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Home My WebLink About20080511 Ver 2_DWR BPDP Comments_20120316Strickland, Bev From: Merritt, Katie Sent: Friday, March 16, 2012 12:43 PM To: Strickland, Bev Subject: FW: La Grange BPDP Comments Good Afternoon BevO Will you please place the email below into laserfische for 2008- 0511v2 and name the document, "BPDP Comments ". Please print this email off for my records and place in my box. I really appreciate it! Have a great weekend! Sincerely, I<atie From: Merritt, Katie Sent: Friday, March 16, 2012 12:37 PM To: Lia Myott Cc: 'jrbecker'; David Knowles Subject: La Grange BPDP Comments Hey Lia, I have reviewed the draft La Grange BPDP for GES and have the following comments, recommendations, and requests: Please add the following two subsections to Section 2.0: Environmental Issues (use data from Environmental Data Resources, Inc. (EDR) regarding the potential for onsite or nearby sources of contamination. If none, please state none -this subsection comes after "Threatened and Endangered Species "); FEMA Flood plain /Floodway Mapping (this section should come after "Environmental Issues ". Please add a section on "Financial Assurance" as required per the UMBI for GES (Item A of Section III) after the section titled "Monitoring & Maintenance Plan ". Please use the following recommended language: Section 5.0 Financial Assurance Lanuae: Green Environmental Services, LLC will provide a performance bond or Letter of Credit to ensure completion of all mitigation work. The amount of the performance bond or Letter of Credit shall be efficient to cover all costs associated with establishing the site for its proposed mitigation. Upon approval of the subject BPDP, Green Environmental Services, LLC will provide financial assurance in the form of a monitoring bond or Letter of Credit in the amount of at least $100,000 to ensure that adequate funds are available for completion of the maintenance and monitoring outlined in the BPDP under Section 4.0. • Update the Table of Contents Page as needed • Rename Section 3.0 to be, "Proposed Nutrient Offset & Riparian Buffer Restoration Plan" • Rename Section 5.0 to be, "Nutrient Offset and Riparian Buffer Mitigation Potential" • BPDP Content: Section 1.0 a) 1s' paragraph: 1. Revise the UMBI name to be just as it is written in the UMBI: "Greene Environmental Services Neuse River Basin Riparian Buffer and Nutrient Offset Umbrella Bank. 2. Please identify the correct longitude and latitude for the bank parcel. As currently written, the lat and long are identical. b) 3" paragraph: Please be consistent with significant figures throughout the document. If the bank parcel is 3.39 acres, please continue to use 3 significant figures when describing the size. You may want to use 4 significant figures instead (which you chose to do in Section 5.0 when you cited the acreage to be 3.387). This is crucial when identifying the exact credit yield. Please revise the following text: "Meuse riparian buffer" unless you are trying to describe the entire project. If you are describing the entire project, please use the following terminology throughout the entire document when describing areas of restoration /planting: When referencing "buffer mitigation ", "riparian zone /area ", "buffer restoration" etc., where Riparian Buffer Credits are proposed to be generated, please add the text "Neuse" buffer mitigation or "Neuse" riparian zone, or "Neuse" buffer restoration. For all other areas proposed for generating Nutrient Offset Credits, please reference those as "riparian" or "nutrient offset area" instead of "buffer ". Please edit the entire document to ensure this is clarified throughout. (one exception: if DWQ determined the feature to be applicable to the Neuse Buffer rules and GES decides to use the riparian buffer zones for nutrient offset instead of buffer restoration, please specify this in the BPDP under the appropriate section so that the mitigation efforts and areas are understood by all parties) c) See comment above on UMBI name d) 4t" paragraph: 1. Please remove Eric Kulz and Lia Gilleski and just use, "DWQ staff" 2. Section 2.0: a) NRCS is now wanting us to document adjacent land use for our nutrient offset projects. Please describe the type the current land use of the areas adjacent to the project boundary (i.e. Agriculture for peanuts, sweet potatoes, corn, etc). Section 3.0: rename section to be "Nutrient Offset & Riparian Buffer Restoration Plan a) DWQ recommends a combination of both trees and shrubs for restoration to establish a sub - canopy layer. Please add one or two shrub species that will be planted on the site. The future As -Built report will need to report that one or two shrub species were planted on the site. b) Paragraph 5 1. Please define all "buffers" as Neuse buffer throughout this section and the document (see comment #1(b)(2) above) 2. Please explain the reason you have included the sentence that speaks to certain volunteers being counted at a maximum of 20% towards success criteria. Is this because the UMBI only says that a minimum of 30% of lap nted stems have to be counted towards success and GES would rather be more stringent than the UMBI and say that actually, GES is going to require that a minimum of 80% of the planted stems will be counted towards success while only a maximum of 20% of certain volunteers will be counted towards success? If so, please make that determination specific in this BPDP. DWQ can only require that you monitor according to the protocol established and agreed upon in the UMBI. While this more stringent counting method is soley up to GES since it's not defined in the UMBI, is more preferred by DWQ than the less stringent requirement in the UMBi. If this is in fact how GES is interpreting their monitoring procedure, please indicate that as I have suggested above. c) Paragraph 6, 1s' sentence: please change "a buffer restoration site indicates" to "the restoration /mitigation site indicates" 4. Section 4.0, second to last sentence: Please add that "target density' is "target acreage density' as specified in the UMBI 5. Section 5.0: rename section to be " "Nutrient Offset and Riparian Buffer Mitigation Potential" a) Use consistent sig. figures as previously requested in above comments. b) Identify approximate Riparian Buffer Credits in both acres and square feet- my calculation of 0.87 acres of RBCs differ from the calculation in the BPDP of 37,939.7 ft'. My calculation shows 0.87 acres of RBC is 37,897.2 ft2. Please recheck your calculations. Additionally, please show the exact significant figures (not to exceed four significant figures) that you use in your calculation. This may be where the discrepancy is. c) Identify approximate Nutrient Offset Credits in both acres and pounds (only Ibs is shown here). please revise the number from 2,273 Ibs -N /acre to be 2,273.02 Ibs -N /acre. Please revise all calculations to include this number. d) Please edit the second to last sentence to read the following: "...for nutrient offset credits which are generated from 51 -200 feet out from the Neuse buffer ". e) Please add the following paragraphs for clarity to this section: Riparian Buffer Credit may be achieved through mitigation of the Neuse riparian buffer, as defined in 15A NCAC 02B .0233. Nutrient Offset Credit may be achieved through restoration of the riparian area adjacent to surface water features. Surface water features do not have to be intermittent or perennial, nor do they have to be depicted on a USGS, NRCS, or EMC approved map. The width of the restoration area begins at the most landward limit of the top of bank or the rooted herbaceous vegetation and extends landward a maximum distance of 200 feet on all sides of the surface water. The mitigation accomplished in the DWQ Neuse buffer, as defined in 15A NCAC 02B .0233 and per 15A NCAC 02B .0242 may be used for either Riparian Buffer Credit or Nutrient Offset Credit, but not both f) Please edit the last sentence to read the following: Each credit ledger shall be submitted on a separate 8 ' /2in X llin spreadsheet with legible font style and font size. At a minimum and unless otherwise requested by DWQ, credit ledgers shall contain the following information: Bank Details listed in a header: (1) name of the approved banking instrument as it appears on the instrument document, (2) sponsor name, (3) bank parcel name as it appears on the BPDP, (4) DWQ project number for the BPDP, (5) date the ledger was last updated, 6) total credits released to date. Credit Details Table with the following for each credit sale: (1) date of credit sale, (2) purchaser name, (3) project name and corresponding HUC, (4) name of local government requiring Nutrient Offset Credits or Riparian Buffer Credits for this project, (4) credits released by DWQ to the Bank listed in pounds for Nutrient Offset Credits and in square feet for Riparian Buffer Credits, (5) credits debited /sold from bank listed in pounds for Nutrient Offset Credits and in square feet for Riparian Buffer Credits, (6) available credits listed in pounds and acres for Nutrient Offset Credits and in square feet and acres for Riparian Buffer Credits • BPDP Figures • Figure 4 needs to be the soil survey map prepared by the NRCS of USDA. Please submit the requested soil survey for Wavne Countv and identify the site on this survey. • Figure 5 — please identifi- the proposed nutrient offset area on the survey map excerpt (hatching is fine). Please edit the calculations based on the comments on the BPDP above. These calculations and acreage areas need to be the same on all documents submitted in the BPDP. That includes all tables and figures, and in the conservation easement. Please ensure that all acreages are identical on all documents submitted. At this time, there is a discrepancy on the Figure 5, the draft easement survey, and in the BPDP on the actual approximate acreage of the buffer and nutrient site as Nvell as the easement boundaiv. Please call me directly if you have any questions or concerns regarding the comments /requests above. If you Nvould like, there is a draft BPDP on public notice at this time that you can use for comparison. That document can be found at this link: PUBLIC NOTICE -Click Here Thank you and have a Nvonderful Nveekend! 3 � Katie Katie Merritt Environmental Compliance Specialist & Nutrient Offset Coordinator Wetlands &StonnwatorBranch Division of Water Quality Work: 919'807'6371 Email correspondence toondƒho/n this address issul.�/ect to the North Coro0no Public Records Lom/ond/noybe disclosed to third purties unless the content is exempt L�y stcitute or other regulution. APlease consider the environment before printing this email.