HomeMy WebLinkAbout20140820 Ver 6_BPDP Review - Caraway Bluff Phase II_20220920
Hamilton, Ryan
From:Merritt, Katie
Sent:Wednesday, September 21, 2022 4:52 PM
To:Hamilton, Ryan
Subject:FW: BPDP Review - Caraway Bluff Phase II
Attachments:Comment Summary_DWR.pdf
Follow Up Flag:Follow up
Flag Status:Flagged
Ryan,
Please file email chain below and the attached Comment Summary into 2014-0820v6
From: Merritt, Katie
Sent: Tuesday, September 20, 2022 5:32 PM
To: Jamey McEachran <jmceachran@res.us>
Subject: BPDP Review - Caraway Bluff Phase II
Hey Jamey
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 September 1, 2022,
Environmental Banc & Exchange, LLC (EBX) submitted a Bank Parcel Development Package (Plan) for the Caraway Bluff
Phase II 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 EBX is ready to submit their final project Plan, please include a summary of all EBXs’ responses to the DWR
comments acknowledging how EBX 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# 2014-0820 (version 6) 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: https://deq.nc.gov/about/divisions/water-resources/water-quality-permitting/401-buffer-permitting-branch
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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.
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Summary of Comments on CarawayBluffII_DWRedits.pdf
Page: 2
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:16:48 PM
project number is 2014-0820 version 6
Page: 4
Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:17:14 PM
(UMBI)
Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:19:20 PM
need to show where the site can be accessed by DWR; include site access on a supporting figure and reference that figure here.
Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:17:35 PM
DMS DWR ID is 2014-0820 version 5
Page: 5
Number: 1 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:20:22 PM
Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:20:25 PM
site
Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:20:13 PM
Add the Preservation under (o)(4) here too since it's also alternative
Page: 9
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:26:23 PM
add a description for D2 since it's entering BH4
Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 5:06:16 PM
within an existing conservation easement
Number: 3 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:26:49 PM
bisects the riparian area adjacent to BH3 and
Number: 4 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:27:13 PM
The
Number: 5 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:27:27 PM
was determined to not be viable
Number: 6 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:27:04 PM
bisects the riparian area adjacent to BH3 and
Number: 7 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:27:54 PM
and as indicated in the site viability letter
Page: 13
Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:28:41 PM
and agricultural ditches
Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:28:57 PM
mitigation
Number: 3 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:29:07 PM
riparian
Number: 4 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:29:16 PM
and preservation
Number: 5 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:30:06 PM
there is no need to reference (o)(7) since it doesn't apply to this site. However, (o)(4) needs to be added
Number: 6 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:30:15 PM
and the UMBI
Number: 7 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:33:11 PM
add a note that the riparian restoration and preservation efforts will begin immediately at the outermost easement boundary of the proposed
DMS Full Delivery project where applicable, ensuring a contiguous conservation easement and forested condition at AsBuilt. Or some other way
of wording this to mean the same thing.
Number: 8 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:33:24 PM
riparian
Number: 9 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:33:30 PM
riparian
Number: 10 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:33:36 PM
riparian
Number: 11 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:33:45 PM
riparian
Page: 14
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:34:32 PM
as noted in phone conversation, add clarity about the culverts. Which are being added, removed, etc. Make sure to update Figure 6
Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:40:59 PM
as discussed over phone, what is EBX intending to do specifically for Ditch 6 since it is bypassing the riparian buffer and is not creditable. We
discussed wetland species, live stakes of willow, etc.
Page: 15
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:39:24 PM
recommend this language or something similar to replace what is currently here:
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 all 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.
Number: 2 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:34:44 PM
Number: 3 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:34:46 PM
EBX
Number: 4 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:34:53 PM
shall
Page: 16
Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:41:22 PM
adjacent to
Page: 19
Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:44:55 PM
per the approved UMBI
Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:45:20 PM
DWR-
Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:47:43 PM
December 31 is in the UMBI language
Number: 4 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:47:28 PM
Number: 5 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:47:25 PM
December 31
Number: 6 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:48:20 PM
If approved by DWR as an acceptable long term steward for this Site,
Number: 7 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:50:20 PM
I did not see this letter/email, but do need this correspondence to make sure EBX is complying with the UMBI expectations
Page: 20
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:53:45 PM
per our phone conversation, once credits are updated in the table, these numbers will change
Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:58:40 PM
buffer
Number: 3 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:55:54 PM
restoration
Number: 4 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:56:15 PM
Number: 5 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:56:27 PM
UMBI
Number: 6 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:58:05 PM
Number: 7 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:56:40 PM
riparian buffer credits
Number: 8 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:57:03 PM
is expected to
Number: 9 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:54:30 PM
Nitrogen
Number: 10 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:55:28 PM
add a note that most of these credits are dependent on the approval and full implementation of the Caraway Bluff DMS F/D project
Number: 11 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:57:45 PM
add a note that final credits will be determined in a survey provided in the asbuitl report...or some custom language that speaks to this
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Page: 21
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:01:51 PM
as discussed, this table is old and needs to be replaced with the correct table
Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:00:06 PM
where applicable, edit feature name to include correct widths where DMS F/D affects Minimum width for bank.
Example: Carraway Creek & BH1 (50-100')
instead of "Carraway Creek & BH1"
Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:00:34 PM
check no
Number: 4 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:02:09 PM
diffused flow deductions are only required off D2
Number: 5 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:01:11 PM
for BH3 on these two rows, add "right bank"
Page: 22
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:03:51 PM
replace this credit release schedule with the one used for Thunder Swamp II
Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:53:14 PM
-
Page: 25
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:04:44 PM
change Figure title to be "Riparian Buffer & Nutrient Offset Credit Service Area" or
Riparian Buffer Mitigation and Nutrient Offset Credit Service Area.
Page: 28
Number: 1 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 5:06:41 PM
Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 5:06:56 PM
Conservation Easement
Page: 29
Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 5:07:36 PM
Conservation Easement
Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:07:55 PM
add "Origin"
Page: 30
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:10:41 PM
this aerial may support your nutrient offset credit proposed in this area. If so, please comment about it in your response back tp DWR
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Page: 32
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:11:06 PM
show location of timber mat bridge
Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:11:58 PM
We discussed culvert naming conventions for adding clarity to what is existing, what is being removed, what is being added.
Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:14:05 PM
no deductions necessary on D5
Number: 4 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:14:43 PM
D5 measurement is not correct. This area should be 0-100 off D5, not 101-200 off BH3
Number: 5 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:19:52 PM
How did EBX justify NOC here?
Number: 6 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:15:10 PM
show D2 diffused flow deductions; show "no credit area" measured perpendicular and landward off D2 and remove radius off BH4
Number: 7 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:16:30 PM
add radius to BH3 here since D2 is actually flowing away from BH3 and due to other unique properties of D2/BH3 connection.
Page: 34
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:17:02 PM
see comments on Figure 6 and adjust as needed.
Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:18:09 PM
if EBX proposes a special restoration plan around D6 as discussed on phone and as requested to be called out in the text of BPDP, then D6 should
not include width boundaries. All boundaries here could be measured off BH3.
Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:18:36 PM
it would be beneficial to include all Stream Origin points to this map
Page: 35
Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:19:20 PM
update areas as requested on other figures.