20140820 Ver 5_ Caraway Bluff Mit Plan - DWR Review_20220803

From:Merritt, Katie
To:Hamilton, Ryan
Subject:FW: Carraway Bluff Mit Plan - DWR Review
Date:Friday, August 19, 2022 12:06:33 PM
Attachments:CarawayBluff DWR Comment Summary.pdf
Please file the attached doc as well as the Email chain below in LF under 2014-0820 version 5
(title the doc same as Subject heading)

From: Merritt, Katie
Sent: Wednesday, August 3, 2022 4:42 PM
To: Xu, Lin <[e-mail]>
Cc: Dow, Jeremiah J <[e-mail]>; Wojoski, Paul A <[e-mail]>
Subject: Carraway Bluff Mit Plan - DWR Review

Hey Lin,

Pursuant to Titles 15A NCAC 02B .0295 and 15A NCAC 02B .0703 (e), a provider shall submit a
project plan proposal to the Division for review and approval that includes specific elements of
the project. On May 17, 2022, the Division of Mitigation Services (DMS) submitted a
Mitigation Plan (Plan) for the Carraway Bluff Site, to the Division, for review and approval.
According to the initial review by DWR staff of the subject Plan, some elements were either
not provided, not explained thoroughly, not accurate or lacking in sufficient information.

In an effort to be as efficient as possible at providing comments to DMS during this busy time,
I have provided my comments in a different format. Attached are the comments & edits
provided within the actual PDF of a condensed Buffer Plan (without Appendices) as well as a
comment summary.

Until DWR receives an updated Plan addressing all comments and edits provided in the
attached 1) comment summary and 2) PDF version of the document itself, DWR cannot
finalize the review of the Plan or issue an approval of the Plan.

When DMS is ready to submit their final project Plan, please include a summary of all DMS’
responses to the DWR comments acknowledging how DMS addressed the comments. Please
upload the final Plan using our Mitigation Project Information Upload Form through this link:
https://edocs.deq.nc.gov/Forms/Mitigation_Information_Upload . Please note the DWR ID#
2014-0820 (version 5) on all electronic submissions for this project.
Thank you for your patience during this time and if you have any difficulty reading though the
comments or edits please let me know.

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, Raleigh, 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.

Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
401 & Buffer Permitting Unit
North Carolina Department of Environmental Quality
Work Cell: 919-500-0683
Website: https://deq.nc.gov/about/divisions/water-resources/water-quality-permitting/401-
buffer-permitting/nutrient-offset-buffer-mitigation-program

512 N. Salisbury Street, Raleigh, NC 27620
1617 Mail Service Center, Raleigh, NC 27699-1617

Mitigation Plan Checklist for Riparian Restoration Mitigation Sites –created 7/15/13
DWR Stream Determination
DWR Site Viability Letter
Site Location
o Directions including Lat & Long
o 8-digit HUC &/or 14 digit (if applicable)
o County
o EMC approved Soil map, Topo and Aerial Maps
o Sub-watershed where applicable
Existing Site Conditions w/ photos
All proposed mitigation activities, including a brief summary of stream and/or wetland mitigation w/
a detailed planting plan
Monitoring & Maintenance Plan
Financial Assurance (if applicable)
Associated buffer and/or nutrient offset credit calcs, which shall include credit generation, service
area, etc.
Credit Determination Table/Map
Verification that the site does not have an impact on threatened or endangered species
Verification that the site is not affected by on-site or nearby sources of contamination as provided
by Environmental Data Resources, Inc.
Verification that the site can be constructed on land if it is an archaeological site;
A list of all permits that will be required and obtained prior to constructing the mitigation site for
nutrient offset and/or buffer mitigation (e.g. Sediment and Erosion Control Plan from Division of
Land Resources, NCG010000 Stormwater Permit from NCDWQ, 404 permit from the Army Corps
of Engineers and corresponding 401 Water Quality Certification from NCDWQ).
Project Name:
__________________________
Reviewed By:
__________________________
DWR # ___________________
Date _____________________
Carraway Bluff
Katie Merritt
2014-0820v5
August 3, 2022
measurements of widths and crediting were not provided off Neuse River TOB, need to
change measurements & credits hat were taken off Caraway Creek ; BH3 NOC potential is
incorrect; see comments on Figures and Table 4
N/A
Note: Overall, this plan was very well put together and mostly complete. More thorough comments and edits are included in the
PDF provided in email correspondence by DWR to DMS on August 3, 2022.
Summary of Comments on CarawayBluff
MP_DWRreview.pdf
Page: 1
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 3:32:04 PM
DWR ID# is 2014-0820 v5
Page: 4
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 3:33:28 PM
EBX is referenced a couple of times as EBX, LLC in the document. Inconsistent naming can lead to confusion so it's recommended this be
edited in the document where applicable.
Page: 8
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 3:36:27 PM
as described here, the sewer easement is within the Zone 1 of the Neuse River, not within Zone 1 of Caraway Creek as it appears to be shown in
Figure 9 and represented in the Table 4. Correct the Table 4 and corresponding figures to show the TOB off Neuse River contributing to
crediting rather than it being Caraway Creek.
Page: 9
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 3:39:57 PM
it is best to describe the adjacent closed out bank project as the "Caraway Creek Bank Parcel"
It is recommended that when describing the buffer and nutrient offset project that EBX plans to develop in conjunction with this DMS site, that
it be referenced as "Caraway Bluff Phase II Bank Parcel".
Page: 10
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 3:41:08 PM
it should be noted that the right bank of D4 also is within an existing CE
Page: 12
Number: 1 Author: kymerritt Subject: Inserted Text Date: 8/3/2022 3:52:39 PM
which are regulated under
Number: 2 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 3:52:18 PM
comments on Table 4 may affect crediting amounts that will need to be updated in this paragraph.
1
2
Page: 14
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 3:56:28 PM
there should be a row depicting total area and total buffer credits measured off TOB of the Neuse River, but it appears those credits and areas
are tabulated within the Carraway Creek amount. edit the table accordingly.
Number: 2 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 3:58:42 PM
BH3 has an area correctly shown on Figure 8 that is not viable for nutrient offset. therefore, there will need to be two rows for BH3. One for the
restoration areas that are convertible to NOC and another where it reads BH3 (1998 cleared) and NO for convertible to NOC
Page: 27
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:02:39 PM
At a point that will mark the end of Caraway creek as it enters the Neuse River so that it isnt confusing as to which feature these measurements
will be derived.
Page: 31
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:09:10 PM
change "NCDWR Bank" to "Private Bank"
Make this change on all other figures.
Number: 2 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:17:03 PM
the yellow and orange CE boundaries are difficult to decipher when looking at the hard copy vs the electronic copy. It is recommended that the
map depicts the bank site CE differently (not orange) so that when or if the plan is printed as a hard copy, it will be easy to decipher.
Number: 3 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:10:56 PM
change "Existing Buffer and Nutrietn Offset Bank" to "Caraway Creek Bank Conservation Easement" and make the same change to other figures.
Number: 4 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:11:47 PM
add "riparian" to all credit types below
Example: "riparian" restoration 0-50; riparian preservation 0-100'....
Number: 5 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:07:36 PM
it is not clear what this area is supposed to depict or whether this area is measured off Caraway Creek or BH2. Should this be yellow or should
it be "ineligible buffer credit area"? add clarity to the figure
Based on the site viability letter, it appears that more areas along BH2 should be called out for being cleared in 1998 and ineligible for buffer
credit. Explain
Number: 6 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:06:08 PM
Same as comment above off BH2;
it is not clear what this area is supposed to depict or whether this area is measured off Caraway Creek or BH1. Should this be yellow or should
it be "ineligible buffer credit area"? add clarity to the figure
Page: 35
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:15:20 PM
need to clarify that all these areas are "Riparian Restoration" areas.
Number: 2 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:14:22 PM
this ineligible NOC area is not depicted in Table 4. see comments on Table 4
Page: 36
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:18:22 PM
are these measurements taken from TOB of the Neuse River? If so, great and Table 4 needs to depict the same. If no, correct to be measured
off TOB of NEuse and update Table 4 to reflect the change.
Number: 2 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:19:35 PM
When looking at this map off BH2 and BH1, Figure 5 may not be accurate. please cross check the two.
Page: 38
Number: 1 Author: kymerritt Subject: Sticky Note Date: 8/3/2022 4:20:34 PM
as mentioned on previous figures make sure to add "riparian" to the different approaches.