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HomeMy WebLinkAbout20191692 Ver 4_BPDP for PN_20210928Mitigation Project Information Upload ID# * 20191692 Select Reviewer:* Katie Merritt Version* 4 Initial Review Completed Date D9124/2021 Mitigation Project Submittal - 9/24/2021 1s this a Prospectus, Technical Proposal or a New Site?* C Yes r No Type of Mitigation Project:* r Stream r Wetlands Pr Buffer rJ Nutrient Offset (Select all that apply) Project Contact Information Contact Name:* Raymond Holz Project Information ID#:* 20191692 Existing IGVt Project Type: Project Name: County: [' DMS r' Mitigation Bank Raleigh Farm Phase A Wake Document Information Mitigation Document Type:* Mitigation Plans File Upload: Signature Print Name:* Signature: * Email Address:* rholz@ restorationsystems.com Version:*4 Existing Version 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 hjenkins@restorationsystems.com 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 w N x a Wake GoanEy, NC 0 -z W¢y = F fX YWQ ZWW qy LL SEPT 2021 0 0 Temporary Consetction Easement Permanent Easement ( C 1 4 0 2 - "ZE :71 -u -0 Wake County, NC imy6rry; 2617 NC OneMap 2 SEPT 2021 0 \ th Wake County, NC 2 cry: 2617 NC One1106p k 2 csi \ 66 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 shelton.sullivan@ncdenr.gov 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 rholz@restorationsystems.com Barrett Jenkins via email blenkins@restorationsystems.com Katie Merritt via email katie.merritt@ncdenr.gov 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 (919) 707-3637 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 katie.merritt@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Holder: Katie Merritt 9/24/2020 1:23:15 PM katie.merritt@ncdenr.gov Location: ❑ocusign Signer Events Signature Timestamp Katie Merritt katie.merrit-t@ncdenr.gov 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 Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Certified Delivered Signing Complete 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 katie.merritt@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Holder: Katie Merritt 9/25/2020 9:44:33 AM katie.merritt@ncdenr.gov Location: ❑ocusign Signer Events Signature Timestamp Paul Wojoski Docu37ned by' Paul.Wojoski@ncdenr.gov 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 In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Certified Delivered Signing Complete Completed HashedlEncrypted Security Checked Security Checked Security Checked 9/25/2020 9:45:17 AM 9/25/2020 1:56:05 PM 9/25/2020 1:56:15 PM 9/25/2020 1:56:15 PM Payment Events Status Timestamps Barrett Jenkins i From: Sent: To: Cc: Subject: Follow Up Flag: Flag Status: Barrett, Saunders, Erickson G <Erickson.Saunders@ncdenr.gov> 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 (919) 707-3659 Office erickson.saunders@nccienr.gov From: Barrett Jenkins[mailto:bjenkins@restorationsystems.comj Sent: Monday, May 17, 2021 6:26 PM To: Saunders, Erickson G <Erickson.Saunders@ncdenr.gov> Cc: Merritt, Katie <katie.merritt@ncdenr.gov>; Thornburg, Nathaniel<nathaniel.thornburg@ncdenr.gov>; 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 <Erickson.Saunders@ncdenr.gov> Sent: Friday, March 26, 2021 3:16 PM To: Merritt, Katie rkatie.merritt@ncdenr.gov>; Barrett Jenkins <bienkins@restorationsystems.comp Cc: Thornburg, Nathaniel<nathaniel.thornburg@ncdenr.gov> 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 erickson.saunders@ncdenr.gov From: Merritt, Katie Sent: Friday, March 26, 2021 2:30 PM To: Barrett Jenkins<bienkins@restorationsystems.com>; Saunders, Erickson G ¢Erickson. Saunders@ncdenr.gov> Cc: Thornburg, Nathaniel cznathaniel.thornburg@ncdenr.gov> 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<blenkins@restorationsystems.com> Sent: Friday, March 26, 2021 11:24:51 AM To: Saunders, Erickson G <Erickson.Saunders@ncdenr.gov> Cc: Merritt, Katie <katie.merritt@ncdenr.gov>; Thornburg, Nathaniel<nathaniel.thornburg@ncdenr.gov> 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. 44121.01 Fart.re iyaa 18141p0on Aemiq eYna1.a.40m Fr rwlr 9. Ted A ..144 sew I[r.d'rktr1 Ares 0FO.__. > M VAIN G14e Rrve i..11 A FW I LMR iYW C.adl. WO 1=11 m 4104.144 a.e.r! 111/444. aril.. Crrda Comerew. 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; ro- lb c Mitigation Totais 3 z w i t l 9 a m � e C. ..1 a =r 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 The ❑ _ `m w o x ro X n r ❑. J❑ c w ❑ a 0 = E.� a m LI ! d a EE m x A ill 4,U C 5 c j w u' w C .m Y 0. D caT c m O❑N CF ❑ i w 'pJ E .0 Y m a yw aU rV . CIs ❑ m E Ati . r 3w 0 . r m a A E A H w cg a 0 , • �'�= v.t a a, $ n" o or _ .• . w c° a s a m 'o 8 1 v a' " w Kt m m m in u u d E duri E c E -w •.c u �di c b iv O r. t-. c S a° o a m o m g 0 ...2 Z" E 4 w a m m 5'i .2 T = 4, c .2cmw a aG 2 a a d ov E 5 a E c 8 p c m 'g _ ' Y 3$° y gg ma " 0° a o .A Z YauE'L3 a 2c ° ymqA w❑ V b y e. a a ° = U a vo oy C" ,s N 6 1 c' ❑ 42 h 2.,w E F° ❑- w •3 A p II a i ❑ E-2 V d C ❑ Q a Q Q 3 ._ 4T1 CI -4J IS ?+❑ c g3 ii o aoa c o Har £ a E "t ro a cm = ❑ w m3ty-w w 3 vm c 4 8 74A E 1 ❑_ u a4 N itu ' F- an cm ^ m £ o m w as ,1 15 a' E F 4-- Ca O Cpp m 7 3 _ z.ra�N, c a E 2 a c ay -t m e _, t a P. o o m u a u E. .. —❑ >- ❑aa m cc, L ..,2- Y3❑ r ayc 5 T A v u. = m m ct - ai w A y an d ❑ -0 .c m aQ oa my a += _w m❑ � g sm a °'6crl ° µ.20. w-5❑' ' dEcm w a ro Q❑ la w a m .E a �i w71-' w❑ u a .� gj a V° = IC 0 fl O N G- ° A w m j a5i O o c m c. r m E 4 w m a c m 17 m m ro d w ,l77,1 N F— E m 2 w p m° 4' Jo '}7 i+ u ° u c r m a E c c u O b m C 7 ❑ au. +tea _.Y 3 j ti m 3 E ti $ d E m E g= a m c a$ w w •, ' Z! a t v 1 w aci c 1. a y 3 ry+ m E1 y w" .�,. Iv •3 c e 'i = r m r pp 2 o m w ip r y a 3.2 E f, T ❑ I-• -0 A � . a a�a. a`❑i ❑ C y V ❑ 2 w F- Y m ry g _ C C ❑ ❑ F wE. E- P A _ " H a a£ a a a ° 3 E Y N 'p D. R' N un ✓! F Y * a II- _ 3 is N u O M N [.7 N .D P. vp 06 a a w p .a E EL 5 u 2 a 4' N R N ;,°, �o o .6w ' m �v ws 4 on = ro 2 c a 2- 2 E 3 E v a' 2 �' o a a0 8 m —° C a ❑ a N ❑ E n w d tl c 0 F 0 ❑ =o a A` ❑ a N a u 4' w =i� « rl c ❑Q• ° m E o 0 C ro „.7 p y •❑ N c w o i ❑ m $ E : C p d C '�po a a i0 2 E iv E ❑ ❑ a y c a N - p m OM1,,. ` N N N 0 Y a w H :a 11 I I l a CC u o V 3 w c w d t Z 6 Q m o ui ETo `u E A � c z o M [j .A $ m 3 _c a E m u c E _ u E ° d , a ro E �• o � a a } m c .2 o a o -`,0 m m y y Y = w C = m � p � � 0 t o o v 0 im ❑ O C O p d m m •v+ O 0 N 0 E a ry ' c 3 % N Lm d ry E Q N a E E m o° a-�. C t a01 L w L 4 A E E C w E c m �° �pp v ! `f �' iy _ E A 19 !6 d0 to E GC t E 2.a m .V+ L av-. c a a 2 a w m .e ❑ ry ti v d � w .43 al d E vi .•I ❑i E .-i i .0 E CV3 V 0 m m as A ❑ c U 0. m 7 U 2 6 44. ', ry ' ui m v ch 5 m & n: ry O V oa 4 ry N A ° E o T c v C P 4D w N 3 2 .. c w L a 2 z C ❑ ❑ .E E� al w - 4' C 'Z = C � m a 0 ❑ _ m E v Q a m .Q a z o p 0 w o •� ❑ ❑ { .` v L '5 06 _w 7 T 0 2 d m m ! y re 40 o Alternative 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. 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