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HomeMy WebLinkAbout20220139 Ver 2_BPDP Comment Summary_20220727Summary of Comments on 20220139 Ver 2-Draft Salem BPDP_DWRedits.pdf Page: 2 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 3:49:44 PM reference Table 5 here and it's called "Project Credit table" as also referenced in the MBI Page: 3 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:21:50 PM EDR Summary not included. Page: 4 �—wNumber: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:05:00 PM "Parcel" should be used throughout the BPDP to represent the bank site. However, "Project", Bank, "Site" and "parcel" are used throughout and thus is becomes confusing what is being referred to. The MBI template refers to the site as a "Bank Parcel", therefore "Parcel" or "Bank Parcel" should be used instead of "Project". correct errors accordingly. Number: 2 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:22:39 PM proposed Number: 3 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:22:29 PM Bank Parcel Development Package for the QNumber:4 Author: kymerr the effective date was April 1, 2020 QNumber:5 Author: correct 0.703 to .0703 [ilNumber:6 Author: Subject: Sticky Note Date: 7/27/2022 4:23:22 PM Subject: Sticky Note Date: 7/27/2022 4:22:56 PM Subject: Inserted Text Date: 7/27/2022 4:23:35 PM �Number:7 Author: kymerritt Subject: Inserted Text Date: 7/27/20224:25:15 PM Performance standards will be consistent with the NOBI and 15A NCAC 02B .0295 (n)(2). Number: 8 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:24:25 PM remove the term "mitigation" from this Plan. We do not define "nutrient offset" as a type of "Mitigation". Where applicable, just rename to '.nutrient offset" Number: 9 Author: kymerritt Subject: Cross -Out Date: 7/27/2022 4:24:28 PM Number: 10 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:25:32 PM , excluding the Falls Lake Watershed. Number: 11 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:25:45 PM offset credit �—wNumber: 12 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:26:13 PM section 5.0 says 11.17 acres will be restored. Explain the difference Page: 5 Number: 1 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:26:38 PM at the confluence with Ditch 2, Page: 6 Number: 1 Author: kymerritt Subject: Cross -Out Date: 7/27/2022 4:27:13 PM Number: 2 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:26:58 PM is acceptable Number: 3 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:27:53 PM the stream and the two Number: 4 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:28:24 PM on the Parcel as indicated Number: 5 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:28:34 PM Site Viability *)Number: 6 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:30:29 PM add details that includes stream A as part of this plan. include commiting that a small segment of stream a will be within the ce to ensure that they hydrological connection of Ditches 1 & 3 remain secured. Page: 7 *)Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 3:58:42 PM Why is ripping not being proposed? Usually long-term agricultural uses result in compacted soils, making it difficult for trees to grow without ripping the soils. Explain. *)Number: 2 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:29:10 PM Add language that any amendments made will be documented in the AsBuilt Report. *)Number: 3 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:12:03 PM How is diffused flow being maintained by Ditches 1, 2, 4 & 5? explain. DWR is supportive of using creative ways to create diffused flow. Suggest ideas for review (i did talk to Daniel about one idea) Make sure to reference Figures and the Project Credkt Table, because the project credit table must include the areas deducted for diffused flow in the calcs. ❑� Number: 4 Author: kymerritt Subject: Cross -Out Date: 7/27/2022 4:34:04 PM Number: 5 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:32:56 PM the uppermost reach of Number: 6 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:33:38 PM as it �Number:7 Author: kymerritt Subject: Inserted Text Date: 7/27/20224:35:08 PM at the confluence with Ditch 2. Riparian restoration also includes the right bank of Ditch 3 where it begins to flow towards the stream on the Parcel (see Figure 5) �Number:8 Author: kymerritt Subject: Inserted Text Date: 7/27/20224:32:32 PM along VNumber: 9 Author: kymerritt Subject: Inserted Text Date: 7/27/20224:33:32 PM along the left bank of the 4PINumber: 10 Author: kymerritt Subject: Cross -Out Date: 7/27/2022 4:34:09 PM Number: 11 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:36:37 PM within the conservation easement for purposes of establishing healthy stems *)Number: 12 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 3:52:00 PM Commit to ensuring that stem species will be well mixed before planting begins to ensure diversity of bare roots across the planted area. r—Number: 13 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:06:58 PM It is crucial tojump start an herbaceous cover on ag lands that are being converted to nutrient offset sites. Thus, please add the following commitment: "An appropriate seed mix will also be applied to provide temporary and permanent ground cover for soil stabilization and reduction of sediment loss during rain events in areas without existing herbaceous cover" Indicate the type of seed mix WLS will use to meet herbacous cover. Ail Number: 14 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:32:06 PM Trees will be planted Number: 15 Author: kymerritt Subject: Cross -Out Date: 7/27/2022 4:32:12 PM Number: 16 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:31:54 PM consequtive ❑+ Number: 17 Author: kymerritt Subject: Cross -Out Date: 7/27/2022 4:35:25 PM Number: 18 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:35:53 PM Comments from page 7 continued on next page Any changes to species proposed to be planted will have to pre -approved by DWR prior to implementation. Number: 19 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 3:58:26 PM 1. Rule says a minimum of 4 species, you have 11 proposed. DWR will hold WLS accountable to the number of species in this table, so if WLS intends on planting less than 11, commit to the absolute minimum WLS will plant and identify which of those 11 (if not all) will definitely be likely to be planted. You can include "alternative species" to be planted if species you selected become unavailable. 2. it is important to include a planting plan where you have canopy and subcanopy species. Add a column for this to the table and identify which species are canopy and which would be subcanopy and make sure to add a subcanopy species if there isn't currently one included. 4. include the type of riparian seed mix you are going to use. it must prove to be native and not likely to outcompete planted trees like bermuda or fescue Number: 20 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:05:33 PM It is highly recommended that providers agree to include pollinator species in their seed mixes. DWR understands this is not a requirement, and that providers do not have to do this. Therefore, adding it into your plan is only a suggestion and completely voluntary. Number: 1 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:37:37 PM will Number: 2 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:37:33 PM are Number: 3 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:37:25 PM qualitative and quantitative �Number:4 Author: kymerritt Subject: Inserted Text Date: 7/27/20224:38:17 PM consecutive Number: 5 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:37:44 PM proposed �—wNumber: 6 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:38:42 PM need to add Vigor Number: 7 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:38:31 PM vigor Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:07:46 PM the MBI requirements state December 31 so that needs to be used here. Number: 2 Author: kymerritt Subject: Inserted Text Date: 7/27/20224:39:12 PM restored riparian Number: 3 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:10:56 PM Edit parts of this section to cite MBI: Within 30 calendar days after completing the establishment of the nutrient offset areas, the Sponsor will submit written notification to DWR documenting that all nutrient offset activities have been completed. Documentation shall include the following: Short summary of activities completed as required per the approved BPDP; Figures representing all riparian restoration, riparian enhancement and riparian preservation activities where applicable; Figures representing location of all monitoring plots installed; Detailed planting plan- including type of species planted, density of species planted, and any modifications to the planting plan from what was approved in the BPDP; Description of how the conservation easement boundaries were marked; Any major changes to the conservation easement boundary or to the amount of Nutrient Offset Credits from what was proposed in the approved in the BPDP. �Number:4 Author: kymerritt Subject: Inserted Text Date: 7/27/20224:39:41 PM completed Number: 5 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:00:53 PM use this section to explain how the Conservation Easement is designed to ensure Ditch 1 & 3 remains directly hydrologically connected to Stream A. (it should be noted here, that a small segment of Stream A (10-20'??) is actually included in the CE. Number: 6 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:41:01 PM commit to including the Tops of banks of all features at a minimum the CE. Centerline is preferable Page: 10 Number: 1 Author: kymerritt Subject: Cross -Out Date: 7/27/2022 4:41:19 PM r,—PNumber: 2 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:08:46 PM Add language commiting to adequately marking the boundary prior to Task 2, not the submittal of the AsBuilt Report. The newer MBI template should have this language already. Number: 3 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:41:27 PM nutrient offset Number: 4 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:13:58 PM if WLS is planning to be the landowner, then the MBI requires that the long term steward be chosen at the outset of the approved BPDP. If WLS isn't going to be the landowner, then add language consistent with the MBI language that long term steward will be chosen prior to the year 4 monitoring period Page: 11 Number: 1 Author: kymerritt Subject: Inserted Text Date: 7/27/2022 4:41:48 PM BPDP rPNumber: 2 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:42:43 PM this credit yield may change after editing table per comments. Number: 3 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:42:23 PM show credits in pounds of Nitrogen [i-]Number:4 Author: kymerritt Subject: Inserted Text Date: 7/27/20224:42:11 PM the Project Credit Table (Table 5.0) ,r--�, Number: only refe Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:14:30 PM this memo where you plan to apply it. L Table 5. Proposed Mitigation Credits an Table S. Salem, 2022-0139 VI, Project Credits New, 03020201. Outside Falls lake Project Area 19.1E39d N Credit Conversion Ratio(ft'/pound) N!a P Credit Cpnyersion Rativ (ftr/pound) su2,1e024uee NOM n-Mae Rune, TorellUetlkablel I halal Gedit Frnal Gedit Conyer0bleto Ripa,lan suRer [anre,tlblem DrM,ed Iblrrred Gedll Type locetbn lOh—le, Featurelype Mldgetbu M.Ry Widlfi{R} Feature Name Torel Area[KI Areaol Buffer Ratio {rrl} %Full Credk Retb(a:tl Rl perlan GldiR NutrkM IXhet7 Nutrient d7ret Nuelen[CNfaeC dtb*. Millgatlen (Kl duifer7 ry{Ihsl PI11gl Nurient Offset Rural No Ouch Restoration P100 Pl Pl 215,875 _ 19 ],207 1 10 33. No No yes yes 12, 308173 102902Fd N1driNtOffset Rural No Pitch Restorallen 141-= Nldriapl Offset Rural No Dkch Res[oratlpn 0d100 03 32,513 1 10056 Np Yu 1,696.572 - MOffset RRrdl No Pitch Resteration 101-200 03 20,9a0 1 0% Np yes 1.092677 2 Tptak jk;)l a86,530 a 0.000 25,38T.7a6 0.000 Total PuNRr (R2): 0 0 3 Tff otal Nutrient Oset lftz}: 4d8,530 NIA Total Ephemeral Area lft`j for Credit: 0 0 Total Eligible Ephemeral Arlo: 0 0.0% Ephemeral Readies m%TABM Enter PrexryatioP Cred NF 9elow Total Flig Ibin for Pre s nratien ft': 0 0.0% Preservation as%TAMA Totrl (Geditahkl Credit Type te(aNUB Sebpecti FNturelype Mlhgatbu Artlally MIrvMaR BuNer Flrl{1rl Herne 7ebl plea [d} ArN fot RORer lRkbl Cradk XFNIILYtl! Final Gedk Riparian WNer Wbq (� Mltlga110r1 IR' M[b jn:lj — Rrtb lal) Uadlb P....tiOn Area Strbtet b (fej:1 0 L. TOTAL AREA OF BUFFER MIAGATION (TAW} Miligntiun ToW, —Rnet Credits Restoration: 0 0.000 Enhancement: C 0000 pre .imr: 0 Total Riparian Ruff- 0 0.000 TOTAL NUTRIENT OFFSET MITIGATION Mitigation Totals re Feat Credits Nutrient Offsnt: Nitragae: A86,530 Is.ln].116 Phwphurusb 4 Page: 13 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:43:07 PM correct the project number to version 2 Number: 2 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:17:06 PM add a line item for showing diffused flow deductions since those areas are still required to be being planted and still represent "Total Area" of the site. Credit Type = Nutrient Offset Feature Name/s = Diffused Flow deductions Total Area = how much area is deducted Total Area for Buffer Mitigation = 0 then check No in both boxes for the credits. Number: 3 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:20:32 PM Stream A needs to be represented in this table since it technically is a feature included in the CE and is the whoel reason Ditch 1 and Ditch 3 can be used for crediting. update figures to adequately represent restoration adjacent to the small segment of Stream A (make sure to measure perpendicular and landward Page: 16 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:43:39 PM All figure titles include "Mitigation" in the name. Change to Nutrient Offset Page: 21 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:44:31 PM label Stream A Page: 22 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:45:19 PM show stream origina again here and label stream A. Show credits measured off Stream vs ditch and make sure the project credit table includes that as well. Page: 23 Number: 1 Author: kymerritt Subject: Sticky Note Date: 7/27/2022 4:45:37 PM show stream origina and label stream A