Britt and Hales BPDPdraft2

From: Hartshorn, Blake
To: Baker. Caroline D
Subject: FW: Britt and Hales BPDP
Date: Tuesday, March 21, 2023 2:46:20 PM
Attachments: imaoe001.ono
DWR Comment SummaryV2.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,
Blake Hartshorn
From: Hartshorn, Blake
Sent: Tuesday, March 21, 2023 2:45 PM
To: Jordan Burbage <[e-mail]>
Cc: Merritt, Katie <[e-mail]>
Subject: Britt and Hales BPDP
Hello 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 March 9, 2023, Eco Terra, submitted a second draft of the Bank Parcel Development
Package (Plan) for the Britt & Hales Site, to the Division, for review and approval. DWR provided
comments on the first draft of this Plan on February 21, 2023. 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 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 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-
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.

Blake Hartshorn (he/him)
Mitigation Specialist, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone]
blake.hartshornna ncdenr.gov
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Summary of Comments on 20220293 Ver 2_2023-03-08
Britt & Hales BPDP SUBMITTAL 20230309
Page: 5
— Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/20/2023 1:27:45 PM
As stated in previous DWR Revision:
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".

Page: 7
Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/20/2023 1:29:27 PM
Different HUC code given in in Section 2.4.
For future reference you only need 8 digit HUC here.

— Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/21/2023 1:22:28 PM
This HUC seems to be the correct HUC. Please correct the Project Attributes Table.

Page: 12
— Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/20/2023 1:53:22 PM
We need to know the actual square foot area deducted or reference the credit table once deducted credits are appropriately addressed.

Page: 17
— Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/20/2023 1:55:34 PM
We need to know the actual square foot area deducted or reference the credit table once deducted credits are appropriately addressed.

Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/17/2023 1:45:56 PM
add a line item for showing diffused flow deductions since those areas are still being planted and still represent "Total Area" of the site.
Credit Type = Buffer
Feature Name = Diffused Flow deductions
Total Area = how much area is deducted
Total Creditable Area for Buffer Mitigation=0
then check No in both boxes for the credits.
If the diffuse flow deductions were calculated in another way, please correct the error and address as requested above.
This is to ensure a transparent representation of where the deductions are occurring and to ensure DWR knows they have been applied
correctly.

— Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/20/2023 1:50:30 PM
We need to discuss credit assets maps representative during our meeting.
— Number: 2 Author: bhartshorn Subject: Sticky Note Date: 3/21/2023 1:08:39 PM
Please label the tree preservation area as non-credit area.
— Number: 3 Author: bhartshorn Subject: Sticky Note Date: 3/20/2023 1:49:29 PM
This area seems to be bumped out due to tree preservation area. We still need to measure from TOB from the ditch, not the treeline.
Please correct and adjust the credit table as well.
— Number: 4 Author: bhartshorn Subject: Sticky Note Date: 3/17/2023 1:54:18 PM
Please put sf in the call out box that applies to the deduction that will also be entered into the credit table.
— Number: 5 Author: bhartshorn Subject: Sticky Note Date: 3/20/2023 1:39:32 PM
Please show the widths within the legend. i.e. 0-100ft and 101-200ft such as it is labeled in the credit table.