20210915 Ver 1_LG Buffer Approval_20220103

P.O. Box 3136  Greensboro, NC 27402-3136  www.greensboro-nc.gov  (336) 373-CITY (2489)  TTY # 333-6930

Determination of No Practical Alternatives
Authorization Certificate
December 30, 2021

David Starkel, PE (Mr. Holden Sabato of SL Reedy Fork LLC)
605 Lexington Ave.
Suite 301
Charlotte, NC 28203

Re: Determination of No Practical Alternative for Stream Buffer disturbance for “Reedy Fork
Industrial”

Dear Mr. Starkel:

In accordance with the State of North Carolina’s Rule 15A NCAC 02B .0267 – Jordan Water Supply
Nutrient Strategy: Protection of Existing Riparian Buffers., any applicant that intends to disturb
Zone 1 and Zone 2 of the stream buffer must show that there is “No Practical Alternative” than to
impact the stream buffer. The applicant submitted a “No Practical Alternative Request” on
December 21, 2021, stating that the stream buffer disturbances were necessary for grading/erosion
control, the installation of a sewer line, the installation/construction of a permanent SCM, driveway
encroaching, driveway crossing, aerial electric utility, and grading/widening of street.

The City of Greensboro determined that the temporary and permanent impacts of the Jordan
Watersupply Watershed stream are the following:
Buffer Impacts
Zone 1: Temporary 9,832 SF; Zone 2: Temporary 15,341 SF
Zone 1: Permanent 20,062 SF; Zone 2: Permanent 24,225 SF

The surface area impact information in square footage, including mitigation area is as follows:

Buffer Zone 1 Impacts Zone 2 Impacts Net Mitigation Required
Zone 1 (3:1)
Zone 2 (1.5:1)
Total 20,062 SF
(13,041 SF of
Mitigation)
24,225 SF
(11,138 SF of Mitigation)
Zone 1- 39,123 SF
Zone 2 – 16,707 SF

Information submitted by the applicant explained how the impacts have been reduced to the
maximum extent practicable. Please be advised the applicant should secure any other required
federal, state, and local certifications before the project proceeds. Mitigation must be provided for
the proposed impacts as specified in the table above. The City has received an acceptance letter

640
from the Benton Branch Mitigation Bank to meet this mitigation requirement. Until the Benton
Branch Mitigation Bank receives and clears your payment, and proof of payment has been
provided to this Office, no impacts specified in this Authorization Certificate shall occur. For
accounting purposes, this Authorization Certificate authorizes payment to the Benton Branch
Mitigation Bank to meet the compensatory mitigation requirement shown on the table above.

This approval is valid only for the purpose and design that was described in the application. If any
modifications are made to the project a written notification describing the changes, must be
submitted to the City of Greensboro Water Resources Department, Engineering Division
(Stormwater Engineering Section). If the property is sold, the new owner must be given a copy of
the certification and approval letter and is thereby responsible for complying with all conditions.

This letter completes the review of The City of Greensboro, Water Resources Department,
Engineering Division (Stormwater Engineering Section) under the Determination of No Practical
Alternative. If you have any questions, please contact Johnnie A. Hill at 336-373-4653.

Sincerely,

Johnnie A. Hill
Plan Review Supervisor

Cc: Sue Homewood, DWQ Winston Salem Regional Office
David E. Bailey, U.S. Army Corps of Engineers, Raleigh Regulatory Field Office
Jennifer L. Robertson, Atlas Environmental, Inc.

ATLAS Environmental, Inc.
338 S Sharon Amity #411, Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte
December 20, 2021

City of Greensboro
Water Resources Department
Attn: Mrs. Marina Rincon Bermudez, Engineering Specialist
2602 S. Elm Eugene Street
Greensboro, North Carolina 27406

Re: Reedy Fork – ~ 158.5 Acres
5955 Summit Avenue Browns Summit, NC 27214
Jordan Lake Buffer Authorization
No Practical Alternatives – Additional Information Package

Mrs. Bermudez:

Atlas Environmental Inc. is submitting to the City of Greensboro a No Practical Alternatives
Letter on behalf of the applicant, Mr. Holden Sabato of SL Reedy Fork LLC, for unavoidable
impacts to Jordan Lake riparian buffers. The purpose of the project is for the construction of
two industrial warehouse buildings and associated infrastructure. The construction will include
building 1 (800,400 sq/ft), building 2 (576,000 sq/ft), a loop driveway for commercial traffic to
access building 1, parking areas for employees and commercial vehicles, driveways to enter the
property, stormwater treatment, a sewer line extension, and additional associated utilities.

Atlas Environmental conducted a stream and wetland delineation of the project Review Area on
March 13, 2021 and identified the presence of 10 streams, 25 wetlands, and one impoundment.
All of the aquatic resources drain to Reedy Fork and Hardy’s Mill Pond. An approved
jurisdictional determination request was submitted to the U.S. Army Corps of Engineers on June
2, 2021. The Corps project manager, Mr. David Bailey, indicated that there was an existing
preliminary jurisdictional determination (PJD) for the property. Upon review of the existing PJD
it was apparent that the delineations did not match due to mapping errors and seasonal
fluctuations. Atlas Environmental worked with Mr. David Bailey to determine a revised
approved delineation to be used during permitting. Atlas Environmental submitted a
Nationwide Permit verification request to the Corps (received by Mr. David Bailey on July 31,
2021) and NC DWR for unavoidable impacts to aquatic resources. Mr. David Bailey and Mrs.
Sue Homewood (NC DWR) field verified the Atlas Environmental delineation on September 15,
2021. Based on map revisions from the field verification Orsborn Engineering Group calculated
the Zone 1 and Zone 2 impacts to riparian buffers that is included as an attachment.

In summary there are 25 areas of proposed buffer impacts which total 1.360 acres in Zone 1
and 1.363 acres in Zone 2. Six impacts are for grading/erosion control within Zone 2, are
temporary, and exempt. Vegetation will be re-established at these six locations after grading is
completed. Three impacts are for non-perpendicular sewer line installation at streams. Each of
these impacts are both temporary and permanent. One impact (#24) has an existing
component. Buffer mitigation is required at two of these impacts as Zone 1 disturbance will be
required for sewer line installation. Three sewer line buffer impacts are located at
perpendicular stream crossings and are thus allowed and do not require mitigation. Each of
these impacts are both temporary and permanent. The streams at these locations will be

ATLAS Environmental, Inc.
338 S Sharon Amity #411, Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

restored once construction is completed. Two impacts are for the construction of stormwater
control outfalls that are all allowed within Zones 1 and 2. Both of these buffer impacts have
temporary and permanent disturbances.

Two permanent stream buffer impacts are necessary for driveway encroachment. These buffer
disturbances are located at impacts #9 and 10. Impacts in Zones 1 and 2 at these locations
require mitigation. Additional justification for these impacts is provided in this cover letter. One
permanent aerial electric non-perpendicular buffer impact is necessary along Summit Avenue.
This overhead power line is getting relocated due to the Summit Avenue road improvements.
The impacts within Zone 1 required mitigation. Two aerial electric non-perpendicular buffer
impacts are also necessary along Summit Avenue. Both of these impacts are existing and
necessary due to road widening improvements.

Buffer impact #14 is currently being proposed as impacted via relocation/piping down to the
existing pipe under Summit Avenue under the 404 permit application to the U.S. Army Corps of
Engineers. This permanent stream and stream buffer impact are necessary for grading and
Summit Avenue road improvements. These permanent buffer impacts will be attributed as
piping of a stream under a permit issued by the U.S. Army Corps of Engineers and therefore
allowable. If for any reason(s) a permit is not issued or the permit does not include denoted
impacts #14, a revised LNPA must be submitted to the City of Greensboro. One buffer impact
is necessary for an access driveway crossing to the Southern building. Some of these impacts
are temporary and some are permanent. The impacts at #15 are allowable since the impact is
less than 150 linear feet (49 linear feet of temporary and 88 linear feet of permanent).

Two stream buffer impacts are necessary for grading for street other than crossing outside right
of way which are both permanent impacts. Mitigation is required for both Zone 1 and 2 at
these locations (#18 and 21). The existing stream will be relocated and enhanced at impact
#18. Currently, a public watermain is being constructed along Summit Avenue by the City of
Greensboro. This waterline is in the vicinity of impact numbers 13-23 and much of the area is
already cleared, impacted, and/or disturbed due to the installation of this utility. Updated
photographs from December 1, 2021 are included as an attachment. The last two buffer
impacts are disturbances for street within right of way. These are both existing and exempt.

Atlas concurs that this project cannot be constructed without the following unavoidable impacts
to riparian buffers. The impacts are summarized in Table 1 below.

ATLAS Environmental, Inc.
338 S Sharon Amity #411, Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

Table 1: Impact Summary Table

Notes: AWM - allowable with mitigation, A - allowable, E – exempt, EXG – existing; mitigation
as required provided at a 3:1 ratio for Zone 1 and 1.5:1 ratio for Zone 2 included in the
mitigation columns
*Allowable only if the U.S. Army Corps of Engineers issues a permit that includes this impact. If
for any reason, this impact no longer falls into this activity, a revised LNPA will need to be
submitted to the City of Greensboro for revision.

The project has avoided and minimized impacts to aquatic resources and riparian buffers by
various design characteristics including placement of the buildings, orientation of the buildings,
sizing of the buildings, placement and orientation of the stormwater control measures, elevation
of the building pad affecting length of graded side slopes, and design/placement of outlet
structures and driveways to access the property. The one sewer line extension (impact #12) is
Impact # Purpose
Temporary vs.
Permanent
Ac SqFt Table
Mitigation
(SqFt) Ac SqFt Table
Mitigation
(SqFt)
1 Grading/Erosion Control temporary 0.000 0 n/a 0.034 1499 E
2 Sewer Non-Perpendicular temporary 0.036 1588 A 0.087 3806 E
2 Sewer Non-Perpendicular permenant 0.007 309 AWM 927 0.068 2953 E
3 Sewer Perpendicular temporary 0.031 1346 A 0.012 509 A
3 Sewer Perpendicular permenant 0.012 534 A 0.005 203 A
4 SCM Outfall temporary 0.002 94 A 0.005 220 A
4 SCM Outfall permenant 0.014 604 A 0.008 355 A
5 Grading/Erosion Control temporary 0.000 0 n/a 0.010 415 E
6 Grading/Erosion Control temporary 0.000 0 n/a 0.017 734 E
7 Sewer Perpendicular temporary 0.038 1663 A 0.031 1356 A
7 Sewer Perpendicular permanent 0.014 607 A 0.010 424 A
8 Sewer Perpendicular temporary 0.069 3021 A 0.038 1671 A
8 Sewer Perpendicular permanent 0.033 1427 A 0.013 572 A
9 Driveway Encroaching permanent 0.105 4568 AWM 13704 0.097 4236 AWM 6354
10 Driveway Encroaching permanent 0.025 1084 AWM 3252 0.050 2171 AWM 3256.5
11 Grading/Erosion Control temporary 0.000 0 n/a 0.000 2 E
12 Sewer Non-Perpendicular temporary 0.001 28 A 0.066 2871 E
12 Sewer Non-Perpendicular permanent 0.000 0 n/a 0.044 1915 E
13
Aerial Electric Non-
Perpendicular permanent 0.027 1165 AWM 3495 0.007 299 A
14
Piping of Stream Under A
Permit Issued By The U.S.
Army Corps Of Engineers* permanent 0.024 1057 A 0.096 4193 A
15 Driveway Crossing temporary 0.025 1106 A 0.012 527 A
15 Driveway Crossing permanent 0.038 1672 A 0.033 1423 A
16 Grading/Erosion Control temporary 0.000 0 n/a 0.004 185 E
17 SCM Outfall temporary 0.018 803 A 0.023 997 A
17 SCM Outfall permanent 0.026 1120 A 0.010 421 A
18
Grading For Street Other
Than Crossing Outside R/W permanent 0.102 4451 AWM 13353 0.093 4047 AWM 6070.5
19 Aerial Electric Non- existing 0.098 4283 EXG 0.050 2170 EXG
20 Street Within R/W existing 0.189 8249 EXG 0.170 7394 EXG
21
Grading For Street Other
Than Crossing Outside R/W permanent 0.032 1401 AWM 4203 0.016 684 AWM 1026
22 Street Within R/W existing 0.222 9669 EXG 0.192 8377 EXG
23
Aerial Electric Non-
Perpendicular existing 0.159 6941 EXG 0.043 1879 EXG
24 Sewer Non-Perpendicular existing 0.005 200 EXG 0.000 0 n/a
24 Sewer Non-Perpendicular temporary 0.004 183 A 0.007 292 E
24 Sewer Non-Perpendicular permanent 0.001 63 AWM 189 0.008 329 E
25 Grading/Erosion Control temporary 0.000 0 n/a 0.006 257 E
SUM 1.360 59236 39123 1.363 59386 16707
Zone 1 Zone 2

ATLAS Environmental, Inc.
338 S Sharon Amity #411, Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

being required by the City of Greensboro for plan approval. Sewer line construction will utilize a
construction easement of less than 40 feet in width within the riparian buffers and have a 10
foot permanent maintenance corridor within the riparian buffers. Orsborn Engineering Group
has designed the 10 foot permanent maintenance corridor within the stream’s riparian buffers
to be able to provide adequate and safe long term maintenance of the proposed sewer line by
the City of Greensboro. Due to existing topographic conditions, depth of the proposed sewer
line, and other field or engineering constraints, a permanent maintenance corridor less than 10
feet wide within the stream’s riparian buffer has been determined by the applicant to not be a
practical alternative. Buffer impacts at sites #13 – 23 are necessary along Summit Avenue
related to piping a stream, moving an overhead utility line, driveway access, grading/erosion
control, scm outfall, and grading for road improvements. All of these impacts are unavoidable
due to NCDOT requirements for site access. Based on the site requirements, design
parameters, best management practices, local requirements, and offered mitigation there is no
practical alternatives which would further reduce the proposed buffer impacts.

The applicant is proposing mitigation for all areas which are designated as “Allowable with
Mitigation”. No mitigation is being proposed for any impacts which are designated as
“Allowable”. The proposed impacts are summarized by the table of use and impact area in
Table 2 below.
Table 2: Impact Summary (square feet)
Zone AWM A E
1 13,041 16,853 0
2 11,138 13,170 15,258
Sum 24,179 30,023 15,258

Below are additional summary tables.
Table 3: Zone 1 Temporary Buffer Impacts

Table 4: Zone 1 Permanent Buffer Impacts

Table 5: Zone 2 Temporary Buffer Impacts

Temporary
Zone 1 AC Sq/Ft
AWM 0.000 0
A 0.226 9832
E 0.000 0
Permanent
Zone 1 AC Sq/Ft
AWM 0.299 13041
A 0.161 7021
E 0.000 0
Temporary
Zone 2 Ac Sq/Ft
AWM 0.000 0
A 0.121 5280
E 0.231 10061

ATLAS Environmental, Inc.
338 S Sharon Amity #411, Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

Table 6: Zone 2 Permanent Buffer Impacts

The applicant proposes to provide compensatory mitigation for the unavoidable 24,179 square
feet of Zone 1 and Zone 2 buffer impacts associated with impacts 2, 9, 10, 13, 18, 21, and 24
that are allowable with mitigation. The applicant proposes to mitigate for buffer impacts within
Zone 1 at a 3:1 ratio (39,123 square feet) and within Zone 2 at a 1.5:1 ratio (16,707 square
feet) in the form of purchased riparian buffer credits from Restoration Systems LLC. A copy of
the Statement of Availability from Restoration Systems LLC is included. Restoration Systems
LLC will provide Jordan Lake Haw River stream buffer mitigation credits from their Benton
Branch Mitigation Bank. SL Reedy Fork LLC will purchase 55,830 stream buffer credits from the
Benton Branch Mitigation Bank to offset project buffer impacts.

It is my understanding that additional information has been requested concerning the proposed
stream buffer impacts at Impact Areas #9 and 10. These buffer impacts are necessary for
driveway crossings at the headwater of an intermittent stream and above the headwater of a
perennial stream. The intermittent stream will be impacted by the development. The stream
impact has been included in the Army Corps 404 and NC DWR 401 permit application. Below is
additional information confirming that these impacts should be deemed allowable as well as
justification for the necessity of these driveway crossings (and intermittent stream impact).

As defined in the City of Greensboro’s Land Development Ordinance (LDO), a driveway is a
private roadway providing access by vehicles and pedestrians to at least one lot or facility. The
driveway at the subject project will provide direct access to Lot 1 (Building 1) as well as a
required (by the Fire Marshall) secondary access to Lot 2 (Building 2). The private driveway off
Summit Avenue provides the ONLY access to the truck courts for Building 1. The
employee/visitor parking lot entrance is located at a separate driveway off Summit Avenue.
Tractor and trailer traffic cannot interact/intermingle with employee/visitor parking for multiple
reasons – pedestrian safety (employees and visitors walking back and forth to their vehicles
cannot interact with the very active travel lanes of the tractors and trailers); productivity (truck
courts are very fast paced areas where time loading and unloading is of the essence);
equipment safety (trailers will be moved back and forth from dock doors to parking spaces so
very clear lines of sight are important); free and clear access to the facilities, dock doors, and
parking spaces (passenger vehicles do not interact well with active truck courts); and site
distance differences in requirements for tractor and trailers versus passenger vehicles. The
passenger vehicle parking lot entrance is located closer to the curve in Summit Avenue since
site distance requirements are shorter. The tractor and trailer driveway entrance which
requires a wider turn radius is located further to the North to allow for required site distances
along Summit Avenue. Tractors and trailers require longer clearance time to enter Summit
Avenue due to the longer length and gear changes.

Permanent
Zone 2 Ac Sq/Ft
AWM 0.256 11138
A 0.181 7890
E 0.112 5197

ATLAS Environmental, Inc.
338 S Sharon Amity #411, Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

The following additional design alternatives have been considered, but are not viable solutions:
1) The trailer parking directly to the east of the proposed driveway is necessary for the
functionality of the facility. Losing trailer parking at this location is not an option.
Warehouse tenants request more trailer spaces than at any other time due to the
increase in on-line shopping. These additional trailers get moved to dock doors and
loaded so that they are ready for pick up.
2) Eliminating the portion of the loop road on the east side of the building and shifting the
entire development to the east is not an option because two separate accesses to the
truck court are necessary for the functionality of this facility. Tractors going to the
opposite end dock doors need a clear travel path as opposed to having to interact with
the very active remaining truck court.
3) The width of Building 1 combined with the width of the docks, truck courts, trailer
parking spaces, and driveway is a fixed dimension. Tenants require very specific
dimensions of all of these features. Leases are lost due to compromises in these
features. Sliding the entire development to the east is not desirable because it will
create new buffer and stream impacts to a separate stream paralleling Summit Avenue.
The stream in this location flows parallel to the building so more stream buffer and
stream impact would be necessary. It is a perennial stream. The stream at Impact
Areas #9 and 10 flow perpendicular to the building so less stream buffer and stream
impact is required. As previously mentioned, the stream requiring direct impact is
intermittent. The stream buffer only impact (#10) is perennial. Permanent stream
impacts in this area have been avoided. Construction of a wall is proposed to minimize
the stream buffer and stream impact as much as possible.
4) A retaining wall was considered but would not have completely eliminated the stream
buffer and stream impacts. The impacts in these areas are very minor (Zone 1 = 0.105
acre, Zone 2 = 0.097 acre, and Stream Impact = 46 linear feet for #9 and Zone 1 =
0.025 acre and Zone 2 = 0.050 acre at #10). Stream buffer mitigation is provided at
these two impact locations. Since the stream buffer and stream impact could not be
eliminated with a retaining wall, the cost-benefit does not justify the construction of a
wall. A retaining wall would need to be an estimated 425 linear feet long. The retaining
wall would need to be an estimated 4,005 square feet. An estimated cost per square
foot for the retaining wall is $25. The estimated cost of the retaining wall is $100,125.
5) A fourth driveway onto Summit Avenue was initially proposed for fire access to Building
2. That driveway was eliminated at the direction of NCDOT and the Fire Marshall with
the understanding that this driveway would serve as the secondary fire access to
Building 2. NCDOT was not comfortable with the location of a fourth driveway due to
the proximity of this entrance to the existing bridge on Summit Avenue.

Per Table 12-5 in the City of Greensboro’s LDO, driveway crossings of streams and other
surface waters subject to the ordinance are deemed Allowable with Mitigation. Therefore, it is
my opinion that the buffer impact resulting from these driveway crossings are both allowable
and necessary for this development. The stream impact at this location is included in the Army
Corps 404 and NC DWR 401 permit application.

Based on the above referenced information, no other alternative than that proposed in the
request is practical for completion of the overall project. Therefore, we request the City of

ATLAS Environmental, Inc.
338 S Sharon Amity #411, Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

Greensboro’s written concurrence via the requested Jordan Lake Buffer Disturbance
Authorization. Please contact me if you need any additional information.

Best regards,

Jennifer L Robertson, Ecologist
[e-mail]
WQ POND 3
WQ POND 2WQ POND 1U.S.HWY 29SUMMIT AVENUEU.S.HWY 29STREAM BUFFER IMPACT OVERALL MAPREEDY FORKGREENSBORO, NORTH CAROLINA
WQ POND 2STREAM BUFFER IMPACT ENLARGED MAPREEDY FORKGREENSBORO, NORTH CAROLINA
WQ POND 1SUMMIT AVENUESTREAM BUFFER IMPACT ENLARGED MAPREEDY FORKGREENSBORO, NORTH CAROLINA
Reedy Fork Site Photographs: December 01, 2021
Note: Date and time stamp on photos is not correct

1: Upstream of enhancement reach looking DNST

2: Upstream of enhancement reach looking up slope

3: Seep along existing silt fence near french drain

4: Seep along existing silt fence near french drain

5: Current channel conditions near cross section 0+67 feet

6: Existing channel conditions
Reedy Fork Site Photographs: December 01, 2021
Note: Date and time stamp on photos is not correct

7: Current channel conditions near cross section 1+89 feet

8: Existing channel condition

9: Current channel conditions near cross section 2+78 feet

10: Fill obstructing channel

11: Fill obstructing channel

12: Fill obstructing channel
Reedy Fork Site Photographs: December 01, 2021
Note: Date and time stamp on photos is not correct

13: Fill obstructing channel

14: Wetland abutting channel at station 4+00 feet

15: Station 4+00 feet at edge of forested area

16: Station 4+25 feet

Reedy Fork Site Photographs: December 01, 2021
Note: Date and time stamp on photos is not correct

Lower reach of channel near culvert under Summit Ave: Plastic mesh matting in channel

Lower reach of channel near culvert under Summit Ave: Plastic mesh matting in channel

Reedy Fork Site Photographs: December 01, 2021
Note: Date and time stamp on photos is not correct

Lower reach of channel near culvert under Summit Ave: Fill in channel

Lower reach of channel at culvert under Summit Ave: Erosion control device (rip-rap check dam) in channel

1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492

Statement of Mitigation Credit Availability
Benton Branch Mitigation Bank

October 21, 2021

SL Reedy Fork LLC
POC: Mr. Dan Lacz
195 Morristown Road
Basking Ridge, NJ 07920

Re: Availability of Compensatory Riparian Buffer Credits
Project: Reedy fork Industrial, DWR Project #: 20210915, Corps Action ID : 2019-02059

This document confirms that 256,322.61 Credits (Credits) from the Benton Branch Mitigation
Bank (Bank) are currently available and all or a portion may be used, once transferred, for
compensatory mitigation relative to the Reedy Fork Industrial project, and as proposed by SL
Reddy Fork LLC (Applicant).

The Applicant may ultimately purchase the Credits, if they are available, following Permit issuance.
Should the Applicant purchase the Credits at that time, we will complete and execute the Mitigation
Credit Transfer Certificate (Certificate) within five (5) days of receipt of the full purchase price.

We will additionally provide copies of the completed and executed Certificate to the Applicant, the
Division of Water Resources (DWR) and, if needed, other regulatory agencies. In addition, we will
provide DWR with an updated copy of the Bank’s Ledger, reflecting the transaction. Transaction
information in the updated Bank Ledger will include relevant Permit and Applicant information as
well as the number and resource type of the debited Credits.

Should your office have any questions, please contact me at 919.334.9118.

Sincerely,

Barrett Jenkins
Restoration Systems, LLC