20201942 Ver 2_DWR Comments - Cox Pond BPDP_20220223

From:Merritt, Katie
To:Andrea Eckardt
Cc:Wojoski, 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 Summary.pdf
Cox Pond BPDP_DWRedits.pdf
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 RS 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: https://edocs.deq.nc.gov/Forms/Mitigation_Information_Upload . 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
https://deq.nc.gov/about/divisions/water-resources/water-quality-permitting/401-buffer-
Website:
permitting-branch
512 N. Salisbury Street, Raleigh, NC 27620
1617 Mail Service Center, Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Summary of Comments on Cox Pond BPDP_DWRedits.pdf
Page: 4
Number: 1Author: kymerrittSubject: Sticky NoteDate: 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.

Page: 5
Number: 1Author: kymerrittSubject: Sticky NoteDate: 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

Page: 6
Number: 1Author: kymerrittSubject: Sticky NoteDate: 2/23/2022 3:54:29 PM
report in ft2
Number: 2Author: kymerrittSubject: Sticky NoteDate: 2/23/2022 3:53:49 PM
update table after updating Table 9
Number: 3Author: kymerrittSubject: Sticky NoteDate: 2/23/2022 3:55:02 PM
also reference Table 9 in addition to Figure 7 since that's where you show the deductions.

Page: 10
Number: 1Author: kymerrittSubject: Sticky NoteDate: 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: 1Author: kymerrittSubject: Sticky NoteDate: 2/23/2022 3:57:36 PM
there should be at least one subcanopy species in this plan

Page: 14
Number: 1Author: kymerrittSubject: Sticky NoteDate: 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: 2Author: kymerrittSubject: Sticky NoteDate: 2/23/2022 4:01:33 PM
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.

Page: 15
Number: 1Author: kymerrittSubject: Sticky NoteDate: 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.

Page: 25
Number: 1Author: kymerrittSubject: Sticky NoteDate: 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: 2Author: kymerrittSubject: Sticky NoteDate: 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: 3Author: kymerrittSubject: Sticky NoteDate: 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

Page: 26
Number: 1Author: kymerrittSubject: Sticky NoteDate: 2/23/2022 4:05:07 PM
make edits based on comment on Figure 7

Page: 27
Number: 1Author: kymerrittSubject: Sticky NoteDate: 2/23/2022 4:05:12 PM
make edits based on comment on Figure 7