20201942 Ver 2_Cox Pond BPDP_20220223

From:
Merritt, Katie
To:
Andrea Eckardt
Cc:
Woioski. Paul A; Baker. Caroline D
Subject:
DWR Comments - Cox Pond BPDP
Date:
Wednesday, February 23, 2022 4:17:54 PM
Attachments:
Cox Pond BPDP Comment Summarv.Ddf
Cox Pond BPDP DWRedits.Ddf
Hey Andrea,
Pursuant to Titles 15A NCAC 02B .0295 and 15A NCAC 02B .0703 (e), a provider shall submit a
project plan proposal to the Division for review and approval that includes specific elements of the
project. On October 20, 2021, Wildlands Holdings III, LLC (Wildlands) submitted a Bank Parcel
Development Package (Plan) for the Cox Pond Site, to the Division, for review and approval.
According to the initial review by DWR staff of the subject Plan, some elements were either not
provided, not explained thoroughly, not accurate or lacking in sufficient information.
Therefore, until DWR receives an updated Plan addressing all comments and edits provided in the
attached 1) comment summary and 2) PDF version of the document itself, DWR cannot finalize the
review of the Plan or issue an approval of the Plan. In an effort to be as efficient as possible at
providing comments to IRS during this busy time, I have provided my comments in a different
format. Attached are the comments & edits provided within the actual PDF of a condensed Plan
(without Appendices) as well as a comment summary.
When Wildlands is ready to submit their final project Plan, please include a summary of all
Wildlands' responses to the DWR comments acknowledging how Wildlands addressed the
comments. Please upload the final Plan using our Mitigation Project Information Upload Form
through this link: http.,,,;,/�Cd,C7C�d,C,q,,I�Cov Forms VIa.i ation Information U load . Please note the
DWR ID# 2020-1942 (version 2) on all electronic submissions for this project.
Thank you for your patience during this time and if you have any difficulty reading though the
comments or edits please let me know.
Katie
Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
401 & Buffer Permitting Unit
North Carolina Department of Environmental Quality
Office: 919-707-3637
Work Cell: 919-500-0683
Website: htt s: de .nc. ov about divisions water -resources water- ualit - ermittin 401-buffer-
ermittin -branch
I.2...N.::....a.li..S.ua.r re t Paleiolh. NC 27620
:I..6.:I..7......M.a i.I....arv...ica.. a.inIa. R...Ra1a%.glh. NC 27699-1617
rr ad correspondence, to and fr wtm this Esc/</rr ss is ,crbject to the
Nrw ?V? u";amfrrra Public , �'rrr;otVs Law andmay ay be, disclosed to thhV t a? ties,

Summary of Comments on Cox Pond BPDP_DWRedits.pdf
am
Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 3:50:06 PM
add that this WUP is a requirement of the certified Animal Feeding Operation associated with permit # AWS960144 issued by the Division of
Water Resources.

Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 3:52:00 PM
existing conditions should call out the unstable banks, sink holes, and active erosion noted in the site viability letter. add language to this section
speaking to that. If you know where those areas are along the UTs, then add call outs on a supporting figure

Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 3:54:29 PM
report in ft2
Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 3:53:49 PM
update table after updating Table 9
Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 3:55:02 PM
also reference Table 9 in addition to Figure 7 since that's where you show the deductions.

Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 3:56:54 PM
DWR approved the new WUP? Do you have documentation supporting that? It is not normally a formal "approval" from DWR so unless you have
documentation that DWR approved the WUP, remove this text.
On a side note: I have already followed up with DWR staff about this WUP and verbally they have said it's fine and complies with all the numbers in
the permit.

Page: 11
Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 3:57:36 PM
there should be at least one subcanopy species in this plan

Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 3:59:39 PM
text implies no buffer credit on east side of UT4 where width is only 30 feet. modify language to provide clarity here. Indicate no NOC can be
generated in areas where riparian restoration is less than 50'.
Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 4:01:33 PM
A add a statement that the total amount of credits that can be converted from riparian buffer credit to nutrient offset is represented in Table 9 and
will be documented in the AsBuilt report.

.
0. y
Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 4:02:05 PM
there are comments made on Figure 7 that will result in changes needed to the crediting areas on this table.

Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 4:04:21 PM
the measurement of widths for crediting purposes is to be taken perpendicular and landward from top of bank of the feature since that's our
policy for measuring as per the MBI. Only the radius should be included when the feature origin begins on the property and has no other
features coming into it. Therefore, remove the radius off UT3 at Ditch C origin and change buffer to nutrient offset within that area
Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 4:03:18 PM
remove the radius off UT3 at Ditch C origin and change buffer to nutrient offset within that area
Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 4:06:47 PM
if Ditch A continues above the CE boundary, the diffused flow deductions need to be applied the same way as on Ditch B

Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 4:05:07 PM
make edits based on comment on Figure 7

Page: 27
Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/23/2022 4:05:12 PM
make edits based on comment on Figure 7

A
TArk Rk FEAMT01-0
M;-D VG UAC
October 2021
COX CAN MITIGATION BANK PARCEL
Wayne County, NC
�DWR Project Number 2020-1942 Q
: I
100 I
PREPARED BY:
IL 1) L A N L) S
Wildlands Engineering, Inc.
1430 South Mint Street, Suite 104
Charlotte, NC 28203
Phone. [phone]
Fax: [phone]

Bank Parcel Development Package
Neuse River Basin
TABLE OF CONTENTS
1J0Project
Introduction ................................. ............................... ........................................................ 1
1.1
Parcel Description .................. ........... ................... ........... ................... ........... ................... ......
1
2/0
Mitigation Project Summary ... ---........... -------........... ------........... ------.2
2.1
Project Goals ----....... --------....... --------....... --------....... ----.2
2.2
Existing Parcel Coniditions--.... ........... -------........... ------........... ------.2
23
Site Viability for Buffer Mitigation and Nutrient Offset Mitigation ... -----....... ------..3
14
Alternative Mitigation ------........... -------........... ------........... ------.4
2.5
Watershed Characterizathzm---... —.... ....... --------....... --------....... ----.4
2.6
Soils ................... ....................... ....................... ....................... .............5
2.7
Existing Vegetative Communities .... .... ....... -------....... --------....... ----.6
2.8
Threatened and Endangered Species ...... -------........... ------........... ------.6
2.9
[mkmna| Resources ----------_---------_---------._-------..7
2.101
REMA Fkoodplaiin Cunnm|ia:mce.... ........... -------........... ------........... ----.......
7
2.11
Parcel Location, Parcel Constraints, and Access. ...... ... .... ....... --------....... —...
—7
2.12
Other Environmental Conditions ...... -------........... ------........... ------.......
7
3/0
Site Protection Instrument. .... ... .... ....... --------....... -------....... ----...
—7
4/B
Mitigation Work Plan -----........... ------........... -------........... ------.......
8
4.1
Parcel Preparation ---------....... -------....... --------....... ------..8
4.2
Riparian Area, Restoration Activities ........ ------........... ------........... -------8
4.3
Riparian Area Preservation Activities ....... -------....... --------...... ------..9
4,4
NCDWR4m-Bm|lt Evaluation -----........... ------........... -------........... ----.9
5/0
Monitoring and Maintenance Plan ... ........ ............. _.......... ............. _.......... ............. _.~9
5.1
K4nmitoMmg Protocol —..--..—..--..~.--..—..--..~.--..—..--..~.--..—.. 9
5.2
Parcel Maintenance ........ .... ........ .............. .... ........ .............. .... ........ .............. .... ....
10
5.3
Easement Boundaries .................................................................................................................
10
6/0
Financial Assurance andLong-Term Management. ... .... ........ .............. .... ........ .............. ..10
6.1
Financial Assurances ...................................................................................................................
10
6.2
Long-term Managenment...... .... ........ .............. .... ........ .............. .... ........ .............. ..11
7/0
Potential Credit Generation ............................................................................................................
11
8/0
References .......... .............. .... ........ .............. .... ........ .............. ........... .... ........ ............
14
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WWI
Table I
Ecological and Water Quality Goals
Table 2
Buffer Project Attributes
Table 3
Project Features
Table 4
Drainage Areas and Associated Land Use
Table 5
Project Soil Types and Descriptions
Table 6
Existing Vegetation
Table 7
Site Protection Instrument
Table 8
Selected Tree Species
Table 9
Cox Pond — Project Credit Table
Table 10
Cox Pond — Total Area of Buffer and Nutrient Offset Mitigation
FiGURES
Figure 1
Vicinity Map
Figure 2
Service Area Map
Figure 3
Site Map
Figure 4
USGS Topographic Map
Figure 5
Watershed Map
Figure 6
NRCS 1974 Soil Survey Map
Figure 7
Buffer Credlits Map
Figure 8
Riparian, Buffer Zones Map
Figure 9
Monitoring Components Map
APPEND110ES
Appendix A Current Land Use Photographs — July 15, 2021
Appendix B Historical Aerials
Appendix C On Site Determination, of Applicability to Neuse Riparian Buffer Rules — March 16, 2021
Site Viability for Buffer Mitigation and Nutrient Offset Letter — May 19, 2021
Appendix D USFWS Self -Certification Letter and Correspondence
SHPO Req�uiest for Review and Response
EDR. Radius Map Report, Executive Summary
Appendix E Waste Utilization, Plan
Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 IPage ii October 2021

Bank Parcel Development Package
Neuse River Basini,
Wildlands, Holdings III
1.0 Project Introduction
The Cox Pond Mitigation, Bank Parcel ((Parcel), is proposed under the terms and conditions of the Cox
Pond and O'Berry Road Nutrient Offset and Buffer Mitigation Banking Instrument (UMBI), made and
entered into by Wildlands IHoldings III, LLC a,ctinig as Bank Sponsor (Sponsor) and the North Carolina
Department of Environmental Quality (NCDEQ), Division of Water Resources (NICIDWR), The Parcel shall
be planned and designed according to the UIVIBI, 15A NCAC 02B .0703, and the Consolidated Buffer
Mitigation Rule 15A NCAC 0213,0295.
The project is in Wayne County approximately two and a half miles northwest of Mount Olive, North
Carolina (Figure 1). Directions are included on, Figure 1. The Parcel creates a protected riparian area
from top of bank to a minimum of 30 feet along streams, or 50 feet along ditches, to a maximum of 200
feet along four unnamed tributaries and three ditches. The primary purpose of the project is to provide
riparian buffer mitigation credits and nutrient offset credlits to compensate for unavoidable impacts in,
the Neuse River Basin 03020201 Hydrologic Unit Code (HUC) outside the Falls Lake Watershed (Figure
2), The Parcel is located within the Neuse River Basin HUC 03020201170050 and NCDWR Subbasin 03-
04-12 in Wayne Couinty.
1.1 Parcel Description
The project features flow to Brooks Swamp off site, which then connects with Thoroughfare Swamp.
Thoroughfare Swamp subsequently flows to Falling Creek and fina:lly into the Neuse River. Brooks
Swamp, Thoroughfare Swamp, and Falling Creek are all classified as Water Supply IV (WSAV)' and
Nutrient Sensitive Waters (NSW) by the NNCDWR. The proposed project supports specific goals identified
in the Neuse River Basin Restoration Priorities (RBRP) by promoting "nutrient and! sediment reduction in
agricultural areas by restoring and preserving wetlands, streams, and riparian buiffers".
Thais riparian mitigation project will reduce sediment and nutrient loading, provide a:nd improve
terrestrial and instream, habitats, and improve stream and bank stability. The area surrounding the
streams proposed for mitigation, is predominantly agricultural fields, typically used to grow corn,
soybeans, and tobacco. See Appendix A for July 2021 cuirrent land use photographs, Permitted direct
application of hog waste from a lagoon located offsite was previously used for fertilizer on the field
adjacent to Ditch C and UT3. With the start of this project, the Waste Utilization Plan was amended to
exclude the entire application field (See Figure 3 and Appendix IE). Restoring the riparian area up to 200
feet from the streams and ditches will rediuce nutrient and sediment inputs in the tributaries to Brooks
and Thoroughfare Swamps, and subsequently Falling Creek and the Neuse River. The restored floodplain
areas will filter sediment during high rainfall events and provide cover and food for wildlife throughouit
the Parcel.
aiU Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 1 October 2021

2.litigation Project Suirrumary
2.1 Project Goals
The major goals of the proposed buffer and nutrient offset mitigation project are to provide ecological
and water quality enhancements to the Neuse River Basin by restoring the riparian area to create a
functional riparian, corridor. Specific enhancements to water quality and ecological processes are
outlined below in Table 1.
Table I.- Ecological and Water Quality Goals
Goals
Objectives
Nutrient input will be decreased by filtering runoff from the agricultural fields
Decrease nutrient levels.
through restored native vegetation. The off -site nutrient input will also be
absorbed on -site by filtering flood flows through restored floodplain areas,
where flood flows can disperse through native vegetation.
Decrease sediment input,
Sediment from off -site sources will be captured by deposition on restored
floodplain areas where native vegetation will slow overland flow velocities.
Decrease water
temperature and increase
Planted riparian trees will shade the project features as they mature, reducing
dissolved oxygen
thermal pollution.
concentrations.
Fecal coliform input will be reduced by restricting the application of animal
Reduce fecal coliform
waste within the conservation easement. Converting fertilized cropland to
inputs.
forest will filter runoff from the adjacent fields through the planting vegetated
buffers.
Create appropriate
Riparian areas will be restored by treating invasive vegetation and planting
terrestrial habitat.
native vegetation.
Permanently protect the
project Parcel from
A conservation easement will be recorded on the Parcel.
harmful uses.
2.2 Existing Parcel Conditions
The proposed buffer mitigation and nutrient offset project includes approximately 24.27 acres of open
row crop fields and forest land along four unnamed tributaries (UT1, UT2, UT3, and UT4), and three
ditches (Ditches A, B, and C). The fields are typically planted with corn or soybeans adjacent to project
streams and ditches. The Parcel easement boundary will extend from top of bank to at least 30 feet
along streams, at least 50 feet along ditches, and out to 200 feet where possible (Figure 3).
UT1 flows north; it enters the Parcel and is then, bordered by active agricultural fields to its confluience
with 'UT2. UT1 continues through a marrow -forested) buffer for approximately another 500 feet to meet
with UT3. UT2 forms from a groundwater seep at the confluence of Ditch A and a seconidl ditch coming
from offsite, becoming an intermittent stream. Ditch A and UT2 are bordered on both, sides for their
entire lengths by agriculture fields. Ditch C becomes UT3, an intermittent stream, and flows southeast
through an active agricultural field to the conifluence with UT1. The field bordering Ditch C and UT3 was
fertilized by a hog lagoon spray outlet until Jiune 2021 when waste application in the area was
discontinued to allow for this project's conservation easement. At the time the Proposal was written,
there was a small offline pond located near the confluence of UT3 with UT1 which is still seen on the
k1q(,I, Cox Pond Mitigation Bank Parcel BPDP
ki;� HUC 03020201 Page 2 October 2021

aerial photography, but it has since been filled. UT4 is an intermittent stream that begins off site and
flows into the easement from an existing culvert at Country Club Road. It flows north, surrounded by
crop fields, and continues off site. hitch B flows east to its confluence with UT4, bordered by a
residential mobile home park to the north and agricultural fields to the south. The Parcel is
characterized by gently sloped valleys of agriculture fields.
In general, this area has maintained its rural, farming chiaracter over the last 60 years with only minor
changes in land cover (see historical aerials in Appendix B). The consistency in land use within the
project watershed indicates that processes affecting hydrology, sediment supply, anid nutrient and
pollutant delivery have not varied widely over this time period. With a lack of developmental pressure,
watershed processes and stressors from outside the project limits are likely to remain consistent
throughout the implementation, monitoring, and closeout of this project.
Table 2: (Buffer (Project Attributes
..............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................
Project Name
Cox Pond Mitigation Bank. Parcel
Hydrologic Unit Code
03020201170050
River Basin
Neuse
Geographic Location (Lat, Long)
P78.0826601-W, 35.2376274°NSite
Protection Instru gent (DB, PG)i
ecorded
Total Credits
435,596.503 buffer mitigation credits and 28,024.248 lbs. N'
Types of Credits
Riparian Buffer and Nutrient Offset Credits
BPDP (Date
October 2021
Initial Planting Date
December 20,2.2
Baseline Report date
April' 2023
MY1 Report Date
December 2023.
MY2 Report 'Date
December 2024
MY3 Report Date
December 2025
MY4 Report Date
December 2826
NVY5 Report Date
December 2027
2..31 Site Viability for Buffer Mitigation and Nutrient Offset Mitigation
On February 4, 2021, NCDWR assessed the stream origin and issued the official Stream Origin
Determination Letter March 16, 2021. INICDWR also performed an onsite visit of the project area to
determine viability for buffer mitigation and nutrient offset on April 15, 2021 and issued a site viability
letter on May 19, 2021. (Eleven features were assessed by NCDWR during the April 15`" site visit, four
features were deemed viable to generate buffer credits and three were deemed viable for nutrient
offset credits only. The Buffer Interpretation/Clarification Memo #20,08-019 applies to Ditches B and C
where mainteniance of diffuse flow into the conservation easement is unattainable. The reduction in
credit from the memo being applied is documented in Figure 7. There have been no changes to land) use
in, the project area since NCDWR's 2021 site visits. A copy of both the "On -Site (Stream Origin)
Determination for Applicability to Neuse Riparian Buffer Rules"° and the "Site Viability for Buffer
Mitigation & Nutrient Offset" letters from NCDWR are included in Appendix C and summarized) in Table
3.
ai U Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 3 October 2021

Table 3. Project Features
Feature Narne-
Classification
Duffer Credit Viable
Nutrient Offset Viable
UTI
Stream
Yes
Yes
(non -forested areas only)_
Yes
UT2
Stream
Yes
(non -forested areas only)
UT3
Strea m
Yes
Yes
UT4
Stream
Yes
Yes
Ditch A
Ditch
No
Yes
Ditch B
Ditch
No
Yes
>3' depth
Ditch
Ditch C
No
Yes
>3' depth
Ditch
Ditch D
>3' depth
No
No
Ditch E, F, G Ditches No No
Ditches D, E, F, and G were evaluated for buffer or nutrient viability but are not being proposed as part of
this project and therefore are not included in any credit requests.
2.4 Alternative Mitigation
In addition to buffer restoration on subject streams, per the Consolidated Buffer Mitigation Rules (15A
NCAC 02B 0.0295 (o)), alternative mitigation, is proposed on the Parcel in the form of buffer preservation
of forested land on subject streams. The proposed project is in compliance in the following ways,
Preservation on Subject Streams (15A NCAC 02B .0295 (o)(5):
• The buffer width, is at least 30 feet from the stream (See Figure 8 for buffer zones). The
minimum width of riparian areas on this site is 50 feet from top of banks,
• The area meets the requirements of 15A NCAC 02R 0.0403(c)(7)1, (8), and (11) with no known
structures, infrastructure, hazardous substances, solid waste, or encumbrances within the
mitigation boundary (See Section 2.21 and Appendix D for an IEDR Radius Report summary).
Mitigation credits for preservation are being requested on no more than 25% of the total area of
buffer mitigation (See Table 9 for credit calculations).
2.5 Watershed Characterization
The Parcel is located within the HUC 03020201170050. All project features drain to Brooks Swamp off
site, which then, connects with Thoroughfare Swamp. Thoroughfare Swamp subsequently flows to
Falling Creek and finally into the Neuse River, Brooks Swamp, Thoroughfare Swamp, and Falling Creek
are all classified as WS-N and NSW by the NCDWR. Waters designated as WS-lV are sources of water for
drinking or food processing in moderately to highly developed watersheds. These waiters are also
protected for Class C uses, which includes recreational use, agriculture, fishing and fish consumption!,
and the maintenance of biological integrity for wildlife. The NSW designation applies to surface waters
that are experiencing excessive growths of microscopic or macroscopic vegetation.
Topography, as indicated on, the Mount Olive USES 7.5-minute topogra:ph,ic quadrangle, shows gently
sloped areas throughout the Parcel (Figure 4). A portion of UT1, downstream of the project area, is
depicted as a stream on the USGS, Topographic Map. Drainage areas were delineated using the USGS,
Stream Stats website and the North Carolina Floodplain, Mapping Program's 2014-2015 Light Detection,
and Ranging (LiIDAR) data. Land uses draining to the project streams are primarily agricultural with some
wetlands and forested areas. The watershed areas and current land use around project streams are
aiU Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 4 October 2021

depicted in Figure 5, the current land use photographs in Appendix A, andl are summarized in Table 4
below.
Table 4: Drainage Areas and Associated Land Use
Watershed Area
Reach Name
(acres)
Land Use
60'% agriculture; 7% wetlands; 6% forest; 11% grassland;
UT1
172
6% developed; 10% shrubland; <1% impervious area
77% agriculture; 12% grassland; 10% developed; <1%
UT2
41
shrubland, <1% impervious area
UT3
22
97% agriculture, 2% forest, 1% developed
59% agriculture; 4% wetlands; 8% forest; 8% developed;
UT4
L_
10,7
20% shrubland; 1% impervious area
RIMMEM. 0
The proposed Parcel is mapped by the Wayne County Soil Survey. The project area soils are described
below in Table 5. UT1 and UT2 are depicted as streams on the MRCS 1974 Soil Survey provided in Figure
6.
Table 5. Project Soil Types and Descriptions
Soil Name
Description
Bibb sandy loam consists of poorly drained soil on floodplains.
Bb - Bibb Sandy Loam, 0-2% slopes
Permeability is moderate and surface runoff is slow. Water ponds in
some places and floods are frequent. Seasonal high water table is at
the surface.
Goldsboro sandy loam consists of moderately well drained soil on
Co - Goldsboro Sandy Loam, 0-2% slopes
floodplains. Permeability is moderate and surface runoff is low. Water
ponds in some places and floods are frequent. Seasonal high-water
table is at 15" to 45".
Kenansville loamy sand consists of poorly drained soil in flood plains in
Ke - Kenansville Loamy Sand, 0-2% slopes
long narrow bands along larger streams. Infiltration is moderate, and
surface runoff is slow. Water ponds in some places. Seasonal high
water table is at 36" to 62".
Lynchburg sandy loam consists of somewhat poorly drained soil on
Ly -Lynchburg Sandy Loam, 0-2% slopes
broad interstrearn divides. Permeability is moderate and surface
runoff is slow. Seasonal high-water table is at 6". Poncling and
flooding are low.
Rains sandy loam consists of poorly drained soil in oval depressions
Ra - Rains Sandy Loam, 0-2% slopes
and on smooth flats in broad areas between streams. Permeability is
moderate, and surface runoff is slow. Water ponds in some places.
Seasonal high water table is at the surface.
Source: Wayne County Soil Survey, June 1974, USDA-NRCS,
https.-Ilwww.arcs. usda.govllnt,ernetIFSEvMANUSCRIPTSItiorth-corolinalwoyneNC19741map3O.pdf
h ttps.,11w ww. nrcs. us do, goylin tern etlFSir MANUSCRIPTS/north carolin alwo yn eNC1 -9741tex t. pdf
k1q(,1, Cox Pond Mitigation Bank Parcel BPDP
ki;� HUC 03020201 Page 5 October 2021

2.7 Existing Vegetative Communities
Existing vegetation within the Parcel is primarily comprised of active row crop fields of corn and
soybeans with a small existing forest along the downstream end of UTI shown on Figure 3, Existing
vegetation species across the project area are listed in Table 6. This is not an exhaustive list but gives an
indication of types of species growing in the area.
Table 6: Existing Vegetation
Woody
Herbaceous
Species
Acer ru,brum
Common Name
Red Maple
Species
Arundinaria gigantea
Common Name
Rivercane
A In us serru la to,
Betula nigra
Tag Alder
River Birch
Lonicera japonica
Persicaria sagittato
Japanese Honeysuckle
Tear thumb
Compsis radicans
Trumpet creeper
Polygonum spp.
Knotwee,d
Diospyros virginiona
American Persimmon
Phytolacca americana
Pokeweed
Ilex opaca
Juglans nigra
American Holly
Black Walnut
Senna obtusifolia
smilax spp.
Sic�klepod
Greenbriar
Lig,ustrum sinense
Chinese Privet
Typha spp.
Cattail
Liquidambar styracifilua
Liriodendron tulip fern
Magnolia virginiana
Sweetgum
Tulip Poplar
Sweetbay Magnolia
Melia ozedarach
Chinaberry
Pinus toeda
Loblolly Pine
Platanus occidentalis
American Sycamore
Prunus se ro tin a
Black Cherry
Quercus phellos
Quercus nigra
Quercus velutina
Willow Oak
Water Oak
Black Oak
Rhus copallinum
Rubus spp.
Salix nigra
Winged Sumac
Blackberry
Black Willow
Sambucus conadensis
Elderberry
Sassafras albidurn
Sassafras
Toxicodendron radicans
Poison Ivy
2.8 Threatened and Endangered Species
The NC Natural Heritage Program (NHP), database and the US Fish and Wildlife Service (U'SFWS)
Information for Planning and Consultation database (IPaC) were searched for federally listed threatened
and endangered plant and animal species in Wayne County, NC. One listed endangered species and two
species proposed for listing as endangered or threatened were identified: the red -cockaded woodpecker
(Picoides borealis), the INieuse River waterdog (Necturus lewisi), and Carolina madtom (Notu'rusfuriosus).
Wildllands performed a pedestrian, survey of the project parcel on January 7', 2021. It was determined
that there is no suitable habitat for any of the listed species; therefore, the project will have "no effect"
on, the federally listed species. The USFWS Self -Certification Letter packet and the USFWS response
letter agreeing with the determinations are included in Appendix D.
Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 6 October 2021

2.9 Cultural Resources
There are no existing structures in the project area. The Parcel is not located near any sites listed on the
National Register with the State Historic Preservation Office (SHPO)l. SHP0 was contacted with request
for review and comment on January 29, 2021, SHPO responded on March 12, 2021 that they "are aware
of no historic resources which would be affected by the project" a:nid have no comment on the project as
it is currently proposed. The SHPO request and response are included in Appendix D.
2.10 FEIVIA Floodplain Compliance
The Parcels are not located in a FEMA floodplain so a floodplain, development permit will not be
required. No hydraulic modeling is proposed for this project.
2.11 Parcel Location, Parcel Constraints, and Access
The project area is split into two sections whiich are both easily accessible, one via, a dirt access road off
Cox Pond Road and the other via Country Club Road. Within, each section, there are no easement breaks
or internal crossings. There are multiple overhead utility easements on the project properties, all
located! outside of the proposed conservation easement, The offline pond along UT, upstream of the
confluence with UTI shown on Figure 3, has been, removed and covered with topsoil (See Figure 3 and
Appendix A),
The field north of U'T3 and Ditch C was used for hog waste application until June 2021, The parcel has
been removed from the Waste Utilization Plan and the associated permit has been, adjusted. The new
plan, has been approved by NCDWR; a copy of the approval has been included in Appendix E for
reference.
2.12 Other Environmental Conditions
An EUR Radius Map Report with Geocheck was ordered for the Parcel through Environmental Data
Resources, IInc. on September 4, 2020. Neither the target property nor the adjacent properties were
listed in any of the Federal, State, or Tribal environmental databases searched by EDR. There were no
known or potentially hazardous waste sites identified within or immediately adjacent to the project
area. The Executive Summary of the EDR report is included in Appendix D.
3.0 Site Protection Instrument
The land required for planting, management, and stewardship of the mitigation, project includes
portions of the parcels listed in Table 7. The Parcel will remain in, private ownership, protected in its
entirety by an approved NCDWR long term steward, and will be managed under the terms detailed in an
approved NCDWR conservation easement.
Table7: Site Protection Instrument
Site
Deed Book
Acreage
Landowner
PIN
County
Protection
and Page
to be
Instrument
Number
Protected
2574-33-4662
2574-42-01745
Conservation
To Be
Jackson Farming Company, LLC
Wayne
2427
2574-41-3713
Easement
Recorded
2574-32-3190:
1
Cox Pond Mitigation Bank Parcel BF`DP
HUC 03020201 Page 7 October 2021

4.0 Wigation Work Plain
The project will restore agricuilturailly impacted land along UT1-UT4 and Ditch A-C on the Parcel to a:
protected riparian corridor, improving the ecological function of the area. Figure 7 illustrates the buffer
credit areas and conceptual design; Figure 8 depicts the riparian buffer zones for the Parcel.
4.1 Parcel Preparation
Thie la:nd within the project parcels has been cleared and maintained for row crop cultivation, except for
the recently filled pond near the conifluence of UTI and UT3 and a small, forested area along UITI. Areas
slated for restoration, will requiire little site preparation because the land has been, cleared and
maintained for agriculture; therefore, soil disturbance during planting of the project will be minimal.
Along UT1 and on the downstream end'! of UT2 where sink holes or active erosion are observed, minor
grading will be completed), erosion control matting installed, and live stakes planted as necessary. The
dlistuirbed areas will be seeded immediately for soil stabilization with, a: mixture of native grasses and
forbs.
Soil samples will also be collected and analyzed prior to planting to determine if soil preparation is
necessary to suipport herbaceous and planted stem success. Additionally, during the spring of 2022, the
condlition of herbaceous cover prior to the establishment of row crops will be visually assessed across
the Parcel. if herbaceous vegetation does not appear to grow naturally, Wildlands will note the areas of
deficiency and seed them the following spring of 2023.
Old farming equipment has been observed in the preservation area along UTI upstream of the
confluence with UT3. Trees have grown up around and into the equipment, in, some places, they have
begun to envelope parts of the metal frame (see the last page of the Current Land) Use Photographs in
Appendix A). Wildlands proposes to leave the larger pieces of equipment as is, so as not to cause
damage to the trees and a: large disturbance in the area: we are preserving.
4.2 Riparian Area, Restoration, ctivities
Riparian area restoration will involve planting appropriate native tree species along the riparian corridor.
Vegetation management and herbicide applications may be needed over the first few years of tree
establishment in the riparian restoration areas to prevent encroachment of undesirable species that
may out -compete the planted native vegetation. Tree species planted across the riparian areas of the
Parcel will include a mixture of at least 8 species listed in Table 8 below.
Table 8: Selected Tree Species
Species
Betulo nig,ra
Common Warne
River Birch
Density
15%
Forest Strata
Canopy
Platanus occidentalis
Acernegundo
American Sycamore
Boxelder
15%
10%
Canopy
Canopy
Diospyros virginiana
Common Persimmon
10%
Canopy
Populus deltoides
Eastern Cottonwood
10%
Canopy
Quercus michauxii
Swamp Chestnut Oak
10%
Canopy
Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 8 October 2021

Species
Common Name
Density
Forest Strata
Quercus pagoda
Cherrybark Oak
10%
Canopy
Celtis loevigato
Sugarberry
5%
Canopy
Magnolia virginiano
Sweetbay Magnolia
5%
Canopy
Prunus se ro tin a
Black Cherry
5%
Canopy
Ulmus americans
American Elm
5%
Canopy
Trees will be spaced at 7 feet by 12 feet during planting, which, is equivalent to a stem density of 521
stems per acre and is sufficient to meet the performance standards outlined in the Rule 15A NCAC 02B
.0295 of 260 planted trees per acre at the end of five years. At least 8 of the 11 species listed in, Table 7
will be planted, and stems will be well mixed prior to planting to ensure diversity of bare root species
across the Parcel. Due to the nature of random mixing, some stems of the same species might be
planted together in some areas. No one tree species will be greater than 501% of the established stems.
A regionally appropriate seed mix of warm season grasses and wildflowers will also be applied to
provide temporary and permanent ground cover for soil stabilization and reduction of sediment loss
dluring rain events in areas without existing herbaceous cover. The proposed planting area, includes the
areas identified as Riparian Restoration for Buffer Credits and Riparian Restoration for Nutrient Offset
Credits on Figure 7. Planting is scheduled for December 2022.
4.3 Riparian Area Preservation Activities
There will be no parcel preparation work done in the buffer preservation, areas, as allowed under 15A
NCAC 02B .0235(o). The sections of mature forest along UTI will be protected in perpetuity by a
conservation easement (Figure 7). No additional treatment or planting is planned for these areas of the
project.
4.4 NCDWR As-Buiilt Evaluation
Within 30 calendar days after completing the establishment of the buffer mitigation and nutrient offset
areas, the Sponsor will submit written notification to NCDWR documenting that a;ll buffer mitigation and
nutrient offset activities have been completed. Failure to submit written notification within 30 days may
result in a modified credit release schedule or a, delay in the issuance of credit releases.
5.1 Monitoring Protocol
Permanent vegetation monitoring plots will be installed and evaluated within, the restoration, areas to
measure the survival of the planted trees. A total of 18 plots will be randomly placed such, that the plots
are representative of the riparian restoration areas (Figure 9)1. The size of individual quadrants will be
100 square meters.
Vegetation assessments will be conducted and follow the Carolina Vegetation Survey (CVS) Level 2
Protocol for Recording Vegetation (Lee et al., 2008). A reference photo will be taken from the
southwestern corner of each of the 18 plots. Overview photos will be taken, each, monitoring year and
provided in, the annual reports. All planted stems will be marked'! with flagging tape a:nid recorded.
IaiU Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 9 October 2021

The first annual monitoring activities will commence at the end of the first growing season, at least five
months after planting has been, completed and no earlier than, the fall season. Species composition,
height, a:nid survival rates will be evaluated on an aninuial basis by plot. The total niumber of voluiniteer
woody stems will also be documented and reported). The measure of vegetative success for the Parcel
will be the survival of at least four native hardwood tree species, where no one species is greater than,
50% of the established planted stems, a:nid an established density of at least 260 planted trees per acre
at the end of the fifth, year of monitoring. Appropriate and desirable native volunteer species may be
included in the Parcel's density to meet the performance standards with written NCDWR approval.
The Sponsor shall submit the annual monitoring report to NCDWR by December 31" of each year for five
consecutive years and will follow the terms and conditions of the NIMBI..
5.2 Parcel Maintenance
If the Parcel or a, specific component of the Parcel fails to achieve the success criteria outlined in Section
5.1, adaptive measures will be developed and/or appropriate remedial actions will be implemented.
Maintenance will be performed to correct any identified problems on the Parcel that have a high
likelihood of affecting project success. Such items include, but are not limited to, fire, flooding, drought,
or insects that cause excess tree mortality. Any actions implemented will be designed to achieve the
success criteria and will include a work schedule and updated monitoring criteria. A rigorous herbicide
schedule may need to be implemented in the first few years of tree establishment in the restoration
areas to prevent establishment of invasive species that may out -compete the planted native vegetation.
Thee only herbicides used on the Parcel will be aquatic approved herbicides that will be applied in
accordance with (North, Carolina Department of Agriculture ruffles and regulations.
Thie easement boundary will be checked annually as part of monitoring activities. Easement boundary
conditions as well as any maintenance performed will be reported in the annual monitoring reports to
NCDWR. If mowing is deemed necessary by the Sponsor during the monitoring period, the Sponsor must
receive approval from NCDWR prior to conducting any mowing activities within Zone I and Zone 2 of
the Neuse buffers to ensure that no buffer violationis have occurred.
5.3 Easement Boundaries
Easement boundaries will be identified in the field to ensure clear distinction between the Parcel and
adjacent properties. Boundaries may be identified by marker, post, tree -blazing, or other means as
allowed by site conditions and/or conservation easement prior to the NCDWR onsite As -Built evaluation
for Task 2 credit release. Boundary markers that have been disturbed, damaged, or destroyed will be
repaired and/or replaced on an as needed basis. Contact information for the conservation easement
holder will be included on easement markers.
6.0 Financial Assurance and Long -Term Management
6a Financial Assurances
Following approval of the Cox Pond Bank Parcel Development Package, the Sponsor shall provide a
Performance Bond from a surety that is rated no less than an "A-" as rated by A.M. Best. The
Performance Bond amount shall be 100% of the estimated cost for implementation of the project as
described in the Bank Parcel Development Package (BPDP), but not less than $150,000.00. In lieu of
posting the performance bond, the Sponsor may elect to construct the project prior to the first credit
release. In, that case no performance bond will be necessary.
aiU Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 10 October 2021

After completion of the restoration/construction, a separate Performance/Maintenance Bond will be
secured for 100% of the estimated cost to implement the monitoring a:nid maintenance plan but not less
than $100,000.00. The Performance/Maintenance Bond shall apply at the inception of the monitoring
period for a term of one year and be extended aninivally for a minimum of five years. Upon NCDWR
approval, this may be lowered each, year based on, the adjusted cost to complete the monitoring.
Performance bonds for monitoring shall be renewed at least annually to cover the next years monitoring
period, with confirmation of renewal provided to NCDWR with each annual monitoring report when
aipplicable. NCDWR reserves the right to alter the credit release schedule if monitoring reports are
submitted without proof of bond renewals when applicable.
6.2 Long-term Management
The Parcel will remain in private ownership, protected in its entirety by an approved NCDWR long term
steward, and will be managed under the terms detailed in an approved NCDWR conservation easement.
The long-term manager will be chosen prior to monitoring year 4 and will be responsible for periodic
inspection of the Parcel to ensure that the restrictions documented in the recorded easement are
upheld in perpetuity,
7.0 Potential Credit Generation
Of the 24.27 acres protected under the conservation easement, the mitigation approach for 22.3 acres is
riparian restoration. Of that 22.3 acres of restoration, 91.97 acres are proposed for buffer mitigation,
credit and 12.33 acres are proposed for nutrient offset credit. Buffer preservation credlits are also
proposed on 0.33 acres within the conservation easement. The Buffer Interpretations/Clarification Memo
#2008-019 applies to Ditches B and C where maintenance of diffuse flow into the easement is
unattainable. Other areas within the conservation easement where no credit is claimed include areas
which are over 2001 feet from top of bank, the project feature chaniniels, and the area which is less than
50 feet from top of bank along Ditch C.
The credit calculations were derived based on Wildlands' conceptual design for maximum ecological
uplift. The management objectives, mitigation type, and proposed amount of buffer mitigation are
presented in Tables 9 and 10 below. The riparian restoration, areas are viable for either riparian buffer
credits or nutrient offset credlits. However, on this parcel, Wildiands is seeking Riparian Buffer Credit
from areas within top of bank to 100 feet along streams, except on the east side of UT4 where the
buffer width is 30 feet from top of bank. These credits can be converted to Nutrient Offset Credits only
upon receiving written approval by NCDWR. Wildlands is seeking Nutrient Offset Credits in riparian
restoration areas from 101-200 feet from top of bank along streams and from top of bank to 200 feet
along ditches. Riparian restoration areas dedicated to Nutrient Offset Credits on this parcel beyond 100
feet will not be convertible to Riparian Buffer Credits per the UMBI. There will be three credlit ledgers for
the project: Buffer Restoration, Buffer Preservation, and Nitrogen Nutrient Offset Credits.
aikU Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 11 October 2021

Table 10: Cox Pond -Total Area of Buffer and Nutrient Offset Mitigation
TOTAL AREA OF BUFFER
MITIGATION (TABM)
Sqt4fe F�eit­
CrWlts
434,271
0
434,27L000
0.000
P
14,254
1,325303
Tot"0000" 00#0 448,525 435,596.503
TOTAL NUTRIENT OFFSET MITIGATION
ilt
m !0 Oil
et"""
OeOO"'
Went
441
Nitr Ile
537,0155
28,024-248
0.000
Upon, submittal of the appropriate documentation by the Sponsor and subsequent approval by NCDWR,
the mitigation credits associated with the Cox Pondl Mitigation, Bank Parcel will be released as described
in the UMBL
Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 13 October 2021

8.0 References
Lee, M.T., Peet, RX, Roberts, S.D., & Wentworth, T.R. 2008. CVS-EEP Protocol for Recording Vegetation
Version 4.2. hittp:Hcvs.bio.unc.edu/protocol/cvs-eep-protocol-v4.2-levl-2.pdf
North Carolina Department of Environmental Quality (NCDEQ), 2015. 15A NCAC O26.01259 Mitigation
Program Requirements for Protection and Maintenance of Riparian Buffers.
http://reports.oah.state.nc.us/nicac/title%2015a%20-
%20environmental%20quality/chapter%2002%20-
%20environmental%20mana:gement/subchapter�/�20b/15a%20nicac�/�2002b%,20.0295.pdf
North Carolina Division of Water Resources (NCDWR), 1992. NC Surface Water Classifications.
hittps,//ncdlen r. ma ps.a rcgis,com/apps/weba ppviewe r/i nclex, htm I?i d=6eI25acI7628f494694e259c8
Odd64265
North, Carolina Division, of Water Resources (NCDWR), 2000. 15A NCAC 028 .0233 Neuse River (Basin.
Nutrient Sensitive Waters Management Strategy: Protection andl Maintenance of Existing Riparian
Buffers.
https:Hfiles,nc.gov/ncdeq/Water`/�20Quaility/Surface�/�2OWater�/�20Protection/401/Buffer�/�2ORul
es/NeuseBufferRule — 15a%20ncac%2002b%20.0233.pdlf
North Carolina Division of Water Resources (NOW13), 2008. Buffer lnterpretation/Clailrification, #2008-
II
I' =.AM
https:Hfiles,nc.gov/ncdeq/Water`/�20Quaility/Surface%2OWater�/�2OProtection/4Ol/Buffer`/`20CIa:r
if ica,tion%20 Memos/ Diffuse-Flow-for-Buffer-M itigaition-Sites-Buffer-Clarification-Memo-
20080819.pdf
North, Carolina Ecosystem Enhancement Program (NCEEP), 2018. Neuse River Basin Restoration
Priorities (RBRP) 2010 — Amended August 2018.
hittps.//files.nc.gov/ncdeq/Mitigation`/`2OServices/Watershed_Planning/Neuise_River—Basin/RBRIP
-Neuise-201807-.pdf
North Carolina Natural Heritage Program (NHP), 2021. Natural Heritage Element Occurrence Database,
Wayne County, NC. https://ncnhde.natureserve.org/
United States Department of Agriculture (USDA), 1974. Natural Resources Conservation Service, Soil
Survey Geographic (SSURGO) database for Wayne County, North Carolina.
hittpis://websoilsuirvey.sc.egov.usda.gov/
United States Fish and Wildlife Service (USFWS), 2021. Endangered Species, Threatened Species, Federal
Species of Concern and Candidate Species, Wayne County, INC. https://ecos,fws,gov/ipac/
Cox Pond Mitigation Bank Parcel BPDP
HUC 03020201 Page 14 October 2021

I

Directiionv. From the City of Raleigh, travel on 1-40
East for approximately 10 miles, following signs for
Benson/ Wilmington. Take exit 309 for U'S-70 E towardi
Smitlifield/Goldsboro. Continue on US-70 E for
approximately 39 miles then take the: exit for 1-795
South, continue on US-70 BUS E/ US- 117 S for 11.5
miles. Take: the exit for Country Cl�ub Road and turn
right�. Drive 1.6 miles and turn right onto Cox Pond
Road. Dtive 0.8 miles. The parcel is accessible via a
dirt access road on the right.
Bank Parcel Conservation Easement
Cox Pond Mitigation Bank ParcO Location
Figure 1. Vicinity Map
W I L, I") L A N D S 0 0.5 1 Miles Cox Pond Mitigation Bank Parcel
P"k r,4 F f�"' m C: 11 i N Bank Parcel DevOopment Package
VA.
"qlw Neuse River Basin (03020201)
Wayne County, NC

County Boundary
HUC 03020201
Service Area for Project's Credits
Cox Pond Mitigation Bank Parcel Location
um, h,
I; i.rirP'ruirr'u
f 1%.
P*
03020201
ONO",
0�0
•
41"of
f "J'1"Am"
hawn,e,
o.)
�r ii iaj L,,W,;
16 W I L, I") L A N D S 0 5 10 Miles
VA.wJ F, PlIk r-I, N ELI F F1, rIJ G I' I
Iql1w
Figure 2. Service Area Map
Cox Pond Mitigation Bank Parcel
Bank Parcel Development Package
Neuse River Basin (03020201)
Wayne County, NC

Figure 3. Site Map
I L, �J�A N 0 200 400 Feet Cox P � �PondMitigation Bank Parcel
F" m �: N _ I JI 'Runk Parcel Deveieprnent Package
Meuse River Basin (03020201)

Figure 4. USGS Topographic Reap
r 0 250 SBt? Feet
I �. � ,�. N I S Cox Pond Mitigation Bank. Parcel
g r �. r��; m a �.: i N _ i JI Bank Parcel Development Package
ease Diver Basin (03020201)
Wayne County, NC

Rank Parcel Conservation Easerrment
» w,
� s
w ud�C,'w4, tl "
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It
\N
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, yM, � ,, b• noµ
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� N RCS 1974 Soil Survey of Wayne County Sheet 36 wu »
Figure 6. MRCS 1974 Soil Survey Map
r t
I �. � :u �l AN � S 0 200 400 FeeCox Pond Mitigation Bank Parcel
.k -1 g N G. F F11 m r»j G b JI 'Bunk Parcel DevOoprnent Package
Meuse River 'Basin (03020201)
Wayne County, NC

Figure 7. Buffer Credits Map
I L, �JN �A 0 200 400 Feet C � �Cox Pond Mitigation Bank Parcel
F" m I JI 'Runk Parcel Deveioprnent Package
Meuse River Basin (03020201)
Wayne County, NC

Figure 8. Riparian puffer Zones Map
I �. � � p A N I S 0 200 400 Feet Cox PondMitigation (Rank Parcel
g N G. F F" m rwj I JI 'Runk Parcel Deveieprnent Package
Meuse River Basin (03020201)
Wayne County, SIC

Feet �..., I��, (� 2(�0 4(��? ��m�re 9. Monitoring Bank Parcel
Map
� A N � �, � Cox PondMitigation
r ws g N G. F F" m rwI I _JI 'Runk Parcel Deveieprnent Package
Meuse River Basin (03020201)
Wayne County, NC

Appendix N
'%'.urrent Land Use PhotograpKi

UT1

UT1 — Upstream heft from confluence with UT2 (0711512021 )
UT2
UT2 — Upstream left (02/1 r/2021 )
r.wnstream (r r
UTI Upstream right from confluence with UT2 (0711512021)
UT2 Downstream right (07115/2021)
9.1%, Cox Pond Mitigation Bank Parcel
I UC OJ3O12D201

UT3 and Ditch C — Downstream left (0711512021)
UT3 and Ditch C — Upstream left (0711512021)
UT3 and Ditch C — Downstream (0711512021)
UT3 and Ditch C — Downstream right (0711512021)
UT3 and Ditch C— Upstream right (0711512021)
9.1%, Cox Pond Mitigation Bank Parcel
*4� HUCO3O20201

t
UT4 Downstream from Country Club Road (0711512021]
UT4 — Downstream (0711512021)
N X
Ditch A — Upstream (0711512021)
UT4 Upstream from confluence with Ditch B (7115120211
Ditch A — Upstream Weft from cornflu.rernce with UT2
(0711.512021)
9.1%, Cox Pond Mitigation Bank Marcel
I UC OJ3O12D201

Ditch B — Downstream (0711512021)
Ditch 8 — Upstream (0711512021)
Ditch B, — Upstream from confluence with UT4 (07115120211
9.1%, Cox Pond Mitigation Bank Parcel
*4� HUCO3O20201

-------------------------------------------------------------------------------------------
Pond Removed near Confluence of UT1 and UT3
Old Farming Equipment
UT1 - Preservation area downstream left (0711,512021)
Cox Pond Mitigation Bank Parcel
HUCO3O20201

Appendix B,
Historical Aerials