GES_LaGrangePhase2_DWRAuditReview

Hartshorn, Blake
From:Hartshorn, Blake
Sent:Friday, March 1, 2024 11:46 AM
To:Salina Campbell
Cc:'Jeff Becker'; Merritt, Katie
Subject:Results of LaGrange Phase 2 Sales Audit
Attachments:LaGrange Phase 2 Ledger.pdf
Good A?ernoon,

DWR has finalized the audit for Nutrient Offset Credit Sales for the LaGrange Phase 2 (DWR ID 2008-0511v3) 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
2/10/2024. The audit results are provided below and require further ac?on from Greene Environmental Services:

Overall Comment: For the DWR credit releases, include the Task#, percentage, and if partial. This can be
added in the “Project w/HUC” column.

Nitrogen Nutrient Offset Credit Le?er
1. Compliance Issue: No MCTC documents for 2021 and 2022 credit sales provided to DWR in the Audit
Packets had official signatures by the GES. For 2024 credit sales and moving forward, there needs to be
a signature on all MCTC documents 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. MCTCs that are not signed for credit sale transactions will not be considered
compliant and may result in credit refunds being required.

2. Compliance Issue: 8-digit HUC locations of the credit sale transactions were not noted on the ledger for
any of the 2021/2022 sales.
o Action Required
 Put the 8-digit HUC project location along with the project name in the “Project w/HUC
#” column for all transactions

3. Compliance issue: The Precision Tune Autocare transaction is Not Compliant. The MCTC indicates a sale date
of August 23, 2021. The credit ledger indicates February 17, 2021. As a default, the ledger date should
always be the sale date shown on the MCTC.
o Action Required
 Change sale date of Precision Tune Auto Care to a sale date of August 23, 2021, on the credit
ledger as indicated in the MCTC. Move the row to below the DWR credit release that was
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issued on August 10, 2021. The credit balances will need to be adjusted accordingly.

4. Compliance issue: The Precision Tune Autocare transaction is Not Compliant. The ledger does not indicate
that it is a Partial credit sale as indicated on the MCTC nor does it have the address as indicated on the
buydown letter.
o Action Required
 In the Project w/ HUC# column, change transaction to read, “Precision Tune Autocare - HUC
03020202 – Partial”

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5. Compliance Issue: The Dunhagan Apartments transaction MCTC indicates a sale date of September 21, 2021.
The credit ledger indicates August 23, 2021. As a default, the ledger date should always be the sale date
shown on the MCTC.
o Action Required
 Change the sale date of Dunhagan Apartments to a sale date of September 21, 2021 on the
credit ledger as indicated in the MCTC. Ensure the transaction are in chronological order by
date. The credit balances will need to be adjusted accordingly.

6. Compliance Issue: The Hawthorn Place transaction was a Partial sale as indicated by the MCTC but is not
shown as a Partial credit sale on the credit ledger.
o Action Required
 Add “partial” along with the project name.
7. Compliance Issue: The MCTC for the Hawthorne Place transaction has a date of August 23, 2021. The credit
ledger indicates September 21, 2021. As a default, the ledger date should always be the sale date shown on
the MCTC.
o Action Required:
 Correct the credit ledger to 8/23/2021 and make sure transactions are in chronological
order after making the edit.
Buffer Credit Ledger

Compliant- no comments

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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