EMH Farms BPDP 2nd Revisions

From:
Hartshorn, Blake
To:
Baker. Caroline D
Cc:
Merritt. Katie
Subject:
FW: EMH Farms BPDP 2nd Revisions
Date:
Friday, March 31, 2023 9:15:05 AM
Attachments:
imaae001.ona
Summary of Comments on EMH Farms 20230330.odf
Good morning 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: Thursday, March 30, 2023 5:04 PM
To: [e-mail]
Cc: Merritt, Katie <[e-mail]>
Subject: EMH Farms BPDP 2nd Revisions
Good afternoon Kevin,
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 28, 2023, Clearwater Mitigation Solutions, submitted a second draft of the Bank
Parcel Development Package (Plan) for the EMH Farm Site, to the Division, for review and approval.
DWR provided comments on the first draft of this Plan on March 15th, 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 Clearwater Mitigation 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 Clearwater Mitigation is ready to submit their final project Plan, please include a summary of
all Clearwater Mitigation responses to the DWR comments acknowledging how Clearwater
Mitigation 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-
1493 (version 1) 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.hartshorn aPncdenr.gov
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Trees will be planted at a density of approximately 680 stems per acre on 8-foot centers,
sufficient to meet the performance standards outlined in Rule 15A NCAC 02B .0295 of 260
planted trees per acre at the end of five years of monitoring. In addition, bare -root tree stock
will be sufficient mixed during planting to ensure diversity and that no one tree species will be
greater than 50% of the established stems. Planting is scheduled for April 2023.
Several additional restoration activities are proposed on the Bank Parcel. Three total culverts
will be removed: a non-functioning culvert on UT 1, and two functioning culverts on UT 2 and UT
3. The culverts will be removed mechanically with machinery, and impacted stream banks will
be sloped at 3:1 grade, matted, seeded, and live -staked to ensure future stability. An existing
ditch feature along the eastern boundary of the Bank Parcel (Feature E 3) will be plugged and
filled for diffuse flow into UT 3. Graded/disturbed areas will be strawed and seeded to minimize
sediment inputs. Minor bank stabilization is proposed, as needed, along UT3. This will include
mechanically sloping at 3:1 grade, matting, seeding, and live -staking. Appropriate seed mixes of
pollinator -attracting annual and perennial species will 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, especially where earthwork is performed. Proposed
seed mixes are listed in Tables 6A-B. SErcies availability may result in the substitution of
regionally appropriate native species he pasture area surrounding the Bank Parcel will be
abandoned by the landowner after the restoration activities are complete, and existing fencing
will be maintained to permanently exclude cattle from the conservation easement area.
Additionally, a small section of fencing within the easement boundary will be removed. See
Figure 6 (Appendix A) for details regarding additional restoration activities and fencing.
Table 6A. Proposed Permanent Seed Mix
Species
Percent of Total Mix
Purpletop (Tridens flovus)
15%
Little Bluestem (Schizachyrium scoparium)
15%
VA Wild Rye (Elymus virginicus)
10%
Bur Marigold (Bidens cernua)
10%
Lance -leaved Tickseed (Coreopsis lanceolate)
10%
Blackeye Susan (Rudbeckia hirta)
10%
Butterfly milkweed (Asclepias tuberosa)
5%
Purple conef lower (Echinacea purpurea)
5%
PA Smartweed (Polygonum pensylvanicum)
5%
Oxeye sunflower (Heliopsis helianthoides)
5%
Big Bluestem (Andropogon gerardii)
5%
Sensitive Pea (Chomaecristo nictitans)
5%
TOTAL
100%
Table 61B. Proposed Temporary Seed Mix
Species
Application Rate
Grain Rye (Secale cereale)
100 lbs. per acre
Brown Top Millet (Urochloo ramosa)
40 lbs. per acre
German Millet (Setaria italica)
25 lbs. per acre
Bank Parcel Development Package
EMH Farm Buffer Mitigation Bank Parcel
Guilford County, North Carolina
page 11
Clearwater Mitigation Solutions
March 2023

Summary of Comments on 20221493 Ver 1_2023-03-28
EMH Farm_BPDP Comment Response w.BPDP_MBI (DWR
No. 2022-1493v1)_20230328
Page: 19
— Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/30/2023 4:52:14 PM
Either remove the sentence on substitutions or include a table 5b with what the substitutions species are with their corresponding
percentages.
Sponsor has to select what those "regionally appropriate native species" would be in order for DWR to approve the planting plan in this
BPDP. Some "regionally appropriate species" may not be acceptable

3.2 Riparian Buffer Enhancement
Riparian buffer enhancement will include supplementally planting and permanently protecting
existing riparian buffer and adjacent riparian areas from livestock via exclusionary fencing,
cutting, clearing, filling, grading, and any similar activities that would affect the functionality of
the riparian buffer (Figures 6, 7, and 8, Appendix A). These areas are primarily described as
disturbed mixed hardwoods. Riparian buffer credits sought in the enhancement area are allowed
pursuant to 15A NCAC 02B .0295 (n). The enhancement area will extend a maximum of 200 feet
from the top of bank with a minimum width of 20 from top of banks.
3.3 Riparian Buffer Preservation Activities
Riparian buffer preservation will include permanently protecting existing riparian buffer from
cutting, clearing, filling, grading, and any similar activities that would affect the functionality of
the riparian buffer. Areas specified for Preservation, as defined in 15A NCAC 02B .0295, are
shown in Figure 8 (Appendix A). These areas are primarily described as mixed hardwoods, with
the number of high value species above 200 n [i acre. They are areas where livestock are
currently fenced out, and there has been littleo historic livestock access.
3.4 Credit Release Schedule
Credit shall be released in accordance with the schedule described in the MBI.
4.0 MONITORING AND MAINTENANCE PLAN
4.1 Monitoring Protocol
Permanent vegetation monitoring plots will be installed and evaluated within the riparian buffer
restoration and enhancement areas to measure the survival of the planted trees. The plots will
be 100 square meters each and will be randomly placed throughout the planted riparian areas.
A total of nineteen (19) plots (2.08% of the restoration/enhancement credit generating area) will
0 be established within the riparian restoration and enhancement areas, and their locations will be
in accordance with the locations depicted on Figure 9 (Appendix A).
Vegetation assessments will be conducted and follow the Carolina Vegetation Survey (CVS) Level
2 Protocol for Recording Vegetation (Lee et. all, 2008). A reference photo will be taken from the
origin point of each plot and provided in the annual reports. All planted stems will be marked
with flagging tape and recorded.
Planting is scheduled for April 2023. Within 30 calendar days after completing the establishment
of the buffer mitigation areas, the Sponsor will submit written notification to DWR documenting
that all riparian buffer restoration and enhancement activities have been completed. Failure to
submit written notification within 30 days may result in a modified credit release schedule or a
delay in the issuance of credit releases. Notification shall include all the items as specified in the
MBI. The first annual monitoring activities will commence at the end of the first growing season,
at least five months after planting has been completed and no earlier than the fall season.
Bank Parcel Development Package page 12
EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions
Guilford County, North Carolina March 2023

Page: 20
_Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/30/2023 4:32:21 PM
"200 stems per acre"
_Number: 2 Author: bhartshorn Subject: Sticky Note Date: 3/29/2023 2:00:47 PM
Do they need to specify that trees will be mixed or does their response (#30) satisfy that?

Tao EMH Farm 2022-1493v1, Project Credits
Project Area
N Credit Conversion Ratio (ft'/pound)
P Credit Conversion Ratio (ft'/pound)
o�
Total Ephemeral Area (it') for Credit:
107,060
107,060
Total Eligible Ephemeral Area (ft):
277,099
9.7%
Ephemerel Reaches as%TABM
Enter Preservation Credits Below Total Eligible for Preservation (ft):
327,393
9.6%
Preservation as%TABM
Type
Location
Subject?
Feature Type
Miitigat-Activity
Be
Min -Max Buffer
Feature Name
Total Area(sf)
�T.tal(Cr.diwbl.)
Area for Buffer
Initial Credit
%FuIlCredit
Final Credit
Riparian
(ftCredit
Width
Mitigation (ft')
Ratio(x:l)
Ratio (x:l)
BufferCredits
Preservation Area Subtotals
TOTAL AREA OF BUFFER MITIGATION
(TABM)
Mitigation Totals Sure Feet
Credits
Restorati.n:
931,861
654,158.197
Enhancement:
50,318
14,998.242
Preservation:
126,216
9,141.125
Total Riparian Buffer:
1,108,396
678,297.564
TOTAL NUTRIENT OFFSET MITIGATION
Mitigation Totals
Square Feet
Credits
NI "an
0.000
Nutrient Offset:
Phosphorus:
0
0.000
1. The Randleman Lake buffer rules allow some ditches to be classified as subject according to 15A NCAC 02B .0250 (5)(a).
last updated 08/03/2020

Page: 23
Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/30/2023 4:33:56 PM
Fix table title

Page: 33
— Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/30/2023 4:45:42 PM
Use the original figure 8 but only take out rural and non -subject information and keep the ephemeral coloring the way it is in this map.

Page: 34
— Number: 1 Author: bhartshorn Subject: Sticky Note Date: 3/30/2023 4:46:17 PM
See comments on figure 8 and apply to figure 9