20150465 Ver 2_Mitigation Evaluation_20231019

From:Merritt, Katie
To:Camden Brunick
Cc:Hartshorn, Blake
Subject:Audit_Buffer Credit Sales - Black Dirt
Date:Thursday, October 19, 2023 12:02:00 PM
Attachments:Black Dirt Buffer Credit Ledger.pdf
Good Morning Camden,
By copy of this correspondence, Wildlands is now compliant with the buffer credit sales for the Black
Dirt bank. The approved credit balances on the buffer credit ledgers (see attached) for Black Dirt
bank as of 10/17/2023 are as follows:
Buffer Restoration Ledger – 41,856.949 credits

Thank you for your cooperation with this audit.

Katie

From: Camden Brunick <[e-mail]>
Sent: Wednesday, October 18, 2023 8:45 AM
To: Merritt, Katie <[e-mail]>
Cc: Hartshorn, Blake <[e-mail]>
Subject: RE: [External] FW: Audit for CTC request - Black Dirt

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Good Morning Katie,

Per the actions required below, please see the attached email regarding the MCTC Partial Refund
and our updated ledger.

Thank you,

Camden Brunick | Mitigation Credit Sales
O: 704.332.7754 x114 M: 919.219.6162

Wildlands Engineering, Inc.
1430 S. Mint St., Suite 104
Charlotte, NC 28203

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From: Merritt, Katie <[e-mail]>
Sent: Monday, October 16, 2023 4:21 PM
To: Camden Brunick <[e-mail]>
Cc: Hartshorn, Blake <[e-mail]>; Andrea Eckardt <[e-mail]>
Subject: RE: [External] FW: Audit for CTC request - Black Dirt

Good Afternoon Camden,
I have finalized the remainder of the audit for the BUFFER credit sales for the Black Dirt
mitigation bank through 10/2/2023 based on the most recent ledger submitted to DWR which
is attached and dated 10/2/23. This audit was required prior to approval of the attached CTC
request for the Division of Mitigation Services. The audit results are provided below and require
further action from Wildlands:

Buffer Restoration Ledger
The Novo Nordisk Site Capacity Expansion (DWR# 2015-0465v2) credit sale is non-
compliant. The Compensatory Mitigation Responsibility Transfer Form (attached) was for
264,118.351 buffer credits. Per th buffer invoice attached to this correspondence,
Wildlands sold 264,119 buffer credits, which is 0.649 more buffer credits than the permit
required from Wildlands’ banks.
0.649 ft2 of buffer credits were oversold for the Novo Nordisk Site Capacity
Expansion project (DWR# 2015-0465v2).
Actions Required:
Add a line item to the buffer restoration ledger dated 10/16/23. Add the
purchaser Name. For Project Name, enter: Novo Nordisk Site Expansion –
FULL REFUND for non-compliant credit sale dated 4/11/23. Under the
“CREDITS RELEASED/AVAILABLE” column, enter 0.649 ft2 and update the
credit balances accordingly, which will add 0.649 more credits back to the
ledger balance.
Create a new Mitigation Credit Transfer Certificate w/ “REFUND” under the
heading, dated 10/16/23 to the permittee, documenting the PARTIAL
REFUND of 0.649 buffer credits due to “overselling 0.649 more buffer
credits than what was required in the Compensatory Mitigation Responsibility
Transfer Form signed by Wildlands representative on April 11, 2023 (see
attached and include the form again with the MCTC).
Once you have finalized the new MCTC notifying the partial refund, send it to
the permittee, their consultant (if applicable), the DWR contact (Vanessa
Manuel/Stephanie Goss) and to me along with the corrected Credit Ledger.

Once Wildlands complies with the audit and addresses “Actions Required” above, DWR can sign
the CTC request attached to this correspondence. If Wildlands sells any credits before DWR
signature of the attached CTC, Wildlands will have to undergo an additional audit.

Thank you,
Katie

From: Camden Brunick <[e-mail]>
Sent: Friday, September 8, 2023 3:31 PM
To: Merritt, Katie <[e-mail]>
Cc: Hartshorn, Blake <[e-mail]>
Subject: RE: [External] FW: Audit for CTC request - Black Dirt

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Katie,

Please see the attached copy of our invoice for the Novo Nordisk project. I believe there was a small
oversell as you mentioned below. Initially, all the required buffer credits were to be purchased from
Wildlands but then only 264,118.351 sq.ft. ended up being purchased from Wildlands.

Please let me know if you need any additional information.

Thank you,

Camden Brunick | Mitigation Credit Sales
O: 704.332.7754 x114 M: 919.219.6162

Wildlands Engineering, Inc.
1430 S. Mint St., Suite 104
Charlotte, NC 28203

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From: Merritt, Katie <[e-mail]>
Sent: Friday, September 8, 2023 3:16 PM
To: Camden Brunick <[e-mail]>
Cc: Hartshorn, Blake <[e-mail]>
Subject: FW: [External] FW: Audit for CTC request - Black Dirt

Hey Camden,
Thank you for the quick reply.
Your response regarding the Novo Nordisk transaction needs further review- (Wildlands
states that the correct amount of buffer credits sold for the Novo Nordisk transaction is
11,298.05 ft and not 11,297.400 as indicated on the July 2023 credit ledger & the MCTC for
Little River Weaver for the same Novo Nordisk project ).
The Buffer ledger submitted with the 2022 Credit Sale Audit Packet (dated 7-10-23)
shows 11,297.400 ft2 (which I used this ledger for the CTC request because it was
submitted for the audit and should be most accurate). The MCTC you sent me for the
Little River Weaver audit for the DMS CTC Request, shows that Wildlands is selling
11,297.400 ft2 from the Black Dirt bank site.
The Buffer ledger submitted with the DMS CTC request (dated 9-5-23) for Black Dirt
shows 11,298.05 ft2, which is different from the ledger you submitted for the Audit and
does not align with the Little River Weaver MCTC for how many buffer credits Wildlands
was selling from Black Dirt.
The total buffer credits the attached MRTF says are being provided by Wildlands’ banks to
satisfy the buffer mitigation required is 264,118.351 ft2. When totaling the amount the
MCTC (for Little River FARM) indicates were sold by all the Wildlands Banks, the total is
264,119 ft2, This means that Wildlands sold 0.649 more credits than were required by
the permit. When using 11,298.05 ft2 as you indicated in your response below, the total
sold by Wildlands is 264,119.65 ft1, which means Wildlands oversold 1.299 buffer
credits.
In both scenarios, Wildlands has sold more buffer credits than what is required by the
permit
ACTION REQUIRED: Provide a copy of the Invoice Wildlands provided to the permittee with the
total amount of buffer credits sold by the Wildlands banks to satisfy the required buffer
mitigation of 264,118.351 ft2. DWR needs to determine what was sold in order to properly
assist Wildlands in bringing their buffer credit sales into compliance. Do not update the credit
ledgers until DWR provides further guidance.

Regarding the MRTF for 1129 Lake Glad road transaction:
no credit sale can occur until that MRTF is signed by the Provider and given to the Permittee.
This document is filed with their permit and is considered a condition requirement of their
permit. If it is not signed by the Provider PRIOR to the credit sale, then the permittee and the
Bank Sponsor are in non-compliance. This MRTF is a new form that came out in Spring
2023, therefore I am sensitive to the fact that it will take some time for permittees and
Providers as well as Regulatory Authorities, to become accustomed to the new process.

Thank you for your cooperation with the buffer credit sale audit for purposes of the CTC request
for Black Dirt. DWR requires a thorough response regarding the non-compliance noted for the
Novo Nordisk transaction prior to finalizing the buffer credit sale audit for the DMS CTC request.

Thank you for your cooperation,
Katie

From: Camden Brunick <[e-mail]>
Sent: Friday, September 8, 2023 1:48 PM
To: Merritt, Katie <[e-mail]>
Cc: Hartshorn, Blake <[e-mail]>
Subject: RE: [External] FW: Audit for CTC request - Black Dirt

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Katie,

Please see the attached as well as responses below in red –

Results from the audit of your buffer ledger are as follows:
There was no Compensatory Mitigation Responsibility Acceptance Form (CMRAF), which is
referenced on Page 2 of the 1129 Lake Glad Road Property transaction dated 7/28/23.
Send DWR the signed form for this transaction. Please see the attached singed MRTF
The MCTC for the Novo Nordisk Site Capacity Expansion states that Wildlands sold
11,298.05 ft2. Whereas the ledger states 11,297.400 ft2.
Provide DWR with an explanation for the differences in credits sold depicted on the ledger
vs the credits sold depicted on the MCTC. The ledger for 11,297.400 ft2 is correct. There
was a mistype on the MCTC where I previously saved 2 copies. Meant to send the correct
one which is attached above.

Please let me know if you have any questions.

Camden Brunick | Mitigation Credit Sales
O: 704.332.7754 x114 M: 919.219.6162

Wildlands Engineering, Inc.
1430 S. Mint St., Suite 104
Charlotte, NC 28203

SUBSCRIBE TO OUR NEWSLETTER! »

From: Merritt, Katie <[e-mail]>
Sent: Friday, September 8, 2023 1:17 PM
To: Camden Brunick <[e-mail]>
Cc: Hartshorn, Blake <[e-mail]>
Subject: RE: [External] FW: Audit for CTC request - Black Dirt

Hey Camden,
Results from the audit of your buffer ledger are as follows:
There was no Compensatory Mitigation Responsibility Acceptance Form (CMRAF), which is
referenced on Page 2 of the 1129 Lake Glad Road Property transaction dated 7/28/23.
Send DWR the signed form for this transaction
The MCTC for the Novo Nordisk Site Capacity Expansion states that Wildlands sold
11,298.05 ft2. Whereas the ledger states 11,297.400 ft2.
Provide DWR with an explanation for the differences in credits sold depicted on the ledger
vs the credits sold depicted on the MCTC.

Once DWR has the necessary items requested above, the audit can be finalized and a review of
the CTC request can be processed.
Thank you,
Katie

From: Camden Brunick <[e-mail]>
Sent: Tuesday, September 5, 2023 12:45 PM
To: Merritt, Katie <[e-mail]>
Cc: Hartshorn, Blake <[e-mail]>
Subject: [External] FW: Audit for CTC request - Black Dirt

CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the
Report Message button located on your Outlook menu bar on the Home tab.

Katie,

Please see the attached CTC as well as a copy of our Buffer ledger, sales, and 2023 Credit Releases
for our Black Dirt. For some reason I cannot add the signed MRT to the other Novo Nordisk PDF so it
has been attached separate. Please sign and return at your earliest convenience.

Thank you,

Camden Brunick | Mitigation Credit Sales
O: 704.332.7754 x114 M: 919.219.6162

Wildlands Engineering, Inc.
1430 S. Mint St., Suite 104
Charlotte, NC 28203

SUBSCRIBE TO OUR NEWSLETTER! »

From: Camden Brunick
Sent: Tuesday, August 15, 2023 3:56 PM
To: Merritt, Katie <[e-mail]>
Cc: Hartshorn, Blake <[e-mail]>
Subject: Audit for CTC request - Black Dirt

Katie,

Please see the attached CTC as well as a copy of our Buffer ledger, sales, and 2023 Credit Releases
for our Black Dirt. For some reason I cannot add the signed MRT to the other Novo Nordisk PDF so it
has been attached separate. Please sign and return at your earliest convenience.

Thank you,

Camden Brunick | Mitigation Credit Sales
O: 704.332.7754 x114 M: 919.219.6162

Wildlands Engineering, Inc.
1430 S. Mint St., Suite 104
Charlotte, NC 28203

SUBSCRIBE TO OUR NEWSLETTER! »

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