20191692 Ver 4_BPDP for PN_20210928

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ID# * 20191692
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Katie Merritt
Version* 4
Initial Review Completed Date D9124/2021
Mitigation Project Submittal - 9/24/2021
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r Stream r Wetlands Pr Buffer rJ Nutrient Offset
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Project Contact Information
Contact Name:*
Raymond Holz
Project Information
ID#:*
20191692
Existing IGVt
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County:
[' DMS r' Mitigation Bank
Raleigh Farm Phase A
Wake
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Mitigation Plans
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rholz@ restorationsystems.com
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2019-1692 V4_Phase A_Raleigh
44.87MB
Farm_BPDP_2021-09-20_.pdf
Rease upload only one RIF of the corrplete file that needs to be submitted...
Raymond Holz

Bank Parcel Development Package
RALEIGH FARM — PHASE A
NUTRIENT ❑FFSET AND BUFFER MITIGATION BANK PARCEL
Neuse River Basin
DWR ID#: 2019-1692 V4
Bank Parcel Sponsor
Restoration Systems, LLC
PAC: Barrett Jenkins
1101 Haynes Street, Suite 211
Raleigh, NC 27604
[e-mail]
919.755.949❑
September 20, 2021

Table of Contents
1.0 Introduction 1
1.1 Bank Sponsor 2
1.2 Project Location & Fee -Simple Ownership 2
1.3 ❑irections to Parcel from Raleigh: ...... ............... ..................... ........... ..................... ....... 3
1.4 Parcel Overview 3
1.5 Historic Land Use............... ..................... ........... ................. ............... ......................... ....... 5
2.0 Project Area - Current Conditions 6
2.1 Physiography 6
2.2 Soils 6
2.3 Existing Vegetative Communities 6
2.4 Parcel Design and Implementation Constraints 7
2.4.1 Threatened and Endangered Species 9
2.4.2 Cultural Resources 9
3.0 Restoration Plan 9
3.1 Project Schedule 11
3.2 Permitting 11
3.3 Planting Plan 12
3.3.1 Permanent Seed Mix12
3.4 Parcel Protection & Easement Boundaries 12
3.5 As -Built Report 13
4.0 Monitoring and Maintenance Plan 13
4.1 Monitoring Protocol & Success Criteria 13
4.2 Parcel Maintenance13
4.3 Maintenance Areas 14
4.4 Long Term Management Plan 14
5.0 Financial Assurance 14
6.0 Mitigation Potential 15
7.0 References 16
Tables
Table 1. Bank Parcel Easement Tracts 1
Table 2. Bank Parcel Fee Simple ❑wnership (Project Parcels) 2
Table 3. Phase A Project Features Descriptions 3
Table 4. Timeline of Land Use 5
Table 5. Parcel Soils 6
Table 6. Reference Forest Ecosystem 7
Table 7. Documented and Recorded Parcel Constraints & Design Avoidance 8
Table 8. Restoration Plan Activities 10
Table 9. Project Schedule 11
Table 10. Summary of Temporary Impacts ,,..11
Table 11. Proposed Hardwood Bare Root Planting Plan by Species 12
Table 12. NRRRF Groundwater Monitoring Locations, Within the Site 14
Table 13. Credit Table - Raleigh Farm Bank Parcel - Phase A, 2019-1692v4, Project Credits 17
Raleigh Farm - Phase A Bank Parcel ❑evelopment Plan (2019.1692 V4) Table of Contents
Neuse River Basin 8-Digit HUC: 03020201

Appendices
Appendix A: Figures & Photos
Figure 1— Parcel Location and Service Area
Figure 2 -- Parcel Easements and Features
Figure 3 — USGS Topography
Figure 4 —NRCS Soil Survey
Figure 5 — Current Conditions
Figure 6 — NRRRF & Proposed Project Footprint
Figure 7 — Biosoild Application Fields
Figure 8 — Restoration Plan
Figure 9 — Credit Determinations (Figures 9A-9D)
Figure 10— Monitoring Plan
Existing Conditions Photos
Appendix B: DWR Correspondence
Appendix C: USDA, NRCS Web Soil Survey Report
Appendix D: EDR Report
Appendix E: USFWS Report
Appendix F: NC NHP and NC SHPO Correspondence
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4) Table of Contents
Neuse River Basin 8-Digit HUC: 03020201

Bank Parcel Development Package
Raleigh Farm Phase A— Nutrient Offset and Buffer Mitigation Bank Parcel
Wake County, NC— Neuse River Basin
1.0 Introduction
The Raleigh Farm Phase A Nutrient Offset and Buffer Mitigation Bank Parcel ("Parcel" or "Site") is
proposed under the terms and conditions of the Raleigh Farm Riparian Buffer and Nutrient Offset
Umbrella Mitigation Banking Instrument, made and entered into on , 20J by Restoration
Systems, LLC (RS), acting as Bank Sponsor (Sponsor), and the North Carolina Department of Environmental
Quality (NCDEQ), Division of Water Resources (DWR). The Parcel shall be planned and designed according
to the MBI, the Consolidated Buffer Mitigation Rule 15A NCAC 02B .0295, which became effective on
November 1, 2015, and the Nutrient Offset Credit Trading Rule 15A NCAC 02B .0703.
Located in Wake County, the Parcel encompasses 77.07 acres of agricultural land and forests. The primary
purpose of the Parcel is to provide Riparian Buffer Credit (RBC) and Nutrient Offset Credits (NOC) for
stormwater and wastewater permitting requirements within the United States Geological Survey (USGS)
Cataloging Unit 03020201 — RBC and NOC are available for offsets within the Cataloging Unit, excluding
the Falls Lake Watershed (Figure 1, Appendix A). The Site will restore 45.027 acres and preserve 22.856
acres of riparian area, measured perpendicularly 200 feet off the top of bank, from eight (8) unnamed
tributaries and one (1) in -line pond (Site Features)(Figure 2-5, Appendix A). An additional 9.187 acres will
be permanently protected within the conservation easement but will not generate credit. The 9.187 acres
consist of areas beyond 200-feet from Site Features, the footprint of Site Features, and non -credited
access/maintenance areas within the conservation easement.
The Site is situated on two tracts of land (Project Parcels), owned by the City of Raleigh (City). Project
Parcels are part of the City's Neuse River Resource Recovery Facility (NRRRF) and managed by the City of
Raleigh Public Utilities Department, also known as Raleigh Water.
Site features drain directly to Beddingfield Creek, a direct tributary to the Neuse River. Proposed Parcel
easement tracts will provide permanent protection to restored and preserved riparian buffers -- Table 1
details the Site's Easement Areas, with individual and total acreages.
Table 1. Bank Parcel Easement Tracts
Phase
Easement
Tract No.
Acreage
Total Phase
Acreage
1
2.14
2
8.62
3
24.64
Phase A
4
3.34
77.07
5
28.88
6
3.32
7
6.13
The City began residual biosolid application on portions of the Project Parcels in 1980 and currently has
1,439 acres permitted for land application of biosolids on the larger farm. Land application of biosolids
has occurred on the parcels since acquired by the City except for the 10-year moratorium between 2003
and 2013. The Site, and proposed easement areas, are located away from fixed infrastructure associated
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4) Page 1 of 17
Neuse River Basin 8-Digit HUC: 03020201

with the application of biosolids (i.e., application piping and wellheads). In addition to biosolid
applications, the property is managed for hay and row crop production. A review of aerial photography
indicates agricultural areas of the property were converted from forest to agricultural before 1993, with
no significant changes to land use since.
Phase A will have its own credit release schedule for milestones met in accordance with the Raleigh Farm
Umbrella Mitigation Banking Instrument for Nutrient Offset and Riparian Buffer Credits (UMBE).
DWR representatives conducted onsite determinations for the applicability and suitability of Site Features
on June 2-3, 2020. Respectively, a Stream Determination and Site Viability letter were provided by DWR
an August 17, 2020, and September 24, 2020 — both letters are provided in Appendix B.
RS will secure a conservation easement to preserve the Site in perpetuity, restricting any development
that would impair or interfere with the Site's conservation values. City allowance of a conservation
easement is further described in Section 3.4 (Parcel Protection & Easement Boundaries) of this document.
Per the referenced Umbrella Mitigation Banking Instrument (UMBI) above, RS will arrange the transfer of
the conservation easement and its interests in perpetuity to a qualified holder under NC. General Statute
("GS") 121-34 et seq. and 170(h) of the Internal Revenue Code before the approval of the As -Built Report
by DWR. The holder shall be a land trust or stewardship program accredited by the Land Trust
Accreditation Commission and/or approved by DWR. A land trust must be certified under 501(c) (3) of the
Internal Revenue Code and must have the qualifications outlined in GS 105-130.24 and GS 105-151.12.
1.1 Bank Sponsor
The Site is proposed by Restoration Systems, LLC (RS). Information for RS is provided below;
Restoration Systems, LLC
Attention: Barrett Jenkins
1101 Haynes Street, Suite 211
Raleigh, NC 27604
bj e n ki ns@ re sto rat io nsyste m s.co m
919.755.9490
1.2 Project Location & Fee -Simple Ownership
The Parcel is located approximately three miles northwest of Clayton, five miles east of Garner, and seven
miles southeast of Raleigh in Wake County, NC. The City is the current fee -simple owner of tracts
associated with the Bank Parcel. The Parcel is within the Neuse River Basin 14-digit U5G5 Cataloging Unit
03020201100030 of the Middle Atlantic Coastal Plain (North Carolina Division of Water Resources [DWR]
Sub -basin Number 03-04-02) (Figure 1, Appendix A). Fee simple ownership and Project Parcel details are
provided in Table 2.
Table 2. Bank Parcel Fee Simple Ownership (Project Parcels)
Owner Name
D.B/Pg.
NC PIN#
Acreage
City of Raleigh
9885/449
1751047213
1462.55
City of Raleigh
11304/106
1740999788
44.34
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4) Page 2 of 17
Neuse River Basin 8-Digit HUC: 03020201

1.3 Directions to Parcel from Raleigh:
Head South on N. Blount St.
Turn left onto Martin Luther King Jr Blvd. (1.1 mi)
Turn right onto Rock Quarry Rd. (0.2 mi)
Keep right to stay on Rock Quarry Rd. (7.4 mi)
Turn left onto Old Baucom Rd. (1.8 mi)
Latitude, Longitude: 35.698851°,-78.494698°
1.4 Parcel Overview
The Site's footprint totals 77.07 acres over two tracts of land. Current land use is a mixture of managed
fields for biosolid applications from the City`s NRRRF, row crop agriculture, and unmanaged hardwood
forests (Figure 2, Appendix A). The Site will provide riparian area restoration and preservation along 14
Project Features that drain directly to Bedingfield Creek, a direct tributary to the Neuse River.
Site Features are devoid of woody vegetation outside of forested areas due to historic and active
agricultural practices. Managed features are maintained (mowed/brush hogged) to keep woody
vegetation from establishing.
DWR representative conducted onsite stream determinations and site viability assessments for mitigation
potential on June 2-3, 2020. A summary of Parcel Features by classification is provided in Tables 3 and
graphically depicted in Figures 2-5 of Appendix A.
Table 3. Phase A Project Features Descriptions
Feature
Classification
onsite
'Subject
to Buffer
Rule
7Riparian Land uses
adjacent to Feature (0-200')
Buffer
Credit
Viable
a Nutrient
Offset Viable
1A
Ephemeral
No
Mostly non forested agricultural
fields with some mature forest
2.8 Yes
Yes (non -
forested areas
only)
Mostly non forested agricultural
fields with some mature forest
'Yes
Yes (non -
forested areas
only}
2A
Ephemeral
No
Combination of non -forested
agricultural fields and mature
forest
2'8 Yes
Yes (non-
forested areas
only)
26
Stream
Yes
Combination of non -forested
agricultural fields and mature
forest
2•6Yes
Yes (non-
forested areas
only)
2C
Main
Tributary 2
Stream
Yes
Combination of non -forested
agricultural fields and mature
forest
A gas line is proposed to impact
stream; existing utilities are
present (Appendix A, Figures)
2 Yes
Yes (non -
forested
areas only)
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201
Page 3 of 17

Table 3. Phase A Project Features Descriptions (Continued)
Feature
Classification
onsite
15uhfect
to Buffer
Rule
Riparian Land uses
adjacent to Feature (0-200')
Buffer Credit
Viable
3 Nutrient
Offset Viable
Pond 2
in -line pond
i' n
Combination of non -forested
agricultural fields and mature
forest
Permitted BMP is located along
left side of pond and shall not be
included in planting efforts or
areas for credit
2Yes
Yes (non -
forested areas
only)
3A
(ends at
confluence of
2C/Main Trio)
Ephemeral
fro
Mostly non -forested agricultural
fields with mature forest at the
top of reach.
2 Yes
Yes (non -
forested areas
only)
4A
Ephemeral
No
Mature forest
2'8Yes
No
4B
(ends at
confluence of
5A)
Stream
Ye
Combination of non -forested
agricultural fields and mature
forest
2 Yes
Yes (non -
forested areas
only)
5A
(continues to
confluence of
2C/Main Trip)
Stream
Yes
Combination of non -forested
agricultural fields and mature
forest
A gas line is proposed to impact
stream; existing utilities are
present (Appendix A, Figures)
z Yes
Yes (non -
forested areas
only)
GA
Ephemeral
No
Combination of non -forested
agricultural fields and mature
forest
'A Yes
Yes (non -
forested areas
only)
6B
Stream
Ve'.
Combination of non -forested
agricultural fields and mature
forest
A gas line is proposed to impact
stream; existing utilities are
present (Appendix A, Figures)
2 Yes
Yes (non-
forested areas
only)
7A
Not Present
No
N/A
N/A
N/A
7B
at DWR flag
Stream
Yea
Non -forested agricultural
fields
Yes
Yes
8A
Stream
Yes
Combination of non -forested
agricultural fields and mature
forest
'Yes
Yes (non-
forested areas
only)
Table 3 footnotes below
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201
Page 4 of 17

Table 3 footnotes:
1 Subjectivity calls for the features were determined by DWR in correspondence dated August 17,
2020 using the 1:24,000 scale quadrangle topographic map prepared by USGS and the most recent
printed version of the soil survey map prepared by the NRCS.
2 The area of preservation credit within a buffer mitigation site shall comprise of no more than 25
percent (25%) of the total area of buffer mitigation per 15A NCAC 0295 (o)(5) and 15A NCAC 0295
(o)(4). Site cannot be a Preservation Only site to comply with this rule.
3 NC Division of Water Resources - Methodology and Calculations for determining Nutrient Reductions
associated with Riparian Buffer Establishment.
6 A small area of the stream has been impacted from sedimentation and riprap which needs to be
removed.
8 The area of the mitigation site on ephemeral channels shall comprise no more than 25 percent (25%)
of the total area of buffer mitigation per 15A NCAC 0213.0295 (o)(7).
* Per 2021-09-10 conversation with DWR, agricultural pond and exempt from Buffer Rule. Meeting
Notes are provided in Appendix B
1.5 Historic Land Use
City of Raleigh's Neuse River Resource Recovery Facility (NRRRF)
The City began biosolid residuals application in 1980 and currently has 1,439 acres permitted for land
application. Land application of biosolids has occurred on Site since the City's acquisition of Project Parcels
except for a 10-year moratorium between 2003 and 2013. Several areas in the Site's proposed footprint
are subject to biosolids application. Specific field boundaries and active biosolid application areas are
further detailed in Figures 6 and 7 of Appendix A. The property is currently managed for hay and row crop
production.
Table 4 details a review of the City's Parcels with aerial photography beginning in 1969.
Table 4. Timeline of Land Use
Period
Arial Photo
Date
Land Use
1969-89
02/9/1969
12/7/1989
Fragmented agricultural within forested lands, progressively more land clearing for
agricultural purposes
Early 90's
02/18/1993
Evidence of final forest to agricultural conversion
- Phase A, Features 1, 2, 3, 6, and 7 (easement areas 1, 2, and 3)
1999 _
Present
02/21/1999
01/03/2005
07J25J2010
05/19/2015
02/04/2019
Established City agricultural fields with no substantial difference observed to land
use activities.
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201
Page 5 of 17

2.0 Project Area - Current Conditions
2.1 Physiography
The Site encapsulates heavily modified headwater stream systems within the Middle Atlantic Coastal
Plain. Specifically, Ecoregion IV--45f Northern Outer Piedmont, located within the eastern portion of the
Piedmont, to the Coastal Plain Fall Line, in northern North Carolina (the transition between North
Carolina's Piedmont and Coastal Plain). This ecoregion consists of dissected irregular plains, rounded hills
and ridges, and low to moderate gradient streams with mostly cobble, gravel, and sandy substrates
(Griffith et al. 2002).
The watershed is dominated by agricultural land, fringe forests, and impervious surfaces associated with
single-family homes and roads. Surrounding area land use is primarily row -crop agriculture, with some
low -density residential housing, cattle pasture, and forested lands.
2.2 Soils
A detailed soil report for the Site was produced using the Natural Resource Conservation Service's (MRCS)
Web Soil Survey (USDA 2019)(Appendix C). Based on the custom report, the Bank Parcel contains the soil
series outlined in Table 5.
Table 5. Parcel Soils
Map Unit
Symbol
Map Unit Name
Acres in
Parcel
Percent of
Parcel
Hydric
Soil Rating
ChA
Chewacla and Wehadkee soils, 0 to 2 percent slopes,
frequently flooded
1.2
1.5%
Yes
DoB
Dothan loamy sand, 2 to 6 percent slopes
3.0
3.8%
No
HeB
Helena sandy loam, 2 to 6 percent slopes
8.8
11.4%
No
RaA
Rains sandy loam, 0 to 2 percent slopes
0.7
1.0%
Yes
RgB
Rawlings -Rion complex, 2 to 6 percent slopes
4.7
6.2%
No
RgC
Rawlings -Rion complex, 6 to 10 percent slopes
19.2
25.0%
No
RgD
Rawlings -Rion complex, 10 to 15 percent slopes
26.1
33.8%
No
WeB
Wedowee sandy loam, 2 to 6 percent slopes
2.3
3.0%
No
WeC
Wedowee sandy loam, 6 to 10 percent slopes
3.0
3.9%
No
WfB
Wedowee -Saw complex, 2 to 6 percent slopes
5.3
6.9%
No
NA
Open Water
2.87
3.5%
NA
Totals for Area of Interest
77.1
100.0%
*May contain inclusions of hydric soils
2.3 Existing Vegetative Communities
Of the Site's 77.07-acre footprint, 46.51 acres are in managed agricultural fields or biosolid application
pasture. Typical crops grown include corn and soybeans, though individual fields are often subject to other
crops like sunflowers. Pasture areas are comprised predominantly of Bermuda and fescue (Festuca sp.)
gasses. Pasture fields are cut/managed throughout the year. In general, Site Features are subject to
agricultural impacts in the upper half of each individual watershed. As the Features migrate downstream,
they typically enter disturbed fringe forests, which expand as Site Features move down valley.
Site Features drain to Beddingfield Creek before entering the Neuse River, 1.5 miles downstream. The
southern extent of the Site abuts the Clem mons Educational State Forest and other lands managed by the
Raleigh Farm - Phase A Bank Parcel Development Plan (2019-1692 V4) Page 6 of 17
Neuse River Basin 8-Digit HUC: 03020201

State of North Carolina (NHP Report Appendix F). Existing hardwood forests of these managed properties
are consistent with Piedmont mesic forests, which occur on moist portions of upland habitat, steep north -
facing slopes, lower slopes, along ravines, high sections of outer floodplains, and stream bottoms. The
most common subtypes in the Piedmont are Mesic Mixed Hardwood Forest and Basic Mesic Forest
(Schafale, M.P. and A.S. Weakley. 2012).
Given the Parcels physiography, R5 has determined a mix of Mesic Mixed Hardwood Forest (Piedmont
Subtype), and Piedmont Bottomland Forest is the most appropriate reference forest (Schafale, M.P. and
A.S. Weakley. 2012). Table 6 outlines the species included in these reference forest ecosystems.
Table 6. Reference Forest Ecosystem
Mesic Mixed Hardwood Forest (Piedmont Subtype) and Piedmont Bottomland Hardwoods
(Schafale, M.P. and A.S. Weakley. 2012)
Understory/Shrub Species
Deerberry (Vaccinium stamineurn)
Red maple (Acer rubrum)
Downy arrowwood (Viburnum rafinesquianum)
Flowering dogwood (Corpus Florida)
American strawberry bush (Euonymus americana)
American holly (Ilex opaca)
American hophornbeam (Carpinus caroliniana)
Papaw (Asimina triloba)
Southern sugar maple (Acerfloridanum)
Canopy Species
Tulip (Liriodendron tulipifera)
Loblolly pine (Pinus taeda)
American sweetgum (Liquidambarstyraciflua)
Shagbark hickory (Carya ovata)
Cherrybark oak (Quercus pagoda)
Bitternut hickory (Carya cordiformis)
Swamp chestnut oak (Quercus michauxii)
American beech (Fagus grandifolio)
American elm (Ulmus americana)
Northern red oak (Quercus rubra)
Southern hackberry (Celtis laevigata)
Red maple (Acer rubrum)
Green Ash (Froxinus pennsylvanica)
Sugar maple (Acer saccharum)
2.4 Parcel Design and Implementation Constraints
The presence of conditions or characteristics that have the potential to hinder restoration activities on
the Site were evaluated. The evaluation focused primarily on the presence of hazardous materials,
utilities, restrictive easements, rare/threatened/endangered species or critical habitats, the potential for
hydrologic trespass, and existing NRRRF infrastructure. Existing information regarding Site constraints was
acquired and reviewed, including an Environmental Records Report developed by Environmental Data
Resources Inc., which located no evidence of environmental risk associated with the Parcels (Appendix D).
A North Carolina Natural Heritage Program Report was conducted and concluded three known historic
locations within the area, but all are located outside the proposed footprint (Appendix F).
Site conditions (existing or future) that have the potential to restrict the restoration, implementation and
long-term protection of the Site were documented digitally and during the field investigation. A summary
of findings and design avoidance is detailed in Table 7 on the following page.
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4) Page 7 of 17
Neuse River Basin 8-Digit HUC: 03020201

Table 7. Documented and Recorded Parcel Constraints & Design Avoidance
Constraint
Design Avoidance
Duke Power (Formally Progress
Energy of the Carolinas, and
Carolina Power & Light Co.)
240 foot, Richmond Wake, 500
KV Overhead Transmission Line
RS reviewed subject parcels and identified recorded deeds that reference the
establishment of the easement in 1981. Subject records place the easement at 200 feet.
The Site's proposed easements are located outside of the utility easement.
Duke Energy — Piedmont
Natural Gas (PNG) Line 142
RS received a City of Raleigh -approved easement boundary from Duke Energy regarding
the future natural gas line — PNG Line 142. The Site's proposed easements are located
outside of the utility easement. Construction of the PNG Line 142 will not affect the project
nor its protected resources.
Dominion Energy's T-030 Gas
Pipeline Extension Project
(Franklin and Wake County)
DWR Project ID No. 2019-0828
V2
Beginning construction in 2020 with an expected completion date in 2021, Dominion
Energy's T-030 Gas Pipeline Extension Project will maintain a 50-foot utility easement over
Project Parcels associated with Phases A. The new easement abuts and runs parallel along
Duke Power's 200-foot overhead transmission line easement. The Sponsor accessed the
digital file of the permanent and temporary construction easements for the T-030 Gas
Pipeline. Site design avoids all temporary and permanent easements associated with the T-
030 Gas Pipeline. The Site's proposed easements are located outside the T-030 Gas
Pipeline easement (permanent and temporary).
NRRRF biosolid application &
ground water monitoring
infrastructure
A digital and physical review of active and inactive NRRRF infrastructure was completed as
part of the Site's design. NRRRF conducts surface water testing in pre -defined locations
along Site Features and within proposed conservation easements. These activities are
consistent with allowable activities of the proposed conservation easement.
Appendix B includes written confirmation outlining DWR's allowance for the City to place a
conservation easement over the subject parcels including fields currently permitted for the
application of biosolids. Areas historically used for biosolid application within the Site
footprint will be removed from the City's NPDES permit.
NRRRF existing agricultural
ponds & BMP infrastructure
Phase A — One in -line pond is located along Main Tributary 2 (Pond 2). Pond 2 has a direct
hydrological connection to downstream waters via a stabilized channel which outlets the
pond on its northern side. An existing concrete drop structure is in the southeast corner of
the pond and drains to a constructed wetland located down valley. Water that enters the
constructed wetland is filtered through the facility and outlets through a subsurface pipe.
The pipe runs underground, towards the "Main Tributary 2" Feature, and discharges into a
stable outlet before entering the feature (Figure 5 and Photos 5-7, Appendix A).
The proposed conservation easement includes all of Pond 2 and the outlet pipe for the
constructed wetland. Easement areas over these items are designated Maintenance
Easements and allow for access and maintenance. No RBC or NOC will be generated within
designated Maintenance Easements.
Dilapidated/
abandoned agricultural
infrastructure and earthen
farm roads
Dilapidated and abandoned agricultural infrastructure items are detailed in the Restoration
Plan (Section 3).
Earthen roads (farm paths) exist throughout the Site and are typically found along forest
edges — Section 3, Restoration Plan, details the removal and restoration of farm paths.
Existing culverted farm paths required to maintain hydrologic connectivity on ephemeral
channels and ditches will be identified and protected under the Conservation Easement.
Table 8 Note: All utility easements will be shown on the Conservation Easement Plat & Parcel's As -Built Survey and
sealed by a licensed surveyor of North Carolina.
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201
Page 8 of 17

2.4.1 Threatened and Endangered Species
Species with the classification of Endangered (E), Threatened (T), or officially Proposed (P) for such listing
are protected under the Endangered Species Act of 1973 (ESA), as amended (16 USC 1531 et seq.). Six
species, listed in Table 10, are federally listed within Wake County by the United States Fish and Wildlife
Service jUSFWSj (USFWS 2020) (Appendix E).
LJSFWS Federally Protected Species List
Common Name
Scientific Name
Status
Cape Fear shiner
Notropis mekistocholas
Endangered
Red -cockaded Woodpecker
Picoides borealis
Endangered
Dwarf Wedgemussel
Alasmidonta heterodon
Endangered
Tar River 5pinymussel
Parvaspino steinstansana
Endangered
Yellow lance
Elliptio steinstansana
Threatened
Michaux's sumac
Rhus michauxii
Endangered
The biological conclusion is no effect on the species listed above, and proposed mitigation activities will
result in positive benefits for these species through improved habitat and water quality.
2.4.2 Cultural Resources
The term "cultural resources" refers to prehistoric or historic archaeological sites, structures, or artifact
deposits over 50 years old. "Significant" cultural resources are those that are eligible or potentially eligible
for inclusion in the National Register of Historic Places. Evaluations of site significance are made with
reference to the eligibility criteria of the National Register (36 CFR 60).
Field visits were conducted in June 2020 to ascertain the presence of structures or features that may be
eligible for the National Register of Historic Places. No structures were found. An online search using the
North Carolina State Historic Preservation Office's (SHPO) Web GIS Service (http://gis.ncdcr.gov/hpoweb/)
and the National Register of Historic Places GIS Search
(https://www. nps.gov/maps/full.html?mapld-7ad17cc9-b808-4ff8-a2f9-a99909164466) identified zero
structures within the Parcel boundaries or within 1 mile of the Parcel (Appendix F).
3.0 Restoration Plan
The primary goals associated with the restoration of riparian areas within the Bank Parcel will focus on
improving water quality, enhancing flood attenuation, and restoring wildlife habitat. These goals will be
achieved by restoring and preserving forested riparian areas adjacent to stream channels, in -line ponds,
and ephemeral channels (Figure 8, Appendix A).
Goals will be accomplished by the following:
1. Removing nonpoint sources of pollution associated with agricultural production, including;
a. Ceasing the broadcast application of class B biosolids, fertilizer, pesticides, and other
agricultural materials into and adjacent to Parcel Features.
b. Providing a restored buffer to filter runoff from adjacent lands.
2. Reducing sedimentation within onsite and downstream receiving waters by reducing bank
erosion, vegetation maintenance, and agricultural land disturbances by ceasing agricultural and
current land use activities.
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4) Page 9 of 17
Neuse River Basin 8-Digit HUC: 03020201

3. Promoting floodwater attenuation by increasing frictional resistance of floodwaters crossing
Parcel floodplains.
4. Improving aquatic habitat by enhancing stream bed shading and natural detritus input.
5. Providing a terrestrial wildlife corridor and refuge in an area extensively disturbed by agricultural
practices.
6. Restoring and re-establishing natural community structure, habitat diversity, and functional
continuity.
7. Protecting the Parcel's riparian buffer functions and values in perpetuity.
Primary components of the Restoration Plan include:
1. Removal of dilapidated/abandoned agricultural infrastructure within forested areas where
feasible,
2. Removal of existing compacted earth roads associated with agricultural use,
3. Parcel -wide soil preparation & herbaceous vegetation treatment,
4. Riparian area restoration (replanting) extending from the top of bank (TDB) out 200' where
applicable and,
5. Parcel protection in perpetuity through a permanent conservation easement.
Table 8 details the Restoration Plan activities.
Table 8. Restoration Plan Activities
Restoration
Plan Activity
Phase Specific Actions
Herbaceous
Treatment
The City, which actively self -manages the farm operations, will treat Bermuda and fescue grasses
within the Parcel ahead of planting efforts. Treatment will consist of a broadcast application using
Roundup Custom (Glyphosate) at a rate of 3% and a surfactant of AgriDex at a rate of 1%, per acre,
mixed with water.
Removal of
Existing
Infrastructure
Remove existing farm paths within the proposed easements by deep ripping to break soil
compaction associated with equipment and vehicle use. NRRRF will establish new roads
dependent on future use and need outside of the Site's proposed easements.
- Remove rock debris associated with a historic farm path across Feature 2B, and stabilize the
channel with matting, ternporary/permanent seeding, and live -stake planting.
- Remove large debris from the easement as is feasible and without damaging the existing
riparian buffer (Main Tributary 2).
Riparian
Restoration
Within the Site's proposed conservation easements:
- Treat Bermuda and fescue grass species within active pasture areas (see Herbaceous
Treatment note above).
Site -wide discing of agricultural and pasture areas ahead of planting — discing will occur parallel
to the Site Features, promoting floodwater attenuation by increasing frictional resistance of
floodwaters crossing Parcel floodplains.
Establishment of a native herbaceous community via site -specific seed mix (See Planting Plan —
Section 3.3.1)
Establishment of a native hardwood forest via the planting of bare -root saplings from the top
of bank out a maximum of 2QB' along Parcel Features —Section 3.3 Planting Plan
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201
Page 10 of 17

3.1 Project Schedule
Project activities, milestones, and anticipated completion dates are outlined in Table 9.
Table 9. Project Schedule
Activity / Milestone
Completion Date
Site Mitigation Banking Instrument and Bank Parcel Development Package Approval
Q4 2021
Acquisition of Conservation Easement
Q4 2021
Removal of Existing Infrastructure & rubble within easement (as feasible)
Q1 2022
Planting
Q1 2022
As -Built & Assignment of Conservation Easement
Q2 2022
Year 1 monitoring
Q4 2022
Year 2 monitoring
Q4 2023
Year 3 monitoring
Q4 2024
Year 4 monitoring
Q4 2025
Year 5 monitoring
Q4 2026
Closeout
Q1 2027
3.2 Permitting
Restoration activities requiring heavy equipment include:
1.) Remove existing, earthen farm paths within the proposed easements by deep ripping with
agricultural equipment to break up soil compaction associated with historic farm equipment and
vehicle use.
2.) Remove rock debris associated with a historic farm path that crosses Feature 2B, and stabilize the
channel with matting, temporary/permanent seeding, and live -stake planting.
3.) Remove reinforced concrete pipes & other debris located within the proposed easement as feasible
without damaging existing forest/vegetation.
Construction activities will not require permitting or authorization from federal, state, or county agencies
for impacts to regulated waterways or ground -disturbing activities. A summary of work is summarized
below in Table 13.
Table 10. Summary of Temporary Impacts
Activity
Location
Feature
Type
Temporary
Impacts
Reasoning
Stabilization
Activities
Removal of
compacted
gravel within
an existing
feature.
Phase A
Feature 2B
�35.701112',
78'501082°)
Intermittent
+/- 201. ft.
Reconnection of upstream and
downstream features by
removal of non-native
material, improvement of
feature function, and habitat
Matting of banks,
temporary and
permanent seed
establishment, and
live -stake planting
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201
Page 11 of 17

3.3 Planting Plan
Restoration of the riparian area allows for recolonization and expansion of characteristic species across
the landscape. The riparian areas will be restored according to the Consolidated Buffer Mitigation Rule
15A NCAC 02B .0295 (November 1, 2015). The planting plan for the riparian restoration area includes
planting 28,000 native bare -root hardwood saplings across 46.51 acres at a Parcel density of +/-600 stems
per acre and live stakes for stream bank stabilization where necessary (Figure 8, Appendix A). Community
associations utilized in the proposed planting plan include Schafale and Weakley's (2012) Mesic Mixed
Hardwood Forest (Piedmont Subtype) and Piedmont Bottomland Hardwoods, as detailed in Section 2.3,
Existing Vegetative Communities. Species composition includes native species known for fruit production.
Tree species will be mixed thoroughly before planting to provide a diverse and random plant across the
Site. Planting density is set to ensure sufficient diversity and density of planted stems outlined in Rule 15A
NCAC 02B .0295 of 260. No one tree species will be greater than 50% of the established stems —Table 11
details tree species reserved by the Sponsor for planting. The final planted species is subject to final
species availability. The Sponsor will note any changes to the planting list in the Site's Baseline Document
and As -built Survey.
Table 11. Proposed Hardwood Bare Root Planting Plan by Species
Common Name
Scientific Name
Tree/Shrub
Phase A (46.51 Ac.)
Species % of Total
River birch
Betula nigra
Tree
4,000
14%
Persimmon
Diospyros virginiana
Tree
3,000
11%
Tulip poplar
Liriodendron tulipifera
Tree
3,200
11%
Red mulberry
Morus rubra
Tree
2,400
9%
Black Gurn
Nyssa sylvatica
Tree
2,000
7%
Sycamore
Plotanus occidentalis
Tree
1,400
5%
White Oak
Quercus alba
Tree
2,000
7%
Water oak
Quercus nigra
Tree
3,600
13%
Cherrybark oak
Quercus pagoda
Tree
3,200
11%
Willow oak
Quercus phe los
Tree
3,200
11%
Total
10 Species
28,000
100%
3.3.1 Permanent Seed Mix
The Sponsor will broadcast a permanent seed mix over all riparian restoration areas. The seed mix will
include native grasses and forbs, with a variety of annual and perennial plants known to benefit wildlife
and pollinators. The grass seed component will focus on low -growing species that favor establishing the
target forest community, particularly species such as purpletop (Tridens flavus) and bentgrass (Agrostis
hyemalis). The forb component will include a diverse mixture of native and naturalized forbs and
wildflowers, including fifteen or more species.
3.4 Parcel Protection & Easement Boundaries
Before the release of any credits, RS will record a permanent conservation easement at the Wake County
Register of Deeds sufficient to ensure protection, operation, and maintenance of restored riparian buffers
and other riparian areas in perpetuity.
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4) Page 12 of 17
Neuse River Basin 8-Digit HUC: 03020201

The form of the conservation easement shall be consistent with the standards employed by the State of
North Carolina in the protection of restored riparian buffers and riparian areas and shall be approved by
the DWR before the release of any credits.
Appendix B includes written confirmation from NCDWR approving of the implementation of this plan on
portions of fields currently permitted for the application of biosolids under NCDWR permit WQ0001730 -
City of Raleigh. Fields currently permitted for the application of biosolids will be removed from the City
of Raleigh's above referenced permit after the conservation easement is recorded and prior to approval
of this Bank Parcel's As -Built report by NCDWR.
Parcel easement boundaries will be identified in the field to ensure a clear distinction between the Parcel
and adjacent properties/land uses. The Sponsor will install marking and signage of the easement boundary
adjacent/close to utility and greenway easements to ensure the clear designation of the easement.
Boundaries may be identified by cattle fence, marker, bollard, post, tree -blazing, or other means as
allowed by Site conditions and/or conservation easement requirements and will be installed before the
As -Built Site visit by DWR. Boundary markers disturbed, damaged, or destroyed will be repaired and/or
replaced on an as -needed basis. The easement boundary will be checked annually as part of monitoring
activities and reported to DWR.
3.5 As -Built Report
A Baseline Monitoring Document and As -Built Survey will be submitted to DWR documenting the
completion of the Site's Restoration Plan and in accordance with the MBI.
4.0 Monitoring and Maintenance Plan
4.1 Monitoring Protocol & Success Criteria
Restoration monitoring procedures for vegetation will monitor plant survival and species diversity.
Quantitative sampling will include thirty-seven (37) permanent 10 x 10-meter vegetation plots as outlined
in the CVS Level 1-2 Protocol for Recording Vegetation, Version 4.2 (Lee et al. 2008) and will occur no
earlier than Fall of each year (Figure 10 - Monitoring Plan). Vegetation plot placement will adequately
represent riparian buffer credit and nutrient offset credit areas. A reference photo will be taken from the
origin point of each plot. All planted stems in the plots will be marked with flagging tape and recorded.
Data collected will include species, height, vigor, and planting type (planted stern and/or volunteer).
Monitoring of the restoration efforts will be performed for five years or until success criteria are fulfilled.
The Sponsor shall submit to DWR annual monitoring reports no later than December 31 of each year. Each
report will document the success of the vegetation and any maintenance, supplemental planting, or
encroachment within the easement areas. Success criteria within the riparian restoration areas will be
based on the survival of planted species at a density of 260 stems per acre after five years of monitoring.
The first annual monitoring activities will commence at the end of the first growing season, at least six
months after planting has been completed.
4.2 Parcel Maintenance
A remedial action plan will be developed and implemented with the approval of DWR in the event the
Parcel or a specific component of the Parcel fails to achieve success criteria as outlined above. Other
vegetation maintenance and repair activities may include pruning, mulching, and fertilizing. If exotic
invasive plant species require treatment, such species will be controlled by mechanical (physical removal
with the use of a chainsaw) and/or chemical methods (aquatic approved herbicide) in accordance with
North Carolina Department of Agriculture (NCDA) rules and regulations.
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4) Page 13 of 17
Neuse River Basin 8-Digit HUC: 03020201

If mowing is deemed necessary by the Sponsor during the monitoring period, the Sponsor must receive
approval from DWR prior to conducting any mowing activities within Neuse Buffer Zones 1 and 2 to ensure
that no buffer violations have occurred.
4.3 Maintenance Areas
City of Raleigh actively manages areas surrounding the site, including the monitoring of existing
groundwater monitoring wells located around and within the Site footprint, as required under their
Non -Discharge Permit for biosolids application # WQ0001730 as well as the permit's corresponding
Corrective Action Plan issued 9/2/2010 by DWR. Raleigh shall retain rights to passive access to monitor
and maintain wells for compliance with the permit, the permit's corresponding "Corrective Active Plan
for the NRRRF" and any parts of 15A NCAC 02L .0107 (e) as applicable. Well reference #s and locations
within the Site footprint are as follows:
Project Phase
Well Label
Adjacent Parcel
Feature
Conservation
Easement Area
Phase A
MW-127
Feature 1A
3
Phase A
MW-30
Pond 2
5
Phase A
MW-56
Pond 2
5
Additionally, maintenance areas will be delineated on the final survey to be included in the conservation
easement footprint, and excluded from nutrient offset and riparian buffer credit generation. These areas
are reserved for infrastructure maintenance such as earthen dams, culverted crossings, and piped
discharges. Land clearing and vehicular traffic in these areas necessary for infrastructure maintenance is
allowed.
4.4 Long Term Management Plan
The conservation easement will preserve all areas and prohibit all use of the property inconsistent with
its use as a nutrient offset and riparian buffer mitigation property, including any activity that would
materially alter the biological integrity of the Site/Parcel. RS will transfer or assign the conservation
easement and its interests in perpetuity to a qualified holder under NC General Statute ("GS") 121-34 et
seq. and 170(h) of the Internal Revenue Code prior to the submittal of the As -Built Report. The holder
shall be a land trust or stewardship program that is accredited by the Land Trust Accreditation Commission
and/or has been approved by DWR. A land trust must be certified under 501(c)(3) of the Internal Revenue
Code.
5.0 Financial Assurance
As required by the UMBI, the Sponsor will secure all financial assurances according to the UMBI. No
bond shall be less than $150,000 to cover costs of construction and no less than $100,000 to cover
monitoring expenses.
Monitoring bonds shall be renewed with confirmation of renewal provided to DWR with each annual
monitoring report. DWR reserves the right to alter the credit release schedule if monitoring reports
are submitted without proof of bond renewals.
Raleigh Farm — Phase A Bank Parcel Development Plan (2019.1692 V4) Page 14 of 17
Neuse River Basin 8-Digit HUC: 03020201

6.0 Mitigation Potential
The Parcel will generate Neuse River Riparian Buffer Credits (RBC) and Nutrient Offset Credit (NOC,
nitrogen) on restored riparian areas measured from the top of bank out perpendicularly 200-feet on
Parcel Features (streams, ephemeral channels, and an in -line pond). Per the Consolidated Mitigation
Buffer Rule, the Parcel will generate RBC via allowed activities under Section (n), Non -forested Areas
[Restoration Site] and (o), Alternative Buffer Mitigation Options. Specifically, RBC is to -be generated from
sub -sections (o)(4), (o)(5), & (o)(7). Parcel compliance with these sub -sections is detailed below.
(o)(4) — Preservation of Buffer on Non -Subject Streams: Preservation of buffers on intermittent or
perennial streams that are not subject per 15A NCAC 02B .0233 are proposed via the permanent
protection under a perpetual conservation easement from cutting, clearing, filling, grading, and similar
activities that would affect the functioning of the buffer. Features proposed under (o)(4) were confirmed
as intermittent or perennial streams by DWR representatives during the June 2-3, 2020 site visit for
applicability and suitability (Appendix B). The area of preservation credit is capped at 25 percent of the
total area of buffer mitigation.
(o)(5) — Preservation of Buffers on Subject Streams: Buffer preservation is proposed on streams that are
subject per 15A NCAC 02B .0233 to permanently protect the buffer from cutting, clearing, filling, grading,
and similar activities that would affect the functioning of the buffer beyond the protection afforded by
the existing buffer rules on sites that meet the definition of a preservation site. The area of preservation
credit is capped at 25 percent of the total area of buffer mitigation.
(o)(7) — Mitigation on ephemeral channels: The Parcel will generate riparian buffer credit on "ephemeral
channels" as defined as a "natural channel exhibiting discernible banks within a topographic crenulation
(V-shaped contour lines) indicative of natural drainage on the 1:24,000 scale (7.5 minute) quadrangle
topographic map prepared by the US Geologic Survey, or as seen on digital elevation models with contours
developed from the most recent available LiDAR data" (15A NCAC 02B .0295). Appendix A Figures depict
the delineated watershed draining to each ephemeral channel proposed for RBC (Features 1A, 2A, 3A, 4A,
and GA). The entire area proposed for RBC from ephemeral channels is within the contributing drainage
area. All subject ephemeral channels are directly connected to an intermittent or perennial stream, are
contiguous with the Site and are proposed for permanent protection under the Site's conservation
easement. The RBC derived from ephemeral channels will not total more than 25 percent of the total area
of buffer mitigation. The proposed buffer credit areas meet all applicable requirements of Paragraph (n)
of Rule [15A NCAC 02B .0295] for restoration or enhancement, and all applicable requirements of
Subparagraph (o)(4) or (o)(5) of Rule [15A NCAC 02B .0295] for preservation. Ephemeral features were
confirmed by DWR representatives during the June 2-3, 2020 site visit for the applicability and suitability
of Site Features (Appendix B).
DWR has determined the nitrogen abatement of restored riparian areas on this Bank Parcel to be 2,273.02
lbs. per acre as agreed to in the Raleigh Farm MBI. RBC will be measured to the nearest whole square foot.
Riparian buffer restoration credits can be converted and transferred to NOC upon approval from DWR.
However, conversions of NOC from widths 101'-200' (measured from top of bank) to RBC will not occur.
Provided in Appendix B is a complete DWR Credit Determination Table, which details the individual
components, generated credit, and which features generating RBC credit comply with criteria to also be
convertible to NOC. The Sponsor must request and receive written approval of the conversion and transfer
of any mitigation credits from DWR prior to adding or removing credits from the ledgers.
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4) Page 15 of 17
Neuse River Basin 8-Digit HUC: 03020201

The Sponsor will maintain three individual ledgers, one to account for riparian buffer restoration credits,
one to account for riparian buffer preservation credits, and one to account for NOC. All credit assets shall
be accurately depicted on these credit ledgers. All accounting will be in accordance with DWR's Clarified
Procedures for Calculating Buffer Mitigation Credits and Nutrient Offset Credits (November 2019) (link in
UMBI). The complete DWR Mitigation Credit Table is shown on the following page, Table 13.
7.0 References
Griffith, G.E., JM Omernik, J.A. Comstock, M.P. Schafale, W.H. McNab, ❑.R. Lenat, T.F. MacPherson, J.B.
Glover, and VB Shelbourne. 2002. Ecoregions of North Carolina and South Carolina. US Geological
Survey, Reston, Virginia.
Schafale, M. P. and Weakley, 2012. A Classification of the Natural Communities of North Carolina, Fourth
Approximation.
US Department of Agriculture (USDA), 2019. Web Soil Survey (online). Available:
https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm [Accessed July 19, 2020].
US Fish and Wildlife Service, 2020. Endangered Species, Threatened Species, and Candidate Species,
Wake County, North Carolina (online). Available:
https://www.fws.gov/raleigh/species/cntylist/wake.html (Accessed July 19, 2020)
Space Purposefully Left Blank
Raleigh Farm — Phase A Bank Parcel ❑evelapment Plan (2019-1692 V4) Page 16 of 17
Neuse River Basin 8-Digit HUC: 03020201

Credit Table 13. Raleigh Farm Bank Parcel - Phase A, 2019-1692v4, Project Credits
Neuse 03020201- Outside Falls Lake
Project Area
N Credit Conversion Ratio (ft'/pound)
P Credit Conversion Ratio (ft'/pound)
19.16394
N/A
Credit Type
Location
Subject? (enter
NO if
ephemeral or
ditch')
Feature Type
Mitigation Activity
Min -Max Buffer
Width (ft)
Feature Name
Total Area (ft')
Total (Creditable)
Area of Buffer
Mitigation (ft-)
Initial Credit
Ratio (x:1)
% Full Credit
Final Credit
Ratio (x:1)
Convertible to
Riparian
Buffer?
Riparian Buffer
Credits
Convertible to
Nutrient Offset?
Delivered
Nutrient Offset:
N (Ibs)
Delivered
Nutrient
Offset: P (Ibs)
Buffer
Rural
No
Ephemeral
Restoration
20-29
1A, 2A
96
96
1
75%
1.33333
Yes
72.000
No
-
-
Buffer
Rural
No
Ephemeral
Restoration
0-100
1A, 2A, 3A, 6A
171,999
171,999
1
100%
1.00000
Yes
171,999.000
Yes
8,975.138
-
Buffer
Rural
No
In -Line Pond
Restoration
0-100
Pond 2
43,766
43,766
1
100%
1.00000
Yes
43,766.000
Ves
2,283.768
-
Buffer
Rural
Yes
I / P
Restoration
20-29
Main Trib 2, 5A
559
559
1
75%
1.33333
Yes
419.251
No
-
-
Buffer
Rural
Yes
I / P
Restoration
0-100
18, 28, Main Trib 2, 4B,
5A, 6B, 78, 8A
619,262
619,262
1
100%
1.00000
Yes
619,262.000
Ves
32,313.919
-
Nutrient Offset
Rural
No
Ephemeral
Restoration
101-200
1A, 2A, 3A, 6A
145,204
1
33%
No
-
Ves
7,576.939
-
Nutrient Offset
Rural
No
In -Line Pond
Restoration
101-200
Pond 2
82,505
1
33%
No
-
Yes
4,305.221
-
Nutrient Offset
Rural
Yes
I / P
Restoration
101-200
1B, 28, Main Trib 2, 4B,
5A, 6B, 78, 8A
892,600
1
33%
No
-
Ves
46,577.061
-
Totals (ft2):
Total Buffer (ft2):
Total Nutrient Offset (ft2):
1,955,991
835,682
835,518.251
102,032.046
0.000
835,682
835,682
1,120,309
N/A
Enter Preservation Credits Below
Total Ephemeral Area (ft') for Credit:
Total Eligible Ephemeral Area (ft'):
Total Eligible for Preservation (ft'):
Credit Type
Location
Subject?
Feature Type
Rural
Rural
Rural
Rural
Rural
Rural
Rural
No
No
No
No
No
Ephemeral
Ephemeral
Ephemeral
In -Line Pond
In -Line Pond
Yes
Yes
I/P
I/P
Rural
Yes
I/P
Mitigation Activity
TOTAL AREA OF BUFFER MITIGATION (TABM)
Mitigation Totals
Square Feet
Credits
Restoration:
835,682
835,518.251
Enhancement:
0
0.000
Preservation:
278,561
39,043.100
Total Riparian Buffer:
1,114,243
874,561.351
TOTAL NUTRIENT OFFSET MITIGATION
Mitigation Totals
Square Feet
Credits
Nitrogen:
1,120,309
58,459.221
Nutrient Offset.
Phosphorus:
0.000
Min -Max Buffer
Width (ft)
20-29
0-100
101-200
0-100
101-200
20-29
0-100
101-200
Feature Name
2A
A, 2A, 3A, 4A, 6A
1A, 2A, 3A, 4A, 6A
Pond 2
Pond 2
Main Trib 2, 6B
18, 28, Main Trib 2, 4B,
68, 78, 8A
Main Trib 2, 213, 48, 613,
78, 8A
Preservation Area Subtotals (ft'):
1. The Randleman Lake buffer rules allow some ditches to be classified as sub'ect according to 15A NCAC 028 .0250 (5)(a).
239,891
239,891
278,561
21.5%
278,561
25.0%
Total (Creditable)
Total Area (sf)
Area for Buffer
Mitigation (ft')
111
0
67,796
67,796
64,518
0
44,074
44,074
3,102
0
883
0
653,677
166,691
152,833
0
986,994
278,561
Ephemeral Reaches as % TABM
Preservation as % TABM
Initial Credit
Ratio (x:1)
% Full Credit
Final Credit
Ratio (x:1)
Riparian
Buffer Credits
5
75%
5
10
100%
5.00000
13,559.200
33%
100%
5.00000
8,814.800
33%
75%
10
100%
10.00000
16,669.100
10
33%
last updated 08/03/2020

Appendix A: Figures and Photos
Figure 1-- Parcel Location and Service Area
Figure 2 - Parcel Easements and Features
Figure 3 - USGS Topography
Figure 4 - MRCS Soil Survey
Figure 5 -Current Conditions
Figure 6 - NRRRF & Proposed Project Footprint
Figure 7 - Biosoild Application Fields
Figure 8 - Restoration Plan
Figure 9--Credit Determinations (Figures 9A-9D)
Figure 10- Monitoring Plan
Existing Conditions Photos
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201 Appendices

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Raleigh Farm Bank Parcel — Neuse 01; Wake County
Photo Date: 09/29/2020
Image 1: Phase A— Feature 1A &
Image 2: Phase A— Feature 2B, rock in channel

Raleigh Farm Bank Parcel — Neuse 01; Wake County
Photo Date: 09/29/2020
Image 3: Phase A— Feature 5A
Image 4: Phase A— Main Tributary 2
2

Raleigh Farm Bank Parcel — Neuse 01; Wake County
Image 5: Phase A— Pond 2, BMP Wetland standpipe
Image 6: Phase A— Main Tributary 2, NRRRF BMP Wetland
Photo Date: 09/29/2020

Raleigh Farm Bank Parcel — Neuse 01; Wake County
Photo Date: 09/29/2020
Image 7: Phase A — Main Tributary 2, wetland BMP outlet through existing buffer (excluded
from proposed easement.
Image 8: Phase A — Main Tributary 2, debris in existing buffer

Appendix B: DWR Correspondence
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201 Appendices

Docusign Envelope ID: ACF675FD-8AA5-41A1-BD65-22AF9AA50486
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
5. DANIEL SMITH
Director
Barrett Jenkins
Restoration Systems, LLC
1101 Haynes Street, Suite 211
Raleigh, NC 27604
NORTH CAROLINA
Environmental Quality
August 17, 2020
Project 2019-1692 V1
Wake County
Subject: On -Site Determination for Applicability to the Neuse Buffer Rules 15A NCAC 02B .0714
Project Name: Raleigh Farm Site Phase A
Address: 8599 Old Baucom Rd. (SR 2542), Raleigh, NC 27610
Location: 35.702396, -78.496346 (south of the road)
Site Inspection Date: 6/2/20 and 6/3/20
Dear Mr. Jenkins:
On June 2 and 3, 2020, Shelton Sullivan of the Division of Water Resources (DWR) conducted an on -site
review of features located on the subject property at the request of Barrett Jenkins with Restoration
Systems, LLC to determine the applicability to the Neuse Riparian Area Protection Rules, Title 15A North
Carolina Administrative Code 02B .0714.
The enclosed map(s) depict the feature(s) evaluated and this information is also summarized in the table
below. Streams were evaluated for being ephemeral, at least intermittent, and subjectivity to the Neuse
Riparian Area Protection Rules. Streams that are considered "Subject" have been located on the most
recently published NRCS Soil Survey of Wake County and/or the most recent copy of the USGS
Topographic (at 1:24,000 scale) map(s), have been located on the ground at the site, and possess
characteristics that qualify them to be at least intermittent streams. Features that are considered "Not
Subject" have been determined to not be at least intermittent, not present on the property, or not
depicted on the required maps.
This determination only addresses the applicability to the buffer rules and does not approve any activity
within buffers or within waters of the state. There may be other streams or features located on the
property that appear or do not appear on the maps referenced above. Any of the features on the site
may be considered jurisdictional according to the US Army Corps of Engineers and subject to the Clean
Water Act.
The following table addresses the features observed and rated during the DWR site visit:
ODE
1
nee tmeaim Emirm�esw w+e
North Carolina Department of Environmental quality 1 Division of Water Resources
512 North Salisbury Street i 1617 Mail Service Center 1 Raleigh. North Carolina 27699-1617
919.707.9000

DocuSign Envelope ID: ACF875FD-8AA5-41A1-BD65-22AF9AA504S6
Project 2019-1692V1, Raleigh Farm Phase A
Wake County
Page 2 of 3
Feature
Point I❑
Feature Type
(stream/pond/ E/I/P')
(ditch/wetland/other)
Subject to
Buffer
Rules
Start @
Stop @
Depicted on
Soil Survey
Depicted on
USGS Topo
1A
Ephemeral
No
lA
1B
Yes
No
1B
Stream - At least
intermittent
Yes
1B, Above the
confluence
with Main
Tributary 2
2C, Confluence with
Main Tributary 2
Yes
Yes
2A
Ephemeral
No
2A
2B
Yes
No
2B2
Stream - At least
intermittent
Yes
2B
2C, Confluence with
Main Tributary 2
Yes
No
Main
Tributary 2
Stream - At least
intermittent
Yes
2C, includes
Pond 2, and
continues to
the easement
and property
line
Confluence with
Beddingfield Creek
Yes
Yes
3A
Ephemeral
No
3A
Confluence with Main
Tributary 2
Yes
No
4A
Ephemeral
No
4A
4B
Yes
No
4B
Stream - At least
intermittent
Yes
4B
Continues to the
confluence with Main
Tributary 2
Yes
No
5A
Stream - At least
intermittent
Yes
5A
Continues to the
confluence with Main
Tributary 2
Yes
No
6A
Ephemeral
No
6A
6B
Yes
No
613
Stream - At least
intermittent
Yes
6B
Continues to the
confluence with
Beddingfield Creek
Yes
No
7A
Not Present
No
See site map
See site map
Yes
No
7B
Stream - At least
intermittent
Yes
78
Continues to property
and easement
boundary
Yes
No
8A
Stream - At least
intermittent
Yes
8A
86
Yes
No
813
Ephemeral
No
8B
8C, dissipates within
the wetlands &
floodplain of
Beddinfield Creek
Yes
No
9
Not Evaluated
Not
Evaluated
See site map
See site map
Yes
No
10
Not Evaluated
Not
Evaluated
See site map
See site map
Yes
No
11
Not Present
No
See site map
See site map
Yes
No
1 E: Ephemeral, I: Intermittent, P: Perennial
2 A small area of the stream below 26 has been impacted from by sedimentation from the adjacent farm field and an
old farm path, however, DWR considers this area to be at least intermittent and subject to the Buffer Rules.
This on -site determination shall expire five (5) years from the date of this letter. Landowners or affected
parties that dispute this determination made by the DWR may request an appeal determination by the
Director of Water Resources. An appeal request must be made within sixty (60) calendar days of the
date of this letter to the Director in writing, as per 15A NCAC 02B .0714 (4).

Docusign Envelope ID: ACF675FD-8AA5-41A1-BD65-22AF9AA50486
Project 2019-1692V1, Raleigh Farm Phase A
Wake County
Page 3 of 3
If sending via U.S. Postal Service:
Paul Wojoski - DWR 401 & Buffer
Permitting Branch Supervisor
1617 Mail Service Center
Raleigh, NC 27699-1617
If sending via delivery service (UPS, FedEx, etc.)
Paul Wojoski -DWR 401 & Buffer
Permitting Branch Supervisor
512 N Salisbury 5t.
Raleigh, NC 27604
This determination is final and binding as detailed above, unless an appeal is requested within sixty (60)
calendar days.
This letter only addresses the features on the subject property and within the proposed project easement
boundary and does not approve any activity within buffers or within waters of the state. If you have any
additional questions or require additional information, please contact Shelton Sullivan at
[e-mail] or 919-707-3636. This determination is subject to review as provided in
Articles 3 & 4 of G.S. 150B.
Sincerely,
r—DocuSigned by:
y
1/4--949D91BA53EF4EU...
Paul Wojoski
Supervisor, DWR 401 & Buffer Permitting
Attachments: Site Map with labeled points, NRCS Soil Survey, USGS Topographical Map
cc: Raymond Holz via email [e-mail]
Barrett Jenkins via email [e-mail]
Katie Merritt via email [e-mail]
401 & Buffer Permitting Branch files
Filename: 20191692v1_Raleigh FarmPhaseA_StreamCalls.docx

DocuSign Envelope F0: AC F875FD.aAA5. 41A1•BD65.22AF9AA50486

n Envelope ID: ACF875FD•8AA5-41A1•BD65.22AF9A450486
Wake County, NC

DocuSign Envelope ID: ACF875FD-SAA5-41A1 BD65-22AF9AA50486
Phase A: Wake County Soil Survey for Reference

DocuSign Envelope ID: 8DCBI9AE-A3A7-43EC-863C-❑627566F280D
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
5. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
September 24, 2020
Barrett Jenkins
Restoration Systems, LLC
1101 Haynes St, Suite 211
Raleigh, NC 27604
(via electronic mail: bienkins!cJrestorationsystems.com)
DWR# 2019-1692v1
Re: Site Viability for Buffer Mitigation & Nutrient Offset — Raleigh Farm Phase A Site
Near 8599 Old Baucom Rd (SR 2542), Raleigh, NC 27610
Lat., Long. 35.702396, -78.496346 (south of road)
Neuse 03020201
Dear Mr. Jenkins,
On February 11, 2020, Katie Merritt, with the Division of Water Resources (DWR), received a
request from you on behalf of Restoration Systems, LLC (RS) for a site visit near the above -
referenced site in the Neuse River Basin within the 8-digit Hydrologic Unit Code 03020201. The site
visit was to determine the potential for riparian buffer mitigation and nutrient offset within a
proposed Easement Boundary, which is more accurately show n in the attached map labeled
"CORPUD-Site Features Phase A" prepared by RS and edited by DWR. On June 2, 2020 and June
3, 2020, Ms. Merritt performed site assessments of the subject site and identified the following site
constraints:
• UTILITIES: Gas lines are being proposed on parts of the site where streams are located.
Existing powerline easements are also present. Specific locations and associated
easements of gas lines were unknown at the time of the DWR site visit, but the attached
CORP U❑ figure details where the proposed and temporary easements 1,1. ill be located.
• PERMITS: State. Federal and/or Local permits may be associated with this property.
Wetland delineation flagging and other stream call determinations were observed on the
site.
• EXISTING INFRASTRUCTURE: The City of Raleigh owns the property on the site
and has used the land for applying biosolids associated with the Neuse River Resource
Recovery Facility (NRRRF). Existing underground and above ground infrastructure is
present for purposes of irrigating the property. The City of Raleigh Public Utilities
Department (CORPUD) manages the property. Existing dirt paths, culverted crossings,
deeded access roads and greenways are present throughout and are adjacent to ditches
and stream onsite where mitigation would be proposed. Some Groundwater Monitoring
Wells were located onsite, but their locations are not depicted on any maps attached to
this correspondence. All existing infrastructure within the proposed conservation
easement shall be delineated and included as parr of the site's restoration plan along with
specific details on management and maintenance and what will be included or excluded.
o Application of bio-solids will not be permitted within a conservation easement.
aE _
oea=,+nunif�. enniunt,i w9m7
North Carolina Department of Environmental Quality I Division of Water Resources
5i2 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

Docu5ign Envelope ID: 8fDCB99AE-A3A7-43EC-863C-❑027560F2800
Raleigh Farm Phase A Site
Restoration Systems, LLC
September 24, 2020
o Impervious surface will not be permitted within a conservation easement unless it
is an access easement or located outside of creditable areas for mitigation or
nutrient offsets.
o Disruption in connectivity between top of bank and adjacent riparian areas will
not be permitted within a conservation easement.
❑ Monitoring wells must remain fully functional and shall be allowed to be
maintained and accessed as needed.
• BMP: A constructed wetland is present onsite adjacent to Pond 2 and shall not be
included in planting efforts or as creditable areas for mitigation or nutrient offset.
Ms. Merritt's evaluation of the features onsite and their associated mitigation determination for the
riparian areas are provided in the table below. This evaluation was made from Top of Bank (TOB)
and landward 200' from each feature for buffer mitigation pursuant to 15A NCAC 02B .0295
(effective November 1, 2015) and for nutrient offset credits pursuant to 15A NCAC 02B .0703.
Feature
Classification
1Subject
7Riparian Land uses
Buffer
3Nutrient
4.5Mitigation Type Determination
onsite
to
Buffer
adjacent to Feature
Credit
Offset
w/in riparian areas
10-200')
Viable
Viable
Rule
lA
Ephc n al
No
Mostly non -forested
agricultural fields with
some tnature forest
2,8yes
Yes (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (o)(7)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(4)
1 B
Stream
Yes
Mostly non -forested
agricultural fields with
some mature forest
:Yes
Yes (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (ii)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(5)
2A
lip heincral
No
Combination anon-
forested agricultural fields
and mature forest
2.8
Yam'
Yes (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 0213 .0295 (o)(7)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(4)
213°
Stream
Yes
Combination of non-
forested agricultural fields
and mature forest
- Y
Yes (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (n)
Forested Areas - Preservation Site per
15ANCAC 0213.0295 (o)(5)
Page 2 of 6

Dacu5ign Envelope ID: 8fDCB19AE-A3A7-43EC-863C-❑027560F2800
Raleigh Farm Phase A Site
Restoration Systems, LLC
September 24, 2020
Feature
Classification
15ubiect
7Riparian Land uses
Buffer
3Nutrient
4•5Mitigation Type Determination
onsite
to
Buffer
adjacent to Feature
Credit
Offset
w/in riparian areas
(0-200')
Viable
Viable
Rule
2C
Main
Tributary 2
Stream
Yes
Combination of non-
forested agricultural fields
and mature forest
A gas line is proposed to
iinpact stream; existing
utilities are present (see
map)
2Yes
Yes (non-
forested
areas on y)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (n)
Forested Areas - Preservation Site per
15A NCAC 02B .0295 (o)(5)
All areas within existing easements
including utilities must be excluded from the
Restoration and Preservation Site.
Cannot be used as a Restoration Site until
after gels line is constructed &
construction easements are n0 longer
needed
Pond 2
in -line pond
Yes
Combination of non-
forested agricultural fields
and mature forest
PermittedBMPislocated
along left side of pond and
shall not be included in
planting efforts or arras for
credit
- Yes
Yes (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (n)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(5)
The dam needs to have controlled
access by RS and should be deeded
along with Conservation Easement so
that dam integrity is maintained. No
trees can be planted & no credit
obtained along the dam or within
controlled access area.
3A
(ends at
confluence
of2C/Main
T'nb)
Ephemeral
No
Mostly non-tbrested
agricultural fields with
mature forest at the top of
retch.
2•8Yes
Ycr (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (o) (7)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(4)
4A
Ephetneral
No
Mature forest
YuS
No
Preservation Site per 15ANCAC 02B
.0295 (o)(4)
413
(ends at
confluence
of 5A)
Stream
Yes
Combination of non-
forested agricultural fields
and mature forest
2Ycs
Yes (non-
forested
areas ony)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (n)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(5)
Page 3 of 6

DocuSign Envelope (D: 8DCB99AE-A3A7-43EC-663C-❑027560F280D
Raleigh Farm Phase A Site
Restoration Systems, LLC
September 24, 2020
Feature
Classification
1Subiect
7Riparian Land uses
Buffer
3Nutrient
1.5Mitigation Type Determination
onsite
to
Butler
adjacent to Feature
Credit
Offset
w/in riparian areas
10-200')
Viable
Viable
Rule
5A
(continues to
confluence
of 2C/Mam
Trih)
Stream
Yes
Combination of non-
forested agricultural fields
and mature forest
A gas line is proposed to
impact stream: existing
utilities are present (see
map)
-Ye,
Yes (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 0213.0295 (n)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(5)
All areas within existing easements
including utilities must be excluded from the
Restoration and Preservation Sire.
Cannot be used as a Restoration Site until
Riker gas line is constructed &
construction easements are no longer
needed
6A
Ephemeral
No
Combination of non-
forested agricultural fields
and mature forest
: Y
Yes (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (o)(7)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(4)
613
Stream
Yes
Combination of non-
forested agricultural fields
and mature forest
A gas line is proposedto
impact stream; existing
utilities are present (see
map)
2
Yes
Yes (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (n)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(5)
All areas within existing easements
including utilities) must be excluded from
the Restoration and Preservation Site.
Cannot be usedas a Restoration Site until
after gas line is constructed &
construction easements are no longer
needed
7A
Not Present
No
N/A
N/A
N/A
N/A
7B
at DWR slag
Stream
Yes
Non -forested agricultural
fields
Yes
Yes
Restoration Site per 15A NCAC 02B
.0295 (n)
SA
Stream
Yes
Combination of non-
forested agricultural fields
and mature forest
2Yes
Yes (non-
forested
areas only)
Non -forested areas - Restoration Site
per 15A NCAC 02B .0295 (n)
Forested Areas - Preservation Site per
15ANCAC 02B .0295 (o)(5)
8l3
(ends at 8C)
Ephemeral
No
Combination of non-
forested agricultural fields
and mature forest
:No
No
directly connects to wetlands
Page 4 of 6

DocuSign Envelope ID: 8DCB19AE-A3A7-43EC-863C-❑027560F280D
Raleigh Farm Phase A Site
Restoration Systems, LLC
September 24, 2020
Feature
Classification
ISubiect
'Riparian Land uses
Buffer
'Nutrient
4,5Mitigation Type Determination
onsite
to
Buffer
adjacent to Feature
Credit
Offset
w/in riparian areas
10-200)
Viable
Viable
Rule
8C
wetlands
No
fully forested
No
No
N/A
81)
not present
No
N/A
NIA
NIA
N/A
9
not evaluated
N/A
N/A
14/A
N/A
N/A
10
not evaluated
NIA
N7A
N/A
N/A
N.•'1
11
not evaluated
NIA
N/A
N/A
N,.'•.
N/A
'Subjectivity calls for the features were determined by DWR in correspondence. dated August 17, 2020 using the 1:24 000 scale
quadrangle topographic map prepared by USGS and the most recent printed version of the soil survey map preparedby theNRCS
2T1te_area ofpre)s at_onAc�:ed t5 i in. butlermitigation site shall comprise (Arlo more than 25.percent (25%) of the Y talaarea of buffer
tnttition per MAC U d 1A NCAC 0295 (0)(4). Site cannot be a 1 reservatx n� site to comply with this rule.
3NC Division of Water Resources - Methodology and Calcvtlaainns for determining Nutrient Reductions associated with Riparian Buffer
Establishment
4 Determinations made for this Site are determined based on the proposal provided in maps and figures submitted with therequest.
5 All features.proposed for �buu rm mitigation or nutrient offset, must have a conservation easement established that includes the tops of
channel bars when being perpendicular and Landward troin the banks, even if no credit is viable within that nparivn area.
6 A small area of the stream has been impacted from sedimentation and riprap which needs to he removed
Land uses may also include the application of bio-solids associated with the NRRRF
BThe area of the mitigation site on ephemeral channels shall comprise no more than 25 percent (25%) of the total area of butter mitigation
per 15A NCAC 0213.0295 (o)(7).
Determinations provided in the table above were made using a proposed easement boundary shoeing
proposed mitigation areas shown in Figure 1, Figure 2 and the CDRPUD map. Maps representing the
proposal for the Site are attached to this letter and are initialed by Ms. Merritt on September 24, 2020.
Substantial changes to the proposed easement boundary as well as site constraints identified on page 1
of this letter could affect the Sites potential to generate buffer and nutrient offset credits.
This letter does not constitute an approval of this Site to generate buffer and nutrient offset credits.
Pursuant to 15A NCAC 02B .0295, a mitigation proposal and a mitigation plan shall be submitted to
DWR for written approval prior to conducting any mitigation activities in riparian areas and/or surface
waters for buffer mitigation credit. Pursuant to 15A NCAC 02B .0703, a proposal regarding a proposed
nutrient load -reducing measure for nutrient offset credit shall be submitted to DWR for approval prior
to any mitigation activities in riparian areas and/or surface waters.
All vegetative plantings, performance criteria and other mitigation requirements for riparian restoration,
enhancement and preservation must follow the requirements in 15A NCAC 02B .0295 to be eligible for
buffer and/or nutrient offset mitigation credits. For any areas depicted as not being viable for nutrient
offset credit above, one could propose a different measure, along with supporting calculations and
sufficient detail to support estimates of load reduction, for review by the DWR to determine viability
for nutrient offset in accordance with 15A NCAC 02B .0703.

Docu5ign Envelope ID:8DCBISAE-A3A7-43EC-863C-❑027560F280Q
Raleigh Farm Phase A Site
Restoration Systems, LLC
September 24, 2020
This viability assessment will expire on September 24, 2022 or upon approval of a mitigation
plan by the DWR, whichever comes first. This letter should be provided in any nutrient offset,
buffer, stream or wetland mitigation plan for this Site.
Please contact Katie Merritt at [phone] if you have any questions regarding this
correspondence.
Sincerely.
,-DDocuSignee7d by:
Pr244 �. WOoiOo i
'-949D91 BA53EF4E0...
Paul Wojoski, Supervisor
401 and Buffer Permitting Branch
PW/kym
Attachments: Phase A -Figure 1, Phase A -Figure 2, CORPUD-Site Features Phase A
cc: File Copy (Katie Merritt)
Page 6 of 6

Phase A - Figure 1
DocuSign Envelope ID:8DC819AE-A3A7-&3EC-863C-D027560F280D

Dacu5ign Envefape ID: 8fDCB19AE-A3A7-43EC-863C-❑027560F280Q
Phase A - Figure 2
DS
9/24/2020
Ire -Line Pond
Post Vrabality Site Vrset - Mapped. Non -Features

DocuSign Envelope ID: 8DCB19AE-A3A7-3EC-863C-D027560F280D
a osco
yW
F
CORPUD - Site Viability Site Visit - Feature Call Pips - Phase A
9/24/2020
Propsoed Gas Line - Proposed and Temperary Easements
Eph
In -Line Pond

Docusign Envelope ID: 8DCB19AE-A3A7-43EC-863C-D027560F280D
Docu
•
6 SECURED
Certificate Of Completion
Envelope Id: A4D24159DB9F48139B9C2B67134772F7
Subject: Please DocuSign: Raleigh Farm A Figures.pdf
Source Envelope:
Document Pages: 3
Certificate Pages: 1
AutoNav: Disabled
Envelopeld Stamping: Disabled
Time Zone: (UTC-08:00) Pacific Time (US & Canada)
Signatures: 0
Initials: 3
Status: Completed
Envelope Originator:
Katie Merritt
217 W. Jones Street
Raleigh, NC 27699
[e-mail]
IP Address: 149.168.204.10
Record Tracking
Status: Original Holder: Katie Merritt
9/24/2020 1:23:15 PM
[e-mail]
Location: ❑ocusign
Signer Events Signature
Timestamp
Katie Merritt
[e-mail]
DWR
❑EQ
Security Level: Email, Account Authentication
(None)
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Signature Adoption: Pre -selected Style
Using IP Address: 149.168.204.10
Sent: 9/24/2020 1:23:28 PM
Viewed: 9/24/2020 1:23:35 PM
Signed: 9/24/2020 1:24:17 PM
Freeform Signing
In Person Signer Events Signature
Timestamp
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Completed
Hashed/Encrypted
Security Checked
Security Checked
Security Checked
9/24/2020 1:23:28 PM
9/24/2020 1:23:35 PM
9/24/2020 1:24:17 PM
9/24/2020 1:24:17 PM
Payment Events Status Timestamps

Docu
•
6 SECURED
Certificate Of Completion
Envelope Id: 8DCB19AEA3A743EC863CD027560F280D
Subject: Please DocuSign: Raleigh A Site Viability to Sign.pdf
Source Envelope:
Document Pages: 10
Certificate Pages: 1
AutoNav: Enabled
Envelopeld Stamping: Enabled
Time Zone: (UTC-08:00) Pacific Time (US & Canada)
Signatures: 1
Initials: 0
Status: Completed
Envelope Originator:
Katie Merritt
217 W. Jones Street
Raleigh, NC 27699
[e-mail]
IP Address: 149.168.204.10
Record Tracking
Status: Original Holder: Katie Merritt
9/25/2020 9:44:33 AM [e-mail]
Location: ❑ocusign
Signer Events Signature
Timestamp
Paul Wojoski Docu37ned by'
[e-mail]
969a91 RA53EFd EO
North Carolina Department of Environmental Quality
Security Level: Email. Account Authentication
(None)
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Signature Adoption: Pre -selected Style
Using IP Address: 149.168.204.10
Sent: 9/25/2020 9:45:17 AM
Viewed: 9/25/2020 1:56:04 PM
Signed: 9/25/2020 1:56:15 PM
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9/25/2020 9:45:17 AM
9/25/2020 1:56:05 PM
9/25/2020 1:56:15 PM
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Payment Events
Status
Timestamps

Barrett Jenkins
i
From:
Sent:
To:
Cc:
Subject:
Follow Up Flag:
Flag Status:
Barrett,
Saunders, Erickson G <[e-mail]>
Tuesday, May 18, 2021 11:14 AM
Barrett Jenkins
Merritt, Katie; Thornburg, Nathaniel; Dalton, Marla
RE: [External] RE: WQ0001730 - City of Raleigh RLAP Additional Information Request
Flag for follow up
Flagged
The project is still in house with us at the moment, I believe we are still waiting on one more thing froth the additional
information request not related to the buffer restoration project.
You are right, the permit will reference this project and have a condition that a permit modification shall be submitted
to formally remove the sections that are a part of the buffer project. I don't know if we necessarily have authority to
provide the approval for the implementation of the plan, but we have no objections to the implementation as long as it
is removed from the permit and the final easement is sufficient. Katie mentioned that our office and hers would work
internally to provide you with assistance with the easement language that we would require.
As for what we might need from you, the only other comment I had for the CoR's response was that there was not an
updated acreage table for the residuals land application fields after the conservation easement goes into effect. I see
that there are certain amount of acres that are considered overlap on the maps, but I would still want the post -
easement acres in a nice table to put into our permit. I know Marla had also mentioned that some of the fields would be
too small and would be removed altogether, so CoR should propose which of those fields should be removed altogether.
Let me know if you have any other questions.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail]
From: Barrett Jenkins[mailto:[e-mail]
Sent: Monday, May 17, 2021 6:26 PM
To: Saunders, Erickson G <[e-mail]>
Cc: Merritt, Katie <[e-mail]>; Thornburg, Nathaniel<[e-mail]>; Dalton, Marla
M arka. Dalton @ ra leigh nc.gov>
Subject: RE: [External] RE: W00001730 - City of Raleigh RLAP Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Erick,
1

I am working on a final draft for our buffer restoration/nutrient offset project on Raleigh's NRRRF property and wanted
to check in with you to see if Raleigh had completed their biosolids application permit renewal and if that renewal
mentioned future plans to implement the buffer restoration project as discussed?
We are looking for written approval from you to allow us to implement our restoration plan and then have Raleigh apply
for a permit modification to formally update the spray field maps after our conservation easement is recorded.
Please let me know where things stand from your end and if I can provide anymore information.
Katie Merritt, who is permitting our restoration project is cc'd as well as Marla Dalton with Raleigh Water.
Thanks,
Barrett Jenkins
Restoration Systems
512.230.0424
From: Saunders, Erickson G <[e-mail]>
Sent: Friday, March 26, 2021 3:16 PM
To: Merritt, Katie [e-mail]>; Barrett Jenkins <[e-mail]
Cc: Thornburg, Nathaniel<[e-mail]>
Subject: RE: [External] RE: W00001730 - City of Raleigh RLAP Additional Information Request
Katie, it's kind of my fault, my additional information asked for them to provide a draft excerpt of the future
conservation easement. I'm not familiar with how your process works so I threw it back on the City of Raleigh to provide
it to me. I didn't ask for anything final regarding the easement, just a draft to ensure the easement would fall within the
scope of our rules. We won't approve anything based on what we receive, it was kind of meant to be a launching point
to make sure it was known that the easement would need special considerations and language to address the
requirements of our program.
Mr. Barrett,
We recognize that whatever maps you send aren't finalized at the moment. I expect we will issue the permit with a
condition for Raleigh to provide a permit modification to formally remove those areas from the permit to get the
finalized version. We just want to anticipate the removal of certain land application areas now so that we have
something concrete in place to help formalize their removal later on. Just to be clear though, Raleigh should be
providing this information to me, so you may want to provide this information to them because they are supposed to
provide a "Post -buffer mitigation map" which shows what land application areas will still be permitted after this action is
done.
As for the language you provided, it'll probably need to get edited to conform with our rules, but this can be done down
the line if needed. It looks to be missing provisions allowing for the State to enter the site for groundwater monitoring
and remediation activities, which is a requirement in the 02L .0107 groundwater rules. The bolded language only
appears to grant Raleigh that kind of access. Again, that's just off the top of my head and is in no way comprehensive,
and well discuss with Katie and probably the Groundwater Section to determine what all needs to be included in the
final easement. We'II also discuss your other final questions regarding the level of restriction and specific easement
language.
Regards,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
2

Water Quality Permitting
{919] 707-3659 Office
[e-mail]
From: Merritt, Katie
Sent: Friday, March 26, 2021 2:30 PM
To: Barrett Jenkins<[e-mail]>; Saunders, Erickson G ¢Erickson. [e-mail]>
Cc: Thornburg, Nathaniel [e-mail]>
Subject: Re: [External] RE: W00001730 - City of Raleigh RLAP Additional Information Request
Hey Barrett,
Just as a side note, I will be taking the lead on providing RS with language for the conservation easement
associated with the Proposed Mitigation Bank. Therefore, Erick, Nathanial and I will work internally together
on what that language needs to be before sending anything to RS. Then, I will contact RS directly with the
suggested language to include and we can discuss. At this time, DWR is not ready to engage in assistance with
the conservation easement since there is not yet an MBI or Plan approved for the Bank yet. Once we get those
documents finalized, DWR staff will meet to go over the necessary changes to the current easement template.
Unless I have misunderstood, I don't believe Raleigh is required to have a conservation easement recorded to
get the permit renewed.
Let's plan to talk more about this next week at our teams meeting.
Thank you,
Katie
Get Outlook for iOS
From: Barrett Jenkins<[e-mail]>
Sent: Friday, March 26, 2021 11:24:51 AM
To: Saunders, Erickson G <[e-mail]>
Cc: Merritt, Katie <[e-mail]>; Thornburg, Nathaniel<[e-mail]>
Subject: [External] RE: WC/0001730 - City of Raleigh RLAP Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Erick,
Please find attached two draft maps showing areas in which the proposed conservation easement overlaps with existing
fields approved for residuals application. At this point our conservation easement is in draft form and we don't
anticipate finalizing until later this year. Is it okay to provide you updated maps of the changes in the residual
application field boundaries after the Conservation Easement Survey is finalized? This may not coordinate with Raleigh's
permit renewal schedule exactly. I'm asking to make sure I understand what we need to do but also when. Are these
maps sufficient for Raleigh residuals permit renewal that is in process?
Also attached is the draft conservation easement which already includes the below language:
"ARTICLE IV.
GRANTEE'S RIGHTS
3

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
November 21, 2019
To:
N.C. Division of Mitigation Services, Private & Public Mitigation Banks, other Interested Parties
Subject Clarified Procedures for Calculating Buffer Mitigation Credits & Nutrient Offset Credits for
Riparian Projects Regulated under 1 SA NCAC 02B .0295 and 15A NCAC 02B .0240
This letter, and the included attachments, outlines procedures and provides guidance for calculating
buffer mitigation credits and nutrient offset credits for projects submitted to the Division of Water
Resources (DWR) for review. In March 2019, the DWR established a small Work Group ("Group")
consisting of 7 people to discuss crediting inconsistencies for nutrient offset and buffer mitigation
projects. The Group consisted of 3 staff members from DWR, two staff members from the Division
of Mitigation Services, and one representative from each of two private mitigation banks. The
procedures and guidance provided in this Ietter were made by consensus from the Group for
implementing 15A NCAC 02B .0295 ("Rule .0295") and 15A NCAC 02B .0240 ("Rule .0240).
These procedures are for implementing buffer mitigation or nutrient offset projects where a
draft mitigation plan or a draft Bank Parcel Development Plan (BPDP) is submitted to the
DWR for review after the date of this letter. All other projects must comply with mitigation
plans and BPDPs submitted to DWR for review prior to the date of this letter.
A summary of the issues resolved by the Group and associated guidance for credit calculations are
detailed in Attachment A "Issues and Resolutions Ver 1.0 — Buffer Mitigation & Nutrient Offset".
For further information regarding this correspondence, please contact Katie Merritt with DWR at
katie.merritt(aincdenr.gov or by phone at 919-707-3637.
Attachments: A, B, C, and D
Sincerely,
c7-AA
Jitxl Gregson
Deputy Director, Division of Water Resources
5Q North Carolina Department of Environmental Quality 1 Division of Water Resources
5t2 North Salisbury Street 1 1G17 Mail Service Center 1 Raleigh. North Carolina 27699 Ibt7
NOp'H LAli011
oi..u,we..daaw 919.707.9000

Attachment A
Issues and Resolutions Ver 1.0 - Buffer Mitigation & Nutrient Offset November 21, 2019
Issue #1: Procedure for crediting mitigation activities within riparian areas for buffer
mitii2ation and nutrient offsets.
Applying ratios and reductions under 15A NCAC 02B .0295 (m) and (n) respectively for buffer
mitigation credit, while also applying the DWR-Methodology and Calculations for determining
Nutrient Reductions associated with Riparian Buffer Establishment
https:I/files.nc.gov/ncdeq/Water%20Quality/Planning,NPU/Nutrient%20Qf]set%2ORu/e1A.-Bulfer-
Credit.pdf often leads to differences in measuring and accounting. Establishing procedures on how
credits are measured, calculated, converted and presented in mitigation plans involved addressing
inconsistencies and creating guidance on rounding, significant digits, units of measurement, as well
as developing credit ratios and conversion ratios.
Resolution: Established (a) guidance for rounding & decimal places, (b) guidance for physical
measurements, (c) buffer mitigation credit ratios, (d) credit conversion ratios, (e) formula for credit
conversions, and (f) a format for presenting credits.
a) Established guidance for rounding and decimal places. See Table 1.0
Table 1.0 — Guidance for Rounding
Physical
Measurements
Credit Ratios &
Credit Conversion
Ratios
Credits
'Nutrient Effectiveness for
Phosphorus & Nitrogen
Round to nearest whole
number
Round to 5 decimal
places
Round to 3 decimal places
Round to 2 decimaI places
Example:
1,452.6424 ft2 = 1,453 ft2
Example:
6.06061444 = 6.06061
Example:
49,625.4876 ft2 = 49,625.488 ft2
Nitrogen: 2,273.02 lbs/ac/30yrs
Phosphorus:146.40 lbslac130yrs
DWR-Methodology and Calculations for determining Nutrient Reductions associated with Riparian Buffer
Establishment hftps:/Ifiles.nc.gov/ncdeq/Water%20Quality/Planning/NPU/Nutrient%20Qfset%2ORule/Ag-Buffer-
Creditpdf
b) Established guidance for physical measurements. See Table 2.0
Table 2.0 — Guidance for Physical Measurements
Credit Type
'Mitigation Activity
Unit of
Measurement
Guidance
Riparian Buffer
Riparian RIEIPIEx
Square Foot
Measure area and
round to the nearest
whole number
Nutrient Offset
(Nitrogen)
Riparian RJE
Square Foot
Measure area and
round to the nearest
whole number
Nutrient Offset
(Phosphorus)
Riparian RIE
Square Foot
Measure area and
round to the nearest
whole number
R= Restoration, E= Enhancement (not cattle exclusion), Ex=Enhancement for permanent
exclusion of grazing livestock, P= Preservation
Page 2 of 8

Attachment A
Issues and Resolutions Ver 1.0 - Buffer Mitigation & Nutrient Offset November 21, 2019
c) Established a buffer mitigation credit ratio for each scenario under 15A NCAC 02B .0295
(m) and (n). See Table 3.0
Table 3.0: Buffer Mitigation Credit Ratio
Location
Buffer
Subjectivity
'Mitigation
Activity
2AWRStream
Buffer Max
Buffer Width
(ft)
3lnitial
Unit
Ratio
(x:1)
4%
Full
Credit
`Final Credit
Ratio (x:1)
Riparian
Buffer Credit
(fta )
N/A
N/A
R,E and P
<20
0
0
0
Credits (f2)
rounded up to
3 decimal
planes
N/A
N/A
R
20-29
I
75%
1.33333
N/A
N/A
R
30-100
l
100%
1.00000
N/A
NIA
R
101-200
1
33%
6.06061
N/A
N/A
E, Ex
20-29
2
75%
2.66667
N/A
N/A
E, Ex
30-100
2
100%
2.00000
N/A
N/A
E, Ex
101-200
2
33%
6.06061
Rural
Subject
P
20-29
10
75%
13.33333
Rural
Subject
P
30-100
10
100%
10.00000
Rural
Subject
P
101-200
10
33%
30.30303
Rural
Non -Subject
P
20-29
5
75%
6.66667
Rural
Non -Subject
P
30-100
5
100%
5.00000
Rural
Non -Subject
P
101-200
5
33%
15.15152
Urban
Subject or Non-
Subject
P
20-29
3
75%
4.00000
Urban
Subject or Nan
Subject
P
30-100
3
1 QD°/°
3.00000
Urban
Subject or Non-
Subject
P
101-200
3
33%9.0909i
1 R= Restoration, E= Enhancement (not cattle exclusion), Ex=Enhancement just for permanent exclusion of grazing livestock, P=
Preservation,
2311 minimum physical measurement ranges of riparian widths are measured landward and perpendicular from top of bank and
assumed to be continuous with top of bank without breaks
Derived from 15A NCAC 02B .0295 (m)
"Derived from 15A NCAC 02B .0295 (n).
5 Combining initial ratios in Rule .0295 (m) with physical measurements and corresponding credit reductions in Rule .0295 (n)
Page 3 of 8

Attachment A
Issues and Resolutions Ver 1.0 - Buffer Mitigation & Nutrient Offset November 21, 2019
d) Established credit conversion ratios for Nitrogen and Phosphorus to simplify the conversion
of buffer mitigation credits (square feet) into nutrient offset credits (pounds) where credits
are deemed by DWR as being eligible for either credit type. See Tables 4a and 4b.
Table 4a: Nutrient Offset Credit Conversion Ratio (CCR) in Square Feet per Pound without Delivery Factors
'Service Area
River Basin/WS and Hydrologic
Unit Code
z Mitigation
Activity
2Min-Max
riparian
Width (ft)
Initial
Unit
Ratio
(x:Ij
4Nitrogen
CCR
(ft2/pound)
'Phosphorus
CCR
(ft2/pound)
NutrientCr
Offset Credits
(lbs)
Cape Fear — Randleman
N/A
N/A
N/A
N/A
NIA
Credits (lbs)
rounded up to
3 decimal
places
Catawba
R & E
NIA
NIA
N/A
NIA
Neuse- 03020201 (Lower Falls
Lake, Upper Falls Lake, Outside
Falls Lake), 03020202, 03020203,
Neuse 03020204
R
50-240
1
19.16394
N/A
E
50-200
2
9.58197
N/A
Tar -Pamlico- 03020101, 03020102,
03020103,03020104,03020€05
R
50-200
l
19.16394
297.54099
E
50-200
2
9.58197
148.77050
Yadkin — Goose Creek
N/A
N/A
NIA
N/A
NIA
service area is defined in I5A NCAC 02B .0240 and G.S. 143-234.26
2R= Restoration, E= Enhancement (not cattle exclusion)
2Al€ minimum physical measurement ranges of riparian widths are measured landward and perpendicular from top of bank and
must be contiguous with top of bank
4DWR-Methodology and Calculations for determining Nutrient Reductions associated with Riparian Buffer Establishment
https:/ /es.nc.trov/ncdeq/Water%2OQualitiJPIanning/NPU/Nutrietrt%2OOfser%20Ride/Ag-Bufir-CredrtpdJ'
Page 4 of 8

Attachment A
Issues and Resolutions Ver 1.0 - Buffer Mitigation & Nutrient Offset November 21, 2019
Table 4b: Nutrient Offset Credit Conversion Ratio (CCR) with Delivery Factors
Credit Generated [1bs/30
Jordan Subwatershed
Nitrogen
Phosphons
Cape Fear - Jordan Haw
2,249.360
143.810
Cape Fear - Jordan Upper New Hope
2,169.260
143.810
Cape Fear - Jordan Lower New Hope
2,273.020
146.400
Jordan 5ubwatershed Watershed !D
Delivery
Factors
TN
Dedvery
Factors
TP
Nitrogen
CCR
(sf/pound]
to 5th derimaf
Phosphorus
ccR
lsf/pound)
Cape Fear •Jordan Haw 03030002010010
Cape Fear - Jordan Haw 03930002010020
Cape Fear - Jordan Haw 03030002010030
Cape Fear - Jordan Haw 63030002010040
Cape Kear- Jordan Haw 03030002010050
Cape Fear -Jordan Haw 03030002020010
Cape Fear Jordan Haw r03030002620020
Cape Fear -Jordan Haw 1133030002020030
Cape Fear -Jordan Haw 03030002020040
Cape Fear -Jordan Haw 03030002020050
Cape Fear -Jordan Haw `3030002020060
Cape Fear -Jordan Haw 03030002020070
Cape Fear -Jordan Haw 03030002039010
Cape Fear -Jordan Haw r03039002030020
Cape Fear -Jordan Haw r0303000203003D
Cape Fear - Jordan Haw 03030002030040
Cape Fear • Johan Haw 03030002030050
Cape Fear -Jordan Haw 03030002030060
1
Cape Fear -Jordan Haw �03030002030Q7Q
Cape Fear -Jordan Haw 03030002030080
Cape Fear - iordarnHaw 03030002040010
Cape Fear -Jordan Haw 03030902040020
Cape Fear - Jordan How 03030002040030
Cape Fear -Jordan Haw 03030002040040
Cape Fear• Jordan Haw r03030902040050
Cape Fear -Jordan Haw 03030002040060
r
Cape Fear -Jordan Haw 03030002040070
Cape fear -]orlon Haw 03030002040060
Cape Fear -Jordan Haw 03030002040090
CapeFear- Jordan Haw 03030002040100
Cape Fear •Jordan Haw 03030032040110
Cape Fear - Jordan Haw 03030002050610
Cape Fear -Jordan Haw 03030902050020
Cape Fear - Jordan Haw 03030002050030
Cape fear -Jordan Haw 03030002059040
CapeFear-Jordan Haw 03030002050050
CapeFear- Jordan Haw 03030092050060
CapeFear- Jordan Haw 03030002050070
Cape Fear - Jordan Haw 03030002050080
Cape Fear -Jordan Haw 03030002050090
Cape fear - Jordan Haw 03030002050100
Cape Fear - Jordan Haw 93630002060010
Cape Fear - Jordan Haw 03030002060020
Cape Fear - Jordan Haw 03030902060030
Cape Fear -Jordan Haw 03030902060040
03030002060050
03030002060062
03030002060070
03039002069080
03030002060100
03030002060110
03030002060120
03930002060140
03030002066130 .
03030002060160
03030002060090'
03030002060090'
03030002060060'
03930002060060'
03030002060150'
Cape Fear - Iordan Haw
Cape Fear -Johan Haw
Cape Fear - Jordan Upper New Hope
Cape fear - Jordan Upper New Hope
Cape Fear - Jordan Upper New Hope
Cape Fear - Jordan Upper New Hope
Cape Fear - iordan Upper New Hope
Cape Fear - Jordan Upper New Hope
Cape Fear - Jordan Upper New Hope
Cape Fear -Johan Lower New Hope
Cape Fear •Jordan Upper New Hope
Cape Fear - Jordan Lower New Hope
CapeFear- Jordan OpperNew Hape
Cape Fear - Jordan Lower Alew Hope
Cape Fear - Jordan Upper New Hope
Cape Lower New Hoe 03030002060150'
p P
25%
37%
44%
49%
55%
15%
22%
48%
32%
32%
47%
54%
60%
44%
25%
42%
64%
3995
36%
73%
30%
28%
71%
32%
52%
54%
67%
53%
54%
75%
66%
74%
81%
42%
80%
71%
79%
78%
80%
79%
81%
8195
95%
88%
97%
92%
98%
40%
59%
69%
61%
69%
85%
69%
85%
92%
92%
9495
94%
88%
88%
10%
36%
4095
44%
48%
4%
12%
43%
33%
32%
42%
47%
56%
31%
8%
30%
622%
19%
18%
64%
14%
14%
63%
15%
50%
51%
60%
51%
51%
65%
6095
68%
74%
17%
73%
67%
73%
7256
73%
73%
75%
74%
97%
91%
98%
95%
99%
1995
45%
63%
58%
63%
89%
63%
90%
94%
94%
96%
96%
91%
91%
77.4620,
52.3392]
44.01257
39.5214!
35.2100:
129.10339
88.0250,
40.34483
60.5172;
60.5/72;
41.20323
35.8620E
32.27585
44.0125;
77.4620d
46.10836
30.25861
49,6551!
53.7930E
26.5281C
64.55170
69.1625, 2,163.569r
27.27531 480.7931
60.5172; 2,019.3310
37.24131 605.7993
35.8620E 593.9209
28.90375 504.8327
36.53870 593.9209
35.86206 593.9209
25.8206f 465.9994
29.3416£ 504.8327
26.1695] 445, ' 1.
23.90804 409.3238
46.1083E 1,781.7627
24.20689 414.9310
27.27537' 452.0890
24.51331 414.9310
24.8275£ 420.6939
24.20685 414,9310'
24.51331 414.93/0'
23.90804. 403.8662
23.90804 409.3238
20.38475 312.2676'
22.00626 332.8567
19.9644f 309.0812
21.04947 318.8417'
19.7607; 305.9592
50.2014E 1,594.2087-
34.03489 673.1103;
29.10230 480.7931
32.91899 522.2408
29.1023E 480.7931
23.6242: 340.3367
29.10234 480.7931
22.54581 330.60111
21.82677 322.2336
20.83037, 316.5329
21.3623; 315.5204
20.3871; 309.9385
22.81883 332.8567
21.7772E 325.9681
3,028.9966,
841.3879'
757.2491'
688.4083;
631.04091
7,572.4914!
2,524.1638.
704.4178:
917.8777!
946.5614,
721,1896:
644.4673:
540.8922!
977.0956E
3,786.2457!
1,009.6655,
488.54784
1,594.2087,
1,682.77585
473.2807
2,163.569
Page 5 of 8
' Watershed is located In both the Upper New Hope WNW and Lower New Hope l LNHI Subwatersheds.

Attachment A
Issues and Resolutions Ver 1,0 - Buffer Mitigation & Nutrient Offset November 21, 2019
e) Establish a formula for credit conversions. See Table 5.0
Table 5.0 Calculation Formula for Credit Conversions
Credit Type
'Mitigation
Activity
'Credit Conversion Formula
(Quantity/Credit Conversion Ratio—X)
Final Project
Credits
Riparian Buffer
Riparian
RIEIPIEx
Creditable Area (ft2) - Final Buffer Credit Ratio = X
ft2 buffer credits
rounded up to
3 decimal
places
Nutrient Offset
(Nitrogen)
Riparian RIE
Total Area (ft2) - Credit Conversion Ratio ft2/ lb-N =
X lbs-N
Nutrient Offset
(Phosphorus)
Riparian RIE
Total Area (112) - Credit Conversion Ratio ft2/ lb-P =
X lbs-P
'R= Restoration, E= Enhancement (not cattle exclusion), Ex —Enhancement just for permanent exclusion of grazing
livestock, P= Preservation
2 A user-friendly tool has been developed in conjunction with this memo to assist in entering a project's credits.
This tool is referenced in Issue #1 (f) of this memo.
f) Developed a format for presenting credits in project plans submitted to the DWR. The
"Project Credit Table" template is a user-friendly "calculation tool" to calculate a project's
riparian buffer and nutrient offset credits and is designed to comply with Rule .0295, Rule
.0240, and the guidance provided in this letter. The calculation tool is useful and
recommended, and is intended to increase efficiency in the review process. A link to the
most up-to-date calculation tool is found at https://deq.nc.Rov/about/divisions/water-
resources/water-quality-permitting/401-buffer-permitting-branchlnutrient and a screenshot is
included in Attachment B. A set of instructions for using the calculation tool is included in
Attachment C.
?age 6iof 8

Attachment A
Issues and Resolutions Ver 1.0 - Buffer Mitigation & Nutrient Offset November 21, 2019
EXAMPLES
Example A- Calculating Buffer Credits on Agricultural land within 0-100' riparian width: Using
Tables 1.0-5.0 included in this memo, and the Project Credit Table referenced in (f) below, the
following example is provided:
A total creditable area of 2.2 acres (95,832 ft2) of agricultural land within top of bank to 100 feet
adjacent from the Neuse River is approved for riparian restoration ("R"). The site will yield the
following buffer credits:
Project Credit Table
Nt .0 2Qi01.Ooade Fall' Lake
19.18 394
Y•'A
vice Area
,N trail Ram (tl/ ridit}
P Credit Ratio (s1/1Iedi[i
Grdir TRH
Eras -
l001tron
Ayr.'
ter
feaha. Type
/P
lfrt 1841i0l ArtlH{y
Raneri41er.
WAS. Pei
0.100
Feature Rama
TOW Ana
Nei sa RAyer
95,832
95.132
rut lcredll
1.1da (4:11
f{Faq 01011
Final Cred11
latu 1441)
Convertible
10.880arNin
■as
Rip.rlwa WSW
Crmir
95.832. �0
Instead ()fusing the Project Credit Table above, one can enter the formula from Table 5.0 as follows:
Creditable Area (ft) ÷ Final Credit Ratio = X ft2 buffer credits
95,832 ft2 (1.0 x 100%) = 95,382.000 IA' buffer credits
Example B- Calculating Nutrient Offset Credits from Example A
Using Tables 1.0-5.0 included in this memo, and the Project Credit Table referenced in (f), the
following example is provided:
Project Credit Table
Naure 0102030 i-04trn. rare. 4.4.
19 19394
4
Serrke Pea
9 Grdn Retie fsl fveddi
P hedh Raga fsgnMlq
kklireti
apnMufy a.
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eYna1.a.40m
Fr rwlr 9.
Ted A ..144
sew
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Ares 0FO.__.
> M
VAIN G14e
Rrve i..11
A FW I LMR
iYW C.adl.
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m 4104.144
a.e.r!
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14 N.914•111
N64.14n11}14a4
Yet
1/9
aarmrarier
0.100
140 12
Tar
951182 091
*a1
5.1�] E+:
Instead of using the Project Credit Table above, one can enter the formula from Table 5.0 as follows:
Total Area (ft2) ÷ Credit Conversion Ratio ft2/ Ib-N = X lbs-N
95,832 ft2 - (19.16394 ft2 /lb-N) = 5,000.642 lbs-N nutrient offset credits
Page 7of8

Attachment A
Issues and Resolutions Ver 1.0 - Buffer Mitigation & Nutrient Offset November 21, 2019
Issue #2: Clarifications to DWR response to Item I. of the March 10, 2017 memorandum to
DMS from DWR titled "DWR Responses to Questions from DMS regarding implementation of
the Consolidated Buffer Mitigation Rule (15A NCAC 02B)" provided in Attachment D.
DWR issued a memo to DMS on March 10, 2017. Item I of this memo clarifies how to calculate the
25% of the total area of buffer mitigation cited under 15A NCAC 02B .0295 (o)(4), (o)(5) to achieve
the allowed amount of preservation area. Examples on how to calculate the Total Area of Buffer
Mitigation (TABM) and the Eligible Preservation Area (EPA) are included. However, the memo
does not address when applicable credit ratios and credit reductions provided in 15A NCAC 02B
.0295 (m) and (n) should be applied to the TABM to achieve the EPA.
Clarification: To achieve the EPA, the TABM is calculated by measuring the area of Restoration
(R) and Enhancement (E) before applying any credit ratios and credit reductions provided in 15A
NCAC 02B .0295 (m) and (n).
Example: [2 acres (R) + 1 acre (E)] / 0. 75 = 4 acres (TABM)
4 acres (TABM) * 0.25 =1 acre (EPA)
1 acre (P) + 3 acres (RIE) = 4 acres total
Page 8 of 8

Attachment 6
Project Credit Table
Meuse 03020201 - Outside Fa
Feature Name
gt
5
Mitigation Totai
Enhancement
Preservation:
Total Riparian Buffer;
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ed as subject according to ISA NCAC 52B. D250 Maj.
The Randleman Lake buffer rules allow some di rc hes to

Attachment C
Project Credit Table Instructions
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Water Resources
(-NVIRONPi [141 AL QUALIP
Attachment D
March 10, 2017
ROY COOPER
MICFIAEL S. REGAN
S. JAY ZIMMERMAN
MEMORANDUM
To: N.C. Division of Mitigation Services
From: 5. Jay Zimmerman, N.C. Division of Water Resources Director
Subject: DWR Responses to Questions from DMS regarding implementation of the
Consolidated Buffer Mitigation Rule [15A NCAC 02B .0295]
On November S, 2016, the Division of Mitigation Services (DMS) met with the Division of Water
Resources (DWR) to discuss questions they had regarding implementation of the Consolidated
Buffer Mitigation Rule [15A NCAC 0213 .0295]. Below is a short summary of each question and
DWR's response.
I. Calculation of "25% of the Total Area of Buffer Mitigation"
15A NCAC 02B .0295 (o) (4) and (5) state "The area of preservation credit within a buffer
mitigation site shall comprise of no more than 25 percent of the total area of buffer mitigation."
DMS believes the following calculations should be used to determine the area eligible for
preservation:
Restoration (R) + Enhancement (E) + Preservation (P) = Total Area of Buffer Mitigation (TABM)
TABM * 0.25 = Eligible Preservation Area (EPA)
Example: 2 acres (R) + 1 acre (E) + 7 acres (P) = 10 acres (TABM)
10 acres (TABM) * 0.25 = 2.5 acres (EPA)
Response:
In the example above, 45% of the area of the site would come from preservation, with the
remaining 55% corning from restoration/enhancement:
2.5 acre (P) + 3 acres (R/E) = 5.5 acres total
Based on a review of the language in the rule, the documents throughout the rulemaking
process, including correspondence with OSBM on the fiscal note, areas where buffer
mitigation credits are not being generated Should not be used to calculate the "total area of
buffer mitigation."
The restoration or enhancement area shall be at least 75% of the area generating buffer
mitigation; the remaining 25% of the area generating buffer mitigation can be preservation:
75% (R/E) + 25% (P) = 100% TABM
Stele of North Carolina 1 Environmental Quality Water Resources
1517 Mail Servicc ('enter I Raleigh, North Carolina 27699.1617
919 807 ,300

Page2of3
To calculate the area eligible for preservation:
[Restoration (R) + Enhancement (E)] / 0.75 = Total Area of Buffer Mitigation (TABM)
TABM * 0,25 = Eligible Preservation Area (EPA)
Example: [2 acres (R) + 1 acre (E)] / 0,75 = 4 acres (TABM)
4 acres (TABM) * 0.25 = 1 acre (EPA)
1 acre (P) + 3 acres (RJE) = 4 acres total
II. Defining Breaks Between Restoration and Enhancement Areas
DMS asked for clarification on how DWR defines the breaks between restoration' and
enhancement2. Specifically, DMS asked whether drip lines were still used and whether
individual trees were excluded from restoration sites.
Response:
DWR has not considered the drip line to represent the outer edge of a wooded area for
several years. This was clarified in a memo from DWR to DMS in August 2013. Individual
trees do not need to be delineated and removed from the restoration area, rather DWR
looks for areas or zones when determining restoration, enhancement or preservation areas.
For example:
characterized by an absence of trees and by a lack of dense growth of smaller woody stems or
are characterized by scattered individual trees such that the tree canopy is less than 25% of the
cover and by a lack of dense growth of smaller woody stems
characterized by conditions between that of a restoration site and a preservation site such that
the establishment of woody stems will maximize nutrient removal and other buffer functions

Page 3 of 3
III. Prior Grazing
15A NCAC 02B .0295 (o)(6) describes enhancement of grazing areas adjacent to streams. It
states that the applicant or mitigation provider shall demonstrate that grazing was the
predominant land use since the effective date of the applicable buffer rule. DMS asked
when is the predominance of grazing demonstrated?
Response
15A NCAC 02B .0295 (1) states that the authority shall issue a mitigation determination that
specifies the area, type and location of the mitigation and the water quality benefits to be
provided by the mitigation site. During the on -site evaluation, DWR looks at existing
conditions to determine whether grazing has been a continuous land use in the proposed
mitigation area (e.g. hoof shear, manure, cattle fencing, etc.) since the effective date of the
applicable buffer rule. DWR also evaluates satellite imagery. If it is not clear to DWR that
grazing has been the predominant land use since the effective date of the applicable buffer
rule, ❑WR will ask for additional documentation (e.g. landowner documentation, photos,
maps, etc.).
If the grazing site is proposed for retroactive credit as described in 15A NCAC 0213 .0295
(o)(1), additional documentation of the pre-existing conditions may be required.
If there is a disagreement regarding the documentation requested by DWR, the request will
be elevated to the Water Quality Permitting Section Chief.
IV. Clarification of Use of 8-19-08 Diffuse Flow Clarification Memo
DMS asked for verification that the Buffer Interpretation Clarification Memo #2008-019,
issued August 19, 2008, was still eligible for use, and whether that method or an alternative
method as provided for in the rule could be used at the discretion of the project proponent.
Response:
The Suffer Interpretation Clarification Memo #2008-019, issued August 19, 2008, is still
eligible for use to comply with 15A NCAC 02B .0295 [lj{3).

From: Merritt. Katie
To: Ray Holz
Subject: Buffer Subjectivity-Ag Ponds -Raleigh Farms
Date: Friday, September 10, 2021 11:42:57 AM
Attachments: 20191692 Ver 4 Draft BPDP-Raleigh 20201224.pdf
Hey Raymond,
This email serves to acknowledge that two (2) in -line ponds associated with the Raleigh Farms A Site
& Raleigh Farms B-C Site are considered "not subject" to the Neuse Buffer Protection Rules due to
the fact that they are agricultural ponds and are therefore "exempt" from that Rule under Session
Law 2013-413 Section 52. Pond 5 on the Raleigh Farm B-C site and Pond 2 on the Raleigh Farm
A site are both "not subject" and therefore shall be referred as such in any Bank Parcel Development
Plans (BPDP) and corresponding Figures/Credit Tables submitted with the Plans. A site plan attached
to this email shows the ponds referenced above.
Thank you for you attention to this matter,
Katie

Appendix C: USDA, NRCS Web Soil Survey Report (full report available upon request to DWR)
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201 Appendices

Raleigh Farm Bank Parcel
8300 State Rd 2542
Raleigh, NC 27610
Inquiry Number: 6199177.2s
September 21, 2020
The EDR Radius Map TM Report with GeoCheck®
('E DR�
6 Armstrong Road, 4th Floor
Shelton, CT 06484
Toil Free: 800.352.0050
www.edmet.com
FORM-LBE-CCA

Appendix F: NC NHP and NC SHPO Correspondence
Raleigh Farm — Phase A Bank Parcel Development Plan (2019-1692 V4)
Neuse River Basin 8-Digit HUC: 03020201 Appendices

■ ■■■
w E NC DEPARTMENT OF
■ ■e■■ NATURAL AND CULTURAL RESOURCES
■ ■■■
Allison Keith
Axiom Environmental
218 Snow Ave
Raleigh, NC 27603
I-2E: Raleigh Parm Nutrient Site; 20-021
Dear Allison Keith:
Roy Cooper, Governor
Susi Hamilton. Secretary
Walter Clark. Director, Land and Water Stewardship
September 4, 2020
NCNHDE-12821
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
A query of the NCNHP database indicates that there are records for rare species, important natural
communities, natural areas, and/or conservation/managed areas within the proposed project
boundary. These results are presented in the attached 'Documented Occurrences' tables and map.
The attached `Potential Occurrences' table summarizes rare species and natural communities that
have been documented within a one -mile radius of the property boundary. The proximity of these
records suggests that these natural heritage elements may potentially be present in the project area
if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one -mile
radius of the project area, if any, are also included in this report.
If a Federally -listed species is documented within the project area or indicated within a one -mile
radius of the project area, the NCNHP recommends contacting the US Fish and Wildlife Service
(USFWS) for guidance. Contact information for USFWS offices in North Carolina is found here:
https://www.fws.gov/offices/Directory/ListOffices.cfm?statecode=37.
Please note that natural heritage element data are maintained for the purposes of conservation
planning, project review, and scientific research, and are not intended for use as the primary criteria
for regulatory decisions. Information provided by the NCNHP database may not be published
without prior written notification to the NCNHP, and the NCNHP must be credited as an information
source in these publications. Maps of NCNHP data may not be redistributed without permission.
Also please note that the NC Natural Heritage Program may follow this letter with additional
correspondence if a Dedicated Nature Preserve, Registered Heritage Area, Clean Water
Management Trust Fund easement, or an occurrence of a Federally -listed species is documented
near the project area.
If you have questions regarding the information provided in this letter or need additional assistance,
please contact Rodney A. Butler at rodney.butler@rlcdcr,gov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPARTMENT of NATURAL AND CULTURAL RESOURCES
QO 121 W. JONES STREET, RALEIGH. NC 27603 • 1651 HAIL SERVICE CENTER, RALEIGH, NC 27E00
OFC 919.707.9120 • FAX G19.707.9121

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