20160393 Ver 4_Final BPDP - Bandit Farms - FOR SUBMITTAL 091323_20230913

ID#* 20160393 Version* 4
Select Reviewer:
Blake Hartshorn
Initial Review Completed Date 09/13/2023
Mitigation Project Submittal - 9/13/2023
Is this a Prospectus, Technical Proposal or a New Site?* Yes No
Type of Mitigation Project:*
Stream Wetlands Buffer Nutrient Offset
(Select all that apply)
Project Contact Information
Contact Name: * Email Address:
Daniel Ramsay [e-mail]
Project Information
ID#: * 20160393 Version: * 4
Existing ID# Existing Version
Project Type: DMS Mitigation Bank
Project Name: Bandit Farms Buffer Mitigation and Nutrient
Offset Bank
County: Orange
Document Information
Mitigation Document Type:*
Mitigation Plans
File Upload: Final BPDP - Bandit Farms - FOR SUBMITTAL
14.94MB
091323.pdf
Please upload only one PDF of the complete file that needs to be submitted...
Signature
Print Name:* Daniel Ramsay
Signature: *
0r?-V.-W'�P4W'k?f

Comment -Response for Bandit Farms BPDP
The following contains RestorEcology Jordan, LLC's (RestorEcology) responses to comments from
the NC Division of Water Resources (DWR) dated August 29, 2023 on the Bandit Farms Bank
Parcel Development Package (BPDP) dated June 5, 2023. A comment -review meeting was held on
September 8, 2023 with DWR staff.
Page 1:
1. 8-digit HUC is irrelevant. replace with the 14 digit HUC.
Response: Revised as requested.
2. Please add the DWR# on title page.
Response: Revised as requested.
Page 4:
1 and 2. Remove term "Mitigation" from Nutrient Offset and add after "Buffer"
Response: Revised as requested.
3. Project #: 2016-0393v4
Response: Revised as requested.
4. Page 3, Insert "proposed."
Response: Revised as requested.
5. Insert "intending to be made."
Response: Revised as requested.
6. This rule is not applicable..0273 is for permittees with stormwater.
Response: Removed as requested.
7. Insert "proposed."
Response: Revised as requested.
8. Insert "Bank Parcel (DWR#2016-0393v1)"
Response: Revised as requested.
9, 10, 11, and 12. Remove "Ib" from Nitrogen and Phosphorus and replace with "nutrient offset credits."
Response: Revised as requested.
13. Insert "Sub -watershed."
Response: Revised as requested.
Bandit Farms BPDP: Comment -Response
Upper New Hope Watershed: Jordan Lake 1 September 2023

Page 5:
1. There is no "existing conditions" labeled figure.
Response: Title for Figure 2 changed to "Existing Conditions."
2. Please indicate if there have been any land use changes within the riparian areas proposed in Fig2 and shown
in Appendix A. If there have not been any land use changes please indicate that in this section.
Response: This is now indicated at the beginning of Section 2.2.
Page 6:
1. Please provide the source for where you got this information (does not need to be in the report just in the
comment response).
Response: The source is NCDOT HUC14 for ESM application, accessed at:
. _. _X. htrr -.Prvices.ncdot.gov/arcgis/rest/se
rvices/NCDOTApp ESM/NCDOT HUC14/MapServer on September 1, 2023.
2. Please do not include anything about credit potential in the Parcel Summary. We have the project credit table
for that.
Response: Noted and removed.
3. When referring to nutrient offset, the term "mitigation" is irrelevant. We do not refer to nutrient offsets as
"mitigation."
Response: Noted and changed throughout. Mitigation will only be used to refer to buffer.
4. Remove "Mitigation" from "Nutrient Offset Mitigation" in Section Title
Response: Removed as requested.
Page 7:
1. Please provide the drainage area that is relative to what is needed for .0295(o)(7) along the Ephemeral
channel of C1 and verify in writing that the riparian restoration of C1 meets the requirements in (o)(7).
Response: Drainage area relevant to (o)(7) now included in Table 4.0 and added to Figure 5. Verified in
writing in Section 2.3 that the riparian restoration of C1 meets the requirements in (o)(7.
Page 10:
1. This site should be considered for fescue treatment during the site preparation stage. Lands historically used
as managed cattle pasture and grazing are also usually compacted and would make planting of bare roots
Bandit Farms BPDP: Comment -Response
Upper New Hope Watershed: Jordan Lake 2 September 2023

susceptible to poor soil conditions. Why is the Bank Sponsor not proposing to amend soils, provide fescue
treatments, or rip as part of this site preparation phase?
Response: Soils have been augered to check for the presence of hardpan layer, and none was identified.
Therefore ripping was not prescribed. The Sponsor would prefer to avoid widespread herbicide usage for
site ecology unless deemed necessary during monitoring of tree/shrub establishment success. The
planting area will be bushhogged prior to planting to promote seedling establishment. Herbaceous cover
is relatively diverse in the former pasture area, which is located on the far west side of the Parcel along
Stream A and Morgan Creek. Based on the vigor of existing vegetation throughout the Parcel, widespread
fertilization is not deemed necessary. Bare soil areas present at bank approval will be fertilized, seeded,
and strawed as part of construction following approval.
2. DWR does not allow Black Walnut to be planted due to the allelopathic properties."
Response: Noted and removed.
Page 11:
1. It says you want to use trees and shrubs towards your performance standard however Table 8 does not
indicate tree vs. shrub. Please add a column with this information clearly identifying what is shrub and tree.
Response: The planting table has been updated to indicate shrub vs. tree.
2. If 15 species (I excluded black walnut) of trees are shown in the table, DWR expects 15 species to be planted.
If anticipating to plant only 7 from the list, DWR cannot confirm the density percentages column would comply
with the performance standard of "no one tree species will be greater than 50%" as noted on Rule .0295 (n)(2).
At this time the density according to Table 8 is not accurate unless all 15 species are planted.
It is understood that changes to planting plans can happen. If any changes are needed to the planting list before
planting, the Provider will need to submit a request to DWR for approval of the modified planting list if not
listed as an approved tree in Table 8. DWR will accept a few substitutions if RestorEcology wants to include a
table as potential substitutions in a Table 8b but you must include the % those subs are intended to be utilized
in the case you need those substitutions.
Response: Table 8.0 has been separated into primary species (Table 8.1) and substitute species (Table 8.2)
to address this comment. Density percentages have been updated accordingly.
3. Change all terminology from "buffer" to "riparian."
Response: reviewed BPDP for appropriate changes and made them.
4. Revise "buffer" to "buffer and adjacent riparian area."
Response: revised to read "riparian restoration areas"
5 and 6. Revise "buffer restoration areas" to "riparian buffer credit and nutrient offset credit area."
Response: revised as requested
7. Please add "vigor" into the evaluation.
Response: added as requested.
Bandit Farms BPDP: Comment -Response
Upper New Hope Watershed: Jordan Lake 3 September 2023

8. Insert "and data included in the annual monitoring report."
Response: inserted as requested.
Page 12:
1. There is no Jordan protected buffer here. remove last sentence.
Response: Based on additional discussion in 9/8/2023 meeting, this comment does not apply. Edited this
section to clarify notification requirements for mowing. Recommended that mowing within the riparian
restoration areas to promote planting establishment be deemed an allowable form of maintenance for
the Parcel during the monitoring period.
Page 13:
1 and 2. Remove two instances of "buffer."
Response: Removed as requested.
3. Please add the credit table attachment in Section 7.0 instead of a separate appendix.
Response: added as requested.
4. Generated Credits are no longer needed therefore they do not need to be referenced in the BPDP.
Response: removed Table 9.0 and discussion of Generated Credits as requested.
5. How did you confirm this HUC? what link did you use?
Response: please see source provided above in response for Page 6, Comment 1.
Page 15 - Project Credits Table:
1. For simplicity, since all these streams are subject, you could consolidate all the streams (A, Morgan, C2, 61,
62) into one row for each width category. Remember, the survey has to match this table and your
corresponding figure. The more complicated the table, the more complicated the survey has to be.
Response: Condensed restoration and preservation by width category as requested and broke out
Ephemeral C1 and Nutrient Offset on 61 into separate rows.
2. The grey area on Figure 7 has to be quantified here in a transparent way. This area will also have to be shown
on the as -built survey. Choose "Buffer" for credit type, for Feature Name, label it "Non-credit Area <30' ". Do
not put a ft2 amount in the "Total (Creditable) area" column and check "No" for RBC and NOC.
Response: As discussed in the 9/8/23 meeting, the No Credit area will not be planted other than for
easement visibility, and thus does not need to be included in the Project Credits Table.
3. Can these rows be consolidated like on the other BPDP?
Response: Consolidated as requested.
Bandit Farms BPDP: Comment -Response
Upper New Hope Watershed: Jordan Lake 4 September 2023

4. Make sure you are using the most recent table updated in July 2023, which is found only online here:
https://deg.nc.gov/water-quality/surface-water-protection/401/mitigation/project-credit-table-tem plate-
u pdated-november-2022"
Response: We used the table available as of the BPDP submittal date of June 5, 2023. For this revised
BPDP we have used the most recent table updated in July 2023.
Page 19 - Figure 2:
1. 1 like this. Can you add this to other figures?
Response: Added Maple View Bank Parcel Conservation Easement Area to other figures as requested.
2. Insert "Bank Parcel Conservation" between "View" and "Easement" in the Legend
Response: Revised as requested.
Page 20 — Figure 3:
1. Insert "for Riparian Buffer Credits & Nutrient Offset Credits."
Response: Inserted into title as requested.
2. Insert "Jordan Lake" into Legend.
Response: Inserted as requested.
3. Empty Comment in Legend.
Response: No changes made.
4. There is no reason to list the Lower New Hope service area because this bank site cannot provide credits to
that service area. Remove that boundary.
Response: Removed as requested.
5. Remove "Lower New Hope Service Area" from Legend.
Response: Removed as requested.
Page 24 — Figure 7:
1. It may be more appropriate for the nutrient offset credits to be generated off C1 instead, leaving this area as
Buffer. It's okay as proposed, just may want to reconsider.
Response: RestorEcology would prefer to leave this as -is, which was affirmed by DWR in the 9/8/2023
meeting.
2. It is hard to tell where this easement line is. Please add a callout here and a zoomed in picture of this
easement line. I need to confirm that the easement line includes the other site of the Ephemeral channel, not
the center -line. I also need to see if this is the Greyed out area called out in the legend as "no credit."
Bandit Farms BPDP: Comment -Response
Upper New Hope Watershed: Jordan Lake 5 September 2023

Response: Added zoomed -in view of the upper section of C1 to Figure 7 and changed symbology to red to
make this clear as one of the "No Credit" areas. The proposed easement includes at least 4.5 feet beyond
the left bank Top -of -Bank, and this is based on survey locations. The other three areas of "No Credit"
should now be more visible on the west side of Stream C2 and B2 where preservation is less than 30 feet
from Top -of -Bank. RestorEcology did not think it worthwhile to account for reduced preservation credit
ratios less than 30 feet from Top -of -Bank in these three areas.
3. Change to "Riparian Restoration for RBC."
Response: Revised as requested.
4. Change to "Riparian Preservation for RBC."
Response: Revised as requested.
5. Change to "Riparian Restoration for NOC."
Response: Revised as requested.
6. Change this to read "Proposed Conservation Easement Boundary". Make this change on all figures.
Response: Revised as requested.
7. Change to Riparian Restoration for RBC."
Response: Revised as requested.
8. Where is this area? why is it "no credit"?
Response: see Page 24 Comment 2 and response above.
Page 25, Figure 8:
1. Show the C2 origin point on all Figures.
Response: added to Figures 5, 7, 8, and 9 in addition to Figure 2. The other figures are at a zoomed -out
scale and it did not fit well on those figures.
2. See comments on Figure 7 and change.
Response: matched to Figure 7 as requested.
3. The easement boundary is black and the 100' is dark blue. Change the easement boundary color so that it
doesn't get confused with the 100' boundary. Make this change on all figures.
Response: RestorEcology elected to revise the 100' boundary to be a purple color to differentiate it from
the proposed conservation easement boundary and other colors on the figure. We prefer to keep the
proposed conservation easement boundary color black on Figures 7, 8, and 9.
4 and S. Change "buffer" to "riparian" in legend and map title.
Response: revised as requested.
6. We don't use the term Buffer loosely. It should only be used when describing the Zone 1 and Zone 2 of the
Jordan lake protected riparian buffer, which doesn't apply to this site. All areas adjacent to the streams on this
Bandit Farms BPDP: Comment -Response
Upper New Hope Watershed: Jordan Lake 6 September 2023

site should be referred to as "riparian areas" and not "buffer" areas. Be sure to correct this throughout your
BPDP.
Response: revised as requested throughout the BPDP to the correct usage of "buffer." It is also noted in
the Page 12 Comment 1 Response that the Jordan Lake protected riparian buffer does apply to the Parcel.
Page 26 — Figure 9:
1. See comments on Figure 7 and change.
Response: Revised as requested.
Bandit Farms
Upper New Hope Watershed: Jordan Lake
BPDP: Comment -Response
7 September 2023

BANDIT FARMS
Bank Parcel Development Package
DWR# 2016-0393v4
14-Digit HUC: 03030002060070
Upper New Hope Arm - Jordan Lake
�RESTORECOLOGY
RESTORECOLOGY JORDAN, LLC
Version 2
September 13, 2023

Table of Contents
1.0 Project Introduction.............................................................................................................................................3
1.1 Project Description.................................................................................................................................................. 3
2.0 Mitigation Project Summary....................................................................................................................................... 3
2.1 Project Goals............................................................................................................................................................ 3
2.2 Existing Parcel Conditions..................................................................................................................................... 4
2.3 Site Viability for Riparian Buffer Mitigation and Nutrient Offset................................................................... 5
2.4 Watershed Characterization................................................................................................................................... 6
2.5 Soils............................................................................................................................................................................ 6
2.6 Existing Vegetative Communities......................................................................................................................... 7
2.7 Threatened and Endangered Species.................................................................................................................... 8
2.8 Cultural Resources................................................................................................................................................... 8
2.9 FEMA Floodplain Compliance............................................................................................................................. 8
2.10 Parcel Location, Parcel Constraints, and Access.............................................................................................. 8
2.11 Other Environmental Conditions....................................................................................................................... 9
3.0 Site Protection Instrument.......................................................................................................................................... 9
4.0 Mitigation Work Plan................................................................................................................................................... 9
4.1 Parcel Preparation.................................................................................................................................................... 9
4.2 Riparian Area Restoration Activities..................................................................................................................... 9
4.3 Riparian Area Preservation Activities.................................................................................................................10
4.4 DWR As -Built Evaluation....................................................................................................................................11
5.0 Monitoring and Maintenance Plan..........................................................................................................................11
5.1 Monitoring Protocol..............................................................................................................................................11
5.2 Parcel Maintenance................................................................................................................................................11
5.3 Easement Boundaries............................................................................................................................................12
6.0 Financial Assurance and Long -Term Management..............................................................................................12
6.1 Financial Assurances.............................................................................................................................................12
6.2 Long -Term Management......................................................................................................................................12
7.0 Project Credit Potential.............................................................................................................................................12
7.1 Riparian Buffer Credits.........................................................................................................................................12
7.2 Nutrient Offset Credits.........................................................................................................................................13
8.0 References....................................................................................................................................................................14
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 1 September 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 — Primary Planting List
Table 8.2 — Substitute Planting List
Table 9.0 - Delivery Factors & Credit Conversion Ratio
Table 10.0 - Bandit Farms Project Credit Table
Figures
Figure 1
- Vicinity Map
Figure 2
- Existing Conditions
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
- Riparian Zones Map
Figure 9
- Monitoring Components Map
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 -
EDR Radius Map Report: Executive Summary
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 2 September 2023

1.0 Project Introduction
The Bandit Farms Buffer Mitigation and Nutrient Offset Bank Parcel (the Parcel) is proposed in the Upper
New Hope Arm of Jordan Lake (Upper New Hope). The Parcel (NC Division of Water Resources [DWR]#
2016-0393v4) is being developed under the proposed Mitigation Banking Instrument (MBI) intending to be
made and entered into by RestorEcology Jordan, 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 proposed MBI and applicable State of NC Regulations
(15A NCAC 02B .0295 and §.0703).
The Parcel has received a Stream Determination Letter dated December 7, 2022, and a Site Viability Letter
dated December 9, 2022. After these letters were issued, the Parcel received a new Sponsor in
RestorEcology, and an updated Site Viability Letter was issued April 12, 2023. BPDP Comments from DWR
were received August 29, 2023, and this BPDP has been revised to address the comments.
1.1 Project Description
The Parcel is located south of Dairyland Road in unincorporated Orange County, North Carolina (Lat/Lon
Coordinates: 35°58'30.10"N, 79' 8'45.89"W). Directions to the Parcel are included in Figure 1. The property
containing the Parcel has been a dairy farm for much of its history and is currently being converted to
viticulture. The Parcel is in the Upper New Hope, within the University Lake 14-digit HUC
03030002060070, and Morgan Creek is the named receiving stream on the Parcel.
To develop the Parcel as an Upper New Hope riparian buffer mitigation and nutrient offset bank,
approximately 12.8 acres of cropland will be planted with native hardwood trees to lessen nutrient inputs into
the streams from agricultural activities and provide restored riparian areas. Existing wooded riparian areas
within the Parcel will be preserved, resulting in a total Parcel size of approximately 17.5 acres. Notably, the
Project is expanding on a previous mitigation bank project called Maple View Bank Parcel (DWR# 2016-
0393v1) on the property, shown in Figure 2. Riparian buffer credits, nitrogen nutrient offset credits, and
phosphorus nutrient offset credits will be generated by the Project and sold to permittees in the Upper New
Hope Sub -watershed. 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 and a viable
ephemeral feature by restoring and expanding a hardwood riparian corridor. These improvements will
positively affect Morgan Creek, which flows to University Lake and eventually into the Upper New Hope
Arm of Jordan Lake. 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
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 3 September 2023

Water Quality and Ecology Goals
Objectives
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
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
As of the date of this BPDP, there have not been any land use changes within the riparian areas proposed in
Figure 2 and shown in Appendix A since the updated Site Viability Letter issued April 12, 2023. As depicted
in the historical aerial photographs provided in Appendix B, land use has remained relatively unchanged since
at least 1993. Cropland, hay, and pasture have been the primary agricultural uses outside of the wooded
areas. The property around the Parcel is planned for viticulture associated with a winery being constructed
on the north side of Dairyland Road.
Viable Parcel features and existing riparian area conditions are described as follows (see Figure 2 for feature
references, and photos in Appendix A):
Morgan Creek: Morgan Creek flows west to east across the south side of the Parcel. It is a perennial stream,
with a heavily -wooded, mature forest on the right bank, and variable -width forest on the left bank that ranges
from 25 to 75 feet wide. Outside of the forested area on the left bank is a cropland area that will be restored
via plantings described in Section 4.0.
Stream A: Stream A flows north to south from Dairyland Road and confluences with Morgan Creek. It is
also a perennial stream with a more entrenched appearance than Morgan Creek. The left bank has a mature
wooded riparian area that is generally greater than 100 feet in width. The right bank has a narrow wooded
riparian area ranging from 0 to 25 feet wide, with a cropland area that extends out beyond 200 feet.
Stream B: Stream B is the easternmost tributary on the Parcel. It flows north to south from Dairyland Road
as an intermittent headwater stream (131), and becomes perennial midway down (B2, see Figure 2). From the
Dairyland Road culvert down to below the perennial transition, the existing riparian area is cropland all the
way to the banks. Stream B enters a mature hardwood forest strip, with existing wooded riparian areas
ranging from 25 feet wide on the left bank to more than 100 feet wide on the right bank. Outside the
treeline, the land use is cropland. The south end of Stream B enters the Maple View project on its right bank.
Stream C: Stream C begins as a viable ephemeral channel issuing from a culvert on Dairyland Road (Cl on
Figure 2) and flows south to an intermittent origin (C2 begins). Stream C starts in a cropland area and has no
existing wooded riparian area. It then enters a mature hardwood forest after the intermittent origin. The
existing forested riparian area on the left bank ranges from 10 to 25 feet in width, and out to more than 100
feet on the right bank in this area. Stream C enters the Maple View Bank Parcel conservation easement at the
downstream end of the Parcel.
Table 2.0 below summarizes the Parcel information, credit yield, and project schedule anticipated.
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 4 September 2023

Table 2.0 - Parcel Summary
Project Name
Bandit Farms
14-Di it Hydrologic Unit Code
03030002060070
Jordan Lake Subwatershed
Upper New Hope Arm
Location (Lat/Lon)
35°58'30.10"N, 79° 8'45.89"W
Site Protection Instrument
Conservation Easement to Long -Term Steward at
Closing following BPDP and MBI Approval
BPDP Submittal Date
September 13, 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 Riparian Buffer Mitigation and Nutrient Offset
On December 7, 2022, DWR issued a Determination for Applicability to the Jordan Lake Buffer Rules 15A
NCAC 02B .0267 (Stream Determination Letter, Appendix C) for the Parcel. On December 9, 2022, DWR
issued a Site Viability Letter for the Parcel (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.
On March 16, 2023, DWR received a request from RestorEcology to modify the existing Site Viability letter
issued in 2022 to reflect the updated Parcel layout and Sponsor. On September 21, 2022, DWR had
performed a site assessment of the subject site for the initial Site Viability Letter, therefore, another site visit
was not deemed necessary.
The updated Site Viability Letter was issued April 12, 2023, and DWR's evaluation of the features onsite and
their associated mitigation determination for the riparian areas are detailed in the updated Site Viability Letter
in Appendix D. The following table summarizes the Parcel features and the results of DWR's evaluation:
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 5 September 2023

Table 3.0 - Site Viability Summary
Parcel Feature
Classification
Buffer Mitigation Credit
Viability
Nutrient Offset Credit
Viability
Morgan Creek
Stream
Viable non -forested fields)'
Viable non -forested fields
A
Stream
Viable (non -forested fields)
Viable (non -forested fields)
B1
Stream
Viable2
Viable
B2
Stream
Viable (non -forested fields)
Viable (non -forested fields)
Cl
Ephemeral Feature
Viable2,3
Viable
C2
Stream
Viable non -forested fields
Viable non -forested fields
'Forested areas deemed viable for Riparian Preservation along Morgan Creek, Stream A, B2, and C2, per
15A NCAC 02B .0295(o)(5).
2No credits allowed within NCDOT Right -of -Way
3Ephemeral feature deemed viable as a Restoration Site per 15A NCAC 02B .0295(o)(7).
The riparian restoration of Cl meets the requirements of §(o)(7), in that the entire area proposed for
mitigation is within the contributing drainage area to Cl (see Section 2.4 below). Ephemeral Cl is also directly
connected to C2, an intermittent/perennial stream and is contiguous with the rest of the Parcel protected
under a perpetual conservation easement.
2.4 Watershed Characterization
The Parcel is located within 14-digit HUC 03030002060070: University Lake along Morgan Creek, which
flows directly into the Upper New Hope Arm of Jordan Lake. The surrounding area contains a mixture of
agricultural, residential, and wooded land uses, as depicted in the USGS Topographic Map provided as Figure
4. The watersheds in Figure 5 were delineated using the U.S. Geological Survey (USGS) Streamstats service.
Table 4.0 - Drainage Areas and Land Uses
Feature
Drainage Area (Ac)
Land Uses'
Morgan Creek
176
26% Agricultural
1% Developed
73% Forested
Stream A
372
44% Agricultural
2% Developed
2% Open Water
52% Forested
Stream B
126
70% Agricultural
5% Developed
2% Open Water
23% Forested
Ephemeral Cl
39
14% Developed
86% A icultural
Stream C2
55
86% Agricultural
10% Developed
4% Forested
'Land uses assessed via aerial photography.
2.5 Soils
The Parcel and its stream features are shown in Figure 6 on the Orange County Soil Survey, dated 1977. The
following table describes Parcel soil types and descriptions:
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 6 September 2023

Table 5.0 — Soil Types
Map Unit Name
Description
Ch - Chewacla loam
This nearly level, somewhat poorly drained soil is on long, flat areas parallel
to the major streams on the floodplains. Permeability is moderate and depth
to bedrock is more than 60 inches. The seasonal high water table is 6 to 18
inches during the late winter/early spring. The soil has a very high potential
for broad -leafed trees, with dominant species such as walnut, oaks, and
poplar.
GeB - Georgeville silt
This well drained soil is on broad ridges on the uplands. Permeability is
loam, 2-6% slopes
moderate and depth to bedrock is more than 60 inches. The seasonal high
water table is below 72 inches. The soil has moderately high potential for
broad -leafed trees, with dominant species such as oaks, poplar, and
sweet m.
G1F - Goldston slaty silt
This well -drained soil is on side slopes adjacent to the major drainageways.
loam, 15-45% slopes
Permeability is moderately rapid and depth to bedrock is 20 to 40 inches.
The seasonal high water table is below 72 inches. The soil has a medium
potential for broad -leafed trees, with dominant species such as oaks,
sweet m, and hickory.
HrB - Herndon silt loam,
This well drained soil is on broad ridges on the uplands. Permeability is
2-6% slopes
moderate and depth to bedrock is more than 60 inches. The seasonal high
water table is below 72 inches. The soil has moderately high potential for
broad -leafed trees, with dominant species such as oaks, poplar, and
sweet m.
HrC - Herndon silt loam,
This well drained soil is on narrow side slopes on the uplands. Permeability
6-10% slopes
is moderate and depth to bedrock is more than 60 inches. The seasonal
high water table is below 72 inches. The soil has moderately high potential
for broad -leafed trees, with dominant species such as oaks, poplar, and
sweet m.
TaD - Tatum silt loam, 8-
This well drained soil is on side slopes on the uplands. Permeability is
15% slopes
moderate, and depth to bedrock is 40 to 60 inches. The seasonal high water
table is at a depth of 48 to 72 inches. The soil has moderately high potential
for broad -leafed trees, with dominant species such as oaks, poplar, and
hickory.
TaE - Tatum silt loam, 15-
This well drained soil is on side slopes on the uplands. Permeability is
25% slopes
moderate, and depth to bedrock is 40 to 60 inches. The seasonal high water
table is at a depth of 48 to 72 inches. The soil has moderately high potential
for broad -leafed trees, with dominant species such as poplar, hickory, and
maple.
2.6 Existing Vegetative Communities
Existing vegetation in the Parcel consists of cropland and mature hardwood forest. Typical vegetation
observed in the existing forest is summarized in Table 6.0.
Table 6.0 - Existing Vegetation
Scientific Name
Common Name
Oversto
Liriodendron tuli i era
Tulip poplar'
Li uidambar s raci lua
Sweet '
u lans ni ra
Black walnut'
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 7 September 2023

Scientific Name
Common Name
Fagusgrandi olia
American beech
Paulownia tomentosa
Princess tree
Understory
Lindera ben oin
S icebushl
Celtis laevi ata
Sugarberryl
Cornus orida
Flowering dogwood
Ulmus amencana
American elm
Li ustrum sinense
Chinese privet
Ailanthus altissima
Tree of Heaven
uni eras viiXiniana
Eastern red cedar
Herbaceous
Pol stichum acrostichoides
Christmas fern
Podo h llum peltatum
Mayapple
Lonicera a onica
Japanese honeysuckle
Oxalis violacea
Violet woodsorrel
'Dominant in forest layer.
2.7 Threatened and Endangered Species
RestorEcology initiated regulatory coordination with the U.S. Fish & Wildlife Service (USFWS) via letter and
self -certification on March 21, 2023 (see Appendix E). The Official Species List from (USFWS) contained
three species: Tricolored Bat (Perimyotis subflavus) — Proposed Endangered, Atlantic Pigtoe (Fusconaia mason) —
Threatened, and Monarch Butterfly (Danaus plexippus) — 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 March 21, 2023. The NCNHP Report
identified no element occurrences intersecting with the Parcel, and no listed species occurrences were found
within one mile of the Parcel. As summarized in the Species Conclusion Table and confirmed in USFWS'
response dated April 26, 2023, the Parcel will have No Effect on 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 March 21, 2023. SHPO responded via letter
on April 4, 2023 that SHPO is aware of no historic resources that would be affected by the Parcel (Appendix
E).
2.9 FEMA Floodplain Compliance
As mapped by the Orange County GIS, a portion of the Parcel along Stream A and Morgan Creek is within
the Regulatory Floodway and the 100-year floodplain. A floodplain development permit for the Parcel will be
obtained from the Orange 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 south of Dairyland Road and is accessed via multiple farm paths from the road (See
Figure 2). The Parcel is located outside of the NCDOT 60-foot right-of-way for Dairyland Road.
Dairyland Road has a single -pole electric transmission line along the south side of the road (see Figure 2).
The 20-foot-wide maintenance right-of-way for this line has been excluded from the Parcel. There is an
ingress, egress, regress, and utilities easement granted in 1991 that crosses Morgan Creek on the west side of
the Parcel (see Figure 2) and is excluded. No crossing or access road is currently in place or planned for that
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 8 September 2023

location. The Parcel landowner is planning to install a 40-foot-wide culverted crossing on Stream C2 at the
location depicted in Figure 2. This crossing will be outside of the Parcel.
2.11 Other Environmental Conditions
A Lightbox — Environmental Data Resources (EDR) report was prepared on April 14, 2023. An excerpt
from the EDR Report is provided as 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 only mapped item was an
emergency release record of raw sewage contaminating a water well approximately 0.45 miles west of the
Parcel. This release is not considered likely to affect the Parcel. Environmental conditions that could affect
the Parcel were not identified in the EDR Report.
3.0 Site Protection Instrument
The Parcel will be protected via a perpetual conservation easement based on DWR's latest template available
online. A DWR-approved Long -Term Steward (Steward) will be the Grantee on the easement, such as
Unique Places To Save, a 501(c)3 not -for -profit organization (UP2S). The parcel and landowner information
is summarized in Table 7.0 below:
Table 7.0 — Site Protection Instrument
Landowner
Orange County PIN
Instrument
Register of
Acreage to be
Deeds Reference
Protected
Bandit Farms II, LLC
9850698697
Conservation
To be Recorded
17.5 Acres
Easement
4.0 Mitigation Work Plan
The Parcel will preserve existing hardwood riparian corridors along Morgan Creek and portions of Stream A,
B2, and C2. Native tree and shrub plantings will be used to expand these corridors up to 200 feet from top -
of -bank, as well as establishing new hardwood forest along the upper sections of Stream B2, B1, and C2; and
along Ephemeral C1. Figure 7 depicts the credit -generating areas and project design, and Figure 8 depicts the
riparian zones for the Parcel.
4.1 Parcel Preparation
The Parcel has historically been used for dairy cattle pasture and cropland and is currently planted in an
herbaceous seed mix. Most of the riparian restoration areas will require minimal soil preparation because
they've been maintained in active agriculture. Soil augering was conducted to check for a hardpan layer that
would need ripping and none was identified. Therefore ripping is not prescribed for preparation at the
Parcel.
The planting area will be bushhogged prior to planting to promote seedling establishment. Areas of poor
herbaceous growth will be visually assessed and fertilized prior to planting. 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.
4.2 Riparian Area Restoration Activities
Riparian restoration areas will be restored using native bare -root plantings of trees and shrubs selected from
the following table:
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 9 September 2023

Table 8.1- Primary Planting List:
Species
Common Name
Approximate
Density'
Category
Forest Layer
Betula ni ra
River birch
15%
Tree
Overstory
Liriodendron tuli i era
Tulip poplar
15%
Tree
Overstory
Platanus occidentalis
Americansycamore
15%
Tree
Overstory
Quercus rubra
Northern red oak
15%
Tree
Overstory
Lindera ben , -pin
S icebush
15%
Shrub
Understory
Cornus amomum
Silky dogwood
15%
Shrub
Understory
Cenis canadensis
Redbud
10%
Shrub
Understor
'Density will be determined by the commercially -available species at the time of planting.
Based on commercial availability, substitute species from Table 8.2 may be selected instead of those in Table
8.1. At least 7 of the species listed in Table 8.1 or 8.2 will be planted.
Table 8.2 - Substitute Planting List:
Species
Common Name
Approximate
Density'
Category
Forest Layer
uercus palustfis
Pin oak
15%
Tree
Overstory
Quercus hellos
Willow oak
15%
Tree
Overstory
Populus deltoides
Eastern
cottonwood
15%
Tree
Overstory
Ca a glabra
Pignut hickory
10%
Tree
Overstory
Fagusgrandi olia
American beech
10%
Tree
Overstory
Ulmus americana
American elm
10%
Tree
Overstory
Celtis laevi ata
Su arber
10%
Tree
Understory
Dio ros i4iginiana
Persimmon
10%
Tree
Understory
Ostrya virginiana
Eastern hop
hornbeam
5%
Shrub
Understory
'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 534
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
Riparian Restoration for RBC and Riparian Restoration for NOC on Figure 7. Planting is scheduled for the
2024 planting season (December 2023 - May 2024).
4.3 Riparian Area Preservation Activities
Preservation areas have been visually assessed for invasive species seed sources. Scattered Chinese privet and
Tree -of -heaven was observed but was not dominant in either the overstory or understory. These species will
be spot -treated at a seasonally -appropriate time during the as -built year to minimize spread to riparian
restoration areas.
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 10 September 2023

4.4 DWR As -Built Evaluation
Within 30 calendar days after completing the establishment of the riparian restoration and riparian
preservation 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 riparian restoration areas to
measure the survival of planted trees and shrubs. The plots will be randomly placed throughout the planted
areas. A total of 11 plots will be randomly placed such that the plots are representative of the riparian buffer
credit and nutrient offset credit areas (Figure 9) and at least 2% of the planted riparian restoration area is
monitored. 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 11 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, vigor, and
survival rates will be evaluated on an annual basis by plot and data included in the annual monitoring report.
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 riparian 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 inside the riparian preservation areas within Zone 1 and Zone 2 of the Jordan Water Supply buffers
is deemed necessary by the Sponsor during the monitoring period, the Sponsor must notify DWR prior to
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 11 September 2023

conducting mowing activities to ensure that no buffer violations occur. Mowing inside the riparian
restoration areas during the Parcel monitoring period to promote planting establishment is deemed allowable
maintenance for the purposes of this BPDP.
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. To
minimize encroachment, trees and/or shrubs will be planted along the eastern boundary of the easement at
Ephemeral C1 depicted on Figure 7 as "No Credit." Horse tape or a similar marking tool will also be tied
between the easement markers in this area to promote boundary visibility.
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
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
Orange County Register of Deeds. 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 Table 10.0.
Riparian 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 preservation on the Parcel can
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 12 September 2023

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. 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.
As required under the Jordan Trading Rule 15A NCAC 02B .0703 (the Jordan Trading Rule), the Sponsor
must account for differences in in -stream nutrient losses between the location of the reduction need and
excess loading reduction being delivered to the affected area of Jordan Lake. DWR provided the delivered
Jordan Lake Total Nitrogen (TN) and Jordan Lake Total Phosphorus (TP) credit yields per acre of riparian
restoration for the University Lake 14-digit HUC in the Clarified Procedures Letter, as summarized in Table
9.0.
Table 9.0 — Delivery Factors & Credit Conversion Ratio
Bank Parcel
TN
TP
Bandit Farms — 14-Digit HUC
03030002060070
Delivery Factor: 40%
Ratio: 50.20146 ft2/lb
Delivery Factor: 19%
Ratio: 1,594.20874 ft2/lb
Delivered TN and TP credits were calculated by dividing the square footage of riparian restoration by the
Credit Conversion Ratio from Table 9.0. The amount of delivered credits is calculated in the Project Credit
Table Template provided as Table 10.0.
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 13 September 2023

Table 10.0: Bandit Farms Buffer and Nutrient Offset Bank [#i2016-0393v4], Project Credits
Cape Fear - Jordan Upper New Hope 03030002060070
Project Area
N Credit Conversion Ratio (ft2/pound)
P Credit Conversion Ratio (ft2/pound)
50.20146
1594.20874
Credit Type
Location
Subject? (enter
NO if
ephemeral or
ditch')
Feature Type
Mitigation Activity
Min -Max Buffer
Width (ft)
Feature Name
i
Total Area (ft)
Total (Creditable)
Area of Buffer
Mitigation (fti)
Initial Credit
Ratio (x:1)
%Full Credit
Final Credit
Ratio (x:l)
Convertible to
Riparian
Buffer?
Riparian Buffer
Credits
Convertible to
Nutrient Offset?
Delivered
Nutrient Offset:
N (Ibs)
Delivered
Nutrient
Offset: P (Ibs)
Buffer
Rural
Yes
I / P
Restoration
0-100
A, Bl, B2, C2, Morgan
Creek
393,705
393,705
1
100%
1.00000
Yes
393,705.000
No
—
—
Buffer
Rural
Yes
I / P
Restoration
101-200
A, B1, B2, C2, Morgan
Creek
69,834
69,834
1
33%
3.03030
Yes
23,045.243
Yes
1,391.075
43.805
Buffer
Rural
No
Ephemeral
Restoration
0-100
Ephemeral C1
80,134
80,134
1
100%
1.00000
Yes
80,134.000
No
—
—
Buffer
Rural
No
Ephemeral
Restoration
101-200
Ephemeral C3
5,603
5,603
1
33%
3.03030
Yes
1,848.992
No
—
—
Nutrient Offset
Rural
Yes
I/ P
Restoration
0-100
B1
9,059
9,059
1
100%
1.00000
Yes
9,059.000
Yes
180.453
5.682
Totals (ft2):
Total Buffer (ft2):
Total Nutrient Offset (ft2):
558,335
558,335
507,792.235 1,571.528 49.487
549,277
549,277
9,059
N/A
Total Ephemeral Area (ft) for Credit
Total Eligible Ephemeral Area (ft)
Enter Preservation Credits Below
Credit Type Location Subject? Feature Type Mitigation Activity Min -Max BufferWidth (ft) Feature Name
Rural I Yes I I / P
TOTAL AREA OF BUFFER MITIGATION (TABM)
Mitigation Totals
Square Feet
Credits
Restoration:
549,277
498,733.235
Enhancement:
0
0.000
Preservation:
163,524
16,352.400
Total Riparian Buffer:
712,801
515,085.635
TOTAL NUTRIENT OFFSET MITIGATION
Mitigation Totals
I Square Feet
Credits
Nutrient Offset:
Nitrogen:
9,059
180AS3
Phosphorus:
5.682
0-100 1 A, B2, C2, Morgan Creel
Preservation Area Subtotals (ft)
1. The Randleman Lake buffer rules allow some ditches to be classified as subject according to 15A NCAC 02B .0250 (5)(a).
85,737
85,737
178,200
12.0%
183,092
22.3%
Total Area (sf)
Total (Creditable)
Area for Buffer
Mitigation (ft')
166,625
163,524
166,625
163,524
Ephemeral Reaches as %TABM
'reservation as %TABM
Initial Credit Final Credit Riparian
Ratio (x:l) %Full Credit Ratio (x:l) I Buffer Credits
10 1 100% 1 10.00000
last updated 07/06/2023

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.bio.unc.edu/protocol/cvs-eep-protocol-v4.2-lev1-5.pdf
North Carolina Department of Environmental Quality (NCDEQ), 2009. 15A NCAC 02B .0273. Jordan
Water Supply Nutrient Strategy: Options for Offsetting Nutrient Loads.
http: / /reports.oah. state.nc.us /ncac /title%2015a%20-%20environmental%20quality/chapter%2002%20-
%20environmental%20management/ subchapter%20b / 15a%20ncac%2002b%20.0273.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
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
United States Department of Agriculture (USDA), 1977. Natural Resources Conservation Service, Soil Survey
for Orange County, North Carolina. https://websoilsurvey.sc.egov.usda.gov/
U.S. Geological Survey, 2019. The StreamStats program, online at https://streamstats.usgs.gov/ss/, accessed
on May 20, 2023.
Orange County, NC GIS, 2023. Accessed online at
https://gis.orangecountync.gov/orangeNCGIS/default.httn on May 31, 2023.
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake 14 September 2023

FIGURES
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake September 2023

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_ 18-Digit HUC Boundaries Figure 3: Service Area for Riparian Buffer
Jordan Lake Upper New Credits and Nutrient Offset Credits N
Hope Service Area A
RESTORECOLOGY 20,23 ° 10 3Miles
Km
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US 0 3 6

' r
k
dc
*A- -4. Z
National-Geographi-"cubed
Proposed Conservation Parcel: Bandit Farms N
Easement Boundary
Maple View Bank Parcel Figure 4: USGS Topographic Map
Conservation Easement
RESTORECOLOGY 2023 0 0.1 o.Mi
-t
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US o 0.23 0.45 m

Syr 1i�
f•
Proposed Conservation Easement
Boundary
0 Stream Origins Parcel: Bandit Farms
Ephemeral Cl (39 AC)
Figure 5: Watershed Map
Stream A (372 AC)
Stream B (126 AC)
Stream C2 (SS AC) 2'023 0Morgan Creek(176AC) RESTOR0.2 04
�I.
E Maple View Bank Parcel ECOLOGY
Conservation Easement KM
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US 0 0.3 0.6

17,
—r c
TEE
ITa 41
Goa
L
IIr
�1sS y a wlr� J Mr@
M — -
lau
'r'4
H r H t IIr:B ■■■
. 1 1 1 •,J
1403
�
Dods*
rkl4i�Q{� la
L�'.� ;. � � � dal: '�' � r•—r .' _.
y
LS
HrB .
Dk3 Tarp
i
GI-H
-r - n
18a
t
Td«'
r :r• R
L'rl r3
t IOT roject ATLAS EEIo 4,N�rnrion
and Analysis, NC11 Boa d
1
Legend
Parcel: Bandit Farms
N
Proposed Conservation
Easement Boundary
Figure 6: Soils Map
Maple View Bank Parcel
Conservation Easement
" r'.i o:K
RESTORECOLOGY
2023
:jNENK=
@MENEM=
0 0.23 0.45 m
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US

�1' A'
A� i
Legend
Top of Bank Credit Areas Riparian Restoration for
Treeline NOC (0-100')
Riparian Preservation
O Stream Origins for RBC (0-100') - No Credit <30' from
TOB
Proposed Conservation Riparian Restoration for
Easement Boundary RBC (0-100') Maple View Bank Parcel
Conservation Easement
Riparian Restoration for
L—� RBC (101-200')
F. R
Al
F }
�A
O / i
Parcel: Bandit Farms
Figure 7: Credit Areas
am B1
Stream 02,
1
N
RESTOR
ECOLOGY
0 100 200 400
Feet

APPENDICES
Bandit Farms BPDP
Upper New Hope Watershed: Jordan Lake September 2023

Appendix A: Bandit Farms Photolog
Photo 1: Morgan Creek, 4/19/2023
Photo 3: Morgan Creek, Buffer Restoration Area
4/19/2023
Photo 2: Morgan Creek Preservation Area, 4/19/2023
Photo 4: Stream A, 2/17/2023
Bandit Farms BPDP: Appendix A
Upper New Hope Watershed: Jordan Lake 1 June 2023

Photo 5: Stream A Preservation Area
4/19/2023
Photo 7: Stream B1, 2/17/2023
Photo 6: Stream A, Buffer Restoration Area, 4/19/2023
Photo 8: Stream B2, 4/19/2023
Bandit Farms BPDP: Appendix A
Upper New Hope Watershed: Jordan Lake 2 June 2023

Photo 9: Stream B1, Buffer Restoration
Area on Left Bank, 4/19/2023
Photo 11: Stream B2, Buffer Restoration Area on Left
Bank, 4/19/2023
Photo 10: Stream B1, Buffer Restoration
Area on Right Bank, 4/19/2023
Photo 12: Stream B2, Buffer Restoration Area on
Right Bank, 4/19/2023
Bandit Farms BPDP: Appendix A
Upper New Hope Watershed: Jordan Lake 3 June 2023

Photo 13: Stream B2, Buffer Preservation Area,
4/19/2023
Photo 15: Ephemeral C1, Buffer Restoration Area on
Left Bank, 4/19/2023
Photo 14: Ephemeral C1, 2/17/2023
Photo 16: Ephemeral C1, Buffer Restoration Area on
Right Bank, 4/19/2023
Bandit Farms BPDP: Appendix A
Upper New Hope Watershed: Jordan Lake 4 June 2023

Photo 17: Stream C2, 2/17/2023
Photo 19: Stream C2 Buffer Preservation Area,
4/19/2023
Photo 18: Stream C2 Buffer Restoration Area,
4/19/2023
Bandit Farms BPDP: Appendix A
Upper New Hope Watershed: Jordan Lake 5 June 2023

J j }� 1
r + 1
AC
I�
I,
44
JAL
Parcels Parcel: Bandit Farms
0 Bandit Farms
Appendix B: 1993 Aerial
( ) RESTORECOLOGY 2'023
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
A.
N
0 250 500
Feet
Km
0 0.07 0.15

0 Parcels
Bandit Farms
v
t�'i ► f' ��� • T t.
f
• �= 41?�
� Y J
}
i
s
Si.sr - - 1.i. .
Parcel: Bandit Farms
Appendix B: 1998 Aerial
( ) RESTOR ECOLOGY 2023
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
V
.,_
N
0 250 500
Feet
Km
0 0.07 0.15

R3�,i r " +
1
,y [
0 Parcels Parcel: Bandit Farms N
Bandit Farms
Appendix B: 2010 Aerial
RESTORECOLOGY 2023 0 =n soFeet
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US 0 0.07 0.15m

DocuSign Envelope ID: E72666F9-329F-44EE-8C04-7764037F7AB0
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Jamey McEachran
Environmental Banc & Exchange, LLC
[e-mail]
WORTH CAROLINA
Environmental Quality
December 7, 2022
Project 2016-0393v2
Orange County
Subject: Determination for Applicability to the Jordan Lake Buffer Rules 15A NCAC 02B .0267
Project Name: Bandit Farms Mitigation Site
Address: 3111 Dairyland Road, Hillsborough, NC
Dear Ms McEachran:
On September 21, 2022, Katie Merritt of the Division of Water Resources (DWR), conducted an
on -site review of features located near or at the address above at the request of Environmental
Banc & Exchange, LLC, to determine the applicability of features on the site to the Jordan Lake
Riparian Area Protection Rules, Title 15A North Carolina Administrative Code 02B .0267.
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 Jordan Lake Riparian Area Protection Rules. Streams that are considered
"Subject" have been located on the most recently published NRCS Soil Survey of Orange 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 easement 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 that
appear 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.
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH MofErNA 919.707.9000
oeparimem of Fmironmentni wai�

DocuSign Envelope ID: E72666F9-329F-44EE-8C04-7764037F7AB0
Page 2 of 3
3111 Dairyl and Road
DWR 20160393v2
The following table addresses the features observed and rated during the DWR site visit.
'Feature Type:
stream
Subject
Depicted
Depicted
(ephemeral,
intermittent,
to
Start @
Stop @
on
on
ID
perennial), ditch,
Buffer
Soil
USGS
swale, wetland,
Rules
Survey
Topo
other
A
Perennial
Yes
At road
Property
Y
Y
culvert
boundary
2At road
35.977034, -
B1
Intermittent
Yes
culvert
79.144308
Y
Y
B2
Perennial
Yes
35.977034,
Confluence
Y
Y
-79.144308
of A
2At road
35.975390, -
C1
Ephemeral
No
culvert
79.146393
Y
C2
Perennial
Yes
35.975390,
Confluence
Y
-79.146393
of A
1 E: Ephemeral, I: Intermittent, P: Perennial
2 Large amounts of sediment from adjacent agricultural practices have deposited into portions of this reach
affecting upstream flows through this reach that need to be remediated
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.
If sending via U.S. Postal Service:
DWR 401 & Buffer Permitting Branch
Supervisor
1617 Mail Service Center
Raleigh, NC 27699-1617
If sending via delivery service (UPS, FedEx, etc.)
DWR 401 & Buffer Permitting Branch
Supervisor
512 N Salisbury St.
Raleigh, 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 Katie
Merritt at [e-mail] or 919-500-0683. This determination is subject to review
as provided in G.S. 150B.

DocuSign Envelope ID: E72666F9-329F-44EE-8C04-7764037F7AB0
Page 3 of 3
3111 Dairyl and Road
DWR 20160393v2
Sincerely,
EpDocuSigned by:
l/titst Daa�iY
9969F633EA974A6...
Erin Davis, Acting Supervisor
401 & Buffer Permitting Branch
Attachments: Site Map with labels, NRCS Soil Survey, USGS Topographical Map, Lidar
cc: 401 & Buffer Permitting Branch Laserfiche File
Filename: 20160393v2 BanditFarms Ltr

a
f
1
7
YWAY/
I
1
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oa'
'a
1 1
9 B2 origin
35.977034,-79.144308
o�ry n C2 origin
35.975390,-79.146393 0
q
AIL
i
Ra

DocuSign Envelope ID: E72666F9-329F-44EE-8C04-7764037F7AB0
Lee end
rProposed Easement
Maple View Conservation Easement W
" Figure 2b - USGS National Map Date: 9ns/zozz
g White Cross
j W E Ores
Bandit Farms Drawn by: HG
9 o soo ,,000 Mitigation Project Checked by: RM
8
a 1 inch = 1,000 feet Restoring o Resilient Earth for a Modern World
Fast Orancie Countv, North Carolina

DocuSian Envelope ID: E72666F9-329F-44EE-8C04-7764037F7AB0

DocuSign Envelope ID: E72666F9-329F-44EE-8C04-7764037F7AB0
As
7'
Ir
A
-A
A,
A",
05,51111 11!11�1� Pr.
4wr
V
Legend
04
-7,
IA
Proposed Easement
Value
High 756.509 ft
Low: 507.151 ft
2' Contour
w EFigure 6 - UDAR Date: 9/15/2022
NOAA, 2022
Ores
Bandit Farms Drawn by: GDS
s Mitigation Project Checked by: RM
5 0 250 500 1
1 inch = 500 feet
I Restoring a Resilient Earth for a Modem World
Orange County, North Carolina I I s FeetI

DocuSign Envelope ID:4E492781-536B-43BF-B21F-OE306A45FA44
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Jamey Mceachran
Environmental Banc & Exchange, LLC
(via electronic mail: jmceachran(cr�,res.us )
NORTH CAROLINA
£nvironmentat Quality
December 9, 2022
Re: Site Viability for Buffer Mitigation & Nutrient Offset — Bandit Farms Site
Near 3111 Dairyland Road in Hillsborough, NC
Upper New Hope Sub -watershed of Jordan Lake
Orange County
Dear Ms. Mceachran,
On September 20, 2022, Katie Merritt, with the Division of Water Resources (DWR), received a
request from you on behalf of Environmental Banc & Exchange, LLC (EBX) for a site visit near the
above -referenced site in the Upper New Hope Sub -watershed of Jordan Lake. The site visit was to
determine the potential for riparian buffer mitigation and nutrient offset within a proposed
conservation easement boundary, which is more accurately depicted in the attached map labeled
"Figure 1 - Bandit Farms Mitigation Project" (Figure 1) prepared by EBX and edited by DWR. The
proposed easement boundary in Figure 1, includes all riparian areas intended to be proposed as part
of the mitigation site. On September 21, 2022, Ms. Merritt performed a site assessment of the
subject site. Staff with EBX were also present.
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
(effective November 1, 2015) and for nutrient offset credits pursuant to 15A NCAC 02B .0703 using
15A NCAC 02B .0295 to define the mitigation type determinations. The following table includes
details regarding the potential of the site to generate buffer mitigation and/or nutrient offsets.
Feature
Classification
onsite
'Subject
Riparian Land uses
adjacent to Feature
Buffer
Credit
3Nutrient
Offset
','Mitigation Type Determination w/in
to
riparian areas
Buffer
0( 200')
Viable
Viable
Rule
A
Stream
Yes
Combination of forested
2yeS
Yes (non-
Non -forested fields - Restoration Site
and non -forested areas.
forested
per 15A NCAC 02B .0295 (n)
Non -forested areas are in
fields only)
active agriculture
Forested areas — Preservation Site per
15A NCAC 02B .0295 (o)(5)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH Mof Er NA 919.707.9000
oeparimem of Fmironmentni wai�

DocuSign Envelope ID:4E492781-536B-43BF-B21F-OE306A45FA44
Bandit Farms Site
EBX
December 9, 2022
Feature
Classification
'Subiect
Riparian Land uses
Buffer
'Nutrient
','Mitigation Type Determination w/in
onsite
to
riparian areas
adiacent to Feature
Credit
Offset
Buffer
0( 200')
Viable
Viable
Rule
B 1
Stream
Yes
Non -forested agricultural
Yes
Yes
Restoration Site per 15A NCAC 02B
fields
.0295 (n)
Partially located in DOT
No credits are allowed within the DOT
R.O.W
R.O.W.
B2
Stream
Yes
Combination of forested
2Yes
Yes (non-
Non -forested fields - Restoration Site
and non -forested areas.
forested
per 15A NCAC 02B .0295 (n)
Non -forested areas are in
fields only)
active agriculture
Forested areas — Preservation Site per
15A NCAC 02B .0295 (o)(5)
C 1
Ephemeral
No
Non -forested agricultural
'Yes
Yes
Restoration Site per 15A NCAC 02B
fields
.0295 (o)(7)
Partially located in DOT
No credits are allowed within the DOT
R.O.W
R.O.W.
C2
Stream
Yes
Combination of forested
2Yes
Yes (non-
Non -forested fields - Restoration Site
and non -forested areas.
forested
per 15A NCAC 02B .0295 (n)
Non -forested areas are in
fields only)
active agriculture
Forested areas — Preservation Site per
15A NCAC 02B .0295 (o)(5)
'Subjectivity calls for the features were determined by DWR in correspondence dated December 7, 2022 (DWR# 2016-0393v2) 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 .
2The 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. Credits are calculated differently in the Jordan Lake Watershed. Phosphorus may be calculated separately.
'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. Easement breaks that disconnect the continuity of riparian restoration/enhancement/preservation result in no credit viable beyond
the break.
'The 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 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.
Determinations provided in the table above were made using a proposed easement boundary showing
proposed mitigation areas shown in Figure 1. The map representing the proposal for the site is
attached to this letter and initialed by Ms. Merritt on December 9, 2022. Substantial changes to the
proposed easement boundary as well as any site constraints identified in this letter, 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.
Page 2 of 3

DocuSign Envelope ID:4E492781-536B-43BF-B21F-OE306A45FA44
Bandit Farms Site
EBX
December 9, 2022
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 December 9, 2024 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 [phone] if you have any questions regarding this
correspondence.
Sincerely,
ED/kym
Attachments: Figure 1: Site Map
cc: File Copy (Katie Merritt)
DOCUSigned by:
9969F633EA974AB...
Erin Davis, Acting Supervisor
401 and Buffer Permitting Branch
Page 3 of 3

DocuSian Envelope ID: 4E492781-536B-43BF-B21F-OE306A45FA44

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
April 12, 2023
Daniel Ramsay
RestorEcology Jordan, LLC
(via electronic mail: dramsay_krestorecology.com )
DWR Project ID#: 2016-0393
Re: Site Viability for Buffer Mitigation & Nutrient Offset — Bandit Farms Site
Near 3111 Dairyland Road in Hillsborough, NC
Upper New Hope Sub -watershed of Jordan Lake
Orange County
Dear Mr. Ramsey,
On December 9, 2022, the Division of Water Resources (DWR) issued a Site Viability letter for the
above referenced site called Bandit Farms, which is in the Upper New Hope Sub -watershed of Jordan
Lake. On March 16, 2023, DWR received a request from RestorEcology to modify the existing Site
Viability letter issued in 2022 to reflect a different conservation easement boundary, which is more
accurately depicted in the attached map labeled "Figure 1 - Bandit Farms modification" (Figure 1)
prepared by RestorEcology and edited by DWR. The proposed easement boundary in Figure 1
includes all riparian areas intended to be proposed as part of the mitigation site. On September 21,
2022, Ms. Merritt performed a site assessment of the subject site for the initial Site Viability letter,
therefore, another site visit was not deemed necessary.
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
(effective November 1, 2015) and for nutrient offset credits pursuant to 15A NCAC 02B .0703 using
15A NCAC 02B .0295 to define the mitigation type determinations. The following table includes
details regarding the potential of the site to generate buffer mitigation and/or nutrient offsets.
Feature
Classification
'Subject
Riparian Land uses
Buffer
3Nutrient
','Mitigation Type Determination w/in
onsite
to
adjacent to Feature
Credit
Offset
riparian areas
Buffer
0( 200')
Viable
Viable at
Rule
2,249.36
lbs-N/acre
A
Stream
Yes
Combination of forested
2Yes
Yes (non-
Non -forested fields - Restoration Site
and non -forested areas.
forested
per 15A NCAC 02B .0295 (n)
Non -forested areas are in
fields only)
active agriculture
Forested areas — Preservation Site per
15A NCAC 02B .0295 (o)(5)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH Mof Er NA 919.707.9000
oeparimem of Fmironmentni wai�

Bandit Farms Site
RestorEcology
April 12, 2023
Feature
Classification
'Subiect
Riparian Land uses
Buffer
'Nutrient
','Mitigation Type Determination w/in
onsite
to
riparian areas
adiacent to Feature
Credit
Offset
Buffer
0( 200')
Viable
Rule
Reach B 1
Stream
Yes
Non -forested agricultural
Yes
Yes
Restoration Site per 15A NCAC 02B
fields
.0295 (n)
Partially located in DOT
No credits are allowed within the DOT
R.O.W
R.O.W.
Reach B2
Stream
Yes
Combination of forested
2Yes
Yes (non-
Non -forested fields - Restoration Site
and non -forested areas.
forested
per 15A NCAC 02B .0295 (n)
Non -forested areas are in
fields only)
active agriculture
Forested areas — Preservation Site per
15A NCAC 02B .0295 (o)(5)
C 1
Ephemeral
No
Non -forested agricultural
'Yes
Yes
Restoration Site per 15A NCAC 02B
fields
.0295 (o)(7)
Partially located in DOT
No credits are allowed within the DOT
R.O.W
R.O.W.
C2
Stream
Yes
Combination of forested
2Yes
Yes (non-
Non -forested fields - Restoration Site
and non -forested areas.
forested
per 15A NCAC 02B .0295 (n)
Non -forested areas are in
fields only)
active agriculture
Forested areas — Preservation Site per
15A NCAC 02B .0295 (o)(5)
Morgan
Stream
Yes
Combination of forested
2Yes
Yes (non-
Non -forested fields - Restoration Site
Creek
and non -forested areas.
forested
per 15A NCAC 02B .0295 (n)
Non -forested areas are in
fields only)
active agriculture
Forested areas — Preservation Site per
15A NCAC 02B .0295 (o)(5)
'Subjectivity calls for the features were determined by DWR in correspondence dated December 7, 2022 (DWR# 2016-0393v2) 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 .
'The 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. Credits are calculated differently in the Jordan Lake Watershed. Phosphorus may be calculated separately.
'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. Easement breaks that disconnect the continuity of riparian restoration/enhancement/preservation result in no credit viable beyond
the break.
'The 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 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.
Determinations provided in the table above were made using a proposed easement boundary showing
proposed mitigation areas shown in Figure 1. The map representing the proposal for the site is
attached to this letter and initialed by Ms. Merritt on April 12, 2023. Substantial changes to the
proposed easement boundary as well as any site constraints identified in this letter, 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
Page 2 of 3

Bandit Farms Site
RestorEcology
April 12, 2023
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 December 9, 2024 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 [phone] if you have any questions regarding this
correspondence.
Sincerely,
Attachments: Figure 1
cc: File Copy (Katie Merritt)
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Katie Merritt
401 and Buffer Permitting Branch
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RESTORECOLOGY
From: Daniel Ramsay
RestorEcology Jordan, 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
March 21, 2023
Re: Online Project Review Request, Bandit Farms Buffer and Nutrient Offset Bank Project, Orange
County, North Carolina, NC Division of Water Resources (DWR) 42016-0393
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 March 21, 2023 and are submitting our project review package in
accordance with the instructions for further review.
Our proposed action consists of: approximately 18.2 acres of cropland and pasture 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. Notably, the Project is expanding on a previous mitigation bank project
called Maple View on the property, shown in the attached figure. 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 Upper New Hope watershed of Jordan Lake. 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°58'30.10"N, 79' 8'45.89"W in the Upper New Hope watershed of
Jordan Lake (HUC 03030002). 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,
Daniel Ramsay, PWS
Owner, RestorEcology
Enclosures:
1) ENTIRE PROJECT REVIEW PACKAGE
2) Other relevant project data/documents

F_OJ7OFTy�2a 7&1& H • E
N United States Department of the Interior
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Raleigh Field Office
P.O. Box 33726
Raleigh, NC 27636-3726
Date:
March 21, 2023
Self -Certification Letter
ProjectNameBandit Farms
Dear Applicant:
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
❑ "may affect, likely to adversely affect" determination for the Northern long-
eared bat (Myotis septentrionalis) and relying on the findings of the January 5,
2016, Programmatic Biological Opinion for the Final 4(d) Rule on the
Northern long-eared bat;
❑✓ "no Eagle Act permit required" determinations for eagles.

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

Species Conclusions Table
Project Name: Bandit Farms Buffer and Nutrient Offset Bank Project
Date: 3/21 /2023
Species / Resource Name
Conclusion
ESA Section 7 / Eagle Act Determination
Notes / Documentation
No effect
Tricolored Bat
Suitable roosting habitat
Cave habitat not present, tree removal
Perimyofis subflavus
present — large
not proposed. No NCNHP element
hardwood trees, no
occurrences present in the project
current survey conducted
vicinity one -mile radius).
Atlantic Pigtoe
No suitable habitat
No effect
Project streams are either intermittent
Fusconaia masoni
present, critical habitat not
or degraded by agricultural and
present
residential runoff; unlikely to support
Atlantic Pigtoe. No NCNHP element
occurrences present in the project
vicinity. No mussel species observed
in site visit conducted 2/10/2023.
Project area streams will be protected
with a permanent conservation
easement.
No effect
Project activities entail tree planting
Monarch Butterfly
Suitable habitat present
and a permanent conservation
Danaus plexippus
along pasture edge, no
easement along streams in pasture,
current survey conducted
cultivated fields, and woodland. These
activities are deemed to have a net
beneficial effect, if any. No NCNHP
element occurrences present in the
project vicinity.
Bald Eagle
Unlikely to disturb
No Eagle Act Permit Required
Not within 660 feet of large bodies of
nesting bald eagles
water. No NCNHP element
occurrences present in the project
vicinity.
Critical Habitat
No critical habitat present
Acknowledgement: I agree that the above information about my proposed project is true. I used all of the provided resources to make an
informed decision about impacts in the immediate and surrounding areas.
&J, � March 21, 2023
Signature /Title: Daniel Ramsay, Owner, RestorEcology Jordan, LLC Date

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United States Department of the Interior
FISH AND WILDLIFE SERVICE
03�/ Raleigh Ecological Services Field Office
Post Office Box 33726
Raleigh, NC 27636-3726
Phone: [phone] Fax: [phone]
In Reply Refer To:
Project Code: 2023-0058056
Project Name: Bandit Farms Buffer and Nutrient Offset Bank Project
March 21, 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

03/21/2023
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.govibirds/policies-and-regulations/
executive-orders/e0-13186.php.

03/21/2023
3
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

03/21/2023
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]

03/21/2023
PROJECT SUMMARY
Project Code: 2023-0058056
Project Name: Bandit Farms Buffer and Nutrient Offset Bank Project
Project Type: Restoration / Enhancement - Agricultural
Project Description: Riparian buffer and nutrient offset restoration project involving tree
planting of cultivated fields to reduce nutrient inputs into streams.
Project Location:
The approximate location of the project can be viewed in Google Maps: https://
www.google.com/maps/(a)35.97552565,-79.14634452139805,14z
Counties: Orange County, North Carolina

03/21/2023 3
ENDANGERED SPECIES ACT SPECIES
There is a total of 3 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
Fisheries1, 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.
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 STATUS
Tricolored Bat Perimyotis sub flavus Proposed
No critical habitat has been designated for this species. Endangered
Species profile: httpss://ecos.fws.gov/ecp/species/10515
CLAMS
NAME STATUS
Atlantic Pigtoe Fusconaia masoni Threatened
There is final critical habitat for this species. Your location does not overlap the critical habitat.
Species profile: https:Hecos.fws.gov/ecp/species/5164
INSECTS
NAME
Monarch Butterfly Danaus plexippus
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/9743
STATUS
Candidate
CRITICAL HABITATS
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S
JURISDICTION.

03/21/2023
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 Treaty Act 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.
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.
Eastern Whip -poor -will Antrostomus voci ferns Breeds May 1
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA to Aug 20
and Alaska.

03/21/2023
2
NAME
BREEDING
SEASON
Kentucky Warbler Oporornis formosus
Breeds Apr 20
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
t0 Aug 20
and Alaska.
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
Breeds Apr 1 to
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
Jul 31
and Alaska.
Red-headed Woodpecker Melanerpes erythrocephalus
Breeds May 10
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
to Sep 10
and Alaska.
Rusty Blackbird Euphagus carolinus Breeds
This is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions elsewhere
(BCRs) in the continental USA
Wood Thrush Hylocichla mustelina Breeds May 10
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA to Aug 31
and Alaska.
PROBABILITY OF PRESENCE SUMMARY
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.

03/21/2023
3
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.
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.
probability of presence breeding season I survey effort — no data
SPECIES JA1N1 I FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Bald Eagle ++++ I I iiii iiii Wi iiii ■ik ++++ Iil111N 1111 Jill
Non -BCC
Vulnerable
Chimney Swift +11+
BCC Rangewide ++1 Al 1+1� I I I I 1141 Jill11111111 Nis+ ++++ ++++
(CON)
Eastern Whip -Poor- ++++ ++++ TTT+ ++11 IL
++++ ++++ ++++
will �i�� ��i�BCC Rangewide --�
(CON)
Kentucky Warbler ++++
BCC Rangewide ++++ ++++ ++L+ TTTT Jill Jill III+ ++++ ++++ ++++ ++++
(CON)

03/21/2023 4
Prairie Warbler BCC Rangewide ++ I I I I I I I I I + *0 IN oil+'�" ,++* „++ ++++ ++++ ++++
(CON) yy
Prothonotary
Warbler ++++ ++++ ++++ ++++ T+++ T��� "" ++++ +,++ ++++ ++++ ++++
BCC Rangewide
(CON)
Red-headed ++++
Woodpecker I I I I � 1010 **** **i+ HE 57i mill ++I$ ++l+ +110
BCC Rangewide
(CON)
Rusty Blackbird ++++ ++++ ++++ +*++ ++++ ++++ ++++ ++++ ++++ ++++ +*++ ++++
BCC -BCR
Wood Thrush BCC Rangewide ++++ ++++ ++++ +'" 0111 UV 11*1 +++1 +W 1+++ ++++ ++++
(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/librarT�/
collections/avoidine-and-minimizinp--incidental-take-miV-ratorv-birds
■ Nationwide conservation measures for birds https://www.fws.gov/sites/default/files/
documents/nationwide-standard-conservation-measures.pdf
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

03/21/2023
5
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?
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.

03/21/2023
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.
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.

03/21/2023
IPAC USER CONTACT INFORMATION
Agency:
RestorEcology Jordan, LLC
Name:
Daniel Ramsay
Address:
150 Wrenn Drive #5842
City:
Cary
State:
NC
Zip:
27512
Email
[e-mail]
Phone:
9198177378

Roy Cooper, Governor
0■ ■■IF NC DEPARTMENT OF
■ !
■■k�■A NATURAL AND CULTURAL RESOURCES
■ ■■■
March 21, 2023
Daniel Ramsay
RestorEcology, LLC
150 Wrenn Dr. #5842
Cary, NC 27512
RE: Bandit Farms Buffer and Nutrient Offset Project
Dear Daniel Ramsay:
D. Reid Wilson, Secretary
Misty Buchanan
Deputy Director, Natural Heritage Program
NCNHDE-21334
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
A query of the NCNHP database indicates that there are records for rare species, important natural
communities, natural areas, and/or conservation/managed areas within the proposed project
boundary. These results are presented in the attached `Documented Occurrences' tables and map.
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 documented within the project area or 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:
https://www.fws.gov/offices/Di rectory_/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.
Also please note that 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 an occurrence of a Federally -listed species is 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(a)ncdcr.clov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPARTMENT OF NATURAL. AND CULTURAL RESOURCES
1:1 W. JONES STREET, RALEIGI 4_ NC 27fiO3 - 1651 MAIL SERVICE CENTER, RALCIGH. NC 27699
OFC 915707.9120 • FA 919.707.4121

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Intersecting the Project Area
Bandit Farms Buffer and Nutrient Offset Project
March 21, 2023
NCNHDE-21334
No Element Occurrences are Documented within the Project Area
There are no documented element occurrences (of medium to very high accuracy) that intersect with the project area. Please note, however, that although the
NCNHP database does not show records for rare species within the project area, it does not necessarily mean that they are not present; it may simply mean that
the area has not been surveyed. The use of Natural Heritage Program data should not be substituted for actual field surveys if needed, particularly if the project
area contains suitable habitat for rare species. If rare species are found, the NCNHP would appreciate receiving this information so that we may update our
database.
Natural Areas Documented Within Project Area
Site Na epresentational Rating lllnr—� Collective Rating
Pickards Mountain R3 (High) C5 (General)
Managed Areas Documented Within Project Area
Managed Area Name I Owner ]Jim Owner Type
NC Agricultural Development and Farmland NC Department of Agriculture State
Preservation Trust Fund Easement
Triangle Land Conservancy Easement Triangle Land Conservancy Private
NOTE: If the proposed project intersects with a conservation/managed area, please contact the landowner directly for additional information. If the project intersects with a Dedicated Nature Preserve
(DNP), Registered Natural Heritage Area (RHA), or Federally -listed species, NCNHP staff may provide additional correspondence regarding the project.
Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.ora/help. Data query generated on March 21, 2023; source: NCNHP, Q4, Winter (January)
2023. Please resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 2 of 5

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mile Radius of the Project Area
Bandit Farms Buffer and Nutrient Offset Project
March 21, 2023
NCNHDE-21334
Element Occurrences Documented Within a One -mile Radius of the Project Area
Taxonomic EO ID Scientific Name Common NameFDate
ast Element
Group bservation Occurrence
6 0 Rank
Bird 16506 Vireo gilvus Warbling Vireo 2001-05-13 CD
Dragonfly or
33764
Somatochlora Coppery Emerald
2004-Pre
Damselfly
georgiana
Natural
13086
Dry-Mesic ---
2021-08-05
Community
Oak --Hickory Forest
(Piedmont Subtype)
Natural
15430
Mesic Mixed Hardwood---
2021-08-05
Community
Forest (Piedmont
Subtype)
Natural
10161
Piedmont Monadnock ---
2021-08-05
Community
Forest (Typic Subtype)
Vascular Plant
22304
Tridens chapmanii Chapman's Redtop
1894-08-21
Natural Areas Documented Within a One -mile Radius of the Project Area
Site Nam Representational Rating
Pickards Mountain R3 (High)
Managed Areas Documented Within a One -mile Radius of the Project Area
Managed Area Name
Owner
Orange County Open Space
Orange County
Conservation Trust for North Carolina Easement
Conservation Trust for North Carolina
Farm and Ranch Lands Protection Program
US Department of Agriculture, Natural
Easement
Resources Conservation Service
NC Agricultural Development and Farmland
NC Department of Agriculture
Preservation Trust Fund Easement
NC Division of Mitigation Services Easement
NC DEQ, Division of Mitigation Services
Orange County Easement
Orange County
Orange County Easement
Orange County
Orange County Easement
Orange County
Orange County Easement
Orange County
H?
AB
B
A
H
Accuracy Federal
State
Global
State
Status
Status
Rank
Rank
4-Low ---
Significantly
G5
S2B
Rare
5-Very ---
Significantly
G3G4
Sl?
Low
Rare
2-High ---
---
G4G5
S4
2-High --- --- G3G4 S4
2-High --- --- G3G4 S3
5-Very --- Threatened G5T3 S1S2
Low
Collective Rating
C5 (General)
Owner Type
Local Government
Private
Federal
State
State
Local Government
Local Government
Local Government
Local Government
Page 3 of 5

Managed Areas Documented Within a One -mile Radius of the Project Area
Managed Area Nam Owner
Triangle Land Conservancy Easement Triangle Land Conservancy Private
Triangle Land Conservancy Easement Triangle Land Conservancy Private
Triangle Land Conservancy Easement Triangle Land Conservancy Private
Triangle Land Conservancy Easement Triangle Land Conservancy Private
Definitions and an explanation of status designations and codes can be found at httos://ncnhde.natureserve.ora/helip. Data query generated on March 21, 2023; source: NCNHP, Q4, Winter (January)
2023. Please resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 4 of 5

NCNHDE-21334: Bandit Farms Buffer and Nutrient Offset Project
March 21, 2023
® NHP Natural Area (NHNA)
Managed Area (MAREA)
Buffered project Boundary
Q Project Boundary
Sources: Esn, Airbus OS, USGS, NGA NASA, CGIAR, N Robinson, NCEAS,
NLS, 05. NMA, Geodafaslyrelsen, Rgks—lerstaal. GSA Gealend FEMA,
Inlermap and [he GIS user wffimunity
Saurces� Esri, HERE, Garmin. FAO, NOAA, USGS, 0 OpmSlreelMap
oonlributars. and Ibe GIS User Community
Page 5 of 5

5/1/23, 3:07 PM RestorEcology, LLC Mail - Re: Online project review request letter: Bandit Farms (USFWS Project Code: 2023-0058056)
Ma i I Daniel Ramsay <[e-mail]>
Re: Online project review request letter: Bandit Farms (USFWS Project Code: 2023-
0058056)
1 message
Matthews, Kathryn H <[e-mail]> Wed, Apr 26, 2023 at 3:56 PM
To: "[e-mail]" <[e-mail]>
Cc: "Mann, Leigh" <[e-mail]>
Hi Daniel,
The Service concurs with your species determinations. Thank you for the opportunity to review.
Please note that 1 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: Tuesday, March 21, 2023 7:30 PM
To: Raleigh, FW4 <[e-mail]>
Subject: [EXTERNAL] Online project review request letter: Bandit Farms
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments,
or responding.
Good afternoon,
For your review, please see the attached letter and review package regarding the Bandit Farms Buffer and Nutrient Offset
Bank in Orange County, NC. I look forward to coordination with the U.S. Fish & Wildlife Service on this riparian buffer
restoration project.
Regards,
Daniel
Daniel Ramsay, PWS
Owner
( ) RESTORECOLOGY
https://mail.google.com/mail/u/1 /?ik=8f6548446f&view=pt&search=all&permthid=thread-f:l 764269994501064379&simpl=msg-f:1764269994501064379 1 /2

5/1/23, 3:07 PM RestorEcology, LLC Mail - Re: Online project review request letter: Bandit Farms (USFWS Project Code: 2023-0058056)
m: 919.817.7378 1 www.restorecology.com
Coordination Letter - USFWS- Bandit Farms 032123.pdf
5691 K
https://mail.google.com/mail/u/l/?ik=8f6548446f&view=pt&search=all&permthid=thread-f:l764269994501064379&simpl=msg-f:1764269994501064379 2/2

RESTORECOLOGY
From: Daniel Ramsay
RestorEcology Jordan, 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]
March 21, 2023
Re: Project Review Request, Bandit Farms Buffer and Nutrient Offset Bank Project (Bandit Farms),
Orange County, North Carolina, NC Division of Water Resources (DWR) #2016-0393
Dear Ms. Gledhill -Earley,
RestorEcology would like to request a project review for Bandit Farms, a proposed riparian buffer
and nutrient offset restoration project regulated by the DWR. The Project is located at
35°58'30.10"N, 79° 8'45.89"W in the Upper New Hope watershed of Jordan Lake (HUC
03030002). 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 18.2 acres of cropland and pasture 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. Notably, the Project is expanding on a previous mitigation bank project
called Maple View on the property, shown in the attached figure. 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. Credits
150 WRENN DR, #5842, CARY, NC 27512
T [phone] U WWW.RESTORECOLOGY.COM

will be sold on the private mitigation bank market to offset development impacts within the
Upper New Hope watershed of Jordan Lake. 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. A
mapped structure viewable on HPOWEB 2.0 on March 23, 2023, OR0409, Nutter Log House
(Gone), is approximately 400-feet east of the project area, but is no longer in existence, per the
HPOWEB 2.0 data.
For additional information, please contact Daniel Ramsay at the address listed above.
Sincerely,
Daniel Ramsay, PWS
Owner, RestorEcology
Fnclnsures-
• USGS Topographic Map
• Aerial Photo Map

OR0409
► r:. r4Nutter Log
House(Gone)
f -
r
Esri C.
FF � • I foal er, icr t
Bandit Farms Project Area N
(18.2 Maple
Bandit Farms Buffer & Nutrient Bank
Maple View Project
Stream Status
Ephemeral RESTOR 2'023
N Mi Stream o 0.0.
- <all other values> ECOLOGY
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet o 0.07 0.15m
li

-- 1
Sa
White Cross USGS
.^-�►� . F
c �pyrignt(c� ?nl� �iat�� Quadrangle
p Cyq h-
�'
Parcels N
Maple View Project Bandit Farms Buffer & Nutrient Bank
Bandit Farms Project Area
(18.2AC+/-)
RESTORECOLOGY 2023 0 0.1 0.2 -ti ,
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet 0 0.23 0.45m

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
April 4, 2023
Daniel Ramsay, PWS
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
dramsay&restorecolo gy. com
RestorEcology
150 Wrenn Drive #5842
Cary, NC 27511
Re: Bandit Farms riparian buffer and nutrient offset mitigation project, 35.977873,-79.144179,
Wayne County, ER 22-2811
Dear Mr. Ramsay:
Thank you for your letter of March 23, 2023, regarding 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 environmental.review(cncdcr.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
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

Bandit Farms
0 Dairyland Rd
Hillsborough, NC 27278
Inquiry Number: 7308827.2s
April 14, 2023
6 Armstrong Road, 4th floor
Shelton, CT 06484
(rEDR . Toll Free: 800.352.0050
www.edrnet.com
FORM-LBE-MGA

TABLE OF CONTENTS
SECTION
PAGE
Executive Summary
ES1
OverviewMap-----------------------------------------------------------
2
DetailMap--------------------------------------------------------------
3
Map Findings Summary
4
MapFindings------------------------------------------------------------
8
Orphan Summary---------------------------------------------------------
10
Government Records Searched/Data Currency Tracking- - - - - - - - - - - - - -
- - - - - - - - - - - - GRA
GEOCHECK ADDENDUM
Physical Setting Source Addendum
A-1
Physical Setting Source Summary
A-2
Physical Setting SSURGO Soil Map -------------------------------------------
A-5
Physical Setting Source Map------------------------------------------------
A-15
Physical Setting Source Map Findings
A-17
Physical Setting Source Records Searched
PSGRA
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.
TC7308827.2s 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 (E 1527-13), the ASTM Standard Practice for Environmental Site
Assessments for Forestland or Rural Property (E 2247-16), the ASTM Standard Practice for Limited
Environmental Due Diligence: Transaction Screen Process (E 1528-14) or custom requirements developed
for the evaluation of environmental risk associated with a parcel of real estate.
TARGET PROPERTY INFORMATION
ADDRESS
0 DAIRYLAND RD
HILLSBOROUGH, NC 27278
COORDINATES
Latitude (North):
Longitude (West):
Universal Tranverse Mercator:
UTM X (Meters):
UTM Y (Meters):
Elevation:
35.9745630 - 35' 58' 28.42"
79.1456650 - 79° 8' 44.39"
Zone 17
667193.6
3982516.2
560 ft. above sea level
USGS TOPOGRAPHIC MAP ASSOCIATED WITH TARGET PROPERTY
Target Property Map: 13840535 WHITE CROSS, NC
Version Date: 2019
Southeast Map: 13839762 CHAPEL HILL, NC
Version Date: 2019
AERIAL PHOTOGRAPHY IN THIS REPORT
Portions of Photo from: 20140619
Source: USDA
TC7308827.2s EXECUTIVE SUMMARY 1

MAPPED SITES SUMMARY
Target Property Address:
0 DAIRYLAND RD
HILLSBOROUGH, NC 27278
Click on Map ID to see full detail.
MAP
ID SITE NAME ADDRESS DATABASE ACRONYMS
RELATIVE DIST (ft. & mi.)
ELEVATION DIRECTION
THOMPSON, BARRY RT 3 BOX 562 IMD Higher 2383, 0.451, West
7308827.2s Page 2

EXECUTIVE SUMMARY
TARGET PROPERTY SEARCH RESULTS
The target property was not listed in any of the databases searched by EDR.
DATABASES WITH NO MAPPED SITES
No mapped sites were found in EDR's search of available ("reasonably ascertainable ") government
records either on the target property or within the search radius around the target property for the
following databases:
STANDARD ENVIRONMENTAL RECORDS
Lists of Federal NPL (Superfund) sites
NPL National Priority List
Proposed NPL---------------- Proposed National Priority List Sites
NPL LIENS Federal Superfund Liens
Lists of Federal Delisted NPL sites
Delisted NPL National Priority List Deletions
Lists of Federal sites subject to CERCLA removals and CERCLA orders
FEDERAL FACILITY---------. Federal Facility Site Information listing
SEMS Superfund Enterprise Management System
Lists of Federal CERCLA sites with NFRAP
SEMS-ARCHIVE Superfund Enterprise Management System Archive
Lists of Federal RCRA facilities undergoing Corrective Action
CORRACTS------------------ Corrective Action Report
Lists of Federal RCRA TSD facilities
RCRA-TSDF RCRA - Treatment, Storage and Disposal
Lists of Federal RCRA generators
RCRA-LQG RCRA - Large Quantity Generators
RCRA-SQG------------------ RCRA - Small Quantity Generators
RCRA-VSQG RCRA - Very Small Quantity Generators (Formerly Conditionally Exempt Small Quantity
Generators)
Federal institutional controls / engineering controls registries
LUCIS------------------------ Land Use Control Information System
TC7308827.2s EXECUTIVE SUMMARY 3

EXECUTIVE SUMMARY
US ENG CONTROLS --------- Engineering Controls Sites List
US INST CONTROLS Institutional Controls Sites List
Federal ERNS list
ERNS Emergency Response Notification System
Lists of state- and tribal (Superfund) equivalent sites
NC HSDS____________________ Hazardous Substance Disposal Site
Lists of state- and tribal hazardous waste facilities
SHWS Inactive Hazardous Sites Inventory
Lists of state and tribal landfills and solid waste disposal facilities
SWF/LF List of Solid Waste Facilities
OLI___________________________ Old Landfill Inventory
DEBRIS Solid Waste Active Disaster Debris Sites Listing
LCID Land -Clearing and Inert Debris (LCID) Landfill Notifications
Lists of state and tribal leaking storage tanks
LUST ------------------------- Regional UST Database
LAST Leaking Aboveground Storage Tanks
INDIAN LUST Leaking Underground Storage Tanks on Indian Land
LUST TRUST ----------------- State Trust Fund Database
Lists of state and tribal registered storage tanks
FEMA UST Underground Storage Tank Listing
UST Petroleum Underground Storage Tank Database
AST__________________________ AST Database
INDIAN UST Underground Storage Tanks on Indian Land
State and tribal institutional control / engineering control registries
INST CONTROL No Further Action Sites With Land Use Restrictions Monitoring
Lists of state and tribal voluntary cleanup sites
VCP__________________________ Responsible Party Voluntary Action Sites
INDIAN VCP Voluntary Cleanup Priority Listing
Lists of state and tribal brownfield sites
BROWNFIELDS Brownfields Projects Inventory
ADDITIONAL ENVIRONMENTAL RECORDS
Local Brownfield lists
US BROWNFIELDS---------- A Listing of Brownfields Sites
TC7308827.2s EXECUTIVE SUMMARY 4

EXECUTIVE SUMMARY
Local Lists of Landfill / Solid Waste Disposal Sites
SWRCY----------------------
Recycling Center Listing
HIST LF
Solid Waste Facility Listing
INDIAN ODI
Report on the Status of Open Dumps on Indian Lands
DEBRIS REGION 9----------.
Torres Martinez Reservation Illegal Dump Site Locations
ODI
Open Dump Inventory
IHS OPEN DUMPS
Open Dumps on Indian Land
Local Lists of Hazardous waste / Contaminated Sites
US HIST CDL---------------- Delisted National Clandestine Laboratory Register
US CDL National Clandestine Laboratory Register
Local Land Records
LIENS 2 CERCLA Lien Information
Records of Emergency Release Reports
HMIRS-----------------------
Hazardous Materials Information Reporting System
SPILLS
Spills Incident Listing
SPILLS 90
SPILLS 90 data from FirstSearch
SPILLS 80-------------------.
SPILLS 80 data from FirstSearch
Other Ascertainable Records
RCRA NonGen / NLR
RCRA - Non Generators / No Longer Regulated
FUDS
Formerly Used Defense Sites
DOD-------------------------
Department of Defense Sites
SCRD DRYCLEANERS
State Coalition for Remediation of Drycleaners Listing
US FIN ASSUR
Financial Assurance Information
EPA WATCH LIST-----------.
EPA WATCH LIST
2020 COR ACTION
2020 Corrective Action Program List
TSCA
Toxic Substances Control Act
TRIS-------------------------
Toxic Chemical Release Inventory System
SSTS
Section 7 Tracking Systems
ROD
Records Of Decision
RMP-------------------------
Risk Management Plans
RAATS
RCRA Administrative Action Tracking System
PRP
Potentially Responsible Parties
PADS------------------------
PCB Activity Database System
ICIS
Integrated Compliance Information System
FTTS
FIFRA/ TSCA Tracking System - FIFRA (Federal Insecticide, Fungicide, & Rodenticide
Act)/TSCA (Toxic Substances Control Act)
MLTS
Material Licensing Tracking System
COAL ASH DOE
Steam -Electric Plant Operation Data
COAL ASH EPA--------------
Coal Combustion Residues Surface Impoundments List
PCB TRANSFORMER
PCB Transformer Registration Database
RADINFO
Radiation Information Database
HIST FTTS-------------------
FIFRA/TSCA Tracking System Administrative Case Listing
DOT OPS
Incident and Accident Data
CONSENT
Superfund (CERCLA) Consent Decrees
INDIAN RESERV-------------
Indian Reservations
TC7308827.2s EXECUTIVE SUMMARY 5

EXECUTIVE SUMMARY
FUSRAP_____________________
Formerly Utilized Sites Remedial Action Program
UMTRA
Uranium Mill Tailings Sites
LEAD SMELTERS
Lead Smelter Sites
US AIRS_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Aerometric Information Retrieval System Facility Subsystem
US MINES
Mines Master Index File
ABANDONED MINES
Abandoned Mines
FINDS ------------------------
Facility Index System/Facility Registry System
DOCKET HWC
Hazardous Waste Compliance Docket Listing
ECHO
Enforcement & Compliance History Information
UXO--------------------------
Unexploded Ordnance Sites
FUELS PROGRAM
EPA Fuels Program Registered Listing
PFAS NPL
Superfund Sites with PFAS Detections Information
PFAS FEDERAL SITES______
Federal Sites PFAS Information
PFAS TSCA
PFAS Manufacture and Imports Information
PFAS RCRA MANIFEST_____.
PFAS Transfers Identified In the RCRA Database Listing
PFAS ATSDR----------------
PFAS Contamination Site Location Listing
PFAS WQP
Ambient Environmental Sampling for PFAS
PFAS NPDES
Clean Water Act Discharge Monitoring Information
PFAS ECHO_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Facilities in Industries that May Be Handling PFAS Listing
PFAS ECHO FIRE TRAINING. Facilities in Industries that May Be Handling PFAS Listing
PFAS PART 139 AIRPORT___
All Certified Part 139 Airports PFAS Information Listing
AQUEOUS FOAM NRC-------
Aqueous Foam Related Incidents Listing
PFAS
PFAS Contamination Site Listing
AIRS
Air Quality Permit Listing
ASBESTOS__________________
ASBESTOS
COAL ASH
Coal Ash Disposal Sites
DRYCLEANERS
Drycleaning Sites
Financial Assurance_ _ _ _ _ _ _ _ _
_ Financial Assurance Information Listing
NPDES
NPDES Facility Location Listing
UIC
Underground Injection Wells Listing
AOP--------------------------
Animal Operation Permits Listing
SEPT HAULERS
Permitted Septage Haulers Listing
PCSRP
Petroleum -Contaminated Soil Remediation Permits
CCB--------------------------
Coal Ash Structural Fills (CCB) Listing
PFAS TRIS
List of PFAS Added to the TRI
MINES MRDS
Mineral Resources Data System
EDR HIGH RISK HISTORICAL RECORDS
EDR Exclusive Records
EDR MGP____________________ EDR Proprietary Manufactured Gas Plants
EDR Hist Auto EDR Exclusive Historical Auto Stations
EDR Hist Cleaner EDR Exclusive Historical Cleaners
EDR RECOVERED GOVERNMENT ARCHIVES
Exclusive Recovered Govt. Archives
RGA HWS-------------------- Recovered Government Archive State Hazardous Waste Facilities List
RGA LF Recovered Government Archive Solid Waste Facilities List
RGA LUST Recovered Government Archive Leaking Underground Storage Tank
SURROUNDING SITES: SEARCH RESULTS
Surrounding sites were identified in the following databases.
TC7308827.2s EXECUTIVE SUMMARY 6

EXECUTIVE SUMMARY
Elevations have been determined from the USGS Digital Elevation Model and should be evaluated on
a relative (not an absolute) basis. Relative elevation information between sites of close proximity
should be field verified. Sites with an elevation equal to or higher than the target property have been
differentiated below from sites with an elevation lower than the target property.
Page numbers and map identification numbers refer to the EDR Radius Map report where detailed
data on individual sites can be reviewed.
Sites listed in bold italics are in multiple databases.
Unmappable (orphan) sites are not considered in the foregoing analysis.
ADDITIONAL ENVIRONMENTAL RECORDS
Records of Emergency Release Reports
IMD: Incident Management Database.
A review of the IMD list, as provided by EDR, and dated 01/13/2023 has revealed that there is 1 IMD
site within approximately 0.5 miles of the target property.
Equal/Higher Elevation Address Direction / Distance Map ID Page
THOMPSON, BARRY RT 3 BOX 562 W 1/4 - 1/2 (0.451 mi.)
Facility Id: 3793
TC7308827.2s EXECUTIVE SUMMARY 7

EXECUTIVE SUMMARY
Due to poor or inadequate address information, the following sites were not mapped. Count: 5 records.
Site Name
STEVENSON PROPERTY
DELUXE CLEANERS
PLAZA CLEANERS
BAILEY PROPERTY
P.W. SCOTT FARM #3
Database(s)
LAST
DRYCLEANERS
DRYCLEANERS
LUST TRUST
LUST TRUST
TC7308827.2s EXECUTIVE SUMMARY 8

OVERVIEW MAP - 7308827.2S
Target Property
o 114 v2
1 races
Sites at elevations higher than
or equal to the target property
Indian Reservations BIA
Hazardous Substance
♦
Sites at elevations lower than
°, a
a a%
Power transmission lines
Disposal Sites
the target property
Special Flood Hazard Area (1%)
1
Manufactured Gas Plants
0.2% Annual Chance Flood Hazard
National Priority List Sites
Dept. Defense Sites
0
National Wetland Inventory
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: Bandit Farms CLIENT: RestorEcology, LLC
ADDRESS: 0 Dairyland Rd CONTACT: Daniel Ramsay
Hillsborough NC 27278 INQUIRY #: 7308827.2s
LAT/LONG: 35.974563 / 79.145665 DATE: April 14, 2023 1:52 pm
Copyright m 2023 EDR, Inc. (c) 2015 TornTom Ref 2015

Map ID
MAP FINDINGS
Direction
Distance
EDR ID Number
Elevation
Site
Database(s) EPA ID Number
1
THOMPSON, BARRY
IMD S103130702
West
RT 3 BOX 562
N/A
1/4-1/2
HILLSBOROUGH, NC
0.451 mi.
2383 ft.
Relative:
IMD:
Higher
Facility ID:
3793
Actual:
Name:
THOMPSON, BARRY
660 ft.
Address:
RT 3 BOX 562
City,State,Zip:
HILLSBOROUGH, NC
Date Occurred:
11/2/1988
Submit Date:
1/8/2003
Incident Desc:
WATER WELL WAS CONTAMINATED WITH RAW SEWAGE. LETTER SENT IN 12/08/1988
DETAILS THE CHLORINATION OF THE WELL AND PUMPIING OF THE WELL TO
REMOVE THE CONTAMINATION
Operator:
THOMPSON, BARRY
UST ID:
Not reported
Incident ID:
Not reported
Initials of UST Regional Contact:
Not reported
Regional Office:
Not reported
Responsible Party/Company Name:
Not reported
Ownership:
5
Responsible Party Contact Name:
Not reported
Operation:
5
Responsible Party Mailing Address:
Not reported
Responsible Party City,State,Zip:
Not reported
Ownership:
Federal
Operation Type:
Industrial
Responsible Party County:
Not reported
Source:
Well
Type:
SEWAGE/SEPTAGE
Location:
Not reported
Petroleum Type:
Not reported
Date Incident Reported:
Not reported
Whether Tank is Commercial or Non Commercial:
Not reported
Site Priority:
40
Whether Tank is Regulated:
Not reported
Priority Update:
Not reported
Notice of Regulatory Requirement:
Not reported
Wells Affected:
Yes
Notice of Violation:
Not reported
Phase 1 or Phase 2:
Not reported
Num Affected:
1
Site Priority:
Not reported
Location:
Not reported
Current Risk Condition:
Not reported
Sampled By:
Not reported
Samples Include:
Not reported
Initial reported risk of incident (never changes):
Not reported
7.5 Min Quad:
Not reported
5 Min Quad:
Not reported
Intermediate Condition Present:
Not reported
Latitude:
35.971666
Longitude:
-79.164166
Use of Land, Industrial:
Not reported
Corrective Action Plan Selected - up to 5:
Not reported
RBCA:
Not reported
Date Close Review Requested From RP or Owner:
Not reported
TC7308827.2s Page 8

Map ID
Direction
Distance
Elevation Site
THOMPSON, BARRY (Continued)
MAP FINDINGS
Date Case Closed:
Extent of Contamination:
Number of Supply Wells Located on Property:
MTBE in Well Y/N/U Yes, No or Unknown:
Facility Phone Number:
MTBE in Groundwater Y/N/U Yes, No or Unknown:
Date Land Use Restriction Filed:
Date Cleanup Initiated:
Record Status:
RBCA GW Codes:
RBCA GW:
Pollutant Type Present:
Reference Number for Media Disk for Archived Record
RP Owner?:
RP Operator?:
RP Landowner?:
Comments:
GW Contam:
Soil Contam:
Contact Phone:
Owner Company:
Operator Address:
Operator City,State,Zip:
Operator County:
Material:
Qty Lost 1:
Qty Recovered 1:
Setting:
Risk Site:
Priority Code:
Dem Contact:
Wells Contam:
Latitude Number:
Longitude Number:
Latitude Decimal:
Longitude Decimal:
GPS:
Agency:
EDR ID Number
Database(s) EPA ID Number
S103130702
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
Yes, Groundwater Contamination has been detected
Not reported
919-942-2929
Not reported
INTERSECTION SR 1102 & SR 1177
HILLSBOROUGH, NC 919-942-2929
Not reported
Not reported
Not reported
Not reported
Not reported
Not reported
A
ER
Not reported
Not reported
Not reported
Not reported
Not reported
EST
DWQ
TC7308827.2s Page 9