20190800 Ver 1_Boseman Mit Plan- DWR comments_20200121

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❑ Site Location
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Project Name:
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All proposed mitigation activities, including a brief summary of stream and/or wetland mit�ation w/
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CtiYvU'LVh-O 1Q_ Verification that the site does not have an impact on threatened or endan tere �r�Zlc�d
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Ss- Verification that the site is not affected by on -site or nearby sources of contamination as provided
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'-,a, 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
nutrient offset and/or buffer mitigation (
9 the mitigation site
Sediment and Erosion Control Pfan from Division
Land Resources, NCG010000 Stormwater Permit from N DWQ, 404 permit from the Army
of Engineers and corresponding 401 Water Quality Certification from NCDWQ).
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Boseman Riparian Buffer Mitigation Plan DWR# 2019-0800
DWR staff (Katie Merritt) Comments submitted 1/21/2020:
1. General Comments:
a. There is reference to an In -Lieu Fee Instrument on cover page. This instrument is for
stream & wetland compensatory mitigation. DWR & DMS have not entered into an
Instrument governing the operations and procedures for the delivery of Buffer
Mitigation or Nutrient Offset. Please remove reference
b. Note that this site cannot be used to generate nutrient offset credits since no nutrient
offset are being proposed for DWR review and approval. If nutrient offset credits are
proposed for this site, DMS must provide an asset table and corresponding asset map
that shows where Nutrient offsets are proposed.
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 Tar -Pamlico buffer, which is 0-50' from top of bank and has a Zone 1
& Zone 2. This also excludes Ephemeral's. Please correct terminology where it is
being misused and replace with "riparian area" where applicable.
■ Example: "The project includes the restoration of riparian buffers and
acdaccnt ril?ariaar
2. Section 1.0
a. Page 1, 1 st paragraph:
■ Add language to clarify this site is being submitted for buffer mitigation
credits to be used in the 03020101 8-digit HUC of the Tar -Pamlico River
Basin.
■ The riparian buffer credits are shown as 617,394.032. Add "ft2" for the unit
3. Add a service area map to the Figures. The Service area map should show the 03020101 8-
digit HUC of the Tar -Pamlico River Basin being serviced by this project
4. Section 2.0
a. Table 1: clarify that 621,810 ft2 includes "riparian buffers anad udjcaccnt rilwricaar
b. Table 2 has unrealistic expectations for Initial Planting Date
c. Table 3: when comparing to Table 9, the Restored buffer areas in this table are
inconsistent. UT should be 490,568, but this table says 484,131; UT2 reach 2a
should be 1.80 acres & 78,590ft; and UT2 reach 2b should be 1.21 acres & 52,652.
Please explain. (please note, that the 25% of the total mitigated area for ephemerals is
calculated before applying any ratios from the rule".)
5. Section 2.6: Provide directions to the site & I didn't see where the Lat & Long were
provided.
6. Section 2.7: correct typo for rule from 0.029 to .0295
7. Section 5.1: no mentioning of sediment & erosion control measures proposed. With this
site's slope along UT & UT2, and the disking that will be necessary for site preparation,
please explain how stormwater runoff during a rain event during site preparation, will be
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controlled such that sediment loss to the streams is prevented? Also need to clarify that the
herbicide used will be one that is safe for the stream systems and will be applied by a
licensed sprayer.
Section 5.2: Planting a permanent 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. Planting in January 2020 is not likely. Change this date.
9. Section 5.3, last sentence: change to `All areas within 115 feet from features as measured
perpendicular from the tops of banks will be devoted to generate buffer mitigation credits"
10. Table 9: This table needs additional information in order for DWR to confirm the information
provided is compliant with the rules.
a. Add columns for "Mitigation Type", "Total Area" (this is the area measured before
ratios are applied), "% Full Credit", "Final Credit Ratio" and complete the table.
The Credit Ratio column in the table doesn't follow the rule. It should be either 1:1,
2:1, 5:1 or 10:1 depending on the Mitigation Type (see 0295 (m) & (n)). The
3.03030 ratio should be in the "Final Credit Ratio" column that you add. This column
is where you apply the Credit Ratio & % Full Credits columns.
b. Change "Buffer Width" column to be "Min -Max Buffer Width" and complete the
table.
c. Showing the width as 30-100 can imply the top of bank to thirty feet is not part of the
project. Therefore, it is preferred that the table actually show what the minimum -
maximum widths are with the applicable ratios applied. Example: if the minimum
width is top of bank and the max is 100, use 0-100' to describe the riparian areas
within that min -max buffer width and apply the applicable ratios and % reductions
d. Add ,ft2,, to the BMU column
e. There is not enough information to confirm that the calcs used to determine the
"creditable area" for the riparian areas adjacent to the ephemeral is correct and
compliant with 0295 (o)(7). Adding the "Total Area" column to the table will assist
with this. See previous comment in 3c.
11. Section 6.0
a. Recommend combining sections 6.0 & 7.0 and adding more clarity such that DWR
can confirm compliance of .0295 (2)(B & E) and (4) is met.
b. Instead of Success Criteria, please use "Performance Standards" to be consistent with
.0295 terminology
c. No clear understanding of the data collected is provided. What exactly will be
collected? 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. Are you including Planted & Volunteers? CVS level 1 implies no volunteers
are being counted and collected, just checking.
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d. More detail needs to be provided. Provide information on what will be recorded in
the plots, will they be rotating or random plots, what size and shape are the plots, do
they make up a certain percentage of the planted area?
e. Need to include a Figure to reference here, showing the plot placement of your 12
plots. Plot placement will need to be representative of the entire mitigation area, 0-
200' from each tributary
f. Vegetation (7.1) — This paragraph is not 100% accurate. According to the 0295
(n)(2), there are more parameters than just 260 stems/acre. Please correct.
12. Section 8.0 — 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.
13. Section 4.0- Thank you for providing the summary of the Cat. Ex findings. These findings
reference letters and correspondence in the Appendix, but I did not see the supporting
materials and correspondence provided. Can this be provided? EDR summary was
provided.
14. Figure 3:
a. Label the reaches so it can be compared to Table 3.
b. Identify what the drainage area is, not just the location of the drainage area. Are they
being shown in miles or acres? I'm assuming Table 3 should align with this figure.
15. Figure 7:
a. Do not use the Credit Ratio to describe the areas. Show the buffer widths as they are
provided in Table 9. It is preferred to show them as 0-100' and 101-??' for this
particular project.
b. Identify the riparian areas adjacent to the ephemeral channel separately from the area
adjacent to the streams. Use a different color.
16. Was there an AD-1006 form required?
17. Overall, if the riparian restoration, enhancement and preservation 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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