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Home My WebLink AboutBPDP Review-Creeping Swamp BFrom: Merritt, Katie To: Menefee -Dunn. Barbara A Subject: BPDP Review - Creeping Swamp B Date: Wednesday, September 13, 2023 4:52:59 PM Attachments: DWR Comment Summary CreepinaB.pdf Barbara, Please file the email thread below with the attached Comment Summary as 1 pdf in Laserfiche. Date: Today File Name: Subject line of email DWR#: 2022-06200 Thank you so much, Katie From: Merritt, Katie Sent: Wednesday, September 13, 2023 4:01 PM To: Jenkins, Barrett <Barrett.Jenkins@davey.com> Cc: Hartshorn, Blake <blake.hartshorn@deq.nc.gov> Subject: BPDP Review - Creeping Swamp B Hey Barrett, Pursuant to Titles 15A NCAC 02B .0295 and 15A NCAC 02B .0703 (e), a provider shall submit a project plan proposal to the Division for review and approval that includes specific elements of the project. On March 9, 2023, Restoration Systems, LLC (RS) submitted a Bank Parcel Development Package (Plan) for the Creeping Swamp B Site, to the Division, for review and approval. According to the initial review by DWR staff of the subject Plan, some elements were either not provided, not explained thoroughly, not accurate or lacking in sufficient information. Therefore, until DWR receives an updated Plan addressing all comments and edits provided in the attached 1) comment summary and 2) PDF version of the document itself, DWR cannot finalize the review of the Plan or issue an approval of the Plan. In an effort to be as efficient as possible at providing comments to IRS during this busy time, I have provided my comments in a unique format. Attached are the comments & edits provided within the actual PDF of a condensed Plan (without Appendices) as well as a comment summary. When IRS is ready to submit their final project Plan, please include a summary of all responses by IRS to the DWR comments acknowledging how IRS addressed the comments. Please upload the final Plan using our Mitigation Project Information Upload Form through this link: https://edocs.deq.nc.gov/Forms/Mitigation_ Information_ Upload . Please note the DWR ID#2022- 0620 (version 3) on all electronic submissions for this project. Thank you for your patience during this time and if you have any difficulty reading though the comments or edits please let Blake or I know. Katie Katie Merritt Nutrient Offset & Buffer Banking Coordinator 401 & Buffer Permitting Unit North Carolina Department of Environmental Quality Office: 919-707-3637 Work Cell: 919-500-0683 Website: https://deq.nc.gov/about/divisions/water-resources/water-quality permitting/401-buffer- permitting-branch NEW EMAIL!! katie.merritt(@deq.nc.gov 512 N. Salisbury Street, Raleigh, NC 27620 1617 Mail Service Center, Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. Summary of Comments on Creeping Swamp BPDP_DWRedits.pdf Page: 1 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:25:20 PM add Restoration Number: 2 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:25:26 PM add 0-100 Number: 3 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:26:21 PM make sure this is the most up-to-date table from the website, which was updated this summer 2023 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 2:26:04 PM DWR ID# is 2022-0620v3 gpNumber: 1 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:52:30 PM parcel photos are dated 1/25/23, which are not "recent" photos but are good photos that show where culvert removal and sink hole grading will be done. Keep the pictures, but add updated photos using photos timestamped with a more recent image of the riparian area conditions. current drone footage can also be included. Page: 5 Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/13/2023 3:27:15 PM and the UBI Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/13/2023 3:27:35 PM Mitigation Page: 7 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:27:52 PM this language is acceptable, but still need more recent photos to support this statement Page: 11 Number: 1 Author: kymerritt Subject: Inserted Text Date: 9/13/2023 3:28:35 PM and shrubs IT-1Number: 2 Author: kymerritt Su Number: 3 Author: kymerritt Su �Number:4 Author: kymerritt Su credits Cross -Out Date: 9/13/2023 3:30:17 PM Cross -Out Date: 9/13/2023 3:30:29 PM Inserted Text Date: 9/13/2023 3:30:40 PM Number: 5 Author: kymerritt Subject: Inserted Text Date: 9/13/2023 3:30:34 PM areas generating Number: 6 Author: kymerritt Subject: Inserted Text Date: 9/13/2023 3:31:16 PM good species diversity Page: 12 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:37:57 PM The "maintenance area" shown on figures does not meet the expectations in the site viability letter for securing the connection of Ditch F to Feature 1 B. This isn't the same scenario as the Maintenance Areas we agreed to allow for the Raleigh Farm site for access to monitoring wells. This area is supposed to be identified as an internal access easement, where RS has complete control within the easement as well as the culverted crossing. Additionally, it appears that RS is intending to extend the existing width of this crossing beyond its current footprint, which is not allowed on a ditch where its connection to the intermittent stream could be compromised. As discussed on site, the existing footprint of the existing path is all that can be proposed for this internal access easement. Add language to this section that DWR can review to determine whether the proposed internal crossing will meet the hydrologic connectivity expectations of the site viability letter. Otherwise, RS will have to remove the section of the ditch proposed upstream of the crossing from credit generating areas. Page: 13 Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:39:44 PM this number doesn't match the credit table. Number: 2 Author: kymerritt Subject: Inserted Text Date: 9/13/2023 3:39:09 PM Nutrient Page: 15 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:40:16 PM wrong Credit Table. remove from file when submitting final draft. Page: 19 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:41:47 PM the way you differentiate the ditches from the streams on this figure is how DWR would like RS to address the comments in Creeping Swamp A on the figures. gbNumber: 2 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:40:43 PM change "Draft' to "proposed" easement on this figure on all remaining figures. wNumber: 3 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:45:45 PM change "maintenance area" to be internal crossing and it needs to be part of the propsed easement. make this change throughout all figures Page: 23 *Number: 1 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:51:03 PM show ditch origins on this figure where the ditches originate within the easement boundary and use a different symbology to differentiate the ditches from streams. difficult to see where the ditches are shown when overlapping parcel boundaries. wNumber: 2 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:49:19 PM add the width of the existing crossing and be sure to only show the internal crossing to be the same width. gbNumber: 3 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:48:39 PM add a "Non-credit" area to the legend to depict the ?200 areas where no credits are generated gbNumber: 4 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:49:46 PM change to 'Riparian Restoration for NOC" QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 9/13/2023 3:49:54 PM Change to "Riparian Preservation" (No Credit) 7qq Culvert to remain Feature 1b Feature 1a =' Culvert to be removed Creeping Swamp Phase B Bank Parcel — Neuse 02; Craven County Photo Date: 01/25/2023 Image 3: Looping downstream at confluence of Feature 1b into 1a and Feature F showing farm road and maintenance area Image 4: Looping upstream at confluence of Feature 1b andla showing existing culvert along 1a excluded from Parcel footprint Creeping Swamp Prase B Bank Parcel — Neuse 02; Craven County Photo ❑ate: 01/25/2023 Image 5: Looking upstream at confluence of Feature i with Feature 1A Image 6: Looking south, downstream Feature F to confluence with Feature 1b, t❑ 1a including Features I and H