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.
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�—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