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Home My WebLink About20201664 Ver 2_BPDP-DWR Comment Summary_20210713Summary of Comments on Bells Bridge Draft BPDP_dwrEdits.pdf Page: 2 Number: 1 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:14:05 AM Number: 2 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 10:14:56 AM correct the DWR ID# to be 2020-1664v2 Page: 3 Number: 1 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:17:10 AM Page: 4 Number: 1 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:27:29 AM ;,,Number: 2 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 10:19:14 AM Photos provided in the Plan are not timestamped, therefore I cannot confirm these photos represent "existing conditions". Number: 3 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 10:19:35 AM Change reference to "Project Credit Table", which will be consistent with the UMBI terms. 0Number: 4 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 10:21:13 AM This table is actually labeled "Table 1". I prefer it be labeled Table 7a and included under the "Tables" reference and inserted within Section 7.0. Number: 5 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 10:19:53 AM There are many Appendices. It is preferred that these appendices be labeled (A, B, C, etc) so as to make it easy for the reviewer to find them as they are referenced in the document. Once a label has been added for the appendices, please update all your references in the document from saying "Attachments" or "Appendices" to the individual label you assign to it. Page: 5 y„+Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 10:24:54 AM i know you prefer to name this UMBI after the landowner's last name. However, since you have another Bank project called "White Farm", it is misleading that this UMBI is for two sites and not just the White Farm site. Please rename the UMBI to avoid confusion. JNumber: 2 Author: kymerritt proposed rc,Number: 3 Author: kymerritt no date needed, remove. Number: 4 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:25:24 AM Subject: Inserted Text Date: 7/13/2021 10:22:32 AM Subject: Sticky Note Date: 7/13/2021 10:25:29 AM Number: 5 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:25:05 AM which will be ,oNumber: 6 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 10:27:04 AM I don't understand the need to reference rule .0731 here. There is nothing about Planning, designing or selling credits from a Bank noted in this rule. The only rules that pertain to this BPDP are 0703 and 0295 Number: 7 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:26:03 AM --_ro- Number: 8 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:46:39 AM This is a little confusing. I think you mean, "the land within the Site encompasses approximately 45.35 acres of riparian buffers and other riparian areas that are actively utilized for row crop production". If so, please change sentence to read as suggested. You use the term "project", not "Parcel or Site" as referenced in the first paragraph of Section 1.0. So in reading this, I didn't know if you were describing the land areas within the Site's parcel boundaries or if you meant to describe the areas within and around it. Number: 9 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:40:02 AM Number: 10 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:40:02 AM Number: 11 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:37:46 AM a direct Number: 12 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:39:08 AM s Number: 13 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:39:51 AM Deep Creek, which a tributary to the Tar River. Number: 14 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:40:01 AM Number: 15 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:44:08 AM to mitigate for authorized impacts along with stormwater and wasterwater permitting requirements, respectively ]Number: 16 Author: kymerritt Subject: Inserted Text generate Riparian Buffer Credits and Nutrient Offset Credits *Number: 17 Author: kymerritt Subject: Sticky Note this paragraph should be moved to section 2.2. ]Number: 18 Author: kymerritt stream Date: 7/13/2021 10:40:53 AM Date: 7/13/2021 10:49:50 AM Subject: Inserted Text Date: 7/13/2021 10:44:42 AM Number: 19 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:45:23 AM and a site viability assessment for buffer mitigation potential and nutrient offset on... *Number: 20 Author: kymerritt Subject: Sticky Note specify which appendix, give it a label Date: 7/13/2021 10:46:35 AM Comments from page 5 continued on next page Page: 6 JNumber: 1 Riparian Number: 2 Author: kymerritt adjacent to ditches and streams id Number: 3 Author: kymerritt March 2021 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:47:18 AM Subject: Inserted Text Date: 7/13/2021 10:47:27 AM Subject: Inserted Text Date: 7/13/2021 10:47:49 AM Number: 4 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:49:06 AM QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 10:55:10 AM Most of this is already noted on page 1. I prefer you move that paragraph to this section and continue with, "A summary of...". this will remove the redundancy. Page: 7 Number: 1 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 10:49:06 AM Page: 8 Number: 1 Author: kymerritt Subject: Sticky Note add the date here that these photos were taken. Number: 2 Date: 7/13/2021 10:53:05 AM Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:52:40 AM n Page: 9 �JNumber: 1 by sjNumber: 2 UMBI Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:58:55 AM Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:55:47 AM r ;)Number: 3 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 10:58:31 AM The template, except under special circumstances, only requires the long term steward transfer be prior to the year 4 monitoring (see UMBI language). If RS wants to be held to another standard, that's fine, but DWR will not require it for this site. I think this may be carry-over from using another approved BPDP for a template. Number: 4 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:55:58 AM a Number: 5 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:56:02 AM Number: 6 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:11:49 AM add specifics to the minimum and maximum widths you will have on the site; add a note that no riparian areas less than 50' will be used for credit. QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:14:13 PM Add that there is a soil path along Feature Ea & Eb that will be removed. What efforts will RS implement to remove it and prep that path area for planting? 4„iNumber: 8 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:07:41 AM DWR recommends RS commit to performing soil testing to determine how best to prepare the soil for planting and success. Additionally, with this site being used for ag for such a long period of time, it is always recommended that the Sponsor implement disking or ripping to break up compact soils. Why has RS not suggested these activities for parcel preparation? Number: 9 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:58:59 AM 1 and Number: 10 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 10:59:05 AM row Number: 11 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:09:05 AM 200' wide Number: 12 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:23:36 AM of streams and hydrologically connected ditches. r--y�Number: 13 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:11:23 AM Commit to ensuring that stems will be well mixed before planting to ensure diversity of bare roots across the planted area. Page: 10 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:23:11 AM It is preferred that you identify only what you intend to plant as your PRIMARY selection. Then, tell me which species would be your SECONDARY selection if your primary selection isn't available. If 10 species of trees are shown in the table, DWR expects 10 species to be planted. If anticipating to plant less than 10 species, you need to at least indicate the minimum # of species RS will plant. The standard in rule is 4, but hopefully RS is intending to plant more than the minimum to avoid the risk of some species not thriving/surviving. Just commit to a minimum so I can hold that accountable in the AsBuilt Report. IF RS ends up needed to plant different species than what is in this list, they need to consult with DWR first to prevent an issue at AsBuilt review. Number: 2 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:15:57 AM add a column to Table 7 for "Canopy/SubCanopy" and complete table accordingly. This is reviewed to ensure there is a good mixture of canopy and subcanopy species. QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:24:56 AM DWR requests that RS consider including pollinator rich seedlings in with their temporary and permanent seeding to enhance the riparian areas' ecological uplift. This request is a comment being provided by DWR in all buffer planting plans at this time. ----_r�Number: 4 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:19:49 AM I don't usually see Pecan trees in planting plans. Why is this specie chosen? QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:13:25 AM what is the anticipated spacing of stems? *Number: 6 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:26:14 AM include the type of Seed Mix; I need to confirm that there will be annual and perennial seed, and that the seed will not be non-native, or invasive. QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 11:35:24 AM RS should take measures to ensure that plots are diverse (have 4 species represented as much as possible) and where a species does not represent more than 50% of the plot. All plots need to be representative of the planted diversity and density surrounding the plot and will be evaluated by DWR during the onsite AsBuilt Walkthru to ensure these criteria are met. All DWR comments provided on planting plan & monitoring are being provided under the following Rule reference 15A NCAC 02B .0295 (n)(2-4). -Number: 8 T. area Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:25:18 AM Number: 9 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 11:32:17 AM Number: 10 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 11:37:50 AM Number: 11 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:33:15 AM and will be representative of the Riparian Buffer Credit areas and the Nutrient Offset Credit areas. Number: 12 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:37:56 AM planted area Number: 13 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:38:14 AM s Number: 14 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:36:04 AM Qualitative and quantitative Page: 11 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:23:53 PM There needs to be a section on "Parcel Protection & Easement Boundaries". Make sure to include language that details what will be used to mark the easement boundary, and that the easement boundaries will include placards identifying the contact information for the easement holder. Clarify that the boundaries will be clearly marked prior to the Task 2 site visit by DWR. Language should also be added that a complete and detailed survey of the easement boundaries will be included in the As -Built Report. the outer easement boundary is not straight along Feature A, which will increase the risk of encroachment from farming activities. RS should either straighten the boundary or implement additional boundary marker standards to reduce the risk for encroachment. What does RS intend to do to acknowledge this concern? T,iNumber: 2 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:39:22 AM Bells Bridge J Number: 3 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:42:13 AM RS will secure all financial assurances according to the approved UMBI. No bond shall be less than $150,000 to cover costs of construction and no less than $100,000 initially, to cover monitoring expenses. Page: 12 I Number: 1 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:54:01 AM Credits Number: 2 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 12:00:14 PM Number: 3 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:54:18 AM efforts Number: 4 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:00:11 PM of Number: 5 adjacent to Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:00:28 PM Number: 6 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:54:50 AM to a maximum width of Number: 7 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:55:07 AM s well as areas of Number: 8 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 11:55:37 AM Number: 9 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 12:00:46 PM Number: 10 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:55:25 AM (restoration and preservation credits) Number: 11 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 12:00:58 PM Number: 12 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:57:38 AM Available Riparian Buffer Credits that are generated within widths of 100' can be converted and transferred into Nutrient Offset Credits only upon written DWR approval. RS must request all conversions and transfers in writing and submit to DWR for review and approval prior to modifying credits on credit ledgers. Number: 13 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:57:52 AM efforts Number: 14 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 12:01:47 PM Number: 15 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:01:21 PM to a maximum width of Number: 16 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:01:29 PM widths Number: 17 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:01:37 PM adjacent to Number: 18 Author: kymerritt Subject: Cross -Out Date: 7/13/2021 11:58:29 AM Number: 19 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:02:15 PM T. per the approved UMBI. Number: 20 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:59:42 AM Project Credit Table Number: 21 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:08:18 PM Need to indicate how many credit ledgers will be provided for this site to account for the credits being generated. You will need 1 for Nitrogen, 1 for Phosp., 1 for Buffer Restoration, 1 for Buffer Preservation (a total of 4). Number: 22 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 11:59:56 AM Comments from page 12 continued on next page provided in Table 7a Number: 23 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:09:31 PM remove Table 8. This credit release will be in the UMBI, it will be the same credit release as for White Farms. See UMBI comments for edits made to the Credit Release schedule. Page: 15 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:10:27 PM Correct this box to be "Nutrient Offset and Buffer Mitigation Bank Parcel". Page: 16 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:12:07 PM add "and Riparian Buffer Credits" Page: 20 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:16:32 PM is there an Access Rd that will be provided to these sites? Page: 21 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:22:28 PM the outer easement boundary is not straight, which will increase the risk of encroachment from farming activities. RS may want to consider modifying the easement to reduce that risk. WNumber: 2 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:19:57 PM show where the R.O.W is located Number: 3 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:18:45 PM for Riparian Buffer Credits Number: 4 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:18:49 PM for Riparian Buffer Credits Number: 5 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:18:53 PM for Riparian Buffer Credits Number: 6 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:19:14 PM for Nutrient Offset Credits Page: 22 Number: 1 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:18:10 PM for Riparian Buffer Credits Number: 2 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:18:17 PM for Riparian Buffer Credits Number: 3 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:18:29 PM for Riparian Buffer Credits Number: 4 Author: kymerritt Subject: Inserted Text Date: 7/13/2021 12:17:41 PM for Nutrient Offset Credits Page: 23 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:24:27 PM photos are required to be date stamped, these are not. When were these taken? Page: 25 r Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:25:41 PM this table is titled "Table 1", but the BPDP references a different Table as Table "1". DWR requests this table be in Section 7.0 and recommends it be referenced as Table 7a. —oNumber: 2 Author: kymerritt Subject: Sticky Note Date: 7/13/2021 12:26:43 PM DWR will provide comments on this table, if any are needed, using the working excel file instead of the PDF provided here.