20231113 Ver 1_RE: Rockingham Quarry

Fyi.

Thanks,

Sue Homewood (she/her/hers)

401 & Buffer Permitting Branch
Division of Water Resources
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From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, January 2, 2024 2:52 PM
To: Homewood, Sue <[e-mail]>
Cc: Harmon, Richard G CIV SAW <[e-mail]>
Subject: RE: [External] RE: Rockingham Quarry

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Hi Sue, it doesn’t look like we Cc’d anyone from NCDWR on our comments but I’ve included them here. I’ve attached our Mit Team’s comments, and included a couple of additional ones below:

I think I had one previous comment on the financial section to remove the UMBI reference. However, I just noticed that the total endowment specified by BWI for $56,826 in Appendix J
doesn’t match the total included by Davey/RS in Section 11 for $50,529. It appears that the $50,529 is a carryover by Davey/RS from Hood Swamp mitigation plan narrative, which should
be reviewed and updated as needed.

For Turkey Hill, Davey/RS used the District’s current conservation easement template (rev. March 2020). They made edits in track changes primarily related to the site being PRM and not
a Bank. A nitpicky thing I noticed was the addition of “or” in the page 2 list and top of page 3 paragraph, which I don’t understand. The one change I would not feel comfortable accepting
without Carl’s review is the code changes referenced on page 8, in article VI.C.

I have not looked at the calculations for how the endowment amount was determined, but recommend that RS/Davey lay out in some detail how they reached the requested endowment amount,
including some basic line items for annual or other expenses, capitalization rate, etc. In general, the bottom line is that if BWI is confident that they can steward the site and it
meets our expectations, that would address our main concerns.

There were a few others from Office of Counsel that were specific to the property documents which I did not include.

Hopefully this helps, and my apologies for not including you earlier!

-Dave Bailey

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