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Home My WebLink AboutSalem BPDP - DWR 2nd ReviewFrom: Hartshorn, Blake To: Baker. Caroline D Cc: Merritt. Katie Subject: FW: Salem BPDP - DWR 2nd Review Date: Friday, March 10, 2023 4:17:00 PM Attachments: imaae001.Dna DWR Comment Summary Rev2.Ddf 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, Blake Hartshorn From: Hartshorn, Blake Sent: Friday, March 10, 2023 4:15 PM To: catherine@waterlandsolutions.com Cc: Merritt, Katie <katie.merritt@ncdenr.gov> Subject: Salem BPDP - DWR 2nd Review Hey Catherine, 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 February 3, 2023, Water & Land Solutions submitted a second draft of the Bank Parcel Development Package (Plan) for the Salem Site, to the Division, for review and approval. DWR provided comments on the first draft of this Plan on July 27, 2022. According to the second 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 WLS 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 WLS is ready to submit their final project Plan, please include a summary of all WLS' responses to the DWR comments acknowledging how WLS 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#2022- 0139 (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. Blake Hartshorn (he/him) Mitigation Specialist, Division of Water Resources North Carolina Department of Environmental Quality Office: (919) 707-3684 blake.hartshorn(@ncdenr.gov EW c xreMm&mce Go- sod k" INs address, auyett fo ML PloM Ca+�hYaa A�,Lhc Re6tiuVs law and rnsy be &wMsed fa Wd pa7-m ID#* 20220139 Version* 2 Select Reviewer: Katie Merritt Initial Review Completed Date 02/03/2023 Mitigation Project Submittal - 2/312023 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 Contact Name.,* Catherine Roland Project Information ID#:* 20220139 Existing IIJ# Project Type: DIMS Mitigation Bank Project Name: Salem Nutrient Offset Bank County: Wayne Document information ........................... ..................... Mitigation Document Type: Mitigation Plans Yes No Email Address:* catherine@watedandsolutions.com Version: 2 Existing Version File Upload: Draft Salem Nutrient Offset Plan _Feb 2023.pdf 27.41MB Please upload only one PDF of the complete file that needs to be submitted... Signature Print Name: * Catherine Roland Signature: * &1?4 6-11 �iY-�� Summary of Comments on 20220139 Ver 2-Draft Salem Nutrient Offset Plan Feb 2023 20230203 Page: 5 Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 3:11:47 PM It appears based off Table 5. 11.17 acres will be restored for nutrient offset credit. Please explain why it says 12.32 will be restored for nutrient credit. This comment was also on the draft BPDP Page: 7 ;Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 1:44:42 PM As requested in original draft comments, please acknowledge stream A here as well. 'Number: 2 Author: bhartshorn Subject: Highlight Date: 3/9/2023 10:49:42 AM Sentence doesn't make sense. Should it say "on the Parcel as indicated by the approved NCDWR Site Viability Letter...? Number: 1 Author: bhartshorn Subject: Cross -Out Date: 3/10/2023 1:50:19 PM Number: 2 Author: bhartshorn Subject: Inserted Text Date: 3/10/2023 1:49:40 PM is secured — Number: 3 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 1:53:42 PM Throughout this report please make sure to use nutrient offset credit when describing the credits rather than "nutrient" only IT] Number: 4 Author: bhartshorn Subject: Highlight Date: 3/10/2023 1:51:19 PM Correct to be DWR Number: 5 Author: bhartshorn Subject: Inserted Text Date: 3/10/2023 1:53:23 PM offset —)Number: 6 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 1:59:46 PM As per previous DWR comments on the draft: It is crucial tojump start an herbaceous cover on ag lands that are being converted to nutrient offset sites. Thus, please add the following commitment: "An appropriate seed mix will also be applied to provide temporary and permanent ground cover for soil stabilization and reduction of sediment loss during rain events in areas without existing herbaceous cover" Indicate the type of seed mix WLS will use to meet herbacous cover. Could add to table 3 or create new table. Number: 7 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 2:02:48 PM As per previous DWR comments on the draft: It is highly recommended that providers agree to include pollinator species in their seed mixes. DWR understands this is not a requirement, and that providers do not have to do this. Therefore, adding it into your plan is only a suggestion and completely voluntary (DWR expects a response if not implementing) —,Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 2:08:07 PM What is the intent with using transect plots indicated in Fig 7 and how will you utilize them in the monitoring reports? Please add additional information in Section 4.1(are they rotating, what are the sizes, etc.) Number: 2 Author: bhartshorn Subject: Highlight Date: 3/10/2023 2:10:50 PM I am calculating 11.51 acres according to Table 5. Why is it noted 12.32 acres are being restored? ,Number: 3 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 2:15:40 PM Just so you know, DWR expects the veg plots to be shown in the location as depicted in Fig 7 at As Built. Page: 11 ;Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 2:44:52 PM Further in this sections it states WLS is the landowner, therfore UP2Save must be recorded as the Grantee of this conservation easement prior to the first credit release. However, it is still the process that the formal transfer of responsibilities of the CIE occurs after at Task 9. Number: 2 Author: bhartshorn Subject: Highlight Date: 3/10/2023 2:17:40 PM A DWR approved Number: 3 Author: bhartshorn Subject: Cross -Out Date: 3/10/2023 2:33:07 PM Number: 4 Author: bhartshorn Subject: Inserted Text Date: 3/10/2023 2:33:04 PM DWR issuance of the final credit release as described in the credit release schedule of the MBI, Number: 5 Author: bhartshorn Subject: Cross -Out Date: 3/10/2023 2:17:00 PM Number: 6 Author: bhartshorn Subject: Inserted Text Date: 3/10/2023 2:17:14 PM steward — Number: 7 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 2:21:27 PM riparian zones should be used to describe these areas. When using the term buffer in North Carolina this means you are referring to a subject stream with a zone 1 and zone 2 as defined in the buffer protection rules. Number: 8 Author: bhartshorn Subject: Cross -Out Date: 3/10/2023 2:19:55 PM ;Number: 9 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 2:47:05 PM If WLS is planning to be the landowner, then the MBI requires that the long term steward be chosen at the outset of the approved BPDP, which means, that the long term steward is noted on the conservation easement as the Grantee. Please acknowledge your understanding on this requirement somewhere in this section (4.6). 'Number: 10 Author: bhartshorn Subject: Highlight Date: 3/9/2023 1:22:55 PM "a nutrient offset site" Number: 11 Author: bhartshorn Subject: Cross -Out Date: 3/9/2023 1:28:16 PM Page: 12 Number: 1 Author: bhartshorn Subject: Inserted Text Date: 3/10/2023 2:49:26 PM 25,387.786 lbs. of nitrogen nutrient offset credits. ;Number: 2 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 2:50:24 PM As noted previously, please show where this credits are depicted off Stream A in Fig 6. Number: 3 Author: bhartshorn Subject: Highlight Date: 3/9/2023 1:36:52 PM state where? i.e. at the entry point of Ditch 1, 4, and 5 Page: 13 ;Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 1:23:29 PM Stream A is not a ditch, please correct !;Number: 2 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 3:04:21 PM Please explain how you got 14,981 if you are deducting .05 acres on each side of the three ditches. If you determine this number is incorrect, please update the entire report accordingly Page: 20 jNumber: 1 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 3:16:57 PM Please depict what the blue arrows mean on the ditch Page: 21 — Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 1:38:02 PM Depict the 414 sq ft of credit from Stream A as shown in Table 5 (differentiate between the ditch credit colors). This comment was also on the draft BPDP ,Number: 2 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 1:32:31 PM Call these areas out as non -diffuse flow in the legend. Number: 3 Author: bhartshorn Subject: Sticky Note Date: 3/10/2023 1:31:56 PM Depict the non-credit areas (ditch foot print, non -diffuse flow) that are still being planted but not credited in the legend.