HomeMy WebLinkAboutNegative Balance Notification & Resolution_EvansBallahackFrom:Merritt, Katie
To:Salina Campbell; Becker email; Trisha Crawford
Cc:Bobby Ham; Hartshorn, Blake; Goss, Stephanie
Bcc:Huisman, John
Subject:FW: [External] Fw: Negative Credit Sales for Ballahack- NON COMPLIANCE-ALL CREDITS ON HOLD 03020103
Date:Wednesday, June 7, 2023 2:07:00 PM
Attachments:REFUNDCreditTransferCertificate_AutoRific_D1800147.pdf
GES_EvansBallahack_NOCreditLedger_10MAR2023.pdf
Hey Jeff & Salina (or Trisha),
To satisfy the non-compliance of overselling Phosphorus nutrient offset credits from the
Ballahack mitigation bank, please follow the directions below based on the March 2023
Ballahack credit ledger which is attached to this correspondence. The credit ledgers submitted
by GES for the Baldwin Swamp Bank and the Ballahack Bank in May and June are not in
compliance with the directions below, and therefore DWR has deleted those ledgers off the
website until compliance has been met. GES needs to address the issues below and update all
credit ledgers accordingly.
BALLAHACK PHOSPHORUS LEDGER
1. GES must issue a FULL REFUND to the permittee for the Farrington Trace Senior project
in the amount of 58.60 lbs of phosphorus credits.
Add a line item to the Ballahack Phosphorus ledger dated 6/7/2023. Add the
purchaser Name. For Project Name, enter: Farrington Trace Senior – FULL
REFUND for non-compliant credit sale dated 12/13/2022. Under the “CREDITS
RELEASED/AVAILABLE” column, enter 58.60 lbs and update the credit balances
accordingly.
Create a new Mitigation Credit Transfer Certificate, dated 6/7/2023 to the
permittee, documenting the FULL REFUND of 58.60 lbs of Phosphorus credits. I
have attached an example of a REFUND MCTC for you to use when drafting yours.
This is not the exact template you should use, but gives you a good example to
start with. Indicate, that the 58.60lbs of Phosphorus will be debited from the GES
Baldwin Swamp Mitigation bank instead and that a new MCTC will be issued
documenting that sale. Make sure to state that the Nitrogen offset credits
purchased are not being refunded, just the P credits.
Once you have finalized the new MCTC, send it to the permittee, the local
government contact (City of Greenville) and to me along with the corrected Credit
Ledger.
2. GES must issue a FULL REFUND to the permittee for the Pitt County Sherriff’s Office’s
project in the amount of 120.00 lbs of phosphorus credits.
Add a line item to the Ballahack Phosphorus ledger dated 6/7/2023. Add the
purchaser Name. For Project Name, enter: Pitt County Sherriff’s Office – FULL
REFUND for non-compliant credit sale dated 1/10/2023. Under the “CREDITS
RELEASED/AVAILABLE” column, enter 120.00 lbs and update the credit balances
accordingly.
Create a new Mitigation Credit Transfer Certificate, dated 6/7/2023 to the
permittee, documenting the FULL REFUND of 58.60 lbs of Phosphorus credits. I
have attached an example of a REFUND MCTC for you to use when drafting yours.
This is not the exact template you should use, but gives you a good example to
start with. Indicate, that the 58.60lbs of Phosphorus will be debited from the GES
Baldwin Swamp Mitigation bank instead and that a new MCTC will be issued
documenting that sale. Make sure to state that the Nitrogen offset credits
purchased are not being refunded, just the P credits.
Once you have finalized the new MCTC, send it to the permittee, the local
government contact (City of Greenville) and to me along with the corrected Credit
Ledger
3. Ending credit balance on the Ballahack Phosphorus ledger should be 2.37 lbs for date
6/7/2023
BALDWIN SWAMP LEDGER
1. GES is authorized by DWR to sell 58.60 lbs of phosphorus credits to the permittee for the
Farrington Trace Senior project.
Add a line item to the Baldwin Swamp Phosphorus ledger dated 6/7/2023. Add
the purchaser Name. For Project Name, enter: Farrington Trace Senior – debited
per DWR findings in audit 6/7/2023 for noncompliant credit sale on Ballahack
ledger”. Under the “CREDITS DEBITED” column, enter 58.60 lbs and update the
credit balances accordingly.
Create a new Mitigation Credit Transfer Certificate, dated 6/7/2023 to the
permittee, documenting the credit sale of 58.60 lbs of Phosphorus credits.
Once you have finalized the new MCTC showing the sale from the Baldwin Swamp
phosphorus credit ledger, send it to the permittee, the local government contact
(City of Greenville) and to me along with the corrected Credit Ledger.
2. GES is authorized by DWR to sell 120 lbs of phosphorus credits to the permittee for the
Pitt County Sherriff’s Office’s project.
Add a line item to the Baldwin Swamp Phosphorus ledger dated 6/7/2023. Add
the purchaser Name. For Project Name, enter: Pitt County Sherriff’s Office–
debited per DWR findings in audit 6/7/2023 for noncompliant credit sale on
Ballahack ledger”. Under the “CREDITS DEBITED” column, enter 120 lbs and
update the credit balances accordingly.
Create a new Mitigation Credit Transfer Certificate, dated 6/7/2023 to the
permittee, documenting the credit sale of 120 lbs of Phosphorus credits.
Once you have finalized the new MCTC showing the sale from the Baldwin Swamp
phosphorus credit ledger, send it to the permittee, the local government contact
(City of Greenville) and to me along with the corrected Credit Ledger.
Thank you for your cooperation. As a reminder, DWR needs corrected ledgers for Ballahack &
Baldwin Swamp along with new MCTC documents for the 4 new transactions (2 REFUND MCTCs
+ 2 DEBIT MCTCs)
Katie
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://deq.nc.gov/about/divisions/water-resources/water-quality-permitting/401-buffer-
permitting-branch
NEW EMAIL!! katie.merritt@deq.nc.gov
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
From: Jeff Becker <jrbecker@bellsouth.net>
Sent: May 24, 2023 1:35 PM
To: Merritt, Katie <katie.merritt@deq.nc.gov>
Cc: Salina Campbell <salina@hamfarms.com>; Trisha Crawford <trisha@hamfarms.com>
Subject: Re: Negative Credit Sales for Ballahack- NON COMPLIANCE-ALL CREDITS ON HOLD
03020103
I will look into this problem immediately and we will correct the problem.. As our ledgers indicate we
have more than enough phosphors credit in TP 03 toc cover nay accounting error. We will explain and
correct.. Sorry for the mix up.. hope you are doing well
On Wednesday, May 24, 2023, 12:48:42 PM EDT, Merritt, Katie <katie.merritt@deq.nc.gov> wrote:
Hey Jeff,
Attached, are the March credit ledgers received for the Ballahack Bank. Please
explain why Greene Environmental Services, LLC (GES) has a negative balance of
Phosphorus Credits (-176.23 lbs). It appears that GES has sold more phosphorus
credits than what has been released to sell. This needs to be addressed
immediately with an explanation and a proposed resolution provided to me in
writing within 5 business days.
As of today, May 24, 2023, and until this matter is resolved, GES is required to
cease the selling of Phosphorus nutrient offset credits from the following GES
Banks located in the 03020103 HUC of Tar-Pamlico: Baldwin Swamp, Barlow
Canal, Evans Ballahack, Pactolus
Your prompt attention to this matter is appreciated.
Thank you,
Katie
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://deq.nc.gov/about/divisions/water-resources/water-quality-permitting/401-buffer-
permitting-branch
NEW EMAIL!!katie.merritt@deq.nc.gov
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.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties by an authorized state official.
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