20141149 Ver 8_RS Response to DWR MY4 Review

From: Merritt, Katie
To: Baker. Caroline D
Subject: FW: [External] RE: Rocky Top MR Review
Date: Friday, April 8, 2022 10:30:57 AM
Attachments: 2014-1149-V8 Rocky Top Response to MY4 DWR Comments.pdf
Please file email and attachment into 2014-1149v8. Thank you
From: Ray Holz <[e-mail]>
Sent: Monday, April 4, 2022 8:12 AM
To: Merritt, Katie <[e-mail]>
Cc: Baker, Caroline D <[e-mail]>; Matthew Harrell
<mharrell@ restorationsystems.com>
Subject: [External] RE: Rocky Top MR Review
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Katie —
I have attached a comment response letter for Rocky Top. As part of the response, IRS reviewed the
USDA Forestland Productivity data, which provides a Site Index, or average height in feet, of
different tree species for the given soil type —the report is included in our response. The Site's
mapped soil units (Herndon silt loam, "HnW and Cullen clay loam, "CnD2") are known to be
relatively low productivity soils given their rocky and eroded composition. The Site Index for these
soils and hardwood species is lower than the typical mitigation site, demonstrating that the Site's
lower than usual tree height is expected.
If you would like to set up a call to discuss the Site Index Report, we are happy to set up a Teams
meeting.
Sincerely,
Raymond H.
Raymond J. Holz I Restoration Systems, LLC
1101 Haynes St. Suite 211 1 Raleigh, NC 27604
tel:[phone] cell:919.604.9314 1 fax:[phone]
email: rholzPrestorationsystems.com
From: Merritt, Katie <[e-mail]>
Sent: Friday, March 04, 2022 3:56 PM
To: Ray Holz <rholzPrestorationsystems.com>
Cc: Baker, Caroline D <[e-mail]>
Subject: Rocky Top MR Review

Hey Raymond,
DWR has reviewed the Year 4 Monitoring Report for the Rocky Top Buffer/Nutrient Offset site.
Comments on the report are provided as follows:
1. Plot data in all 4 plots reveals very short heights on planted stems in comparison to what
is common by Year 4. Of most concern is Plot 3, where all planted stems are smaller than
3 feet. Is there a factor other than rocky soil conditions to consider here that may need to
be addressed by IRS prior to the next growing season? What additional efforts can IRS
take to assist in tree development?
2. During supplementing efforts in 2020, did IRS include areas within buffer and nutrient
offset credit generating areas as part of that supplemental plant? If not, explain why.
Please provide a response to the comments above, and include all required documentation
requested. Once DWR receives a response to comments, DWR can proceed issuing a credit
release for this task.
Thank you for your patience,
Katie
Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
401 & Buffer Permitting Unit
North Carolina Department of Environmental Quality
Office: 919-707-3637
Work Cell: 919-500-0683
Website: https://deq.nc.gov/about/divisions/water-resources/water-quality permitting/401-buffer-
permitting-branch
512 N. Salisbury Street, Raleigh, NC 27620
1617 Mail Service Center, Raleiah, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Restoration Systems, LLC
1101 Haynes St. Suite 211
Raleigh, North Carolina
Ph: [phone]
Fx: [phone]
Response to DWR Comments Dated March 7, 2022
Monitoring Year 4 (2021)
Rocky Top Bank Parcel
DWR Project Number: 2014-1149 v8
Alamance County
Comments Received (Black Text) & Responses (Blue Text)
DWR Comments. Katie Merritt:
1.) Plot data in all 4 plots reveals very short heights on planted stems in comparison to what is
common by Year 4. Of most concern is Plot 3, where all planted stems are smaller than 3 feet. Is
there a factor other than rocky soil conditions to consider here that may need to be addressed
by IRS prior to the next growing season? What additional efforts can IRS take to assist in tree
development?
Restoration Systems (RS) reviewed the USDA Forestland Productivity data, which provides a Site
Index, or average height in feet, of different tree species for the given soil type (report
attached). The Site's mapped soil units (Herndon silt loam, "HnD" and Cullen clay loam, "CnD2")
are known to be relatively low productivity soils given their rocky and eroded composition. The
Site Index for these soils and hardwood species is lower than the typical mitigation site,
demonstrating that the Site's lower than usual tree height is expected.
Planting conditions were difficult given the poor soils, both for initial planting and supplemental
efforts. Extra care was taken to make sure trees had viable locations to establish, including using
a mechanical auger to create planting pockets where typical bare -root planting tools were
inadequate.
Monitoring reports have noted competition from herbaceous vegetation as a potential issue.
Due to the steep and erodible soils, IRS does believe this is a significant contributor to planted
tree height, nor does IRS plan to treat the herbaceous groundcover. Efforts to overcome the soil
limitations might achieve taller trees faster, but would include the input of additional nutrients
(nitrogen and phosphors) to the Site, which could be counterproductive to the Site's
goals/objectives. With tree numbers in the appropriate range and continued volunteer
recruitment, IRS believes the Site is on track with no vegetation management needed.
2.) During supplementing efforts in 2020, did IRS include areas within buffer and nutrient offset
credit generating areas as part of that supplemental plant? If not, explain why.
The supplemental efforts in the 2020/2021 dormant season included the buffer and nutrient
offset areas.
Attachments:
- Rocky Top — Forested Productivity Report (2022-03)
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492

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Custom Soil Resource Report
Map Unit Legend
Map Unit Symbol
Map Unit Name
Acres in AOI
Percent of AOI
CnD2
Cullen clay loam, 10 to 15
0.6
11.8%
percent slopes, moderately
eroded
CnE2
Cullen clay loam, 15 to 45
1.4
27.7%
percent slopes, moderately
eroded
HnC
Herndon silt loam, 6 to 10
0.0
0.0%
percent slopes
HnD
Herndon silt loam, 10 to 15
3.1
60.5%
percent slopes
Totals for Area of Interest
6.2
100.0%
11

Forestland Productivity --- Alamance County, North Carolina
Rocky Top Area of Interest
Forestland Productivity
This table can help forestland owners or managers plan the use of soils for wood
crops. It shows the potential productivity of the soils for wood crops.
Potential productivity of merchantable or common trees on a soil is expressed as
a site index and as a volume number. The site index is the average height, in
feet, that dominant and codominant trees of a given species attain in a specified
number of years. The site index applies to fully stocked, even -aged, unmanaged
stands. Commonly grown trees are those that forestland managers generally
favor in intermediate or improvement cuttings. They are selected on the basis of
growth rate, quality, value, and marketability. More detailed information regarding
site index is available in the "National Forestry Manual," which is available in
local offices of the Natural Resources Conservation Service or on the Internet.
The volume of wood fiber, a number, is the yield likely to be produced by the
most important tree species. This number, expressed as cubic feet per acre per
year and calculated at the age of culmination of the mean annual increment
(CMAI), indicates the amount of fiber produced in a fully stocked, even -aged,
unmanaged stand.
Trees to manage are those that are preferred for planting, seeding, or natural
regeneration and those that remain in the stand after thinning or partial harvest.
Reference:
United States Department of Agriculture, Natural Resources Conservation
Service, National Forestry Manual.
Report—Forestland Productivity
USDA Natural Resources Web Soil Survey 3/28/2022
Conservation Service National Cooperative Soil Survey Page 1 of 6

Forestland Productivity --- Alamance County, North Carolina
Rocky Top Area of Interest
Forestland Prod uctivity—Alamance County, North Carolina
Map unit symbol and soil
name
Potential productivity
Trees to manage
Common trees
Site Index
Volume of
wood fiber
Cu ft/ac/yr
ChA—Chewacla loam, 0 to 2
percent slopes, frequently
flooded
Chewacla, frequently flooded
American sycamore
97
116.00
American sycamore, Green
ash, Loblolly pine,
Sweetgum, Yellow -poplar
Green ash
G
78
46.00
Loblolly pine
95
142.00
Sweetgum
100
138.00
Willow oak
90
86.00
Yellow -poplar
96
100.00
Riverview, frequently flooded
Loblolly pine
100
154.00
Loblolly pine, Sweetgum,
Yellow -poplar
Sweetgum
100
138.00
Yellow -poplar
110
124.00
Wehadkee, frequently flooded
Green ash
89
64.00
Green ash, Sweetgum, Yellow-
poplar
Sweetgum
97
128.00
Water oak
94
91.00
Willow oak
94
91.00
Yellow -poplar
100
107.00
CnB2—Cullen clay loam, 2 to 6
percent slopes, moderately
eroded
Cullen, moderately eroded
Loblolly pine
80
114.00
Loblolly pine, Shortleaf pine
Northern red oak
70
57.00
Shortleaf pine
70
114.00
Yellow -poplar
80
72.00
Enon, moderately eroded
Loblolly pine
73
108.00
Loblolly pine, Shortleaf pine
Shortleaf pine
63
82.00
Sweetgum
87
98.00
Yellow -poplar
88
86.00
USDA Natural Resources Web Soil Survey 3/28/2022
Conservation Service National Cooperative Soil Survey Page 2 of 6

Forestland Productivity --- Alamance County, North Carolina
Rocky Top Area of Interest
Forestland Prod uctivity—Alamance County, North Carolina
Map unit symbol and soil
name
Potential productivity
Trees to manage
Common trees
Site Index
Volume of
wood fiber
Cu ft/ac/yr
CnC2—Cullen clay loam, 6 to
10 percent slopes,
moderately eroded
Cullen, moderately eroded
Loblolly pine
80
114.00
Loblolly pine, Shortleaf pine
Northern red oak
70
57.00
Shortleaf pine
70
114.00
Yellow -poplar
80
72.00
Enon, moderately eroded
Loblolly pine
73
108.00
Loblolly pine, Shortleaf pine
Shortleaf pine
63
82.00
Sweetgum
87
98.00
Yellow -poplar
88
86.00
CnD2—Cullen clay loam, 10 to
15 percent slopes,
moderately eroded
Cullen, moderately eroded
Loblolly pine
80
114.00
Loblolly pine, Shortleaf pine
Northern red oak
70
57.00
Shortleaf pine
70
114.00
Yellow -poplar
80
72.00
Enon, moderately eroded
Loblolly pine
73
108.00
Loblolly pine, Shortleaf pine
Shortleaf pine
63
82.00
Sweetgum
87
98.00
Yellow -poplar
88
86.00
CnE2—Cullen clay loam, 15 to
45 percent slopes,
moderately eroded
Cullen, moderately eroded
Loblolly pine
80
114.00
Loblolly pine, Shortleaf pine
Northern red oak
70
57.00
Shortleaf pine
70
114.00
Yellow -poplar
80
72.00
Enon, moderately eroded
Loblolly pine
73
108.00
Loblolly pine, Shortleaf pine
Shortleaf pine
63
82.00
Sweetgum
87
98.00
Yellow -poplar
88
86.00
USDA Natural Resources Web Soil Survey 3/28/2022
Conservation Service National Cooperative Soil Survey Page 3 of 6

Forestland Productivity --- Alamance County, North Carolina
Rocky Top Area of Interest
Forestland Prod uctivity—Alamance County, North Carolina
Map unit symbol and soil
name
Potential productivity
Trees to manage
Common trees
Site Index
Volume of
wood fiber
Cu ft/ac/yr
HnB—Herndon silt loam, 2 to 6
percent slopes
Herndon
Loblolly pine
75
101.00
Loblolly pine, Shortleaf pine,
Yellow -poplar
Shortleaf pine
68
106.00
Southern red oak
72
57.00
White oak
65
43.00
Yellow -poplar
91
86.00
Lignum
Loblolly pine
76
103.00
Loblolly pine, Shortleaf pine
Northern red oak
68
50.00
Red maple
—
—
Shortleaf pine
66
101.00
Southern red oak
68
50.00
Virginia pine
74
114.00
Yellow -poplar
—
—
Nanford
Loblolly pine
90
131.00
Loblolly pine, Shortleaf pine
Northern red oak
—
—
Shortleaf pine
—
—
Virginia pine
—
—
HnC—Herndon silt loam, 6 to
10 percent slopes
Herndon
Loblolly pine
75
101.00
Loblolly pine, Shortleaf pine,
Yellow -poplar
Shortleaf pine
68
106.00
Southern red oak
72
57.00
White oak
65
43.00
Yellow -poplar
91
86.00
Lignum
Loblolly pine
76
103.00
Loblolly pine, Shortleaf pine
Northern red oak
68
50.00
Red maple
—
—
Shortleaf pine
66
101.00
Southern red oak
68
50.00
Virginia pine
74
114.00
Yellow -poplar
—
—
Nanford
Loblolly pine
90
131.00
Loblolly pine, Shortleaf pine
Northern red oak
—
—
Shortleaf pine
—
—
Virginia pine
—
—
USDA Natural Resources Web Soil Survey 3/28/2022
Conservation Service National Cooperative Soil Survey Page 4 of 6

Forestland Productivity --- Alamance County, North Carolina
Rocky Top Area of Interest
Forestland Prod uctivity—Alamance County, North Carolina
Map unit symbol and soil
name
Potential productivity
Trees to manage
Common trees
Site Index
Volume of
wood fiber
Cu ft/ac/yr
HnD—Herndon silt loam, 10 to
15 percent slopes
Herndon
Loblolly pine
75
101.00
Loblolly pine, Shortleaf pine,
Yellow -poplar
Shortleaf pine
68
106.00
Southern red oak
72
57.00
White oak
65
43.00
Yellow -poplar
91
86.00
Lignum
Loblolly pine
76
103.00
Loblolly pine, Shortleaf pine
Northern red oak
68
50.00
Red maple
—
—
Shortleaf pine
66
101.00
Southern red oak
68
50.00
Virginia pine
74
114.00
Yellow -poplar
—
—
Nanford
Loblolly pine
90
131.00
Loblolly pine, Shortleaf pine
Northern red oak
—
—
Shortleaf pine
—
—
Virginia pine
—
—
HnE—Herndon silt loam, 15 to
45 percent slopes
Herndon
Loblolly pine
75
101.00
Loblolly pine, Shortleaf pine,
Yellow -poplar
Shortleaf pine
68
106.00
Southern red oak
72
57.00
White oak
65
43.00
Yellow -poplar
91
86.00
Lignum
Loblolly pine
76
103.00
Loblolly pine, Shortleaf pine
Northern red oak
68
50.00
Red maple
—
—
Shortleaf pine
66
101.00
Southern red oak
68
50.00
Virginia pine
74
114.00
Yellow -poplar
—
—
Nanford
Loblolly pine
90
131.00
Loblolly pine, Shortleaf pine
Northern red oak
—
—
Shortleaf pine
—
—
Virginia pine
—
—
USDA Natural Resources Web Soil Survey 3/28/2022
Conservation Service National Cooperative Soil Survey Page 5 of 6

Forestland Productivity --- Alamance County, North Carolina
Rocky Top Area of Interest
Forestland Prod uctivity—Alamance County, North Carolina
Map unit symbol and soil
name
Potential productivity
Trees to manage
Common trees
Site Index
Volume of
wood fiber
Cu ft/ac/yr
MaB—Mandale-Secrest
complex, 2 to 6 percent
slopes
Mandale
Loblolly pine
77
105.00
Loblolly pine, Shortleaf pine
Shortleaf pine
64
97.00
Secrest
Loblolly pine
77
105.00
Loblolly pine, Shortleaf pine
Shortleaf pine
64
97.00
Biscoe
Loblolly pine
77
105.00
Loblolly pine, Shortleaf pine
Shortleaf pine
64
97.00
MaC—Mandale-Secrest
complex, 6 to 10 percent
slopes
Mandale
Loblolly pine
77
105.00
Loblolly pine, Shortleaf pine
Shortleaf pine
64
97.00
Secrest
Loblolly pine
77
105.00
Loblolly pine, Shortleaf pine
Shortleaf pine
64
97.00
Biscoe
Loblolly pine
77
105.00
Loblolly pine, Shortleaf pine
Shortleaf pine
64
97.00
W—Wate r
Water
—
—
—
—
Data Source Information
Soil Survey Area: Alamance County, North Carolina
Survey Area Data: Version 21, Jan 21, 2022
USDA Natural Resources Web Soil Survey 3/28/2022
am Conservation Service National Cooperative Soil Survey Page 6 of 6