20081473 Ver 4_WAyne Co BPDP Edits_20120503

Research Triangle Park NC
Post Oflloe Box 14006
Reseadr Triangle Park
North Carolina 27709
2905 Meridian Parkway
Durham North Carolina 27713
800. 733 -6646
919 287 4262
919-3612269 Fax
EcolEngineering D M-
A division of The John R McAdams Company Inc
MA
Y ,� 2012
April 27 2012
Ms Katie Merritt
Environmental Compliance Specialist & Nutrient Offset Coordinator
Wetlands & Stormwater Branch
NCDENR DWQ
Archdale Budding
512 N Salisbury Street
Raleigh North Carolina 27603
Re Wayne County Development Alliance Bank Parcel (DWQ # 2008
1473v4)
Bank Parcel Development Package
Response to Bank Parcel Development Package Comments
EBX -11050
Following your March 22, 2012 e mail please find our responses to your
review comments on the project listed above Our response comments are in
bold
Section 10
A) Change, Proposed stream buffer restoration activities to
Proposed riparian restoration activities — this is because the term
riparian can be used to include both nutrient and buffer restoration
areas, while using the term buffer only refers to the riparian zone
within the first 50 feet from ajurisdictional stream
JRM Response The document has been revised to distinguish
between Neuse buffer and riparian nutrient offset credit
B) When referencing "stream buffer restoration' stream buffer
mitigation riparian buffer restoration etc please identify if those
areas are ` Neuse buffers which are the areas within the first 50 feet
of a jurisdictional stream/waters of the State or if they are dust
riparian restoration areas Please make this edit throughout the entire
document
JRM Response The document has been revised to distinguish
between Neuse buffer and riparian nutrient offset credit
C) Please refer to the riparian zone adjacent to non jurisdictional
stream features and ditches as riparian and not `buffer' to identify
only nutrient offset restoration since the Neuse buffer rules would not
apply to non jurisdictional streams Please make this edit throughout
the entire document
JRM Response The document has been revised to distinguish
between Neuse buffer and riparian nutrient offset credit
"mecwngrCom I Design Services Focused On Client Success

EcoEngineering
A division of The John R McAdams Company Inc
Ms Katie Merritt
Response to Bank Parcel Development Package Comments
April 27 2012
Wayne County Development Alliance Bank Parcel
Page 2 of 6
D) Paragraph 3 Please add the Bank s DWQ project number as a
reference That number is DWQ# 2008 1473 Please also add that it
was entered into by the parties on 11/10/08
JRM Response The title page of the document has been
revised providing the DWQ project number
2 Section 2 2
Please add a paragraph in this section that describes the adjacent land
use (land adjacent to the Bank Parcel) If it s agriculture please
describe the types of crops that have been cultivated This request has
come recently from NRCS
JRM Response The document has been revised as follows
The Bank Parcel is currently within active agricultural activities
and currently contains corn fields which have been recently
harvested Land located adjacent to the Bank Parcel is comprised
of active agricultural fields which have historically cultivated corn
and soybean crops
Section 2 5
Please add more detail as to whether the leaking has stopped and if
there are any known soil and water contamination issues from the
leaks that have affected the streams /ditches on your bank parcel
JRM Response The document has been revised as follows
Soil and water contamination was noted with the four leaking
underground storage tank listings and all incidences have been
closed out with removal and remedial actions conducted for each
tank. The Bank Parcel is separated from the four listed leaking
underground storage tanks by adjacent topographic gradients
which grade away from the Bank Parcel It is believed the four
listed leaking underground storage tanks are not impairments to
the Bank Parcel due to separate topographic gradients, and the
close out and remedial actions associated with each tank.
4 Section 2 6
Please note how restoration efforts will affect the
floodplain/floodway
JRM Response The document has been revised
appropriately

EcoEngineering
A division of The John R McAdams Company Inc
Ms Katie Merritt
Response to Bank Parcel Development Package Comments
April 27 2012
Wayne County Development Alliance Bank Parcel
Page 3 of 6
5 Section 4 0
A) If planting is anticipated for Spring 2012 DWQ does not support
monitoring prior to the Fall 2012 Please revise the text to support
this comment
JRM Response The document has been revised as follows
For Phase I, planting is anticipated to occur in the Spring of 2012,
therefore, the riparian restoration will be monitored the following
growing season, protected to be the Fall of 2012
B) Please add similar text as the following the first monitoring data
for Phase I and Phase II shall not be measured less than 5 months
after site work is completed (if site work isn t completed until the
Fall 2012 the first annual monitoring report shall be submitted in
Fall 2013)
JRM Response The document has been revised as follows
For both phases, first monitoring data shall not be measured less
than 5 months after completion of initial planting
C) If Phase I and Phase I1 are planted at different intervals you may
have to prepare 2 monitoring reports one representing Phase I and
one representing Phase II Or you may have one monitoring report
representing both phases but that monitoring report data will have to
be collected after site work is completed on both phases and shall be
collected no less than 5 months after all site work is completed If
EBX chooses to specify any of this in the BPDP that is their choice
However this comment will be documented and future reviews will
be based on these comments to the BPDP
JRM Response Comment has been noted
D) Why is there a `target density of 320 trees and shrubs per acre9
According to NCEEP s Guidelines for Riparian Buffer Restoration
Trees should be planted at a density sufficient to provide 320 trees
per acre at maturity To achieve this density approximately 436
(10x10 feet spacing) to 681 (8x8 feet spacing) trees per acre should be
planted initially Shrubs should be planted at a density sufficient to
provide 1200 shrubs per acre
JRM Response The document has been revised as follows
Within Neuse buffer and riparian nutrient offset restoration areas,
success criteria will be based on the survival of a minimum density
of 320 trees per acre after five (5) years of monitoring

EcoEngineering
A division of The John R McAdams Company Inc
Ms Katie Merritt
Response to Bank Parcel Development Package Comments
April 27 2012
Wayne County Development Alliance Bank Parcel
Page 4 of 6
E) Please ensure that the target density on this parcel is consistent
with the above guidance It shall be the same for both neuse buffer
restoration and nutrient offset areas
JRM Response See comment to 5 (D) above
F) Please specify how success criteria is measured Recommended
text would be the following Success criteria will be based on the
survival of a minimum of 320 planted trees per acre following five
years of monitoring
JRM Response See comment to 5 (D) above
6 Section 5
The RBMBI (Item 25) states that the `financial assurances shall retire
upon submittal of the as built report for each site' Please specify in
this section that a second method of financial assurance will be
provided to cover the monitoring and maintenance of the mitigation
site for at period of 5 years You may also add the following
statement which is consistent with what we are allowing for another
bank parcel under this same RBMBI (Rudolf) the performance
bond/monitoring bond may be lowered, based on the adjusted cost to
finish the monitoring on a case by case basis and only with DWQ
approval of the monitoring reports Your RBMBI does not allow or
disallow for this adjustment therefore DWQ does not have a problem
offering this for this bank parcel
JRM Response The document has been revised as follows
EBX Neuse I, LLC agrees to provide financial assurances for this
Bank Parcel in accordance with the terms and conditions of the
EBX Neuse Riparian Buffer Umbrella Mitigation Bank (Bank)
made and entered into by EBX Neuse I, LLC (EBX), acting as the
Bank Sponsor, and the North Carolina Department of
Environment and Natural Resources - Division of Water Quality
(DWQ)
After completion of the restoration /construction, a separate
Performance/Maintenance Bond will be secured for 100% of the
estimated cost to implement the monitoring and maintenance
plan but not less than $100,00000 The
Performance/Maintenance Bond shall be in effect for a minimum
of five years, and until DWQ has released all mitigation credits to
the Bank Sponsor Upon DWQ approval, this may be lowered
each year based on the adjusted cost to complete the monitoring

EcoEngineering
A division of The John R McAdams Company Inc
Ms Katie Merritt
Response to Bank Parcel Development Package Comments
April 27 2012
Wayne County Development Alliance Bank Parcel
Page 5 of 6
7 Section 6 0
A) Please use 2 273 02 in the calculation instead of 2 273 Even
though it s a small difference I will be asking Banks to use the
number exactly as it is indicated in the rules when submitting all new
BPDPs for approval
JRM Response See comment to 7 (B) below
B) Please replace the last sentence of the paragraph with the following
text the exact amount of nutrient offset mitigation potential
(currently based on 2 273 02 lbs of nitrogen/ac of riparian restoration)
will be included in the As Built Report and on the corresponding
credit ledgers
JRM Response The document has been revised as follows
The exact amount of nutrient offset mitigation potential
(currently based on 2,273 02 lbs of nitrogen /ac of riparian buffer
restoration) will be included in the As -Built report and on the
corresponding Bank Ledger
C) Second paragraph Please modify the following text Phase I
consists of Parcel Number 2598449002 and will provide
approximately 32 57 acres of riparian restoration Phase I will contain
approximately 102 acres (44 431 ft2) of riparian buffer credits
and
JRM Response The document has been revised as follows
Phase I consists of Parcel Number 2598449002 and will provide
approximately 32 59 acres of riparian restoration Phase 1 will
contain approximately 102 acres (44,431 ft2) of Neuse buffer
credits and approximately 3157 acres of riparian nutrient offset
(71,759 241 pounds of nitrogen nutrient offset credit)
D) Second paragraph Phase II consists of Parcel Numbers and will
provide approximately 37 06 acres of riparian restoration Phase II
will contain approximately 5 45 acres (237,402 ft2) of riparian buffer
credits and
JRM Response The document has been revised as follows
Phase II consists of Parcel Numbers 2598632250 and 2598543857
and will provide approximately 37 06 acres of riparian restoration
Phase II will contain approximately 5 45 acres (237,402 ft2) of
Neuse buffer credits and approximately 3161 acres of riparian
nutrient offset (71,850162 pounds of nitrogen nutrient offset
credit)

EcoEngineering
A division of The John R McAdams Company Inc
Ms Katie Merritt
Response to Bank Parcel Development Package Comments
April 27 2012
Wayne County Development Alliance Bank Parcel
Page 6 of 6
Figure 2
A) DWQ determined that Feature 03 as identified on the onsite stream
determination was a jurisdictional stream and subject to the Neuse
Buffer rules Figure 2 of the BPDP shows that Feature 03 is a ditch
Please revise the figure to be consistent with the onsrte stream
determination that was made by DWQ (make this a blue stream on
your map and call it a stream rather than a ditch)
JRM Response Figure 2 has been revised
B) A portion of the purposed nutrient offset on this site is located in
HUC 03020202 (near Feature 04) DWQ needs to discuss the nutrient
offset credit for this portion with you before approving the BPDP
JRM Response The document has been revised within
Section 1 first paragraph and Section 3 second paragraph to
reference the adjacent HUC, the Neuse River Buffer
Determination, and which jurisdictional streams are applicable to
the Neuse River Riparian Buffer Rules
Consideration of this response is greatly appreciated A revised report is
provided If you should have any questions or require additional information,
please do not hesitate to contact me at [phone]
Sincerely
EcoEngmeenng
A division of The John R McAdams Company Inc
g
Buchholz REM P
Environmental Scientist
cc Tommy Cousins Environmental Banc & Exchange LLC
Enclosures