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HomeMy WebLinkAboutBrooks Swamp DWR Comment SummarySummary of Comments on Brooks Swamp BPDP_DWRedits.pdf Page: 1 goNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:28:16 PM General Comments: -Nutrient offset credits are not allowed in the Restoration and Enhancement areas of hte swamp areas because they are not agricultural landuses. Remove all nutrient offsets from the table and figures in these areas -Since restoration and enhancement within the wooded areas were primarily allowed if full removal of privet was done and an Adaptive Management plan was established, it is necessary to depict the areas of privet and canopy privet on the supporting figures w/ unique color symbology and include a Privet Management Plan in the text of this Plan with its own section. Must include a committment for how privet will be managed for 5 years of the monitoring. Without full removal and an AMP, these areas will only be valid for Preservation credits. QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:21:16 PM add the DWR ID# which is 2023-0163 v2 Page: 3 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:29:08 PM include a figure showing "planted areas" that will be planted according to the tables included in the plan (swamp/wet areas vs upland, privet areas, etc.) Page:4 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:32:16 PM when referring to nutrient offsets, we can't use the word "mitigation". Mitigation only applies to buffer. Number: 2 Author: kymerritt Subject: Cross -Out Date: 12/12/2023 2:31:52 PM JilNumber: 3 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 2:31:48 PM mitigation Number: 4 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 2:32:26 PM riparian Number: 5 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 2:35:26 PM adjacent to two streams Number: 6 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 2:33:33 PM riparian areas adjacent to streams Number: 7 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 2:33:02 PM and adjacent riparian areas out to a maximum of 200' landward from existing stream top of banks. Number: 8 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 2:33:55 PM nutrient offset credits it Number: 9 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 2:34:30 PM 03020201 (excluding the Falls Watershed) to offset authorized impacts. JilNumber: 10 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 2:35:03 PM and depicts where riparian buffer credits and nutrient offset credits can sold from this site. Page: 6 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:36:40 PM this will need to be updated after updating the table Page: 10 Number: 1 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 2:37:33 PM as they were observed during the DWR site visit in March along UT1, *Number: 2 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:41:14 PM there are 17 in the table, you have to plant what you list in the table. If only planting 6 species, you have to list out those 6 species and DWR has to approve those 6 species as part of this plan review. Include the approximate density of those 6. For the rest of the stems presented, you will need to show as "possible substitutes" and then include the maximum density you will be planting those substitutes if you needed them. *Number: 3 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:44:29 PM no figure is included showing the proposed "planting area". include a figure and reference it here. *Number: 4 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:14:50 PM there is also privet in restoration areas. describe how these areas will be handled. see viability letter *Number: 5 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:40:48 PM include a column for "tree/shrub" and fill in accordingly. *Number: 6 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:41:51 PM you have to include exactly what you are planting. Pick the other species as "possible substitutes" and include teh density. Page: 11 "Number: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 2:43:38 PM add "shrub/tree" column and fill in accordingly. "Number: 2 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:18:28 PM no figure is provided showing where the "Swamp wetland" areas are. Add this figure and reference it here. Remember, this is being proposed as an "alternative" planting plan than what rule requires in that you are wanting to plant "softwoods" such as Cypress and White Cedar. Therefore these two species have to be site selected and just in wet areas. You will need to explain why these two species need to be a part of the planting plan. and indicate where you will be plantng them. "Number: 3 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:12:06 PM DWR does not approve Tag Alder for nturient offset or buffer mitigation projects since the goal is not to add nutrients to soil but to remove it. Tag alder adds nutrients. r"Number: 4 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:16:21 PM ijnclude a table showing what will be seeded on the site. need to ensure that you are using perennial and annual species in the seed mix. "Number: 5 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:16:47 PM push "December" back to a later date. "Number: 6 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:18:59 PM speak to privet removal on a broader level; wasn't the privet described in these areas as "complete canopy"? need a privet management plan describing how the privet will be managed (see viability letter) through site implementation and monitoring. See Figure comments as well where Enhancement is being proposed. "Number: 7 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:17:48 PM i don't see wetland tolerant species pointed out in Table 8.1. Maybe just use Table 8.2 for those. "Number: 8 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:20:32 PM need to speak to the barn area and the debris that was noted in the site viabilty letter around it. need to acknowledge that the barn footprint is excluded from credit area and is shown in a supporting figure as "Non credit Area" "Number: 9 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:21:13 PM Add Section 4.6 to be a privet management plan "Number: 10 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:21:36 PM is this 2% of the planted area? Page: 12 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:28:05 PM will you want to adopt the new monitoring schedule agreed to at the annual provider meeting, where you only provide average vigor per plot and height data in years 1, 3 and 5 instead of every year? All other monitoring date is still required for every year. Vigor would be measured as an average per plot and Height will be measured per stem per plot. Page: 13 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:44:23 PM the Project Credit Table has to be moved to this section. It is currently at the back of the Plan. Page: 14 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:44:38 PM this will change after edits are made Page: 18 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:45:09 PM show Barn Footprint Page: 19 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:45:33 PM change to "Credit Service Area" TI Number: 2 Author: kymerritt Subject: Inserted Text Date: 12/12/2023 3:45:53 PM for Riparian Buffer Credits and Nutrient Offset Credits Page: 23 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:59:05 PM show barn footprint as "non credit area" and remove from Preservation Number: 2 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:04:55 PM this whole area in the woods shown as Restoration 0-100' needs to be shown as Restoration for RBC only since it's not convertible to NOC. Change the symbology of these areas to differentiate between Restoration for both vs Restoration for buffer only. update thr project credit table accordingly. Number: 3 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:10:50 PM the privet removal needs to be represented more broadly. Maybe do this on the same figure I have requested you show "Proposed Planting Area". that would be the best place to put it. QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:05:41 PM this enhancement area is not convertible to NOC. clarify in the legend as "Riparian Enhancement for Buffer Credit" QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 3:59:56 PM this area needs to be shown as Restoration for RBC only since it's not convertible to NOC. QNumber: 6 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:05:53 PM change to riparian preservation for buffer credit Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:06:08 PM change to riparian preservaiton for buffer credit QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:10:02 PM once you fix the orange areas that are not in Ag land and change to represent "non-ag Riparian Restoration" vs Restoration areas in ag. fields, you can then change to "Riparian Restoration for Buffer Credit". make sure the table is updated accordingly. QNumber: 8 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:06:35 PM change to Riparian Enhancement for Buffer Credit QNumber: 9 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:08:12 PM change to Riparian Enhancemet for Nutrient Offset Page: 24 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:16:32 PM label the 200' line QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:16:34 PM label the 100' line QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:16:51 PM what is this line representing? It's not blue or pink as shown in the legend QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:18:22 PM change "buffer" to "Riparian" and add other changes as requested on previous figure. QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:17:24 PM the TOB is not presented here. add it. Page: 25 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:22:26 PM move this plot inwards closer to the 100' line QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:19:28 PM label widths QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:21:00 PM call out privet areas or privet management areas, call out swamp/wetland areas QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:19:40 PM label width QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:20:06 PM what is this line representing? QNumber: 6 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:21:26 PM add a plot to this restoration area since it's privet heavy and we need monitoring date here. QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:20:29 PM update legend and symbology based on comments made previously n �5V a z o � d � o � po po O 8 � - �� rs u .i p G O N e Q N 3 88888 - 4 � 0 0 0 888�8MM 3 a � x u - 0 s a c o ry o n m oo a pa N 2 saf ` c m^ m C vi W ul �� uai N Ya O m w x 55�5555 �mo o — F 2 c� o❑ d d d o d o o 3 N K K O t c b « m M �p L Y a z a 0 .41 i a � a a m a v 2 m — H Y O � � O m � C a V z z a a m � � sa � C �o m F 2 6 N 2 _❑ F � � � m N rn 0 O 5 z Page: 29 QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:14:12 PM this table is hard to compare to the supporting credit figure. QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:14:23 PM check no per the MBI QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:14:34 PM check NO per the MBI QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:11:43 PM move to section 7.0 QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:13:01 PM differentiate Non-ag Riparian Restoration from Ag Riparian Restoration on these rows so that i can tell where the total area is being measured. For the non-ag riparian restoration rows, check "NO" for the "Convertible to Nutrient Offset" column QNumber: 6 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:15:10 PM remove the ft2 that makes up the footprint of the barn QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 12/12/2023 4:11:24 PM change project ID to be version 2