20180181 Ver 3_As-Built Report - DWR Review_20210528

From: Merritt, Katie
To: Cara Conder
Subject: As -Built Report - DWR Review
Date: Friday, May 28, 2021 12:34:00 PM
Hey Cara,
I have finalized my review of the Scarborough As -Built Report for the Buffer Mitigation & Nutrient
Offset Plan received in February 2021. The following comments are provided below for your
response:
1. The document you reference as a Bank Parcel Development Plan (BPDP) in the report
should be referred to as a "Buffer Mitigation & Nutrient Offset Plan (Plan)" to comply with
your MBI & Plan.
Action Required: Commit to making this correction on all future document submittals for
this site. You do not have to resubmit the As -Built Report with those corrections made.
2. As noted in the credit release letter for Task 2, two additional vegetation plots need to be
added to the 101-200' width nutrient offset credit areas adjacent to UT1-R3.
Action Required: 1) Provide a map showing where you anticipate installing two plots, 2)
Describe the shape of the plot (size should be comparable to other plots onsite), 3) Identify if
the plots are permanent or rotating , 4) Commit to monitoring these two plots beginning in
MY1, Fall 2021.
3. Section 2.0 —There is no language describing the amount of buffer credits that could be
converted from nutrient offset credits on the site. The MBI (Section IX) & Plan (Section 7.0)
suggested this was an option and identified how many credits could be converted. With the
As -Built survey, the amount of convertible nutrient offset credits to buffer credits has
changed.
Action Required: Add language to this section to reference Item E of Section IX of the MBI
and indicate the maximum amount of nutrient offset acres that could be converted to buffer
upon DWR approval. (it should be 10.19 acres and only within the 0-100' Zone which would
come to 443,876.40 ft2)
4. The Table 1 in section 2.0 includes Total Acreage Totals out to the thousandths decimal
place.
Action Required: Round those two acreage totals (15.952 & 15.569) for buffer and nutrient
offset to the hundredths, to comply with the Plan. Those totals should be 15.95 for Buffer &
15.57 for nutrient offset.
5. Table 1 needs the mitigation credits modified based on comment #4.
Action required: Change Buffer credits to 694,782 ft2 & Nutrient Offset to 35,390.92 Ibs-N.
Change "Mitigation" to "Credits" in Table 1 for Nutrient Offset. We do not use the term
"Mitigation" to describe nutrient offsets. I apologize for missing this in the review of the
Plan
6. Sheet #1 of the Survey has an error in the total ft2 of Nutrient Offset (0-50'). The survey
shows this area to be 3,317,439.92 ft2. It should be 317,439.92 ft2.
Action Required: No action required since this error was not noted on the rest of the survey
and appears to just be a typo on Sheet 1. The totals on the other sheets are correct. It is
recommend that WLS notify the surveyor of the error.
7. Vegetation Assessment Data Sheets — All looks good.

Please provide a written response to all items 1-6 above as instructed. Submit your response using
the Online Form submittal process. Once that response is received, DWR can proceed with the
issuance of a credit release pending all other items have been received.
Thank you for your patience,
Katie
Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
401 & Buffer Permitting Unit
North Carolina Department of Environmental Quality
Office: 919-707-3637
Work Cell: 919-500-0683
Website: http://portal.ncdenr.org/web/wq/401bufferpermitting
512 N. Salisbury Street, Raleigh, NC 27620
1617 Mail Service Center, Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.