20230163 Ver 2_SUBMITTAL - Draft BPDP - Brooks Swamp - 081123_20230811

BROOKS SWAMP
Bank Parcel Development Package
HUC: 03020201
Neuse River Basin
Excluding Falls Lake Watershed
�RESTORECOLOGY
RESTORECOLOGY NEUSE, LLC
Version 1
August 11, 2023

Table of Contents
2.6 Existing Vegetative Communities ...........................
2.7 Threatened and Endangered Species ......................
2.8 Cultural Resources.....................................................
2.9 FEMA Floodplain Compliance ...............................
2.10 Parcel Location, Parcel Constraints, and Access
2.11 Other Environmental Conditions .........................
3.0 Site Protection Instrument ............................................
4.0 Mitigation Work Plan ..................................
4.1 Parcel Preparation ...................................
4.2 Riparian Area Restoration Activities....
4.3 Riparian Area Enhancement Activities
4.4 Riparian Area Preservation Activities..
4.5 DWR As -Built Evaluation .....................
5.0 Monitoring and Maintenance Plan
5.1 Monitoring Protocol
5.2 Parcel Maintenance..
.7
.8
.8
.8
.8
.8
.8
.9
.9
.9
10
10
10
10
10
11
5.3 Easement Boundaries............................................................................................................................................11
6.0 Financial Assurance and Long -Term Management..............................................................................................11
6.1 Financial Assurances.............................................................................................................................................11
6.2 Long -Term Management......................................................................................................................................12
7.0 Project Credit Potential.............................................................................................................................................12
7.1 Riparian Buffer Credits.........................................................................................................................................12
7.2 Nutrient Offset Credits.........................................................................................................................................12
8.0 References....................................................................................................................................................................14
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 1 August 2023

Tables
Table 1.0
- Water Quality and Ecology Goals for the Parcel
Table 2.0
- Parcel Summary
Table 3.0
- Site Viability Summary
Table 4.0
- Drainage Areas and Land Uses
Table 5.0
- Soil Types
Table 6.0
- Existing Vegetation
Table 7.0
- Site Protection Instrument
Table 8.1 - Planting List for Upland, Seasonally -Saturated Wetland
Table 8.2 - Planting List for Swamp Wetland
Table 9.0 — Brooks Swamp Project Credits
Figures
Figure 1
- Vicinity Map
Figure 2
- Site Map
Figure 3
- Service Area Map
Figure 4
- USGS Topographic Map
Figure 5
- Watershed Map
Figure 6
- Soils Map
Figure 7
- Credit Areas Map
Figure 8
- Buffer Zones Map
Figure 9
- Monitoring Plan
Appendices
Appendix A
- Current Land Use Photographs
Appendix B -
Historical Aerials
Appendix C -
Stream Determination
Appendix D
- Buffer Viability
Appendix E -
Regulatory Correspondence
Appendix F
— Other Environmental Conditions
Appendix G
— Brooks Swamp, #20230163, Project Credit Table Template
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 2 August 2023

1.0 Project Introduction
The Brooks Swamp Buffer and Nutrient Offset Mitigation Bank Parcel (the Parcel) is proposed in the Neuse
River Basin HUC#03020201, excluding the Falls Lake Watershed (Meuse 01). The Parcel (NC Division of
Water Resources [DWR] # 20230163) is being developed under the Mitigation Banking Instrument (N4BI)
made and entered into by RestorEcology Neuse, LLC (RestorEcology) and the NC Department of
Environmental Quality — Division of Water Resources (DWR). This Bank Parcel Development Package
(BPDP) has been prepared in accordance with the MBI and applicable State of NC Regulations (15A NCAC
02B .0295 and �.0703).
The Parcel has received a Stream Determination Letter dated March 1, 2023, and a Site Viability Letter dated
June 27, 2023.
1.1 Project Description
The Parcel is located west of Old Mt. Olive Highway in unincorporated Wayne County, North Carolina near
the Dudley township (Lat/Lon Coordinates: 35.2487418°N, 78.0413133°W). Directions to the Parcel are
included in Figure 1. The property containing the Parcel has historically been cropland and that is the
ongoing use. The Parcel is in the Neuse 01, within the Brooks Swamp 12-dig1t HUC 030202011401, and
Brooks Swamp is the named receiving stream immediately south of the Parcel.
To develop the Parcel as a Neuse 01 riparian buffer and nutrient offset mitigation bank, approximately 9.2
acres of cropland will be planted with native hardwood trees and shrubs to lessen nutrient inputs into the
streams from agricultural activities and provide restored stream buffers. Existing wooded stream buffers
within the Parcel will be preserved and enhanced, resulting in a total Parcel size of approximately 11.1 acres
(Figure 2). Riparian buffer credits and nitrogen (lb) will be generated by the Parcel and sold to permittees in
the Neuse 01. The Parcel Service Area Map is provided as Figure 3.
2.0 Mitigation Project Summary
2.1 Project Goals
The overarching goals of the Parcel are to improve water quality and ecology in streams by restoring and
expanding a hardwood riparian corridor. These improvements will positively affect Brooks Swamp, which
flows to Thoroughfare Swamp and eventually into the Neuse River. Specific goals are described in Table 1.0
as follows:
Table 1.0 - Water Quality and Ecology Goals for the Parcel
Water Quality and Ecology Goals
Objectives
Decrease nutrient levels
Converting cropland along the streams to a restored
hardwood riparian corridor will diminish nutrient
inputs directly into the streams and provide a
forested area where nutrient inputs can be further
reduced by biogeochemical processes in the soil
before entering the streams.
Decrease sediment input
Providing a restored hardwood riparian corridor
along the streams will filter and decrease sediment
flows from adjacent fields. Restoring and
preserving wooded floodplains along the streams
will allow for deposition of off -site sediment
sources in the flood lain.
Decrease water temperature and increase dissolved
Increased shading of streams as the restored
oxygen concentrations
hardwood forest matures will decrease water
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 3 August 2023

Water Quality and Ecology Goals
Objectives
temperatures and allow for increased dissolved
oxygen concentrations.
Restore appropriate terrestrial habitat
Invasive seed sources in the Parcel will be treated to
promote establishment of a restored native
hardwood forest community.
Permanently protect Parcel
The Parcel will be protected by a perpetual
conservation easement.
2.2 Existing Parcel Conditions
The Parcel has historically been used as cropland. Viable Parcel features and existing buffer conditions are
described as follows (see Figure 2 for feature references, and photos in Appendix A):
Unnamed Tributar)(U) 1 - UT1 is a modified natural stream that flows north to south on the western side
of the Parcel before confluencing with Brooks Swamp. The UT1 centerline is the property and Parcel
boundary to the west. It is an intermittent stream, with cropland up to the banks on both sides for most of
its length. There is a small woodland area on the north end and a narrow strip of wooded buffer (5 to 30
feet) on the south end. The cropland areas along the left bank of UT1 will be restored via plantings described
in Section 4.0.
U12: UT2 is a perennial natural stream that flows northeast to southwest on the eastern side of the Parcel
before confluencing with Brooks Swamp. The UT2 centerline is the property and Parcel boundary to the
east. The stream's right bank has a narrow existing buffer ranging from 30 to 60 feet wide, with a cropland
area that extends out beyond 200 feet. The majority of the UT2 floodplain is low and swampy, with scattered
shrubs and trees amid herbaceous wetland vegetation. The cropland areas along the right bank of UT2 will
be restored via plantings described in Section 4.0.
As depicted in the historical aerial photographs provided in Appendix B, land use has remained relatively
unchanged since at least 1993. Cropland has been the primary agricultural use. As of the date of this BPDP,
the current land use of cropland has not changed since the Site Viability Letter issued June 27, 2023.
Table 2.0 below summarizes the Parcel information, credit yield, and project schedule anticipated.
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 4 August 2023

Table 2.0 - Parcel Summary
Project Name
Brooks Swam
12-Digit Hydrologic Unit Code
030202011401
Watershed
Neuse River Basin, Excluding Falls Lake
Location at/Lon
35.2487418°N, 78.0413133°W
Site Protection Instrument
Conservation Easement to RestorEcology Neuse,
LLC to be assigned to Long -Term Steward prior to
MY4
Total Riparian Buffer Credits ft2
213,706.136
Total Nutrient Offset Credits (Nitrogen lb
9,802.890
BPDP Submittal Date
August 11, 2023
Anticipated Planting Date
February 20241
As -Built Report Date
May 2024
MY1 Report Date
November 2024
MY2 Report Date
November 2025
MY3 Report Date
November 2026
MY4 Report Date
November 2027
MY5 Report Date
November 2028
Anticipated Closeout Date
June 2029
'Planting is anticipated to occur during the December 2023 — May 2024 planting season.
2.3 Site Viability for Buffer Mitigation and Nutrient Offset Mitigation
On January 19, 2023, DWR conducted an on -site review of Parcel stream features and issued a
Determination for Applicability to the Neuse Buffer Rules 15A NCAC 02B .0714 (Stream Determination
Letter, Appendix C) for the Parcel dated March 1, 2023. The Parcel was known at the time as the Price Farm
and has since been formally named Brooks Swamp Parcel.
On March 22, 2023, DWR conducted a site visit and issued a Site Viability Letter for the Parcel June 27, 2023
(Appendix D). The evaluation was made from Top of Bank (TOB) and landward 200 feet from each feature
for buffer mitigation pursuant to 15A NCAC 02B .0295 and for nutrient offset credits pursuant to �.0703
using �.0295 to define the mitigation type determinations.
DWR's evaluation of the features onsite and their associated mitigation determination for the riparian areas
are detailed in the Site Viability Letter in Appendix D. The following table summarizes the Parcel features
and the results of DWR's evaluation:
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 5 August 2023

Table 3.0 - Site Viability Summary
Parcel Feature
Classification
Buffer Restoration Viability
Nutrient Offset
Restoration Viability
UT1
Stream
• Viable for Restoration (non -forested
• Viable (non -forested
fields and densely -populated privet
fields)
stands')
• Viable for Preservation (forested
areas2
UT2
Stream
• Viable for Restoration (non -forested
• Viable (non -forested
fields and densely -populated privet
fields)
stands')
• Viable for Enhancement (partially
forested area with privet')
• Viable for Preservation (forested
areas2
115A NCAC 02B .0295(n)
215A NCAC 02B .0295(o) (5)
3DWR, Methodology and Calculations for Nutrient Reduction associated pith R,fanan Buffer Estab§shment
2.4 Watershed Characterization
The Parcel is located within the Neuse 01, on two unnamed tributaries to Brooks Swamp. The UT1 and
UT2 watersheds have a majority use of agriculture, with a mixture of residential, wooded, and educational
uses as well (Figure 4, Figure 5). The watersheds in Figure 5 were delineated using 2-foot-interval topographic
contours made available by NC One Map.
Table 4.0 - Drainage Areas and Land Uses
Feature
Drainage Area (Ac)
Land Uses'
UT1
66.3
56% Agricultural
39% Developed
5% Forested
UT2
317.9
62% Agricultural
13% Developed
25% Forested
'Land uses assessed via aerial photography.
2.5 Soils
The Parcel and its stream features are shown in Figure 6 on the Wayne County Soil Survey, dated 1974. The
following table describes Parcel soil types and descriptions:
Table 5.0 — Soil Types
Map Unit Name
Description
NoB — Norfolk loamy
This well drained soil occurs on smooth sides of divides. Infiltration is
sand, 2 — 6% slopes
moderate, and surface runoff is medium. The seasonal high water table is at
a depth greater than 60 inches. Needleleaf trees are recommended in the soil
surve for planting.
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 6 August 2023

Map Unit Name
Description
WaB — Wagram loamy
This well drained soil is on slightly convex, smooth and broad divides.
sand, 0 — 6% slopes
Infiltration is rapid, and surface runoff is slow. The seasonal high water
table is at a depth greater than 60 inches. The surface layer is prone to low
fertility.1 Needleleaf trees are recommended in the soil survey for planting.
RyB2 — Ruston sandy
This well drained soil occurs on smooth sides of divides. Infiltration is
loam, 2 — 6% slopes,
moderately slow and surface runoff is medium. The seasonal high water
eroded
table is at a depth greater than 60 inches. Needleleaf trees are recommended
in the soil survey for planting.
Bb — Bibb sandy loam
This poorly drained soil occurs on nearly -level floodplains. Infiltration is
moderate and surface runoff is slow, with ponding water in places and
frequent flooding. The seasonal high water table is at the surface. Wet -
tolerant broadleaf deciduous trees are recommended for planting.
The ongoing cultivation at the Parcel should mitigate this tendency.
2.6 Existing Vegetative Communities
Existing vegetation in the Parcel consists of cropland, mature hardwood forest, and swamp. Typical
vegetation observed in the existing forest is summarized in Table 6.0.
Table 6.0 - Existing Vegetation
Scientific Name Common Name
Overstory
uevcus vubva
Southern red oak'
Tir odendvon tuh i eva
Tulip poplar'
Acev vubvum
Red maple'
Movus vubva
Mulberry
N ssa a uatica
Swamp b ackgurn
uevcus ni va
Water oak
Pvaxinus enns lvanica
Green ash
Pinus taeda
Loblolly pine
Salk ni va
Black willow
Understor
Ta' uidambav st vaci lua
Sweet t
Alnus serrulata
Tag alder'
Ma no§a viv iniana
Sweetba
1_1 ustvum sinense
Chinese privet
Avundinaria gi antea
Giant cane
Sassafras albidum
Sassafras
Vitzs labvusca
Fox grape
Herbaceous
TViks mtundi o§a
Muscadine grapevine'
Smilax votundi o§a
Greenbrier'
Sauvuvus cevnuus
Lizard tail'
Toxicodendvon vadicans
Poison ivy
Wl'ood)aravdia aevolata
Netted chain fern
Atli num elix- emina
Common lad fern
Micoste ium vimineum
Microste um
'Dominant in forest layer.
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 7 August 2023

2.7 Threatened and Endangered Species
RestorEcology initiated regulatory coordination with the U.S. Fish & Wildlife Service (USFWS) via letter and
self -certification on July 17, 2023 (see Appendix E). The Official Species List from (USFWS) contained five
species: tricolored bat (Penmyotis subflavus) — Proposed Endangered, red -cockaded woodpecker (Picoides bovea§s)
— Endangered, Neuse River waterdog (Nectuvus le2ilisz) — Threatened, Carolina madtom (Notuvus furiosus) —
Endangered, and monarch butterfly (Danausplexippus) — Candidate. As part of coordination with the USFWS,
RestorEcology also purchased a Natural Heritage Resource Report from the NC Department of Natural and
Cultural Resource — Natural Heritage Program (NCNHP) dated July 13, 2023. The NCNHP Report
identified no element occurrences intersecting with the Parcel. An occurrence of the state -threatened
Ironcolor shiner (Notvopis chaI baeus) was noted within one mile of the Parcel. As summarized in the Species
Conclusion Table and confirmed in USFWS' response dated July 27, 2023, the Parcel is not likely to adversely
affect any listed species (see Appendix E).
2.8 Cultural Resources
RestorEcology initiated regulatory coordination via letter to the NC Department of Natural and Cultural
Resources — State Historic Preservation Office (SHPO) dated July 17, 2023. SHPO responded via letter on
August 2, 2023 that SHPO is aware of no historic resources that would be affected by the Parcel (Appendix
E) .
2.9 FEA/1A Floodplain Compliance
As mapped by the Wayne County GIS, a portion of the Parcel at the bottom/southern end of UT1 and UT2
is within the 500-year and 100-year floodplain for Brooks Swamp. If required, a floodplain development
permit for the Parcel will be obtained from the Wayne County Planning Department before planting and will
be submitted to DWR along with the As -Built Report.
2.10 Parcel Location, Parcel Constraints, and Access
The Parcel is located west of Old Mt. Olive Highway and is accessed via an existing 30-foot-wide
ingress/egress easement (See Figure 2). The Parcel is located outside of the NCDOT 60-foot right-of-way
for Old Mt. Olive Highway. There are no utilities, easements, or constraints located within the Parcel. UT1
is a ditched natural stream and ongoing ditch maintenance from the right bank west of the Parcel is
anticipated.
2.11 Other Environmental Conditions
A Lightbox — Environmental Data Resources (EDR) report was prepared on August 7, 2023. An excerpt
from the EDR Report is provided in Appendix F. The full report can be made available upon request by the
DWR. The Parcel was not listed in any of the databases searched by EDR. The Georgia Pacific Corp Comp
Hazardous Substance Disposal and State Hazardous Waste Site (Facility Id: NCD000813659) was mapped
0.71 — 0.74 miles northwest and at a higher elevation than the Parcel. An excerpt from the Draft NPDES
Permit# NCO090051 for the Georgia Pacific Dudley Plywood Facility (the Facility) at that location is attached
in Appendix F and shows permitted Outfall 001 entering an unnamed tributary to Brooks Swamp north and
downstream of the Parcel. As such, environmental conditions on the Parcel associated with the Facility are
not anticipated.
3.0 Site Protection Instrument
The Parcel will be protected via a perpetual conservation easement based on DWR's latest template available
online. RestorEcology will be the Grantee on the easement and will assign it to a qualified land trust or long
term steward approved by DWR before monitoring year 4. The parcel and landowner information is
summarized in Table 7.0 below:
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 8 August 2023

Table 7.0 — Site Protection Instrument
Landowner
Wayne County PIN
Instrument
Register of
Acreage to be
Deeds Reference
Protected
Daniel Ramsay and
2584566186
Conservation
To be Recorded
11.1 Acres
Erica Ramsay
Easement
4.0 Mitigation Work Plan
Native tree and shrub plantings will be used to establish hardwood forested corridors up to 200 feet from
top -of -bank on UT1 and UT2. Figure 7 depicts the credit -generating areas and project design, and Figure 8
depicts the riparian buffer zones for the Parcel.
4.1 Parcel Preparation
The Parcel has historically been used for cropland and is planted in feed corn as of the date of this BPDP.
Most of the buffer restoration areas will require minimal soil preparation because they've been maintained in
active agriculture. If sinkholes or unstable erosional areas are observed along the streams they will stabilized
using methods such as minor grading, erosion control matting, live staking, straw bales, and seeding with
native grasses and forbs. Areas of poor herbaceous growth will be visually assessed and fertilized prior to
planting.
4.2 Riparian Area Restoration Activities
Buffer restoration areas throughout much of the Parcel will be restored using native bare -root plantings of
trees and shrubs selected from Table 8.1. At least 6 of the species listed in Table 8.1 will be planted based on
commercial availability at the time of planting.
Table 8.1 - Planting List for Upland, Seasonally -Saturated Wetland:
Species
Common Name
Approximate Density'
Forest Layer
Betula ni va
River birch
15
Overstory
Tir odendvon tuh i eva
Tulip poplar
15
Overstory
Platanus occidenta§s
American sycamore
15
Overstory
uevcus ni va
Water oak
15
Overstory
Quevcus alcata
Southern red oak
15
Overstory
uevcus pagoda
Cher bark oak
15
Overstory
uevcus michauxii
Swamp chestnut oak
15
Overstory
Quevcus palustris
Pin oak
10
Overstory
uevcus phellos
Willow oak
10
Overstory
Po ulus deltoides
Eastern cottonwood
10
Overstory
Quevcus laud o§a
Laurel oak
5
Overstory
Tzha amenicana
American basswood
5
Oversto
Ulmus amenicana
American elm
5
Oversto
Movus vubva
Red mulberry
5
Understor
Covnus amomum
Silky dogwood
5
Understor
Diospyros viv iniana
Persimmon
5
Understor
Cen s canadensis
I Redbud
1 5
Understor
'Density will be determined by the commercially -available species at the time of planting.
In swampy portions of the Parcel along UT1 and UT2, which likely have long periods of seasonal inundation
and saturation associated with the Brooks Swamp floodplain, at least 3 of the tree and shrub species from
Table 8.2 will be planted based on commercial availability at the time of planting:
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 9 August 2023

Table 8.2 — Planting List for Swamp Wetland
Species
Common Name
Approximate Density'
Forest Layer
Taxodium distichum
Bald cypress
30%
Overstory
Salk ni ra
Black willow
20%
Overstory
N ssa a uatica
Swamp blackgum
20%
Overstory
uercus michauxii
Swamp chestnut oak
10%
Overstory
Chamaecypans th oides
Atlantic white cedar
10%
Overstory
Cornus amomum
Silky dogwood
10%
Understor
Ilex deadua
Possumhaw
5%
Understor
Alnus serrulata
Tag alder
5%
Understor
'Density will be determined by the commercially -available species at the time of planting.
Trees and shrubs will be spaced at 9 feet by 9 feet during planting, which will provide a stem density of 529
stems per acre and is sufficient to meet the performance standards outlined in 15A NCAC 02B .0295 and the
MBI of 260 planted trees and shrubs per acre at the end of five years. Stems will be mixed before planting to
promote diversity of bare root species across the Parcel. Due to the randomized mixing, some stems of the
same species may be planted together. No single tree or shrub species will be greater than 50% of the planted
stems.
In areas without existing ground cover, a regionally appropriate seed mix of warm season grasses and
wildflowers will also be applied to provide temporary/permanent ground cover for soil stabilization and
reduction of sediment loss during rain events. The proposed planting area includes the areas identified as
Buffer Restoration, Buffer Enhancement, and Nutrient Restoration on Figure 7. Planting is scheduled for the
2024 planting season (December 2023 — May 2024).
4.3 Riparian Area Enhancement Activities
The buffer enhancement area depicted in Figure 7 has been visually assessed for invasive species seed sources
and Chinese privet was observed. The privet will be completely removed through invasive treatment, and
supplemental planting of shade and wetland -tolerant species selected from Table 8.1 and 8.2 will be
performed.
4.4 Riparian Area Preservation Activities
Preservation areas have been visually assessed for invasive species seed sources. Scattered Chinese privet was
observed but was not dominant in either the overstory or understory, except along the field edges. Chinese
privet will be treated during the as -built year to minimize spread to buffer restoration areas. Trash and debris
in preservation areas will be removed before the as -built report is submitted.
4.5 DWR As -Built Evaluation
Within 30 calendar days after completing the establishment of the buffer mitigation and nutrient offset areas,
the Sponsor will submit written notification to DWR documenting that all buffer mitigation and nutrient
offset 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.
5.0 Monitoring and Maintenance Plan
5.1 Monitoring Protocol
Permanent vegetation monitoring plots will be installed and assessed within the buffer restoration and
enhancement areas to measure the survival of planted trees and shrubs. The plots will be randomly placed
throughout the planted areas. A total of 8 plots will be randomly placed such that the plots are representative
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 10 August 2023

of the buffer restoration and enhancement areas (Figure 9). The size of individual quadrants will be 100
square meters.
Vegetation assessments will be conducted and follow the Carolina Vegetation Survey (CVS) Level 2 Protocol
for Recording Vegetation (2008). A reference photograph will be taken from the southwestern corner of each
of the 8 plots. Overview photographs will be taken each monitoring year and provided in the annual reports.
All planted stems in the plots will be marked with flagging tape and recorded.
The first annual monitoring activities will begin at the end of the first growing season, at least five months
after planting has been completed and no earlier than the fall season. Species composition, height, and
survival rates will be evaluated on an annual basis by plot. The total number of volunteer woody stems will
also be documented and reported. The measure of vegetative success for the Parcel will be the survival of at
least four native hardwood tree and shrub species, where no one species is greater than 50% of the
established planted stems, and an established density of at least 260 planted trees and shrubs per acre at the
end of the fifth year of monitoring. Appropriate and desirable native volunteer species may be included in the
Parcel's density to meet the performance standards with written DWR approval.
The Sponsor shall submit the annual monitoring report to DWR by December 31st of each year for five
consecutive years and will follow the terms and conditions of the MBI regarding content.
5.2 Parcel Maintenance
If the Parcel or a specific component of the Parcel fails to achieve the success criteria outlined in Section 5.1,
adaptive measures will be developed and appropriate remedial actions will be implemented. Maintenance will
be performed to correct problems on the Parcel that have a high likelihood of affecting project success. Such
items include, but are not limited to, fire, flooding, drought, or insects that cause excess tree mortality.
Implemented actions will be designed to achieve the success criteria and will include a work schedule and
updated monitoring criteria.
An herbicide application schedule may need to be implemented in the first few years of tree establishment in
the buffer restoration areas to prevent establishment of invasive species that may out -compete the planted
native vegetation. The only herbicides used on the Parcel will be aquatic -approved herbicides that will be
applied in accordance with North Carolina Department of Agriculture rules and regulations.
The easement boundary will be checked annually as part of monitoring activities. Easement boundary
conditions as well as maintenance performed will be reported in the annual monitoring reports to DWR. If
mowing is deemed necessary by the Sponsor during the monitoring period, the Sponsor must receive
approval from DWR prior to conducting any mowing activities within Zone 1 and Zone 2 of the Neuse River
Basin buffers to ensure that no buffer violations occur.
5.3 Easement Boundaries
Easement boundaries will be marked to ensure clear distinction between the Parcel and adjacent properties.
Boundaries may be identified by marker, post, tree -blazing, or other means as allowed by site conditions
and/or the conservation easement prior to the DWR onsite As -Built evaluation for the Task 2 credit release.
Boundary markers that have been disturbed, damaged, or destroyed will be repaired or replaced as needed.
Contact information for the conservation easement holder will be included on the easement markers.
6.0 Financial Assurance and Long -Term Management
6.1 Financial Assurances
Following approval of the BPDP, the Sponsor shall provide a Performance/Maintenance Bond (Bond) from
a surety company that is rated no less than an "A-" as rated by A.M. Best. The amount of the Bond shall be
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 11 August 2023

100% of the estimated cost for implementation of the riparian restoration and other related activities for the
construction of the Parcel, but not less than $150,000. Alternatively, in lieu of posting a Bond, the Sponsor
may elect to construct the Bank Parcel prior to the first credit release.
After completion of the riparian activities and construction activities on the Parcel, a separate Bond will be
secured for 100% of the estimated cost to implement the monitoring and maintenance plan, but not less than
$100,000 initially. Each Bond shall be renewed annually for a minimum of five years, and until DWR has
released all Riparian Buffer Credits and Nutrient Offset Credits to the Sponsor. Upon DWR approval, the
bond amount may be lowered each year based on the adjusted cost to complete the monitoring and
maintenance. Confirmation of bond renewal will be provided to DWR with each annual monitoring report
when applicable. DWR reserves the right to alter the credit release schedule if a monitoring report is
submitted without proof of bond renewal when applicable.
6.2 Long -Term Management
The Parcel will remain in private ownership, protected by a DWR-approved Long -Term Steward (Steward),
and will be managed under the terms detailed in a DWR-approved Conservation Easement recorded with the
Wayne County Register of Deeds. The Steward will be chosen by the Sponsor and assigned the Conservation
Easement prior to the Monitoring Year 4 Report submittal. Among other requirements documented in the
Conservation Easement, the Steward will be responsible for periodic inspection of the Parcel to ensure that
the easement restrictions are upheld in perpetuity.
7.0 Project Credit Potential
7.1 Riparian Buffer Credits
All Riparian Buffer Credits have been determined based on the ratios and percentages provided in 15A
NCAC 02B. 0295 (m) and (n) following the guidance provided in the Clarified Procedures for Calculating
Buffer Mitigation Credits and Nutrient Offset Credits letter issued by the DWR (Clarified Procedures Letter),
including the most recent Project Credit Table Template provided by DWR and incorporated in this BPDP
as Appendix G (Project Credit Table).
Riparian buffer restoration on the Parcel that is performed on agriculture lands within the Parcel, may be
used for either Riparian Buffer Credit or Nutrient Offset Credit, but not both. Riparian buffer enhancement
and preservation on the Parcel can only be used for Riparian Buffer Credit. Riparian Buffer Credit is defined
as one (1) buffer credit per one square foot or 43,560 buffer credits per one acre.
7.2 Nutrient Offset Credits
The square footage of Nutrient Offset Credits on the Bank Parcel has been determined by applying the
applicable ratios as provided in 15A NCAC 02B. 0295(m) for a Restoration Site following the guidance
provided in the Clarified Procedures Letter and using the Project Credit Table Template. As documented in
these sources, the nitrogen (N) credit conversion rate for the Neuse 01 is 19.16394 square foot of restored
riparian buffer per pound of nitrogen. All riparian areas proposed for Nutrient Offset Credits are a minimum
of 50 feet from the top of the banks along viable features on land noted in a Site Viability Letter as having
agricultural use.
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 12 August 2023

Table 9.0 — Brooks Swamp Project Credits
TOTAL AREA OF BUFFER MITIGATION (TABM)
Mitigation Totals
Square Feet
Credits
Restoration:
205,602
205,602.000
Enhancement:
5,271
2,635.500
Preservation:
56,825
5,468.636
Total Riparian Buffer:
267,698
213,706.136
TOTAL NUTRIENT OFFSET MITIGATION
Mitigation Totals
Square Feet
Credits
Nutrient
Offset:
Nitrogen:
187,863
9,802.890
Phosphorus:
0.000
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 13 August 2023

8.0 References
Lee, M. T., Peet, R. K., Roberts, S. D., & Wentworth, T. R. 2008. CVS- EEP Protocol for Recording
Vegetation Version 4.2. http://cvs.blo.unc.edu/protocol/cvs-eep-protocol-v4.2-levl-5.pdf
DWR, 2008. Buffer Interpretation/ Clarification # 2008-019 — Memorandum.
https://edocs.deq.nc.gov/WaterResources/DocView.aspx?dbid=0&id=2580086
DWR, 2019. Clarified Procedures for Calculating Buffer Mitigation Credits and Nutrient Offset Credits for
Riparian Projects Regulated under 15A NCAC .0295 and 15A NCAC 02B .0240 — Memorandum.
https://edocs.deq.nc.gov/WaterResources/DocView.aspx?dbid=0&id=2582459 6.
DWR, 2023. Project Credit Table Template —Updated July 2023. https://www.deq.nc.gov/water-
quality/surface-water-protection/401/mitigation/project-credit-table-template-updated-july-2023
DWR. Methodology and Calculations for Nutrient Reduction associated with Riparian Buffer Establishment.
https://files.nc.gov/ncdeq/Water%20Quality/Planning/NPU/Nutrient%20Offset%20Rule/Ag-Buffer-
Credit.pdf
NCDEQ, 2015. 15A NCAC 02B .0295. Mitigation Program Requirements for Protection and Maintenance of
Riparian Buffers. http://reports.oah.state.nc.us/ncac/title%2015a%20-
%20environmental%20quality/chapter%2002%20-
%20environmental%20management/subchapter%20b / 15a%20ncac%2002b%20.0295.pdf
NCDEQ, 2020. 15A NCAC 02B .0703. Nutrient Offset Credit Trading.
http://reports.oah.state.nc.us/ncac/title%2015a%20-%20environmental%20quality/chapter%2002%20-
%20environmental%20management/subchapter%20b / 15a%20ncac%2002b%20.0703.pdf
NC One Map, 2023. Contours: 2' Interval. Accessed online at
https://www.nconemap.gov/datasets/nconemap::contours-2-interval/about on August 10, 2023.
United States Department of Agriculture (USDA), 1974. Natural Resources Conservation Service, Soil Survey
for Wayne County, North Carolina. https://websollsurvey.sc.egov.usda.gov/
Wayne County, NC GIS, 2023. Accessed online at https://wayne-county-gis-
waynecountync.hub.arcgis.com/ on August 10, 2023.
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 14 August 2023

FIGURES
Brooks Swamp BPDP
Neuse HUC #03020201, Excluding Falls Lake August 2023

Burroughs
Pond
Directions:
-From US Hwy 117 take the O'Berry Road
exit onto O'Berry Rd east and drive 0.8
miles.
-Turn right onto Old Mt. Olive Highway
and drive 1.3 miles. Turn right at gravel
driveway and proceed to Parcel.
Site Coordinates:
35.2487418°N, 78.0413133°W
Dudley
l
Parker_,
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raph, GeoTechnologZ�, Inc, METI/NASA,
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Figure 1: Vicinity Map
RESTORECOLOGY 2023
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- Top of Bank
0-100,
Q Conservation Easement
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Credit Areas
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_ Buffer Enhancement,
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Figure 9: Monitoring Plan
RESTORECOLOG- 2023
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
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0 100 200
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APPENDICES
Brooks Swamp BPDP
Neuse HUC #03020201, Excluding Falls Lake August 2023

Appendix A: Brooks Swamp Photolog
s F,
4I`
r
r.
�r
Photo 1: UT1, 7/14/23
Photo 3: UT1 Preservation Area, 7/14/2023
Photo 2: UT1 Left Bank Upland Restoration Area,
7/14/23
Photo 4: UT2, 10/31/2022
Brooks Swamp BPDP: Appendix A
Neuse HUC# 03020201, Excluding Falls Lake 1 August 2023

Photo 5: UT2 Preservation Area, 7/14/23
Photo 7: UT2 Swamp Buffer Restoration Area,
10/31/22
Photo 6: UT2 Upland Buffer Restoration
Area, 4/19/2023
Photo 8: UT2 Buffer Enhancement Area, 10/31/22
Brooks Swamp BPDP: Appendix A
Neuse HUC# 03020201, Excluding Falls Lake 2 August 2023

Legend Parcel: Brooks Swamp
0 Parcel Area Historical Aerial: 1993
RISTORECOLOGY
N
A
20231 100 200
Feet
Km
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet 0 0.05 0.1

■
T - f
Legend Parcel: Brooks Swamp
0 Parcel Area Historical Aerial: 1998
RESTORECOLOGY 2023
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet
or
N
0 100 200
Feet
Km
0 0.05 0.1

Legend
0 Parcel Area
Parcel: Brooks Swamp
Historical Aerial: 2013
RESTORECOLOGY 2023
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet
N
A
0
100
200
Feet
Km
0
0.05
0.1

s
e
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A
Legend Parcel: Brooks Swamp N
0 Parcel Area Historical Aerial: 2017
RESTORECOLOGY 2023 0 10o zoFeet
Km
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet 0 0.05 0.1

DocuSign Envelope ID: 167C2E1 13-131319-4DFC-B9DB-B7D85FA84612
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Direcror
Daniel and Erica Ramsay
RestorEcology, LLC
dramsayCa)restorecology.com
NORTH CAROLINA
Environmental Quality
March 1, 2023
Project 20230163 Version 1
Wayne County
Subject: Determination for Applicability to the Neuse Buffer Rules 15A NCAC 02B .0714
Project Name: Price Farm Mitigation Site
Address: Old Mount Olive Highway, Dudley, NC 28333
Location: Lat, Long: 35.248741,-78.041313
Dear Mr. Ramsay:
On January 19, 2023, Shelton Sullivan of the Division of Water Resources (DWR) conducted an
on -site review of feature(s) located on the Price Farm Mitigation Site at the request of
RestorEcology, LLC to determine the presence of streams and the applicability of features on
the site to the Neuse River Riparian Area Protection Rules, Title 15A North Carolina
Administrative Code 02B .0714.
The enclosed map(s) depict the feature(s) evaluated and this information is also summarized
in the table below. Streams were evaluated for being ephemeral, at least intermittent, and for
subjectivity to the Neuse River Riparian Area Protection Rules. Streams that are considered
"Subject" have been located on the most recently published NRCS Soil Survey of Johnston
County and/or the most recent copy of the USGS Topographic (at 1:24,000 scale) map(s), have
been located on the ground at the site, and possess characteristics that qualify them to be at
least intermittent streams. Features that are considered "Not Subject" have been determined
to not be at least intermittent, not present on the property, or not depicted on the required
maps.
This determination only addresses the applicability to the buffer rules within the
proposed property boundary and does not approve any activity within buffers or within
waters of the state. There may be other streams or features located on the property or
just off the property that were not evaluated or do not appear on the maps referenced
above. Any of the features on the site may be considered jurisdictional according to the
US Army Corps of Engineers and subject to the Clean Water Act.
The following table addresses the features observed and rated during the DWR site visit.
North Carolina Department of Environmental Quality I Division of Water Resources
�NCRT�HG�512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NCRTH CAROLINA 919.707.9000
oePnnmem m enwromm�nw O.Z,,

DocuSign Envelope ID: 167C2E1 B-BB19-4DFC-B9DB-B7D85FA84612
Page 2 of 2
Price Farm.
DWR 20230163 V1
Feature Type:
stream (ephemeral,
Subject
Feature ID
intermittent,
to Buffer
Start @
Stop @
Depicted on
Depicted on
perennial), ditch,
Rules
Soil Survey
USGS Topo
swale, wetland,
other
Just south of
road culvert,
Modified Stream, at
north of
Continues to
UT1
least intermittent
Subject
property
confluence of
Yes
No
boundary.
Brooks Swamp
Labeled UT1
Start.
Southeastern
Stream, at least
property
Continues to
UT2
Subject
boundary.
confluence of
Yes
No
intermittent
Labeled UT2
Brooks Swamp
Start.
* E: Ephemeral, I: Intermittent, P: Perennial
This on -site determination shall expire five (5) years from the date of this letter.
Landowners or affected parties that dispute this determination made by the DWR may
request an appeal determination by the Director of Water Resources. An appeal request
must be made within sixty (60) calendar days of the date of this letter to the Director in
writing.
Ifsending via U.S. Postal Service:
Division of Water Resources
401 & Buffer Permitting Branch Supervisor
1617 Mail Service Center
Raleigh, NC 27699-1617
Ifsending via delivery service (UPS, FedEx, etc.)
Division of Water Resources
401 & Buffer Permitting Branch Supervisor
512 N Salisbury St
Raleich. NC 27604
This determination is final and binding as detailed above unless an appeal is requested within
sixty (60) calendar days of the date of this letter.
If you have any additional questions or require additional information, please contact Shelton
Sullivan at [e-mail] or 919-707-3636. This determination is subject to
review as provided in G.S. 150B.
Sincerely, DocuSigned by:
�l� WI1en,�
A43C72700BD543E...
Katie Merritt, Acting Supervisor
401 & Buffer Permitting Branch
Attachments: Site Map with labels, NRCS Soil Survey, USGS Topographical Map
cc: 401 & Buffer Permitting Branch, Laserfiche File 20230163 V1
DWR Washington Regional Office, via email
Filename: 20230163_PriceFarm_Strem Det_Wayne_Co

DocuSign Envelope ID: 167C2E1 13-131319-4DFC-B9DB-B7D85FA84612
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Census Bureau, USDA, NC CGIA, Maxar, Microsoft Feet
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Coordinate System: NAD 1983 StatePlane North Carolina PIPS 3200 Feet 0.1

DocuSign Envelope ID: 167C2E1 B-BB19-4DFC-B9DB-B7D85FA84612
Soil Survey, Wayne County NC
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DocuSign Envelope ID: 1313755ABF-413FF-4454-AC92-1 BCB3846E849
RDY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
June 27, 2023
RestorEcology, LLC
Attn: Daniel Ramsay
(via electronic mail: [e-mail] )
Re: Site Viability for Buffer Mitigation and Nutrient Offset — Brooks Swamp Site
Near 35.2487418,-78.0413133 located off Old Mt. Olive Highway in Dudley, NC
Neuse 03020201
Johnston County
Dear Mr. Ramsay,
On March 13, 2023, Katie Merritt, with the Division of Water Resources (DWR), received a request
from you on behalf of RestorEcology, LLC (RE) for a site visit near the above -referenced site in the
Neuse River Basin within the 8-digit Hydrologic Unit Code 03020201. The site visit was to
determine the potential for nutrient offset and buffer mitigation within a proposed conservation
easement boundary, which is more accurately depicted in the attached figure labeled "Figure 1 —
Brooks Swamp Parcel" prepared by RE. Another map, labeled "Figure 2 — Land Cover Aerial Photo:
2017" is also attached to depict land cover and privet areas and was prepared by RE and edited by
DWR. The proposed easement boundary on Figure 1, includes all riparian areas intended to be
proposed as part of the mitigation site. On March 22, 2023, Ms. Merritt performed a site assessment
of the subject site. Staff with RE were also present. The following site constraints/concerns were
observed:
• Sinks holes, erosional rills and other areas with active erosion were observed throughout
UT1. Stabilization efforts for active erosion and sink holes need to be addressed as part of
the riparian restoration plan.
• Invasives, such as privet, were observed in high densities along UT1 and UT2. Treatment of
invasive privet will be required as part of the riparian restoration plan. See Figure 2 for land
cover descriptions.
• Inundated floodplain areas along UT1 and UT2 are high risk for stem survivability. DWR
recommends RE proposed planting wetland tolerant species as part of the riparian restoration
plan.
• Trash and debris within the stream channel and/or riparian areas were observed onsite and
need to be removed as part of the riparian restoration plan. Stable structures, such as the barn
onsite, are not required to be removed from the riparian area but cannot be included within
credit generating square footage. See Figure 2 for approximate locations of structures and
debris.
Ms. Merritt's evaluation of the features onsite and their associated mitigation determination for the
riparian areas are provided in the table below. This evaluation was made from Top of Bank (TOB)
and landward 200' from each feature for buffer mitigation pursuant to 15A NCAC 02B .0295 and for
North Carolina Department of Environmental Quality I Division of Water Resources
,&0,fD-E > 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
Uepanmem of BA —mental puel�

DocuSign Envelope ID: 1313755ABF-413FF-4454-AC92-1 BCB3846E849
Brooks Swamp Site
RestorEcology
June 27, 2023
nutrient offset credits pursuant to 15A NCAC 02B .0703 using 15A NCAC 02B .0295 to define the
mitigation type determinations.
Feature
Classification
Subject
Riparian Land uses
Buffer
Nutrient
Mitigation Type Determination w/in
onsite
to
adjacent to Feature
Credit
Offset
riparian areas 4,5,8
Buffer
0-200'
Viable
Viable3
Rulel
UT1
Stream
Yes
A combination of non-
Yes
Yes (non-
Non -forested fields - Restoration Site
forested agricultural fields
forested ag
per 15A NCAC 02B .0295 (n)
and mature forest. Dense
fields only)
privet along field edge at
Forested areas — Preservation Site per
southern boundary (see
15A NCAC 02B .0295 (o) (5)
Figure 2)
Density populated Privet - Restoration
Site per 15A NCAC 02B .0295 (n)
*must completely remove invasives, have
a management plan for invasives, &
supplementally plant with native trees
UT2
Stream
Yes
A combination of non-
YesZ
Yes (non-
Non -forested fields - Restoration Site
forested agricultural fields
forested ag
per 15A NCAC 02B .0295 (n)
and mature forest.
fields only)
Areas where privet is the majority canopy
- areas where densely
— Restoration Site per 15A NCAC 02B
populated privet is the
.0295 (n)
only stem present (see
*must completely remove invasives, have
Figure 2)
a management plan for invasives, &
supplementally plant with native trees
-areas with clumps of
densely populated privet
Forested areas (without Privet) —
but within partially
Preservation Site per
forested areas of scattered
15A NCAC 02B .0295 (o) (5)
hardwoods
Partially forested areas w/ clumps of
privet — Enhancement Site per 15A
NCAC 02B .0295 (n)
*must completely remove invasives, have
a management plan for invasives, &
supplementally plant with native trees
'Subjectivity calls and stream origins for the features were determined by DWR in correspondence dated January 24, 2023 (DWR#
2022-1555) using the 1:24,000 scale quadrangle topographic map prepared by USGS and the most recent printed version of the soil
survey map prepared by the NRCS.
ZThe area of preservation credit within a buffer mitigation site shall comprise of no more than 25 percent (25%) of the total area of buffer
mitigation per 15A NCAC 0295 (o) (5) and 15A NCAC 0295 (o) (4). Site cannot be a Preservation Only site to comply with this rule.
3NC Division of Water Resources - Methodology and Calculations for determining Nutrient Reductions associated with Riparian Buffer
Establishment
4 Determinations made for this Site are determined based on the proposal provided in maps and figures submitted with the request.
5 All features proposed for buffer mitigation or nutrient offset, must have a planted conservation easement established that includes the
tops of channel banks when being measured perpendicular and landward from the banks, even if no credit is viable within that riparian
area.
6The area of the mitigation site on ephemeral channels shall comprise no more than 25 percent (25%) of the total area of buffer
mitigation per 15A NCAC 02B .0295 (o) (7).
7The area described as an Enhancement Site was assessed and determined to comply with all of 15A NCAC 02B .0295 (o) (6). Cattle
exclusion fencing is required to be installed around the mitigation area to get buffer credit under this part of the rule.
'The confluence of a ditch to a stream is required to be secured with a conservation easement to preserve the hydrologic connectivity of
ditches to streams to be viable to generate buffer and/or nutrient offset credits
Page 2 of 3

DocuSign Envelope ID: 1313755ABF-413FF-4454-AC92-1 BCB3846E849
Brooks Swamp Site
RestorEcology
June 27, 2023
Determinations provided in the table above were made using a proposed easement boundary showing
proposed mitigation areas and features shown on Figure 1 and Figure 2. The maps representing the
proposal for the site are attached to this letter and initialed by Ms. Merritt on June 27, 2023.
Substantial changes to the proposed easement boundary as well as any site constraints identified in
this letter that are not addressed in a riparian restoration plan, could affect the Site's potential to
generate buffer mitigation and nutrient offset credits.
This letter does not constitute an approval of this Site to generate buffer and nutrient offset credits.
Pursuant to 15A NCAC 02B .0295, a mitigation proposal and a mitigation plan shall be submitted to
DWR for written approval prior to conducting any mitigation activities in riparian areas and/or
surface waters for buffer mitigation credit. Pursuant to 15A NCAC 02B .0703, a proposal regarding a
proposed nutrient load -reducing measure for nutrient offset credit shall be submitted to DWR for
approval prior to any mitigation activities in riparian areas and/or surface waters.
All vegetative plantings, performance criteria and other mitigation requirements for riparian
restoration, enhancement and preservation must follow the requirements in 15A NCAC 02B .0295 to
be eligible for buffer and/or nutrient offset mitigation credits. For any areas depicted as not being
viable for nutrient offset credit above, one could propose a different measure, along with supporting
calculations and sufficient detail to support estimates of load reduction, for review by the DWR to
determine viability for nutrient offset in accordance with 15A NCAC 02B .0703.
This viability assessment will expire on June 27, 2025 or upon approval of a mitigation plan by
the DWR, whichever comes first. This letter should be provided in any nutrient offset, buffer,
stream or wetland mitigation plan for this Site.
Please contact Katie Merritt at [e-mail] if you have any questions regarding this
correspondence.
Sincerely,
Docu'S,ig-n1e-d ,by,
S� � GDSS
755ABFOCD8OB428...
Stephanie Goss, Supervisor
401 and Buffer Permitting Branch
Attachments: Figure 1 — Brooks Swamp Parcel; Figure 2 — Land Cover Aerial Photo 2017
cc: File Copy (Katie Merritt)
Page 3 of 3

DocuSign Envelope ID: BB755ABF-4BFF-4454-AC92-1 BCB3846E849
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( ) RESTORECOLOGY
From: Daniel Ramsay
RestorEcology Neuse, LLC (RestorEcology)
PO Box 5842
Cary, NC 27512
919-817-7378
[e-mail]
To: Ms. Kathryn Matthews
U.S. Fish and Wildlife Service
Raleigh Field Office
P.O. Box 33726
Raleigh, NC 27636-3726
July 17, 2023
Re: Online Project Review Request, Brooks Swamp Buffer and Nutrient Offset Bank Project,
Wayne County, North Carolina, NC Division of Water Resources (DWR) #20230163
Dear Ms. Matthews,
We have reviewed the referenced project using the North Carolina Field Office's online project
review process and have followed all guidance and instructions in completing the review. We
completed our review on July 17, 2023 and are submitting our project review package in
accordance with the instructions for further review.
Our Proposed Action consists of: approximately 11.1 acres of cropland will be planted with native
hardwood trees to lessen nutrient inputs into the streams from agricultural activities and provide
restored stream buffers. Existing wooded stream buffers within the project area will be
preserved and enhanced. Waters of the U.S. permitting under Section 404/401 of the Clean
Water Act will not be required for the Project because ground -disturbing construction activities
and changes to Project streams are not proposed. Riparian buffer credits, nitrogen (lb) and
phosphorus (lb) will be generated by the Project, as regulated by the NC DWR. Credits will be
sold on the private mitigation bank market to offset development impacts within the Neuse River
Basin HUC #03020201, excluding Falls Lake Watershed. The project tree planting is expected to
be completed by winter 2024/2025.
150 WRENN DR, #5842, CARY, NC 27512
T [phone] U WWW.RESTORECOLOGY.COM

The Project is located at 35.2487418°N, 78.0413133°W in the Neuse River Basin HUC #03020201
in Wayne County, NC. The location of the project and the action area are identified on the
enclosed USGS topographic map and aerial photo map.
There is no federal nexus, but project review has been requested by the NC DWR.
The enclosed project review package provides the information about the species, critical habitat,
and bald eagles considered in our review, and the species conclusions table included in the
package identifies our determinations for the resources that may be affected by the project.
For additional information, please contact Daniel Ramsay at the address listed above.
Sincerely,
&Mis � k�
Daniel Ramsay, PWS
Owner, RestorEcology
Enclosures:
1) ENTIRE PROJECT REVIEW PACKAGE
2) Other relevant project data/documents

aP�t�,�.NT OF Tfy�'
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9 FISH AND WILDLIFE SERVICE
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Raleigh Field Office
P.O. Box 33726
Raleigh, NC 27636-3726
Date: July 17, 2023
Self -Certification Letter
Project Name
Brooks Swamp Buffer and Nutrient Bank
IPaC Project Code:
Dear Applicant:
2023-0104366 IPaC Record Locator #
Y1fASNN GL His
Interior
Thank you for using the U.S. Fish and Wildlife Service (Service) Raleigh Ecological
Services online project review process. By printing this letter in conjunction with your
project review package, you are certifying that you have completed the online project
review process for the project named above in accordance with all instructions
provided, using the best available information to reach your conclusions. This letter,
and the enclosed project review package, completes the review of your project in
accordance with the Endangered Species Act of 1973 (16 U.S.C. 1531-1544, 87 Stat.
884), as amended (ESA), and the Bald and Golden Eagle Protection Act (16 U.S.C.
668-668c, 54 Stat. 250), as amended (Eagle Act). This letter also provides
information for your project review under the National Environmental Policy Act of
1969 (P.L. 91-190, 42 U.S.C. 4321-4347, 83 Stat. 852), as amended. A copy of this
letter and the project review package must be submitted to this office for this
certification to be valid. This letter and the project review package will be maintained
in our records.
The species conclusions table in the enclosed project review package summarizes
your ESA and Eagle Act conclusions. Based on your analysis, mark all the
determinations that apply:
❑"no effect" determinations for proposed/listed species and/or
proposed/designated critical habitat; and/or
❑ "may affect, not likely to adversely affect" determinations for proposed/listed
species and/or proposed/designated critical habitat; and/or
❑E "no Eagle Act permit required" determinations for eagles.
Version 5/22/2023

Applicant Page 2
We certify that use of the online project review process in strict accordance with the
instructions provided as documented in the enclosed project review package results in
reaching the appropriate determinations. Therefore, we concur with the "no effect" or
"not likely to adversely affect" determinations for proposed and listed species and
proposed and designated critical habitat; the "may affect" determination for Northern
long-eared bat; and/or the "no Eagle Act permit required" determinations for eagles.
Additional coordination with this office is not needed. Candidate species are not
legally protected pursuant to the ESA. However, the Service encourages consideration
of these species by avoiding adverse impacts to them. Please contact this office for
additional coordination if your project action area contains candidate species.
Should project plans change or if additional information on the distribution of
proposed or listed species, proposed or designated critical habitat, or bald eagles
becomes available, this determination may be reconsidered. This certification letter is
valid for 1 year. Information about the online project review process including
instructions, species information, and other information regarding project reviews
within North Carolina is available at our website http://www.fws.gov. If you have any
questions, you can write to us at [e-mail] or please contact Leigh Mann of
this office at 919-856-4520, ext. 10.
Sincerely,
/s/Pete Benjamin
Pete Benjamin
Field Supervisor
Raleigh Ecological Services
Enclosures - project review package
Version 5/22/2023

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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Ecological Services Field Office
Post Office Box 33726
Raleigh, NC 27636-3726
Phone: [phone] Fax: [phone]
In Reply Refer To:
Project Code: 2023-0104366
Project Name: Brooks Swamp Buffer and Nutrient Offset Mitigation Project
e x
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July 13, 2023
Subject: List of threatened and endangered species that may occur in your proposed project
location or may be affected by your proposed project
To Whom It May Concern:
The enclosed species list identifies threatened, endangered, proposed and candidate species, as
well as proposed and final designated critical habitat, that may occur within the boundary of your
proposed project and/or may be affected by your proposed project. The species list fulfills the
requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of the
Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 et seq.). If your project area
contains suitable habitat for any of the federally -listed species on this species list, the proposed
action has the potential to adversely affect those species. If suitable habitat is present, surveys
should be conducted to determine the species' presence or absence within the project area. The
use of this species list and/or North Carolina Natural Heritage program data should not be
substituted for actual field surveys.
New information based on updated surveys, changes in the abundance and distribution of
species, changed habitat conditions, or other factors could change this list. Please feel free to
contact us if you need more current information or assistance regarding the potential impacts to
federally proposed, listed, and candidate species and federally designated and proposed critical
habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the
Act, the accuracy of this species list should be verified after 90 days. This verification can be
completed formally or informally as desired. The Service recommends that verification be
completed by visiting the ECOS-IPaC website at regular intervals during project planning and
implementation for updates to species lists and information. An updated list may be requested
through the ECOS-IPaC system by completing the same process used to receive the enclosed list.
The purpose of the Act is to provide a means whereby threatened and endangered species and the
ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2) of the
Act and its implementing regulations (50 CFR 402 et seq.), Federal agencies are required to
utilize their authorities to carry out programs for the conservation of threatened and endangered

07/13/2023
species and to determine whether projects may affect threatened and endangered species and/or
designated critical habitat.
A Biological Assessment is required for construction projects (or other undertakings having
similar physical impacts) that are major Federal actions significantly affecting the quality of the
human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2)
(c)). For projects other than major construction activities, the Service suggests that a biological
evaluation similar to a Biological Assessment be prepared to determine whether the project may
affect listed or proposed species and/or designated or proposed critical habitat. Recommended
contents of a Biological Assessment are described at 50 CFR 402.12.
If a Federal agency determines, based on the Biological Assessment or biological evaluation, that
listed species and/or designated critical habitat may be affected by the proposed project, the
agency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Service
recommends that candidate species, proposed species and proposed critical habitat be addressed
within the consultation. More information on the regulations and procedures for section 7
consultation, including the role of permit or license applicants, can be found in the "Endangered
Species Consultation Handbook" at:
http://www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF
Migratory Birds: In addition to responsibilities to protect threatened and endangered species
under the Endangered Species Act (ESA), there are additional responsibilities under the
Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle Protection Act (BGEPA) to
protect native birds from project -related impacts. Any activity, intentional or unintentional,
resulting in take of migratory birds, including eagles, is prohibited unless otherwise permitted by
the U.S. Fish and Wildlife Service (50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)). For more
information regarding these Acts see https://www.fws.gov/birds/policies-and-regulations.php.
The MBTA has no provision for allowing take of migratory birds that may be unintentionally
killed or injured by otherwise lawful activities. It is the responsibility of the project proponent to
comply with these Acts by identifying potential impacts to migratory birds and eagles within
applicable NEPA documents (when there is a federal nexus) or a Bird/Eagle Conservation Plan
(when there is no federal nexus). Proponents should implement conservation measures to avoid
or minimize the production of project -related stressors or minimize the exposure of birds and
their resources to the project -related stressors. For more information on avian stressors and
recommended conservation measures see https://www.fws.gov/birds/bird-enthusiasts/threats-to-
birds.php.
In addition to MBTA and BGEPA, Executive Order 13186: Responsibilities of Federal Agencies
to Protect Migratory Birds, obligates all Federal agencies that engage in or authorize activities
that might affect migratory birds, to minimize those effects and encourage conservation measures
that will improve bird populations. Executive Order 13186 provides for the protection of both
migratory birds and migratory bird habitat. For information regarding the implementation of
Executive Order 13186, please visit https://www.fws.gov/birds/policies-and-regulations/
executive-orders/e0-13186.php.

07/13/2023
We appreciate your concern for threatened and endangered species. The Service encourages
Federal agencies to include conservation of threatened and endangered species into their project
planning to further the purposes of the Act. Please include the Consultation Code in the header of
this letter with any request for consultation or correspondence about your project that you submit
to our office.
Attachment(s):
• Official Species List
• Migratory Birds

07/13/2023
OFFICIAL SPECIES LIST
This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the
requirement for Federal agencies to "request of the Secretary of the Interior information whether
any species which is listed or proposed to be listed may be present in the area of a proposed
action".
This species list is provided by:
Raleigh Ecological Services Field Office
Post Office Box 33726
Raleigh, NC 27636-3726
[phone]

07/13/2023
PROJECT SUMMARY
Project Code: 2023-0104366
Project Name: Brooks Swamp Buffer and Nutrient Offset Mitigation Project
Project Type: Restoration / Enhancement - Forest
Project Description: Converting agricultural fields to protected conservation area and planting
trees and shrubs along project streams.
Project Location:
The approximate location of the project can be viewed in Google Maps: https:
www.google.com/maps/@35.24667705,-78.04355093022687,14z
Counties: Wayne County, North Carolina

07/13/2023
ENDANGERED SPECIES ACT SPECIES
There is a total of 5 threatened, endangered, or candidate species on this species list.
Species on this list should be considered in an effects analysis for your project and could include
species that exist in another geographic area. For example, certain fish may appear on the species
list because a project could affect downstream species.
IPaC does not display listed species or critical habitats under the sole jurisdiction of NOAA
Fisheriesi, as USFWS does not have the authority to speak on behalf of NOAA and the
Department of Commerce.
See the "Critical habitats" section below for those critical habitats that lie wholly or partially
within your project area under this office's jurisdiction. Please contact the designated FWS office
if you have questions.
1. NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an
office of the National Oceanic and Atmospheric Administration within the Department of
Commerce.
MAMMALS
NAME S TATU S
Tricolored Bat Perimyotis sub flavus Proposed
No critical habitat has been designated for this species. Endangered
Species profile: https://ecos.fws.gov/ecp/species/10515
BIRDS
NAME
S TATU S
Red -cockaded Woodpecker Picoides borealis
Endangered
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/7614
AMPHIBIANS
NAME
S TATU S
Neuse River Waterdog Necturus lewisi
Threatened
There is final critical habitat for this species. Your location does not overlap the critical habitat.
Species profile: https://ecos.fws.gov/ecp/species/6772
FISHES
NAME
S TATU S
Carolina Madtom Noturus furiosus
Endangered
There is final critical habitat for this species. Your location does not overlap the critical habitat.
Species profile: https://ecos.fws.gov/ecp/species/528

07/13/2023
4
INSECTS
NAME
Monarch Butterfly Danaus plexippus
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/9743
STATUS
Candidate
CRITICAL HABITATS
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S
JURISDICTION.
YOU ARE STILL REQUIRED TO DETERMINE IF YOUR PROJECT(S) MAY HAVE EFFECTS ON ALL
ABOVE LISTED SPECIES.

07/13/2023
MIGRATORY BIRDS
Certain birds are protected under the Migratory Bird Treaty Act! and the Bald and Golden Eagle
Protection Act2.
Any person or organization who plans or conducts activities that may result in impacts to
migratory birds, eagles, and their habitats should follow appropriate regulations and consider
implementing appropriate conservation measures, as described below.
1. The Migratory Birds Treater of 1918.
2. The Bald and Golden Eagle Protection Act of 1940.
3. 50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)
The birds listed below are birds of particular concern either because they occur on the
USFWS Birds of Conservation Concern (BCC) list or warrant special attention in your
project location. To learn more about the levels of concern for birds on your list and how this
list is generated, see the FAQ below. This is not a list of every bird you may find in this location,
nor a guarantee that every bird on this list will be found in your project area. To see exact
locations of where birders and the general public have sighted birds in and around your project
area, visit the E-bird data mapping tool (Tip: enter your location, desired date range and a species
on your list). For projects that occur off the Atlantic Coast, additional maps and models detailing
the relative occurrence and abundance of bird species on your list are available. Links to
additional information about Atlantic Coast birds, and other important information about your
migratory bird list, including how to properly interpret and use your migratory bird report, can be
found below.
For guidance on when to schedule activities or implement avoidance and minimization measures
to reduce impacts to migratory birds on your list, click on the PROBABILITY OF PRESENCE
SUMMARY at the top of your list to see when these birds are most likely to be present and
breeding in your project area.
BREEDING
NAME SEASON
Bald Eagle Haliaeetus leucocephalus Breeds Sep 1 to
This is not a Bird of Conservation Concern (BCC) in this area, but warrants attention Jul 31
because of the Eagle Act or for potential susceptibilities in offshore areas from certain types
of development or activities.
Brown -headed Nuthatch Sitta pusilla Breeds Mar 1
This is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions to Jul 15
(BCRs) in the continental USA
Chimney Swift Chaetura pelagica Breeds Mar 15
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA to Aug 25
and Alaska.

07/13/2023
NAME
BREEDING
SEASON
Prairie Warbler Dendroica discolor Breeds May 1
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA to Jul 31
and Alaska.
Prothonotary Warbler Protonotaria citrea
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
and Alaska.
Red-headed Woodpecker Melanerpes erythrocephalus
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
and Alaska.
Wood Thrush Hylocichla mustelina
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
and Alaska.
PROBABILITY OF PRESENCE SUMMARY
Breeds Apr 1 to
Jul 31
Breeds May 10
to Sep 10
Breeds May 10
to Aug 31
The graphs below provide our best understanding of when birds of concern are most likely to be
present in your project area. This information can be used to tailor and schedule your project
activities to avoid or minimize impacts to birds. Please make sure you read and understand the
FAQ "Proper Interpretation and Use of Your Migratory Bird Report" before using or attempting
to interpret this report.
Probability of Presence (■)
Each green bar represents the bird's relative probability of presence in the 10km grid cell(s) your
project overlaps during a particular week of the year. (A year is represented as 12 4-week
months.) A taller bar indicates a higher probability of species presence. The survey effort (see
below) can be used to establish a level of confidence in the presence score. One can have higher
confidence in the presence score if the corresponding survey effort is also high.
How is the probability of presence score calculated? The calculation is done in three steps:
The probability of presence for each week is calculated as the number of survey events in
the week where the species was detected divided by the total number of survey events for
that week. For example, if in week 12 there were 20 survey events and the Spotted Towhee
was found in 5 of them, the probability of presence of the Spotted Towhee in week 12 is
0.25.
2. To properly present the pattern of presence across the year, the relative probability of
presence is calculated. This is the probability of presence divided by the maximum
probability of presence across all weeks. For example, imagine the probability of presence
in week 20 for the Spotted Towhee is 0.05, and that the probability of presence at week 12
(0.25) is the maximum of any week of the year. The relative probability of presence on
week 12 is 0.25/0.25 = 1; at week 20 it is 0.05/0.25 = 0.2.

07/13/2023 3
3. The relative probability of presence calculated in the previous step undergoes a statistical
conversion so that all possible values fall between 0 and 10, inclusive. This is the
probability of presence score.
Breeding Season( )
Yellow bars denote a very liberal estimate of the time -frame inside which the bird breeds across
its entire range. If there are no yellow bars shown for a bird, it does not breed in your project
area.
Survey Effort (1)
Vertical black lines superimposed on probability of presence bars indicate the number of surveys
performed for that species in the 10km grid cell(s) your project area overlaps. The number of
surveys is expressed as a range, for example, 33 to 64 surveys.
No Data (—)
A week is marked as having no data if there were no survey events for that week.
Survey Timeframe
Surveys from only the last 10 years are used in order to ensure delivery of currently relevant
information. The exception to this is areas off the Atlantic coast, where bird returns are based on
all years of available data, since data in these areas is currently much more sparse.
R' probability of presence breeding season I survey effort — no data
SPECIES JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Bald Eagle ��.. -L All Jill Jill Jill 11-- — — — — JIII Jill Jill Jill
Non -BCC
Vulnerable
Brown -headed —
— — --
— — — — — — — — —
— — — Jill Jill 11"' —+ r—III
Nuthatch
BCC-BCR
Chimney
BCC R ng wlide — — — — —
— — --III Jill Jill Jill — — — —
(CON)
Prairie Warbler
---- ----
---- ----
IFFFJill — — — — — — — —
BCC Rangewide
(CON)
Prothonotary
Warbler ---- ----
---- --- ----
Jill IN 1111 Jill —
BCC Rangewide
(CON)
Red-headed
— — — — —
Woodpecker
— — — — — — — — — — — — — —
Jill Jill II
BCC Rangewide
(CON)

07/13/2023 4
Wood Thrush
BCC Rangewide T
(CON)
Additional information can be found using the following links:
• Birds of Conservation Concern https://www.fws.gov/program/migratory-birds/species
• Measures for avoiding and minimizing impacts to birds https://www.fws.gov/library/
collections/avoiding-and-minimizing-incidental-take-miuratorv-birds
Nationwide conservation measures for birds https://www.fws.gov/sites/default/files/
documents/nationwide-standard-conservation-measures.Ddf
MIGRATORY BIRDS FAQ
Tell me more about conservation measures I can implement to avoid or minimize impacts
to migratory birds.
Nationwide Conservation Measures describes measures that can help avoid and minimize
impacts to all birds at any location year round. Implementation of these measures is particularly
important when birds are most likely to occur in the project area. When birds may be breeding in
the area, identifying the locations of any active nests and avoiding their destruction is a very
helpful impact minimization measure. To see when birds are most likely to occur and be breeding
in your project area, view the Probability of Presence Summary. Additional measures or permits
may be advisable depending on the type of activity you are conducting and the type of
infrastructure or bird species present on your project site.
What does IPaC use to generate the list of migratory birds that potentially occur in my
specified location?
The Migratory Bird Resource List is comprised of USFWS Birds of Conservation Concern
(BCQ and other species that may warrant special attention in your project location.
The migratory bird list generated for your project is derived from data provided by the Avian
Knowledge Network (AKN). The AKN data is based on a growing collection of survey, banding_,
and citizen science datasets and is queried and filtered to return a list of those birds reported as
occurring in the 10km grid cell(s) which your project intersects, and that have been identified as
warranting special attention because they are a BCC species in that area, an eagle (Eagle Act
requirements may apply), or a species that has a particular vulnerability to offshore activities or
development.
Again, the Migratory Bird Resource list includes only a subset of birds that may occur in your
project area. It is not representative of all birds that may occur in your project area. To get a list
of all birds potentially present in your project area, please visit the Rapid Avian Information
Locator (RAIL) Tool.
What does IPaC use to generate the probability of presence graphs for the migratory birds
potentially occurring in my specified location?

07/13/2023
The probability of presence graphs associated with your migratory bird list are based on data
provided by the Avian Knowledge Network (AKN). This data is derived from a growing
collection of survey, banding, and citizen science datasets.
Probability of presence data is continuously being updated as new and better information
becomes available. To learn more about how the probability of presence graphs are produced and
how to interpret them, go the Probability of Presence Summary and then click on the "Tell me
about these graphs" link.
How do I know if a bird is breeding, wintering or migrating in my area?
To see what part of a particular bird's range your project area falls within (i.e. breeding,
wintering, migrating or year-round), you may query your location using the RAIL Tool and look
at the range maps provided for birds in your area at the bottom of the profiles provided for each
bird in your results. If a bird on your migratory bird species list has a breeding season associated
with it, if that bird does occur in your project area, there may be nests present at some point
within the timeframe specified. If "Breeds elsewhere" is indicated, then the bird likely does not
breed in your project area.
What are the levels of concern for migratory birds?
Migratory birds delivered through IPaC fall into the following distinct categories of concern:
1. "BCC Rangewide" birds are Birds of Conservation Concern (BCC) that are of concern
throughout their range anywhere within the USA (including Hawaii, the Pacific Islands,
Puerto Rico, and the Virgin Islands);
2. "BCC - BCR" birds are BCCs that are of concern only in particular Bird Conservation
Regions (BCRs) in the continental USA; and
3. "Non -BCC - Vulnerable" birds are not BCC species in your project area, but appear on
your list either because of the Eagle Act requirements (for eagles) or (for non -eagles)
potential susceptibilities in offshore areas from certain types of development or activities
(e.g. offshore energy development or longline fishing).
Although it is important to try to avoid and minimize impacts to all birds, efforts should be made,
in particular, to avoid and minimize impacts to the birds on this list, especially eagles and BCC
species of rangewide concern. For more information on conservation measures you can
implement to help avoid and minimize migratory bird impacts and requirements for eagles,
please see the FAQs for these topics.
Details about birds that are potentially affected by offshore projects
For additional details about the relative occurrence and abundance of both individual bird species
and groups of bird species within your project area off the Atlantic Coast, please visit the
Northeast Ocean Data Portal. The Portal also offers data and information about other taxa besides
birds that may be helpful to you in your project review. Alternately, you may download the bird
model results files underlying the portal maps through the NOAA NCCOS Integrative Statistical
Modeling and Predictive Mapping of Marine Bird Distributions and Abundance on the Atlantic
Outer Continental Shelf project webpage.

07/13/2023
Bird tracking data can also provide additional details about occurrence and habitat use
throughout the year, including migration. Models relying on survey data may not include this
information. For additional information on marine bird tracking data, see the Diving Bird Study
and the nanotag studies or contact Caleb Spiegel or Pam Lorin.
What if I have eagles on my list?
If your project has the potential to disturb or kill eagles, you may need to obtain a permit to avoid
violating the Eagle Act should such impacts occur.
Proper Interpretation and Use of Your Migratory Bird Report
The migratory bird list generated is not a list of all birds in your project area, only a subset of
birds of priority concern. To learn more about how your list is generated, and see options for
identifying what other birds may be in your project area, please see the FAQ "What does IPaC
use to generate the migratory birds potentially occurring in my specified location". Please be
aware this report provides the "probability of presence" of birds within the 10 km grid cell(s) that
overlap your project; not your exact project footprint. On the graphs provided, please also look
carefully at the survey effort (indicated by the black vertical bar) and for the existence of the "no
data" indicator (a red horizontal bar). A high survey effort is the key component. If the survey
effort is high, then the probability of presence score can be viewed as more dependable. In
contrast, a low survey effort bar or no data bar means a lack of data and, therefore, a lack of
certainty about presence of the species. This list is not perfect; it is simply a starting point for
identifying what birds of concern have the potential to be in your project area, when they might
be there, and if they might be breeding (which means nests might be present). The list helps you
know what to look for to confirm presence, and helps guide you in knowing when to implement
conservation measures to avoid or minimize potential impacts from your project activities,
should presence be confirmed. To learn more about conservation measures, visit the FAQ "Tell
me about conservation measures I can implement to avoid or minimize impacts to migratory
birds" at the bottom of your migratory bird trust resources page.

07/13/2023
IPAC USER CONTACT INFORMATION
Agency: Private Entity
Name: Daniel Ramsay
Address: 150 Wrenn Drive #5842
City:
Cary
State:
NC
Zip:
27512
Email
[e-mail]
Phone:
9198177378

Roy Cooper, Governor
9" 0 INC DEPARTMENT OF
""i ■
WMk.M 1 NATURAL AND CULTURAL RESOURCES
■-000
July 13, 2023
Daniel Ramsay
RestorEcology, LLC
150 Wrenn Dr. #5842
Cary, NC 27512
RE: Brooks Swamp Buffer and Nutrient Offset Mitigation Project
Dear Daniel Ramsay:
13. Reid Wilson, Secretary
Misty Buchanan
Deputy Director, Natural Heritage Program
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
Based on the project area mapped with your request, a query of the NCNHP database indicates that
there are no records for rare species, important natural communities, natural areas, and/or
conservation/managed areas within the proposed project boundary. Please note that although there
may be no documentation of natural heritage elements within the project boundary, it does not
imply or confirm their absence; the area may not have been surveyed. The results of this query
should not be substituted for field surveys where suitable habitat exists. In the event that rare
species are found within the project area, please contact the NCNHP so that we may update our
records.
The attached `Potential Occurrences' table summarizes rare species and natural communities that
have been documented within a one -mile radius of the property boundary. The proximity of these
records suggests that these natural heritage elements may potentially be present in the project area
if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one -mile
radius of the project area, if any, are also included in this report.
If a Federally -listed species is found within the project area or is indicated within a one -mile radius of
the project area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS) for
guidance. Contact information for USFWS offices in North Carolina is found here:
httr)s://www.fws.gov/offices/Directory/ListOffices.cfm?statecode=37.
Please note that natural heritage element data are maintained for the purposes of conservation
planning, project review, and scientific research, and are not intended for use as the primary criteria
for regulatory decisions. Information provided by the NCNHP database may not be published
without prior written notification to the NCNHP, and the NCNHP must be credited as an information
source in these publications. Maps of NCNHP data may not be redistributed without permission.
The NC Natural Heritage Program may follow this letter with additional correspondence if a
Dedicated Nature Preserve, Registered Heritage Area, Land and Water Fund easement, or Federally -
listed species are documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance,
please contact Rodney A. Butler at rod ney.butler�ncdcr.gov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPARTMENT OF NATURAL AND CULTURAL RESOURCES
121 1N. JON S STREET, RALEIGI I_ NC 27603 - 16Sl MAOL SERVICE CENTER. PAL EIGH. rkc 276�0
OFC 919.707.9120 • FAK 919.707.9421

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7/27/23, 1:17 PM RestorEcology, LLC Mail - Re: Brooks Swamp Buffer and Nutrient Bank, IPAC # 2023-0104366
mail Daniel Ramsay <[e-mail]>
Re: Brooks Swamp Buffer and Nutrient Bank, IPAC # 2023-0104366
2 messages
Matthews, Kathryn H <[e-mail]> Thu, Jul 27, 2023 at 12:39 PM
To: "[e-mail]" <[e-mail]>
Cc: "Mann, Leigh" <[e-mail]>
Hi Daniel,
Based on the information provided and other information available, it appears that the proposed action is
not likely to adversely affect any federally -listed endangered or threatened species, their formally
designated critical habitat, or species currently proposed for listing under the Act at this site. Thank you for
the opportunity to consult.
Sincerely,
Please note that I am teleworking Wednesday through Friday, every week. Email is the best way to reach
me. Thanks,
Kathy Matthews
NC Renewable Energy Coordinator &
Fish and Wildlife Biologist
U.S. Fish and Wildlife Service
551-F Pylon Drive
Raleigh, NC 27606
919-856-4520, x. 27
From: Daniel Ramsay <[e-mail]>
Sent: Monday, July 17, 2023 6:13 PM
To: Raleigh, FW4 <[e-mail]>
Subject: [EXTERNAL] Project Review Request, Brooks Swamp Buffer and Nutrient Bank, IPAC # 2023-0104366
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments,
or responding.
Good afternoon,
I would like to request USFWS concurrence with the attached Online Project Review Package for Brooks Swamp Buffer
and Nutrient Offset Mitigation Bank Project, IPAC #2023-0104366, in Wayne County, NC. I look forward to receiving the
USFWS' response.
Regards,
https://mail.google.com/mail/u/1 /?ik=8f6548446f&view=pt&search=all&permthid=thread-f:1772592548503661122&simpl=msg-f:177259254850366112... 1 /2

7/27/23, 1:17 PM RestorEcology, LLC Mail - Re: Brooks Swamp Buffer and Nutrient Bank, IPAC # 2023-0104366
Daniel
Daniel Ramsay, PWS
Owner
( ) RESTORECOLOGY
m: 919.817.7378 1 www.restorecology.com
Brooks Swamp Coordination Letter - USFWS.pdf
5245K
Daniel Ramsay <[e-mail]> Thu, Jul 27, 2023 at 1:17 PM
To: "Matthews, Kathryn H" <[e-mail]>
Cc: "Mann, Leigh" <[e-mail]>
Hi Kathryn,
Thanks very much for the feedback. Have a great weekend.
Thanks,
Daniel
[Quoted text hidden]
https://mail.google.com/mail/u/1 /?ik=8f6548446f&view=pt&search=all&permthid=thread-f:1772592548503661122&simpl=msg-f:177259254850366112... 2/2

( ) RESTORECOLOGY
From: Daniel Ramsay
RestorEcology Neuse, LLC (RestorEcology)
PO Box 5842
Cary, NC 27512
919-817-7378
[e-mail]
To: Ms. Renee Gledhill -Earley
State Historic Preservation Office
4617 Mail Service Center
Raleigh, NC 27699-4617
Transmitted via email to: [e-mail]
July 17, 2023
Re: Project Review Request, Brooks Swamp Buffer and Nutrient Offset Bank Project (Brooks
Swamp), Wayne County, North Carolina, NC Division of Water Resources (DWR) #20230163
Dear Ms. Gledhill -Earley,
RestorEcology would like to request a project review for Brooks Swamp, a proposed riparian
buffer and nutrient offset restoration project regulated by the DWR. The Project is located at
35.2487418°N, 78.0413133°W in the Neuse River Basin (HUC 03020201). The location of the
project and the action area are identified on the enclosed USGS topographic map and aerial
photo map.
Our proposed action consists of: approximately 11.1 acres of cropland will be planted with native
hardwood trees and shrubs to lessen nutrient inputs into the streams from agricultural activities
and provide restored stream buffers. Existing wooded stream buffers within the project area will
be preserved or enhanced. Waters of the U.S. permitting under Section 404/401 of the Clean
Water Act will not be required for the Project because changes to Project streams are not
proposed. Riparian buffer credits and nitrogen (lb) will be generated by the Project. Credits will
be sold on the private mitigation bank market to offset development impacts within the Neuse
150 WRENN DR, #5842, CARY, NC 27512
T [phone] U WWW.RESTORECOLOGY.COM

River Basin (HUC 03020201), excluding the Falls Lake Watershed. The project tree planting is
expected to be completed by winter 2024/2025.
Based on aerial photographs, USGS topographic maps, and our on -site review of the project area,
there are no historic properties (buildings, structures, districts, archaeological sites, or designed
landscape features that are listed in, or eligible for listing in, the National Register of Historic
Places, or that are 50 or more years old) within or immediately adjacent to the project area.
For additional information, please contact Daniel Ramsay at the address listed above.
Sincerely,
Daniel Ramsay, PWS
Owner, RestorEcology
Enclosures:
• USGS Topographic Map
• Aerial Photo Map

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Legend Brooks Swamp Buffer and N
Streams Nutrient Offset Mitigation Bank
Project Area
RESTORECOLOGY 2'023 0 200 400
Feet
Km
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US 0 0.07 0.15

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Mount Olive Quadrangle
Co right:© 2013 National Geographic Society; i-cubed
Legend Brooks Swamp Buffer and N
Project Area Nutrient Offset Mitigation Bank
RESTORECOLOGY 2023 0 400 800
Feet
Km
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US 0 0.15 0.3

6 � STAT£
r� Qunr-n •nog%'•
North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
August 2, 2023
Daniel Ramsay
RestorEcology Neuse, LLC
PO Box 5842
Cary, NC 27512
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
dramsay 9 restore cology. com
Re: Brooks Swamp Buffer and Nutrient Offset Bank, 27530-3930 Old Mt Olive Highway, Goldsboro,
Wayne County, ER 23-1625
Dear Mr. Ramsay:
Thank you for your letter of July 17, 2023, concerning the above -referenced undertaking. We have
reviewed the submittal and offer the following comments.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or [e-mail]. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
r Ramona Bartos, Deputy
�] State Historic Preservation Officer
Location: 109 East Jones Street Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

Brooks Swamp
0 Old Mt. Olive Highway
Dudley, NC 28333
Inquiry Number: 7410134.2s
August 07, 2023
6 Armstrong Road, 4th floor
Shelton, CT 06484
Toll Free: 800.352.0050
(rEDR www.edrnet.com
FORM-LBE-MGA

TABLE OF CONTENTS
SECTION
PAGE
Executive Summary-------------------------------------------------------
ES1
Overview Map
2
Detail Map
3
Map Findings Summary----------------------------------------------------
4
Map Findings
8
Orphan Summary---------------------------------------------------------
9
Government Records Searched/Data Currency Tracking
GRA
GEOCHECK ADDENDUM
Physical Setting Source Addendum------------------------------------------
A-1
Physical Setting Source Summary-------------------------------------------.
A-2
Physical Setting Source Map
A-7
Physical Setting Source Map Findings----------------------------------------
A-8
Physical Setting Source Records Searched------------------------------------.
PSGR-1
Thank you for your business.
Please contact EDR at 1-800-352-0050
with any questions or comments.
Disclaimer - Copyright and Trademark Notice
This Report contains certain information obtained from a variety of public and other sources reasonably available to Environmental Data
Resources, LLC. It cannot be concluded from this Report that coverage information for the target and surrounding properties does not exist
from other sources. This Report is provided on an "AS IS", "AS AVAILABLE" basis. NO WARRANTY EXPRESS OR IMPLIED IS MADE
WHATSOEVER IN CONNECTION WITH THIS REPORT. ENVIRONMENTAL DATA RESOURCES, LLC AND ITS SUBSIDIARIES,
AFFILIATES AND THIRD PARTY SUPPLIERS DISCLAIM ALL WARRANTIES, OF ANY KIND OR NATURE, EXPRESS OR IMPLIED,
ARISING OUT OF OR RELATED TO THIS REPORT OR ANY OF THE DATA AND INFORMATION PROVIDED IN THIS REPORT,
INCLUDING WITHOUT LIMITATION, ANY WARRANTIES REGARDING ACCURACY, QUALITY, CORRECTNESS, COMPLETENESS,
COMPREHENSIVENESS, SUITABILITY, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON -INFRINGEMENT,
MISAPPROPRIATION, OR OTHERWISE. ALL RISK IS ASSUMED BY THE USER. IN NO EVENT SHALL ENVIRONMENTAL DATA
RESOURCES, LLC OR ITS SUBSIDIARIES, AFFILIATES OR THIRD PARTY SUPPLIERS BE LIABLE TO ANYONE FOR ANY DIRECT,
INCIDENTAL, INDIRECT, SPECIAL, CONSEQUENTIAL OR OTHER DAMAGES OF ANY TYPE OR KIND (INCLUDING BUT NOT LIMITED
TO LOSS OF PROFITS, LOSS OF USE, OR LOSS OF DATA) INFORMATION PROVIDED IN THIS REPORT. Any analyses, estimates,
ratings, environmental risk levels, or risk codes provided in this Report are provided for illustrative purposes only, and are not intended to
provide, nor should they be interpreted as providing any facts regarding, or prediction or forecast of, any environmental risk for any property.
Only an assessment performed by a qualified environmental professional can provide findings, opinions or conclusions regarding the
environmental risk or conditions in, on or at any property.
Copyright 2023 by Environmental Data Resources, LLC. All rights reserved. Reproduction in any media or format, in whole or in part, of any
report or map of Environmental Data Resources, LLC, or its affiliates, is prohibited without prior written permission.
EDR and its logos (including Sanborn and Sanborn Map) are trademarks of Environmental Data Resources, LLC or its affiliates. All other
trademarks used herein are the property of their respective owners.
TC7410134.2s Page 1

EXECUTIVE SUMMARY
A search of available environmental records was conducted by Environmental Data Resources, Inc (EDR).
The report was designed to assist parties seeking to meet the search requirements of EPA's Standards
and Practices for All Appropriate Inquiries (40 CFR Part 312), the ASTM Standard Practice for
Environmental Site Assessments (E1527 - 21), the ASTM Standard Practice for Environmental Site
Assessments for Forestland or Rural Property (E2247 - 16), the ASTM Standard Practice for Limited
Environmental Due Diligence: Transaction Screen Process (E1528 - 22) or custom requirements developed
for the evaluation of environmental risk associated with a parcel of real estate.
TARGET PROPERTY INFORMATION
ADDRESS
0 OLD MT. OLIVE HIGHWAY
DUDLEY, NC 28333
COORDINATES
Latitude (North):
Longitude (West):
Universal Tranverse Mercator
UTM X (Meters):
UTM Y (Meters):
Elevation:
35.2466910 - 35' 14' 48.08"
78.0430970 - 78' 2' 35.14"
Zone 17
769056.4
3904211.0
141 ft. above sea level
USGS TOPOGRAPHIC MAP ASSOCIATED WITH TARGET PROPERTY
Target Property Map
Version Date:
North Map:
Version Date:
AERIAL PHOTOGRAPHY IN THIS REPORT
13847247 MOUNT OLIVE, NC
2019
13846641 SOUTHWEST GOLDSBORO, NC
2019
Portions of Photo from: 20200930
Source: USDA
TC7410134.2s EXECUTIVE SUMMARY 1

F- MAPPED SITES SUMMARY
Target Property Address:
0 OLD MT. OLIVE HIGHWAY
DUDLEY, NC 28333
Click on Map ID to see full detail.
MAP RELATIVE DIST (ft. & mi.)
ID SITE NAME ADDRESS DATABASE ACRONYMS ELEVATION DIRECTION
Reg GA -PACIFIC CORP COMP NC HSDS Same 3907, 0.740, NNE
GA -PACIFIC CORP COMP OLD MOUNT OLIVE HIGH SHWS Higher 3751, 0.710, NNE
7410134.2s Page 2

EXECUTIVE SUMMARY
STANDARD ENVIRONMENTAL RECORDS
Lists of state- and tribal (Superfund) equivalent sites
NC HSDS: The Hazardous Substance Disposal Sites list contains locations of uncontrolled and
unregulated hazardous waste sites. The file contains sites on the national priority list as well as the state
priority list. The data source is the North Carolina Center for Geographic Information and Analysis.
A review of the NC HSDS list, as provided by EDR, and dated 08/09/2011 has revealed that there is 1
NC HSDS site within approximately 1 mile of the target property.
Equal/Higher Elevation Address Direction / Distance Map ID Page
GA -PACIFIC CORP COMP NNE 1/2 - 1 (0.740 mi.) 0 8
Lists of state- and tribal hazardous waste facilities
SHWS: The State Hazardous Waste Sites records are the states' equivalent to CERCLIS. These sites
may or may not already be listed on the federal CERCLIS list. Priority sites planned for cleanup using state
funds (state equivalent of Superfund) are identified along with sites where cleanup will be paid for by
potentially responsible parties. The data come from the Department of Environment & Natural Resources'
Inactive Hazardous Sites Program.
A review of the SHWS list, as provided by EDR, and dated 02/28/2023 has revealed that there is 1 SHWS
site within approximately 1 mile of the target property.
Equal/Higher Elevation Address Direction / Distance Map ID Page
GA -PACIFIC CORP COMP OLD MOUNT OLIVE HIGH NNE 1/2 - 1 (0.710 mi.) 1 8
Facility Id: NCD000813659
TC7410134.2s EXECUTIVE SUMMARY 7

EXECUTIVE SUMMARY
Due to poor or inadequate address information, the following sites were not mapped. Count: 1 records.
Site Name
GA -PACIFIC CORP CHIP-N-SAW
Database(s)
SHWS
TC7410134.2s EXECUTIVE SUMMARY 8

OVERVIEW MAP - 7410134.2S
Target Property
A
Sites at elevations higher than
or equal to the target property
♦
Sites at elevations lower than
the target property
1
Manufactured Gas Plants
National Priority List Sites
Dept. Defense Sites
0 1/4 1/2 1 Mlles
Indian Reservations BIA Hazardous Substance
Power transmission lines Disposal Sites
Special Flood Hazard Area (1%)
El0.2% Annual Chance Flood Hazard
0 National Wetland Inventory
0 State Wetlands
This report includes Interactive Map Layers to
display and/or hide map information. The
legend includes only those icons for the
default map view.
SITE NAME: Brooks Swamp CLIENT: RestorEcology, LLC
4DDRESS: 0 Old Mt. Olive Highway CONTACT: Daniel Ramsay
Dudley NC 28333 INQUIRY #: 7410134.2s
-AT/LONG: 35.246691 / 78.043097 DATE: August 07, 2023 1:28 pm
Copyright �o 2023 EDR, Inc.(,) 2015 Tom Tom Rel. 2015.

Map ID
Direction
Distance
Elevation
HSDS
Region
NNE
1/2-1
3907 ft.
MAP FINDINGS
Site
[HeaJeH3Iy[dd lNZd lkyiIJA1
,NC
HSDS:
Name:
Address:
City:
Site Type:
Superfun Number:
Total area in coverage units:
Total perimeter in coverage units:
X-value coordinate in feet:
Y-value coordinate in feet:
Sites designated as superfund cleanup sites:
Length of feature in internal units:
Area of feature in internal units squared:
1 GA -PACIFIC CORP COMPLY
NNE OLD MOUNT OLIVE HIGHWAY
1/2-1 DUDLEY, NC
0.710 mi.
3751 ft.
Relative:
SHWS:
Higher
Name:
Actual:
Address:
177 ft.
City,State,Zip:
EPAID:
Lat/Longitude:
Geolocation Method:
GA -PACIFIC CORP COMPLY
Not reported
Not reported
1
Not reported
678702.25
3376.45996093
2288399.75
552116.75
640
3376.46011275
678702.267144
GA -PACIFIC CORP COMPLY
OLD MOUNT OLIVE HIGHWAY
DUDLEY, NC
NCD000813659
Not reported
Not reported
Click here to access the North Carolina DEQ records for this facility:
EDR ID Number
Database(s) EPA ID Number
NC HSDS S102442728
N/A
SHWS S104918995
N/A
TC7410134.2s Page 8

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mike Golden, Plant Manger
Georgia-Pacific Wood Products, LLC
139 Brewington Rd
Dudley, NC 28333
Dear Mr. Golden:
NORTH CAROLINA
Environmental Quality
April 5, 2022
Subject: Draft NPDES Permit NCO090051
Georgia Pacific Dudley Plywood Facility
Physical Chemical Not Classified WPCS
Wayne County
The Division has reviewed your request for the subject NPDES permit. Please review this draft carefully
to ensure a thorough understanding of the information, conditions, and requirements it contains.
The NPDES standard conditions (Parts II, III, and IV) that are a part of the permit are not included in this
draft document (cover, map, and Part 1). The conditions are the same as in your current permit except that
agency and division naives have been updated. The latest version is available at https.//bit.ly/2BZ4xxx
and can be viewed online or downloaded as a PDF file.
With this notification, the Division will solicit public comment on this draft permit by publishing a notice
in newspapers having circulation in the general Wayne County area, per EPA requirements. Please
provide your comments, if any, to me at the address below no later than 30 days after receiving this
draft permit.
Following the 30-day public comment period, the Division will review all pertinent comments and take
appropriate action prior to issuing a final permit. If you have questions concerning the draft, please
contact me at 919-707-3618, or via a -mail at [[e-mail]].
Sincerely,
Derek ❑enard, Environmental Specialist
NPDES Compliance and Expedited Permitting
Division of Water Resources, NCDEQ
cc: NPDES Filc
WaRO 1 Robert Tankard [[e-mail]]
Wastewater Operator Certification Group [[e-mail]]
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Bureau TIGER/Line data; USFS•Road Data; Natural Earth Data; U.S-
Brooks Swamp Department of State Humanitarian Information Unit; and NOAA National
Centers for Environmental Information, U.S. Coastal Relief Model. Data
refreshed August, 2021.
Georgia Pacific Dudley Plywood Facility
NPDES Permit NCO090051
139 Brewington Dr, Dudley
Receiving Stream: UT to Brooks Swamp (Buck Swamp)
Stream Index: 27-54-5-2 Stream Class: WS-IV; NSW
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