIV USARMY CESAW (USA); 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
Subject:
[External] eApproval Letter NCDMS/ Alexander Farm Site/ Alexander County/
SAW -2018-00451 (UNCLASSIFIED)
Attachments:
Draft Mit Plan Comment Memo -Alexander Farm_2018-00451.pdf, eApproval
Letter -Alexander Farm_SAW-2018-00451.pdf
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CLASSIFICATION: UNCLASSIFIED
Mr. Baumgartner,
Attached is the Draft Alexander Farm 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.
Very Respectfully,
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

Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
September 5, 2019
Re: NCIRT Review and USACE Approval of the NCDMS Alexander Farm Site / Alexander County /
SAW -2018-00451; NCDMS Project # 100048
Mr. Tim Baumgartner
North Carolina Division of Mitigation Services
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 Alexander Farm Draft Mitigation Plan, which closed on August 16,
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,
Digitally signed by
BROWN INGAMBERLY. BROWNING.KIMBERLY.DANIELLE.
DAN I ELLE.1527683510 1527683510
Date: 2019.09.05 14:19:55 -04'00'
Kim Browning
Mitigation Project Manager
for Tyler Crumbley
Enclosures
Electronic Copies Furnished:
NCIRT Distribution List
Paul Wiesner, Harry Tsomides– NCDMS
Shawn Wilkerson, Aaron Earley—WEI

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