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Home My WebLink About20220293 Ver 2_BPDP Review - Britt & Hales_20230221From: Merritt, Katie To: Baker. Caroline D Cc: Hartshorn. Blake Subject: Fwd: BPDP Review - Britt & Hales Date: Wednesday, February 22, 2023 8:24:33 AM Attachments: BPDP Comment Summarv.odf Caroline, Please File email thread below with the attached document. title the file same as the subject of the email. Please combine email and pdf into 1 pdf before filing in LF. Thank you. Get Outlook for iOS From: Merritt, Katie <katie.merritt@ncdenr.gov> Sent: Tuesday, February 21, 2023 3:06 PM To: Jordan Burbage <jordan@ecoterra.com> Cc: Mitigation <mitigation@ecoterra.com> Subject: BPDP Review - Britt & Hales Hey Jordan, 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 22, 2022, Eco Terra, LLC (Eco Terra) submitted a Bank Parcel Development Package (Plan) for the Britt & Hales 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 Eco Terra 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 Eco Terra is ready to submit their final project Plan, please include a summary of all Eco Terra's responses to the DWR comments acknowledging how Eco Terra addressed the comments. Please upload the final Plan using our Mitigation Project Information Upload Form through this link: https://edocs.deci.nc.gov/Forms/Mitigation_ Information_ Upload . Please note the DWR ID#2022- 0293 (version 2) 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 Acting Supervisor —401 & Buffer Permitting Branch 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://deg.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. ID#* 20220293 Version* 2 Select Reviewer: Katie Merritt Initial Review Completed Date 09/26/2022 Mitigation Project Submittal - 9/22/2022 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 CompanytOwner: * Eco Terra, LLC Contact Name: * Michael Beinenson Project Information Yes No Email Address: * m itigation@ecoterra.com Project Type: ❑M5 Mitigation Bank Project Name: Britt & Hales Riparian Buffer Mitigation Site County: Wayne Document Information Mitigation Document Type: Mitigation Plans File Upload: 2022-09-22 Britt & Hales BPDP Submittal.pdf 28.41MB Please upload only one POF of the complete file that needs to be submitted... Signature Print Name: * Kerry Bray Signature: * cl�vt f�/- ow Buffer Mitigation & Nutrient offset Plan El Britt & Hales Riparian Buffer Mitigation Site Neuse River Basin HUC 03020201 Wayne County, NC 2 NCDWR Project #: 20220293 V1 _y r SPONSORED BY: PREPARED BY: ocolterra • WADAMS 117 Centrewest Court 2905 Meridian Parkway Cary, NC 27513 Durham, NC 27713 SEPTEMBER 2022 PREPARED FOR: North Carolina Department of Environmental Quality Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Summary of Comments on BrittHales6PDP_DWRedits.pdf Page: 2 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:38:15 PM this is more than a "Riparian Buffer Mitigation Site", it is also a Nutrient Offset site. rename title accordingly. r Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:37:36 PM use ProjectlD#2022-0293v2 am Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:38:48 PM these photos are not timestamped to show this date. edit accordingly. Page: 5 oNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:39:33 PM rename project title as previously commented. QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:41:24 PM this document is a "Bank Parcel Development Package" as referenced in the MBI. Change mitigation plan to BPDP here and throughout the Plan. Number: 3 Author: kymerritt Subject: Cross -Out Date: 2/21/2023 1:00:05 PM QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:42:30 PM Bank Sponsor name needs to include the company name as seen on the Secretary of State Website, which includes the "LLC". Edit accordingly. Number: 5 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 1:00:14 PM proposed QNumber: 6 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:04:02 PM it is important to introduce the applicable rules for which this BPDP is being submitted. Need to reference 15A NCAC 02B .0295 (for buffer mitigation) and 15A NCAC 02B .0703 (for nutrient offset). It is also necessary to state somewhere in this section that riparian restoration for generating nutrient offsets will be done in accordance with the MBI since Rule 0703 doesn't specifically speak to riparian restoration for generating nutrient offsets. QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:43:48 PM The service area is incorrectly cited. The service area for this bank's credits is the neuse 03020201, excluding the Falls Watershed. Please add "excluding the Falls Watershed" to this paragraph and correct throughout the document where applicable. QNumber: 8 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:45:54 PM "The final project area will be delineated and depicted in the As -Built Survey and submitted with the As -Built Survey. Therefore, credit totals may change slightly depending on the As -Built survey." it Number: 9 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 12:51:02 PM Parcel QNumber: 10 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:53:58 PM where references where restoration and preservation will occur, the plan mostly says "adjacent to streams". But this plan includes a lot of restoration adjacent to ditches as well. Edit the plan throughout to be more specific of where the restoration will actually be taking place. By just mentioning streams, this is inaccurate. QNumber: 11 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:35:41 PM When describing the restoration areas, make sure to include "and adjacent riparian areas" . In some sections, it only says the riparian restoration or preservation of "riparian buffers". However, "Riparian Buffer" is defined in rules as having a "Zone 1" and a "Zone 2" and only being the area adjacent to streams depicted on certain maps. Not all of your streams on this Parcel were deemed "Subject to the Buffer rules", therefore using the term "Riparian Buffer" is not accurate for describing those areas. Errors can simply be avoided byjust saying "riparian buffers and adjacent riparian areas". I have corrected this in the Plan in some areas, but i did not correct it in all sections. Number: 12 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 12:54:13 PM and adjacent riparian areas. Number: 13 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 12:52:20 PM project features (streams and ditches) Number: 14 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 12:51:42 PM a minimum width of 50' from tops of banks and extend out QNumber: 15 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 12:59:22 PM when describing nutrient offset, we do not (and are not allowed) to use "mitigation". The term "mitigation" for this Parcel can only be used when descriving the buffer mitigation credit areas/credits. Check through the plan and make sure this is edited accordingly. I recommend switchig the phrase to say "riparian buffer mitigation and nutrient offset" or "nutrient offset and riparian buffer mitigation" Number: 16 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 12:57:49 PM mitigation Number: 17 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 12:59:50 PM DWR-approved IC Number: 18 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 12:59:42 PM Comments from page 5 continued on next page according to the MBI. *Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:05:28 PM photo dates were quite a while ago. indicate any changes, if any, that have occurred on the Parcel since the photos were taken. this includes any landuses or conditions that were not seen on the date the viability assessment was conducted by DWR. Page: 7 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:17:42 PM it says that bank erosion will be stabilized as part of the "buffer restoration". Change "buffer" to "riparian" to be all inclusive of buffer and nutrient offset areas. Details regarding what kind of "bank stabilization" will be performed needs to be added in detail to section 4.1. Therefore, add a reference to 4.1 here knowing that those details need to be added to the final draft. *Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:10:11 PM is this buried culvert in good condition? is it impeding any flows? speak to the condition of this culvert. *Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:19:57 PM It says the culvert is remaining to provide access for the landowner. Reference Section 2.10 here and then be sure to define "access" in Section 2.10. considerations for text in Section 2.10: Will this be an " internal crossing" and therefore an access easement, which is deeded and recorded with the Deed/Conservation Easement but isn't generating credits but also where the Bank Sponsor or Long Term Steward have control over the crossing..., or will the crossing be an "external crossing", and completely located outside of the conservation easement? There are only these 2 options if leaving a culvert in place for a landuse to have access. If the access is only to allow him to "walk" from one side of the stream to the other, then no issues. But if the intent of this crossing to allow vehicular access, then you have to choose 1 of the 2 options in my comments. add details where needed and update figures where needed. * Number: 4 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:14:05 PM update name (PNumber: 5 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:18:12 PM this table doesn't clarify the service area for credits. add the service area to this table as "neuse 03020201, excluding the Falls Watershed" (PNumber: 6 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:14:48 PM make sure "RBC" and "NOC" are defined below the table or somewhere in the Document if using this acronym. *Number: 7 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:15:16 PM March 2023 may not be feasible. i recommend changing to "late March or early April" Page: 11 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:20:36 PM see comments in Section 2.2 and address in detail here followed by references to supporting figures. TI Number: 2 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 1:21:04 PM and adjacent riparian areas Page: 12 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:24:09 PM explain the minimum and maximum widths for the riparian restoration. i need to know that Ecoterra is meeting the minimum widths for buffer mitigation at 1:1 (which is 30') and for nutrient offset at 1:1. (which is 50') Number: 2 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 1:21:42 PM and adjacent riparian areas Number: 3 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 1:24:21 PM riparian *Number:4 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:25:40 PM Non -diffused flow is an issue on this Parcel with Al. But restoring diffused flow in not addressed in this Plan, which is required in rule. How is EcoTerra addressing non -diffused flow of A1? wNumber: 5 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:27:20 PM please explain what is meant by "mechanically controlled" and what is meant by "chemically controlled". Make sure to indicate that you will be using aquatic safe herbicides by a licensed applicator wNumber: 6 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:26:12 PM details of "minor bank stabilization" needed Number: 7 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 1:34:49 PM riparian wNumber: 8 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:34:41 PM on many as -built site walks in the past, ive witnessed where the tops of ditch/stream banks are void of planted stems (anywhere from 5-25' landward void of stems). Please make sure this plan addresses this to make sure Ecoterra oversees the planting efforts of planting crews and commits to adequate stem placement to include tops of banks. otherwise, if at the Asbuilt walk this area is void of stems, there will be a required supplemental plant before credit releases. Number: 9 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 1:44:44 PM and in the MBI gbNumber: 10 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:31:19 PM the expectation, is that EcoTerra will make sure the stems are well mixed in the bags BEFORE they are planted by the crews. The way this is worded doesn't meet that expectation. reword the sentence to acknowledge this expectation Commit to ensuring that stem species will be well mixed before planting to ensure diversity of bare roots across the planted area. Page: 13 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:45:15 PM Buttonbush is a shrub, but is listed as a tree? In order to plan shrubs and have shrubs be counted towards performance criteria, this BPDP will need to indicate that the performance standard EcoTerra wants to be held to, is 260 trees and shrubs. the MBI allows you to choose 1 of 2 performance standards according to Rule 0295 (n)(2). 1) Trees, or 2) trees and shrubs. According to Section 4.2 and 5.0, EcoTerra intends to use the performance standard forjust trees. If this is correct, remove all shrubs from the table and just show trees in the planting list. If not, adjust the Planting plan accordingly and update the performance standards that apply to the planting plan. *Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:41:15 PM If 16 species of trees are shown in the table, DWR expects 16 species to be planted. If anticipating to plant less than 16 species, you need to at least indicate the minimum # of species Ecoterra will plant. Ecoterra indicated only a minimum of 4 species ... if that is true, DWR cannot confirm the "approximate percentage" column would comply with the performance standard of "no one tree species will be greater than 50V as noted on Rule 0295 (n)(2). Additionally, with the minimum proposal of 4, Ecoterra is at risk for not meeting the performance standard for stem diversity if less than 4 species end up in plots or fail to thrive/survive. The standard in rule is 4, but hopefully EcoTerra is intending to plant more based on the comment above. However, at this time, the column on '% of total planted trees", which is required to include in this plan, is not accurate unless EcoTerra truly plants 16 species (all adding up to be 100%). Adjust the table accordingly I understand that changes to planting plans can happen. If any changes are needed to the planting list before planting, EcoTerra will need to submit a request to DWR for approval of that modified planting list if not listed as an approved tree/shrub in table 8. DWR will accept a FEW substitutions if EcoTerra wants to include those few potential substitutions in a Table 8b...but you must include the % those subs are intended to be utilized in the case you need those substitutions. Page: 14 gpNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:45:58 PM update this section accordingly based on previous comments regarding trees vs trees & shrubs. Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:46:41 PM a general note: EcoTerra should take measures to ensure that plots are diverse (have 4 species represented as much as possible) and where a species does not represent more than 50% of the plot. All plots need to be representative of the planted diversity and density surrounding the plot and will be evaluated by DWR during the onsite AsBuilt Walkthru to ensure these criteria are met. All DWR comments provided on planting plan & monitoring are being provided under the following Rule reference 15A NCAC 02B .0295 (n)(2-4). *Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:52:29 PM the 2% is taken from the Total Planted Area, the total planted area is represented in Table 10 as the "Total Area" and shown to be 968,380 square feet, which is approximately 22 acres. How did 18 plots get calculated? �Number:4 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 1:49:17 PM and the corresponding MBI IV Number: 5 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 1:49:59 PM buffer mitigation rule Page: 15 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:53:45 PM it is expected that in order to meet the performance standards, and to be able to determine if the Health of stems is sufficient (0295)(2)(E), the data that needs to be committed to being collected are: species, height, planting date (or volunteer) and Vigor. add clarity to this paragraph on what data, both qualitative and quantitative" will be collected for the vegetation. gbNumber: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:55:22 PM add language to this section committing to marking these boundaries prior to the Task 2 milestone and DWR site walk. the credit release schedule for task 2 requires a site visit, so in order to make sure task 2 is fully completed, the boundaries need to be marked. Page: 16 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:56:39 PM to comply with the MBI, the monitoring bond must be 100% of the estimated cost, but no less than $100,000. Edit the text accordingly. Does EcoTerra anticipate more than $100,000? Wumber: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:57:32 PM reiterate that the total credit generation for RBC and NOC will depend on the final survey.... *Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 1:59:36 PM add any non -diffused flow deductions required for Al, unless able to diffuse flows. if diffusing flows, make sure to describe your methods in section 4.0 Number: 4 Author: kymerritt Subject: Inserted Text Date: 2/21/2023 2:00:45 PM Riparian Buffer Credit (RBC) areas and Nutrient Offset Credit (NOC) areas Number: 5 Author: kymerritt Subject: Cross -Out Date: 2/21/2023 2:01:06 PM Number: 6 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:03:11 PM it is best tojust refer to the table where the credit assets are summarized and refer to the appropriate figures that support that table. The is referred to as the "Project Credit Table" in the MBI, so please use same references here. wNumber: 7 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:08:18 PM you can summarize the credit assets similar to the following text, all other details and specifics of crediting should be deleted with references added to table 10 and supporting figures. "Riparian restoration adjacent to the streams is primarily intended to be used to generate RBC out to 100' and to generate NOCs beyond 100' in width. Riparian restoration adjacent to the ditches will be used to generate NOC because they are not viable to generate RBC. Credits that could be converted from RBC to NOC if still available are depicted in Table 10. Any credit conversion requests must be submitted to DWR in writing and receive written approval froM DWR prior to debiting or crediting credits from the Parcel's credit ledgers." Page: 17 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:14:16 PM this table is correct, but it could be consolidated if EcoTerra wanted to reduce the amount of rows and work effort involved in separating it out. The supporting Figure will definitely have to change, but how you depict the credits in the table is up to you. My recommendations are as follows: Consolidate features that are the same (Ditch, Subject Streams, Non -Subject Streams) and have the same characteristics (mitigation activity, width). for example: Al, 131, B2 are all ditches and all used for Nutrient Offset. Show two rows instead of your 6: one row for 0-100' and one row for 101-200. *Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:08:56 PM update title *Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:09:10 PM update table title to include nutrient offset in the name Page: 22 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:15:59 PM add "RBC and NOC Service Area - Neuse 03020201, excluding Falls Watershed" gbNumber: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:15:04 PM this is a Nutrient Offset & Buffer Mitigation Site Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:16:20 PM Modify the boundaries to clarify the service area to be only neuse 01 below Falls. Verbiage should read "Neuse 03020201, excluding the Falls Watershed" Page: 23 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:19:06 PM label the "Stream Origins" on this map using the letter from Shelton Sullivan as a reference. Add the Stream Origin labels to all figures. Page: 27 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:22:28 PM show as Internal or External ... see further comments on Figure 8 and in text for Section 2.10. Number: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:53:20 PM UT2 and UT3 to not need to be differentiated since they are both subject streams and both using RBC in the 0-100' width and NOC in the 101-200' width. Color code the same. Table 10 also does not need to show UT2 and UT3 on separate rows..combine in table as well. *Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:43:59 PM this corner needs to be shown as nutrient offset off B2 ditch. it is currently shown as buffer credit on UT2. While i don't disagree that this can and has been argued in the past, measuring in this way is not consistent with the way we require the banks and dms to measure their credit generating areas. we have consistently measured it this way since before i can even remember reviewing the plans. edit the figure accordingly and update the Project Credit Table to reflect the change of RBC to NOC. It is only necessary within the first 50', beyond that width, you can measure however you wantto *Number: 4 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:24:42 PM i know a lot of hard work went into generating this figure, but it needs to be modified to show less. It doesn't mean the figure is wrong necessarily, but when the survey is prepared, i want to make sure EcoTerra has a good figure that the surveyor can use in knowing what they need to prepare measurements for and where. Number: 5 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:53:49 PM Edit the figure based on the following comments: 1) change Riparian Buffer Credits to "Riparian Restoration for RBC" or "Riparian Preservation for RBC", whichever is applicable 2) Change Nutrient Offset Credits to "Riparian Restoration for NOC" 3) Show all Subject Streams in one color to represent RBC and a different color to represent NOC. All subject streams should be color coded the same two colors. 4) Show all Non -Subject Streams in one color to represent RBC and a different color to represent NOC. All non -subject streams should be color - coded the same two colors. 5) Show all the ditches in one color for 0-100' and another color for 101-200. All ditches should be color coded the same two colors. Example: Show A1, B1 and B2 on the same row, one color to represent the 0-100' for NOC and another color (or hatching) to represent the 101-200'. Do not depict 6 rows to depict this information. It should all be depicted in the PRoject Credit Table the same as in this figure. *Number: 6 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:45:31 PM remove the ratios, RBC amounts, and SF. Table 10 accounts for all that, the figure does not this extra information. *Number: 7 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:48:55 PM "Approximate" plot locations are approved by DWR via this Plan approval. while the figure labels them "approximate", please know, that Plot placement, while random, still has to be approved by DWR. Where ever the plots are shown to be placed in this Plan, they are required to be placed on the ground and will be confirmed during the AsBuilt site walk for Task 2 at the best of DWR staff ability. gpNumber: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:22:00 PM this crossing needs to be identified as Internal or External. If External, remove from the Red Easement Boundary. How wide will this crossing be? Show that width on the figure. Wumber: 2 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:21:06 PM thank you for using straight lines for the easement boundary. Number: 3 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:20:41 PM show non -diffused flow and any deductions necessary or other method for approval. qDNumber: 4 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:20:06 PM add "Planted Area" to the Legend and depict the planted area. Page: 30 Number: 1 Author: kymerritt Subject: Sticky Note Date: 2/21/2023 2:54:25 PM Document the dates these photos were taken on the pictures