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Home My WebLink About20210348 Ver 2_DWR Comment Summary_MitPlan_20220207are irxwdid 'n tv",A lkk_ VIV bms Mitt ation Plan Checklist for Ri avian Restoration Miti ation Sites —created 7/15/13 Ll"'DWR Stream Determination �DWR Site Viability Letter j.P"'Site Location -e— Directions including Lat & Long -!!( 8-digit HUC Wor 14 digit (if applicable) el' County 0-'EMC approved Soil map, Topo and Aerial Maps -6 Sub -watershed where applicable Project Name: 4�ic�l�. Cr e Reviewed By: VT" DWR #r 9, Q Date — 4- Existing Site Conditions w/ photos h�S Q mor currerr h --E�-- All proposed mitigation activities, including a brief summary of stream and/or wetland mitigation w(1 a detailed planting plan - somt rnor&wt ly r CAo prrr2 la 41 9 date �2 tJ�h1r�A �t�'C �� %B�Monitodng & Maintenance Plan t a, — d �nkkod `pn ��If19 p�kar�d 1(�kC�pp Financial Assurance (if applicable) .flO'W\0iv) m& "guyw� ho%'kn0 1 -VII"Associated buffer and/or nutrient offset credit calcs, which shall include credit generation, service - D�4AS-t-4�0`CA0w �uW�Npn tK bZ ha+'�e.�d �QAD 0 area, etc. p �iJ TA P C� C �k, p h'}o►�k add d�,iLs Srt:C#�bh Lk<redit Determination iablelMap skk6 mM4Ui +D bW'RuV. 2&4 yww � 31 b to i3dn C� oR c- L�Verification that the site does not have an impact on threatened or endangered species �1G�AJl� V;-' erfication that the site is not affected by on -site or nearby sources of contamination as provided by Environmental Data Resources, Inc. _tl/ Offcation that the site can be constructed on land if it is an archaeological site; V 1A list of all permits that will be required and obtained prior to constructing the mitigation site for nutrient offset and/or buffer mitigation (e.g. Sediment and Erosion Control Plan from Division of Land Resources, NCG010000 Sformwafer Permit from NCDWQ, 404 permit from the Army Corps of Engineers and corresponding 401 Water Quality Certification from NCDWQ) �` 4- L> A r �C - t0 a it rVtA oc '� WS ��a� ,0 W - ,r t m 1y . amply ? • it l 4.0 !tA -iv Summary of Comments on Draft Mit Plan_PickleCrk_DWRed its. pdf Page: 5 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 11:42:03 AM Add a DWR ID # on this page. the number is 2021-0348v2 Page: 6 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 11:44:00 AM photos provided in this section are dated August 2020 and do not adequately represent "existing" conditions upon submittal of the mitigation plan. Provided more current photos of the riparian areas and features. Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:39:51 PM Current land use does not indicate that the riparian areas are also used for the land application of animal waste. Add that detail here. Modify Figure 2 to show areas where the land application of animal waste is currently permitted. Then, reference Figure 2 in this same section after adding the requested lanaguage/detail in 1.1 Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 11:46:48 AM ephemeral channels are not considered to be 'unnamed tributaries" just Intermittent and Perennial channels get this classification. make sure to use stream, ephemeral channel and ditch when describing the features within the project boundary or that are draining into the project boundary such as D2 Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:37:26 PM make sure to describe project by using "riparian buffer and riparian areas" and not limiting it to "riparian buffer". QNumber:4 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:36:27 PM this should read "project stream, ephemeral channels and ditches" QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 11:48:23 AM the viability assessment performed by DWR was for buffer mitigation AND nutrient offset. please correct existing language. Correct date to April 17, 2021. �—QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 11:49:03 AM reference Table 4 and Figure 8 in this paragraph somewhere appropriate. QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 11:52:36 AM this date may be unrealistic considering the site constraints with existing infrastructure that need to removed as well as the land application permit affiliated with the land within the easement boundary. The land within the easement boundary needs to be removed from the Waste Utilization Plan before the easement is secured (deeded and recorded). QNumber:4 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:41:49 PM if the project easement boundary will not be less than 50' adjacent to all the features being proposed in the project area, then I'd prefer it state that in this section since all areas have to be at least 50' to be convertible to nutrient offsets. QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:42:37 PM Section 2.1 doesn't appear to be the correct reference here. Page: 12 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:43:41 PM outdated photos. need more current photos documenting conditions of riparain areas and features post -site viability letter. Page: 14 *)Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:48:07 PM since there will be a mitigation bank CE and restoration along D2, there will no non -diffused flow. Therefore, no deductions are necessary. However, in order to benefit from this, add language that speaks to the Bank and that since D2 is part of the Bank, deductions aren't required. When referencing the Bank, indicate that the riparian restoration plan has already been submitted for DWR review (DWR ID# 2021-03480). Modify Figure 4 to include the easement boundary for the proposed mitigation bank. Then refernce Figure 4 appropriately in this section. Page: 15 r Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:48:28 PM as indicated in previous comment, no deductions for non -diffused flow are necessary Page: 17 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:52:08 PM need to reference the site viabilty letter issued by DWR and that the letter indicated certain criteria that would need to be addressed prior to using this land as a mitigation site. What were those criteria, and then add a reference to SEction 4.2.4 where it appears those criteria are further explained. I have provided further comments in 4.2.4 as well Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 12:57:25 PM Add language to this section that describes what documentation will be submitted with the Asbuilt Report confirming full compliance with the criteria indicated in the site viability letter. This documentation should be any and all approvals from DWR related to permits affiliated with the project and Waste plans. There are two permits affiliated with this land proposed for the DMS project (AWS960127 and AW1960127) add that the provider will consult with DWR staff within the Certified Animal Feeding Operation Branch of the Water Quality Permitting Section Page: 18 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:00:55 PM It needs to be noted in this section, that site preparation includes activities related to activities described in 4.2.4 considering many of these activities are required to be done prior to riparian restoration activities as indicated in the Site Viability Letter. Site preparation for this site doesn't just include land prep for planting ... but also includes hydrant removals, infrastructure capping and deadheading, etc. QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:03:22 PM add "ephemeral channels" here. Ephemeral channels and "streams" are referred to differently in our buffer mitigation rule (and buffer protection rule 0714), therefore it is important to use correct terminology of features within the project boundary throughout the Plan QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:06:22 PM this rule reference (o)(7) is specific to Ephemerals. But the title of this sub section says "Perennial". REmove this citation if not applicable to 4.2.1. Based upon my reading of 4.2.1 and 4.2.2, it appears that riparian restoration of Streams & Ephemeral could be defined together within the same subsection. QNumber:4 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:09:20 PM Based upon my reading of section 4, it may be best if 4.2.2 and 4.2.3 were included under section 3.0 "regulatory considerations" since both of these subsections are describing how the Ephemeral channels and Ditches are complying with the rules specific to Eph. and Ditches. Riparian restoration activities should be the same for all features, so you could lump riparian restoration activities into one subsection to avoid confusion. All information provided in 4.2.2 and 4.2.3 is relevant for DWR review, just likely better provided for in SEction 3.0. rPNumber: 5 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:11:03 PM two Ephemeral channels... QNumber: 6 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:10:23 PM the allowable Ephemeral credit may change when Diffused flow deductions are removed. I don't think so, but check before finalizing the numbers referenced here. Page: 19 r—Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:12:17 PM Section 3.1 is "Determination of Credits". I'm not sure this is the correct reference here. wNumber: 2 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:11:45 PM There is no Section 3.3 in this Plan. What section should be noted here? Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:29:29 PM Second Paragraph of 4.2.4 lacks information needed to confirm that the criteria and expectations identified in the site viability letter are addressed adequately. Please give DWR an itemized plan on how they will ensure compliance with the criteria noted in that letter. It is recommended that the provider respond to this comment as follows: Copying each bulleted item as it is worded in the Site Viability Letter and indicate how the provider will comply with each item. Furthermore,1) indicate any actions that the provider has already taken to address those bulleted items (include any letters or correspondence in the Appendix that support the response), and 2) indicate what actions need to be further addressed, and 3) provide a timeline as to when the remaining items will be addressed. (DWR is specifically looking for 1) what will be addressed BEFORE planting, 2) BEFORE infrastructure is removed or modified, 3)BEFORE Conservation Easement is secured, ETC). Look at the site viability letter for guidance to make sure activities are done when they are required to be done before providing that language in this section. Lastly, there needs to be a commitment that the provider will provide DMS & DWR all necessary documentation indicated above, in the As -Built Report. Without documentation confirming full compliance of the items in the site viability letter, DWR cannot guarantee the buffer mitigation credits proposed by this project are in compliance with rule, permits, etc. Page: 20 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:33:38 PM I don't recall seeing that the Bank will incorporate "additional stream features". The bank's Plan includes D2 in its entirety, but doesn't really include "additional stream features". The bank mostlyjust incorporates wider riparian areas. correct existing language that may be misleading Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:35:48 PM should this be 50 instead of 30 or are there areas adjacent to ditches where 50 is not the minimum? If there are areas <50 along the ditch or other features, then the figures nd Table 4 need to depict those areas and exclude them from being convertible to Nutrient Offsets. *— Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:34:18 PM add language committing to mixing the stems during initial planting efforts in order to ensure diversity at initial planting. Page: 29 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:42:03 PM depict land application areas affiliated with a permit Page: 31 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:43:45 PM depict the Bank CE boundary and then remove the diffused flow deduction area along D2 Page: 35 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:44:26 PM depict Bank CE boundary Page: 36 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/7/2022 1:44:59 PM add a call -out where there are areas <50