20201225 Ver 2_Elm Grove INCOMPLETE Comment Response from RS_20211005

From: Merritt, Katie
To: "Barrett Jenkins"
Cc: Wojoski, Paul A; "Ray Holz"
Subject: Elm Grove Comment Response from RS
Date: Tuesday, October 5, 2021 2:40:00 PM
Attachments: DWR Comment Summary - ElmGroveBPDP.pdf
Hey Barrett,
On July 19, 2021, DWR received a summary of RS' responses to comments (see below text) made by
DWR on the Elm Grove BPDP from 6/23/21. At a glance, it was noted that you provided a response
to 5 DWR comments. However, DWR made at least 32 comments (see Comment Summary
attached) on the initial BPDP worthy of a response from RS on how the revised final BPDP was
modified to address those comments. By providing a thorough response to DWR comments, DWR
staff can be more efficient and timely with their review of the final draft. Until DWR receives a
complete response to comments that DWR made on the initial draft BPDP, DWR will not initiate the
review of the final draft BPDP received by RS on July 19, 2021.
Thank you for your attention to this matter,
Katie
RS Response to DWR Comments below:

Restoration Systems, LLC
1101 Haynes St. Suite 211
Raleigh, North Carolina
Ph: [phone]
Fx: [phone]
July 12, 2021
Attn: Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
North Carolina Department of Environmental Quality
512 N. Salisbury Street, Raleigh, NC 27620
RE: DWR Draft MBI & BPDP Comments Elm Grove Nutrient Offset Site (DWR #2020-1225v2)
Dear Ms. Merritt:
Restoration Systems (RS) has reviewed the Division of Water Resources (DWR) comments dated
6/23/2021 for the Draft Bank Parcel Development Plan (BPDP) and comments for the Draft Mitigation
Banking Instrument for the Elm Grove Nutrient Offset Site. The following is a response to those
comments. Specific DWR comments are in black, and RS' responses are in blue. All other comments
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made have been addressed or corrected in the documen>�ecmeselves. �� PP-
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BPDP Comments: xC\ Q 11 l71'l(Thit1 Y
1. There are many Appendices. It is preferred that these appendices be labeled (A, B, C, etc) so as
to make it easy for the reviewer to find them as they are referenced in the document. Once a
label has been added for the appendices, please update all your references in the document
from saying "Attachments" or "Appendices" to the individual label you assign to it.
Appendix labels have been clarified and appropriate references included in documents.
2. The farm path dividing Ditch G must always have a clear pathway via a culvert in order not to
disrupt the direct hydrologic connectivity of the upstream reaches of Ditch G to its downstream
reach. Since G is a ditch, the only connection of upstream ditch G to downstream ditch G is
through the farm path culvert. Therefore, the Provider needs to have controlled access such
that they can maintain the culvert if ever needed. What efforts will be taken to secure this
controlled access?
Clarifying language has been added to Section 2.4 of the BPDP and the culverted crossing with
be delineated on the final survey to allow maintenance of the culvert. Language added to the
BPDP denotes the easement holder will have the ability to maintain the functioning culvert and
related hydrologic connectivity. The area is delineated on Figure 6.
3. There was no documented response from SHPO to RS included in the Appendix. How does RS
know for sure there isn't a historical site or land included in the project area without this
correspondence? Please include (an email from SHPO will suffice). This is mostly necessary for
this site since there likely an historical site in such close proximity to the project area.

A response letter from SHPO was received March 5, 2021, has been reverenced in section 2.4.3
of the BPDP, and included in appendix D.
4. If 10 species of trees are shown in the table, DWR expects 10 species to be planted. If
anticipating to plant less than 10 species, you need to at least indicate the minimum # of species
RS will plant. The standard in rule is 4, but hopefully RS is intending to plant more than two
species of trees and two species of shrubs. Just commit to a minimum so I can hold that
accountable in the AsBuilt Report. Clarifying language has been added to 3.3 of the BPDP to
detail the minimum requirement of 4 species. RS plans to plant species shown in table 7 and
table 8, however final plantings may vary based on the availability of species at the time of
planting.
5. There will be a deduction required at the upstream end of G to compensate for non -diffused
flow from the ditch feeding into G. Make note of this there and what that deduction is. Make
sure to reference the clarification memo from your MBI references. This has been addressed in
section 6.0 of the BPDP the Credit Table itself and as shown on Figure 6.
We appreciate your attention and timely review. Please do not hesitate to contact me if you have any
questions during your review.
Barrett Jenkins
Restoration Systems, LLC