20191261 Ver 2_AsBuilt Review DWR comments - Kittrell Hill_20200820

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Merritt, Katie
Ted Griffith
Scott Frederick
AsBuilt Review - Kittrell Hill
Thursday, August 20, 2020 4:09:00 PM
Hey Ted,
I have finalized my review of the Kittrell Hill As -Built Report that was submitted to DWR on
June 24, 2020. 1 have the following comments that I need you to address:
1. Title of this document says Baseline Monitoring Report. To be consistent with the MBI
& BPDP language, please make sure to use "AsBuilt Report" in the title for these
documents in the future
2. The project number on the cover page shows 2019-1261. The correct # for this project
is 2019-1261 version 2
3. Section 2.0 — There is acknowledgment in the last paragraph that there are differences
in total credits generated than what was proposed in the BPDP. Provide specifics as to
where these credits were reduced (UT1, UT2, the ditch, etc).
4. Section 3.1— Please indicate specifically where culverts were removed. (did you also
remove drainage pipes from the fields)
5. Section 3.2 — It is noted on page 4 that "additional trees were planted to ensure
success...". What were the "additional trees"?
6. Section 3.2 - There is no stem density provided for each of the planted stems. Provide
a table showing the planted density for each species planted. I need this information
to determine if EcoTerra complied with the density allotments approved in the BPDP.
7. There is nothing in the report regarding how Eco Terra complied with section 5.4 of the
BPDP. Explain how Eco Terra complied with this requirement for marking the site's
boundary.
8. Table 7 (planting list) from the BPDP showed 12 species proposed. In reviewing the
BPDP, it was assumed that Eco Terra was planting 12 species, but only 5 were planted.
Provide an explanation as to why Eco Terra only chose to plant 5 from the list.
9. There may have been miscommunication, but DWR expects the proposed planting list
and proposed densities provided in the approved BPDP be exactly what the Provider
plants. Knowing that Eco Terra had such a robust and diverse planting list in the BPDP
DWR did not make many comments on the planting plan proposed & did not feel the
need to express much concern with the species chosen. However, upon review of the
species planted, Eco Terra has 3 oak species that together comprise of >75% of the
planted stems. Additionally, only 1 subcanopy species was planted (3 were proposed).
Planting plans are reviewed by DWR to ensure that not only are the minimum
performance standards being achieved, but also whether the species selected are
appropriate for the site, are a reasonable mix of canopy & sub -canopy species, are a
good ratio of fast-growing to slow -growing species, and whether the densities are
appropriate based on environmental factors or other concerns. Please explain how
the 5 species you selected to plant meet those expectations.

10. Even though 5 is above the minimum performance standard of 4, the spacing and lack
of randomness in planting efforts of these species, as represented by the plot data
provided in Appendix 5, has affected compliance with the diversity and density
performance standards in the MBI, the BPDP and Rule 0295.
a. Plot data show that 12 of 17 plots (>70%) did not meet the minimum
performance standard of 4 species. Explain how Eco Terra will achieve
compliance with this performance standard.
b. Plots 5-17 only have oak species present. Explain how these three oak species
were selected and how your selection meets or does not meet the
expectations of DWR provided in Comment #7 and what efforts Eco Terra plans
to take on the site.
c. Plot data show that 4 of 17 plots ( 24%) did not meet the performance
standard for having no species to be greater than 50% of planted stems.
Explain how Eco Terra will achieve compliance with this performance standard.
d. Silky dogwood was only present in 2 of the 17 plots. With planting 2,500 stems
(@ 17%) as indicated in Section 3.2, DWR would expect more plots to have
Silky dogwood. This data suggests that plot data is not representative of the
planting plan. Explain why silky dogwood is not represented in the other plots.
e. Green Ash is present in 4 of 17 plots, which is greater than what is represented
for silky dogwood (in comment d). However, with planting only 500 stems of
green ash, this would only be 3% of planted stems. This data suggests that
plot data is not representative of the planting plan. Please explain.
11. Section 4.0 — Eco Terra did not acknowledge that the site was not meeting
performance criteria. Please explain why Eco Terra did not address this in the report.
12. Figure 2 & 3 — There are areas within the conservation easement that are not
represented by buffer credit or nutrient offset credits. Please provide updated figures
that shows these areas as "No Credit Areas" and label them ">200'
13. Figure 2 — please call out where there was a conservation easement boundary change
along UT2 at the ditch/stream confluence. The BPDP shows the ditch included in the
boundary and being planted for nutrient offset credits (which are no longer being
claimed). Explain why Eco Terra decided not to include the ditch.
14. Table 2 (project # is incorrect, see comment #2).
15. Table 2 was provided on an 8 % x 11 paper size and is not legible. For future
submittals, this table needs to be provided in a format that is legible as a hard copy. I
recommend exporting the table as a PDF and printing it to fit on a larger paper size.
16. Appendix 2 is not necessary to include in the AsBuilt Report. This information is only
necessary with the submittal of the BPDP.
17. Appendix 3 was provided on an 8 % x 11 paper size and is not legible. For future
submittals, the As -Built survey needs to be provided in a format that will fit on larger
paper sizes and is legible.

Once all items are addressed above and a summary of your responses to these comments is
provided, DWR will discuss needed actions prior to initiating the credit release process for
Task 3. Please upload your responses to these comments and the updated figures as one file
when using our online form. DWR is NOT requesting a resubmittal of the As -Built Report to
address items 1-16. Please just provide your responses and any supporting documentation
that is necessary.
Thank you for your patience,
Katei
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: http://aortal.ncdenr.org/web/wq/401bufferpermitting
512 N. Salisbury Street, Raleigh, NC 27620
1617 Mail Service Center, Raleigh, NC 27699-1617
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