20211422 Ver 1_Dutch Farms Comment Summary_BufferPlan_20220613

DRAFT BUFFER MITIGATION & NUTRIENT OFFSET PLAN
DUTCH FARMS SITE
Guilford County, North Carolina
DWR Project Number: 2021-1422 v1
Haw River Subwatershed of Jordan Lake
8-Digit HUC 03030002114-Digit HUC 03030002040010
Mitigation Bank Sponsor. -
Davey Mitigation, A Division of Davey Resource Group, Inc.
(attn. T.J. Mascia, Director)
Prepared by:
Davey Resource Group, Inc. dba Land Management GroLip
Raleigh, NC
January 2022

Summary of Comments on Buffer Plan_DutchFarms
DWRedits.pdf
Page: 3
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 1:01:15 PM
Add plan sheets PI-2 and PL2A since they are relevant for the vegetation plan on this bank site
Number: 2 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 11:44:27 AM
the Buffer MBI will not be an Appendix to the 401 Plan or the Buffer Plan it's a standalone product and therefore remove this Appendix from the
Plan (and 4011404 Mit Plan as well)

Page: 4
,,Number: 1 Author: kymerritt Subject: Sticky Note
Date: 6/13/2022 11:27:44 AM
edit to read "Buffer Mitigation and Nutrient Offset Plan"
Number: 2 Author: kymerritt Subject: Sticky Note
Date: 6/13/2022 11:42:42 AM
The bank sponsor, if Davey Mitigation, should be referred to here
on out in this Plan as "Sponsor" instead of as 'DM" to avoid confusion.
Therefore, where DM is used, replace it with Sponsor.
Number: 3 Author: kymerritt Subject: Sticky Note
Date: 6/13/2022 11:41:04 AM
add "Proposed" to the MBI language
Number: 4 Author: kymerritt Subject: Sticky Note
Date: 6/13/2022 11:43:35 AM
Remove reference of Appendix AA from the section and anywhere else it is referred to. the MBI will not be an Appendix to the Buffer Plan or the
401/404 Mit Plan.
,;Number: 5 Author: kymerritt Subject: Sticky Note
Date: 6/13/2022 11:41:22 AM
pNumber: 6 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 11:45:14 AM
Add the DWR Number for the stream Plan, which is also 2021-1422 version 1.
Number: 7 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 11:48:56 AM
Regarding the stream credits - is the Sponsor proposing to use the non-standard buffer width tool towards stream crediting? If not, please provide
that information here. DWR needs to make sure no buffer credit is being proposed in the wider riparian areas ()beyond 50') if stream credit is
being sought for wider buffers.
iqFlNumber: 8 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 12:32:43 PM
viability determinations for riparian buffer and nutrient offset viability determinations for riparian buffer and nutrient offset

Page: 5
LTINumber: 1 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 12:32:45 PM
Number: 2 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 12:32:55 PM
Division of Water Resources
LEI Number: 3 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 12:40:13 PM
resaectively.
IwNumber:4 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 12:42:30 PM
while this may be true, this goes against the Nutrient offset method DWR is authorizing the Sponsor to use to generate nutrient offset credits on
the site (see MBI). There is no "cattle exclusion" benefit recognized in that Method so do not imply that the 1,169 lb/year or 120 Ib/yr are
somehow are supported by that Method.
Number: 5 Author: kymerritt Subject: Sticky Note
Date: 6/13/2022 12:43:27 PM
provide the widths of the maintenance breaks/crossings and explain how they will designed to ensure cattle do not have access to the stream and
riparian zones.
itlNumber: 6 Author: kymerritt Subject: Inserted Text
Date: 6/13/2022 12:49:55 PM
stream
Number: 7 Author: kymerritt Subject: Inserted Text
Date: 6/13/2022 12:50:16 PM
this Plan
JNumber: 8 Author: kymerritt Subject: Inserted Text
Date: 6/13/2022 12:50:31 PM
mitigated
Number: 9 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 12:50:55 PM
Number: 10 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 12:50:52 PM
and adjacent riparian areas are
Number: 11 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 12:53:00 PM
nutrient offset is only viable where the minimum width is obtained at 50'. Will any riparian zones be less than 50' and if so, point those areas out
in Figures and on the corresponding Project Credit Table. those areas less than 50 feet will not be viable for nutrient offsets.
.yNumber: 12 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 12:53:38 PM
the 3.16 acres of Preservation may change after credits are altered based on DWR edits and comments.

,Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 12:58:26 PM
Make sure the Conservation Easement you are using is the Joint 404/Buffer Easement

*Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 1:00:05 PM
These photos are not timestamped. Photos needs to be as current as possible, and represent the riparian conditions at the time the Buffer Plan
was submitted to DWR.

Page: 12
,,Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 1:02:50 PM
PL2 and PL2A need to be added to the Buffer Plan as either Figures or Appendices. They are also in G of the 404/401 Plan, but because these two
plan sheets are so relevant to the buffer plan, they need to be tied directly to the Buffer Plan as well and made "a part of of this Plan specifically in
addition to the 404/401 plan

Page: 13
,;Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 1:05:02 PM
the 30' distance from the TOB is not shown on supporting Figures. Add to a figure and then reference the figure here. Please note that the 50'
distance from TOB will also need to be shown on figures with the crediting adjusted where applicable. see further comments on Project Credit
Table
;Number: 2 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 3:25:12 PM
change rule reference to be 0295 (o)(6) as indicated in the Site Viability Letter for Enhancement via Cattle Exclusion.
JNumber: 3 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 1:06:56 PM
Number: 4 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 1:07:02 PM
LTI Number: 5 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 1:07:05 PM
P

Page: 14
4UNumber: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 1:09:04 PM
the vegetation plan includes both shrubs and trees but the performance standards that the Sponsor is using here only speak to Trees. The rule
allows for a mix of shrubs and trees to be used towards performance standards, so if shrubs and trees are planted, you may want to edit the
language to allow for that. specific reference to rule is 0295 (n)(2)
.FjNumber: 2 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 1:27:19 PM
Tag Alder is a nutrient fixing tree and is not an acceptable species to plant on buffer and nutrient offset crediting sites where the goal of the
planting plan is remove nutrients from the soil, not add nutrients. It is presented as being planted only within the Streamside Assemblage area.
What is the width of the streamside assemblage area? If greater than 10', then Alder needs to be removed from the Planting plan.

Page: 15
*Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 2:10:10 PM
This is a nice robust list of diversity. DWR needs to make sure the Sponsor is going to be compliant with expectations regarding minimum density
requirements (have to be at least 4), no more than 50% of any one species, etc at AsBuilt. We also want to make sure the Sponsor is planting a
mix of Canopy and Subcanopy species and not too many shrubs vs trees. The Sponsor needs to highlight any tree species they are certain will be
planted on the site and then have other tree species noted in the tables as "possible substitutions" if those certain trees happen to be unavailable.
This will help me determine whether the planting plan will meet expectations at AsBuilt.
Number: 2 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 2:11:33 PM
For Zone 1 and 3 add a column to show Canopy/Subcanopy and denote which are shrubs.

Page: 16
,;Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 2:13:13 PM
Add language to 3.6 committing to have the easement properly marked with posts and signs prior to the DWR site visit for Task 2 of the credit
release.
,FjNumber: 2 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 2:14:35 PM
Create a 3.7 and add language from the MBI about the 30-day notice of site completion to DWR
,FjNumber: 3 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 2:32:43 PM
This Plan is for the Sponsor to get Buffer & Nutrient Offset credit according to the Credit Table. However, this section only speaks to Buffer credit
areas being monitored. Explain.
Number: 4 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 2:35:14 PM
no earlier than late August of each year.
The MBI states this requirement.
Number: 5 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 2:17:01 PM
consecutive
Number: 6 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 2:34:45 PM
If the Sponsor is planting trees and shrubs, you may want to request that the monitoring performance standard be written to allow for shrubs to
be included. if shrubs are not noted in 4.1, then only trees will be allowed to be counted towards performance standards
Number: 7 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 3:02:34 PM
the 2% plot expectation should be based on the Planted Area of the Buffer/Nutrient offset areas. Revise plots amounts based on this Planted
Area, not including the Wetland planted areas.
LE Number: 8 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 3:01:34 PM
nutrient offset and riparian
LTJ Number: 9 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 3:01:45 PM
*Number: 10 Author: kymerritt Subject: Sticky Note
Date: 6/13/2022 3:04:01 PM
recording heights for volunteer species is not required for this Plan.
Le Number: 11 Author: kymerritt Subject: Inserted Text
Date: 6/13/2022 2:35:32 PM
qualitative and quantitative
LE Number: 12 Author: kymerritt Subject: Inserted Text
Date: 6/13/2022 2:33:16 PM
common name,
Number: 13 Author: kymerritt Subject: Inserted Text
Date: 6/13/2022 2:33:02 PM
vigor
Number: 14 Author: kymerritt Subject: Sticky Note
Date: 6/13/2022 2:37:13 PM
just so Davey understands, the monitoring reports for this Plan are not submitted as Appendices with the 404/401 monitoirng reports. They are
completely separate reports.
Number: 15 Author: kymerritt Subject: Sticky Note
Date: 6/13/2022 2:36:14 PM
add that monitoring reports complying with this Plan must be submitted
to DWR by December 31 of each year.

Page: 17
JNumber: 1 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 3:09:08 PM
performance standards
JNumber: 2 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 3:09:16 PM
LE Number: 3 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 3:09:19 PM
T
,,Number: 4 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 3:10:43 PM
add language that commits to the assignment to the steward by Year 4 (see MBI)
JNumber: 5 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 3:11:11 PM
1
Number: 6 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 3:11:58 PM
this is spelled out in the MBI and not needed here.
JNumber: 7 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 3:11:28 PM
;Number: 8 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 3:17:56 PM
This Bank is supposed to be a Nutrient Offset & Buffer Bank, however, in order to approve that, the Initial Credit release has to have nutrient offset
credits AND riparian buffer credits released to the Sponsor. Section 6.0., corresponding figures and the project credit table only depict Buffer
credits. The Sponsor must determine where nutrient offset credits will be derived in the Buffer Plan. Currently, most of the areas proposed as
Buffer restoration are viable for Nutrient offsets except where riparian restoration is less than 50' from TOB. As proposed, DWR cannot approve
this bank to provide nutrient offsets. Keep in mind, when determining where nutrient offsets will be derived, the MBI has language that restricts
converting nutrient offsets in the 100-200' width to buffer credits and that will still be required for this Bank if the Sponsor chooses that width to
provide nutrient offsets. Lastly, no areas chosen for Nutrient Offsets can be used towards the Preservation cap, so your preservation area for credit
will shrink. These are just a few things to consider when deciding where nutrient offsets will be derived.

Page: 18
Number: 1 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 3:19:27 PM
described in this Plan
,;Number: 2 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:05:42 PM
this paragraph will change once edits are made with regards to nutrient offsets.
,;Number: 3 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:06:09 PM
do not combine Restoration & Enhancement numbers as they are treated differently in the way they are allowed to be converted.
Number: 4 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 3:18:40 PM
being proposed
,;Number: 5 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 4:26:17 PM
Add the Delivery Factors for Nitrogen and Phosphorus to this section. The 14-digit HUC of this project location is how you retrieve that
information. Take note, that the 14-digit HUC you have indicated throughout this plan, including on the cover letter and in the Project Credit
Table, reflects the incorrect HUC information. The 12 digit is 030300020301 but i don't have the 14 digit at the moment
Number: 6 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 3:22:13 PM
This section also needs to provide the amount of Generated Credits (Nitrogen and Phosphorus). Generated credits are described in the MBI and
are calculated as the credits before applying the delivery factor.
Number: 7 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 5:06:38 PM
and cattle exclusion areas
Number: 8 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 5:07:03 PM
and Enhancement
,,Number: 9 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 3:20:05 PM
the Project Credit Table needs to be moved to Section 6.0 and titled Table 4.0. Currently, it is in the Appendix.

Page: 20
,;Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 3:26:25 PM
clarify this service area is for Riparian Buffer Credits and Nutrient Offset Credits.
,Number: 2 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 3:45:38 PM
the service area for this site is in the Haw River Subwatershed.

Page: 23
,;Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 4:43:56 PM
edit this map according to comments provided in the Plan:
-Need to show nutrient offset credit area
-Show 50' width so that i cna verify the minimum widths are met for nutrient viability
-prove no widths are less than 30 or otherwise show on the figure
,;Number: 2 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 4:50:47 PM
state the following:
Riparian Restoration for (buffer credits?)
1+1 Number: 3 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 4:49:46 PM
Number: 4 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 4:51:03 PM
for Buffer Credits
Number: 5 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 4:49:58 PM
Number: 6 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 4:51:12 PM
for Buffer Credits
+Number: 7 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 4:50:01 PM
JNumber: 8 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 4:51:18 PM
for
Number: 9 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 4:50:04 PM
LE Number: 10 Author: kymerritt Subject: Inserted Text Date: 6/13/2022 4:51:23 PM
for

Page: 28
,Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 4:59:41 PM
see comments are Figure 4 and do the same on this figure. make sure there are plots representative of both buffer credit areas and nutrient offset
credit areas.
Number: 2 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 4:58:42 PM
Number: 3 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 4:58:45 PM
+Number: 4 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 4:58:46 PM
_F Number: 5 Author: kymerritt Subject: Cross -Out Date: 6/13/2022 4:58:48 PM

0
2
0
Tahlel- hute h Farms Mitigation Site, OWR N
2022-1422 v1,
Project Credits
a
Cape Fear-Jordanik-M300020 OIC
Project Art
5
64.5511
L�'L
N Credit Conversion Ratio(ft'/poM
?I63.I
P Err, d it Conversion Ratio rl4l
Subject?tenter
Credit Type
NO iI
Location
FeatureType
MitirativnAHiYFty
Min -Mao Duller
Feature Name
Total Area (ft'i
Total(Credltable)
Area of Buller
Initial Credit
%Full Oredlt
Final Credit
Eomeruhle Eo
Riparian
Riparian Bvtfer Cvnrerlible to
nelivered.
Nvident Offset:
Delivered
Nu[lierd
ephemeral yr
Width lHl
Mitig.dan (H'l
Ra[iO la:ll
wio(.:l)
wrleO
Credits Nutde
nr Offset?
N(16sj
Olhet: Pill
ditch 1)
85",
Aural
Yes
/p
Restoration
0-100
UT
1M,469
194,469
100%
100000
Yes
194,469000
Yes
3,012. WA
898R3
Butter
aural
Yes
lip
Restoration
I01 200
UT 1
3.688
3.668
1
33%
3.03C30
Ycs
1.210.441
Yes
56.823
1.695
8.ff"
Rural
rRo
l (p
REReraliev
0.100
OT 4, UT f, UT 7, UT 8
284,926
284,926
1
100%
1.60000
Yes
284,926.000
Yes
4,413,919
131,693
Suffer
Rural
No
lip
Restoration
101.200
UT 4, U19
4,W
4,fiR7
I
3W
3,030M
Yes
1,546.712
Yes
72.l
2.1E6
R.l
Rural
No
I / P
R—stlon
0-100
OT 5
20.969
20,959
1
1DD%
1A0)00
Yes
20,969.000
No
—
—
Total Buffer (ftzj:
Total Nutrient Otfset Ift2l:
Total Ephemeral Area (fl for Credit:
Total Eligible Ephemeral Area (ftr),
Enter Preservation Credits Below
Credit Type Location Subi-t? Feat. re Type Mitigation Activity Min -Mao euHerI Feature Name
W dth Ift{
Rural No I1P Oleo UTS
Preserve tion Area
TO TAIL AREA OF BUFFER MITIGATION (TABMI
Mitigation Totals
Sq,uale Feat
Credit.
Restoration:
508.719
503,121,153
Enhance man t:
28,699
14, 349.500
Preservation:
14,825
2,965.000
Total Riparian BuN.r:
SSLZ43
52(143SA53
TOTAL NUTRIENT OFFSET
MITIGATION
Mitigatim Totals
Squen.Feet
Sgdke
NI[r on:
0.p00
Nutrient Offset:
PJt horys:
0
Doan
fl.i ,.,%TARN
m a, %TABFR
T—UCredltahlel
Total A—lsf) Area fnr Buffer Initial Credit %Full Gedlt Final Credff Riparian
Mitigatil Ratio le:ll Rativ(g:ll Buffer Credl6

Page: 29
*Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:08:17 PM
label Table 4.0 and move to section 6.0. Edit title to include "Buffer & Nutrient Offset"
,Number: 2 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:02:24 PM
this table must match corresponding Figure 4 and 9
,;Number: 3 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:08:59 PM
this is the wrong 14 digit HUC for this project
,;Number: 4 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:04:34 PM
per the MBI, if you chose "Nutrient Offset" in column 1 for widths 100-200' which is most commonly done by others, then this will be checked "no"
per the MBI
Number: 5 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:00:42 PM
there has to be Nutrient Offset selected as a Credit Type on at least one of these rows to be approved as a Nutrient Offset & Buffer Bank.
,;Number: 6 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:02:06 PM
Nutrient Offset is only viable and convertible where widths are a minimum of 50'. For any areas less than 50', add a row to show that width as only
for Buffer Credit.
,,Number: 7 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:02:52 PM
Total Eligible preservation will change when issues are addressed iwth the crediting.
,;Number: 8 Author: kymerritt Subject: Sticky Note Date: 6/13/2022 5:03:30 PM
there needs to be credits shown here to be able to be reviewed and approved as a Buffer & Nutrient Offset Bank