20040325 Ver 1_Monitoring Report Year 2_20001206

December 1, 2000
Mr. Scott McLendon
U.S. Army Corps of Engineers
P.O. Box 1890
Wilmington, NC 28402-1890
ECOBANKI
Ref: Annual Wetland Monitoring Report (Year 3)
Barra Farms Cape Fear Regional Mitigation Bank
Action ID No. 199704890
Dear Mr. McLendon:
6 4€L Y.t
L [9,
ECOBANK herein submits the Year 3 Annual Wetland Monitoring Report (AWMR) to you
and the other members of the Mitigation Bank Review Team (MBRT) for your review.
Based upon the results of this AWMR, we are pleased to report that both hydrology and vegetation
at the Bank met the success criteria stated in the mitigation plan, and the Bank is now eligible for Year 3
credits to be made available according to the Mitigation Credit Release Schedule.
We appreciate your continued interest and cooperation in assisting us to achieve the ecological
success of this restoration project. If you have any question, please feel free to contact me. We look
forward to hearing from you soon regarding the AWMR and Year 3 credit release.
Sincerel
G:
Alan G. Fickett, Ph.D.
ECOBANK
c: Mr: John Dorney ?
NC Division of Water Quality
Ms. Kathy Matthews
Environmental Protection Agency
Mr. Ron Ferrell
NC Wetland Restoration Program
Mr. Kevin Moody
U.S.F.W.S.
Mr. Bennett Wynne
NC Wildlife Resources Commission
1555 HOWELL BRANCH ROAD • WINTER PARK, FLORIDA 32789
[phone] • FAX [phone]
ANNUAL WETLAND MONITORING REPORT (YEAR 3)
BARRA FARMS CAPE FEAR REGIONAL MITIGATION BANK
CUMBERLAND COUNTY, NORTH CAROLINA
Prepared for:
Ecosystems Land Mitigation Bank Corporation
1555 Howell Branch Road
Winter Park, Florida 32789
[phone]
Prepared by:
Land Management Group, Inc.
P.O. Box 2522
Wilmington, North Carolina. 28402
[phone]
November 29, 2000
TABLE OF CONTENTS
LIST OF FIGURES AND TABLES ........................................... ii
1.0 INTRODUCTION ....................................................... 1
2.0 HYDROLOGY MONITORING ............................................ 4
2.1 Monitoring Program ............................................... 4
2.2 Monitoring Results ................................................ 6
Groundwater Flats (GF) .......................................... 6
Riverine Floodplains (RF) ........................................ 7
Headwater Slopes (HS) .................................... ..... 8
2.3 Evaluation of Success Criteria ........................................ 9
3.0 VEGETATION MONITORING ......................................... 12
3.1 Monitoring Program .............................................. 12
3.2 Monitoring Results ............................................... 14
Herbaceous Vegetation .......................................... 14
Groundwater Flats ............................................. 15
Headwater Slope ............................................... 15
3.3 Evaluation of Success Criteria ....................................... 15
4.0 WETLAND FUNCTIONAL ATTRIBUTES AND MITIGATION CREDIT ..... 19
4.1 Post-Restoration Conditions (October 1999 to October 2000) .............. 19
4.2 Photographs of Barra Farms 1999-2000 ............................... 21
5.0 SUMMARY ........................................................27
6.0 APPENDICES
Appendix A: Mitigation Credit Release Schedule
Appendix B: Wetland Hydrology Data and Hydrographs
Appendix C: Wetland Vegetation Data
Appendix D: Summary of Monitoring Plan

LIST OF FIGURES
1
1
Figure 1. Vicinity map ....................................................... 3
Figure 2. Location of vegetation plots and wells .................................... 5
LIST OF TABLES
Table 1. Summary of hydrology monitoring data ................................... 10
Table 2. Number and species of trees planted at Barra Farms during the winter of 2000 ...... 14
Table 3. Woody species found in groundwater flats habitat ......... 17
Table 4. Woody species found in headwater slope habitat ............................ 18
11
ANNUAL WETLAND MONITORING REPORT (YEAR 3)
BARRA FARMS CAPE FEAR REGIONAL MITIGATION BANK
CUMBERLAND COUNTY, NORTH CAROLINA
1.0 INTRODUCTION
ECOBANK, a private sector mitigation banking company, has established the Barra Farms Cape
Fear Regional Mitigation Bank within the Coastal Plain region of the Cape Fear River Basin. The
bank comprises 623 acres located along upper reaches of Harrison Creek in Cumberland County
(Figure 1). Wetland restoration/enhancement activities were completed in the winter of 1997-
1998 as described in the detailed mitigation plan. A mitigation banking instrument has also been
prepared through ongoing coordination with the mitigation banking review team (MBRT) as
outlined in the Federal Guidance on the Establishment, Use, and Operation of Mitigation Banks
(60 FR 12286-12293, 1995).
Hydrological and vegetation monitoring are important components of a successful mitigation plan
and are required for release of compensatory mitigation credits. The Barra Farms monitoring plan
requires annual monitoring for a five year period and analysis of the data to evaluate success in
the establishment and maintenance of diagnostic wetland parameters. The monitoring plan and
mitigation credit schedule are attached for reference in Appendices A and E.
This document represents the Annual Wetland Monitoring Report (AWMR) for Year 3 of the
monitoring plan. Monitoring has been performed during the 2000 growing season for hydrology
and vegetation, consisting primarily of a comparison between hydrology model predictions,
reference wetlands, and wetland restoration areas in the Bank. Subsequently, the success criteria
are analyzed and verified to facilitate issuance of mitigation credit designated in the MBI at the
end of Year 3 monitoring.
Since the restoration process at Barra Farms began, extremes in weather have made achieving
success criteria difficult. Heavy rainfall in the winter/spring of 1998 and in the fall of 1999 created
ponding over much of the site and contributed to seedling mortality. As expected, Year 2
monitoring performed in the fall of 1999 revealed low seedling survivability, and subsequent
contingency measures were employed to increase survivorship. Six drainage pipes were installed
to alleviate ponding and over 40,000 seedlings were planted in the winter of 2000 to increase
species abundance and achieve success criteria. A vegetation survey performed in April of 2000
found species numbers and diversity to have surpassed success criteria. At that time, the NMRT
/ agreed to release Year 2 credits and Barra Farms mitigation bank is now on schedule for release
of Year 3 credits.
Year 3 hydrologic monitoring at Barra Farms has been occurring throughout the year, with
regular checks of manual and automated wells within Barra Farms and adjacent reference areas.
Vegetation monitoring was conducted in October of 2000 and consisted of identifying woody and
herbaceous species within 34 0.1 acre plots. After compiling and analyzing the data, it has been
determined that the hydrology and vegetation success criteria identified in the mitigation plan have
been achieved.
1
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Barra Farms Cape Fear Regional Mitigation Bank
ECOBANK
Figure 1. Vicinity Map Cumberland County, NC
? i
Land Management Group, Inc.
3
2.0 HYDROLOGY MONITORING
2.1 Monitoring Program
Twenty three surficial monitoring wells (manual recording) were located throughout the
Barra Mitigation Bank to provide representative coverage and flow gradients extending
through each of the four physiographic landscape areas: 1) uplands; 2) groundwater flats;
3) headwater slope; and 4) riverine floodplain. Figure 2 depicts the approximate location
of monitoring wells in the Bank. In addition, five automated recording wells were placed
on-site to provide continuous data that can be extrapolated to manual recording devices.
Monitoring wells were installed and downloaded by a subcontractor in accordance with
specifications in U.S. Corps of Engineers' Installing Monitoring Wells / Piezometers in
Wetlands (WRP Technical Note HY-IA-3.1, August 1993). The manual monitoring wells
are set to a depth of approximately 24 inches below the soil surface.
Five manual monitoring wells and two automated recording wells were placed in reference
wetlands to compare hydrology between the Bank and relatively undisturbed wetlands in
the region. Four wells (3 manual and 1 automated) were located in the reference
groundwater flats along the northwestern periphery of Barra Farms. Three additional wells
(2 manual and 1 automated) were located in the reference riverine wetland along Colly
Creek in the Bushy Lake/Horse Shoe Lake Natural Area. These wells provided
comparative annual hydroperiods within the organic soil flat and riverine floodplain
physiographic areas of the site. The headwater slope physiographic area was interpolated
from the two adjacent systems as described in the mitigation plan and the MBI.
Hydrological data continue to be collected at weekly intervals on-site and within the
reference sites. The data extending from March 11, 2000 (1st reading within the growing
season) to September 1, 2000 (last reading before submittal of report) have been utilized
in this Year 3 monitoring report.
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2.2 Monitoring Results
The raw well data are depicted in hydrograph and tabular format in Appendix B. Wetland
hydrology criteria in number of consecutive days and percent of the growing season is also
summarized in Table 1. Line intersection at 12 inches below the surface was used as the
cut off for wetland hydrology, following the regulatory wetland criterion requiring
saturation (free water) within one foot of the soil surface. As in Year 1 and 2 monitoring,
groundwater levels were highest in early spring, followed by dry periods during summer
0 months.
Well data have been subdivided into three wetland physiographic wetland types: 1)
groundwater flats (GF); 2) headwater slopes (HS); and 3) riverine floodplains (RF).
Groundwater Flats (GF)
Three wells located within reference groundwater flats provided a general indication of the
average 2000 hydroperiod on groundwater flats supporting steady state forest structure
and organic soils. Data indicated that the reference groundwater flats habitat maintained
wetland hydrology during 24% of the growing season. The automated reference well
located within this same reference area recorded wetland hydrology for 27.2% of the
growing season.
0 The groundwater flats data from the restoration wetland area had an average wetland
hydrology of 30.5% of the growing season and ranged from 9.6 to 54.8% (Table 1). Year
1 monitoring indicated that the wetland hydrology within this habitat correlated with
vegetation cover and soil organic matter content, with the wettest hydrology in areas of
high organic matter and low vegetation cover and the driest hydrology in areas with
mineral soil flats. Year 2 monitoring results were similar, with organic soil flats on former
farmland supporting the longest duration of wetland hydrology, 41 % of the growing
season. However, Year 2 results indicated that mineral soil flats on former farmland
exhibited wetland hydrology longer (34%) than that of organic soil flats supporting dense
successional (pocosin-like) vegetation (30%), which did not correlate with the results of
Year 1 monitoring. Year 3 results, however, do not correlate with either Year 1 or Year 2
trends. In fact, no obvious trend in the Year 3 data based on former vegetation
composition or soil type can be found. There was no significant difference between the
average hydrology of former farmland and pocosin vegetation, or between that of mineral
soil flats and organic soil flats. This may be because as more vegetation becomes
established within the bank, causing evapotranspiration, hydrological differences between
these areas are diminished.
The automated monitoring wells located within groundwater flats habitat at Barra Farms
(wells # 1, 2, and 5; Figure 2) documented wetland hydrology within this habitat for 23%,
22%, and 20% of the growing season, respectively (Appendix B). These percentages are
slightly lower than the average of the manual wells (30.5%). Because manual wells are
monitored weekly and the automated wells read the groundwater level daily, the difference
in hydrology may be a result of the inability of the manual wells to document short-term
decreases in the water table. However, the results of both the manual and automated wells
were similar and both sets of data met the hydrology criterion.
Riverine Floodplains (RF)
Two manual wells are located in reference riverine floodplain habitat. The data from these
wells indicated that the average wetland hydrology for small stream swamps was
approximately 37.7% of the growing season. Unlike Year 1 and 2 monitoring, the two
reference hydrology wells had the same number of consecutive saturation days and
therefore no difference in hydrology due to proximity of well to stream channel was noted.
The automated well located in the reference riverine floodplain habitat documented
wetland hydrology for 47.3% of the growing season. This was considerably longer than
the average wetland hydrology demonstrated by manual wells within the reference riverine
floodplain habitat and may be a result of landscape position of the wells within the
7
reference habitat.
Data from the two manual wells located in the restoration riverine floodplain habitat
showed that wetland hydrology averaged 25% of the growing season. As in Year 1
monitoring, hydrology appeared to decrease in proximity to stream channels and increase
along outer floodplain fringe influenced by riparian groundwater discharge, the lack of
discharge outlets, and backwater flooding.
! Headwater Slopes (HS)
Reference wetland hydrology for the headwater slope habitat was simulated by averaging
wetland hydrology exhibited by adjacent riverine floodplain and groundwater flats. The
average amount of time the headwater slope habitat met wetland hydrology was 29.5% of
the growing season and ranged from 22% (groundwater flats) to 37.7% (riverine
floodplain).
Headwater slope in the restoration wetlands supported wetland hydrology averaging 30%
of the growing season and ranged from 25 to 33%. As in Year 1 monitoring, the range
appeared to be influenced primarily by landscape position within the headwater storage
area and vegetation cover. The shortest percentage of time meeting the wetland hydrology
criterion (25%) occurred in an area dominated by pocosin habitat (W19) and in the upper
reaches of a former farmland area (28%). The duration of wetland hydrology in forested
areas and the interior slope of former farmland was longer (31%, 33%, and 33% of
growing season).
The automated monitoring well (well # 3; Figure 2) located within the headwater slope
habitat recorded a wetland hydrology for 22.6% of the growing season. As in the
groundwater flats habitat, this was slightly below the manual well data, but still met the
wetland hydrology criterion.
2.3 Evaluation of Success Criteria
Success in the restoration of wetland hydrology in the Bank required saturation (free
water) within one foot of the soil surface for at least 50% of the time the reference habitat
achieved wetland hydrology. This criterion was applied separately to each of the restored
habitats.
The reference groundwater flats, riverine floodplain, and headwater slope habitats
1 exhibited wetland hydrology for a period averaging 24%, 37.7%, and 29.5%, respectively.
In the Bank, restoration wetlands supported wetland hydrology averaging 30.5% (127%
of reference), 25% (66% of reference), and 30% (102% of reference), respectively.
Therefore, each habitat evaluated fulfilled the wetland hydrology criterion during 2000.
0
9
Tahle 1 Rnmmarv of 2000 hydrology monitoring data at Barra Farn7s.
Well
Number Maximum
Consecutive
Saturation Days Percent of Growing
Season
(Saturatn Days/239) Comments
Groundwater Flats
Restored
Wetland
W1 67 28 former farmland (FF)
W2 67 28 FF
W4 131 54.8 FF
W5 79 33 FF, mineral soil flat
W6 23 9.6 FF, mineral soil flat
W7 67 28 FF
W10 90 37.7 FF
W 11 67 28 FF
W12 79 33 FF, mineral soil flat
W14 79 33 FF, mineral soil flat
W17 67 28 FF, located on fill material in backfilled ditch
W20 74 31 FF
W21 60 25 Existing pocosin vegetation (PV), end organic
soil flat (targeted swamp forest community)
W22 67 28 PV
W23 79 33 PV
Average 73.1 30.5 Range: 9.6-54.8%
Reference
Wetland
JB1 53 22 Existing forest vegetation (FV), mineral soils
J132 53 22 FV, organic soils
JB3 67 28 FV, organic soils
Average 57.7 24 Range: 22-28%
10
Table 1 continued. Surnmarv of 2000 hydrology monitoring data at Barra Farms.
I
Well Number Maximum
Consecutive
Saturation Days Percent of Growing
Season
(Saturat'n Days/239) Comments
Riverine Floodplain
Restored
Wetland
W15 67 28 existing forest vegetation (FV), upstream
reach, outer floodplain
W18 53 22 FV, downstream terminus, inner
floodplain
Average 60 25 Range: 22-28%
Reference
Wetland
SS1 90 37.7 FV, outer floodplain
SS2 90 37.7 FV, inner floodplain
Average 90 37.7 Range: none
Headwater Slope
Restored
Wetland
W3 67 28 Former farmland (FF), upper reaches
W8 74 31 FV, interior slope
W9 79 33 FF, interior slope
W16 79 33 FV, interior slope
W19 60 25 existing pocosin vegetation (PV), upper
reaches
Average 71.8 30 Range: 28-33%
Reference
hydroperiod* 70.6 29.5 Average of riverine and groundwater flats
The reference hydroperiod for the headwater slope physiographic area is calculated as the average
hydroperiod exhibited by both the groundwater and riverine floodplain reference wells.
3.0 VEGETATION MONITORING
3.1 Monitoring Program
Quantitative sampling of vegetation was conducted in October of 2000 and was similar to
the sampling performed in 1999. Thirty four plots that were each 0.1 acre in size were
sampled resulting in 3.4 total acres of former crop land being surveyed (Figure 2). The
center of each plot has been permanently established with a labeled, white polyvinyl
chloride (PVC) pipe marked with pink and black striped flagging. During the 2000
sampling effort, the coordinates of each of these plot centers was identified with a global
positioning system (GPS) unit.
Plot centers are located within two community types at Barra Farms: groundwater flats
habitat, which represents 324 acres, and headwater slope habitat, which comprises
approximately 38 acres. No plots are located within the riverine habitat since none of this
habitat type was formerly cropland. In the Year 2 monitoring report, 30 plots were
considered to be located in groundwater flats and four sample plots were considered to be
within the headwater slope habitat. However, based on the GPS location of the plot
centers, Plot 8 has been determined to be located within the headwater slope habitat instead
of the groundwater flats. Therefore, 29 plots are located within the groundwater flats and 5
plots are located within the headwater slope.
I
At each plot center, woody species within a 37.2-foot radius of the plot center were
flagged, identified, and measured for height. Diameter at breast height (DBH)
measurements equal to or greater than one inch were also recorded. In most cases, clumps
of multiple black willow (Salix nigra) stems originating from a common root source were
counted as a single stem. In addition, since water tupelo (Nyssa aquatica) and swamp
tupelo (Nyssa biflora) cannot be distinguished from each other as seedlings, these Nyssa
species were grouped into one category in the data analysis.
12
Herbaceous vegetation at each plot was recorded and assigned to one of seven cover
classes: 1 = 0-0.5%, 2 = 0.5-1%, 3 =1-3%, 4 = 3-15%, 5 = 15-33%, 6 = 33-66%9 7 = 66-
99%. Cover classes for all species were determined by visually estimating the area of
ground surface covered by its vertical projection.
Because of low survivability of planted vegetation after Years 1 and 2 monitoring,
supplemental planting at the Cape Fear Regional Mitigation Bank was performed February
8-11, 2000. Twelve species that have shown an ability to survive at Barra (Table 2) were
planted across the groundwater flats and headwater slope habitats, which comprise 362
acres of this site. Seedlings that were approximately 2 years old were purchased from the
North Carolina Division of Forest Resources Nursery in Goldsboro, NC and were evenly
distributed across the former crop land at Barra. However, in wetter areas, such as the
headwater slope habitat, a greater number of bald cypress and water tupelo were planted,
since these species are better adapted to wet conditions. Planting actions were closely
monitored by Land Management Group, Inc. personnel. A total of 43,300 seedlings planted
across 362 acres resulted in approximately 120 trees/acre (- 20-foot spacing). Since an
average of 241 characteristic trees/ac (average of groundwater flats and headwater slope
habitats) was observed in Year 2 monitoring, tree density increased to 361 trees/acre
immediately following the supplemental planting.
11
13
Table 2. Number ands ecies of trees lanted at Barra Farms during the winter of 2000.
I
Common Name Scientific Name Number Planted
Atlantic White Cedar Chamaecyparis thyoides 4000
Bald Cypress Taxodium distichum 6000
Black Gum Nyssa sylvatica 1000
Eastern Sycamore Platanus occidentalis 800
Green Ash Fraxinus pennsylvanica 2500
Pond Pine Pinus serotina 2000
Swamp Blackgum Nyssa Mora 6500
Sweetgum Liquidambar styraciflua 2000
Water Oak Quercus nigra 6000
Water Tupelo Nyssa aquatica 5600
Willow Oak Quercus phellos 5900
Yellow Poplar Liriodendron tulipifera 1000
TOTAL 43,300
Another vegetation survey was performed in April of 2000 to evaluate the success of the
drainage pipes and the supplemental planting. The average stem count at Barra rose to
446.4 trees/acre and species diversity was approximately 7 characteristic species/plot.
These numbers far exceeded the minimum requirement of 320 stems/acre and 5
characteristic species. Therefore, the vegetation success criteria were achieved.
3.2 Monitoring Results
Herbaceous Vegetation
During year 3 monitoring, a total of 20 herbaceous species were identified within the 34
sample plots (Appendix Q. The most common were broomsedge (Andropogon virginicus),
woolgrass (Scirpus cyperinus), goldenrod (Solidago spp.) and aster (Aster pilosus). The
headwater slope and wetter groundwater flats plots, located within the center of the site,
14
contained dense stands of woolgrass and some cattails. The drier plots, located at the
western and eastern ends of the site, supported more aster and goldenrod. Broomsedge
was found throughout Barra in areas not exceptionally wet or dry.
Groundwater Flats
Within the groundwater flats habitat, 25 woody species were surveyed among the 29 plots.
Of the 25 species, 18 were tree species and 7 were shrub species. Of the tree species, 14
were planted and 4 were volunteer. All shrubs were volunteer. Most common species
included red maple (Acer rubrum), bald cypress (Taxodium distichum), swamp tupelo
and/or water tupelo (Nyssa biflora, N. aquatica), and black willow (Salix nigra). The
abundance of red maple stems was attributed to the hundreds of small maple seedlings
growing opportunistically in areas of open sunlight. The vegetation observed within
groundwater flats averaged 646.2 stems/acre with approximately 241 stems/acre from
planted species. When using the number of trees/acre by species that can be applied to the
stems/acre criterion (<_ 20% of 320 stems/acre for hardwoods and _< 10% of 320
stems/acre for softwoods), the total number of trees that can be counted per acre was
448.5 (see Table 3, column 5).
Headwater Slope
A total of 14 woody species was identified within this habitat, of which 9 were planted and
5 were volunteer. The most common species included red maple (Acer rubrum), black
willow (Salix nigra), and swamp tupelo and /or water tupelo (Nyssa biflora, N. aquatica).
1
Density averaged 866 stems/acre, with 220 stems/acre resulting from planted species.
When success criteria percentages were used (s 20% of 320 stems/acre for hardwoods and
< 10% of 320 stems/acre for softwoods), the total number of trees that can be counted per
acre was 334 (see Table 4, column 5).
3.3 Evaluation of Success Criteria
Success criteria for the Barra Farms Mitigation Plan included a minimum mean density of
320 characteristic trees/acre. At least five character tree species must be present, and no
15
hardwood species can comprise more than 20 percent of the 320 stems/acre (64 stems).
Softwood species cannot comprise more than 10 percent of the 320 stems/acre (32 stems).
Tables 3 and 4 show the number of trees/acre by species that can be applied to the
stems/acre criterion. For groundwater flats, a mean density of 646.2 stems/acre was found
across 24 character wetland species, with an average of 6.8 species/plot. An average of
448.5 stems/acre can be applied to the vegetation success criterion. In the headwater slope
habitat, a mean density of 866 stems/acre was found across 14 wetland species, with an
average of 6.6 species/plot. An average of 334 stems/acre in this habitat can be applied to
the vegetation success criterion. Therefore, both of these wetland community types meet
the vegetation success criteria.
I
16
Table 3. Woody species found in groundwater flats habitat, average number of trees/acre, and the number of trees
ollmuarl in ciiCCPQC nritArin
Common name Scientific Name Avg # of
trees/ acre % of total #
of trees/ac # trees/ac
allowed in
criteria Comments
Red Maple Acer rubrum 215.0 33.3 64 several plots had many
seedlings, less than 6" in
height
Bald Cypress Taxodium distichum 83.1 12.9 83.1 hardwood
Swamp/Water Tupelo Nyssa spp. 72.1 11.2 72.1 hardwood
Black Willow Salix nigra 56.9 8.8 32 softwood
Winged Sumac Rhus copallina 47.9 7.4 32 mostly from 1 plot
Sweet Pepperbush Clethra alnifolia 33.8 5.2 32 shrub
Willow Oak Quercus phellos 19.3 3.0 19.3 hardwood
Overcup Oak Quercus lyrata 17.1 2.6 17.1 hardwood
Atlantic White Cedar Chamaecyparis thyoides 15.8 2.4 15.8 hardwood
Sweetgum Liquidambar styraciflua 14.5 2.2 14.5 hardwood
Red Bay Persea borbonia 12.1 1.9 12.1 softwood
Water Oak Quercus nigra 11.7 1.8 11.7 hardwood
Swamp Chestnut Oak Quercus michauxii 7.2 1.1 7.2 hardwood
Titi Cyrilla racemi,Jlora 6.9 1.1 6.9 shrub
Groundsel Bush Baccharis halimifolia 5.5 0.8 5.5 shrub
Pond pine Pinus serotina 4.9 0.7 4.9 softwood/planted
Blueberry Vaccinium corymbosum 4.4 0.7 4.4 shrub
Green Ash Fraxinus pennsylvanica 4.1 0.6 4.1 hardwood
Longleaf Pine Pinus palustris 4.1 0.6 0 softwood, FACU
Pond Cypress Taxodium ascenders 3.4 0.5 3.4 hardwood
Fetterbush Lyonia lucida 2.4 0.4 2.4 shrub
Eastern Sycamore Platanus occidentalis 1.3 0.2 1.3 hardwood
Tulip Poplar Liriodendron tulipifera 1.0 0.2 1.0 hardwood
Wax Myrtle Myrica cerifera 1.0 0.2 1.0 shrub
Swamp Cottonwood Populus heterophylla 0.7 0.1 0.7 hardwood
Total 646.2 100 448.5
17
Table 4. Woody species found in headwater slope habitat, average number of trees/acre, and the number of
trPAe allnwP.d in cnccPSC Criteria.
Common name Scientific Name Average
# of
trees/
acre % of total
# of
trees/ac % of total /
ac allowed in
criteria Comments
Red Maple Acer rubrum 478.0 55.2 64 volunteer hardwood;
one plot had many
seedlings, less than 6"
in height
Black Willow Salix nigra 150.0 17.3 32 volunteer
Swamp/Water Tupelo Nyssa spp. 114.0 13.2 114 hardwood
Bald Cypress Taxodium distichum 58.0 6.7 58 hardwood
Overcup Oak Quercus lyrata 26.0 3.0 26 hardwood
Green Ash Fraxinus pennsylvanica 6.0 0.7 6 hardwood
Groundsel Bush Baccharis halimifolia 6.0 0.7 6 shrub
Pond Cypress Taxodium ascenders 6.0 0.7 6 hardwood
Swamp Cottonwood Populus heterophylla 6.0 0.7 6 hardwood
Atlantic White Cedar Chamaecyparis thyoides 4.0 0.5 4 hardwood
Eastern Sycamore Platanus occidentalis 4.0 0.5 4 hardwood
Loblolly Bay Gordonia lasianthus 4.0 0.5 4 shrub
Sweetgum Liquidambar styraciua 2.0 0.2 2 volunteer hardwood
Willow Oak Quercus phellos 2.0 0.2 2 hardwood
TOTAL 866 100 334
18
4.0 WETLAND FUNCTIONAL ATTRIBUTES AND MITIGATION CREDIT
Post-Restoration Conditions (October 1999 to October 2000)
The following is a brief summary of the conditions observed at Barra Farms during the past
year.
As was noted in the last monitoring report, three hurricanes affected the coast of North
Carolina in September and October of 1999, producing large amounts of rainfall that
inundated most of Barra Farms. This rainfall was heavy enough to produce standing water on
both the former crop land on-site and forested sections within the reference site.
In October of 1999, six drainage pipes (18" diameter) were placed through the northern farm
road/berm to drain the standing water from the restoration areas (Picture 1). Despite these
efforts, water levels were still aboveground in some places during November and December.
These pipes significantly reduced standing water at Barra.
Because of the ponding, seedling survival did not meet success criteria in 1999. To
compensate for this, over 40,000 seedlings of twelve different woody species were planted at
Barra in February of 2000 (Picture 2). These seedlings have been able to survive in strong
numbers and vegetation success criteria have been met.
0
Some ponding still exists in the middle of the tract, which provides a freshwater marsh
habitat for certain bird species like the great blue heron and the American bittern. However,
these areas are not as extensive or as deep as they were in 1998 and 1999, and tree species
like bald cypress, water tupelo, and swamp tupelo have been able to survive (Picture 3). The
remainder of the tract is no longer ponded and supports a variety of planted and volunteer
trees, shrubs, and herbaceous plants (Picture 4). Many of the trees are greater than 7 feet tall
(Picture 5).
19
Species noted this past year: great blue heron (Ardea herodias), American kestrel (Falco
sparverius), American bittern (Botaurus lentiginosus), white-tailed deer (Odocoileus
virginianus), coyote (Canis latrans), quail, black bear (Ursus americanus) tracks (Picture 6),
otter feces, crayfish remains, mallard (Arras platyrhynchos), and belted kingfisher
(Megaceryle alcyon). In addition, there are a great deal of insects throughout the tract
including grasshoppers, dragonflies, and butterflies.
1
20
L .?
1 0
47' -
:`
1. In October of 1999, six drainage pipes were
installed at Barra Farms to alleviate ponding.
y;1G ?s - I

Barra Farms Cape Fear Regional Mitigation Bank
Ecobank
Cumberland County, NC
Land Management Group, Inc.
21

0
0
I•
I•
fi
I

rs "'` _ f
? r
ss - .
,.r -- Mkt.:
2. In February of 2000, 43,300 seedlings were planted
at Barra Farms to compensate for seedling mortality
due to ponding.
Barra Farms Cape Fear Regional Mitigation Bank
Ecobank
Cumberland County, NC
Land Management Group, Inc.
22

PLOT # 1
11
I0
PI nT #31
3. Bald and pond cypress were found throughout
the tract, especially in wetter areas.
Barra Farms Cape Fear Regional Mitigation Bank
Ecobank
Cumberland County, NC
Land Management Group, Inc.
i0
23

I0
•
PLOT # 12
PLOT #25
4. A variety of vegetation was found throughout the
tract during the Year 3 monitoring (trees and shrubs
were marked with blue flagging).
Barra Farms Cape Fear Regional Mitigation Bank
Ecobank
Cumberland County, NC
Land Management Group, Inc.
0 24
t
PLOT #3
PLOT # 1
5. Most trees observed within the tract appeared
healthy and many were greater than 7 feet tall.
Barra Farms Cape Fear Regional Mitigation Bank
Ecobank
Cumberland County, NC
Land Management Group, Inc.
0 25

I0
•
Barra Farms Cape Fear Regional Mitigation Bank
Ecobank
6. Bear tracks found near plot 24-A. Cumberland County, NC
Land Management Group, Inc.
i0
26
5.0 SUMMARY
Wetland hydrology success criteria were met for all three habitat types, as in Year 1 and Year 2
monitoring. Success in the restoration of wetland hydrology in the Bank required saturation (free
water) within one foot of the soil surface for at least 50% of the time that the reference wetland
exhibited wetland hydrology. The reference groundwater flats, riverine floodplain, and headwater
slope habitats exhibited wetland hydrology for a period averaging 24%, 37.7%, and 29.5%,
respectively. In the Bank, restoration wetlands supported wetland hydrology averaging 30.5%
(127% of reference), 25% (66% of reference), and 30% (102% of reference), respectively. Since
hydrologic criteria have been satisfied for the past three years of monitoring and because there are
now five automated monitoring wells located on site that provide accurate groundwater data
(Appendix B), ECOBANK has formally requested (letter to MBRT dated 9/22/00) to decrease the
intensity of monitoring the manual wells. ECOBANK would like to discontinue using the manual
wells altogether, or at least stop monitoring them once the groundwater level has fallen below the
wetland hydrology cut off(>12 in below surface) for that growing season.
The wetland vegetation success criterion was met during Year 3 monitoring. According to the
mitigation plan, at least 320 trees/acre and at least five character wetland species must survive in
order to meet success criteria. After factoring in acceptable percentages of hardwoods and
softwoods, the groundwater flats habitat contained 448.5 stems/acre across 24 wetland species.
Headwater slope habitat supported 334 stems/acre and 14 character wetland species. The installation
of drainage pipes to alleviate ponding and normal weather conditions over the past 12 months have
created better growing conditions for planted vegetation. In addition, supplemental planting in the
winter of 2000 increased the number of stems/acre.
Year 3 monitoring found both hydrology and vegetation at the Barra Farms Cape Fear Regional
Mitigation Bank to meet the success criteria stated in the mitigation plan. Therefore, the conclusion
of this monitoring report is that this mitigation site is thus far successful and Year 3 credits should be
released.
27
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APPENDIX B.
Wetland Hydrology Data, Rainfall, and Hydrographs
M N N N N N N N v) r+ 00 00 O O N N 7 R 7 V V
00 -? C N N N N N N N N
'?' O O O O O O O V' ' ' N A A A A A A
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Hydrographs for the manual monitoring wells in the groundwater flats habitat during the 2000
season. Zero represents ground level.
Groundwater Flats
1
6
0
C
-6
-12
+W1 WW2 -4,W4 +W5 -12'belowsurface
Groundwater Hats
0
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-18
---------------------------------------------------
o?oa ?a??a?'Qoo? o?yd?y?Q°????Q°?y??loo°oVa?ti?o a`1o°???o°?yo'?'o? oo
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0
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-18
.24
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a 1
-------------------------- ---------- \ ---- --------------------
----------------- ---------------------------------------r >--Te r <a r

w6 -,&-W7 O-W10 $WI1 -12°belownvface
Hydrographs for groundwater flats contd.
Groundwater Flag
0
6
0
? -6
v3
? -12
-18
-24
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
________?t___ ______________'F___?
_________________________________________--------
,
____ _____________________________________________ '}-
Is 41,
-W12 +W14 -*W17 -WW20 -12'belowsurfice
Groundwater Flats
I
0
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-18
-24
r
-----------------------
3
-------------------------------------------------------` ------- ------------------------
-----------------------------------------------------------
°?°°????°??,°a°°?,??°°?^?°??,°???°?????°o?
elow surface
W21 -WW22 -WW23 -12-b
Hydrographs for the manual monitoring wells in the headwater slope and riverine floodplain
habitats during the 2000 season. Zero represents ground level.
Headwater Slope Habitat
6
0

a
o -12
Ur'
- - - - - - - - - - - - - - - - - 7 - - - - -- --- - - = - - -- - -- -
------------------------
-18
-24
ee
J-eW3 4sW8 •W9 -+W16 --W19 -12"below surface
Riverine Floodplain
1
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1
-------? -----------------------------
--------- - -3` /--- -------------- ° - ---------
----------------------------------------- -
------1

W15 -*W18 -SS1 -SS2 -12°belowsurface
Hydrograph for the manual monitoring wells in the uplands habitat during the 2000 season. Zero
represents ground level.
Uplands
s

1 ?

0
-6
-12
-18
-24
------------ -----------------------------------------------------------------------------
°° ?°?
Q°°1Q° °,°?}}'.. o??,? ?g ty ?? 1. ?°
p?p?p?'? ???Q"O 0 0 0 0 6 0 4
• 513 -12° below surface
0
Table C 1. Woody species found in groundwater flats habitat, average height, and DBH.
Species #
Found Average
height # with DBH
> 1"
Acer rubrum 639 15.6 6
Taxodium distichum 241 56.1 12
Nyssa spp. 208 46.3 5
Salix nigra 165 61.1 10
Rhus copallina 139 42.7
Clethra aln folia 98 30.6
Quercus phellos 56 28.7
Chamaecyparis thyoides 46 45.2 2
Quercus lyrata 45 40.2 3
Liquidambar styraciflua 42 34.8 2
Persea borbonia 35 34.9 1
Quercus nigra 34 18.2
Quercus michauxii 21 22.7
Cyrilla racemiflora 20 43.5
Baccharis halimifolia 16 41.4
Pinus serotina 14 22.9
Vaccinium corymbosum 13 68.2
Fraxinus pennsylvanica 12 22.3
Pinus palustris 12 29.2
Taxodium ascendens 10 66.2 2
Lyonia lucida 7 28.9
Platanus occidentalis 4 120.0 4
Liriodendron tulipifera 3 41.3
Myrica cerifera 3 46.0
Populus heterophylla 2 81.0 1
Table C2. Woody species found in headwater slope habitat, average height, and DBH.
Species #
Found Average
height # with DBH
> 1"
Acer rubrum 239 17.7 2
Salix nigra 75 99.6 12
Nyssa spp. 57 64.4 2
Taxodium distichum 29 75.0 2
Quercus lyrata 13 58.6
Baccharis halimifolia 3 48.0
Fraxinus pennsylvanica 3 33.3
Populus heterophylla 3 108.0 1
Taxodium ascendens 3 78.0 1
Chamaecyparis thyoides 2 33.0
Gordonia lasianthus 2 35.0
Platanus occidentalis 2 48.0
Liquidambar styraciua 1 144.0 1
Quercus phellos 1 18.0
Table C3. Herbaceous species found in all 34 plots and average cover class.
Species Average Cover
Class
Andropogon virginicus 5.2
Scirpus cypermus 3.9
Solidago sp. 2.4
Panicum verricosum 1.5
Polygonum sp. 1 1.4
Aster pilosa 1.3
Juncus romerianus 0.6
Eupatorium capillifolium 0.5
Ludwigia sp. 0.5
Typha latifolia 0.5
Eupatorium hyssopifolium 0.4
Polygonum sp. 2 0.4
Juncus effusus 0.3
Rubus sp. 0.3
Hypericum hypericoides 0.2
Juncus canadensis 0.2
Lespedeza virginica 0.2
Smilax laurifolia 0.2
Cyperus polystachos 0.1
Xanthium strumarium 0.1
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1.0 MONITORING PLAN
The L'Aonitoring Plan will consist of a comparison between hydrology model predictions, reference
streams and wetlands, and restoration areas on the Site. Stream restoration monitoring will be
performed through analysis of in-stream flows, stream..aeometry, and biological stream attributes.
Wetland monitoring will entail analysis of two primary parameters: vegetation and hydrology.
Monitoring of restoration and enhancement efforts will be performed until success criteria are
fulfilled.

1.1 HYDROLOGY MONITORING
After hvdroloaical modifications are being performed on the site, surficial monitoring wells will be
designed and placed in accordance with specifications in U.S. Corps of Engineers', Installing
Monitoring Wells/Piezometers in Wetlands (WRP Technical Note HY-IA-3.1, August 1993).
Monitoring wells will be set to a depth of approximately 24 inches below the soil surface.
Twenty three surficial monitoring wells (manual recording) will be installed at the Site to provide
representative coverage and flow Gradients extending through each of the three physiographic
landscape areas (Figure 2). Four monitoring wells will also be placed within the reference wetland
site in similar landscape positions, where available. Three continuous recording (RDS24) wells will
also be installed on-site to provide continuous data that can be extrapolated to manual recording
devices.
Hydrological sampling will be performed on-site and within reference during the growing season (17
INfarch to 12 November) at intervals necessary to satisfy the hydrology success criteria within the
designated physiographic area (EPA 1990). In general, the wells will be sampled weekly through
the Spring and early Summer and intermittently through the remainder of the growing season. if
needed to verify success.
1.2 HYDROLOGY SUCCESS CRITERIA
Target hvdrological characteristics have been evaluated using a potential combination of three
different methods: 1) regulatory wetland hydrology criteria; 2) reference groundwater modeling; and
3) reference wetland sites.
Retrulatorv Wetland Hvdrolo7_y Criteria
The regulatory wetland hydrology criterion requires saturation (free water) within one foot of the soil
surface for 12.5 percent of the growing season under normal climatic conditions. In some instances,
the re`u!ator.?, wetland hydroperiod may extend for between and 12.5% of the growing season.
Reference Groundwater Model
The reference groundwater model forecasts that the wetland hydroperiod in interior areas of the Site
?. ill a%'2rage 221-7o of the growing season in early successional phases. As steady state forest
corid.t.-ns develop, the average wetland hydroperiod is forecast to encompass 407C of the growing
seas0 Over the 31 year modeling period, the annual hydroperiod fluctuated from less than 12.5-7c
t e'.'?- - dependent upon ra,nia!! patter and sL:ccess!onal phase. 1_^. add'r'on. the 0 :-site
-a,c 1 0; 5
landscape includes diverse wetland geomorphology, especially near uplands and the stream channel.
which are not characterized by the model.
Due to wide fluctuations in modeled annual hydroperiod (<12-44+%), the groundwater model cannot
provide a specific hydrology success criteria above the regulatory criterion (12.5%) on an annual
basis. A specific success criteria such as a 22% target hydroperiod will fail in 50% of the years
sampled. A success criteria of 12.5% (the regulatory criteria) will also fail in 10% of the years
sampled in reference wetlands.
Reference Wetland Sites
Four monitoring wells will be placed in the groundwater flats reference wetland located in the
northwestern periphery of Barra Farms. Wells will be also be placed in a riverine reference wetland
in the Bushy Lake/Horse shoe Lake natural area dependent upon contact with the North Carolina
Park and Recreation Service. These wells will provide annual hydroperiods on the organic soil flat,
and riverine floodplain physiographic areas of the Site. The headwater slope physiographic area may
be interpolated between the two systems. Transition zones from uplands towards the wetland interior
will not be represented. Therefore, these wells will provide comparative information on interior
wetlands only.
The hydrology success criteria for this Site will require saturation (free water) within one foot of the
soil surface for at least 5090 of the hydroperiod exhibited by the reference wetland.
Based on groundwater models, average wetland hydroperiods in groundwater flats will exhibit a
steadv, non-linear increase from 227o to 40% of the gro%ving season during forest (post-farmland)
development. This trend includes a hypothetical reduction in hydraulic conductivities and a 50°c
increase in surface eater storage through the first 15 years of wetland development. Therefore, a
coal of 50 +/-% hydroperiods relative to reference wetlands is warranted for the five year monitoring
period. This 509o goal may not apply in non-organic soils as evapotranspiration may play a greater
role in early successional hydroperiods than surface water storage.
1.3 VEGETATION
Restoration monitoring procedures for vegetation are designed in accordance with EPA guidelines
presented in Mitigation Site T%pe (MiST) documentation (EPA 1990) and COE Compensator-
Hardwood INlitigation Guidelines (DOA 1993). The following presents a general discussion of the
monitoring program.
After planting has been completed in winter or early spring, an initial evaluation will be performed
to verify planting methods and to determine initial species composition and density. Supplemental
planting and additional site modifications will be implemented, if necessary.
During the first year, vegetation will receive cursory, %isual evaluation on a periodic basis to
ascertain the degree of overtopping of planted elements by weeds. Subsequently, quantitative
sampling of vegetation %"'ill be cerformed between September 1 and Octobe_ 1 after each growing
season unt,l the Vegetation success criteria is achi':e '

After planting plan implementation, 0.1 acre plots will be within each restored ecosystem type.
Twenty three plots will be correlated with hydrological monitoring locations to provide point-related
data on hydrological and vegetation parameters.
1.4 VEGETATION SUCCESS CRITERIA
Success criteria have been established to verify that the wetland vegetation component supports a
species composition sufficient for a jurisdictional determination. Additional success criteria are
dependent upon the density and growth of characteristic forest species. Specifically, a minimum
mean density of 320 characteristic trees/ac must be present for the five year monitoring period.
Characteristic tree species are those within the reference ecosystems, elements enumerated in the
planting plan, along with natural recruitment of sweet gum, red maple, loblolly bay, loblolly pine,
and pond pine. Loblolly.or pond pine (softwood species) cannot comprise more than 10 percent of
the 320 stem/acre requirement. In addition, at least five character tree species must be present, and
no species can comprise more than 20 percent of the 320 stem/acre total. Supplemental plantings
will be performed as needed to achieve the vegetation success criteria.
No quantitative sampling requirements are proposed for herb and shrub assemblages as part of the
vegetation success criteria. Development of a forest canopy over several decades and restoration of
wetland hydrology will dictate the success in migration and establishment of desired wetland
understory and groundcover populations. Visual estimates of the percent cover/composition of shrub
and herbaceous species and photographic evidence will be reported for information purposes.
1.; STREAM
1.5.1 Initial Monitoring Plan
Monitoring and success criteria will be established through periodic measurement of stream stage
and rainfall in the Bank. One staff gauge will be placed on central sections of the mitigation stream
reach and the second staff Gauge will be located approximately 300 feet below outrall from the Bank.
Rain gauges will be placed at open locations within central portions of the Bank. Stream stage and
rainfall will be measured weekly throughout the monitoring period.
1.5 .2 Updated iMonitoring Plan
Stream monitoring and success criteria will be established through measurement of in-stream flows,
measurement of stream aeometry, and measurement of biological stream attributes.
In-stream flows will be measured through placement of two continuos monitoring stream tlov,
gauges. The gauges will be capable of recording velocity (ft/second) and discharge (cubic feet per
second. CFS). Discharge is typically calculated by measuring height (or depth) of the water column
and inputting the resulting cross-section. One gauge will be placed within the central reach of the
restored stream channel on the mitigation site The Gauge will be located approximately 100 feet
downstream of a former dirt road crossing in central potions of the site (Drainage Area: 2.5 mi').
The second gauge will be placed within the riverine wetland reference site in Bladen Lakes State
Forest. The reference gauge will be located a rrurnmum of 100 feet upstrea;' o tie Mate road
Pa 2e o:
crossing (Drainage Area: 6.7 mi-). The data will be reported as mean daily flows for velocity
(ft/second) and discharge (CFS) in tabular and graphic format.
Stream geometry will be measured along a fixed stream reach located immediately upstream and/or
downstream of the stream gauge located on the mitigation site. The stream reach will extend for a
minimum of 200 feet along the restored channel. Annual fall monitoring will include development
of a channel plan view, three channel cross-sections, pebble counts, and a water surface profile of
the channel. The data will be presented in graphic and tabular format as summarized in the attached
table. Data to be presented will include: 1) cross-sectional area; 2) bankfull width; 3) average depth;
4) average width; 5) width/depth ratio; 6) meander wavelength; 7) beltwidth; 8) water surface slope;
9) sinuosity; and 10) stream substrate composition. The stream will subsequently be classified
according to stream geometry and substrate (Rosgen 1996). Significant changes in channel
morphology will be tracked and reported by comparing data between the reference stream and
1 mitigation stream and by comparing data in each successive monitoring year.
Biological stream attributes will be measured annually at the mitigation site and in the reference
wetland site between April 15 and May 15 of each year. Aquatic surveys will record
presence/absence of macro-invertebrate, reptile, amphibian, and fish species populations.
Presence/absence of species populations identified will be reported along with observations of
changes to in-stream aquatic habitat or species presence/absence over time.
1.6 STREAM SUCCESS CRITERIA
1.6.1 Initial Monitoring Plan
Success criteria will include establishment of near-permanent stream flows within the Bank.
Specifically, stream stage and obse. able flow must be present for a minimum of 80;'0 of the
calendar year. Intermittent flow may occur during periods of groundwater draw-down, generally
confined to summer months.
1.6.2 Updated Nfonitorina Plan
Success criteria for stream restoration will include: 1) stream classification: 2) t.rCet mean daily
stream flows; and 3) increased stream faunal recruitment and diversity.
1 Stream geometry measurements will be incorporated into the Rosgen stream classification system.
The channel and flood prone area must support characteristics supporting an E. C, or DA stream type
to fulfill the success criteria.
In-stream flow measurements must indicate that the mitigation stream reach supports mean daily
flows per unit of drainage area equal to. or exceeding the mean daily flows per unit of drainage area
within the riverine reference reach. The reference stream reach supports an approximate 6.7 M11-
drainage area while the mitigation stream reach supports an approximate 2.5 mi' drainage area (37co
of reference). Therefore, mean daily flows in the mitigation reach must equal to, or exceed 30"c of
the met daily flo%,"s in refeCeilCe. li (he miii_ation rZaCh and/or reference reach supporn0
rai, - 0 , 5
measurable flow during a drought period, fulfillment of success criteria will be based upon mean
daily flows prior to, and following the no flow condition.
k..
1
Biolojical monitoring will indicate similar species diversity as compared to reference conditions or
an increase in species diversity towards reference conditions over time. Specifically, the type and
number of species populations identified in the mitigation reach must be equal to, or increasing
towards, the type and number of species identified in the reference reach in each successive
monitoring year.
1.7 REPORT SUBNIITTAL
Documentation will be submitted to the MBRT certifying completion of implementation activities.
Any changes to this mitigation plan will be described in this documentation. The document will be
provided within 60 days of completion of all work at the Site.
Subsequently, reports will be submitted yearly to the MBRT following each assessment. Reports
will document the sample transeet locations, along with photographs which illustrate site conditions.
Surficial well data will be presented in tabular/graphic format. The duration of wetland hydrology
during the growing season will be calculated at each well. within each on-site physiographic area,
and within the reference wetland site.
The survival and density of planted tree stock will be reported. In addition, characteristic tree
species mean density and average height as formatted in the Vegetation Success Criteria will be
calculated. Estimates and photographic evidence of the relative percent cover of understory and
groundcover species will be generated.
1.8 CONTINGENCY
In the event that vegetation or hydrology success criteria are not fulfilled, a mechanism for
contingency will be implemented. For vegetation contingency, replanting and extended monitoring
periods will be implemented if co=unity restoration does not fulfill minimum species density and
distribution requirements.
Hydrological contingency will require consultation with hydrologists and regulatory agencies if
1 wetland hydrology restoration is not achieved during the monitoring period. Recommendations for
contingency to establish wetland hydrology will be implemented and monitored until the Hydrology
Success Criteria are achieved. Performance bonds have been established to Guarantee fiscal
resources for remediation.
Pa_e 5 or