20080511 Ver 1_Staff Comments_20120312

Merritt, Katie
From: Merritt, Katie
Sent: Thursday, March 15, 2012 11:59 AM
To: 'D'
Cc: 'jrbecker'; Lia Myott
Subject: Follow up -La Grange & CLCBB
David,
Thank you again for allowing me to come see the LaGrange site yesterday. It was a pleasure talking with you. As you
and I discussed at the site visit yesterday, I'm sending you a follow -up email of the items we discussed. You said that it
was okay to submit these items electronically via email...
1) Lia will get comments from me soon regarding the BPDP for LaGrange. Once she incorporates those comments
into the BPDP, she will need to send me a final for approval. The BPDP is the guidance document that you must
follow as close as possible when planting the site. Following all plantings and when the site is considered,
"done ", GES needs to submit an As -Built report. This report will include all of the things done on the site and
should resemble what was approved in the BPDP as close as possible. Any deviation from the approved BPDP
needs to be addressed in the As -Built report (any deviation to the BPDP should have received prior approval
from me in some fashion). After the As -Built report is approved, your next step is to submit Year 1 Monitoring
Report by December 31. The first monitoring report should be submitted no sooner than approximate 5 -6
months after the entire site has been planted. This site will start with "Year 1" even though you have planted
portions of the site in Dec 2010 and 2011. DWQ had not approved the plantings or approved a BPDP for this site
when planting were done. Therefore, when the BPDP is approved, this will mark when Year 1 begins for the
site.
2) We determined that there is no "L -10a" on the CLCBB and it doesn't exist. What we agreed on, was that GES is
interested in "L -10b" being a nutrient offset site on the CLCBB bank.
Submit a BPDP for L -10b (previously known as A -4). Please see the letter I gave you onsite about how to
proceed with getting approval for L -10b. L -10 b has never been formally approved for nutrient offset.
Therefore, approval is required before any credits can be generated from the site. The following items will need
to be submitted for L -10b and in this order: BPDP, As -Built Report, Year 1 Monitoring Report.
3) 1 recommended to you that it would be best for L -8 on the CLCBB parcel to be completely deleted from the
overall CLCBB bank. I recommended that a BPDP be submitted for L -8 so that we can treat L -8 as a separate
bank parcel. L -8 had failed success criteria after 5 years and it cannot yield nutrient and buffer credits until it
has been replanted and gone through another 5 years of monitoring. The site was so dense with trees that
DWQ recommended replanting the entire site if GES wanted that site to yield nutrient and buffer credits at
some point. Because of the substantial replanting needed on L -8, DWQ will need to see 5 years of monitoring
accomplished on the site and for success to be met by year 5 in order for the site to yield all of the potential
credits. DWQ does not require that you proceed with any particular process. This is just highly recommended.
If GES determines to move forward as recommended above for L -8, the following items must be submitted to
DWQ for approval: BPDP for initial approval of the planting plan, then the As -Built report (when site has been
completely planted), then, Year 1 Monitoring Report by December 31 (at least 5 -6 months after site was
completely planted).
4) We talked about the parcels on the CLCBB bank that aren't currently under conservation easements but were
approved for nutrient and /or buffer in the original CLCBB BPDP. I told you that as a conservation easement is
placed on each parcel, those parcels that get conservation easements will result in a credit release for the
amount of credits earned for those parcels.

Please feel free to contact me at any time via phone if there are any questions. We certainly talked about lots of things
yesterday O
Sincerely,
Katie
Katie Merritt
Environmental Compliance Specialist & Nutrient Offset Coordinator
Wetlands & Stormwater Branch
Division of Water Quality
Work: 919- 807 -6371
Website: http: / /Portal.ncdenr.org /web /wq /swp /ws /webscape
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