MR Review Yr2 - Banished Bull

From:
Hamilton, Ryan
To:
Baker. Caroline D
Subject:
FW: MR Review Yr2 - Banished Bull
Date:
Thursday, December 22, 2022 1:00:46 PM
Attachments:
imaoe001.ono
Hi Caroline,
Please file
Laserfiche Upload: Email
DWR#: 2020-0047v2
Doc Date: 12/22/2022
Doc Type: Mitigation Monitoring Report Review
Doc Name: Same as email subject
Thanks,
Ryan Hamilton
401 & Buffer Permitting Branch
Division of Water Resources
North Carolina Department of Environmental Quality
[phone] Cell
Location: 512 N. Salisbury Street, Archdale Building, Raleigh, NC 27604
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Email correspondence to and from this address is subject to the
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From: Hamilton, Ryan
Sent: Thursday, December 22, 2022 12:34 PM
To: [e-mail]
Cc: Merritt, Katie <[e-mail]>
Subject: MR Review Yr2 - Banished Bull
Hello Mike,
DWR has reviewed the Year 2 Monitoring Report for the Banished Bull Site. Comments on the report
are provided as follows:
1. There were three issues pointed out in the MR1 review that were subsequently not addressed
in the MY2 Report. These issues must be addressed in all future monitoring reports. Issues are
as follows:
a. Height data for stems in table 8 did not include the units of measurement. It assumed
height measurements are in centimeters, but this information must be included.
b. The correct DWR ID# is 2020-0047v2, not 2020-0047. The version number must be
included, and the ID# must be recorded correctly throughout the report.

c. Vigor data for each planted stem in monitoring plots must be included in the
monitoring reports but was not provided in MY1 or MY2 reports. At a minimum, the
average vigor for plots will suffice for this requirement.
2. Supplemental planting throughout approximately half the site was conducted in February
2022. Neither the Year 1 Report summary nor the plot data collected in October of 2021
suggested issues warranting the need to provide such extensive supplemental planting. Lastly,
the provider is required to notify DWR of all adaptive management, including supplemental
planting, and receive approval prior to implementation. Explain why there was no mention of
adaptive management being necessary in the MY1 report. Our records show that the
provider did not notify DWR or seek approval of the supplemental planting efforts prior to
implementation. Please explain. Moving forward, the provider is not to implement such an
extensive adaptive management without first notifying DWR.
3. In addition to the low stem density recorded in plots 2 and 6, there is also a low stem diversity
in plots 3 and 6. One of the performance standards for riparian restoration sites is to have a
minimum of 4 different species of trees represented consistently across the site. Plot data is
one way we can determine if this performance standard is being met. The plot data in #3 and
#6 suggest that this performance standard is not being met. Explain how this plot data for #3
and #6 represent the areas in and around the plots and if that data is representative of the
stem diversity within those areas. If it is determined that this data does in fact represent the
diversity around these plots, this information should be included in the report and any
remedial actions deemed necessary by the provider to achieve this performance standard
needs to be detailed in the report.
4. The adaptive management plan attached to this monitoring report includes the planting of
300 one -gallon trees in the winter of 2022-2023. One of the species being considered for this
supplemental planting is Red Maple (Acer rubrum). Red maple was not included in the original
approved planting list, and therefore should not be used in supplemental planting unless a
specific reason for doing so is provided and approved by DWR. DWR approves the adaptive
management plan included in the report with the exception of planting Red Maple. If the
provider still chooses to plant Red Maple, this species cannot be used towards measuring the
performance standards for stem density or stem diversity.
Once DWR receives a response to all comments above, DWR will consider issuance of a partial
credit release with the remaining credits to be released upon confirmation that the AMP has been
fully implemented.
Additionally, confirmation of bond renewal through next year's monitoring period will also be
required before the issuance of a credit release.
Thank you for your patience,
Ryan Hamilton
401 & Buffer Permitting Branch
Division of Water Resources
North Carolina Department of Environmental Quality
[phone] Cell
Location: 512 N. Salisbury Street, Archdale Building, Raleigh, NC 27604

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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.