20130436 Ver 1_BPDP Comments_20130224

Merritt, Katie
From:
Merritt, Katie
Sent:
Wednesday, February 27, 2013 1:05 PM
To:
'David Knowles'
Cc:
Becker email
Subject:
Ballahack BPDP Comments
Good Afternoon David,
I received the Ballahack Bank Parcel Development Package (BPDP) on February 21, 2013. 1 have finalized my review of
this BPDP and have the following comments:
• Please use the term "Proposed" throughout the entire document when referencing the Umbrella Mitigation
Banking Instrument (UMBI), since we don't actually one at this time
• Section 2.3: please add a statement to this section that describes what type of impact, if any, this Bank will have
on the endangered species.
• Section 3.0:
o Table 3 (and applicable text in this section): please remove the following trees from your proposed
planting list: White Oak, Water Oak, Willow Oak. While these character trees do provide nutrient
removal, they will most likely naturally colonize on their own without the help of additional plantings
since they are located on adjacent parcels close to the purposed mitigation.
o DWQ used to require at least 1 shrub species for nutrient offset mitigation in the form of riparian
restoration. However, it has been since determined, that shrubs are not required unless the bank
chooses to do so. If the bank chooses to plant shrubs, such as the Buttonbush, they will have to meet
the success criteria for shrubs as well as the success criteria for trees (two separate success criterion).
The success criteria for shrubs shall be stated in the BPDP as "Shrubs should be planted at density
sgfficient to provide 1,200 shrubs per acre ". Please note that the Bank may plant buttonbush
voluntarily, knowing that this shrub will not be counted towards the 320 planted trees per acre success
criteria, if they choose. If so, please make a statement regarding the Bank Sponsor's decision to do that.
0 4t" paragraph:
■ Success criteria is defined differently in the proposed Tar -Pam UMBI (per the template) as
compared to your Neuse UMBI signed in 2008. Therefore, please state that the success criteria
"shall be defined as a survival of an average density of 320 planted trees per acre after five
years" and delete any text that suggests any different. Please correct this throughout the
document.
• In addition, please delete the following sentence from your BPDP as DWQ does not agree to
those terms: "FeF the r of R,t„r; ~ , planted speeies must of
30 peFeeRt of the tree �
�o�ci cci�c vi ci�c cicc aen5lty -In the menitering p ets.
0 5t" paragraph: Please delete the following sentence, because the UMBI determines what shall be
measured in the success criteria: "Ne quaRtitative ~ t.- .,f ti ^r " assemblages will be F e
• Section 4.0:
• 2nd paragraph: Please add the following statement: First monitoring data will not be collected less than
five (5) months after completion of initial planting.
• Please state that at least one of the four monitoring plots will be located within the riparian buffer
• Section 6.0: Please remove all text following the second sentence of this section. All of this text is within your
proposed Tar -Pam UMBI. However, you may leave the last sentence of this paragraph if you choose to do so,
but it also is stated within your proposed UMBI.
• Appendix B: there is no "Draft Conservation Easement" as the content of this Appendix suggests. GES
submitted a "Draft Conservation Easement Boundary'. Please revise.

Thank you for your submittal of the Ballahack BPDP. Please resubmit the BPDP addressing the comments
above and mail to my attention. If you have any questions regarding the comments above, please don't hesitate
to give me a call.
Thank you,
Katie
Katie Merritt
Environmental Senior Compliance Specialist & Nutrient Offset Bank Coordinator
Wetlands & Stormwater Branch
NCDENR- Division of Water Quality
Work: 919- 807 -6371
Website: http: / /Portal.ncdenr.org /web /wq /swp /ws /webscape
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