GES_Evans Ballahack_DWRAuditReview

Hartshorn, Blake
From:Hartshorn, Blake
Sent:Friday, March 1, 2024 12:27 PM
To:Salina Campbell
Cc:'Jeff Becker'; Merritt, Katie
Subject:Results of Evans Ballahack Sales Audit
Attachments:Evans Ballahack_Ledger.pdf
Good A?ernoon,
DWR has finalized the audit for Nutrient Offset Credit and Riparian Buffer Credit Sales for the Evans Ballahack (DWR ID
2013-0436v1) 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 Ledger
1. No MCTC documents for 2021 and 2022 credit sales provided to DWR had official signatures 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.

2. Compliance Issue: 8-digit HUC project location was not included on the credit ledger.
o Action Required
 Add the 8 digit HUC of the project location in the “Project w/HUC” column on the credit ledger
for all transactions.
3. Compliance Issue: The City of Greenville is the incorrect government agency listed in the “Gov’t Requiring”
column on the ledger. According to the buydown letter for the Stow and GO Mini storage phase 7 transaction, it
is Pitt County.
o Action Required
 Change the Local Government Requiring to Pitt County which is who provided the buydown
letter.
Phosphorous Nutrient Offset Credit Ledger
1. all credit sale transactions are compliant.
Buffer Credit Ledger
2. No transactions for 1/1/2021 to 12/31/2022. This ledger is currently compliant.

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]
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Cell: [phone]
[e-mail]

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