20191261 Ver 2_As-Built DWR Comments (signed)_rev_20200915

ID#* 20191261 Version* 2
Select Reviewer:*
Katie Merritt
Initial Review Completed Date 09/16/2020
Mitigation Project Submittal - 9/15/2020
Is this a Prospectus, Technical Proposal or a New Site?* r Yes r No
Type of Mitigation Project:*
r Stream r Wetlands W Buffer V Nutrient Offset
(Select all that apply)
Project Contact Information
Contact Name:*
Ted Griffith
Project Information
...................................................................................
ID#:* 20191261
Existing IDY
Project Type:
Project Name:
County:
Email Address:*
[e-mail]
Version:
*2
Existing Version
r DMS r Mitigation Bank
Kittrell Hill Nutrient Offset and Buffer
Mitigation Bank
Pitt
Document Information
Mitigation Document Type:*
Mitigation Information
File Upload: As -Built DWR Comments on Letterhead
3.08MB
(signed)_rev.pdf
Rease upload only one RDF of the conplete file that needs to be subnitted...
Signature
Print Name:* Ted Griffith
Signature:*

ecolerraA
MEMO
Mrs. Katie Merritt, DWR
9/15/20
Re: Kittrell Hill As -Built Report Comments (DWR Email Dated: 8/20/20)
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
The title of the report has been changed to As -Built Report and will be done on
future documents.
2. The project number on the cover page shows 2019-1261. The correct # for this
project is 2019-1261 version 2
The Project # has been changed to 2019-1261 V2 and will be done on future
documents.
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.).
Credits Generated BPDP vs As -Built
BPDP: Proposed (Table 8)
Buffer: UT1 = 273,427 ft2, UT2 = 95,911 ft2, Total = 369,338 ft2
NOC: UT1 = 17,197.831 IbsN, UT2 = 4,555.222 IbsN, Total = 21,752.990 IbsN
As -Built: Completed (Table 2)
Buffer: UT1 = 273,708 ft2 , UT2 = 90,109 ft2, Total = 363,817 ft2
NOC: UT1 = 17,404.406 IbsN, UT2 = 3742.654, Total = 21,147.061 Ibs N
These differences are the result in a revision to the actual surveyed property
boundary project breaks along the NE/NW property lines compared to GIS
parcel data resulting in credit reduction along UT2(ditch) at the origin of UT2
(stream). In addition, a more accurate survey and drawings resulted in more
accurate credit calculations along all reaches. On future
As -Built reports, these differences will be noted in addition to the tables in the
respective reports.
4. Section 3.1— Please indicate specifically where culverts were removed. (did you
also remove drainage pipes from the fields)
1117 Peachtree Walk NE, STE 126, Atlanta, GA 30309 1 404.596.8004 1 EcoTerra.com

eco,1erra.
Please see the attached revised Figure 2 showing where the drainage
pipes/culverts were removed.
5. Section 3.2 — It is noted on page 4 that "additional trees were planted to ensure
success...". What were the "additional trees"?
Additional trees planted consisted of the five species available at the time of
project construction including water oak, willow oak, laurel oak, green ash, and
silky dogwood.
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.
Stem densities for each of the five species of trees are as follows and were
noted in the text (Page 4): laurel oak (4,000 stems), willow oak (3,750 stems),
water oak (3,750 stems), green ash (500 stems), and silky dogwood (2,500
stems). A table summarizing the species is provided below:
Species
Quantity
%
Laurel oak
4,000
27.5
Willow oak
3,750
25.9
Water oak
3,750
25.9
Green ash
500
3.4
Silky dogwood
2,500
17.2
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.
The permanent conservation easement boundary has been marked with metal
U-channel posts and signage at sufficient distances to ensure easement
integrity and prevent encroachment. Short-term signage was placed initially
showing the State contact information and not the long-term steward now
assigned to inform others farming adjacent to the project early in the growing
season. ETP will compile with Section 5.4 of the BPDP by erecting signage
appropriately on existing metal posts with contact information and fill in any
areas lacking sufficient posts and signage discussed during the As -Built field
review June 16 th, 2020.
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.
1117 Peachtree Walk NE, STE 126, Atlanta, GA 30309 1 404-596.8004 1 EcoTerra.cOm

ecol,terra.
During the period leading up to BPDP approval, only 5 of the 12 appropriate
species considered in the BPDP planting list were available in quantities needed
to cover the proposed project planting area.
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.
The intent of the proposed planting plan in the BPDP was to provide a diverse
mix of tree species including hard and soft mast species, as well as a diversity of
canopy and sub -canopy species matched to the site and soils. Unfortunately,
due to vendor supplies at the time of planting, only the select 5
species appropriate for the project were available. Further, with trees secured
through the BPDP review phase it was revealed green ash could only account
for 5% of the species diversity due to the potential of future ash -bore weevil
mortality. Silky dogwood was available; however, that species thrives in the
near -bank stream region and was planted close to the streams. Although, a
minimum diversity of trees was planted consisting of hard -mast climax species
oaks, the project will ultimately consist of more diverse species across the
project, including pioneer species seeding in from the stream corridors and
forests nearby. Pioneer species recruitment will be noted in the plots on an
annual basis according to CVS Level II protocols. Climax hard -mast species were
chosen not only due to availability but are shade tolerant in herbaceous
competition often found on restored historic agricultural fields in row crops.
These species are also often challenging to establish and maintain in a buffer
restoration project, thus the high planting densities achieved for each oak
species (693 oak trees/ac). Ensuring climax species establishment initially will
result in a more diverse buffer long-term, because climax species rely on slow
dispersal mechanisms such as animals and floodwaters and are often absent
from restoration projects lacking this initial focus on these species.
1117 Peachtree Walk NE, STE 126, Atlanta, GA 30309 1 404-596.8004 1 EcoTerra.cOm

ecolerraA
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.
The three species of oaks selected from the four original canopy trees available
were planted as a randomized mixture across the site as best as possible.
Given, the green ash was reduced to <5%, those trees were positioned in
smaller, wetter areas of the site noted at the time of planting ensuring long-
term survival. As discussed previously, the silky dogwood was planted in the
near -bank region of the streams, the most likely place for that species to
survive and thrive. Overall, the
project meets the intent of the .0295 goals and performance standards given
the circumstances of seedling availability at the time of planting.
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.
It is noted in Table 3 that all the plots meet the tree stem density within
all credit types and widths proposed in the BPDP (Exceeds Criteria (260
stems/ac) by 10%). If considering the circumstances noted above in
Comment #8 at the time of planting, and as indicated by Rule .0295,
additional trees are needed for compliance, ETP will perform
supplemental planting uniformly across the site with 2 or 3 additional
species (depending on availability), likely cherry bark oak, another climax
hard mast species, and river birch or yellow poplar, both wind-blown
seeding species.
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.
Although, a minimum diversity of trees was planted consisting of hard -
mast climax species oaks, the project will ultimately consist of more
diverse species across the project, including pioneer species seeding in
from the stream corridors and forests nearby. Pioneer species
recruitment will be noted in the plots on an annual basis according to CVS
Level II protocols and as approved by DWR for total species counts within
plots.
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.
1117 Peachtree Walk NE, STE 126, Atlanta, GA 30309 1 404-596.8004 1 EcoTerra.cOm

ecolerraA
Explain how Eco Terra will achieve compliance with this performance
standard.
Due to very high planting densities and mixture consistency, some plots
show a species exceeding 50% of planted stems (i.e. willow oak). As
noted previously, stem densities were chosen to not exceed 50% of
planted stems across the entire site in accordance with .0295. During
supplemental planting, additional trees may be planted across the site as
uniformly as possible to ensure ETP is meeting this performance
standard. In addition, natural regeneration from pioneer species will also
reduce the density of a particular species within a plot. Only 4 of the 17
plots indicate this issue, so it is anticipated this will not be an ongoing
issue or impact the overall success of the project.
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.
Silky dogwood is a species that thrives in the near -bank region of streams
and was planted close to the streams/ditches, the most likely place for
that species to survive and thrive. The location and orientation of the
representative plots within each credit type and width (i.e. 0-50', 51-100',
101-200') resulted in the presence of silky dogwood in the plots noted.
The near -bank region was too narrow an area to make a separate
planting zone, and with greater than four species originally planned for
the one project planting zone, the resulting situation planting four
canopy species was not considered diverging from the planting plan and
plot representation across the site.
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.
The intent of planting a more diverse mixture of tree species, including
green ash across the majority of the site did not occur due to seedling
availability and reducing green ash to <5% of species diversity. As noted
previously, given, the green ash was reduced, those trees were
positioned in smaller, wetter areas of the site noted at the time of
planting. Considering only 500 stems were planted, the plots
1117 Peachtree Walk NE, STE 126, Atlanta, GA 30309 1 404-596.8004 1 EcoTerra.cOm

ecolerra.
represented the diversity of credit types and widths within the overall
planting area, rather than the narrow planting area of silky dogwood in
the near -bank region, thus 4 of 17 plots is appropriate and a
circumstantial result of plot placement within buffer types and widths
within the wetter area of the project site where green ash was planted.
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.
Eco Terra's understanding of the intent of .0295 was the project was in
compliance and meeting performance criteria overall. As noted previously, the
circumstances at the time of BPDP approval did not allow additional tree
species dispersed evenly across the project, however, the goals of .0295 were
met. If considering the circumstances noted above in Comment #8 at the time
of planting, and as indicated by Rule .0295, additional trees are needed for
compliance, ETP will perform supplemental planting uniformly across the site
with 2 or 3 additional species (depending on availability), likely cherry bark oak,
another climax hard mast species, and river birch or yellow poplar, both wind-
blown seeding species.
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'
Updated figures showing "No Credit Areas >200' " are attached.
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.
The ditch above UT2 was not included for any nutrient offset credits because
the boundary survey performed by the land surveyor revealed an error in the
GIS mapping provided in the BPDP document and relevant figures, thus
removing this area from the easement and project.
14. Table 2 (project # is incorrect, see comment #2).
The Project # has been revised to Project # 2019-1261 V2
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.
1117 Peachtree Walk NE, STE 126, Atlanta, GA 30309 1 404-596.8004 1 EcoTerra.cOm

ecolerraA
Table 2 will be revised and submitted on 11x17 paper with future submittals.
16. Appendix 2 is not necessary to include in the AsBuilt Report. This information is
only necessary with the submittal of the BPDP.
Appendix 2 data will be removed from future As -Built Report submittals.
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.
The As -Built Survey will be revised and submitted on 11x17 paper with future
submittals.
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.
Regards,
Ted Griffith
1117 Peachtree Walk NE, STE 126, Atlanta, GA 30309 1 404.596.8004 EcoTerra.com

250 125 0
Feet
Legend
250
Property Boundary
F_
Riparian Buffer Restoration (0-50') UT 1 Ditch
0 Non -Credit Area
Nutrient Offset (51-200') UT 1 Ditch
_ UT 1 Stream
Riparian Buffer Restoration (0-100') UT 1 Stream
_ UT 1 Ditch
Nutrient Offset (101-200') UT 1 Stream
UT 2 Stream
Riparian Buffer Restoration (0-100') UT 2 Stream
Unbuffered Ditch Credit Removal
—
Nutrient Offset (101-200') UT 2 Stream
Q Conservation Easement 18.3 acres X Culvert Removal
*0
4150-
ec
Figure 2 Project Component/Asset Map
Kittrell Hill Nutrient Offset & Riparian Buffer Mitigation Bank
Baseline Monitoring Report (MY 0)
Neuse 03020203
Pitt County, North Carolina
September 2020
2016 NC OneMap Aerial

Note- Vegetation Plot photos are from the origin
of the vegetation plot. The origin is located in the
southwest corner of each plot.
1,7 k
16 Pp 12 Pp 14
Pp 10 2
11 1
Pp 9 15 Pp 15 Pp 1
13
Pp 8 Pp 11
12 14
10 � 3
Pp 16
4
Origin Latitude/Longitude (Decimal Degrees)
Plot Number Y Coordinate XCoordinate
Pp 7 9 Pp 17 ` 5 1 35.61278051-77.54167172
2 35.61293295-77.54228007
Pp 3 3 35.61236395-77.54309817
4 35.61171611-77.54356579
-
Pp 6 V 5 35.61138423-77.54453178
6 6 35.61059089-77.54476964
7 7 35.61044404-77.54526965
8 35.61082033-77.54556637
Pp 5 9 35.61129253-77.54545579
10 35.6120444-77.54535981
11 35.61278604 77.54495721
�• 12 35.61249992-77.54498904
13 35.61252301-77.54466279
14 35.61215726-77.54454754
300 150 0 300 15 35.61258453-77.54343206
16 35.61307725-77.54321039
Feet 17 35.61342085-77.54254375
Legend
Vegetation Plot (N=17) Conservation Easement 18.3 acres Riparian Buffer Restoration (0-100') UT 1 Stream
+ Photo Points 0 Non -Credit Area Nutrient Offset (101-200') UT 1 Stream
Property Boundary i is Unbuffered Ditch Credit Removal 27Riparian Buffer Restoration (0-100') UT 2 Stream
_ UT 1 (Stream) Riparian Buffer Restoration (0-50') UT 1 Ditch Nutrient Offset (101-200') UT 2 Stream
_ UT 1 (Ditch) Nutrient Offset (51-200') UT 1 Ditch
UT 2 (Stream)
a - j C
Figure 3 Monitoring Plan View Map
Kittrell Hill Nutrient Offset & Riparian Buffer Mitigation Bank
Baseline Monitoring Report (MY 0) N
�, Neuse 03020203
Pitt County, North Carolina
eco terra. September 2020
2016 NC OneMap Aerial
IA