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Home My WebLink About20201095 Ver 1_Double Rock Buffer Plan - DWR Review_20220516Summary of Comments on Draft DoubleRock Buffer Plan_DWR edits.pdf Page: 1 Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:27:02 PM Project # is 2020-1095 Page: 3 :Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:29:00 PM these photos are dated April 2021. Provide photos of riparian conditions that are dated more closely to when the Buffer Plan was submitted to DWR ,Number: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 1:09:56 PM Plan sheet 3.1 only shows that Permanent Seeding will be used in disturbed areas. However. as correctly addressed in section 4.1 of the Buffer Plan, it should be sitewide if there are non -disturbed areas, but areas that are bare and have no vegetation. Explain Page: 4 ¢,Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:32:55 PM General Comments: 1) This document represents a Buffer Mitigation Plan that is attached to a Stream Mitigation Plan. Remove all references to a "Bank Parcel Development Plan" or "BPDP" and change to "Buffer Mitigation Plan" and reference here on out as "Buffer Plan". 2) Conservation Easement included in this Buffer Plan is not the same as what was provided in the Stream Mit Plan. Explain the discrepancy and provide a figure that provides teh same CE boundary as what will be secured for the stream mitigation bank. ¢,Number: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:33:21 PM Add that the DWR ID# for the Stream site is 2020-1095) ;Number: 3 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:34:48 PM Did wildlands apply the non-standard buffer width tool toward their stream mitigation credits? If yes, explain and provide a supporting figure *yNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:39:13 PM Add more information to this section describing the crossings. Include the widths of all breaks and what activities will be restricted within those crossings. Will they be referenced in the Conservation Easement? How will the internal crossings be designed such that cattle passage isn't allowed in riparian areas and streams? Will they be ford crossings or culverted crossings? There are three breaks on figures provided with this Plan. However, no details on whether they are Internal is provided. Lastly, the crossings show on figures in this Plan do not correspond with the crossings or locations provided in the Stream Plan. Explain and update accordingly. Number: 2 Author: kymerritt Subject: Inserted Text Date: 5/16/2022 12:39:35 PM out from Page: 10 ;Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:40:25 PM see General comments regarding Conservation Easement ¢;Number: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:41:46 PM add a note that all activities associated with generating riparian buffer credit will occur at the same time as the stream mitigation activities and not before. if this is not the intent, Explain. ;Number: 3 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:53:26 PM Is fescue going to be treated during parcel preparation? Explain why or why not. If being treated, explain how. J:Number:4 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:44:43 PM As seen on other sites planted in pasture areas, compacted soils are likely present throughout the entire area where riparian restoration activities are being performed due to the historical use of the land as pasture. DWR recommends site wide ripping, not just selected ripping, for this reason such that planted stems have lower risk of mortality associated with soil compaction. Page: 11 ¢,Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:48:47 PM Tag Alder is proposed in the wetland areas as shown in the table in Appendix E. DWR is okay with Tag Alder in the planting list as long as it is only planted within the small wetland areas indicated on Plan Sheet 3.1. Tag Alder is not an appropriate species to plant site wide on buffer mitigation sites since they are known for adding nutrients to the soil. Our buffer protection rules are focused on limiting/removing nutrients to surface waters, including in the soils of riparain zones. Commit to ensuring that Tag Alder will not be planted site wide and will only be within small wetland areas. ;Number: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:49:49 PM Wildlands will be held to this planting list at AsBuilt, which includes planting 13 species. Is this section accurate in that Wildlands will be planting a minimum of 13 species? ;Number: 3 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:52:19 PM Adjust performance standards to include trees AND shrubs. rule allows shrubs to be included in the 260 stems/acre and is cited as: "the final performance standard shall include a minimum of four native hardwood tree and native shrub species" Number: 4 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:56:22 PM Citation of rule should be (o)(4) for the preservation of streams for crediting on this site. Explain the 25% cap on preservation credits and which steam/s Wildlands is submitting under (o)(4) for crediting Page: 12 ;Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:57:02 PM modify language in this section to accommodate shrubs towards perf standard. Page: 13 JNumber: 1 Author: kymerritt Subject: Inserted Text Date: 5/16/2022 1:00:16 PM riparian buffer credits ¢,Number: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 12:59:28 PM add a note about how the credits comply with the 25% cap for Preservation. Also add a note that none of the riparian buffer credits generated on this site are convertible or transferrable to nutrient offset credits. Page: 19 Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 1:01:18 PM modify this map to correspond to the same CE boundary and location of crossings (internal and external) as what is going to be used to describe the Stream bank. Page: 23 ;Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 1:02:36 PM stream restoration and stream enhancement were shown in the Stream Plan in Figure 9a. This legend only shows Stream Restoration. update accordingly based on what is going to be proposed for the Stream Mitigation Plan. .wNumber: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 1:02:55 PM this crossing is not shown in 9a of the Stream Plan. Explain. ;Number: 3 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 1:07:07 PM there are BMPs in the riparian restoration areas shown on figures provided in the Stream Plan. Since these BMPs are being constructed within riparian areas that are generated riparian restoration credit for this buffer bank, Wildlands needs to include the BMPs on this Figure and in corresponding text of the Buffer Plan. Add additional information that describes how the BMPs will be planted and explain the purpose of these BMPS. DWR cannot ensure the BMPs meet compliance for the buffer mitigation rule without this additional information included in this Buffer Plan. If these BMPs intend to be more like vernal pools that are not going to be planted, then those areas will need to be removed from the Total Creditable Area column in the Project Credit Table with a specific row dedicated to the square footage of these BMPs. Page: 24 Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2022 1:07:33 PM update figure as previously requested