20160366 Ver 1_DWR Response Letter_20170323

W ILDLANDS
E N G I N E E R 1 N G
March 17, 2017
Katie Merritt
NCDEQ— Division of Water Resources
RE: DWR review comments of Mitigation Plan
Martin Dairy Mitigation Site (DMS #97087)
Neuse 03020201, Orange County, NC
Dear Ms. Merritt,
We have reviewed the comments on the Mitigation Plan for the above referenced project dated
February 9, 2017 and have revised the Mitigation Plan and plan set based on these comments. The Final
Mitigation Plan is submitted with this letter including the revisions discussed herein. Below are
responses to comments. For your convenience, the comments are reprinted with our response in italics.
1. Section 8.7 Vegetation and Planting Plan — page 20: Recommend stating types of stems (trees,
shrubs, combo) that will be planted and that "at least 4 species will be planted" — Rule 0295.
Cite Rule 0295 as 'Which became effective November 1, 2015" since there wre 2 iterations of
that rule.
The first paragraph in Section 8.7 has been updated to include the above comments.
2. Section 9.2 Vegetation Performance Standards — page 22: Add the following statement to
decipher between the vegetation performance standards of the IRT and those of buffer credit
generating areas. "The final performance standard within buffer restoration areas generating
riparian buffer mitigation credits shall include a minimum of four native hardwood tree speces
or four native hardwood tree and native shrub species, where no one species is greater than
50% of stems". Note that DWR must also provide written approval of vegetation success of
buffer restoration areas generating buffer credit before monitoring can be terminated.
These statements have been added to the third paragraph in Section 9.2.
3. Section 10.0 Monitoring Plan — page 22:
a. DMS has a "NC Division of Mitigation Services' Riparian Buffer and Nutrient Offset
Buffer Annual Monitoring Report Template (ver. 1.0) dted Feb. 2, 2014. Is there a
difference between this template and the one referenced in this section?
This section has been updated. We have decided to submit two individual monitoring reports for
simplicity. The buffer and nutrient offset report will follow NCDWR guidelines for buffer and nutrient
monitoring. The stream restoration portion will follow the DMS Annual Monitoring Report Template
dated (April 2015). This way all buffer reporting will be in compliance with NCDWR standard reports
and alleviates any possible differences in report formats between the divisions of NCDEQ.
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609

W ILDLANDS
E N G I N E E R 1 N G
Based on Rule 0295, "The mitigation provider shall submit written annual reports ... for a
period of five years after completion of the activities...". According to text in 10.0, it's
not clear when DMS would be proposing the completion of monitoring for the buffer
generating areas. Is the project, as a whole, on a 7 year cycle or a 5 year cycle? If DMS
intends to bring DWR a closeout request for this project based on 5 years of vegetation
monitoring, they need to state that clearly in this section.
Sections 9.2 and 10.0 have been updated to clearly state that NCDMS intends to request closeout
for buffer credits after five years of monitoring. The stream monitoring will continue for seven
years.
c. Table 15: Based on "Note 4", there are 5 total written annual reports that are going to
be spread out over a 7 year period.... which is fine... as long as DMS knows that DWR
won't close out the project until there are 5 written annual reports. As this is written,
buffer mitigation cannot be closed out prior to year 7.
Note 4 was updated to clarify that two separate reports will be submitted to NCDMS and
NCDWR. NCDWR will receive an individual report including monitoring of all buffer activities in
years 1,2,3,4, and 5 so that buffers may close out after five years. A separate report will be
submitted to NCDMS for the stream restoration portion of the site in years 1,2,3,5, and 7.
4. Section 13 Determination of Credits — page 26:
a. Typo —Table 18b should be "17b"
This has been fixed.
b. Table shows 30'-100' instead of TOB — 100' as shown in Concept Map. It should be
shown in table 17b as "TOB —100"' and square feet to be measured accordingly from
TOB back 100' for full credit. If there are any areas less than 30' or 20' within the
easement, then you would show that acreage on a spearate row with the applicable
of full credit as provided in the Rule 0295. Use the columns and descriptions to
complete your asset table.
The table has been updated to show TOB-100'.
c. Verify the assets in 17b with Figure 11 (Concept Map) because the acreages do not
match.
The Concept Map has been updated to the correct acreage, which matches Table 17b.
d. Verify the service area where buffer credits from this project can be provided in the last
row of the table.
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609

W ILDLANDS
E N G I N E E R I N G
The service area has been updated in Table 17b.
5. Appendix 4 — Contains pertinent Figures/Maps including the Riparian Buffer Concept Map and
Monitoring Components Map. Verify the assets in 17b with Figure 11 (Concept Map) because
the acreages do not match.
Figure 11 (Concept Map) has been updated with the appropriate acreage to match table 17b.
6. Appendix 6 Plan Sheets — Sheet 2.0 is the Planting Plan which contains planting zones and
species lists. DWR recomments not planting Tag Alder on buffer restoration sites adjacent to
NSW waters.
Tag Alder has been removed from the planting plan.
If you have any questions please contact me at [e-mail], [phone] x 106.
Sincerely,
Angela Allen, P.E., Project Manager
W Wildlands Engineering, Inc. (P) 919.851.9986 • 312 West Millbrook Road, Suite 225 • Raleigh, NC 27609