Loading...
HomeMy WebLinkAbout20190159 Ver 1_DWR Comment Summary-Buffer Plan review_20201120�i'aO�ak ll'(YlS r �w� ' YQVI�� '}��ah u,nc� bb�_ Oag6 �- �� . brl U-�> Mitigation Plan Checklist for Riparian Restoration Mitigation Sites -created 7/15/13 �WR Stream Determination iYDWR Site Viability Letter - rnJSSkYN , L? Site Location u 4e,*' Directions including Lat & Long le�,- 8-digit HUC &/or 14 digit (if applicable acid. LO�hL e-a_Wdt _� ,cT— County SLO•LP U� �(An o EMC approved Soil map, Topo and Aerial Maps Sub -watershed where applicable Project Name: , r-aLu _ Reviewed By: DWR# dab[CJ--b� Date I I I tqo existing Site Conditions w/ photos Er' -`All proposed mitigation activities, including a brief summary of stream and/or wetland mitigation w/ -- e d AS WzAUd 41 addi-�vcL! u�kto ✓uro , % .�1. a detailed planting plan obkx Q1'C-t4� f4 - Monitoring & Maintenance Plan - t&&q Yl9-Qc. d - �&C)owgw_Qj'OCA -14 o, +- 01�& WNM do"Asw d blav Will bt , ^f-5- Financial Assurance (if applicable) Associated buffer and/or nutrient offset credit talcs, which shall include credit generation, service area, etc. c� �tixh�Qh E +aw , ►r -td e cA JAS 4-0 CA rnp�y v-tb3, nLtd cWnckpl . h0pl-RSA,04 credit Determination Table/Map ,- VWds QA l+S 4e cbtl4. UJ` p`i b3 ❑ 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. G Vic?} ❑ Verification that the site can be constructed on land if it is an archaeological site; list of all permits that will be required and obtained prior to constructing the mitigation site for nutrient offset and/or buffer mitigation (e.g. Sediment and Erosion Control Plan from Division of Land Resources, NCG010000 Stormwater Permit from NCDWQ, 404 permit from the Army Corps of Engineers and corresponding 401 Water Quality Certification from NCDWQ). (4ot 1(4bq i N SC Summary of Comments on Strawberry Hill Buffer Plan_DWRedits.pdf Page: 9 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/20/2020 11:41:57 AM since DIMS has requested DWR to review the Plan under both 0295 (Buffer Mitigation) & under 0703 (Nutrient Offset), additional rule references and edits will be necessary within the document. I have provided comments where appropriate. add rule 15A NCAC 02B .0703 "Nutrient Offset Credit Trading" Rule effective April 1, 2020 Page: 10 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/20/2020 11:40:29 AM Add another Figure titled "Nutrient Offset Conceptual Map" and add clarification that this Figure only represents areas that are viable for nutrient offsets if ever DMS converted the RBCs. This areas shown in the Figure as being viable for NOC should match the asset table in Al for what is deemed convertible to Nutrient Offset. ONumber: 2Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:50:12 PM Buffer Mitigation Credits Number: 3Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:49:13 PM There is no stream determination correspondence in A2. Only the Slte Viability Letter. The stream determination letter is found in Appendix H. Correct reference. �,)Number:4Author: kymerritt Subject: Sticky Note Date: 11/20/2020 1:16:02 PM The Site Viability Letter is missing Page 4 Number: 5Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:49:35 PM Letter NRINumber: 6Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:49:31 PM Site Page: 11 Number: 1 Author: kymerritt Subject: Cross -Out Date: 11/19/2020 4:48:00 PM Number: 2Author: kymerritt Subject: Cross -Out Date: 11/19/20204:48:53 PM Number: 3Author: fifty foot riparian Number: 4Author: channels Number: 5Author: Neuse Number: 6Author: protection Inserted Text Date: 11 /19/2020 4:48:24 PM Inserted Text Date: 11/19/2020 4:49:03 PM Inserted Text Date: 11 /19/2020 4:48:42 PM Inserted Text Date: 11 /19/2020 4:48:38 PM QNumber: 7Author: kymerritt Subject: Sticky Note Date: 11/19/20204:49:44 PM i think you mean to reference Appendix H. The Stream Determination letter issued by DWR is in Appendix H, not A2. Page: 12 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/19/2020 4:51:27 PM no language is provided acknowledging that the service area for these credits is limited to the Neuse 01 excluding the Falls Lake Watershed. I have recommended language to insert into this paragraph/ Number: 2Author: kymerritt Subject: Inserted Text Date: 11/19/20204:50:15 PM , excluding the Falls Lake Watershed Number: 3Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:02:39 PM Add, "Not within the Falls Lake Watershed' �Number:4Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:01:52 PM add, "with flexibility to convert to Nutrient Offset if needed" Page: 15 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/19/2020 4:53:56 PM With the presence of loblolly pine, eastern baccharis and sweetgum in the clear cut areas, is there a need to do a thinning of these species before project implementation? *)Number: 2Author: kymerritt Subject: Sticky Note Date: 11/19/20204:55:52 PM There is a statement indicating that the riparian areas within the clear cut area have failed to regenerate trees. What is being proposed within these areas that will promote healthy and successful stem establishment? Page: 20 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/19/2020 4:56:42 PM This should not include "Enhancement' but rather "Preservation" ONumber: 2Author: kymerritt Subject: Cross -Out Date: 11/20/2020 12:39:40 PM Number: 3Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:46:49 PM clarify the meaning here by "restoration activities". Do you mean after "stream restoration activities" are completed or after "riparian restoration activities" are completed? *)Number: 4Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:42:05 PM the location where the agricultural buildings are being demolished will likely require grading, soil amendments and ripping to give stems and herbaceous vegetation the best chance at survival and vigor. Therefore, specifically call out this area & incllude a plan to specifically address this area as part of the riparian restoration. Include a plot in this area as well. Number: 5Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:42:44 PM it is greatly appreciated to see pollinator friendly species included in your seeding plan. thanks. Page: 21 4+1 Number: 1 Author: kymerritt Subject: Cross -Out Date: 11/19/2020 5:04:37 PM QNumber: 2Author: kymerritt Subject: Sticky Note Date: 11/19/2020 5:05:36 PM correct rule reference to be 15A NCAC 02B .0295 (1)(2)(3) _)Number: 3Author: kymerritt Subject: Sticky Note Date: 11/19/2020 5:06:24 PM identify the untreated flow referenced here along JH1-A on Figure 4. i do not see where it is. Number: 4Author: kymerritt Subject: Sticky Note Date: 11/20/2020 11:50:24 AM riparian restoration adjacent to ditches or streams with less than a 50' riparian zone will not be viable to generate nutrient offset. Since DMS has requested that DWR review this Plan under both 0295 & 0703, please identify any and all areas where a riparian width is less than 50' and show those areas on the Table in Al and on the Figures that correspond to the asset table. If no areas are less than 50', please confirm that within the text of this plan. Number: SAuthor: kymerritt Subject: Inserted Text Date: 11/20/2020 12:05:25 PM site Page: 22 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/19/2020 5:12:34 PM In order to get buffer credit along ditches, compliance of all of (o)(8) must be achieved, including the following: "The perpetual conservation easement... shall provide language that prohibits future maintenance of the ditch" Explain how this requirement will be met. Number: 2Author: kymerritt Subject: Cross -Out Date: 11/19/2020 5:07:47 PM Number: 3Author: kymerritt Subject: Inserted Text Date: 11/19/2020 5:07:58 PM t [—,]Number:4Author: kymerritt Subject: Inserted Text Date: 11/19/2020 5:07:29 PM According the Site Viability Letter issued by DWR (Appendix A2) ,Number: 5Author: kymerritt Subject: Sticky Note Date: 11/19/2020 5:12:54 PM add the total square feet of that deduction. Page: 23 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/19/2020 5:15:00 PM are any areas along ditches or streams less than 50'. If so, DWR needs to see those areas represented in the Appendix Al (Buffer Credit Calculation) as well as in the corresponding figures. This is only necessary if DWR is requested to review the Plan under to generate Nutrient Offsets. Otherwise, this comment can be omitted. FilNumber: 2Author: kymerritt Subject: Inserted Text Date: 11/19/2020 5:15:27 PM and M1-M2 ,vNumber: 3Author: kymerritt Subject: Sticky Note Date: 11/19/2020 5:20:15 PM In order to approve alternative planting plans where softwoods are proposed (like Bald Cypress), i need to know that the Provider is planting this species in areas where site wetness is prevalent. The rule gives me two scenarios where I can allow alternative planting plans: 1) Site Wetness, and 2) availability. Therefore, on the Planting Sheets, indicate where Bald Cypress will be planted. DWR recommends the Provider stick to planting this species along the clear cut riparian areas along JH1 B where wetlands have already been identified and represented in Figure 2. Page: 24 ,Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/19/2020 5:21:48 PM all these trees are Canopy trees. It is best to include some sub -canopy species in the mix. Explain how the Provider intends to meet this expectation. Page: 25 Number: 1 Author: kymerritt Subject: Cross -Out Date: 11/19/2020 5:22:00 PM Number: 2Author: kymerritt Subject: Inserted Text Date: 11/19/2020 5:22:03 PM total _Number: 3Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:52:20 PM What is your anticipated planting density to ensure you meet the 260 by Year 5? Page: 26 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/19/2020 5:22:23 PM Reference Appendix K Number. 2Author: kymerritt Subject: Sticky Note Date: 11/19/2020 5:24:04 PM correct this rule reference. the Neuse Buffer Protection Rule is now referenced as 15A NCAC 02B 0714 as of June 15, 2020 Page: 31 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/20/2020 11:51:53 AM This is more of a Vicinity Map, even though titled "Service Area". Modify this figure to include only the Neuse 01 service area excluding the Falls Watershed. You will need to Zoom out to show the entire service area provided by this Project. Since DMs has requested DWR to review this Plan under both 0295 and 0703, please add "Nutrient Offset & Buffer Mitigation Service Area to the Title. These two credit types share the same service area for this Plan. Page: 34 Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:36:13 PM there was a statement in the text regarding non -diffused flow at the upper reach of JH1. Can you show where that is? Number: 2Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:29:15 PM In the legend, call out the areas that not receiving credit due to clear cut in buffer. ,vNumber: 3Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:27:57 PM area that may be less than 50'? *)Number:4Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:34:47 PM for this particular site and plan, it is recommended that the widths 0-50, 51-100, 101-200 be outlined and shown around all features, even if the width outline extends beyond the CE boundary. This will help DWR ensure compliance with width requirements for buffer credit & nutrient offset potential. i recommend a thin outline (color coded) to represent each width. You may include this information in a separate figure if that is preferred. *)Number: 5Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:28:15 PM area that may be less than 50'? *)Number: 6Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:30:31 PM *)Number: 7Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:29:26 PM Number: 8Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:35:06 PM Riparian Number: 9Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:35:10 PM Riparian Number: 10 Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:35:15 PM Riparian Number: 11 Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:35:19 PM Riparian *)Number: 12 Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:37:48 PM i don't see this category represented on this figure. Please point out where this width is represented for Preservation. Number: 13 Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:35:30 PM Riparian Page: 37 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:38:S4 PM move a plot to the area where the buildings will be demolished. Number: 2Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:39:11 PM Riparian Number: 3Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:39:15 PM Riparian [,—]Number:4Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:39:18 PM Riparian Number: SAuthor: kymerritt Subject: Inserted Text Date: 11/20/2020 12:39:24 PM Riparian Number: 6Author: kymerritt Subject: Inserted Text Date: 11/20/2020 12:39:28 PM Riparian Page: 39 ,Number: 1 Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:58:07 PM add the following statement to this table somewhere appropriate "Credit conversions must be calculated using the guidance provided in the Clarified Procedures for Calculating Buffer Mitigation Credits and Nutrient Offset Credits letter issued by the DWR in November 2020" and located at https:Hfiles.nc.gov/ncdeq/Water%20Quality/Surface%20Water% 20Protection/401/Mitigation/Issues --- Resolutions-Ver-1.0- buffer- mitigation -nutrient-offset.pdf If DIMS prefers this letter be referenced by including the PDF in an Appendix to this Buffer Plan instead of included as a link on this table, that will be acceptable as well. Number: 2Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:00:04 PM if DIMS is expecting to have the flexiblity to convert to nutrient offset as indicated by this table, please add text below the table that speaks to that directly. Using a text box may be the easiest way to add that Text. Number: 3Author: kymerritt Subject: Sticky Note Date: 11/20/2020 11:53:51 AM Provide a figure to support this table where it says "YES" for convertible to Nutrient Offset. This table needs to be replaced with the newest version on our website. Number: 4Author: kymerritt Subject: Sticky Note Date: 11/20/2020 11:54:48 AM all of these need to be checked "YES" instead of N/A Number: 5Author: kymerritt Subject: Sticky Note Date: 11/20/2020 11:54:29 AM where a particular feature and width is viable for NOC (check viability letter), please check "YES" in this column. Number: 6Author: kymerritt Subject: Sticky Note Date: 11/20/2020 11:58:15 AM add a row to show the features receiving deductions for lack of Diffused flow . Title that Feature Name "Diffused Flow Deductions (JH4, JH2, etc). then, enter the Total Area for the deductions. Leave the "Total Creditable Area" as -0- and Check "No" for both columns for Buffer & Nutrient Offset QNumber: 7Author: kymerritt Subject: Sticky Note Date: 11/20/2020 12:01:01 PM if you run out of room to fit this table on a legible sheet size, then you can ask DMS (Jeremiah) to remove some rows where they aren't needed.