20081143 Ver 1_Mitigation Plan Review_20070427

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April 11, 2007
Mr. Andrew Williams
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
6508 Falls of Neuse Road, Suite 120
Raleigh, NC 27615
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Re: Comments on Proposed Stream and Wetland Mitigation Project
Cripple Creek Mitigation Bank
Alamance County, NC
USACE Action ID No. SAW-2007-01188-201
Dear. Mr. Williams:
On March 23, 2007, Eric Kulz and Tammy Hill with the Division of Water Quality (DWQ) 401
Oversight and Express Review Permitting Unit attended an on-site meeting at the proposed mitigation
site to make observations and to discuss the project with Restoration Systems, LLC and other regulatory
agencies making up the Mitigation Bank Review Team (MBRT).
Based on the site visit and the Prospectus provided for the proposed project, our comments are as
follows:
• In general, the site appears to be a good candidate for restoration/enhancement activities. Both
the impacted wetlands and streams would benefit from the proposed mitigation activities.
DWQ recommends a tree survey of the project site to identify individual hardwood trees that
could potentially benefit the restoration processes through input of organic matter into the system
and providing a native seed source to support natural succession processes on the site. Policies
currently in place and under development from DWQ target hardwood trees that are five inches
DBH or greater as providing an ecological benefit to the stream and are part of an established
and functioning riparian zone. Efforts should be made to preserve as many of these trees as
possible.
DWQ recommends harvesting native bed material from the stream for use in the restored stream
channel. Despite the fact that the channel has been straightened and areas of bank erosion and
incision are present, well-developed cobble riffles are present at a number of locations. As much
of this material as possible should be harvested for use in the riffles of the restored channel.
NOnethCaro na
- atura?t?
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / Fax [phone]
Internet: http://h2o.enr.state.nc.us/ncwetlands
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
Mr. Andrew Williams
' U.S. Army Corps of Engineers
Cripple Creek Mitigation Bank
Page 2
• A strategy for invasive/exotic plant management should be included in the Mitigation Plan for
the site.
• Information on possible land use changes within the project watershed should be collected and
considered in the design of the stream.
• The credit release schedule proposed in the Prospectus is not consistent with the Stream Credit
Release Schedule presented as Appendix IX of the Stream Mitigation Guidelines (April 2003 -
U.S. Army Corps of Engineers, Wilmington District; U.S. Environmental Protection Agency;
N.C. Wildlife Resources Commission; and N.C. Division of Water Quality).
DWQ supports interagency discussion involving a revision of the credit release schedule that
applies to all new mitigation banks. However, DWQ does not support case-by-case modification
of the release schedule based on "track record" of the bank providers or other such subjective
criteria.
If an overall policy dictating a revised credit release schedule is developed and implemented by
the participating agencies, then such a schedule can be included in the Mitigation Banking
Instrument for this project, and can be used for this site. Otherwise, DWQ recommends that the
stream credit release schedule adhere to the Stream Mitigation Guidelines.
Please feel free to contact Eric Kulz or me at [phone] if you have any questions regarding this
project or our comments.
Sincerely v
7 /?
Cyndi B. Karoly, Program Manager
401 Oversight and Express Review Program
Cc: File Copy (Eric Kulz)
Tammy Hill
Daryl Lamb - WSRO
Central Files
NorhCaro ina
latUM1111
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / Fax [phone]
Internet: htto://h2o.enr.state.nc.us/ncwetlands
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper
Cripple Creek Mitigation Bank
3
Subject: Cripple Creek Mitigation Bank
From: [e-mail]
-Date: Fri, 27 Apr 2007 09:38:45 -0400
To: [e-mail]
CC: [e-mail], [e-mail], [e-mail],
[e-mail], [e-mail]
April 27, 2007
Andy,
This provides informal comments on the proposed Cripple Creek Stream and
Wetland Mitigation Bank in Alamance County. I say informal because the
thoughts are mine, but represent the positions I would recommend to Pete
Benjamin, our Field Supervisor.
I have reviewed the Mitigation Prospectus and Mitigation Plan, both
dated March 2007. I also attended the site review on March 23, 2007.
The bank site includes approximately 19.1 acres with 3,782 linear feet
of stream characterized as an unnamed tributary to Boyd Creek which is
within the Cape Fear River Basin. The project site serves a watershed
of four-tenth of a square miles (256 acres). The plan calls for stream
restoration and Level II enhancement of 4,300 and 142 linear feet,
respectively. This would create 4,357 stream mitigation units. The
effort also involves riverine wetland restoration and enhancement of 5.9
acres and 1.5 acres, respectively. Non-riverine wetland restoration and
enhancement would occur on 1.2 and 0.6 acres, respectively. overall,
the bank sponsor seeks 8.15 wetland mitigation units.
Bank Location in Landscape
The Service notes that the project area flows directly into a downstream
impoundment. While the bank seeks to improve water quality and enhance
flood attenuation, these benefits in Boyd Creek and Haw River watershed
will probably continue to be influenced more by the impoundment and any
release schedule from the dam. There would appear to be limited
opportunities for upstream mitigation of aquatic organisms from below
the dam or downstream migration from the bank site to Boyd Creek and
beyond. However, I recognize that there are opportunities to establish
on-site habitat for wildlife and aquatic organisms. While the
impoundment limits the geographic scope of benefits derived from the
bank, at this time I do not think the impoundment precludes
establishment of the proposed bank.
Stream Restoration/enhancement
The stream restoration plan (Section 5.1) seeks to restore a stable
meandering stream. Based on my limited knowledge of the finer points of
stream restoration and enhancement, the plan seems adequate. I believe
others on the MBRT may be able to make more informed comments on this
aspect of the bank.
Wetland Restoration/enhancement
The plan states (p. 5) that reforestation with hardwood species is
proposed over 19.1 acres of the bank, including areas of pastureland and
disturbed forest. The target plant communities are Piedmont alluvial
forest and dry-mesic, oak-hickory forest. The area of restored wetlands
would be 9.2 acres. The plans for wetland restoration/enhancement
(Section 5.3) and vegetation planting (Section 5.4) seem adequate.
Vegetative Success criteria
,f 5 4/30/2007 12:17 PM
Cripple Creek Mitigation Bank
One of my concerns regarding wetland restoration is for quantitative
criteria to ensure that a stable, climax, plant community can become
established on the site. These are usually addressed as the vegetative
success criteria. The prospectus states (p. 5) that the proposed credit
release schedule would apply only if Restoration Systems documents
"acceptable survival and growth of planted vegetation." I certainly
support this broad principle, but, as always, the devil is in the
details.
In recent years, I have tried to distill my ideas on restoring wetland
plant communities down to five points which.are:
First, there should be a list of the preferred species. The current
plan uses the term "characteristic," and this is acceptable. The
characteristic species are those that should dominated in the mature,
climax community. These would be primarily trees, but shrubs may be
included. Then, by definition, every other species within the same
category (such as woody vegetation) is non-preferred. For some reason,
folks seem to have a problem with this either-or breakdown and often
want a long list of categories, e.g. preferred planted, preferred
non-planted, and on and on.
Second, the restoration process can plant some, most, or, all of the
preferred species, but overall success should be based solely on: (1)
absolute abundance; (2) relative abundance; and, (3) diversity of the
preferred species.
Third, absolute abundance should apply only to the preferred species.
This is the criterion where the 260 stems/per acre applies. All the
preferred species (whether planted, naturally recruited, or existing
prior to restoration) can be considered in reaching this goal. The
current plan for Cripple Creek proposes (p. 18) an acceptable measure of
absolute abundance, 260 characteristics trees/acre in year five.
Fourth, relative abundance refers to the percent of stems of the
preferred species versus all other stems. This is a measure to ensure
that aggressive colonizers do not overwhelm the desirable,
characteristic species. I suppose it is possible that a restoration
site could have the required 260 stems/acre after five years, but if
there were over 1,000 stems of red maple, sweetgum, and pines, it would
not bode well for the long-term establishment of the target community.
Many years ago, there was a standard that at least half the plants in a
given category, such as woody stems, must be the approved/characteristic
species. In 2002, David Lekson proposed a standard for forested wetland
restoration which stated that no more than 20% of the tree stems on the
site could be undesirable invaders (that is, at least 80% of the trees
must be the desired species). More recently, a bank has proposed that
"undesirable species . . . should constitute less than 10% of the total
population." I'm not sure the term "should" represents a definite
success criterion. At this time, I can't provide justification for
fixed standard of relative abundance, but the range of 50-90% for the
characteristics species seem like a good starting point for discussion.
The real issue is limiting harmful competition during the very early
years of reforestation and this issue should be addressed by a
quantifiable measure of relative abundance.
Fifth, there should be a measure of species diversity which applies only
to the characteristic species. This criterion has been difficult to
define and I admit that after considering this for several years, I have
not been able to develop a practical, quantitative measure aimed at
ensuring that a diverse planting program actually is on track to produce
a diverse mature, wetland community. This can be approached by
requiring that a certain percentage of all planted trees survive for at
least five years. For example, if each species is planted in the
proportion desired in the mature community, then success could require
2of5

d/2n/?nM 17.77 A
Cripple Creek Mitigation Bank
the survival of at least 800 of the plants in each species after five
years. However, this measure would not consider any natural recruitment
of characteristic species. Diversity can also be approached by
requiring that the percentage of each preferred species at the end of
the monitoring period does not deviate more than a certain amount for
the percent (such as 50%) it represented at the start of the restoration
effort. For example, if green ash constituted 10% all preferred species
at the start of the restoration effort (after any planting), this
species must represent between 5% and 15% of the preferred species at
the time success is declared. Each species required for success would
be considered separately. This approach would allow some species to
increase in abundance and some species to decline, but no species would
be allowed to disappear from the community.
The key concern here is to have a simple, effective measure to prevent a
restoration effort that seeks to establish 6-10 preferred species but
ends the monitoring period with only 2-3 species - even if the surviving
species have the required 260 stems/acre. In this regard, red maple and
sweetgum can be characteristic species for some natural communities and
should be counted toward success, but without a good species diversity
criterion, a community with only these two species could not constitute
successful restoration.
As a starting point for discussion, I would suggest that (at the very
least) vegetative success should require the presence of a certain
percentage of the characteristic species at the end of the monitoring
period. A recent commercial bank has proposed that vegetative success
would require 70% of target species should be present in viable
populations. This is a constructive proposal, but I think the
percentage of surviving species should be at least 80%. For example, if
the natural community typically has 10 dominant species, then at least 8
of these species must be present at the end of monitoring to achieve
success.
I believe that good criteria for relative abundance and diversity could
be helpful to the sponsor. These criteria could allow some less
desirable species, such as red maple and sweetgum, to contribute to
vegetative success. While these aggressive colonizing trees should not
be planted, they are part of the two target communities. If measures
are in place to limit their dominance of the site, they could be counted
toward establishing the desired communities. Such limited, natural
colonization could reduce costs for the bank sponsor - but only if their
abundance was carefully controlled.
Federally Protected Species
As noted in the plan (p. ii), no federally listed threatened and
endangered species are known to occur in Alamance County. Several
Federal Species of Concern (FSC) have been reported from the county. A
list of these species can be found on the Service website at
http://www.fws.gov/nc-es/cntylist/alamance.htm . A major concern would
be for mussels that are state-listed or FSC. I am pleased that the
sponsor intends to conduct "appropriate investigations" for listed
mussels within the bank streams and areas surrounding the bank. I
suggest that similar surveys be conducted for other state-listed species
or FSC.
Credit Release Schedule
A major concern with the current proposal is a request for the
accelerated sale of credits. The current plan would represent a
significant exception to the credit release schedule (CRS) given in the
interagency Stream Mitigation Guidelines (SMG) of April 2003. The SMG
allow for the sale of 25% of credits upon completion of all initial
physical and biological improvements. The current proposal (p. 20)
would increase this level to 55% after planting and delivery of
'I of 5 4/30/2007 12:17 l
Cripple Creek Mitigation Bank
"as-builts."
At this time, I do not believe the Mitigation Bank Review Team (MBRT)
for the Cripple Creek Project should make this change in the CRS. There
is an issue of fairness to other private mitigation bankers who might
correctly claim that the rules have been changed after they were locked
into the prior CRS.
The CRS of the SMG provides an incentive to carefully plan and execute
the restoration. While I understand the concept of a performance bond,
I confess that I do not know the details of how these funds would used
to complete the work if the original bank sponsor could not. The use of
a performance bond to replace the incentives of a gradual release of
credits opens up a whole range of questions regarding how much work
would be needed to be completed at each stage of the monitoring period,
how much money would need to be available at each stage, how would the
work be contracted, how much money would need to be set aside to ensure
success of the first, or possibly second, remedial effort, etc. I do
not have the expertise to evaluate these issues.
For example, I notice that the financial assurance section of MBI
discusses two performance bonds. The first bond of $450,000 would be
for construction, planting, and all other activities necessary to
deliver the as-built drawings. After the as-built drawings are
delivered, a second bond of $125,000 would be provided to the Corps to
cover the cost of monitoring. I am uncertain whether the second bond
replaces the first bond, or is in addition to the first bond. If the
first bond is terminated after initial construction (which would be my
guess), are there financial assurances that work can be redone if
success criteria are not met? If the stream channel fails to perform as
planned or the planted vegetation does not survive, can the necessary
remedial actions be taken? If 55% of all bank credits have been sold at
essentially time 0 of the monitoring period, are there sufficient
incentives for the sponsor to make any necessary corrective actions over
the next five years?
Any change in the CRS should only be done as part of a formal change to
the interagency SMG. The original agencies that developed the SMG would
need to formally reconsider the CRS. These agencies could consider the
role of performance bonds in ensuring completion of the work if the
original bank sponsor was not able to achieve the success criteria.
There could be a consideration of holding the initial construction bond,
$450,000 for Cripple Creek, throughout the entire monitoring period.
There could also be a consideration of establishing a two-tier system
for private, mitigation bankers: one tier for those with an established
record of successful banks and another tier for those without such a
record. Bankers in the former tier, with an established record of
success, would be eligible for an accelerated CRS. However, it would
seem that bankers with successful banks should have the working capital
to comply with the current CRS. In any case, the standards for
established banker would need to be written out in detail before any
changes in the CRS are approved. The standards should be very specific
with virtually no "wiggle room." Otherwise, each new MBRT will spend
many hours hearing arguments on why the new bank should qualify for the
accelerated CRS. Any establishment of categories for private bankers
would certainly add extra work for the MBRT due to the need to carefully
review the details of past mitigation banks and evaluate their success
or failure.
The Service appreciates the opportunity to provide these comments on the
proposed banks. we look forward to the successful resolution of these
issues and continued involvement with the MBRT for this project.
Best regards, Howard
4 of 5 dignionm 1)-1'7 DT%A
Cripple Creek Mitigation Bank
Howard F. Hall
U. S. Fish and wildlife Service
Ecological Services
P. 0. Box 33726
Raleigh, North Carolina 27636-3726
Ph: 919-856-4520, ext. 27
Fax: [phone]
e-mail: [e-mail]
c ,.c c 4/30/2007 12.17 PM
® North Carolina Wildlife Resources Commission
Richard B. Hamilton, Executive Director
MEMORANDUM
TO: Mr. Andrew Williams, Raleigh Regulatory Field Office
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 27 April 2007
SUBJECT: Cripple Creek Mitigation Bank, Restoration Systems, LLC, Alamance County, North
Carolina. Action ID No. SAW-2007-01188-201
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document and we are familiar with the habitat values of the area. An on-site visit was conducted
on 23 March 2007.
Restoration Systems, LLC proposes to establish the Cripple Creek Stream and Wetland
Mitigation Bank. The proposed mitigation bank is located on a 19.1 acre portion of a farm used for
grazing horses and hay production. The proposed work includes restoring approximately 4,300 linear feet
of stream channel using Rosgen methodologies, enhancement (level II) of approximately 147 linear feet
of degraded stream channel, establishing vegetated buffers on both sides of the stream channel,
restorating 7.1 acres of riparian wetlands, and enhancement of 2.1 acres of wetlands. Over 19 acres of
woody vegetation will be planted, including 9.2 acres of wetland community and approximately 10 acres
of a non-wetland riparian community. A conservation easement will be prepared to protect the Bank site
in perpetuity. The purpose of the work and objective of the Bank is to remove non-point sources of
pollution associated with agricultural activities, reduce sedimentation, re-establish stream stability,
promote floodwater attenuation, improve aquatic and terrestrial wildlife habitat, and provide
compensatory mitigation for impacts resulting from future permitted projects.
The Bank includes unnamed tributaries to Boyds Creek in the Cape Fear River basin. There are
no records for the federal or state listed species in these unnamed tributaries or Boyds Creek; however,
there are records for the state threatened Carolina fatmucket (Lampsilis radiata conspicua) and the state
significantly rare Eastern creekshell (Villosa delumbis) in adjacent watersheds. The applicant indicates
the federal species of concern and state endangered Carolina creekshell (Villosa vaughaniana) and yellow
lampmussel (Lampsilis cariosa) have potential habitat within the Bank and proposes to conduct a survey
to determine if either of these listed mussel species are present in the streams or immediately downstream
of the Bank.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
27 April 2007
Cripple Creek Mitigation Bank
Action ID No. SAW-2007-01188-201
This site has the potential to be a good stream and wetland restoration site. The proposed stream
restoration, enhancement, and preservation activities will benefit water quality and aquatic and terrestrial
wildlife habitats. We offer the following comments and recommendations regarding the Prospectus and
Mitigation Plan.
The Prospectus (#7) and Mitigation Plan (Section 1. 1, pg. 1) discuss excluding livestock from
streams, stream banks and floodplains; however, there are no details in the Mitigation Plan
regarding how livestock will be excluded. Please include details on the method (e.g., fencing) to
be used to exclude livestock from the mitigation bank.
2. It is unclear whether livestock crossings will be installed across any of the stream or wetland
mitigation areas. If livestock crossings are proposed, these should be detailed in the Prospectus
and Mitigation Plan including location, type of crossing, and any exclusionary fencing. If
livestock crossings are proposed, generally, we prefer the use of geo-textile fabric and rock to
stabilize the stream bottom rather than concrete. Fencing that is permanently installed across a
stream can trap debris and require maintenance. Instead, we suggest that cable is installed at the
crossing to prevent livestock from accessing the crossing. When the livestock need to cross the
stream, these cables can be detached and stretched across the stream to the fencing on the
opposite stream bank. This allows the livestock to cross and limits access to only the crossing.
Once the livestock have crossed, the cables can be reattached to the fencing to prevent livestock
from accessing the crossing.
3. A portion of the stream channel will be constructed on a new location within the adjacent
floodplain (Mitigation Plan, Section 5.1.1, pg. 13). Where feasible, we encourage the applicant to
remove substrate material from the existing channel and to use this substrate material in the new
channel.
4. The applicant proposes an accelerated credit release schedule (Prospectus #7; Mitigation Plan,
Section 7.2, pg. 20). While we recognize the North Carolina Ecosystem Enhancement Program
(NCEEP) has a credit release schedule that differs from the one in the Stream Mitigation
Guidelines, to our knowledge, all private mitigation banks adhere to the credit release schedule
detailed in the Stream Mitigation Guidelines (April 2003). Therefore, we feel the credit release
schedule for this Bank should be consistent with the current Stream Mitigation Guidelines (April
2003). The NCWRC would support an interagency discussion regarding a potential revision to
the current credit release schedule detailed in the Stream Mitigation Guidelines (April 2003).
The applicant intends to conduct studies to determine if listed mussel species may be present in
the Bank streams or immediately downstream (Mitigation Plan, Section 8.2.2., pg. 22). We
recommend any surveys be conducted by biologists with both state and federal endangered
species permits.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at [phone].
ec: Ryan Heise, WRC
Corey Oakley, WRC

Natural Resources
Restoration & Conservation
March 26, 2007
Mr. Ken Jolly, Chief
Regulatory Division
U.S. Army Corps of Engineers
69 Darlington Avenue
Wilmington, N.C. 28403
Dear Ken:
g
lJ
MAR 2 8 2007
1*II OS ANO STORUWATFR BRANCH
Restoration Systems (RS) had a Mitigation Bank Review Team (MBRT) site
meeting this past Friday the 23rd for its Cripple Creek wetland and stream bank located in
Alamance County. Prior to this meeting we sent to all agencies on the team a Prospectus
and conceptual mitigation plan for the site that closely followed the USACE template for
establishing a mitigation bank with one exception. We proposed a modified credit release
schedule rather than the one in place since 1999 (that was prescribed for RS' Bear Creek
Mill Branch site) and was put into regulatory guidance in the Stream Mitigation
Guidelines in 2003.
We noted this proposed change in the mitigation credit release schedule in the
cover letter (see attached) that was sent to all team members with the site Prospectus and
mitigation plan so that it would be made clear upfront to all MBRT members. At the start
of our site meeting I reiterated this proposed change to the assembled agencies and
elaborated on the rationale for why it was requested. The primary reason being that the
existing mitigation credit release schedule does not allow for release of enough mitigation
credit through the first year of monitoring to make speculative mitigation banks
economically feasible.
I cited the meeting that Tara Allden, George Howard, and I had with you and
Scott McLendon in you office on April 17th 2006 and our conversation on this topic in
both the cover letter and again on Friday. I tried diligently to provide an accurate and fair
account of that meeting and checked with Tara and George, as well as my meeting notes
before citing it. The gist of which is that when we brought up the issue of revising the
credit release schedule in that meeting, you and Scott both acknowledged that when it
was first put into place there was little track record in North Carolina for mitigation banks
or for the credibility of firms doing mitigation work. Thus, a very conservative credit
release was deemed to be justified at that time. However, over the past 7-8 years there has
been greater work experience and demonstrated track records in which the USACE could
gauge proposed mitigation sites and the quality level of firms performing the work. You
both then suggested that if RS were to propose a high quality mitigation site as a bank
that we could expect to possibly get a more liberal credit release schedule and that this
decision would be made on a case by case basis.
Pilot Mill • 1101 Haynes St., Suite 107 • Raleigh, NC 27604 • www.restorationsystems.com • Phone [phone] • Fax [phone]
We took this, in good faith, to be an offer of `put up or shut up' on the issue of
revising the credit release schedule so we went forward and have now put up a site which
we would like to have permitted as a mitigation bank with a somewhat accelerated credit
release schedule.
It became clear this past Friday that the credit release schedule we proposed is
going to now involve discussion between several of the agencies, most notably the
USACE, the EPA, and NCDWQ. What I thought would be a topic of discussion relating
to the site then became pretty much `the discussion'. I certainly was not trying to make
more work for you or Scott on this and hope that we can help resolve it without major
ordeal. To this end, I asked Kathy Mathews of the EPA if we (RS as the bank sponsor)
could be a participant in the agency discussion on revising the credit release schedule and
provide relevant information to help the agencies.
The irony in all this is that the credit release schedule we proposed was
intentionally modest in its change in order to avoid over-reaching for something we did
not think realistically acceptable to the agencies. As you will see, we are asking for the
current 15% credit release upon execution of a Mitigation Banking Instrument, and then
20% upon site construction ( per USACE site inspection), and 20% upon planting and
delivery of As-Built drawings of the constructed site. This is similar to the revised credit
release schedule NCDWQ proposed to the USACE in 2002 (see attached). We also used
for comparison the current EEP milestone payment schedule which pays 70% of the
contract total after delivery of As-Built drawings.
Other than this issue, the site visit was without any other significant discussion
and the MBRT acknowledged the merits of the sites' potential for both wetland and
stream mitigation. The USACE MBRT chair was very fair in handling the concerns of all
MBRT members, including RS. It was understood at the meeting's end that the credit
release schedule decision would come from your office separate from the MBRT.
I regret that I didn't make you aware of any of this prior to the meeting but I was
expecting a lower level of discussion on the issue. Please let me know if either Randy
Turner or I can be of any help to you or the other agencies as we work through this.
Sincerely,
` 4 - Z__----_.
John Preyer?
Cc Scott McLendon/USACE
Andy Williams/USACE
Monte Mathews/USACE
Jean Manuelle/USACE
Kathy Mathews/EPA
Eric Kulz & Tammy Hill/NCDWQ
John Dorney/NCDWQ
Howard HaIWSFWS
Shari Bryant/USFWS
Randy Tumer/RS

March 12, 2007
U. S. Army Corps of Engineers
Raleigh Regulatory Field Office
6508 Falls of Neuse Road, Suite 120
Raleigh, North Carolina 27615
ATTN: Monte Matthews, Chairperson, Mitigation Banking Review Team
Restoration Systems, LLC (RS) is pleased to present the enclosed Prospectus and Mitigation Plan
for the Cripple Creek Stream and Wetland Mitigation Bank proposed at a site in northeast
Alamance County within the Cape Fear River Basin.
Please note that the Prospectus is prepared in the format of the Mitigation Banking Instrument
(MBI) template developed by the U.S. Army Corps of Engineers and found on their web page at
http://www.saw.usace.army.mil/WETLANDS/Mitip-ation/mitbanks.htmi. This approach is taken
to facilitate a more efficient and timely transition from Prospectus to MBI following the approval
of the Prospectus notwithstanding any changes the Mitigation Banking Review Team (MBRT)
may recommend. Although the Prospectus follows the MBI very closely, MBI-specific elements
such as agency signature blocks and paragraphs germane only to the MBI (i.e., paragraphs 27-33)
were deleted, or modified to be more pertinent to a Prospectus.
One issue deserving special attention is the formula for credit release. The credit release schedule
cited in the MBI template is the same model used by MBRTs since before 2000. More recently it
has been appended to the 2003 interagency Stream Mitigation Guidelines. RS is proposing a
modification of this credit release schedule (Table 1), which is a hybrid between the Ecosystem
Enhancement Program's (EEP) current milestone payment schedule (Table 2) and the interagency
format cited above.
Table 1. Proposed Credit Release Schedule
Task Completion Verification Credit Release (% of total)
*I (Pre-Construction) Execution of MBI 15
II (Construction) Site Inspection by USACE 20
III (Planting and As-Builts) Delivery of As-Builts 20
IV (1" Year Monitoring) Monitoring Report 5
V (2"d Year Monitoring) Monitoring Report' 5
VI (3rd Year Monitoring) Monitoring Report 5
VII (4`h Year Monitoring) Monitoring Report 5
VIII (5`h Year Monitoring) Monitoring Report 25**
*Task I includes: execution of MBI , MBRT approval of Mitigation Plan, delivery of financial assurances,
recordation of conservation easement and delivery of title opinion to MBRT. ** Denotes that release of
25% of credits is contingent upon at least one occurrence of a bankfull event during the previous five years.
In the absence of a bank full event, release is limited to 15% with the 10% balance available following the
occurrence of a bankfull event.
Pilot Mill - 1101 Haynes St., Suite 107 - Raleigh, NC 27604 - www.restorationsystems.com - Phone [phone] - Fax [phone]
Page 2
March 12, 2007
Monte Matthews, USACE
We have several justifications for proposing this modification to the credit release schedule:
• In a meeting on April 17, 2006 with Restoration Systems, the Chief of Regulatory for
the Wilmington District and one of his senior staff made it clear to RS that the U. S.
Army Corps of Engineers (USACE) would allow for accelerated credit release
schedules on a case by case basis in recognition of factors including significant
advances in the quality and efficacy of a private mitigation company's work since the
original credit release schedule was proposed. These same USACE managers
acknowledged that the credit release schedule was somewhat onerous to the private
sector with the effect of limiting the growth of private mitigation banking in NC.
• Although the interagency credit release schedule is appended to the Stream
Mitigation Guidelines, and April 2003 document, RS is aware that this same credit
release schedule was in use by the USACE as early as 2000, because it was employed
by the MBRT at the Bear Creek Mitigation Bank.
The EEP milestone schedule for payment to full delivery providers (Table 2) is
significantly different from the MBI template's formula. The vast majority of private
mitigation work performed in North Carolina in recent years has been through the
programs originating with the former Wetland Restoration Program and the current
EEP in accordance with the following schedule:
Table 2. EEP Project Milestones and Payment Schedule
Task Project Milestone Payment (% of Contract)
1 Feasibility Study, CE Document 5
2 Recordation of Conservation Easement 20
3 Approval of Restoration Plan 15
4 Completion of Construction 15
5 Site Planting/Installation of Monitoring Devices 10
6 Approval of Mitigation Plan and As-Builts 5
7 Approval of Monitoring Report 1 10
8 Approval of Monitoring Report 1 5
9 Approval of Monitoring Report 1 5
10 Approval of Monitoring Report 1 5
11 Approval of Monitoring Report 1 5
Note that revenue from pre-monitoring activities (tasks 1-6) totals 70% of project value in the EEP model,
whereas the interagency credit release schedule would only authorize the release of up to 25% of total
credits at the same milestone point. RS's proposed compromise schedule (Table 1 above) would generate a
55% credit release for the same milestone, while still holding 25% of project value until success has been
demonstrated in year 5.
One item of good news is that RS is proposing more than 9 acres of either wetland restoration or
enhancement. When we originally investigated this site a couple of years ago, using cursory
methods pursuant to preparing a technical proposal in response to an RFP deadline, we estimated
that hydric soils occupied only 6+ acres of land area. Recently, more intensive investigations by
our soil scientist/wetland consultant reveals that approximately 9.2 acres of hydric soils are
present including more than 2 acres of existing jurisdictional wetlands (see enclosed Mitigation
Plan and survey plat of hydric soils delineation).
RS is excited to submit this Prospectus and Mitigation Plan to the MBRT and we look forward to
putting forth our best efforts to provide a high quality wetland and stream mitigation complex that
will provide the utmost in functionality for the benefit of the entire ecoregion.
Page 3
March 12, 2007
Monte Matthews, USACE
We are hopeful that you will provide comments to Mr. Matthews in a timely manner so this
project can move forward expeditiously. Thanks for your time and cooperation. We look
forward to seeing you at the site on March 23. Please call me if you have any questions or
comments.
Sincerely,
44?
M. Randall Turner, Ecowarrior Emeritus
Enclosures
cc: Howard Hall, U.S. Fish and Wildlife Service, Raleigh
Kathy Matthews, U.S. Environmental Protection Agency, Durham
Shari Bryant, N.C. Wildlife Resources Commission, Sedalia
Eric Kulz, N.C. Division of Water Quality, Raleigh
Tammy Hill, N.C. Division of Water Quality, Raleigh
Daryl Lamb, N.C. Division of Water Quality, Winston-Salem
Andy Williams, U.S. Army Corps of Engineers, Raleigh
Jean Manuele, U.S. Army Corps of Engineers, Raleigh
111111
Or kZ9 William G. Ross Jr., Secretary
O? Q North Carolina Department of Environment and Natural Resources
IG Y Alan W. Klimek, P.E. Director
D -f Division of Water Quality
November 18, 2002
Mr. Dave Lekson
Washington Field Office US Army Corps of Engineers RIC,CENED
P.O. Box 1000
#`fi ,.1 20c'..
N w.
Washington, NC 27889-1000
Dear Mr. Lekson: i21+OOWN, 0-OW-42 RA
RE: Stream Mitigation Bank Credit Release Schedule
In response to your letter of October 28, 2002 DWQ staff (including staff of the Wetlands Restoration
Program) have reviewed the proposed Stream Mitigation Bank Credit Release Schedule. In general we
believe that the schedule should be changed to allow more rapid release of stream mitigation credits from
mitigation banks (within constraints) since it is our experience that stream restoration projects can be quickly
determined to be successful and also quickly revamped to correct observed problems. Therefore, we are
proposing the attached schedule with the original version alongside it for comparison purposes. I expect that
you will need to send this version to the other agencies for their comment. A meeting may be helpful to explain
the logic behind this as well.
COE DWQ

Initial release 15% 15%
Construction release 35%
After first year 10% 10%
After second year •10% 10%
After third year 10% 5%
After fourth year 15% 5%
After fifth year 15% 20%
Post fifth year 25%
Total 100% 100%
Advantages in DWQ's proposal: This credit release schedule accelerates the release of credits and thereby
promotes mitigation banking since it begins to address the cash flow problems. This also recognizes DWQ's
understanding with respect to stream mitigation that most problems that occur will occur soon after
construction. The longer term monitoring is valuable for vegetation success and macrobenthos monitoring as
well as whether the success criteria are met.
Definitions:
Initial release - MBRT signed, approval final plan, financial assurances,
conservation easement
Construction release -constructed, submission of as-built, MBRT inspection and
approval)
After first year - site inspection, report and repairs made
After. second year - site inspection, report and repairs made
After third year - site inspection, report and repairs made
After fourth year - site inspection, report and repairs made
After fifth year - site inspection, report and repairs made, success criteria met
Post fifth year - if bank meets overall objectives and success criteria met.
nc ®R
^•! c Division of Water Oualily 1650 Mail Service Center Raleigh, NC 27699-165 7 7 (919) 73;3-17£16 Customer Service
1 800 (;2:).774£1
? .. .. ... .. .. .. ... .. ... .. .1..C.-r+sa.w??a14,i=iL. s»?ri.:..:_.[;:. ; ...J6,:
'We also believe that the final schedule that the agencies support should be sent out for public
comment. Since a credit release schedule is a crucial item, it would be possible to implement. a schedule and
then send it out for review as a working draft rather than to gather public comments and keep the process in
limbo until then. We would certainly be able to use the 401 Water Quality Certification mailing list for this
public comment purpose.
Please call me at 919-733-9646 if you have any questions.
Cc: Todd St. John
Cyndi Karoly
Dennis Ramsey
Mac Haupt, WRP

4, 3
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Coastal Management
Michael F. Easley, Governor Charles S. Jones, Director William G. Ross Jr., Secretary
March 12, 2007
Mr. Carl Classen
Interim County Manager
County of Hyde
P.O. Box 188
Swan Quarter, NC 27885
MAR ?DOl
LJ,1,Jk - WAXER QUALITY
WETLANDS AMID 81, 04N1wsTER 13RAtMOH
Mr. Classen,
The purpose of this letter is to provide comments on the Year 1 Swan Quarter Dike
Mitigation Monitoring Report that was submitted to the North Carolina Division of Coastal
Management (DCM), as required by the conditions of Major CAMA/Dredge and Fill Permit
167-02. I would first like to note that DCM considers construction of the coastal marsh
mitigation site to be incomplete because it is out of compliance with the permit conditions and
the approved mitigation plan. The original issuance of Major CAMA/Dredge and Fill permit no.
167-02 required (condition no. 16) the installation of a third culvert pipe under HWY 45 in order
to improve the tidal connection and transport of detrital material from coastal marsh mitigation
site to Swan Quarter Bay. Last year, DCM staff developed an alternative to condition no. 16,
which was accepted by Hyde County. This alternative involved the removal of berms that were
left adjacent to the tidal roadside ditches when the field was excavated and the removal of
blockages in tidal roadside ditches adjacent to the coastal marsh mitigation area. DCM felt this
alternative would be less costly than the original permit condition and would achieve the desired
result. At the request of Hyde County, the permit was modified on 28 June 2006. DCM
removed condition no. 16, which requires the installation of a third culvert pipe, and replaced it
with a condition requiring the removal of the field berms and ditch blockages.
As of this date, removal of the berms and ditch blockages has not been completed. The
monitoring report does not address any timeline to fulfill this permit condition. Until
construction of the coastal wetland mitigation site is complete, it is premature to undertake
hydrologic and vegetation monitoring on the coastal marsh mitigation site. While the monitoring
data may provide useful background information to evaluate the progress of the mitigation site
over time, they will not count towards the five years of monitoring that will be required
following project completion.
Nonetheless, DCM has reviewed the Annual Monitoring Report and would like to provide
several comments regarding the content of the Monitoring Report and the status of the site. - First,
1638 Mail Service Center, Raleigh, North Carolina 27699-1638
Phone: [phone] \ FAX: [phone] \ Internet: www.nccoastalmanagement.not
An Equal Opportunity \ Affirmative Action Employer- 50% Recycled \ 10% Post Consumer Paper
l
the Monitoring Report does not contain sufficient information to determine whether the site is on
track to meet its hydrologic and vegetation success criteria. The following supplemental
information needs to be provided to DCM to assist interpretation of the monitoring results:
• A full-page map that shows the location of the reference sites in relation to the
location of the two mitigation sites.
• Detailed maps of the two mitigation sites and their associated reference sites. These
maps should indicate the location of the ground water monitoring wells and surface
water gauges. They should also show the location of vegetation survey plots and
photo points.
• According to the final Swan Quarter Dike Mitigation Plan, dated June 16, 2003, the
vegetation success criterion for the marsh site is that 80% of surface area will be
covered with plant species similar to the reference marsh by the end of the fifth year
of monitoring. Plant species composition and percent cover were to be monitored
at 1-meter plots spaced at 6-meter intervals along four permanent 100-foot
transects. These data are not presented in the Year 1 Monitoring Report. Please
provide a table indicating the percent cover and species present for each plot, along
with an average percent cover for the entire marsh site. Also indicate the presence
of invasive species, particularly Phragmites australis.
• According to the final mitigation plan, the vegetation success criterion for the
forested wetland site is that there will be a minimum of 320 trees per acre surviving
after the fifth year of monitoring. This should include at least six species of
hardwood trees and no single species should comprise more that 20% of the total
trees on the site. Please provide a table indicating the trees per acre for each of the
5 monitoring plots and an average number of trees per acre for the entire site..
This information should be included as part of the Annual Monitoring Report in future years.
Also, one photo of the coastal marsh mitigation shows a large stand of the invasive reed
Phragmites australis along the boundary of the site. In the approved mitigation plan, the County
committed to eliminating Phragmites adjacent the coastal wetland creation site. Steve Trowell,
DCM's field representative for Hyde County, has observed that the stand is spreading into the
site. Please be aware that DCM does not allow mitigation credit for mitigation sites dominated
by Phragmites. Any portions of the mitigation site that contain homogenous stands of
Phragmites at the end of the fifth year of monitoring will not be considered successful
mitigation. To ensure success of the mitigation site, the Phragmites stand must be treated this
year. DCM recommends using an appropriate aquatic-approved herbicide (e.g. Rodeo) late in
the growing season after the seed-head has fully emerged (Mid-August to Mid-September). This
will ensure that the herbicide is transported to the root system, where growth and spread of the
plant occurs. Herbicide application should focus on the top of the plant, but an effort should also
be made to spray the entire stalk. Following chemical treatment, the dead stalks should be
removed mechanically or through controlled burning. This will facilitate the re-establishment of
native species and minimize the chance of significant Phragmites re-growth. Follow-up
treatments will be needed for 1-2 years to fully eradicate the stand.
I would also like to inform you that I am leaving my position with the Division of Coastal
Management effective March 30. Steve Trowell will be the primary DCM contact for this
mitigation site until my replacement is hired. If you have any questions after March 30, please
.4 , 1
contact Steve by phone at 252-948-3854 or by email at [e-mail]. Before
March 30, you may contact me at 919-733-2293, x254 or by email at
[e-mail].
Si el ,
Melissa M. Carle
Wetlands Specialist
N.C. Division of Coastal Management
Copies provided to:
Steve Trowell, DCM
Terry Moore, DCM
Ted Tyndell, DCM
Doug Huggett, DCM
Raleigh Bland, USACE
John Dorney, DWQ
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS 5U?
P.O. BOX 1890 „r
WILMINGTON, NORTH CAROLINA 28402-1890
REPLY TO
ATTENTION OF March 29, 2007
Regulatory Division
Action ID No. SAW-2007-01188-201
SEE DISTRIBUTION
Dear Colleague:
This correspondence is in reference to the Cripple Creek Stream and Wetland Mitigation
Bank that is proposed to be developed by Restoration Systems, LLC. This proposed mitigation
bank is located approximately 3,000 feet southeast of the intersection of State Roads 1750 and
SR 1729, approximately 2 miles northeast of Burlington, in Alamance County, North Carolina.
The proposed bank is a non-umbrella bank. On March 23, 2007, we met with the project
proponent and various MBRT participants from interested state and federal agencies. The
purpose of this letter is to solicit comments regarding the Prospectus and Mitigation Plan
submitted by Restoration Systems, LLC dated March 12, 2007, and/or any concerns observed
during the March 23, 2007, site inspection.
Please provide your comments within 30 days of the date of this letter. All comments should
be submitted to Mr. Andrew Williams, U.S. Army Corps of Engineers, Raleigh Regulatory Field
Office, 6508 Falls of Neuse Road, Suite 120, Raleigh, North Carolina 27615.
Thank you for your time and cooperation. Should you have any questions, please contact me
at [phone], Extension 26.
Sincerely,

Andrew Williams
Regulatory Project Manager
Raleigh Field Office 'A A+ ?7
APR I cop
yr i111AL, 0FY1?_? _„u?ZIS f
4-
DISTRIBUTION:
Mr. Eric Kulz
Environmental Specialist
North Carolina Division of Water Quality
401 Oversight and Express Permitting Unit
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604
Ms. Tammy Hill
North Carolina Division of Water Quality
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604
Mrs. Kathy Matthews
U.S. Environmental Protection Agency
Region 4 Wetlands Section
109 T.W. Alexander Drive
Durham, NC 27711
Mail Code: E-143-04
Ms.Shari Bryant
NC Wildlife Resources Commission
Habitat Conservation Program
Post Office Box 129
Sedalia, NC 27342-0129
Mr. Howard Hall
US Fish and Wildlife Services
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh, NC 27636-3726
Mr. Daryl Lamb
North Carolina Department of Water Quality
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Ms. Renee Gledhill-Early
State Historic Preservation Office
4617 Mail Service Center
Raleigh, NC 27699-4617
2

Copies Furnished:
Mr. Randy Turner
Restoration Systems, LLC
1101 Haynes Street, Suite 107
Raleigh, North Carolina 27604
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS 5U°
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890
REPLY TO
ATTENTION OF March 29, 2007
Regulatory Division
Action ID No. SAW-2007-01188-201
t
SEE DISTRIBUTION
M ??9
r , oil ?Tsrf; a;w"C}{
Dear Colleague:
This correspondence is in reference to the Cripple Creek Stream and Wetland Mitigation
Bank that is proposed to be developed by Restoration Systems, LLC. This proposed mitigation
bank is located approximately 3,000 feet southeast of the intersection of State Roads 1750 and
SR 1729, approximately 2 miles northeast of Burlington, in Alamance County, North Carolina.
The proposed bank is a non-umbrella bank. On March 23, 2007, we met with the project
proponent and various MBRT participants from interested state and federal agencies. The
purpose of this letter is to solicit comments regarding the Prospectus and Mitigation Plan
submitted by Restoration Systems, LLC dated March 12, 2007, and/or any concerns observed
during the March 23, 2007, site inspection.
Please provide your comments within 30 days of the date of this letter. All comments should
be submitted to Mr. Andrew Williams, U.S. Army Corps of Engineers, Raleigh Regulatory Field
Office, 6508 Falls of Neuse Road, Suite 120, Raleigh, North Carolina 27615.
Thank you for your time and cooperation. Should you have any questions, please contact me
at [phone], Extension 26.
Sincerely,

Andrew Williams
Regulatory Project Manager
Raleigh Field Office
DISTRIBUTION:
Mr. Eric Kulz
Environmental Specialist
North Carolina Division of Water Quality
401 Oversight and Express Permitting Unit
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604
Ms. Tammy Hill
North Carolina Division of Water Quality
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604
Mrs. Kathy Matthews
U.S. Environmental Protection Agency
Region 4 Wetlands Section
109 T.W. Alexander Drive
Durham, NC 27711
Mail Code: E-143-04
Ms.Shari Bryant
NC Wildlife Resources Commission
Habitat Conservation Program
Post Office Box 129
Sedalia, NC 27342-0129
Mr. Howard Hall
US Fish and Wildlife Services
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh, NC 27636-3726
Mr. Daryl Lamb
North Carolina Department of Water Quality
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Ms. Renee Gledhill-Early
State Historic Preservation Office
4617 Mail Service Center
Raleigh, NC 27699-4617
2
Copies Furnished:
Mr. Randy Turner
Restoration Systems, LLC
1101 Haynes Street, Suite 107
Raleigh, North Carolina 27604
f- 1

U. S. Army Corps of Engineers
Raleigh Regulatory Field Office
6508 Falls of Neuse Road, Suite 120
Raleigh, North Carolina 27615:,
March 12, 2007
e4.
gp,?
MAR 1 2 2007 `a
t-NPk -WATER QUALI YWERAN[?Fg t!_ !i; .yTO?? ?31e 7 ? RRA?d+ }t
ATTN: Monte Matthews, Chairperson, Mitigation Banking Review Team
Restoration Systems, LLC (RS) is pleased to present the enclosed Prospectus and Mitigation Plan
for the Cripple Creek Stream and Wetland Mitigation Bank proposed at a site in northeast
Alamance County within the Cape Fear River Basin.
Please note that the Prospectus is prepared in the format of the Mitigation Banking Instrument ,
(MBI)template developed by the U.S. Army Corps of Engineers and found on their web page ai
http://www.saw.usace.army.mil/WETLANDS/Mitigation/mitbanks.html. This approach is taken
}-to facilitate a more efficient and timely transition from Prospectus to MBI following the approval
of the Prospectus notwithstanding any changes the Mitigation Banking Review Team (MBRT)
may recommend. Although the Prospectus follows the MBI very closely, MBI-specific elements
a <' such as agency signature blocks and paragraphs germane only to the MBI (i.e., paragraphs 27-33)
were deleted, or modified to be more pertinent to a Prospectus.
One issue deserving special attention is the formula for credit release. The credit release schedule
cited in the MBI template is the same model used by MBRTs since before 2000. More recently it
has been appended to the 2003 interagency Stream Mitigation Guidelines. RS is proposing a
modification of this credit release schedule (Table 1), which is a hybrid between the Ecosystem
Enhancement Program's (EEP) current milestone payment schedule (Table 2) and the interagency
format cited above.
Table 1. Proposed Credit Release Schedule
Task Completion Verification Credit Release (% of total)
*I (Pre-Construction) Execution of MBI 15 16y
II (Construction) Site Inspection by USACE 20 ? 16Y
III (Planting and As-Builts) Delivery of As-Builts 20
IV (Pt Year Monitoring) Monitoring Report 5 i6-70Y.
V (2"d Year Monitoring) Monitoring Report' 5 10-26Y.
VI (3`d Year Monitoring) Monitoring Report 5 10-L0%
VII (0' Year Monitoring) Monitoring Report 5 I6 •zd%
VIII (5"' Year Monitoring) Monitoring Report 25**` 15-3.5'
*Task 1 includes: execution of MBI , MBRT approval of Mitigation Plan, delivery of financial assurances,
recordation of conservation easement and delivery of title opinion to MBRT. ** Denotes that release of
25% of credits is contingent upon at least one occurrence of a bankfull event during the previous five years.
In the absence of a bank full event, release is limited to 15% with the 10% balance available following the
occurrence of a bankfull event.
Pilot Mill - 1101 Haynes St., Suite 107 - Raleigh, NC 27604 - www.restorationsystems.com - Phone [phone] - Fax [phone]

Page 2
March 12, 2007
Monte Matthews, USACE
We have several justifications for proposing this modification to the credit release schedule:
• In a meeting on April 17, 2006 with Restoration Systems, the Chief of Regulatory for
the Wilmington District and one of his senior staff made it clear to RS that the U. S.
Army Corps of Engineers (USACE) would allow for accelerated credit release
schedules on a case by case basis in recognition of factors including significant
advances in the quality and efficacy of a private mitigation company's work since the
original credit release schedule was proposed. These same USACE managers
acknowledged that the credit release schedule was somewhat onerous to the private
sector with the effect of limiting the growth of private mitigation banking in NC.
• Although the interagency credit release schedule is appended to the Stream
Mitigation Guidelines, and April 2003 document, RS is aware that this same credit
release schedule was in use by the USACE as early as 2000, because it was employed
by the MBRT at the Bear Creek Mitigation Bank.
• The EEP milestone schedule for payment to full delivery providers (Table 2) is
significantly different from the MBI template's formula. The vast majority of private
mitigation work performed in North Carolina in recent years has been through the
programs originating with the former Wetland Restoration Program and the current
EEP in accordance with the following schedule:
Table 2. EEP Project Milestones and Payment Schedule
Task Project Milestone Payment (% of Contract)
1 Feasibility Study, CE Document 5
2 Recordation of Conservation Easement 20
3 Approval of Restoration Plan 15
4 Completion of Construction 15
5 Site Planting/Installation of Monitoring Devices 10
6 Approval of Mitigation Plan and As-Builts 5
7 Approval of Monitoring Report 1 10
8 Approval of Monitoring Report 1 5
9 Approval of Monitoring Report 1 5
10 Approval of Monitoring Report 1 5
11 Approval of Monitoring Report 1 5
Note that revenue from pre-monitoring activities (tasks 1-6) totals 70% of project value in the EEP model,
whereas the interagency credit release schedule would only authorize the release of up to 25% of total
credits at the same milestone point. RS's proposed compromise schedule (Table 1 above) would generate a
55% credit release for the same milestone, while still holding 25% of project value until success has been
demonstrated in year 5.
One item of good news is that RS is proposing more than 9 acres of either wetland restoration or
enhancement. When we originally investigated this site a couple of years ago, using cursory
methods pursuant to preparing a technical proposal in response to an RFP deadline, we estimated
that hydric soils occupied only 6+ acres of land area. Recently, more intensive investigations by
our soil scientist/wetland consultant reveals that approximately 9.2 acres of hydric„soils are
present including more than 2 acres of existing jurisdictional wetlands (see enclosed Mitigation
Plan and survey plat of hydric soils delineation).
RS is excited to submit this Prospectus and Mitigation Plan to the MBRT and we look forward to
putting forth our best efforts to provide a high quality wetland and stream mitigation complex that
will provide the utmost in functionality for the benefit of the entire ecoregion.
Page 3
March 12, 2007
Monte Matthews, USACE
We are hopeful that you will provide comments to Mr. Matthews in a timely manner so this
project can move forward expeditiously. Thanks for your time and cooperation. We look
forward to seeing you at the site on March 23. Please call me if you have any questions or
comments.
Sincerely,
44A,
M. Randall Turner, Ecowarrior Emeritus
Enclosures
cc: Howard Hall, U.S. Fish and Wildlife Service, Raleigh
Kathy Matthews, U.S. Environmental Protection Agency, Durham
Shari Bryant, N.C. Wildlife Resources Commission, Sedalia
Eric Kulz, N.C. Division of Water Quality, Raleigh
Tammy Hill, N.C. Division of Water Quality, Raleigh
Daryl Lamb, N.C. Division of Water Quality, Winston-Salem
Andy Williams, U.S. Army Corps of Engineers, Raleigh
Jean Manuele, U.S. Army Corps of Engineers, Raleigh
4
MITIGATION PROSPECTUS
CRIPPLE CREEK MITIGATION BANK
RESTORATION AND ENHANCEMENT OF
UNNAMED TRIBUTARIES TO BOYD CREEK
AND ADJACENT PALUSTRINE WETLANDS
Alamance County, North Carolina
PREPARED BY:
RESTORATION SYSTEMS, LLC
1101 HAYNES STREET, SUITE 107
RALEIGH, NORTH CAROLINA 27604
MARCH 2007
General Provisions
1. The goal of the Cripple Creek Stream and Wetland Mitigation Bank (The Bank) is to
restore and enhance first- and second-order streams, and to restore and enhance riverine
and non-riverine wetlands, including their collective functions and values to compensate
for the loss of these regulated resources for unspecified, future and unavoidable impacts
to wetlands and/or streams, as authorized by Clean Water Act Section 404 permits in
circumstances deemed appropriate by the Corps after consultation, through the permit
review process, with members of the MBRT.
2. Use of credits from The Bank to offset wetland impacts authorized by Clean Water Act
permits must be in compliance with the Clean Water Act and implementing regulations,
including but not limited to the 404(b)(1) Guidelines, the National Environmental Policy
Act, and all other applicable Federal and State legislation, rules and regulations. This
agreement has been drafted following the guidelines set forth in the proposed "Federal
Guidance for the Establishment, Use and the Operation of Mitigation Banks," 60 Fed.
Rey. 58605, November 28, 1995 (Guidance).
3. The MBRT shall be chaired by Monte K. Matthews, the representative of the U.S. Army
Corps of Engineers, Wilmington District. The MBRT shall review monitoring and
accounting reports as described below. In addition, the MBRT will review proposals for
remedial actions proposed by Restoration Systems, LLC (RS), or any of the agencies
represented on the MBRT. The MBRT's role and responsibilities are more fully set forth
in Sections Il. C. 3 and 6 of the Guidance. The MBRT will work to reach consensus on
its actions.
4. The Corps, after consultation with the appropriate Federal and State review agencies
through the permit review process, shall make final decisions concerning the amount and
type of compensatory mitigation to be required for unavoidable, permitted wetland
impacts, and whether or not the use of credits from The Bank is appropriate to offset
those impacts. In the case of permit applications and compensatory mitigation required
solely under the Section 401 Water Quality Certification rules of North Carolina, the
N.C. Division of Water Quality (NCDWQ) will determine the amount of credits that can
be withdrawn from The Bank.
5. The parties to this agreement understand that, where practicable, on-site, in-kind
compensatory mitigation is preferred, unless use of The Bank is determined by the Corps
to be environmentally preferable.
Mitigation Plan
6. The Bank is a 19.1 acre portion of an active farm in northeast Alamance County, which is
utilized for grazing horses and production of hay. Approximately 3782 linear feet of
stream associated with an unnamed tributary to Boyds Creek and its secondary
tributaries, as well as 9.2 acres of hydric soils exhibit mitigation potential within The
Bank. These areas are accessible to livestock and are regularly maintained and mowed
for hay production, resulting in local disturbances to stream banks and wetland soil
surfaces. Historical land use practices, including the maintenance and removal of
riparian vegetation, and the relocation, dredging, and straightening of onsite streams has
resulted in degraded water quality, unstable channel characteristics (stream entrenchment,
erosion, and bank collapse), and reduced storage capacity/floodwater attenuation.
Proximity of stream channels to adjacent floodplains, including seepage areas and their
degraded morphology has removed wetland hydrology from adjacent landscapes that are
dominated by a hydric soil matrix. A more detailed description of the baseline conditions
on the site is contained in the enclosed Mitigation Plan.
7. RS will perform work described on pages 12-18 of the Mitigation Plan, including:
• Restoration of approximately 4300 linear feet of stable, riffle-pool stream channels
using Rosgen restoration methodologies;
• Enhancement (Level II) of approximately 147 linear feet of degraded stream channel;
• Establishment of vegetated buffers on both sides of affected stream channels;
• Restoration of 7.1 acres of riparian wetlands by: (1) restoring active floodplain
attributes through stream restoration/enhancement methods, (2) reducing the draw-
down effect of nearby channels, and (3) reestablishing a wetland plant community;
• Enhancement of 2.1 acres of wetlands by: reestablishing wetland plant community and
eliminating vegetation maintenance and livestock grazing activities.
Over 19 acres of woody vegetation will be planted, including 9.2 acres of a wetland community
and approximately 10 acres of a non-wetland, riparian community. In addition, substrate
modifications will be made to areas that are highly compacted from equipment and livestock
usage, and to add microtopograhpic variation in the land surfaces to facilitate slowing and
trapping surface water flows and accumulations.
The purpose of this work, and the objective of The Bank, is to:
• Remove nonpoint sources of pollution associated with agricultural activities including a)
removal of livestock from streams, stream banks, and floodplains; b) cessation of
broadcasting fertilizer, pesticides, and other agricultural materials into and adjacent to
The Bank streams and wetlands; and c) provide a vegetative buffer adjacent to streams
and wetlands to treat surface runoff, which may be laden with sediment and/or
agricultural pollutants.
• Reduce sedimentation within onsite and downstream receiving waters through a)
reduction of bank erosion associated with hoof shear, vegetation maintenance, and
agricultural plowing, and b) planting a forested vegetative buffer adjacent to The Bank
streams.
2
• Reestablish stream stability and the streams' capacity to transport watershed flows and
sediment loads by restoring a stable dimension, pattern, and profile supported by natural
in-stream habitat and grade/bank stabilization structures.
• Promote floodwater attenuation through a) reconnection of bankfull stream flows to the
abandoned floodplain terrace, b) reduce floodwater velocities within smaller catchment
basins by restoring the secondary, entrenched tributaries, c) restore depressional
floodplain wetlands, thereby increasing the storage capacity for floodwaters within the
Site, and d) revegetate floodplains to increase frictional resistance on floodwaters
crossing The Bank.
• Improve aquatic habitats by enhancing stream bed variability and the wise use of in-
stream structures.
• Provide wildlife habitat, including seepage slope wetlands, which are relatively
uncommon in the piedmont portion of the State.
• Provide a legitimate opportunity for providing compensatory mitigation to offset
unavoidable impacts authorized by the Corps and NCDWQ in consultation with state and
federal partner agencies.
8. The Sponsor will monitor The Bank Site as described on pages 18-19 of the Mitigation
Plan, until such time as the MBRT determines that the success criteria described on pages 19-20
of the Mitigation Plan have been met.
9. RS is responsible for assuring the success of the stream and wetland restoration and
wetland enhancement activities at The Bank, and for the overall operation and management of
The Bank.
10. RS will provide to each member of the MBRT annual monitoring reports, which will
provide data and analyses addressing vegetation success within the context of stated success
criteria on pages 18-19 of the Mitigation Plan. In addition, the annual monitoring report will
address wetland hydrological data and hydrogeomorphic data associated with restored stream
channels. These data and analyses, and the results of benthic macroinvertebrate sampling, as
described on pages 19 will also be included in the annual report.
11. The Corps shall review said reports, and may, at any time, after consultation with the
Sponsor and the MBRT, direct RS to take remedial action at The Bank. Remedial action
required by the Corps shall be designed to achieve the success criteria specified above. All
remedial actions required under this paragraph shall include a work schedule and monitoring
criteria that will take into account physical and climactic conditions.
12. RS shall implement any remedial measures required pursuant to the above.
13. In the event RS determines that remedial action may be necessary to achieve the required
success criteria, it shall provide notice of such proposed remedial action to all members of the
MBRT. No remedial actions shall be taken without the concurrence of the Corps, in consultation
with the MBRT.
14. The members of the MBRT will be allowed reasonable access to The Bank Property for
the purposes of inspection of The Bank and compliance monitoring of the Mitigation Plan.
Use of Mitigation Credits
15. The Geographical Service Area (GSA) is the designated area wherein a bank can
reasonably be expected to provide appropriate compensation for impacts to wetland or other
aquatic resources. The GSA for The Bank shall include the Cape Fear River Basin Hydrologic
Unit 03030002 in North Carolina. Use of The Bank to compensate for impacts beyond the
geographic service area may be considered by the Corps or the NCDWQ on a case-by-case basis.
Table 1 below provides a breakdown of proposed mitigation quantities and their equivalent
mitigation units (SMUs, or WMUs).
Table 1. Proposed Mitigation Quantities vs. Mitigation Credits
Proposed Mitigation Mitigation Units
Proposed Mitigation Activity Quantity (Credits)
Sreams Wetlands Stream Units Wetland Units
(10 (ac) (SMUs) (WMUs)
Stream Restoration
Stream Enhancement (Level II)
Riverine Wetland Restoration
Nonriverine Wetland Restoration
Riverine Wetland Enhancement
Nonriverine Wetland Enhancement 0.6 I 0.3
3._ + Total: 4357 Total: 8.15
16. It is anticipated by the parties to this agreement that use of mitigation credits shall be "in-
kind;" that is, that riverine or non-riverine wetland credits will be used to offset riverine or
non-riverine wetland impacts.
17. It is anticipated by the parties that in most cases in which the Corps, after consultation
with the MBRT, has determined that wetland mitigation credits from The Bank may be used to
offset wetland impacts authorized by Section 404 permits, for every one acre of impacts, two
credits will be debited from The Bank. One of those credits must be a restoration credit; the
remaining credit will be made up of any combination of restoration and enhancement credits, as
selected by RS and approved by the Corps during its permit process. For streams, application of
credits to impacts will be on a 1:1 (restoration credit for impact) on a linear foot basis, where 1
linear foot of restored stream is equal to 1 stream mitigation credit. Deviations from this
compensation ratio may be authorized by the Corps on a case-by-case basis where justified by
considerations of functions of the wetlands impacted, the severity of the wetland impacts,
whether the compensatory mitigation is in-kind, and the physical proximity of the wetland
impacts to The Bank site, except that in all cases, a minimum of a one-to-one ratio of impact
acres to restoration mitigation credits (acres) must be met.
4
18. Notwithstanding the above, all decisions concerning the appropriateness of using credits
from The Bank to offset impacts to waters and wetlands, as well as all decisions concerning the
amount and type of such credits to be used to offset wetland and water impacts authorized by
Department of the Army permits, shall be made by the Corps of Engineers, pursuant to Section
404 of the Clean Water Act and implementing regulations and guidance, after notice of any
proposed use of The Bank to the members of the MBRT, and consultation with the members of
the MBRT concerning such use. Notice to and consultation with the members of the MBRT
shall be through the permit review process.
19. Credit releases are authorized upon full and satisfactory completion of important
milestones. The first authorized release of credits Fifteen percent (15%) of The Bank's total
restoration credits shall be available for sale immediately upon execution of the MBI, an act
preconditioned on completion of the following:
a. Approval of the final mitigation plan;
b. Delivery of the financial assurance described in paragraph 23 of this MBI;
c. Recordation of the preservation mechanism described in paragraph 22 of this MBI, as
well as a title opinion covering the property acceptable to the Corps;
20. Release of the remaining credits will be determined by the successful completion of
specific tasks, as approved by the MBRT. Table 2 provides details of the proposed credit release
schedule as it correlates with task completion:
Table 2. Proposed Credit Release Schedule
Task Completion Verification Credit Release (% of total)
*I (Pre-Construction) Execution of MBI 15
II (Construction) Site Inspection by USACE 20
III (Planting and As-Builts) Delivery of As-Builts 20
IV (1St Year Monitoring) Monitoring Report 5
V (2nd Year Monitoring) Monitoring Report' 5
VI (3rd Year Monitoring) Monitoring Report 5
VII (4th Year Monitoring) Monitoring Report 5
VIII (5th Year Monitoring) Monitoring Report 25**
*Task 1 includes: execution of MBI , MBRT approval of Mitigation Plan, delivery of financial
assurances, recordation of conservation easement and delivery of title opinion to MBRT. ** Denotes that
release of 25% of credits is contingent upon at least one occurrence of a bankfull event during the
previous five years. In the absence of a bank full event, release is limited to 15% with the 10% balance
available following the occurrence of a bankfull event.
The above schedule applies only if RS documents acceptable survival and growth of planted
vegetation, and attainment of acceptable wetland hydrology as described under the success
criteria in the monitoring section of the mitigation plan. The final 25% of credits will be
available for sale only upon a determination by the MBRT of functional success as defined in the
mitigation plan.
21. RS commits to developing accounting procedures acceptable to the MBRT for
maintaining accurate records of debits made from The Bank. Such procedures shall include the
generation of a report by RS showing credits used at the time they are debited from The Bank,
which RS shall provide within 30 days of the debit to each member of the MBRT. In addition,
RS shall prepare an annual report, on each anniversary of the date of execution of this agreement,
showing all credits used, and the balance of credits remaining, to each member of the MBRT,
until such time as all of the credits have been utilized, or this agreement is otherwise terminated.
All reports shall identify credits debited and remaining by type of credit (e. g., pocosin wetland),
and shall include for each reported debit the Corps' Action ID number for the permit for which
the credits were utilized.
Property Disposition
22. RS commits to the preparation of a conservation easement, in a form acceptable to the
MBRT, sufficient to protect The Bank site in perpetuity. The conservation easement shall be
perpetual, preserve all natural areas, and prohibit all use of the property inconsistent with its use
as mitigation property, including any activity that would materially alter the biological integrity
or functional and educational value of wetlands within The Bank site, consistent with the
mitigation plan. The purpose of the conservation easement will be to assure that future use of
The Bank site will result in the restoration, protection, maintenance and enhancement of wetland
and stream functions described in the mitigation plan. RS shall deliver a title opinion acceptable
to the Corps covering the mitigation property. The property shall be free and clear of any
encumbrances that would conflict with its use as mitigation, including, but not limited to, any
liens that have priority over the recorded preservation mechanism.
Financial Assurances
23. RS shall provide a performance bond to the Corps naming it as the Obligee in the amount
of $450,000 prior to the signing of the Mitigation Banking Instrument to cover all costs related to
the design, construction, and planting of the site. This includes but is not limited to: boundary
surveys, topographic mapping, sediment and erosion control measures, earthwork, planting with
contingency cost of 50%, installation of monitoring gauges, control of invasive species, and
delivery of As-Built drawings. Upon delivery of the As-Built drawings, RS shall provide a
performance bond to the Corps naming it as the Obligee for costs related to site monitoring for a
period of five years in the amount of $125,000. This includes but is not limited to: travel to the
site, downloading of monitoring gauges, sampling of vegetation plots, cross sections on riffles
and pools, pebble counts, visual assessment of in-stream structures, a photographic record of pre
and post restoration conditions, and all other tasks detailed in section 6.0 Monitoring of the
mitigation plan.
Long-term Management
24. RS shall implement the long-term management measures described in the Mitigation Plan
within 12 months of the MBRT's declaration that The Bank has achieved success.
Miscellaneous
25. Any agency participant may terminate its participation in the MBRT with notice in
writing to all other parties to this agreement. Termination shall be effective seven (7) days from
placing said notices in the United States mail. Member withdrawal shall not affect any prior sale
of credits and all remaining parties shall continue to implement and enforce the terms of this
MBI. Except for termination as described above, this agreement may be modified only with the
written agreement of all remaining parties to this agreement at the time of the modification.
26. Any delay or failure of RS shall not constitute a default hereunder if and to the extent that
such delay or failure is primarily caused by any act, event or conditions beyond RS's reasonable
control and significantly adversely affects its ability to perform its obligations hereunder
including: (i) acts of God, lightning, earthquake, fire, landslide, drought, hurricane, storm, flood,
or interference by third parties; (ii) condemnation or other taking by any governmental body; (iii)
change in applicable law, regulation, rule, ordinance or permit condition, or the interpretation or
enforcement thereof, (iv) any order, judgment, action or determination of any federal, state or
local court, administrative agency or government body; or (v) the suspension or interruption of
any permit, license, consent, authorization or approval. If the performance of RS is affected by
any such event, RS shall give written notice thereof to the MBRT as soon as is reasonably
practicable. If such event occurs before the final availability of all credits for sale, RS shall take
remedial action to restore the property to its condition prior to such event, in a manner sufficient
to provide adequate mitigation to cover credits that were sold prior to such delay or failure to
compensate for impacts to waters, including wetlands, authorized by Department of the Army
permits. Such remedial action shall be taken by RS only to the extent necessary and appropriate,
as determined by the MBRT.
7
MITIGATION PLAN
CRIPPLE CREEK MITIGATION BANK
Developed Through
RESTORATION AND ENHANCEMENT OF
UNNAMED TRIBUTARIES TO BOYD CREEK
AND ADJACENT PALUSTRINE WETLANDS
Alamance County, North Carolina
PREPARED BY:
RESTORATION SYSTEMS, LLC
1101 HAYNES STREET, SUITE 107
RALEIGH, NORTH CAROLINA 27604
.nrss?l;:?xx?:?e
AND
AXIOM ENVIRONMENTAL, INC.
2126 ROWLAND POND DRIVE
WILLOW SPRING, NORTH CAROLINA 27592
Axiom Environmental, Inc.
MARCH 2007
EXECUTIVE SUMMARY
Restoration Systems proposes the establishment of a stream and wetland mitigation bank at the Cripple
Creek Site (The Bank) approximately two miles northeast of Burlington, in northeast Alamance County.
The Bank is located within the Cape Fear River Basin in 14-digit United States Geological Survey
(USGS) Cataloging Unit and Targeted Local Watershed 03030002030050 of the South Atlantic/Gulf
Region (North Carolina Division of Water Quality [NCDWQ] subbasin number 03-06-02).
The Bank encompasses approximately 19.1 acres of land that is utilized for livestock grazing and hay
production. Approximately 3782 linear feet of stream associated with an unnamed tributary to Boyds
Creek and its secondary tributaries, as well as 9.2 acres of hydric soil exhibit mitigation potential within
The Bank. These areas are accessible to livestock and are routinely cleared and mowed for hay
production, resulting in local disturbances to stream banks and wetland soil surfaces. Additional land use
practices including the maintenance and removal of riparian vegetation, and relocation, dredging, and
straightening of onsite streams has resulted in degraded water quality, unstable channel characteristics
(stream entrenchment, erosion, and bank collapse), and reduced storage capacity/floodwater attenuation.
The primary goals of this stream and wetland restoration project focus on improving water quality,
enhancing flood attenuation, and restoring aquatic and riparian habitat, which will be accomplished by:
1. Removing nonpoint sources of pollution associated with agricultural activities including a)
excluding livestock from streams, stream banks, and floodplains; b) eliminating the broadcasting
of fertilizer, pesticides, and other agricultural materials into and adjacent to streams and wetlands;
and c) establishing a vegetative buffer adjacent to streams and wetlands to treat surface runoff
which may be laden with sediment and/or agricultural pollutants from the adjacent landscape.
2. Reducing sedimentation within onsite and downstream receiving waters through a) reduction of
bank erosion associated with hoof shear, vegetation maintenance, and agricultural plowing, and
b) planting a diverse woody vegetative buffer adjacent to The Bank's streams.
3. Reestablishing stream stability and the capacity to transport watershed flows and sediment loads
by restoring a stable dimension, pattern, and profile supported by natural in-stream habitat and
gradelbank stabilization structures.
4. Promoting floodwater attenuation through a) reconnecting bankfull stream flows to the
abandoned floodplain terrace, b) restoring secondary, entrenched tributaries thereby reducing
floodwater velocities within smaller catchment basins, c) restoring depressional floodplain
wetlands, thereby increasing the storage capacity for floodwaters within The Bank, and d)
revegetating The Bank's floodplains to increase frictional resistance on floodwaters crossing The
Bank.
5. Improving aquatic habitat by enhancing stream bed variability and the use of in-stream structures.
6. Providing wildlife habitat including seepage slope wetlands, which are uncommon in the
piedmont portion of the State.
The Bank's mitigation plan includes 1) construction of a stable, riffle-pool stream channel, 2)
restoration/enhancement of historic wetland functions, 3) enhancement of water quality functions (reduce
nonpoint source sedimentation and nutrient inputs), 4) restoration of a natural woody riparian buffer along
The Bank's stream reaches, 5) restoration of wildlife habitat associated with a riparian corridor/stable
stream, and 6) establishment of a permanent conservation easement which will encompass all restoration
activities.

Restoration options outlined in this report are as follows:
Proposed Mitigation Quantity Proposed Mitigation Units
Credits
Proposed Mitigation Activity
Streams
(linear feet)
Wetlands
(acres)
Stream Units
(SMUs)
Wetland Units
(WMUs)
T
Stream Restoration 4300 4300
Stream Enhancement (Level II) 142
- 57
- - - - -- _
}tiverine Wetland Restoration 5.9 5.9
Riverine Wetland Enhancement 1.5 0.75
Nonriverine Wetland Restoration 1.2 _ J 1.2
Nonriverine Wetland Enhancement 0.6 0.3
Total: 4357 Total: 8.15
After completion of the project The Bank will offer 4357 Stream Mitigation Units and 8.15 Wetland
Mitigation Units.
No federally protected species are listed for Alamance County; however, two Federal Species of Concern
that are protected by the state have potential habitat within The Bank: 1) Carolina creekshell (Villosa
vaughaniana) and 2) yellow lampmussel (Lampsilis cariosa). Although not protected by federal law, the
Fish and Wildlife Service strongly advises that surveys be conducted for aquatic species (fish and
mussels) in the state with status designations of Endangered or Threatened. Accordingly, Restoration
Systems intends to conduct appropriate investigations to determine if either of the listed mussel species
may be present in The Bank streams, or in downstream waters in close proximity to The Bank.
TABLE OF CONTENTS
EXECUTIVE SUMMARY ....................................................................... ...............................................I
1.0 INTRODUCTION ............................................................................. ..............................................1
1.1 Project Goals .......................................................................... ..............................................1
2.0 EXISTING CONDITIONS ................................................................ .............................................. 2
2.1 Physiography, Topography, and Land Use .............................. ......................................... 3
2.2 Water Quality ......................................................................... ..............................................4
2.3 Vegetation .............................................................................. ..............................................5
2.4 Soils and Land Form .............................................................. .............................................. 6
2.5 Jurisdictional Wetlands ........................................................... .............................................. 7
3.0 STREAM CHARACTERISTICS ...................................................... ............................................... 8
3.1 Hydrology ............................................................................. ............................................... 8
3.2 Stream Classification ............................................................. ............................................. 10
3.2.1 Dimension ....................................................................... .............................................10
3.2.2 Profile ............................................................................. .............................................11
3.2.3 Plan Form ........................................................................ ............................................. 11
4.0 REFERENCE FOREST ECOSYSTEM ............................................ ............................................. 12
5.0 RESTORATION PLAN .................................................................... ............................................. 12
5.1 Stream Restoration ................................................................ .............................................13
5.1.1 Reconstruction on New Location ..................................... ............................................. 13
5.1.2 In-Stream Structures ........................................................ ............................................. 15
5.1.3 Stream Reconstruction In-Place ....................................... ............................................. 16
5.2 Stream Enhancement (Level II) ............................................. ............................................. 16
5.3 Wetland Restoration/Enhancement ........................................ ............................................. 16
5.4 Vegetative Planting ............................................................... ............................................. 17
6.0 MONITORING PLAN ...................................................................... ............................................. 18
6.1 Stream Monitoring ................................................................ ............................................. 18
6.2 Vegetation Monitoring .......................................................... ............................................. 18
6.3 Hydrological Monitoring ....................................................... .............................................18
6.4 Biotic Community Changes ................................................... ............................................. 19
7.0 AVAILABLE CREDIT AND PROPOSED RELEASE .................................................................. 19
7.1 Credit Determination ............................................................. ............................................. 19
7.2 Credit Release Schedule ....................................................... .............................................. 20
7.3 Perpetual Maintenance of Mitigation Bank ......................................................................... 20
7.4 Nonproject Development Scenario ....................................... .............................................. 21
7.5 Corporate Experience ........................................................... .............................................. 21
8.0 JURISDICTIONAL TOPICS ........................................................... ..............................................21
8.1 Waters of the United States .................................................. .............................................. 21
8.2 Rare and Protected Species ................................................... .............................................. 22
8.2.1 Federally Protected Species ............................................ .............................................. 22
8.2.2 Federal Species of Concern ............................................ .............................................. 22
9.0 CULTURAL RESOURCES ............................................................. .............................................. 23
10. 0 REFERENCES ................................................................................ .............................................. 24
APPENDICES
Appendix A. Figures
Appendix B. NCDWQ Stream Forms
LIST OF FIGURES
Figure 1. The Bank Location
Figure 2. Mitigation Service Area
Figure 3. Drainage Area and Topography
Figure 4. Existing Conditions
Figure 5. NRCS Soils Map
Figure 6. Proposed Conditions
Figure 7. Typical Structure Details
LIST OF TABLES
Table 1.
Table 2.
Table 4.
Table 5.
Table 6.
Table 7.
Table 8.
Appendix A
Appendix A
Appendix A
Appendix A
Appendix A
Appendix A
Appendix A
Existing Stream Characteristics ................................................................................................. 4
NRCS Soils Mapped within The Bank ...................................................................................... 6
Stream Geometry and Classification .......................................................................................... 9
Reference Forest Ecosystem .................................................................................................... 12
Proposed Mitigation Quantities vs. Mitigation Credits ............................................................. 20
Proposed Credit Release Schedule ........................................................................................... 20
Federal Species of Concern ..................................................................................................... 22
IV
MITIGATION PLAN
CRIPPLE CREEK MITIGATION BANK
RESTORATION AND ENHANCEMENT OF
UNNAMED TRIBUTARIES TO BOYD CREEK
AND ADJACENT PALUSTRINE WETLANDS
Alamance County, North Carolina
1.0 INTRODUCTION
Restoration Systems proposes the establishment of a stream and wetland mitigation bank at the Cripple
Creek Site (The Bank), which is located approximately two miles northeast of Burlington, in northeast
Alamance County (Figures 1 and 2, Appendix A). The Bank encompasses approximately 19.1 acres of
land that is utilized for livestock grazing and hay production. Approximately 3782 linear feet of stream
associated with an unnamed tributary to Boyds Creek and its secondary tributaries, as well as 9.2 acres of
hydric soil exhibit mitigation potential within The Bank. These areas are accessible to livestock and are
routinely cleared and mowed for hay production, resulting in local disturbances to stream banks and
wetland soil surfaces. Additional land use practices including the maintenance and removal of riparian
vegetation, and relocation, dredging, and straightening of onsite streams has resulted in degraded water
quality, unstable channel characteristics (stream entrenchment, erosion, and bank collapse), and reduced
storage capacity/floodwater attenuation.
Directions to The Bank:
? Take exit 150 off Interstate 85-40 just east of Burlington
? Travel north/towards Haw River/Green Level for - 2.2 miles
? At the Highway 49 junction, turn right/travel north on Highway 49 towards Green Level/Roxboro
for -2.7 miles
? Turn left on Sandy Cross Road (at the Sandy Cross Mini Mart) for -1.6 miles
? Turn right on Fonville Road for -1.7 miles to a T-intersection
? Turn left on Deep Creek Road for -0.9 mile
? Turn left on Roney-Lineberry Road just after Deep Creek Baptist Church for -0.3 mile
? After passing through a trailer park, take a left at the stop sign into The Bank
? Point in center of road crossing at the upstream end of the Main Channel
Latitude: 36.138332274 °N, Longitude: 79.380963290 °W
1.1 PROJECT GOALS
The primary goals of this stream and wetland restoration project focus on improving water quality,
enhancing flood attenuation, and restoring aquatic and riparian habitat, which will be accomplished by:
1. Removing nonpoint sources of pollution associated with agricultural activities including a)
excluding livestock from streams, stream banks, and floodplains; b) eliminating the broadcasting
of fertilizer, pesticides, and other agricultural materials into and adjacent to streams and wetlands;
and c) establishing a vegetative buffer adjacent to streams and wetlands to treat surface runoff
which may be laden with sediment and/or agricultural pollutants from the adjacent landscape.
2. Reducing sedimentation within onsite and downstream receiving waters through a) reduction of
bank erosion associated with hoof shear, vegetation maintenance, and agricultural plowing, and
b) planting a diverse woody vegetative buffer adjacent to The Bank's streams.
Cripple Creek Mitigation Plan Restoration Systems, LLC
3. Reestablishing stream stability and the capacity to transport watershed flows and sediment loads
by restoring a stable dimension, pattern, and profile supported by natural in-stream habitat and
grade/bank stabilization structures.
4. Promoting floodwater attenuation through a) reconnecting bankfull stream flows to the
abandoned floodplain terrace, b) restoring secondary, entrenched tributaries thereby reducing
floodwater velocities within smaller catchment basins, c) restoring depressional floodplain
wetlands, thereby increasing the storage capacity for floodwaters within The Bank, and d)
revegetating The Bank's floodplains to increase frictional resistance on floodwaters crossing The
Bank.
5. Improving aquatic habitat by enhancing stream bed variability and the use of in-stream structures.
6. Providing wildlife habitat including seepage slope wetlands, which are uncommon in the
piedmont portion of the State.
These goals will be achieved by:
Providing 4357 Stream Mitigation Units.
o Restoring approximately 4300 linear feet of stream channel through construction of stable
channels, thereby reestablishing stable dimension, pattern, and profile.
o Enhancing (Level II) approximately 142 linear feet of stream channel through the removal of
invasive species, cessation of livestock grazing, and bank stabilization.
Providing 8.15 Wetland Mitigation Units.
o Restoring approximately 5.9 acres of riverine wetlands and 1.2 acres of nonriverine wetlands
by reconstructing channels of tributaries that exhibit more natural, historic interplay with the
floodplain, filling ditched channels, rehydrating floodplain soils, and planting with native
woody vegetation.
o Enhancing approximately 1.5 acres of riverine wetlands and 0.6 acres of nonriverine wetlands
by reconstructing The Bank's tributaries within the floodplain, rehydrating floodplain soils,
removing livestock, and planting with native woody vegetation.
Planting a native woody riparian buffer adjacent to restored/enhanced streams and wetlands
within The Bank.
• Protecting The Bank in perpetuity with a conservation easement.
2.0 EXISTING CONDITIONS
The Bank is characterized by pastureland, which is utilized by the Taylor family for horse grazing and
hay production (Figure 4, Appendix A). A horse complex including barn, riding ring, and feed storage
facility is located adjacent to the western margins of The Bank. Horses predominantly graze the northern
half of The Bank and are constrained by natural drainage
features, permanent fences, and temporary electric fences.
The southern half of The Bank is characterized by hay
pasture and mixed forest. An agricultural road traverses
the northern edges of The Bank and provides access to the
horse complex and hay fields that lie in the eastern half of
the property.
The main hydrologic features of The Bank include an
unnamed tributary to Boyds Creek and associated
secondary tributaries and floodplains (Figures 3 and 4,
Appendix A). The unnamed tributary to Boyds Creek

Looking from the top of the Main Channel at the
narrow, disturbed buffer and adjacent hydric
soils within the pastureland.
2
Cripple Creek Mitigation Plan Restoration Systems, LLC
r
e <
1 fr Yx?? ro?.'`
619
??" ?I • "??4466 vv ?4• y
Straightened Main Channel Straightened Southern Tributary
??L?< dx t: 4 F'.-... .::9• _ ? ?Gi" A?"?res.?:a?f,•?.t? .. e.'?tiw ....:" 1 i; (Main Channel) drains an approximately 0.4-square mile watershed at The Bank's outfall. The unnamed
tributary to Boyds Creek is a second-order bank-to-bank stream system, which has been dredged and
straightened and is characterized by eroding banks, bimodal sediment transport, and a narrow and sparse,
disturbed riparian buffer. The two secondary tributaries (Northern Tributary and Southern Tributary) are
disturbed first-order streams (Figure 4, Appendix A).
Approximately 9.2 acres of The Bank's land area are currently underlain by hydric soils, which have been
impacted by stream channel entrenchment, ditching, excavation of pools in the floodplain, casting of spoil
in wetlands, and removal of vegetation. Hydric soils have been mapped by the Natural Resource
Conservation Service (MRCS) as Worsham and Chewacla; however, a significant portion of the Chewacla
mapping unit appears to be characterized by Wehadkee/Worsham inclusions.
2.1 PHYSIOGRAPHY, TOPOGRAPHY, AND LAND USE
The Bank is located in the Southern Outer Piedmont portion of the Piedmont Ecoregion of North Carolina
within United States Geological Survey (USGS) Cataloging Unit 03030002 (North Carolina Division of
Water Quality [NCDWQ] subbasin number 03-06-02) of the Cape Fear River Basin. Regional
physiography is characterized by dissected, irregular plains and some low, rounded hills and ridges with
low to moderate gradient streams over cobble, gravel, and sand-dominated substrates. Onsite elevations
range from a high of 630 feet National Geodetic Vertical Datum (NGVD) on slopes adjacent to the
northern tributary at the upstream end of The Bank to a low of approximately 610 feet NGVD at The
Bank's outfall (USGS Lake Burlington, North Carolina 7.5-minute topographic quadrangles).
The Bank provides water quality functions to a 0.4-square mile watershed at The Bank outfall (Figure 3,
Appendix A). The watershed is dominated by timber production, agricultural land, and residential
development. A high-density residential trailer park is situated in the headwaters of the drainage basin
and drainage from State Road (SR) 1729 and SR 1735 flows into The Bank's tributaries (see picture
below). Impervious surfaces account for less than 10 percent of the upstream watershed land surface.
Onsite land use is characterized by agricultural land (horse pasture and hay production) and forest (Figure
4, Appendix A). Horses have indiscriminate access to onsite streams and wetlands, resulting in
degradation of stream banks through vegetative cropping and hoof shear. Hay is produced throughout the
remainder of The Bank, with the exception of a mixed pine-hardwood forest located at the southern extent
of The Bank. Riparian vegetation adjacent to restoration/enhancement reaches of onsite streams is sparse
and disturbed due to livestock grazing, bush hogging, and regular maintenance activities.
3
Cripple Creek Mitigation Plan Restoration Systems, LLC
The Bank encompasses 3780 linear
feet of stream channels including
three unnamed tributaries to Boyds
Creek (Main Channel, Northern
Tributary, and Southern Tributary).
Table 1 gives characteristics of The
Bank's streams; the locations of each
are depicted in Figure 4 (Appendix
A).
Approximately 9.2 acres of The Bank
are underlain by hydric soils, which
may have historically supported
jurisdictional wetlands. Hydric soils
are located on slopes and within
floodplains adjacent to onsite streams.
Extensive floodplain manipulations associated with stream ditching and straightening, deforestation,
floodplain ditching, and excavation of small ponds in the floodplain have effectively removed
groundwater hydrology from these areas. These features are discussed in more detail in Section 2.5
(Jurisdictional Wetlands).
TahIP 1 F.victina CtrPam Charartorictirc

Stream Reach Stream Length
b
(linear feet) USGS

Stream Order
Stream Classification
Main Channel 1850 second perennial
Northern Tributary 832 first intermittent*
Southern Tributary 1 100 first intermittent*
Total 3782
I These tributaries are depicted as intermittent on the USON T.) minute topographic quadrangle anoior NKU6 sous mapping, nowever, streams
exhibited characteristics of perennial streams during field investigations (see NCDWQ stream classification forms in Appendix B).
2.2 WATER QUALITY
The Bank is located within the Cape Fear River Basin in 14-digit USGS Cataloging Unit and Targeted
Local Watershed 03030002030050 of the South Atlantic/Gulf Region (NCDWQ subbasin number 03-
06-02) (Figure 2, Appendix A) (NCWRP 2001). Topographic features of The Bank drain to Boyds Creek
and the Haw River, which have been assigned Stream Index Numbers 16-16 and 16-(1), respectively. In
the vicinity of The Bank, these waters have been assigned a designation of C, NSW (NCDWQ 2000).
Streams with a designation of C are suitable for aquatic life propagation and survival, fishing, wildlife,
secondary recreation, and agriculture. Secondary recreation includes wading, boating, and other uses not
involving human body contact with waters on an organized or frequent basis. The designation NSW
(Nutrient Sensitive Waters) includes areas with water quality problems associated with excessive plant
growth resulting from nutrient enrichment.
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NCDWQ has assembled a list of impaired waterbodies according to the Clean Water Act Section 303(d)
and 40 CFR 130.7, which is a comprehensive public accounting of all impaired waterbodies. An
impaired waterbody is one that does not meet water quality standards including designated uses, numeric
and narrative criteria, and anti-degradation requirements defined in 40 CFR 131. The Bank's tributaries
are not listed on the NCDWQ final 2004 or draft 2006 303(d) lists; however, the section of the Haw River
that The Bank's tributaries drain to is on the 303(d) lists due to impaired biological integrity most likely
resulting from nonpoint agricultural and urban runoff and elevated levels of fecal coliform bacteria
(NCDWQ 2006a, 2006b).
The proposed project is supportive of the reduction in Total Maximum Daily Loads (TMDLs) which will
serve to address existing deficiencies with the watershed, and will assist in meeting mitigation goals in the
Cape Fear River Basin Cataloging Unit and Targeted Local Watershed 03030002030050.
2.3 VEGETATION
The Bank is composed of agricultural land managed for horses and hay production, early successional
disturbed forests, and an early successional disturbed wetland area.
Disturbed forest fragments occur along the southern
margin of The Bank and adjacent to site streams, and r
are predominately comprised of early successional ` f
species. The more prolific tree species include
sweetgum (Liquidambar styraciflua), black cherry .'
(Prunus serotina), red maple (Acer° rubrurn), loblolly
pine (Pious taeda), short-needle pine (P. echinata)
and Virginia pine (P. virginiana) with a dense
understory composed of blackberry (Rubus sp.),
Disturbed stream buffer with adjacent
honeysuckle (Lonicera japonica), greenbrier (Smilax
R pasture/hay fields.
sp.), and American holly (Ilex opaca). A sparse _ .ZAI?_,, * ?K:.:W}
subcanopy and canopy includes Virginia pine (Pious virginiana), eastern red cedar (Juniperus
virginiana), American beech (Fagus grandifolia), ironwood (Carpinus caroliniana), river birch (Betula
nigra), various oak species (Quercus spp.), and tuliptree (Liriodendron tulipifera).
A small, disturbed wetland pocket is located at the
northern end of The Bank on the Northern Tributary,
immediately below an off-site pond and road crossing.
This area is accessible to livestock and contains
species such as black willow (Salix nigra), cattail
(Typha sp.), and smartweed (Polygonum sp.).
Reforestation using hardwood species is proposed over
approximately 19.1 acres of The Bank, including areas
Small wetland pocket below pond and road crossing of pastureland and disturbed forest. Plant community
on the Northern Tributary; contains disturbed composition is expected to vary from Piedmont
vegetation. Alluvial Forest to Dry-Mesic Oak-Hickory Forest, as
described in Classification of the Natural Communities
of North Carolina, Third Approximation (Schafale and Weakley 1990). Forest communities may vary
5
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based on floodplain size, flooding regime, and/or topographic variations. Species composition will mimic
reference forests within undisturbed floodplains up or downstream of The Bank and offsite reference
forests. An ecological approach will be taken for restoration of wetlands and riparian buffer plant
communities; therefore, a varied forest structure will help achieve habitat diversity.
2.4 SOILS AND LAND FORM
Soils that occur within The Bank, according to the Soil Survey of Alamance County, North Carolina
(MRCS unpublished) are depicted in Figure 5 (Appendix A) and are described in Table 2.
Table 2. NRCS Soils Mapped within The Bank
Nonhydric Hydric Family Description
Soil Series Status*
Appling Nonhydric Typic This series consists of well-drained, moderately permeable soils of
Hapludult broad ridges and long, linear side slopes. Slopes are generally
between 2 and 10 percent. Depth to seasonal high water table occurs
below 6.0 feet. Soft bedrock occurs at a depth of more than 60
inches.
Cecil Nonhydric Typic This series consists of well-drained, moderately permeable soils of
Hapludults broad ridges and long, linear side slopes. Slopes are generally
between 2 and 15 percent. Depth to seasonal high water table occurs
below 6.0 feet. Soft bedrock occurs at a depth of more than 60
inches.
Chewacla Class B Fluvaquentic This series consists of frequently flooded, somewhat poorly drained,
Dystrochrept moderately permeable soils of floodplains adjacent to stream
channels. Slopes are generally between 0 and 2 percent. Depth to
seasonal high water table occurs at 0.5 to 1.5 feet. Soft bedrock
occurs at a depth of more than 60 inches.
Enon Nonhydric Ultic This series consists of well-drained, slowly permeable soils of long,
Hapludalf narrow side slopes on uplands. Slopes are generally between 6 and
15 percent. Depth to seasonal high water table occurs at 1.0 to 2.0
feet. Soft bedrock occurs at a depth of more than 60 inches.
Iredell Nonhydric Typic This series consists of well-drained, slowly permeable soils of flats
Hapludalf and concave areas near the heads of intermittent drainageways.
Slopes are generally between 0 and 4 percent. Depth to seasonal
high water table occurs at greater than 6 feet; however, due to slow
permeabilities a perched watertable often occurs at about 18 inches.
Soft bedrock occurs at a depth of 20 to 40 inches.
Worsham Class A Typic This series consists of poorly drained, slow to very slowly
Endoaquult permeable soils of floodplains adjacent to headwater drainageways.
Slopes are generally between 0 and 4 percent. Depth to seasonal
high water table occurs at 0.5 to 1.0 feet. Bedrock occurs at a depth
of more than 60 inches.
" Class A= Hydric soils; Class B = Nonhydric soils that may contain inclusions ofhydric soils.
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Cripple Creek Mitigation Plan Restoration Systems, LLC
Restorable portions of The Bank are predominantly underlain by soils of the Worsham and Chewacla
series; however, a significant portion of the floodplain mapped as Chewacla is characterized by
Wehadkee/Worsham inclusions. Floodplain soils are grey to gley in color and have been impacted by
plowing, land clearing, ditching, and incision of adjacent stream channels.
2.5 JURISDICTIONAL WETLANDS
Jurisdictional wetlands are defined by the presence of three criteria: hydrophytic vegetation, hydric soils,
and evidence of wetland hydrology during the growing season (Environmental Laboratory 1987).
Portions of The Bank supporting jurisdictional wetlands may originally have been characterized by
palustrine, forested wetlands which were seasonally flooded. However, onsite.wetland areas have been
impacted by livestock trampling, deforestation, groundwater draw-down from stream channel incision,
floodplain ditching, and excavation of the floodplain.
Within The Bank's boundaries, approximately 9.2 acres of floodplain and adjacent side slopes are
underlain by hydric soils (Figure 4, Appendix A). Onsite hydric soils and wetlands are grey to gley in
color and are compacted and pockmarked by livestock trampling. Livestock trampling, grazing and
annual mowing for harvest of hay has also resulted in a vegetative community that is herbaceous in
nature. Groundwater springs and surface runoff contribute hydrology to these areas, although the
dominant hydrological influence is the lateral draw-down effect of incised streams and maintained
ditches.
Some portions of onsite wetlands have been impacted by groundwater table alterations, ditching,
dredging, and discharge of fill material in the floodplain. Groundwater table fluctuations mainly occur
adjacent to entrenched stream channels, which have effectively lowered the groundwater table below
hydrologic thresholds outlined for wetland criteria. Preliminary groundwater modeling has been
conducted in order to quantify impacts to the groundwater table from onsite ditching and stream incision.
Groundwater Model
For this study, the Boussinesq equation was utilized to predict groundwater impacts associated with
floodplain ditching and stream channel incision. The Boussinesq equation represents a two-dimensional
general flow equation for unconfined aquifers. The equation has been applied in the past to predict the
decline in elevation of the water table near a pumping well as time progresses.
The Boussinesq equation was applied to The Bank's ditches and stream channels to predict the linear
distance of groundwater drawdown that exceeds 1 foot for 12.5-percent of the growing season. The
percentage of the growing season (12.5 percent) was selected based upon guidance from the Corps of
Engineers Wetland Delineation Manual (Environmental Laboratory 1987). The equation is solved for
wetland impacts with data for the following variables: 1) equivalent hydraulic conductivity, 2) drainable
porosity, 3) an estimated depth to the impermeable layer or aquiclude, 4) the time duration of the
drawdown, 5) target water table depth (1 foot below the soil surface), and 6) minimum ditch depth.
Results from the Boussinesq equation predicted lateral effects for incised stream reaches in the range of
99 to 206 feet. Results of the Boussinesq equation are summarized in Table 3. Model predictions
indicate that the incised stream channels impact approximately 7.1 acres of The Bank's hydric soils
through groundwater table drawdown. Figure 4 (Appendix A) depicts hydric soils drained as the result
lateral drawdown effects of incised streams versus hydric soils that are not drained. The general location
7
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of each hydric soil type is depicted on the USDA soils map in Figure 5 (Appendix A). Worsham soils
occur along the entire length of site streams, while an inclusion of Wehadkee occurs within the mapped
area of Chewacla soils located on the south side of the very upstream reach of the Main Channel.
Restoration efforts should focus on elevating groundwater tables through restoration of entrenched stream
channels, filling of secondary ditches, removal of livestock, and planting with native forest vegetation.
These measures will restore approximately 7.1 acres of jurisdictional wetland and enhance approximately
2.1 acre of wetland. Mitigation efforts should allow the floodplain to perform wetland functions such as
flood-flow suppression, nutrient cycling, pollutant removal, and provision of native species habitat.
Table 3. Results for Boussinesq Equation
Depth to
Ditch Depth Growing Drainable Ditch Impact
Soil Aquaclude Ksat (cm/hr)
(ft) Season (hrs) Porosity (cm) (ft)
(cm)
2 178 1.5 552 0.006 130
3 178 1.5 552 0.006 177
Worsham
4 178 1.5 552 0.006 198
5 178 1.5 552 0.006 206
2 152 3.3 552 0.018 99
3 152 3.3 552 0.018 135
Wehadkee
4 152 3.3 552 0.018 148
5 152 3.3 552 0.018 151
3.0 STREAM CHARACTERISTICS
The Bank's streams have been characterized based on fluvial geomorphic principles (Rosgen 1996).
Table 4 provides a summary of measured stream geometry attributes under existing conditions
(considered to be unstable) and a preliminary estimate of potentially stable stream attributes. Preliminary
estimates of stable stream attributes are based primarily upon data observations along the existing
reaches, measurements of two cross-sections within the Site (Figure 4, Appendix A), and regional curves
(Harman et al. 1999).
3.1 HYDROLOGY
This hydrophysiographic region is characterized by moderate rainfall with precipitation averaging
approximately 40-50 inches per year (MRCS unpublished). Drainage basin sizes range from 0.07-square
mile for the southern tributary to 0.4-square mile for the main channel at The Bank's outfall.
The Bank's discharge is dominated by a combination of upstream basin catchment, groundwater flow,
and precipitation. Based on regional curves (Harman et al. 1999), the bankfull discharge for a 0.4-square
mile watershed is expected to average 46 cubic feet per second, which is expected to occur approximately
every 1.3 to 1.5 years (Rosgen 1996, Leopold 1994).
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Cripple Creek Mitigation Plan Restoration Systems, LLC

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3.2 STREAM CLASSIFICATION
Stream geometry and substrate data have been evaluated to orient stream restoration based on a
classification utilizing fluvial geomorphic principles (Rosgen 1996). This. classification stratifies streams
into comparable groups based on pattern, dimension, profile, and substrate characteristics. Primary
components of the classification include degree of entrenchment, width-depth ratio, sinuosity, channel
slope, and stream substrate composition.
Historically, onsite stream reaches may have been characterized by E-type channels. E-type streams are
characterized as slightly entrenched, riffle-pool channels exhibiting high sinuosity (>1.5); however,
reference streams in the region typically are characterized by sinuosities slightly lower than 1.3. In North
Carolina, E-type streams often occur in narrow to wide valleys with well-developed alluvial floodplains
(Valley Type VIII). E-type streams typically exhibit a sequence of riffles and pools associated with a
sinuous flow pattern. E-type channels are typically considered stable. However, these streams are
sensitive to disturbance and may rapidly convert to other stream types.
Onsite streams appear to be progressing through a common evolutionary tendency found in piedmont
streams of North Carolina. As streams are dredged and straightened the water surface profile tends to
become oversteepened resulting in 1) the loss of horizontal flow vectors that maintain pools and 2) an
increase in erosive forces to channel bed and banks. The lack of deep rooted riparian vegetation and the
introduction of livestock into the channel appear to have exacerbated problems with erosion to onsite
channels.
Bed and bank erosion typically leads to channel downcutting and evolution of a stable E-type channel into
a G-type (gully) channel. Continued erosion eventually results in lateral extension of the G-type channel
into an F-type (widened gully) channel. The F-type channel will continue to widen laterally until the
channel is wide enough to support a stable C-type or E-type channel at a lower elevation and the original
floodplain is no longer subject to regular flooding.
The majority of onsite streams have been impacted by land clearing, erosive flows, livestock grazing,
hoof shear, and manipulation of the channels including dredging and straightening. Onsite streams are
expected to continue to erode and deposit sediment into receiving streams until a stable stream pattern has
been carved from the adjacent floodplain.
3.2.1 Dimension
Regional curves (Harman et al. 1999) were utilized to determine bankfull channel cross-sectional areas of
The Bank's streams. The cross-sectional area was then utilized to determine the bankfull width, average
bankfull depth, maximum depth, and floodprone area of the existing channels. Using this method, a
departure from stability could be estimated based on a comparison of existing and proposed/stable
dimension variables.
During field investigations, three cross-sections were measured (two on the main channel and one on the
southern tributary). Cross-section locations are depicted on Figure 4 (Appendix A). The main channel is
characterized by a range of stream dimensions and types including an entrenched E-type channel and a G-
type channel (Table 4). Although the upper reach (cross-section 3) is classified by a stable channel type
(E-type), the bank-height ratio is 1.9 indicating a highly incised channel. In addition, the regional curve
predicts a stable cross-sectional area of 8.0 square feet; however, the existing cross-sectional area
10
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measures approximately 20 square feet. This channel is starting to exhibit bank erosion and increased
destabilization due to land management practices and livestock impacts.
Cross-sections conducted in the lower reach of the main channel (cross-section 2) and the southern
tributary (cross-section 1) indicate the channels are classified as a G-type channels with bank-height ratios
of 2.0 to 3.0, respectively. These channels exhibit excessive bank collapse, appear unstable, and
destabilization of the stream banks is continually increasing. Regional curves indicate that the cross-
sectional area should be 11.5 and 3.6 square feet; however, the existing cross-sectional areas measure
25.6 and 15.1 square feet, respectively, more than twice the predicted cross-sectional area for each
channel.
Based on regional curve estimations of cross-sectional area, onsite streams are characterized by channel
incision and excessively high bank-height ratios. Channel incision has resulted in bank erosion below the
effective rooting depth of existing riparian vegetation in combination with erosive flow velocities.
Measures to reduce channel size (cross-sectional area) and bank height ratios will be targeted for this
project.
3.2.2 Profile
Based on the USGS 7.5-minute topographic quadrangle, the onsite valley slope for restorable portions of
The Bank's stream channels measure approximately 0.0090 to 0.0215 rise/run (Table 4). Estimated
valley slopes appear typical for the Piedmont physiographic region of North Carolina. Water surface
slopes were estimated by dividing the valley slope by channel sinuosity. Sinuosity was measured from
Geographic Information Systems (GIS) analysis of aerial photography and visual observations of the
stream channel during field surveys, and was measured at 1.1 for onsite stream channels. Calculated
water surface slope measured approximately 0.0082 and 0.0195 rise/run.
Impacts to onsite streams such as straightening, downcutting, incision, and bank erosion have resulted in
oversteepening of the average water surface profile. In addition, impacts have removed most of the riffle
and pool morphology characteristic of stable streams in this region. Stream incision may have resulted in
excessive sediment deposition within pools, thereby steepening pool slopes and flattening riffle slopes.
Measures designed to flatten the average water surface profile and restore riffle/pool slopes to suitable
ranges are to be targeted on the onsite streams.
3.2.3 Plan Form
Analysis of aerial photography utilizing GIS was conducted to determine existing onsite plan form
variables. Existing plan form variables were compared to ratios of stable plan form based on fluvial
geomorphic methods (Rosgen 1996). Using this method, a departure from stability was estimated.
The Bank's streams have been straightened in the past, resulting in sinuosity measuring approximately
1.1 (thalweg distance/valley distance) (Table 4). Due to channel alterations, no distinct repetitive pattern
of riffles and pools occurs in the existing channel. In addition, values for belt-width, pool-to-pool
spacing, and meander wavelength were not measurable.
Based on plan form variables, The Bank's streams contain reaches that have been degraded by 1) bank
collapse, erosion, and incision; 2) straightening resulting in no repetitive riffle and pool sequence and
reduction in sinuosity; and 3) a subsequent reduction in the overall length of The Bank's channels.
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Cripple Creek Mitigation Plan Restoration Systems, LLC
Mitigation efforts along degraded channel sections will target restoration of riffle/pool pattern and
bringing pool-to-pool spacing and meander wavelength into suitable relationship for this region.
4.0 REFERENCE FOREST ECOSYSTEM
According to Mitigation Site Classification (MIST) guidelines (USEPA 1990), Reference Forest
Ecosystems (RFEs) must be established for restoration sites. RFEs are forested areas on which to model
restoration efforts at The Bank in relation to soils, hydrology, and vegetation. RFEs should be
ecologically stable climax communities and should represent believed historical (predisturbance)
conditions of the restoration site. Data describing plant community composition and structure are
collected at the RFEs and subsequently applied as reference data for design of the restoration site.
Reference vegetative communities for this'project are located upstream from The Bank on the southern
tributary. Tree and shrub species identified in this area are listed in Table 5 and will be utilized, in
addition to other relevant species to supplement community descriptions for Piedmont Alluvial Forest and
Dry-Mesic Oak-Hickory Forest.
Table 5. Reference Forest Ecosystem
Piedmont Alluvial Forest
(Wet Bottoms and Slopes) Dry-Mesic Oak-Hickory Forest
(Adjacent Uplands)
Canopy Species Understory Species Canopy Species Understory Species
Acer rubrum Acer rubrum Acer rubrum Acer rubrum
Liquidambar styraciflua Betula ni a Carya alba/tomentosa Carpinus caroliniana
Liriodendrum tulipifera Carpinus caroliniana Liriodendron tulipifera Diospyros virginiana
Pinus taeda Liriodendron tuli ifera Pinus taeda flex o aca
Platanus occidentalis Pinus virginiana Juniperus virginiana
Quercus phellos Quercus alba Pinus taeda
Quercus shumardii Quercus falcata
Reference vegetation was dominated by red maple, tuliptree, sycamore, and various oak species including
willow oak (Quercus phellos), southern red oak (Quercus falcata), and white oak (Quercus alba). Other
species identified were large loblolly pine (Pinus taeda) and Virginia pine (Pinus virginiana), as well as
river birch (Betula nigra) and iron wood (Carpinus caroliniana).
5.0 RESTORATION PLAN
The primary goals of this mitigation plan include 1) construction of a stable, riffle-pool stream channel, 2)
restoration/enhancement of historic wetland functions, 3) enhancement of water quality functions (reduce
nonpoint source sedimentation and nutrient inputs), 4) restoration of a natural woody riparian buffer along
The Bank's stream reaches, 5) restoration of wildlife habitat associated with a riparian corridor/stable
stream, and 6) establishment of a permanent conservation easement which will encompass all restoration
activities.
Primary activities include 1) stream restoration, 2) stream enhancement (Level II), 3) wetland restoration,
4) wetland enhancement, and 5) riparian buffer restoration. The restoration concept as outlined in Figure
6 (Appendix A) is expected to:
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Cripple Creek Mitigation Plan Restoration Systems, LLC
• Restore 4300 linear feet of stream channel
• Enhance (Level II) 142 linear feet of stream channel along the upper reaches of the Northern
Tributary
• Restore 5.9 acres of riverine wetland and 1.2 acres of nonriverine wetland
• Enhance 1.5 acres of riverine wetland and 0.6 acre of nonriverine wetland
• Reforestation of 19.1 acres with native species
5.1 STREAM RESTORATION
This stream restoration effort is designed to restore a stable, meandering stream that approximates
hydrodynamics, stream geometry, and local microtopography relative to reference conditions. Geometric
attributes for the existing, degraded channel and the proposed, stable channel are listed in Table 4.
Stream restoration is expected to entail 1) belt-width preparation, 2) channel excavation, 3) spoil
stockpiling, 4) channel stabilization, 5) channel diversion to newly constructed channels, and 5)
abandoned channel backfill.
An erosion control plan and construction/transportation plan will be developed. Erosion control will be
performed locally throughout The Bank and will be incorporated into the construction sequencing.
Exposed surficial soils at The Bank are unconsolidated, alluvial sediments which do not revegetate
rapidly after disturbance; therefore, seeding with appropriate grasses and immediate planting with
disturbance-adapted shrubs will be employed following the earth-moving process. In addition, onsite root
mats (seed banks) and vegetation will be stockpiled and redistributed after disturbance.
A transportation plan, including the location of construction access routes and staging areas, will be
designed to avoid impacts to the proposed design channel corridor. In addition, the transportation plan
and all construction activities will minimize disturbance to existing vegetation and soils to the extent
feasible. The number of transportation access points into the floodplain will be maximized to avoid
traversing long distances through The Bank interior.
5.1.1 Reconstruction on New Location
Portions of The Bank characterized by an adjacent floodplain suitable for design channel excavation on
new location will be utilized to the maximum extent feasible. Primary activities designed to restore the
channel on new location include 1) beltwidth preparation and grading, 2) channel excavation, 3)
installation of channel plugs, and 4) backfilling of the abandoned channel.
j) Beltwidth Preparation and Grading
The stream beltwidth corridor will be cleared to allow survey and equipment access. Care will be taken
to avoid the removal of existing, deeply rooted vegetation within the beltwidth corridor, which may
provide design channel stability. Material excavated during grading will be stockpiled immediately
adjacent to the channel segments to be abandoned and backfilled. These segments will be backfilled after
stream diversion is completed.
Spoil material may be placed to stabilize temporary access roads and to minimize compaction of the
underlying floodplain. However, all spoil will be removed from floodplain surfaces upon completion of
construction activities.
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After preparation of the corridor, the design channel and updated profile survey will be developed and the
location of each meander wavelength will be plotted and staked along the profile. Riffle locations and
relative frequency will be staked according to parameters outlined in a detailed restoration plan and/or
construction plans. These configurations may be modified in the field based on local variations in the
floodplain profile, presence of bedrock, etc.
2) Channel Excavation
Once belt-width corridor preparation is complete, the proposed channel will be excavated to the average
width, depth, and cross-sectional area derived from reference reach studies and detailed measurements of
the onsite reach.
The stream banks and local belt width area of constructed channels will be immediately planted with
shrub and herbaceous vegetation. Shrubs such as tag alder and black willow may be purchased and
planted, or removed from the banks of the abandoned channel and stockpiled during clearing, and placed
into the stream construction area. Deposition of shrub and woody debris into and/or overhanging the
constructed channel is encouraged. Root mats may also be selectively removed from adjacent areas and
placed as erosion control features on channel banks.
Particular attention will be directed toward providing vegetative cover and root growth along the outer
bends of each stream meander. Live willow stake revetments and available root mats or biodegradable,
coir-fiber matting may be embedded into the break-in-slope to promote more rapid development of an
overhanging bank. Willow stakes will be obtained and inserted through the coir-fiber mat into the
underlying soil.
4) Channel Plugs
Impermeable plugs will be installed along abandoned channel. The plugs will consist of low-permeability
materials or hardened structures designed to be of sufficient strength to withstand the erosive energy of
surface flow events across The Bank. Dense clays suitable for plug construction may be imported from
offsite or extracted from existing materials and compacted within the channel. The plug will be
sufficiently wide and deep to form an imbedded overlap in the existing banks and channel bed.
The plug situated at the upstream terminus of the design channel, located below the stream diversion
point, may sustain high-energy flows; therefore, a hardened structure or additional armoring may be
considered at this location.
5) Channel Backfillins
After impermeable plugs are installed, the abandoned channel will be backfilled. Backfilling will be
performed primarily by pushing stockpiled materials into the channel. Based on initial grading plan
estimates, sufficient backfill material is expected from channel excavation, floodplain grading, and soil
borrow areas. The channel will be filled to the extent that onsite material is available and compacted to
maximize microtopographic variability, including ruts, ephemeral pools, and hummocks in the vicinity of
the backfilled channel.
A deficit of fill material for channel backfill may occur. If so, a series of closed, linear depressions may
be left along confined channel segments. Additional fill material for critical areas may be obtained by
excavating shallow depressions along the banks of these planned, open-channel segments. These
excavated areas will represent closed linear, elliptical, or oval depressions. In essence, the channel may
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Cripple Creek Mitigation Plan Restoration Systems, LLC
be converted to a sequence of shallow, ephemeral pools adjacent to effectively plugged and backfilled
channel sections. These pools are expected to stabilize and fill in with organic material over time.
Vegetation debris (root mats, top soils, shrubs, woody debris, etc.) will be redistributed across the backfill
area upon completion.
5.1.2 In-Stream Structures
Stream restoration under natural stream design techniques normally involves the use of in-stream
structures for bank stabilization, grade control, and habitat improvement. Primary activities designed to
achieve these objectives may include 1) installation of cross-vane weirs and/or 2) installation of J-
hook/log vanes.
1) Cross-vane Weirs
Cross-vane weirs may be installed in the channel as conceptually depicted in Figure 7. The purpose of
the vane is to 1) sustain bank stability, 2) direct high velocity flows during bankfull events toward the
center of the channel, 3) maintain average pool depth throughout the reach, 4) preserve water surface
elevations and reconnect the adjacent floodplain to flooding dynamics from the stream, and 5) modify
energy distributions through increases in channel roughness and local energy slopes during peak flows.
Cross-vane weirs will be constructed of boulders approximately 24 inches in minimum width. Cross-
vane weir construction will be initiated by imbedding footer rocks into the stream bed for stability to
prevent undercutting of the structure. Header rocks will then be placed atop the footer rocks at the design
elevation. Footer and header rocks create an arm that slopes from the center of the channel upward at
approximately 7 to 10 degrees, tying in at the bankfull floodplain elevation. The cross-vane arms at both
banks will be tied into the bank with a sill to eliminate the possibility of water diverting around the
structure. Once the header and footer stones are in place, filter fabric will be buried into a trench
excavated around the upstream side of the vane arms. The filter fabric is then draped over the header
rocks to force water over the vane. The upstream side of the structure can then be backfilled with suitable
material to the elevation of the header stones.
2) J-hook Vanes/Log Vanes
The primary purpose of these vanes is to direct high-velocity flows during bankfull events towards the
center of the channel. J-hook vanes will be constructed using the same type and size of rock employed in
the construction of cross-vane weirs (Figure 7, Appendix A). Log vanes will be constructed utilizing
large tree trunks harvested from The Bank or imported from offsite. The tree stem harvested for a log-
vane arm must be long enough to be imbedded into the stream channel and extend several feet into the
floodplain (Figure 7, Appendix A). A trench will be dug into the stream channel that is deep enough for
the head of the log to be at or below the channel invert. The trench is then extended into the floodplain
and the log is set into the trench such that the log arm is below the floodplain elevation. If the log is not
of sufficient size to completely block stream flow (gaps occur between the log and channel bed) then a
footer log or stone footers will be installed beneath the header log. Boulders will then be situated at the
base of the log and at the head of the log to hold the log in place.
Similar to a cross-vane, the arm of the J-hook vane and the log vane (which forms an arm) must slope
from the center of the channel upward at approximately 7 to 10 degrees, tying in at the bankfull
floodplain elevation. Once these vanes are in place, filter fabric is toed into a trench on the upstream side
of the vane and draped over the structure to force water over the vane. The upstream side of the structure
is then backfilled with suitable material.
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Cripple Creek Mitigation Plan Restoration Systems, LLC
5.1.3 Stream Reconstruction In-Place
Reconstruction in-place is proposed for areas of The Bank where reconstruction on new location is not
feasible due to proximity to the upstream/downstream boundaries of The Bank, stream gradient, or
easement constraints. The main objective of restoration in these reaches is to promote an average
bankfull channel depth of approximately 0.7 to 1.2 feet from the channel bottom to the floodplain surface
and to reduce channel size to the cross-sectional area depicted in Table 4. Primary activities designed to
achieve these objectives may include 1) installation of in-stream structures and 2) installation of a
bankfull floodplain bench.
Bankfull Bench Creation
The creation of a bankfull, floodplain bench is expected to 1) remove eroding material and collapsing
banks, 2) promote overbank flooding during bankfull flood events, 3) reduce the erosive potential of flood
waters, and 4) increase the width of the active floodplain. Bankfull benches may be created by
excavating the adjacent floodplain to bankfull elevations or filling eroded/abandoned channel areas with
suitable material.
After establishing the bench, a relatively level floodplain surface is expected to be stabilized with suitable
erosion control measures. Planting of the bench with native floodplain vegetation is expected to reduce
erosion of bench sediments, reduce flow velocities in flood waters, filter pollutants, and provide wildlife
habitat.
5.2 STREAM ENHANCEMENT (LEVEL II)
Stream Enhancement Level II is being proposed on approximately 142 linear feet along the upper reaches
of the northern tributary (Figure 6, Appendix A). Enhancement Level II is expected to include removal of
livestock, removal of invasive species, if necessary, and planting of native woody vegetation. Planting
with native vegetation is discussed in detail in Section 5.4 (Vegetative Planting).
5.3 WETLAND RESTORATION/ENHANCEMENT
Alternatives for wetland restoration/enhancement are designed to restore a fully functioning wetland
system that will provide surface water storage, nutrient cycling, removal of imported elements and
compounds, and will create a variety and abundance of wildlife habitat.
Portions of The Bank underlain by hydric soils have been deprived of sufficient hydrology by channel
incision, vegetative clearing, livestock grazing, and earth movement associated with stream impoundment
and agricultural practices. These areas are characterized by herbaceous and shrub vegetation with
compacted soils resulting from livestock trampling. Wetland mitigation options will focus on the
restoration of vegetative communities, elevation of groundwater tables to jurisdictional conditions, and
the reestablishment of soil structure and micro-topographic variations within the existing floodplain.
Restoration of wetland hydrology and wetland soil attributes may involve 1) excavation of elevated spoil
and sediment embankments, 2) backfilling of entrenched stream reaches, 3) filling onsite ditches or man-
made depressions in the floodplain, and 4) scarification of pasture soils prior to planting. In addition, the
construction of (or provisions for) surface water storage depressions (ephemeral pools) also adds an
important component to groundwater restoration activities. These mitigation activities are expected to
result in the restoration/enhancement of approximately 9.2 acres of jurisdictional wetlands at The Bank.
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Cripple Creek Mitigation Plan Restoration Systems, LLC
5.4 VEGETATIVE PLANTING
Deep-rooted, riparian vegetation will be restored within approximately 19.1 acres of The Bank. Planting
vegetation on cleared stream banks is proposed to reestablish native/historic community patterns within
the stream corridor, associated side slopes, and transition areas. Revegetating The Bank's floodplains and
stream banks will provide stream bank stability, give shade, reduce surface water temperatures, filter
pollutants from adjacent runoff, and provide habitat for area wildlife. The vegetated stream buffer will
extend to a minimum of 50 feet from the top of stream banks in both directions. Scarification of
floodplain surfaces may be required prior to planting.
Variations in vegetative planting will occur based on topographic locations and hydraulic conditions of
the soil. Vegetative species composition will mimic reference forest data and onsite observations.
Species expected for this project may include the following elements.
Piedmont Alluvial Forest
1. Sycamore (Platanus occidentalis)
2. American elm (Ulmus americana)
3. Hackberry (Celtis laevigata)
4. Green ash (Froxinus pennsylvanica)
5. Shagbark hickory (Carya ovata)
6. Willow oak (Quercus phellos)
7. Schumard oak (Quercus schumardii)
8. River birch (Betula nigra)
9. Silky dogwood (Corpus amomum)
10. Pawpaw (Asimina triloba)
Dry-Mesic Oak-Hickory Forest
1. White oak (Qwrcus alba)
2. Northern red oak (Quercus rubra)
3. Pignut hickory (Carya glabra)
4. Mockernut hickory (Carya alba/tomentosa)
5. Black gum (Nyssa sylvatica var. sylvatica)
6. Flowering dogwood (Corpus fdorida)
7. Eastern red cedar (Juniperus virginiana)
8. Persimmon (Diospyros virginiana)
9. Ironwood (Carpinus caroliniana)
Stream-Side Assemblage
1. Black willow (Salix nigra)
2. Tag alder (Anus serrulata)
3. Buttonbush (Cephalanthus occidentalis)
Stream-side trees and shrubs include species with high value for sediment stabilization, rapid growth rate,
and the ability to withstand hydraulic forces associated with bankfull flow and overbank flood events.
Stream-side trees and shrubs will be planted within 15 feet of the channel throughout the meander belt-
width. Shrub elements will be planted along the reconstructed stream banks, concentrated along outer
bends. Piedmont Alluvial Forest is the target community for The Bank wetlands and the Dry-Mesic Oak-
Hickory Forest is the target community for the upland slopes.
Bare-root seedlings of species within the Piedmont Alluvial and Dry-Mesic Oak-Hickory Forests will be
planted at a density of approximately 680 stems per acre on 8-foot centers. Shrub species in the stream-
side assemblage will be planted at a density of 2720 stems per acre on 4-foot centers.
17
Crinn7o t-rootr Al itiantinn Plnrr R"Wnrntinn Nuvtvmv I1.('
6.0 MONITORING PLAN
Monitoring of The Bank's restoration efforts will be performed for five years or until agreed upon success
criteria are fulfilled. Monitoring is proposed for the stream channel and riparian vegetation.
6.1 STREAM MONITORING
Annual monitoring will include development of channel cross-sections on riffles and pools, pebble
counts, and a water surface profile of the channel as outlined in interagency Stream Mitigation Guidelines
(USACE et al. 2003). The data will be presented in graphic and tabular format. Data to be presented will
include 1) cross-sectional area, 2) bankfull width, 3) average depth, 4) maximum depth, 5) width-to-depth
ratio, 6) meander wavelength, 7) belt-width, 8) water surface slope, 9) sinuosity, and 10) stream substrate
composition. A photographic record of preconstruction and postconstruction conditions will also be
compiled.
Stream Success Criteria
Success criteria for stream restoration will include 1) successful classification of the reach as a
functioning stream system (Rosgen 1996) and 2) channel variables indicative of a stable stream system.
Visual assessment of in-stream structures will be conducted to determine if failure has occurred. Failure
of a structure may be indicated by collapse of the structure, undermining of the structure, abandonment of
the channel around the structure, and/or stream flow beneath the structure.
6.2 VEGETATION MONITORING
After planting has been completed in winter or early spring, an initial evaluation will be performed to
verify planting methods were successful and to determine initial species composition and density.
Supplemental planting and additional modifications will be implemented, if necessary.
During quantitative vegetation sampling in early fall of the first year, sample plots will be randomly
placed within The Bank as per guidelines established in CVS-EEP Protocol for Recording Vegetation,
Version 4.0 (Lee et al. 2006). In each sample plot, vegetation parameters to be monitored include species
composition and species density. Visual observations of the percent cover of shrub and herbaceous
species will also be recorded.
Vegetation Success Criteria
Characteristic Tree Species include woody tree and shrub species planted at the site, observed within a
reference forest, or outlined for the appropriate plant community in Scafale and Weakley (1990). An
average density of 320 stems per acre of Characteristic Tree Species must be surviving in the first three
monitoring years. Subsequently, 290 Characteristic Tree Species per acre must be surviving in year 4 and
260 Characteristic Tree Species per acre in year 5.
6.3 HYDROLOGICAL MONITORING
Groundwater monitoring gauges will be installed to take measurements after hydrological modifications
are performed at the Bank. Hydrological sampling will continue throughout the growing season at
intervals necessary to satisfy the jurisdictional hydrology success criteria within each wetland restoration
area (EPA 1990).
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Cripple Creek Mitigation Plan Restoration Systems, LLC
Hydrology Success Criteria
Target hydrological characteristics include saturation or inundation for 12.5 percent of the growing
season, during average climatic conditions. During growing seasons with atypical climatic conditions,
groundwater gauges in reference wetlands may dictate threshold hydrology success criteria. These areas
are expected to support hydrophytic vegetation; if wetland parameters are marginal as indicated by
vegetation and/or hydrology monitoring, a jurisdictional determination will be performed.
6.4 BIOTIC COMMUNITY CHANGES
Changes in the biotic community are anticipated from a shift in habitat opportunities as the unnamed
tributaries to Boyds Creek are restored. In-stream, biological monitoring is proposed to track the changes
during the monitoring period. The benthic macroinvertebrate community will be sampled using NCDWQ
protocols found in the Standard Operating Procedures for Benthic Macroinvertebrates (NCDWQ 2006c)
and Benthic Macroinvertebrate Protocols for Compensatory Stream Restoration Projects (NCDWQ
2001). Biological sampling of benthic macroinvertebrates will be used to collect preconstruction baseline
data for comparison with postconstruction restored conditions.
Benthic macroinvertebrate monitoring locations will be established within The Bank as well as up and
downstream of The Bank's restoration reaches. It is anticipated that postrestoration collections may move
slightly from the prerestoration conditions in order to take advantage of developing habitat niches (i.e.
riffles, vegetative cover, woody debris in channel, overhanging banks) that cannot be predicted prior to
restoration. Benthic macroinvertebrate samples will be collected from individual reaches using the Qual-
4 collection method. Sampling techniques of the Qual-4 collection method consist of kick nets, sweep
nets, leaf packs, and visual searches. Collection procedures will be available for review by NCDWQ
biologists. Preproject biological sampling will occur during the spring of 2007 or 2008, depending upon
construction schedules, with postproject monitoring occurring in the spring of each subsequent
monitoring year.
Identification of collected organisms will be performed by personnel with the NCDWQ or by a NCDWQ
certified laboratory. Additional data collected will include D50 values and appropriate NCDWQ habitat
assessment forms.
7.0 AVAILABLE CREDIT AND PROPOSED RELEASE
7.1 CREDIT DETERMINATION
The Cripple Creek Mitigation Bank encompasses unnamed tributaries to Boyds Creek (Main Channel,
Northern Tributary, and Southern Tributary) and drained hydric soils. Onsite stream reaches have been
impacted by land clearing, livestock grazing, channel dredging and straightening, and erosive velocities.
In addition, The Bank soils have been impacted by stream channel incision and floodplain ditching.
Restoration options outlined in this report are as follows:
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Cripple Creek Mitigation Plan Restoration Systems, LLC
Table 6. Proposed Mitigation Quantities vs. Mitigation Credits
Proposed Mitigation Quantity Proposed Mitigation Units
Proposed Mitigation Activity
Streams Wetlands Stream Units Wetland Units
(linear feet) (acres) (SMUs) (WMUs)
Stream Restoration 4300 4300 _
Stream Enhancement (Level II) 142 57 _
Riverine Wetland Restoration - - 5.9 5.9
Riverine Wetland Enhancement 1.5 0.75
Nonriverine Wetland Restoration 1.2 1.2
Nonriverine Wetland Enhancement 0.6 0.3
Total. 357 Total: 8.15
After completion of the project The Bank will offer 4357 Stream Mitigation Units and 8.15 Wetland
Mitigation Units.
7.2 CREDIT RELEASE SCHEDULE
A credit release scenario is proposed that complies with the Department of Environment and Natural
Resources, EEP full-delivery program. Under this credit release scenario the credit release schedule is
based upon satisfactory completion of project milestones. Project milestones and percent of credit
released include the following:
Table 7_ Prnnnsed Credit Release Sehednle

Task Completion
Verification Percent of Credit

Release
I (Preconstruetion)* Execution of MBI 15
II (Construction) Site Inspection by USACE 20
III (Planting and As-builts) Delivery of As-builts 20
IV (lst Year Monitoring) Monitoring Report 5
V (2°d Year Monitoring) Monitoring Report 5
VI (3`d Year Monitoring) Monitoring Report 5
VII (4th Year Monitoring) Monitoring Report 5
VIII (5th Year Monitoring) Monitoring Report 25**
Total 100
* Task I includes the execution of the MBI, MBRT approval of the Mitigation Plan, delivery of financial assurances, recordation
of the conservation easement, and delivery of the title option to the MBRT.
** Denotes that the release of 25 percent is contingent upon at least one occurrence of a bankfull event during the five-year
monitoring period. In the absence of a bankfull event, release is limited to 15 percent with the 10 percent balance available
following the occurrence of a bankfull event.
7.3 PERPETUAL MAINTENANCE OF MITIGATION BANK
Restoration Systems currently holds an Option to Purchase the approximately 19.1-acre site. Upon
approval of the contract, Restoration Systems will execute the option and immediately place a
conservation easement over the subject parcels. Restoration Systems will remain the owner of the
easement for the 5-year monitoring period. After the 5-year monitoring period, Restoration Systems will
transfer the conservation easement to an conservation organization approved by the MBRT.
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Cripple Creek Mitigation Plan Restoration Systems, LLC
7.4 NONPROJECT DEVELOPMENT SCENARIO
Currently the property is used as pasture and for hay production. If the proposed stream restoration does
not occur, the stream-side buffer will continue to be maintained for pasture and livestock will continue to
have access to The Bank streams and wetlands.
Channel erosion is expected to continue under existing scenarios. Sediment from bank erosion is
deleterious to benthic macroinvertebrate habitat and can be expected to reduce fisheries populations in the
existing and downstream reaches. In addition, proposed mitigation activities will provide wildlife and
fish habitat, shade/cool surface waters (thereby increasing dissolved oxygen levels), filter nutrients,
reduce sedimentation, reduce downstream flooding, and increase bed morphology (habitat) through
maintenance of perpendicular flow vectors. The proposed project offers substantial ecological
improvement within and downstream from The Bank.
7.5 CORPORATE EXPERIENCE
Restoration Systems is an environmental restoration, mitigation banking, and full-delivery mitigation firm
founded in 1998. The firm was formed to improve the quality of environmental restoration and
mitigation by locating and acquiring the best available sites, planning their restoration using proven
science, and constructing them with the most qualified contractors. Restoration Systems staff has been
involved in environmental mitigation and mitigation banking since 1992. Project managers have more
than 80 years of experience in resource evaluation, environmental restoration, and mitigation
implementation. The company employs 17 permanent staff, with its main office in Raleigh, North
Carolina and a satellite office in Greensboro.
Corporate experience of the principals began with completion of the state's first full-delivery mitigation
project in 1997, the Barra Farms Mitigation Bank (623 acres), the subsequent Bear Creek - Mill Branch
Mitigation Bank in 2001 (450 acres), and Sleepy Creek Mitigation Site (550 acres). The firm then
performed all of the off-site mitigation (7500 linear feet of stream restoration and 10 acres of wetland
restoration) for the Piedmont Triad International Airport Authority.
Restoration Systems has implemented projects for the EEP and the North Carolina Wetland Restoration
Program; including, the removal of the Carbonton and Lowell Dams in the Cape Fear and Neuse River
Basins (132,000 linear feet), the Haw River Wetland Restoration Site (34 acres, Cape Fear), the Elk
Shoals Stream Restoration Site (6000 linear feet, Catawba), the Lick Creek Stream Site (10,000 linear
feet, Cape Fear), Gatlin Swamp Wetland Restoration Site (125 acres, Roanoke), and a number of buffer
restoration projects, including Casey Dairy, Walnut Creek, Big Bull, Brogden Road, and Little Buffalo.
8.0 JURISDICTIONAL TOPICS
8.1 WATERS OF THE UNITED STATES
The Bank streams are subject to jurisdictional consideration under Section 404 of the Clean Water Act as
waters of the United States (33 CFR Section 328.3). The Bank streams may be classified as riparian,
upper perennial with an unconsolidated bottom dominated by gravel/sand (R3UB1/2) (Cowardin et al.
1979).
These waters are subject to the jurisdiction of the United States Army Corps of Engineers (USACE) and
will require permitting for implementation of proposed mitigation strategies. Therefore, Nationwide
Permit (NWP) 27 will be used for this project and is expected to authorize restoration activities proposed
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Cripple Creek Mitigation Plan Restoration Systems, LLC
within this mitigation plan. In addition, in accordance with Section 401 of the Clean Water Act,
application for 401 General Certification (GC) 3495 will be required.
8.2 RARE AND PROTECTED SPECIES
Some populations of fauna and flora have been in, or are in, the process of decline due to either natural
forces or their inability to coexist with human activities. Federal law (under the provisions of the
Endangered Species Act of 1973, as amended) requires that any action, likely to adversely affect a species
classified as federally protected, be subject to review by the United States Fish and Wildlife Service
(USFWS). Other species may receive additional protection under separate State laws.
8.2.1 Federally Protected Species
Plants and animals with federal classifications of Endangered, Threatened, Proposed Endangered, and
Proposed Threatened are protected under provisions of Sections 7 and 9 of the Endangered Species Act of
1973, as amended.
Based on the most recently updated county-by-county database of federally listed species in North
Carolina as posted by the USFWS at hM?://www.fws.gov/southeast/es/county%201ists.htm, no federally
protected species are listed for Alamance County.
8.2.2 Federal Species of Concern
There are six Federal Species of Concern (FSC) listed by the USFWS for Alamance County, North
Carolina. FSC are not afforded federal protection under the Endangered Species Act of 1973, as
amended, and are not subject to any of its provisions, including Section 7, until they are formally
proposed or listed as Threatened or Endangered. An FSC is defrled as a species that is under
consideration for listing for which there is insufficient information to support listing.
In addition, FSCs classified as Endangered (E), Threatened (T), or Special Concern (SC) by the state of
North Carolina are afforded state protection under provisions of the North Carolina State Endangered
Species Act or the North Carolina Plant Protection and Conservation Act of 1979, as amended. Table 8
summarizes FSC listed species that for Alamance County that are protected by the state.
Table R. Federal Snecies of Concern
Common Name Scientific Name Potential
Habitat* State
Status**
Carolina darter Etheostoma collis lepidinion No SC
Carolina creekshell Villosa vaughaniana Yes E
Yellow lampmussel Lampsilis cariosa Yes E
* Potential Habitat: Portions of The Bank under review for potential habitat are limited to areas which are proposed for earth moving activities
including restoration and/or enhancement reaches/areas.
** State Status: E = Endangered; T = Threatened; SC = Special Concern
Although not protected by federal law, the Fish and Wildlife Service strongly advises that surveys be
conducted for aquatic species (fish and mussels) in the state with status designations of E or T.
Accordingly, Restoration Systems intends to conduct appropriate investigations to determine if either of
the listed mussel species may be present in The Bank streams, or in downstream waters in close proximity
to The Bank.
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Cripple Creek Mitigation Plan Restoration Systems, LLC
9.0 CULTURAL RESOURCES
The term "cultural resources" refers to prehistoric or historic archaeological sites, structures, or artifact
deposits over 50 years old. "Significant" cultural resources are those that are eligible or potentially
eligible for inclusion in the National Register of Historic Places. Evaluations of site significance are
made with reference to the eligibility criteria of the National Register (36 CFR 60) and in consultation
with the North Carolina State Historic Preservation Office (SHPO).
Field visits were conducted in January 2007 to ascertain the presence of structures or features that may be
eligible for the National Register of Historic Places. No structures or features were observed within the
easement; however, coordination with the SHPO will occur prior to construction activities to determine if
any significant cultural resources are present.
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Cripple Creek Mitigation Plan Restoration Systems, LLC
10.0 REFERENCES
Cowardin, Lewis M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classifications of Wetlands and
Deepwater Habitats of the United States. U.S. Fish and Wildlife Service. U.S. Government
Printing Office, Washington D.C.
Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report
Y-87-1. United States Army Engineer Waterways Experiment Station, Vicksburg, Mississippi.
Franklin, M.A, and Finnegan, J.T. 2004. Natural Heritage Program List of the Rare Plant Species of
North Carolina. North Carolina Natural Heritage Program, Division of Parks and Recreation,
N.C. Department of Environment, Health and Natural Resources, Raleigh. 111 pp.
Harman, W.A., G.D. Jennings, J.M. Patterson, D.R. Clinton, L.A. O'Hara, A. Jessup, R. Everhart. 1999.
Bankfull Hydraulic Geometry Relationships for North Carolina Streams. N.C. State University,
Raleigh, North Carolina.
Leopold, L.B. 1994. A View of the River. Harvard University Press. Cambridge, MA. 298 pp.
Lee, M.T., R.K. Peet, S.D. Roberts, and T.R. Wentworth. 2006. CVS-EEP Protocol for Recording
Vegetation, Level 1-2 Plot Sampling Only. Ecosystem Enhancement Program, North Carolina
Department of Environment and Natural Resources. 11 pp.
LeGrand, H.E., Jr., S.P. Hall, and J.T. Finnegan. 2004. Natural Heritage Program List of the Rare
Animal Species of North Carolina. North Carolina Natural Heritage Program, Division of Parks
and Recreation, N.C. Department of Environment, Health and Natural Resources, Raleigh. 67 pp.
North Carolina Division of Water Quality (NCDWQ). 2000. Cape Fear River Basinwide Water Quality
Plan. North Carolina Department of Environment and Natural Resources. Raleigh, North
Carolina.
North Carolina Division of Water Quality (NCDWQ). 2001. Benthic Macroinvertebrate Monitoring
Protocols for Compensatory Mitigation. 401/Wetlands Unit, Department of Environment and
Natural Resources. Raleigh, North Carolina.
North Carolina Division of Water Quality (NCDWQ). 2006a. Final North Carolina Water Quality
Assessment and Impaired Waters List (2004 Integrated 305(b) and 303(d) Report) (online).
Available:
http://h2o.enr.state.nc.us/tmdl/documents/2004IRCategories4-7.PDF [January 3, 2007]. North
Carolina Department of Environment and Natural Resources, Raleigh, North Carolina.
North Carolina Division of Water Quality (NCDWQ). 2006b. Draft North Carolina Water Quality
Assessment and Impaired Waters List (2006 Integrated 305(b) and 303(d) Report). Public Review
(online). Available:
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Cripple Creek Mitigation Plan Restoration Systems, LLC
http://h2o.enr.state.nc.us/tmdl/documents/2006303dListPublicReviewDraft.pdf [January 3, 2007].
North Carolina Department of Environment and Natural Resources, Raleigh, North Carolina.
North Carolina Division of Water Quality (NCDWQ). 2006c. Standard Operating Procedures for
Benthic Macroinvertebrates. Biological Assessment Unit, Department of Environment and
Natural Resources. Raleigh, North Carolina.
North Carolina Wetlands Restoration Program (NCWRP). 2001. Watershed Restoration Plan for the
Cape Fear River Basin (online). Available:
http://www.nceep.net/services/restplans/cape?_feail_2001.pdf [January 3, 2007]. North Carolina
Department of Environment and Natural Resources, Raleigh, North Carolina.
Rosgen, D. 1996. Applied River Morphology. Wildland Hydrology (Publisher). Pagosa Springs,
Colorado
Schafale, M and Weakley, A. 1990. Classification of the Natural Communities of North Carolina, Third
Approximation. North Carolina Natural Heritage Program, Division of Parks and Recreation.
Raleigh, North Carolina
United States Army Corps of Engineers, United States Environmental Protection Agency, North Carolina
Wildlife Resources Commission, North Carolina Division of Water Quality. 2003 Stream
Mitigation Guidelines.
United States Environmental Protection Agency (USEPA). 1990. Mitigation Site Type Classification
(MIST). USEPA Workshop, August 13-15, 1989. EPA Region IV and Hardwood Research
Cooperative, NCSU, Raleigh, North Carolina.
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Cripple Creek Mitigation Plan Restoration Systems, LLC
APPENDIX A
FIGURES
Appendix A
Cripple Creek Mitigation Plan Restoration Systems, LLC
Directions to the Site:
Tale exit 150 off of Interstate 85 just east of Burlington
Travel north/towards Haw River,/Green Level for - 2.2 miles
At the Highway 49junetion, turn right/travel north on Highway 49 towards
Green Level/Roxboro for -2.7 miles
Turn left on Sandy Cross Road (at the Sandy Cross Mini Mart) for -1.b miles
Turn right on Fonville Road for -1.7 miles to a T-intersection
Turn left on Deep Creek Road for --0.9 mile
Turn left on Roncy-Lineberry Road just after Deep Creek Baptist Church for -0.3 mile
After passing through a trailer park, take a left at the stop sign into the Site
N
r
The Bank Location
?y Cross
z Ln„ - -
Z. I
.40
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Buriington - ,
a J I
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3 ., 4 j
1 mi. 4 mi.
1:158,400
orth Carolina Atlas and Gazetteer, p.18.
Dwn. by:
THE BANK LOCATION CLIP FIGURE
6 Rowland Pond DrNe Ckd by:
PPLE CREEK MITIGATION SITF wG?
9)2115`1 93 C27592 CRI
9) 341-3839 fax DateAlamance County, North Carolina January 2007
Project: 07-001
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The Bank Location
Targeted Local
Watershed
03030002030050
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I -I A T I--1 t I A 1\4
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it !.I
5 mi. 0 5 mi. 15 mi.
1:625,044
Source: Hydrologic Unit (dap • 1974 State of North Carolina

Dwn. by:
CLF
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FIGURE
/ 2126 Rowland Pond Drive

- Willow Spring NC 27592 MITIGATION SERVICE AREA Ckd by.

WGL
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(Q'°i2,S.,F93

\ [phone] fax
I T F
CRIPPLE CREEK MITIGATIONS
rth C
rolina
N
Al
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t
Date
January 2007

2

Axiom Environmental. Inc. oun
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amance
y, Proect
l 07-001
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,r Legend
The Bank Boundary = 19.1 acres ,
Property Boundary
j 0 0.050.1 0.2 0.3 0.4 1 4.0 t II Main Channel Drainage Area = 0.4 square mile
Miles Southern Tributary Drainage Area = 0.07 square mile
112,000 1 ?•'r-
Northern Tributary Drainage Area 0.07 square mile
FIGURE
- 126Ro lanmenla1 TOPOGRAPHY AND DRAINAGE AREA cLF
2
2126 Rowland Pond Drive ive
?^.,l'•. Willow Spring, NC 27592 CRIPPLE CREEK MITIGATION SITE Dale.
[phone] January 2007
i \ [phone] fax -i
- Alamance County, North Carolina Project.
A,lom Environmental, Inc.
07-001
Northe
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b any
?., . f "• 1 t?W V
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Legend
Property Boundary
®?J The Bank Boundary = 19.1 acres
Existing Streams = 3782 linear feet
Hydric Soils - Not Drained = 2.1 acres
Drained Hydric Soils = 7.1 acres
f:

01
Axiom Environmental, Inc
2126 Rowland Pond Drive
Willow Spring, NC 27592
[phone]
- [phone] fax
Axiom Environmental. Inc.
0 50 100 200 300 400
Feet
FIGURE
EXISTING CONDITIONS cLF
CRIPPLE CREEK MITIGATION SITE Date Feb 2007 4
Alamanee County, North Carolina Protect
07-001
--- Property Boundary
The Bank Boundary
>.%}t Y

j •i
:;YS
Legend
Man Unit Soil Name Slope Class Taxnomic Nomenclature Hydnc Status
Adc Appling Sandy Loam Sloping Typic Hapludult Nonhydric
_
CaC3 Cecil Sandy Loam _
Sloping Typic Hapludult Nonhydric
Cd Chewacla Sandy Loam NA Fluvaquentic Dystrochrept Class e.
EdC2 Enon Fine Sanv Loam ..........
SloDino Ultic HaDludalf Nonhydric
Ha

(! \ C L F FIGURE
_ 2126 Rowand Pond D, MRCS SOILS MAP Ckd by. WGL
(91q
Willow ) 215p-nng,1693 NC 27592
(919
CRIPPLE CREEK MITIGATION SITE Date
[phone] fax January 2007
Alamance County, North Carolina Project
A- n, t.,J , 07-001

IN
Mkt f V!. , c r t:cl" y,?,#
A,
F

Legend
I if
Axiom Environmental, Inc
_ 2126 Rowland Pond Drive
Willow Spring, NC 27592
[phone]
[phone] fax
Axiom F-ronmeNal, Ir r..
i-or

W
Property Boundary
7-1 The Bank Boundary = 19.1 acres
Stream Enhancement (Level II) = 142 If
Stream Restoration = 4300 If
Abandoned Stream Channel
Riverine Wetland Restoration = 5.9 acres
Riverine Wetland Enhancement = 1.5 acres
Nonriverine Wetland Restoration = 1.2 acres
Nonriverine Wetland Enhancement = 0.6 acre
Approximate Floodplain Boundary
Wq'
Feet
111111C! 00 300 400
FIGURE
PROPOSED CONDITIONS cLF
CRIPPLE CREEK MITIGATION SITE Da1e Feb 2007
Alamance County, North Carolina Project
j 07-001