20190647 Ver 1_Eight Point DWR comments_20200121

Mitigation Plan Checklist for Riparian Restoration Mitigation Sites -created 7/15/13
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❑ Site Location
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digit HUC &/or 14 digit ('f applicable
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Project Name:
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❑ Existing Site Conditions w/.p o�tos
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❑ All proposed mitigation activities, including a brief summary of stream and/or wetland mitigation w/
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❑ Verification that the site does not have an impact on threatened or endangered species
❑ Verification that the site is not affected by on -site or nearby sources of contamination as provided
\ by Environmental Data Resources, Inc.
❑ Verification that the site can be constructed on land if it is an archaeological site;
❑ A list of all permits that will be required and obtained prior to constructing 9 the mitigation site for
nutrient offset and/or buffer mitigation (e.g. Sediment and Erosion Control Plan from Division of
Land Resources, NCG01000Q Stormwater Permit from NCDWQ, 404 permit from the Army Corps
of Engineers and corn finding 401 Water Quality Certification from NCDWQ).
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Eight Point Riparian Buffer Mitigation Plan DWR# 2019-0647
DWR staff (Katie Merritt) Comments submitted 1/21/2020:
1. General Comments:
a. The plan is incomplete and somewhat hard to follow with having Figures placed
within each section. The preferred template has the figures provided at the end of the
plan's text and before the Appendices.
b. Add a service area map to the Figures. The Service area map should show the
Randleman Lake Watershed being serviced by this buffer project
c. Consistent misuse of the term "riparian buffer" or "buffer" is used throughout the text
and can lead to confusion or misleading information. These terms are only to be used
to describe the Randleman Lake Watershed buffers, which is 0-50' from top of bank
and has a Zone 1 & Zone 2. Please correct terminology where it is being misused
and replace with "riparian area" where applicable.
■ Example: "The project includes the restoration of riparian buffers card
ad/(ecent ri/)crr•iart ar (/t
2. Section 1.0; pages 5-6
a. Define EPBRS.
b. Table 2 has unrealistic expectations for Initial Planting Date
c. Add language to clarify this site is being submitted for buffer mitigation credits to be
used in the Randleman Lake Watershed. Currently, it only references the 14-digit
HUC and the Cape Fear River basin.
d. Last paragraph of 1.2 states there is a "small structure that sits within the easement."
What is this structure?
3. No photos are provided showing existing riparian conditions. Please add photos of the
riparian areas w/ dates that are recent. Indicate any land use changes, if any, from the date
DWR was last onsite, which was July 2019
4. Section 2.0
a. There are no regulatory considerations provided. This section needs to include a
summary of the results from the Cat -Ex findings, and reference any and all
correspondence relative to the Cat -Ex findings. The Cat -Ex signature page is signed,
but the form is not filled out completely.
b. Table 2:
■ Change "Buffer Width" column to be "Min -Max Buffer Width" and complete
the table.
■ Add a column for "Total Area" (this is the area measured before ratios are
applied)
■ Insert "No" for the column on nutrient offset conversion
5. Figure 6 — the scale is shown for 150', but the widths are wider than 150'. Adjust the scale to
200'; Change 100-200' to 101-200'
6. Section 3.1 —
a. What is the acronym, PHBRS?
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b. It says, "no grazing will occur on the parcel outside of the easement". What about
inside of the easement? Explain.
7. Section 3.2 —
a. The Planting Plan is incomplete and lacks sufficient detail for DWR review. Stems
are described as "potential species that may be included". Revise plan to include
exactly what is intended to be planted along with the percentage of each species that
will be planted. The performance std for success of the site in 0295 (n)(2) states that
no one species planted can be more than 50% of the stems. Therefore, this
information is necessary to provide.
b. Provide detail on the riparian widths that will be planted
c. How will diffused flow be achieved or is there no problem?
d. Remove Tag Alder from the selected species, it is not an appropriate species for
buffer mitigation sites
e. Green Ash should either be removed or limited to no more than 5% of stems that are
planted. The Emerald Ash borer is a risk to this species.
f. It isn't clear if the herbaceous seed mix noted in this section refers to temporary or
permanent seeding. However, DWR requests that permanent riparian seeding also be
applied and established where bare areas caused from cattle are present. It is
important to maintain a healthy and diverse herbaceous layer within the riparian areas
to reduce the potential of runoff, nutrients and sediments into the streams.
g. Planting with a seed mix that is abundant in annual and perennial pollinator species is
strictly voluntary but is being encouraged by DWR in other mitigation plans to
promote diversity and enhance the health of the herbaceous layer, which can also
greatly benefit planted stems.
Section 4.0 —
a. The Monitoring Plan is incomplete and lacks significant details needed to confirm
compliance of .0295 (2)(B & E) and (4).
b. There is no clear understanding of what data is going to be collected, it only says,
"data will include a count of individuals by species". DWR requires the Quantity &
Quality of the stems in the plots be provided in monitoring reports. Therefore, it is
expected that heights of species counting towards your perf. Criteria are included in
the data along with the species name.
c. Will data include Planted &/or Volunteers? CVS level 1 or II? If planning to count
volunteers, it must be stated that "desirable volunteers may count towards
performance standards only upon DWR approval".
d. Figure 7 only shows 3 permanent plots, but the text says there will be 1 plot per
planted acre and half will be a permanent location. Table 2.0 exhibits 5 acres to be
planted. Explain.
e. Random vs Permanent plots: All plots, including the Permanent plots should be chosen at
random. Explain the difference here. Do you mean, "rotating plots"?
f. For Random/Rotating plots: Indicate the frequency that plots will be rotated, how many
plots will this consist of each year in addition to the permanent plots? Acknowledge that
the location of the random plots used for recording vegetation data need to be provided
with each monitoring report and have to be representative of the areas planted. These
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plots have to be the same size as the permanent plots but can be different shapes. What
will the shapes be of these plots?
g. Stems are supposed to be flagged in the plots. State this will be done.
h. Quantity of plots: DWR needs to know the minimum # of plots DMS intends to use, both
permanent & random, for each monitoring year.
i. Clarify that monitoring will be conducted for 5 years or until performance standards
have been achieved.
Section 5.0: Instead of Success Criteria, please use "Performance Standards" to be consistent
with .0295 terminology
a. Explain what is meant by "vegetation plantings". Trees? Shrubs? Herbaceous?
b. The rule 0295 (n)(2)(B) provides two options for planting plans, Is it Trees? Or Trees &
Shrubs combined? please pick the one that applies to this site and cite the rule
c. There was only one shrub, Buttonbush, listed in Section 4.0. What is the % of this shrub
in your planting plan?
d. Without knowing what data will be collected in Section 4.0, reviewing this section for
completion and compliance with 0295 is difficult.
e. Clarify that a photograph will be taken of each permanent & random/rotating plot each
year for the report.
f. How are "qualitative conditions" going to be measured? What data will this consist of?
10. Section 6.0
This section describes what DENR stewardship will do. But what is the Provider
expected to do during their monitoring years 1-5? Identify how the boundary will be
marked at as -built. It says the stewardship program will install signage...but isn't
that done at closeout? If so, the provider needs to install their own temporary signs
and mark the easement boundary before As -Built as to avoid any confusion of where
the boundaries are.
11. Was there an AD-1006 form required?
12. Overall, if the riparian restoration is done according to the plan and addresses all comments
and corrections provided by DWR, the site should provide a good buffer mitigation project.
A response to all comments above, along with edits made to the final draft are requested by DWR
prior to final review & issuance of any plan approval. No work is to be done on the site until written
DWR approval has been provided in accordance with 15A NCAC 02B .0295 (n)(2).
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