20200047 Ver 2_MY2BannishedBull_ResponseToDWRComments_20230201

ID#* 20200047
Select Reviewer:
Katie Merritt
Initial Review Completed Date 02/03/2023
Mitigation Project Submittal - 2/1/2023
Version* 2
Is this a Prospectus, Technical Proposal or a New Site?*
Type of Mitigation Project:*
Stream Wetlands Buffer Nutrient Offset
(Select all that apply)
Project Contact Information
O Yes O No
Email Address:*
Contact Name:* mherrmann@watershed investment
Michael Herrmann snc.net
Project Information
ID#:* 20200047 Version:* 2
Existing ID# Existing Version
Project Type: DMS • Mitigation Bank
Project Name: Banished Bull Buffer Mitigation and Nutrient
Offset Site
County: Orange
Document Information
Mitigation Document Type:*
Mitigation Bank Information
File Upload: MY2BannishedBull_ResponseToDWRComments.pdf 1.56MB
Please upload only one PDF of the complete file that needs to be submitted...
Signature
Print Name:* Michael Herrmann
Signature: *
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February 1, 2023
Katie Merritt & Ryan Hamilton
Nutrient Offset & Buffer Banking Coordinator
NCDENR-Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Response to Monitoring Year 2 NCDWR Comments for the Banished Bull BPDP (DWR#
2020-0047v2)
Dear Ms. Merritt & Mr. Hamilron:
This is a reponse to NCDWR’s review of Version 1 of the Monitoring Year 2 Report for the
subject mitigation bank submitted for your review on 10/17/22. NCDWR’s comments were
provided in an email from Ryan Hamilton dated 12/22/22. Also, as noted in this response,
Adaptive Management Measures approved in the response were implemented with changes
due to the NCDWR feedback.
An electronic version of the project bond renewal is included this
submission. In addition, a hardcopy will be delivered to the division.
If you need to discuss the project, please contact me at
[e-mail] (email) or 919-559-6264 (phone).
Thank you for your review,
Mike Herrmann
1630 Weatherford Circle, Raleigh NC 27604 | Tel : [phone] | www.watershedinvestmentsnc.net

Response to DWR Comments on Version 1 & 2 of the Banished Bull BPDP

Comment 1: 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.
Response to Comment 1:
A. Height measurements are in centimeters and will be included in future year monitoring
reports. If there is a preference for feet/inches, please advise and we will provide that.
B. The need for this correction is noted and it will be included in future monitoring reports.
C. We will provide reporting of vigor data in future monitoring reports.

Comment 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.
Response to Comment 2:
Supplemental bare stem planting was triggered by Ripple EcoSolutions’ warranty of at least 80%
survival on the bare stems planted at a density of 680 stems/ac,. The MY1 stem counts averaged 521
stems/ac across the site, below 544 stems/ac warranty. This triggered the warranty and led to the work
being undertaken by the contractor. Both fieldwork and monitoring data were used to target bare root
replanting areas where either visible stems were more sparse or plot counts were below the threshold.
This trigger for the replant was not revealed until after the report had been approved which was why it
was omitted from the MY 1 report Moving forward, Watershed Investments will seek approval from
DWR prior to implementing extensive adaptive management.

Comment 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.

Response to Comment 3
For Plot 6 and the surrounding area, the supplemental planting adaptive measures proposed in
the report address concerns over both the lack of abundance and diversity. For Plot 2, the
adjacent monitoring transects #7 and #9 show species diversity of 4 and 5 different counted
plant types, respectively. Overall, monitoring plots had 10 different planted species present
with platanus occidentalis (American Sycamore) counting as 20% of the stems.

Species diversity for the site will continue to be monitored and considered for adaptive
management measures if performance measures for the site are not being met.

Comment 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.
Response to Comment 4
Planting of the 300 1 gal plants occurred on 1/10/23. Based on DWR comments, Red Maple
were removed from the plant list. All planted 1 gallon species were on the approved BPDP
list for the Site. Planting species and numbers are provided below:

1-Gallon Planted Species # of Plants
Betula nigra - River birch 55
Platanus occidentalis - Sycamore 70
Celtis occidentalis - Hackberry 40
liriodendron tulipifera - tulip poplar 40
Diospyros virginiana - Persimmon 40
Quercus michauxii - Swamp chestnut oak 55