GES_Contentnea_DWRAuditReview

Hartshorn, Blake
From:Hartshorn, Blake
Sent:Wednesday, January 24, 2024 10:25 AM
To:Salina Campbell
Cc:Merritt, Katie
Subject:Results of Contentnea Sales Audit
Attachments:Contentnea Credit ledger.pdf
Good Morning,

DWR has finalized the audit for Nutrient Offset Credit Sales for the Contentnea/Li?le Contentnea (DWR ID 2008-0511v1)
mi?ga?on bank from 1/1/2021 to 12/31/2022 based on the most recent ledger submi?ed to DWR which is a?ached and
dated 1/10/2024. The audit results are provided below and require further ac?on from Greene Environmental Services:
Nitrogen Nutrient Offset Credit Le?er
 No MCTC’s for 2021 and 2022 have a signature by the Provider. For 2024 credit sales and moving
forward, there needs to be a signature on the MCTC template for every transaction. Digital signatures
are acceptable for this requirement. No signature on a MCTC could imply the sale was never validated
or correctly processed by the Provider.

 The HUC location is not provided on transactions from February 5, 2021 to December 31, 2022.
o Action Required:
 Provide the project HUC location along with the project name in the Project w/HUC#
column for ALL transactions

 The amount of credits sold noted in the MCTC and City of Wilson letter for the Storage Central Addition
4001 transaction, with a transaction date of August, 12, 2022, does not correspond with the amount of
pounds of nitrogen shown as being sold on the ledger. The ledger depicts 337.19 pounds were sold, but
the MCTC and City letter both indicate the amount sold and required, respectively, is 377.19 lbs.
o Action Required
 Adjust the amount of sold credits on the ledger from 337.19 to the correct amount of
377.19 and adjust the nutrient balances accordingly.

 The debited amount of the DWR credit release for September 12, 2022 is incorrect. The release letter
was for 16,897.50 amount but the ledger shows 1689.75 amount.
o Action Required:
 Change the amount in Credits Released/ Available to Bank “Pound” column to 16,897.50
pounds per nitrogen and 7.43 acres and adjust the nutrient balances accordingly.

 Carolina Poultry Power Rg2, LLC project name does not match the City of Wilson Letter
o Action Required:
 Update the project name to Carolina Poultry Power Rg2, LLC - CHP Plant
Buffer Credit Ledger
 The debited amount of the DWR credit release for September 12, 2022 is incorrect. The release letter
was for 13721.40 amount but the ledger shows 1372.14 amount.
o Action Required:
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 Change the amount in Credits Release/ Available to Bank “Pound” column to 13,721.40
square feet and 0.32 acres and adjust the buffer balances accordingly.

Once all ac?on items are completed and a summary of all responses to the comments and ac?ons required are provided
to DWR, we can finalize the audit for this Bank.

Blake Hartshorn (he/him)
Mitigation Specialist, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone]
Cell: [phone]
[e-mail]

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