20201664 Ver 2_RS Response to NCDWR comments_20211027

Restoration Systems, LLC
1101 Haynes St. Suite 211
Raleigh, North Carolina
Ph: [phone]
Fx: [phone]
Roseneath UBI: Bells Bridge BPDP
DWR Project No. 2020-1664v2
IRS Response to NCDWR comments
Comments Received (Black Text) & Responses (Blue Text)
*Grammatical corrections proposed by NCDWR have been made and are not listed below.
Page 2
1. Comment: Correct the DWR ID# to be 2020-1664v2
Response: Complete
Page 4
2. Comment: Photos provided in the Plan are not timestamped, therefore I cannot confirm these
photos represent "existing conditions"
Response: Date added. Change Complete
3. Comment: Change reference to "Project Credit Table", which will be consistent with the UMBI
terms.
Response: Corrected with site name reference
4. Comment: This table is actually labelled "Table 1". 1 prefer it be labeled table 7a and included
under the "Tables" reference and inserted within Section 7.0
Response: Added to tables ended up being Table 8
5. Comment: There are many Appendices. It is preferred that these appendices be labelled (A, B,
C, etc) o as to make it easy for the reviewer to find them as they are referenced in the
document. Once a table 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.
Response: Updated, see document.
Page 5
6. Comment: I know you prefer to name this UMBI after the landowner's last name. However,
since you have another Bank project called "White Farm". It is misleading that this UMBI is for
two sites and not just the White Farm site. Please rename the UMBI to avoid confusion.
Response: Updated. Name changed to "Roseneath".
7. Comment: No date needed, remove
Response: Updated
8. Comment: I don't understand the need to reference rule .0731 here. There is nothing about
Planning, designing, or selling credits from a Bank noted in this rule. The only rules that pertain
to this BPDP are .0703 and .0295
Response: Updated, reference removed
9. Comment: This is a little confusing. I think you mean "the land within the Site encompasses
approximately 45.35 acres of riparian buffers and other riparian areas that are actively utilized

for row crop production". If so, please change sentence to read as suggested. You use the term
"project", not "Parcel or Site" as referenced in the first paragraph of Setcion 1.0. so in reading
this, I didn't know if you were describing the land areas within the Site's parcel boundaries or if
you meant to describe the areas within and around it.
Response: Clarified
10. Comment: This paragraph should be moved to section 2.2
Response: Updated
11. Comment: Specify which appendix, give it a label
Response: Updated
Page 6
12. Comment: Most of this is already noted on page 1. 1 prefer you move that paragraph to this
section and continue with, "A summary of...". This will remove the redundancy.
Response: Updated
Page 8
13. Comment: Add the date here that these photos were taken
Response: Updated
Page 9
14. Comment: The template, except under special circumstances, only requires the long term
steward transfer be prior to the year 4 monitoring (see UMBI language). If RS wants to be held
to another standard, that's fine, but DWR will not require it for this site. I think this may be
carry-over from using another approved BPDP for a template.
Response: Correct, removed
15. Comment: Add specifics to the minimum and maximum widths you will have on the site; add a
note that no riparian areas less than 50' will be used for credit
Response: Language added
16. Comment: Add that there is a soil path along Feature Ea &Eb that will be removed. What efforts
will RS implement to remove it and prep that path area for planting?
Response: Updated/added
17. Comment: DWR recommends RS commit to performing soil testing to determine how best to
prepare the soil for planting and success. Additionally, with this site being used for ag for such a
long period of time, it is always recommended that the Sponsor implement disking or ripping to
break up compact soils. Why has RS not suggested these activities for parcel preparation?
Response: We left these things out of the document originally because we reviewed other
providers approved BPDPs (Moccasin Creek, Wildlands) and this language was not included in
their approved BPDPs. We will try to get the soil test done and have added language regarding
ripping. We prefer ripping to disking.
18. Comment: Commit to ensuring that stems will be well mixed before planting to ensure diversity
of bare roots across the planted areas.
Response: Language added

Page 10
19. Comment: It is preferred that you identify only what you intend to plant as your PRIMARY
selection. Then, tell me which species would be your SECNDARY selection if your primary
selection isn't available.
If 10 species of trees are shown in he table, DWR expects 10 species to be planted. If
anticipating to plant less than 10 species, you need to at least indicate the minimum # of species
RS will plant. The standard in rule is 4, but hopefully RS is intending to plant more than the
minimum to avoid the risk of some species not thriving/surviving. Just commit to a minimum so
I can hold that accountable in the AsBuilt Report. If RS ends up needing to plant different
species than what is in this list, they need to consult with DWR first to prevent an issue at
AsBuilt review.
Response: Updated. At the time of this draft submittal we hadn't ordered trees, however final
tree orders have now been placed and we intend to plant what is listed. Alternatives have also
been listed below the table.
20. Comment: Add a column to Table 7 for "Canopy/SubCanopy" and complete table accordingly.
This is reviewed to ensure there is a good mixture of canopy and subcanopy species.
Response: Added
21. Comment: DWR requests that RS consider including pollinator rich seedlings in with their
temporary and permanent seeding to enhance the riparian areas' ecological uplift. This request
is a comment being provided by DWR in all buffer planting plans at this time.
Response: See updated proposed seed mix in Table 7
22. Comment: I don't usually see Pecan tree in planting plans. Why is this specie chosen?
Response: I like pecans and it is not against the rules. As we have finalized the species selection
at this point in the year it turns out they weren't available and have been removed.
23. Comment: What is the anticipated spacing of stems?
Response: 8 x 8ft. See first paragraph section 4.2
24. Comment: Include the type of Seed Mix; I need to confirm that there will be annual and
perennial seed, and that the seed will not be non-native or invasive.
Response: Updated. You didn't make Wildlands do this on their approved Moccasin Creek BPDP
and we used that as a template. See table 7 for updated seed mix.
25. Comment: RS should take measures to ensure that plots are diverse (have 4 species represented
as much as possible) and where a species does not represent more than 50% of the plot. All
plots need to be representative of the planted diversity and density surrounding the plot and
will be evaluated by DWR during the onsite AsBuilt Walkthru to ensure these criteria are met.
All DWR comments provided on planting plan & monitoring are being provided under the
following Rule reference 15A NCAC 02B .0295(n)(2-4)
Response: Understood.

Page 11
26. There needs to be a section on "Parcel Protection & Easement Boundaries".
Make sure to include language that details what will be used to mark the easement boundary,
and that the easement boundaries will include placards identifying the contact information for
the easement holder. Clarify that the boundaries will be clearly marked prior to the Task 2 site
visit by DWR.
Language should also be added that a complete and detailed survey of the easement boundaries
will be included in the As -Built Report.
The outer easement boundary is not straight along Feature A, which will increase the risk of
encroachment from farming activities. RS should either straighten the boundary or implement
additional boundary marker standards to reduce the risk for encroachment. What does RS
intend to do to acknowledge this concern?
Response: Updated, Section 5.3 added.
Page 12
27. Comment: Need to indicate how many credit ledgers will be provided for this site to account for
the credits being generated. You will need 1 for Nitrogen, 1 for phosp., a1 for Buffer Restoratin,
1 for Buffer Preservation (a total of 4)
Response: We made this a nutrient only site so will have one for N and one for P, total 2. See
section 7.0
28. Comment: Remove Table 8. This credit release will be in the UMBI, it will be the same credit
release as for White Farms. See UMBI comments for edits made to the Credit Release schedule.
Response: Updated and agreed, but again the Moccasin creek BPDP was used as template and it
is included there.
Page 15
29. Comment: Correct this box to be "Nutrient Offset and Buffer Mitigation Bank Parcel"
Response: For simplicity we made this site and related UMBI nutrient offset only
Page 16
30. Comment: Add "and Riparian Buffer Credits".
Response: For simplicity we made this site and related UMBI nutrient offset only
Page 20
31. Comment: Is there an access road that will be provided to these sites?
Response: Yes, will be shown on final survey
Page 21
32. Comment: The outer easement boundary is not straight, which will increase the risk of
encroachment from farming activities. RS may want to consider modifying the easement to
reduce that risk.
Response: Point noted, we will leave as is and take the risk.
33. Comment: Show where the right of way is located
Response: Added
Page 23
34. Comment: Photos are required to be date stamped, these are not. When were these taken?

Response: Date added, 311612021
35. Comment: this table is titled Table 1 but the BPDP references a different Table as Table 1. DWR
requests this table be in Section 7.0 and recommends it be referenced as Table 7a.
Response: Updated as Table 8
36. Comment: DWR will provide comments on this table, if any are needed, using the working excel
file instead of the PDF provided here.
Response: Okay