DWR Plan Review

From:
Merritt, Katie
To:
Menefee -Dunn, Barbara A
Subject:
FW: Georgianna Plan Review
Date:
Monday, March 11, 2024 4:27:49 PM
Attachments:
DWR Comment Summary Georoianna.odf
Hey Barbara,
Please file email thread below into LF along with the ATTACHMENT as 1 PDF. Metadata description is
as follows:
DWR#: 2023-0425 version 2
Doc Date: March 11, 2024
Doc Type: Mitigation Plans
Doc Name: DWR Plan Review
Thank you,
katie
From: Merritt, Katie
Sent: Monday, March 11, 2024 4:24 PM
To: Kaitlyn Hogarth <[e-mail]>
Cc: Hartshorn, Blake <[e-mail]>
Subject: Georgianna Plan Review
Hey Kaitlyn,
Pursuant to Titles 15A NCAC 02B .0703 (e), a provider shall submit a project plan proposal to the
Division for review and approval that includes specific elements of the project. On October 10,
2023, Wildlands Holdings X, LLC (Wildlands) submitted a Nutrient Offset Plan (Plan) for the
Georgianna Site, to the Division, for review and approval. According to the initial review by DWR
staff of the subject Plan, some elements were either not provided, not explained thoroughly, not
accurate or lacking in sufficient information.
Therefore, until DWR receives an updated Plan addressing all comments and edits provided in the
attached 1) comment summary and 2) PDF version of the document itself, DWR cannot finalize the
review of the Plan or issue an approval of the Plan. In an effort to be as efficient as possible at
providing comments to Wildlands during this busy time, I have provided my comments in a unique
format. Attached are the comments & edits provided within the actual PDF of a condensed Plan
(without Appendices) as well as a comment summary.
When Wildlands is ready to submit their final project Plan, please include a summary of all responses
by Wildlands to the DWR comments acknowledging how Wildlands addressed the comments.
Please upload the final Plan using our Mitigation Project Information Upload Form through this link:
https://edocs.deq.nc.gov/Forms/Mitigation Information Upload . Please note the DWR ID# 2023-
0245 (version 2) on all electronic submissions for this project.

Thank you for your patience during this time and if you have any difficulty reading though the
comments or edits please let me know.
Thanks,
Katie
Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
401 & Buffer Permitting Unit
North Carolina Department of Environmental Quality
Office: 919-707-3637
Work Cell: 919-500-0683
Website: https://deq.nc.gov/about/divisions/water-resources/water-quality permitting/401-buffer-
permitting-branch
NEW EMAIL!! katie.merritt(@deq.nc.gov
512 N. Salisbury Street, Raleigh, NC 27620
1617 Mail Service Center, Raleiah, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third
parties by an authorized state official.

Q 1
Nutrient Offset Plan GEORGIAN NAIbITIGATION BANK PARCEL
Wayne County, NC
DWR Project Number 20230245 v.1 a a
Neuse River Basin
October 2023 HUC 03020201
PREPARED BY:
W I LDLA NDS
L KIG I NEER I:aG
Wildlands Engineering, Inc.
312 W Millbrook Road Suite 225
Raleigh, NC 27607
Phone: [phone]
Fax: [phone]

Summary of Comments on Georgianna NOP_DWRedits.pdf
Page: 1
*Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:04:54 PM
FOR NUTRIENT OFFSET ONLY PROJECTS, WE DO NOT USE "MITIGATION" IN THE NAME OR PLAN
Number: 2 Author: kymerritt Subject: Cross -Out Date: 3/11/2024 1:04:30 PM
Number: 3 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 1:04:36 PM
NUTRIENT OFFSET
*Number: 4 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:04:19 PM
change project number to Version 2 instead of version 1
Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:04:23 PM

am
Number: 1 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 1:05:11 PM
Nutrient Offset
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:07:43 PM
once the naming conventions on maps have been updated to reflect the names on the site viability letter, please update those names/labels here
and throughout the Plan where relevant.
Number: 3 Author: kymerritt Subject: Cross -Out Date: 3/11/2024 1:05:45 PM
�Number:4 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 1:06:11 PM
stormwater and agriculture flows
;.Number: 5 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 1:06:27 PM
riparian restoration
ITQ
Number: 6 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 1:06:37 PM
s
It Number: 7 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 1:06:45 PM
nutrient offsets
Number: 8 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 1:06:59 PM
Nutrient Offset

Page: 5
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:08:38 PM
i won't make any more edits to the Plan to remove "mitigation" from the text. But Wildlands need to check the document and remove this word
where it is used.
1+1 Number: 2 Author: kymerritt Subject: Cross -Out Date: 3/11/2024 1:07:56 PM

QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:13:20 PM
modify this to be the 12-digit, 14 digit isn't applicable for Neuse.

am
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:39:16 PM
this culvert was determined to be clogged at Site Viability assessment and preventing aquatic life passage. Identify this as a site constraint and
explain how it will be addressed in Section 4.0
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:39:32 PM
this should likley be section 4.0 but there is no section number
Number: 3 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 1:40:19 PM
Nutrient Offset
QNumber:4 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:41:59 PM
this section is lacking in details. identify culvert removals, culvert maintenance, ripping of any soils (or explain why you aren't manipulating the
soils)....
QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:50:04 PM
if seeding is not planned, then tell me what Wildlands observed as "herbaceous". Detail the observations: Annual? Perennial? grasses, sedges,
crops, rye, etc... Not all herbaceous is good, not all herbacous will thrive or last.
Since Wildlands isn't proposing to seed with pollinator species or any seeding at all, and ag fields can be barren with soils unstable at planting
stage, then DWR needs to know what exactly wildlands saw establishing in June. Otherwise, Wildlands needs to include a seeding proposal to take
place prior to year 1. Every provider proposes a seeding plan, with the exception of Wildlands. Therefore wildlands is required to provide
additional details in this section tojustify not needing to seed the ag fields. Overland flow on barren soils will continue to add nutrients into
streams and other features even after planting hardwood species... therefore, nutrient loading isn't being reduced as quickly or effectively when
there are bare soils lacking in vegetation.

Page: 10
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:51:46 PM
additional details are needed in this section. Explain the min and max widths that will be restored, identify any areas that are not creditable and
explain why (i.e. areas <50 or >200 )
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:52:51 PM
bank stablization measures were identified as necessary during the site viability (see letter) on UT2, but no measures are being described or
proposed. Add this missing information.
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 2:05:14 PM
suggest changing this table with the 8 species to be planted to be Table 8a, with an 8b table showing the 3 substitutions.
QNumber:4 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:55:23 PM
add a column for "Tree/Shrub" and add that information for each species proposed.
QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:54:25 PM
this all adds up to 100%, but only 8 of these 11 are suggested as being planted. Address comment above and change the density associated with
planting the 8 species.
QNumber: 6 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 1:53:44 PM
identify the 8 that will be planted and include which 3 remaining species will be used as substitutions and at what density those 3 would be
substituted if they were needed.
Number: 7 Author: kymerritt Subject: Cross -Out Date: 3/11/2024 2:01:56 PM
Number: 8 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 2:01:59 PM
non
Number: 9 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 2:01:49 PM
The
Number: 10 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 2:01:45 PM
as depicted on Figure 7 are due to...... and are
Number: 11 Author: kymerritt Subject: Cross -Out Date: 3/11/2024 2:02:33 PM
Number: 12 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 2:02:32 PM
. These areas will still be planted but at a
Number: 13 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 2:04:39 PM
Possible substitutions are listed in Table 8b
QNumber: 14 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 2:03:54 PM
add a statement about non -diffused flow here and request to use the clarification memo (use correct reference in MBI template) to address the
non -diffused flow from the ditch/es
QNumber: 15 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 2:00:30 PM
add a seeding plan here in csae it's ever needed and you don't want to have to submit for approval later.
QNumber: 16 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 2:08:16 PM
add language to this section identifying what nutrient offset activities should be completed at this stage:
including adequately marking the easement boundaries, installing all the plots, plantings completed, culvert maintenance complete, culvert
removals, bank stabilization measures...

Page: 11
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 2:10:10 PM
clarify that the number of plots is in fact making up 2 percent of the planted area. What is the total planted area in acres?? According to the
project credit table, it's about 42 acres. are these plots Fixed? Random? Rotating? explain...
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 2:16:06 PM
the monitoring protocol for height and vigor is to record height for each stem in each plot in years 1, 3 and 5. Average vigor per plot is to be
recorded in years 1, 3, and 5. adjust language accordingly. Remember that all other monitoring expectations are the same for years 1-5
consecutively.
ANumber: 3 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 2:15:59 PM
and included in monitoring reports
QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 2:18:02 PM
add language that if there are any encroachments within the conservation easement that are identified during the year, that the Sponsor will notify
DWR promptly, take corrective measures, provided written notification to the landowner (or third party) and included all information in the
monitoring report.

Page: 12
Number: 1 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 2:18:24 PM
initially
Number: 2 Author: kymerritt Subject: Inserted Text Date: 3/11/2024 2:18:39 PM
In accordance with the NOBI,
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:43:51 PM
using the prhase "mitigation activity" is okay here since it's a Column name on the project credit table. But I'd ALL CAPS it as "Mitigation Activity"
QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:42:52 PM
attach this clarification memo to the appendix and reference it here.
QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:48:27 PM
what is going on with Ditch F? The site viability letter didn't address F, is F a ditch? a swale? Did DWR miss this during the site viability? should
the ft2 of the feature's footprint (bank to bank) be deducted from riparian restoration? Is it causing non -diffused flow please explain
QNumber: 6 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:45:47 PM
please add a statement to this section telling DWR how the Total Area you included in the Project Credit Table was measured/quantified. Give us
the technique used to get the ft2. Tell me how your tree lines were measured out (did you use aerial, onsite, etc...

aQ.ble 10: Georgianna Project Credit Taable11
Neuse 03020201- Outside Falls Lake
Project Area a IJ
N Credit Conversion Ratio (ft'/pound) 40
P Credit Conversion Ratio (ft'/pound) a
19.16394
N/A
Total
Subject?
Min -Max
(Creditable)
Initial
Final
Convertible
Riparian
Delivered
Delivered
Credit type
Location
(enter NO if
ephemeral
Feature
Type
Mitigation
Activity
Buffer
Feature Name
Total Area
(ft')
Area of Buffer
Credit
Ratio
%Full
Credit
Credit
Ratio
to Riparian
Buffer
to Nutrient
to
Nutrient
Offset: N
Nutrient
Offset: P
or ditch')
width (ft)
Mitigation
(z:l)
(x:1)
Buffer?
Credits
Offset?
(Ibs)
(Ibs)
(ft2)
Nutrient Offset
Rural
Yes
UP
Restoration
0-100
UT1, UT2
402,363
1
100%
No
—
Yes
20,995,839
—
Nutrient Offset
Rural
Yes
I/P
Restoration
101-200
UT1, UT2
340,542
1
33%
No
—
Yes
17,769.937
—
Nutrient Offset
Rural
No
UP
Restoration
0-100
UT3
284,896
1
100%
No
—
Yes
14,866.254
—
Nutrient Offset
Rural
No
I/P
Restoration
101-200
UT3
200,271
1
33%
No
—
Yes
10,450.356
—
Nutrient Offset
Rural
No
Ephemeral
Restoration
0-100
UT3
98,845
1
100%
No
—
Yes
4,636.051
—
Nutrient Offset
Rural
No
Ephemeral
Restoration
101-200
UT3
72,525
1
33%
No
—
Yes
3,784.451
—
Nutrient Offset
Rural
No
Ditch
Restoration
0-100
Ditch A, Ditch B,
264,042
1
100%
No
—
Yes
13,778.064
—
Ditch C, Ditch D
Ditch A, Ditch B,
Nutrient Offset
Rural
No
Ditch
Restoration
101-200
Ditch C, Ditch D
187,905
1
33%
No
—
Yes
9,805.134
—
Diffused Flaw
5
Nutrient Offset
Rural
No
Ditch
Restoration
101-200
__
Deductions-
9754
1
33%
No
—
No
—
—
Ditch B, Ditch D,
Ditch E
Totals(ft2):
1,951,143
0
0.000 96,086.138 0.000
Total Buffer
(ft2):
o
0
Total Nutrient
Offset (ft2):
1,851,143
N/A
Total Ephemeral Area (ft') 0 0
for Credit:
Total Eligible Ephemeral 0 0.0% Ephemeral Reaches as %TABM
Area (ft
Enter Preservation Credits Below Total Eligible for 0 0.0% Preservation as %TABM
Preservation Ift21:
Min -Max
Total (Creditable)
Credit Type
LocationSubjectT
Feature
Mitigation
Buffer
Feature Name
Total Area
Area for Buffer
Initial Credit Ratio
%Full Credit
Final Credit
Riparian Buffer Credits
Type
Activity
width (ft)
15f)
Mitigation (ft')
Ratio Iz:l)
Preservation Area
Subtotals (ft'):
WGeorgianna Mitigation Bank Parcel Nutrient Offset Plan
HUC 03020201 Page 10 October 2023

Page: 13
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:49:07 PM
please use the revised project credit table i provided you via email to test out the nutrient offset credits.
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:49:32 PM
this table is called out as Table 9 in the T.O.0
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:51:30 PM
you should be able to combine all streams intojust 2 categories ( 0-100 and 101-200)
you should be able to combine al ephemeral intojust 2 categories (0-100 & 101-200)
you should be able to combine all ditches into 2 categories (0-100, & 101-200)
QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:50:04 PM
see comments on figures and change the names of the features to match what is in the viability letter.
QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:52:23 PM
need to show a row for any planted area that is not receiving credit based on being less than 50'

Page: 14
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:52:51 PM
this is Table 10 in the TOC

Q Project Location
.w
---� Bank Parcel Conservation
r°-- Easement
� r
r" Ingress/Egress Easement
r Project Stream
' 0 ; Project Ephemeral
Channel
Project Ditch
r
Non -Project Ditch
i
Non -Project Stream
r i Existing Culverts
w
a r
.r A
R
N�
}
uY
1
M
1
4
M'
Existing Culvert
!�
"
to he Removed re'
'�`"
'�
'
Existing Culvert
_
to be Removed
wW I L D L A N D S 0 200 400 Feet
ENGINEERING I I I I I
Figure 3. Site IVY
Georgianna Mitigation Bank Parcel
Nutrient Offset Plan
Neuse River Basin (03020201)
Wayne County, NC

QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:54:29 PM
this is the culvert that was determined to be clogged. add a note here
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:57:48 PM
this ditch was labeled as Da in the site viability letter add that label here
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:59:39 PM
change all feature names to match exactly as they are in the site viability letter and update the text of the Plan and all other figures to match. for
example: Ditch C should be Cb and Ditch G is Ca
QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:57:25 PM
Ditch G is shown as Pink, Purple then black. explain
QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:56:01 PM
add intermittent origins of this reach (see stream call letter)
QNumber: 6 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:55:42 PM
add ephemeral origin point
QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:55:18 PM
QNumber: 8 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:59:00 PM
add a call out here to note that existing conditions include a sink hole and bank erosion. see site viability letter.
QNumber: 9 Author: kymerritt Subject: Sticky Note Date: 3/11/2024 3:59:22 PM
change to "Existing Conditions Map". There should also be a figure in the Plan representing existing conditions which are also described in the
text of the Plan

Project Location
Bank Parcel Conservation
��-- Easement
S Ingress/Egress Easement
Project Stream
u� Project Ephemeral Channel
r
I'��►"
l
v,
l
- Project Ditch
Non -Project Ditch
i
Riparian Restoration for Nutrient
Offset Credits (0'-100')
Riparian Restoration for Nutrient
"
Offset Credits (101' - 200')
Riparian Restoration for Nutrient
Offset Credits (0'-100') - Ephemeral
s
Riparian Restoration for Nutrient
7,:
Offset Credits (101'-200') -
IIiI.•
Ephemeral
Diffuse F€ _
+
Not For Credit a
r
�I
C, Proposed Planting Area a
ex�st�nq Culvert
Non -Project Stream
to be Removed
.... Surveyed Treeline
a Existing Culverts
4V
,IS
V
+1
_ I
Existing Culvert)
to be Removed
Existing Culvert
to be Removed,_.
0 200 400 Feet
kVW1LDLANDS
ENGINEERING I I I I I t
Figure 7. Project Credits Map
Georgianna Mitigation Bank Parcel
Nutrient Offset Plan
Neuse River Basin (03020201)
Wayne County, NC

Page: 22
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/20244:03:11 PM
please draw an arrow pointing to the specific spot <50'
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 3/11/20244:01:03 PM
this should actually be called "non -diffused flow" deduction
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 3/11/20244:00:39 PM
add (<50' or >200) if that is the reason the gray areas are not for credit.
QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 3/11/20244:06:07 PM
this area is shown with blue polka dots on the hard copy, but it isn't showing up with blue polka dots here. it could be a problem with the
electronic upload on our end, butjust make sure it is showing up with the polka dots when you upload the final.
QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 3/11/20244:04:36 PM
is this a ditch? i don't remember this feature during the site viability assessment. Explain.
QNumber: 6 Author: kymerritt Subject: Sticky Note Date: 3/11/20244:03:17 PM
please draw an arrow pointing to the specific spot <50'
QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 3/11/20244:02:42 PM
make sure this area is also shown on a row in the project credit table. Prefer the Feature Name on that table for that row be "UT1, UT3 (<50')

a,.
E�
WILDLANDS
k &V ENGINEERING
Q Project Location
r---+ Bank Parcel Conservation
---• Easement
Ingress/Egress Easement
Project Stream
Project Ephemeral Channel
Project Ditch
Non -Project Ditch
Riparian Restoration for Nutrient
Offset Credits (0'-100')
Riparian Restoration for Nutrient
Offset Credits (101' - 200')
Riparian Restoration for Nutrient
Offset Credits (0'-100') - Ephemeral
Riparian Restoration for Nutrient
Offset Credits (101'-200') -
Ephemeral
Diffuse Flow
Not For Credit
50' from Top of Bank
100' from Top of Bank
200' from Top of Bank
Non -Project Stream
Figure S. Riparian Buffer Zones Map
Georgianna Mitigation Bank Parcel
Nutrient Offset Plan
Neuse River Basin (03020201)
Wayne County, NC

Page: 24
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 3/11/20244:12:12 PM
the way you have the maps showing credit assets within 0-100 and 101-200 is fine, as long as you use the new project credit table I gave you for
nutrient offset only projects. Otherwise, you'd have to have a different color representing the Nutrient Offset credits measured off ditches vs
streams and from Subject streams (UT1,UT2) vs non -subject streams (UT3). If this site were being proposed for Buffer, you would have to have
these features represented differently. The nutrient offset project credit table should also help keep the survey for asbuilt alot simpler. Let me
know if you run into any errors.
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 3/11/20244:09:14 PM
confirm that this ditch is directly connected to Da. I don't remember, and the figure you submitted for the Site Viability doesn't show Da
connected to Ditch B. If it is found to NOT be connected, remove teh credit deduction for non -diffused flow... otherwise, leave it in.