20170919 Ver 1_Buffer MBI-email review_20201120

From: Merritt, Katie
To: Bradley Breslow
Subject: Walnut Wood MBI review
Date: Friday, November 20, 2020 3:09:00 PM
Hey Brad (not sure who the PM is for this one),
Upon initial review of the Walnut Wood MBI, I have determined the MBI is substantially lacking in
many areas and needs to be completely rewritten and resubmitted for DWR review. It is not written
according to the MBI templates. There is insufficient referencing of nutrient offset within the MBI,
but the Buffer Plan clearly shows there is nutrient offset being requested in addition to buffer
credit. It appears the MBI was mostly written just for Riparian Buffer Credits. The MBI also does not
follow the Jordan Lake template for nutrient offset either. Additionally, there are many ponds onsite
that will be breached and planted for credits according to the draft Mit Plan. The Credit Release
schedule proposed in the MBI should resemble the schedule on other sites where ponds are being
used for credit. Please see Stone Creek & DogTown for RES examples.
I also recommend RES use a combination of the Cloud & Banner Jordan MBI as well as the most
recently posted Long Pond MBI (see recent Public Notice email for document link) as guidance for
the Walnut Wood MBI.
Once the MBI has been resubmitted and is more complete, DWR will initiate the review of the MBI.
Please forward to the proper PM if necessary.
Thank you for your patience,
Katie