20221617 Ver 2_More Info Requested_20240123

Homewood, Sue
From:
Homewood, Sue
Sent:
Tuesday, January 23, 2024 8:40 AM
To:
Harbour, Jeff W
Cc:
Martin, Matthew K CIV CESAW
Subject:
RE: [External] RE: Request for Additional Information for Eastfield Development -
Johnston County - DWR#20221617v2
Jeff,
DWR has reviewed the response to our request for additional information and the buffer restoration plan. We have a
few final comments and questions:
Specific to the Buffer Restoration Plan:
1. Please clarify when buffer restoration activities are proposed to be conducted. Note that the schedule should
address the appropriate tree planting season.
2. Section 3.0 of the Buffer Restoration Plan states that "Within one year after NCDWR approval of the restoration
plan the application will provide documentation of restoration". DWR appreciates that your plan follows the
protocol set out in the Consolidated Buffer Mitigation Rule 15A NCAC 2B .0295, however the rule was developed
for mitigation sites and not all aspects are applicable/appropriate for violation restoration activities. As such,
DWR requires that the restoration be conducted as soon as possible and DWR be notified immediately upon
completion.
3. Section 3.0 also states that the success criteria for the buffer restoration is to be 361 living and viable
stems. While this total number may be in accordance with the overall density requirement, DWR will evaluate
the buffer density within the restoration area, and if there are any portions of the buffer where DWR
determines the restoration to be unsuccessful the permittee will be required to develop a remediation plan,
regardless of the overall total number of stems throughout the entire project.
4. Section 4.0 of the Buffer Restoration Plan states that the applicant will notify future landowners of buffer
restrictions and maintenance requirements. Please clarify if the applicant expects that the property will be
sold/transferred to another owner within the proposed monitoring period.
5. DWR requests that the applicant provide that they will record deed notifications of the buffers on all applicable
lots within Block E with reference to the Neuse Buffer Rules.
6. Section 4.0 states that noxious and/or invasive vegetation will be managed. The Neuse Buffer Rules require that
the buffer be maintained in vegetation therefore mulch and weed control fabrics and herbicide are not generally
appropriate because they will prevent all herbaceous vegetation which is an important aspect of a stable,
functioning buffer. The Buffer Restoration Plan proposes stabilization with temporary herbaceous vegetation
which DWR agrees is essential. DWR typically recommends complete removal and control of invasive species
prior to buffer restoration. DWR recommends that the area be evaluated for invasive species prior to initiating
the buffer restoration and invasive control be conducted if necessary prior to planting. Please modify Section
4.0 to either include a species specific invasive removal plan, such as spot treatment/removal only, or a general
invasive control plan that will retain native vegetation within the buffer to the maximum extent. Please refrain
from using the word "weed" within the revision.
General comments:
1. The area circled in red below shows development right up to the edge of the buffer. Can you please verify that
this parking area will not require a shoulder/fill slope or other construction support that would potentially
encroach into the buffer at this location.

l/
Lastly, you may want to consider confirming with private mitigation banks that wetland credits are still available before
DWR issues any final approvals, this can avoid the need for modifications later.
Thanks,
Sue Homewood (she/her/hers)
401 & Buffer Permitting Branch
Division of Water Resources
[e-mail] please note my new email address
336 813 1863 mobile
919-707-3679 office
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Harbour, Jeff W <[e-mail]>
Sent: Tuesday, January 2, 2024 10:09 AM
N