The URL can be used to link to this page

Home My WebLink About20140820 Ver 6_BPDP Review - Caraway Bluff Phase II_20220920 Hamilton, Ryan From:Merritt, Katie Sent:Wednesday, September 21, 2022 4:52 PM To:Hamilton, Ryan Subject:FW: BPDP Review - Caraway Bluff Phase II Attachments:Comment Summary_DWR.pdf Follow Up Flag:Follow up Flag Status:Flagged Ryan, Please file email chain below and the attached Comment Summary into 2014-0820v6 From: Merritt, Katie Sent: Tuesday, September 20, 2022 5:32 PM To: Jamey McEachran <jmceachran@res.us> Subject: BPDP Review - Caraway Bluff Phase II Hey Jamey 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 September 1, 2022, Environmental Banc & Exchange, LLC (EBX) submitted a Bank Parcel Development Package (Plan) for the Caraway Bluff Phase II 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. Therefore, 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. In an effort to be as efficient as possible at providing comments to RS 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 Plan (without Appendices) as well as a comment summary. When EBX is ready to submit their final project Plan, please include a summary of all EBXs’ responses to the DWR comments acknowledging how EBX 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 6) 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 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 1 512 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. 2 Summary of Comments on CarawayBluffII_DWRedits.pdf Page: 2 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:16:48 PM project number is 2014-0820 version 6 Page: 4 Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:17:14 PM (UMBI) Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:19:20 PM need to show where the site can be accessed by DWR; include site access on a supporting figure and reference that figure here. Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:17:35 PM DMS DWR ID is 2014-0820 version 5 Page: 5 Number: 1 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:20:22 PM Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:20:25 PM site Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:20:13 PM Add the Preservation under (o)(4) here too since it's also alternative Page: 9 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:26:23 PM add a description for D2 since it's entering BH4 Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 5:06:16 PM within an existing conservation easement Number: 3 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:26:49 PM bisects the riparian area adjacent to BH3 and Number: 4 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:27:13 PM The Number: 5 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:27:27 PM was determined to not be viable Number: 6 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:27:04 PM bisects the riparian area adjacent to BH3 and Number: 7 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:27:54 PM and as indicated in the site viability letter Page: 13 Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:28:41 PM and agricultural ditches Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:28:57 PM mitigation Number: 3 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:29:07 PM riparian Number: 4 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:29:16 PM and preservation Number: 5 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:30:06 PM there is no need to reference (o)(7) since it doesn't apply to this site. However, (o)(4) needs to be added Number: 6 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:30:15 PM and the UMBI Number: 7 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:33:11 PM add a note that the riparian restoration and preservation efforts will begin immediately at the outermost easement boundary of the proposed DMS Full Delivery project where applicable, ensuring a contiguous conservation easement and forested condition at AsBuilt. Or some other way of wording this to mean the same thing. Number: 8 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:33:24 PM riparian Number: 9 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:33:30 PM riparian Number: 10 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:33:36 PM riparian Number: 11 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:33:45 PM riparian Page: 14 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:34:32 PM as noted in phone conversation, add clarity about the culverts. Which are being added, removed, etc. Make sure to update Figure 6 Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:40:59 PM as discussed over phone, what is EBX intending to do specifically for Ditch 6 since it is bypassing the riparian buffer and is not creditable. We discussed wetland species, live stakes of willow, etc. Page: 15 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:39:24 PM recommend this language or something similar to replace what is currently here: Within 30 calendar days after completing the establishment of the buffer mitigation and nutrient offset areas, the Sponsor will submit written notification to NCDWR documenting that all buffer mitigation and nutrient offset activities have been completed. Failure to submit written notification within 30 days may result in a modified credit release schedule or a delay in the issuance of credit releases. Number: 2 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:34:44 PM Number: 3 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:34:46 PM EBX Number: 4 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:34:53 PM shall Page: 16 Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:41:22 PM adjacent to Page: 19 Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:44:55 PM per the approved UMBI Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:45:20 PM DWR- Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:47:43 PM December 31 is in the UMBI language Number: 4 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:47:28 PM Number: 5 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:47:25 PM December 31 Number: 6 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:48:20 PM If approved by DWR as an acceptable long term steward for this Site, Number: 7 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:50:20 PM I did not see this letter/email, but do need this correspondence to make sure EBX is complying with the UMBI expectations Page: 20 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:53:45 PM per our phone conversation, once credits are updated in the table, these numbers will change Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:58:40 PM buffer Number: 3 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:55:54 PM restoration Number: 4 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:56:15 PM Number: 5 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:56:27 PM UMBI Number: 6 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 4:58:05 PM Number: 7 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:56:40 PM riparian buffer credits Number: 8 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:57:03 PM is expected to Number: 9 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:54:30 PM Nitrogen Number: 10 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:55:28 PM add a note that most of these credits are dependent on the approval and full implementation of the Caraway Bluff DMS F/D project Number: 11 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 4:57:45 PM add a note that final credits will be determined in a survey provided in the asbuitl report...or some custom language that speaks to this 1 2 3 4 5 Page: 21 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:01:51 PM as discussed, this table is old and needs to be replaced with the correct table Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:00:06 PM where applicable, edit feature name to include correct widths where DMS F/D affects Minimum width for bank. Example: Carraway Creek & BH1 (50-100') instead of "Carraway Creek & BH1" Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:00:34 PM check no Number: 4 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:02:09 PM diffused flow deductions are only required off D2 Number: 5 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:01:11 PM for BH3 on these two rows, add "right bank" Page: 22 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:03:51 PM replace this credit release schedule with the one used for Thunder Swamp II Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 4:53:14 PM - Page: 25 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:04:44 PM change Figure title to be "Riparian Buffer & Nutrient Offset Credit Service Area" or Riparian Buffer Mitigation and Nutrient Offset Credit Service Area. Page: 28 Number: 1 Author: kymerritt Subject: Cross-Out Date: 9/20/2022 5:06:41 PM Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 5:06:56 PM Conservation Easement Page: 29 Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/20/2022 5:07:36 PM Conservation Easement Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:07:55 PM add "Origin" Page: 30 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:10:41 PM this aerial may support your nutrient offset credit proposed in this area. If so, please comment about it in your response back tp DWR 1 2 34 5 6 7 Page: 32 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:11:06 PM show location of timber mat bridge Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:11:58 PM We discussed culvert naming conventions for adding clarity to what is existing, what is being removed, what is being added. Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:14:05 PM no deductions necessary on D5 Number: 4 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:14:43 PM D5 measurement is not correct. This area should be 0-100 off D5, not 101-200 off BH3 Number: 5 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:19:52 PM How did EBX justify NOC here? Number: 6 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:15:10 PM show D2 diffused flow deductions; show "no credit area" measured perpendicular and landward off D2 and remove radius off BH4 Number: 7 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:16:30 PM add radius to BH3 here since D2 is actually flowing away from BH3 and due to other unique properties of D2/BH3 connection. Page: 34 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:17:02 PM see comments on Figure 6 and adjust as needed. Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:18:09 PM if EBX proposes a special restoration plan around D6 as discussed on phone and as requested to be called out in the text of BPDP, then D6 should not include width boundaries. All boundaries here could be measured off BH3. Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:18:36 PM it would be beneficial to include all Stream Origin points to this map Page: 35 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/20/2022 5:19:20 PM update areas as requested on other figures.