20220112 Ver 3_Bonsai 20220112v1 NOBMP Draft_20240315

Prepared By:
Nutrient Offset and Buffer Mitigation Plan
Bonsai Mitigation Site
Edgecombe County, North Carolina
Tar -Pamlico Basin HUC 03020101
NCDWR No. 20220112 V1
Prepared For: NC Department of Environmental Quality
Division of Water Resources
At
ecoterra
Eco Terra, LLC
117 Centrewest Court
Cary, NC 27513
409.913.0020
1617 Mail Service Center
Raleigh, NC 27699-1617
March 2024
•;i
`►sV I b
VHB Engineering NC, P.C.
940 Main Campus Dr. Ste. 500
Raleigh, NC 27606
919.754.5019

Table of Contents
1.0 Introduction...............................................................................................................................
2.0 Mitigation Project Summary...................................................................................................
2.1 Project Goals.........................................................................................................................
2.2 Existing Parcel Conditions...................................................................................................
2.3 Site Viability...........................................................................................................................
2.4 Watershed Characterization................................................................................................
2.5 Soils........................................................................................................................................
2.6 Existing Vegetative Communities.......................................................................................
2.7 Threatened and Endangered Species................................................................................
2.8 Cultural Resources................................................................................................................
2.9 Jurisdictional Resources -Clean Water Act Sections 404/401..........................................
2.10 FEMA Floodplain Compliance.............................................................................................
2.11 Site Access, Utilities, and Site Constraints.........................................................................
3.0 Site Protection Instrument.......................................................................................................
4.0 Mitigation Work Plan...............................................................................................................
4.1 Parcel Preparation................................................................................................................
4.2 Restoration Activities............................................................................................................
4.3 NCDWR As -Built Evaluation................................................................................................
5.0 Monitoring and Maintenance Plan.........................................................................................
5.1 Monitoring Protocol.............................................................................................................
5.2 Adaptive Management Plan................................................................................................
6.0 Financial Assurance and Long -Term Management..............................................................
6.1 Financial Assurances.............................................................................................................
6.2 Long Term Management Plan............................................................................................
7.0 Project Credits and Credit Release.........................................................................................
8.0 References.......................................................................................................................................

Figures
Figure 1.
Vicinity Map
Figure 2.
Credit Service Area
Figure 3.
Existing Conditions
Figure 4.
USGS Topographic
Figure 5.
Drainage Areas
Figure 6.
NRCS 1979 Soil Survey
Figure 7.
Mitigation Credit
Figure 8.
Riparian Buffer Zones
Figure 9.
Monitoring Plan
Tables
Table 1.
Project Goals and Objectives
Table 2.
Feature Description
Table 3.
Project Attributes
Table 4.
Project Features
Table 5.
Drainage Area and Associated Land Use
Table 6.
Soil Types and Descriptions
Table 7.
Potential Federally Protected Species at the Site
Table 8.
Site Protection Instrument
Table 9.
Proposed Planting Plan
Table 10.
Project Credit Tables
Table 11.
Credit Release Schedule
Appendices
Appendix A. Site Photographs- February 26, 2024
Appendix B. Historical Aerials
Appendix C. On -Site Determination of Applicability to the Tar -Pam River Basin Buffer
Rules - April 7, 2022
Site Viability for Buffer Mitigation and Nutrient Offset Letter -
August 23, 2022
Appendix D. USFWS Self -Certification Concurrence Email
SHPO Request for Review and Response
Appendix E. EDR Radius Map Report - Executive Summary
Appendix F. Long -Term Stewardship

1.0 Introduction
Eco Terra, LLC proposes to provide buffer and nutrient offset mitigation within the 22.8-acre
Bonsai Mitigation Site in Edgecombe County, NC, hereinafter referred to as the Project or Site.
This Nutrient Offset and Buffer Mitigation Plan (NOBMP) is developed for the Project and covers
approximately 22.8 acres of proposed conservation easement under the proposed Bonsai -
Umbrella Mitigation Banking Instrument (UMBI). The UMBI is being established between Eco
Terra, LLC (Eco Terra) and the NC Division of Water Resources (NCDWR). The Bonsai Site is located
approximately seven miles northeast of Rocky Mount (Figure 1). This Project will provide riparian
buffer credits and nutrient offset credits for unavoidable impacts due to development in the Tar -
Pamlico River Basin, US Geological Survey (USGS) 8-digit hydrologic unit code (HUC) 03020101
(Tar -Pam 01) (Figure 2). The NOBMP is in accordance with the Mitigation Program Requirements
for Protection and Maintenance of Riparian Buffers Rule 15A NCAC 02B .0295 (Consolidated
Mitigation Rule) and Nutrient Offset Credit Trading Rule 15A NCAC 02B .0703.
To access the Project from Raleigh, take 1-40 East and continue on to 1-87 and US-64 East towards
Rocky Mount. Continue on US-64 East approximately 57 miles to Exit 470 for NC-97/Atlantic Ave.
Head north on NC-97/Atlantic Ave and then turn right onto NC-97/Cool Springs Road at the T-
intersection. Proceed approximately 2.5 miles, turn left onto Cool Springs Road, and travel
approximately two miles before turning right onto Battleboro-Leggett Road. Once on Battleboro-
Leggett Road, the entrance to the Site is approximately 2.3 miles on the right. The Site coordinates
are 35.999523,-77.682193. The areas proposed for riparian buffer and nutrient offset credits are
located along one jurisdictional stream and four ditches. Proposed buffers extend a minimum of
30-feet outward from the top of bank JOB) and do not extend beyond 200 feet from viable
features.
2.0 Mitigation Project Summary
The Project will help to reduce future sediment and nutrient loading associated with one unnamed
tributary (UT) to Falling Run. It will also improve terrestrial habitats along four ditches by
establishing forested buffers that will help to reduce and filter surface runoff from the surrounding
fields. The Project will restore forested buffers to a maximum of 200 feet from the TOB.
2.1 Project Goals
The primary goal of the Site is to provide ecological and water quality enhancements to the Tar -
Pamlico River Basin by restoring riparian areas to expand the riparian corridor along two UTs to
Falling Run and the associated ditches. The proposed project supports goals identified in the 2018
Tar -Pamlico River Basin Restoration Priorities (RBRP) by promoting "nutrient and sediment
reduction in agricultural areas by restoring and preserving wetlands, streams, and riparian
buffers." Table 1 lists the specific enhancements to water quality and the ecological process.
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Table 1: Project Goals and Objectives
Goal
Objectives
CU-Wide and RBRP
Supported Goals
Nutrient inputs will be significantly decreased
Promote nutrient and
by changing the overall land use from
sediment reduction in
Reduce nutrient
agriculture/pasture to forest. As a result,
agricultural areas by restoring
levels
runoff will be filtered through re-established
and preserving riparian
buffer areas.
buffers.
Promote nutrient and
Decrease sediment
Benefits will be achieved via the reduction of
sediment reduction in
sediments from agricultural areas due to
agricultural areas by restoring
inputs
continuous maintenance and disturbance.
and preserving riparian
buffers.
Benefits will be achieved through the
Promote nutrient and
Preserve/restore
restoration and preservation of buffer areas
sediment reduction in
streams, wetlands,
allowing for increased infiltration and nutrient
agricultural areas by restoring
and riparian buffers
uptake during precipitation events.
and preserving riparian
buffers.
Continue targeted
Protect property in
Record a conservation easement.
implementation of projects
perpetuity
under the Buffer programs.
Benefits will be achieved by restoring riparian
buffer habitats to functioning headwater and
D programmatic goal,
Restore terrestrial
bottomland hardwood forest ecosystems.
Nortthh Carolina Genera( Statue
habitats
These restored habitats will connect to
habitats both up and downstream of the
143-214.10
restored/enhanced areas.
2.2 Existing Parcel Conditions
The conservation easement associated with the Project covers approximately 22.8 acres and
consists of agricultural fields, four ditches (identified and labeled as D12, D13B, D14, and D15),
and one UT to Falling Run (denoted as SE) (Figure 3 & Appendix Q. Evidence of livestock
management and alteration of the hydrologic regime for agriculture occurs throughout the entire
Project area. Currently, the fields are being used for row crop production. Surface and
groundwater quickly move across the Site via a well -developed system for conveyance. This water
continues flowing towards Falling Run, a tributary of Beech Branch and the Tar River (Figure 4).
The Project exhibits approximately 1,030 linear feet of jurisdictional stream channel and 2,650
linear feet of ditches. Table 2 describes these attributes in detail.
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Table 2: Feature Description
Resource ID
Resource Type
Length
(linear feet)
Jurisdictional
Connection
SE
Stream
1,030
Falling Run
D12
Ditch
592
SE
D13B
Ditch
898
SE
D14
Ditch
500
SE
D15
Ditch
660
SE
Table 3: Project Attributes
Project Watershed
Summary Information
Project Name
Bonsai Mitigation Site
Geographic Location (Lat, Long)
35.999523,-77.682193
River Basin
Tar -Pamlico
USGS HUC (8-digit, 12-digit)
03020101, 030201010902
Site Protection Instrument
To be recorded
Total Credits
444,808 RBCs, 21,637 Ibs of N, 1,393 Ibs of P
Types of Credits
Riparian Buffer and Nutrient Offset
NOBMP Date
March 2024
Initial Planting Date
February 2025
Baseline Report Date
March 2025
MY1 Report Date
December 2025
MY2 Report Date
December 2026
MY 3 Report Date
December 2027
MY4 Report Date
December 2028
MY5 Report Date
December 2029
2.3 Site Viability
A representative from the NCDWR met on -site with Eco Terra personnel on February 28, 2022, to
assess applicable stream origins of Site resources across the entire Falling Run Mitigation Site.
An official Stream Origin Determination Letter was issued on April 7, 2022. NCDWR performed a
second site visit on June 8, 2022, to determine the Site's viability for riparian buffer and nutrient
offset mitigation. Eco Terra received the Site Viability Letter on August 23, 2022. Both documents
cover the entire 133-acre proposed easement area. According to NCDWR, 17 ditches were
deemed suitable for riparian buffer and/or nutrient offset credits pursuant to 15A NCAC 02B .0295.
There have been no changes to land use since NCDWR's site visit in June 2022. Copies of both
NCDWR letters are included in Appendix C and those resources applicable to the Project are
summarized in Table 4.
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Table 4: Project Features
Resource ID
Classification
Buffer Credit Viable'
Nutrient Offset Viable"
SE
C; NSW
Yes
Yes
D12
N/A
Yes
Yes
D13B
N/A
Yes
Yes
D14
N/A
Yes
Yes
D15
N/A
Yes
Yes
'Must follow requirements stated in NCDWR Letter dated 8/23/2022
2.4 Watershed Characterization
The Site is located in the 12-digit HUC 030201010902 and NCDWR Subbasin 03020101. All runoff
from the Site flows toward Falling Run. Falling Run is classified by NCDWR as C; NSW. The
watershed is dominated by agricultural land and forested areas (Figure 3). There is minimal
impervious surface. This subbasin is expected to experience significant population growth due to
its proximity to Wake County. Figure 4 depicts topography at the Site and its surrounding areas.
Based on elevations presented on the Hartsease and Whitakers, NC US Geological Survey (USGS)
7.5-minute topographic quadrangles, topography gently slopes to the southeast towards the Tar
River. Table 5 details the drainage area and landuse of Stream E and the ditches.
Table 5: Drainage Areas and Associated Land Use
Resource
ID
Drainage Area
acres
Drainage Area
S .ft.
Land Use
SE
205
8,929,800
Planted row crops (96%), solar panels (4%)
D12*
5.45
237,552
Planted row crops (100%)
D13B*
6.73
293,028
Planted row crops (100%)
D14*
1 3.97
1 172,867
1 Planted row crops (100%)
D15*
1 3.55
1 154,735
1 Planted row crops (100%)
* Riparian buffer restoration credits were derived as no greater than a quarter of the drainage area in
square feet as required by 15A NCAC 02B .0295 (8)(o).
2.5 Soils
The Site soils are mapped on the 1979 Natural Resources Conservation Service Soil Survey as
Altavista fine sandy loam, Cape Fear loam, and State loamy sand. Table 6 provides general
descriptions of each map unit.
Table 6: Soil Types and Descriptions
Soil Series Name
Description
Altavista fine sandy loam consists of well drained soils on smooth flats and
AaA-Altavista fine sandy
low ridges and shallow areas in stream terraces. Permeability is moderate
loam, 0-3% slopes
and surface runoff is moderately high. Seasonal high-water table is at 1.5
to 2.5 feet during late winter and early spring.
Ca -Cape Fear loam, 0-4%
Cape Fear loam consists of very poorly drained soil on broad flats and
slopes
slightly depressional drainageways in the Coastal Plain. Seasonal high-
water table is at or near the surface for several months a year.
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Soil Series Name
Description
State loamy sand consists of well -drained soil on smooth to slightly
StB-State loamy sand, 0-
rounded, low ridges on stream terraces. Permeability is moderate to
4% slopes
moderately rapid and surface runoff is moderate. Seasonal high-water
table is at a depth of 6 feet or greater.
2.6 Existing Vegetative Communities
Row crop vegetation serves as the dominant vegetative community across the Site. The current
crop is soybeans. Less frequently maintained areas such as field edges and drainages consist
primarily of early successional vegetation. American pokeweed (Phytolacca americana) and other
various early successional weeds are common. There are several small areas exhibiting canopy
vegetation along the top of banks of the ditches and tributaries outside this Project. Trees
observed were loblolly pine (Pinus taeda), willow oak (Quercus phellos), and sweet gum
(Liquidambar styraciflua). The understory and herbaceous layer of these limited areas consists of
smaller sweetgum saplings, sea myrtle (Baccharis halimifolia), poison -ivy (Toxicodendron radicans),
peppervine (Ampelopsis arborea), blackberry (Rubus pensilvanicus), common greenbrier (Smilax
rotundifolia), Virginia creeper (Parthenocissus quinquefolia), and Chinese privet (Ligustrum
sinense).
Stream channels possess emergent vegetation such as cattails (Typha latifolia), pennywort
(Hydrocotyle vulgaris), parrot's feather (Myriophyllum aquaticum), and soft rush (Juncus effusus).
The ditches throughout the Project are less diverse, exhibiting only soft rush and bulbous
buttercup (Ranunculus bulbosus).
2.7 Threatened and Endangered Species
The US Fish and Wildlife Service (USFWS) Information for Planning and Consultation (IPaC) website
was checked on February 14, 2024. Three federally protected species, one proposed endangered,
and one proposed threatened were listed as potentially occurring on the Site. Additionally, a NC
Natural Heritage Program (NHP) data explorer report reviewed on February 14, 2024, identified
one federally protected species, bald eagle, occurring within one mile of the Site (Table 7).
The Bald and Golden Eagle Protection Act is enforced by the USWFS. Habitat for the bald eagle
primarily consists of mature forests that are in proximity to large bodies of water for forage.
Nesting sites are typically found in large dominant trees within 1.0 mile of a large body of water.
A desktop-GIS assessment of the conservation easement area, as well as the area within a 1.0-
mile radius of the Project limits was performed using 2021 color aerials. There are no water bodies
large enough to be considered potential feeding sources within the easement area or within 1.0-
mile of the Project limits. There are no large trees within the Project that are suitable for nesting.
Due to the lack of habitat and minimal impact anticipated with this mitigation site, it has been
determined that this project will have no effect on this species.
In an e-mail response dated August 2, 2022 (Appendix D), the USFWS concurred with the
proposed biological conclusions submitted in a self -certification request for this project. An
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updated self -certification request was submitted on February 15, 2024. An updated concurrence
email will be provided if one is received.
Table 7: Potential Federally Protected Species at the Site*
Federal
HabitatStatus
Scientific Name
Common Name
Biological Conclusion
Present
Halioeetus
Bald eagle
BGPA
No
No Eagle Act Permit
leucocepholus
Required
Perimyotis subflavus
Tricolored bat
Proposed
No
Not Required
Endangered
May Affect, Not Likelyog
Necturus lewisi
Neuse River waterd
Threatened
No
to Adversely Affect
Noturus furiosus
Carolina madtom
Endangered
No
No Effect
Fusconaia masoni
Atlantic pigtoe
Threatened
No
No Effect
Lasmigona subviridis
Green floater
Proposed
No
Not Required
Threatened
*Checked study area in USFWS IPaC on February 14, 2024.
2.8 Cultural Resources
A review of the NC State Historic Preservation Office (SHPO) database (accessed February 14,
2024) was conducted for compliance with Section 106 of the National Historic Preservation Act.
The database did not reveal any historic properties located within one mile of the Site listed on or
eligible for listing on the National Register of Historic Places (NRHP). Additionally, a scoping letter
response from SHPO dated September 14, 2022, indicated no historic properties would be
affected (Appendix D).
2.9 Jurisdictional Resources -Clean Water Act Sections 404/401
A preliminary jurisdictional determination (PJD) site visit has not been conducted by the US Army
Corps of Engineers (USACE). NCDWR staff has been on -site to verify which features are subject
to the Tar -Pamlico Riparian Buffer Rules and which can provide riparian buffer and nutrient offset
mitigation credits (Appendix Q. Implementation of this project will not fill or impact any Waters
of the United States; therefore, no Section 404 or 401 permits will be required.
2.10 FEMA Floodplain Compliance
The Site is located in the 100 Year Floodplain of Swift Creek. A floodplain development permit will
be submitted to the Edgecombe County Floodplain Manager once the conservation easement is
recorded. Proposed implementation of work will not commence until all required permits have
been received. The Site is within one FEMA regulated area as shown on DFIRMS 3720389200K and
3720388200K. The site occurs in Zone AE.
2.11 Site Access, Utilities, and Site Constraints
An EDR Radius Map Report with GeoCheck was requested for the entire parcel through
Environmental Data Resources, Inc on May 5, 2022. The Federal, State, and Tribal environmental
databases list three records that occur within 0.25 miles of the Site, including one leaking
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underground storage tank 0.185 miles from the Site, one underground storage tank located 0.217
miles from the Site, and one US mine located 0.003 miles from the Site. The executive summary
of the EDR report is included in Appendix D.
There are no known utility easements that will interfere with the implementation of the riparian
buffer restoration. There are no proposed crossings within the easement.
3.0 Site Protection Instrument
The land required for planting, management, and stewardship of the Site includes portions of the
parcels listed in Table 8. The parcels will remain in private ownership with a portion protected by
a conservation easement. The stewardship of the conservation easement will transfer to a NCDWR
approved long-term stewardship group and will be managed under the terms detailed in the
approved NCDWR conservation easement.
Table 8: Site Protection Instrument
Deed Book
Site Protection
Protected
Landowner
PIN
County
and Page
Instrument
Acreage
Number*
3882-90-
Conservation
Edgecombe
1622/0239
0.67
Bonsai Mitigation, LLC
0327
Easement
3892-02-
Conservation
Edgecombe
0846/0445
22.13
6539
Easement
*The Conservation Easement Deed Book and Page Number will be determined at the time of recording
4.0 Mitigation Work Plan
The Project will restore a forested area on land that has been impacted by agriculture. The restored
riparian buffers and nutrient offset planting will improve the water quality of downstream
receiving waters. Project implementation will generate riparian buffer and nutrient offset credits.
The riparian buffer and nutrient offset restoration areas are shown on Figures 7 and 8.
4.1 Parcel Preparation
Site preparation may include soil sampling to determine if soil amendments are needed for
successful establishment of a forested riparian buffer. Soil amendments may be applied, and
invasive species will be treated as needed across the Site.
4.2 Restoration Activities
The Site will be planted with appropriate native hardwood tree species. Vegetation management
and herbicide applications may be needed in the first three years to prevent invasive species and
promote the establishment of planted hardwood trees. The target community type is Coastal
Plain Small Stream Swamp (Schafale, 2023). Tree species and permanent seed mix planted across
the Site will potentially include the species listed below in Table 9.
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Table 9: Proposed Planting Plan
Scientific Name
Common Name
Density
Spacing
Strata
Betula ni ra
River birch
5%
10 X 8
Canopy
Celtis laevigato
Sugarberry
2%
10 X 8
Canopy
Diospyros vir iniana
Common persimmon
5%
10 X 8
Understory
Froxinus pennsylvanica
Green ash
2%
10 X 8
Canopy
Liriodendron tuli ifera
Yellow poplar
5%
10 X 8
Canopy
Magnolia virginiona
Sweetbay
5%
10 X 8
Understory
N ssa biflora
Swamp tupelo
5%
10 X 8
Canopy
Persea palustris
Red bay
5%
10 X 8
Understory
Platanus occidentalis
Sycamore
2%
10 X 8
Canopy
Quercus bicolor
Swamp white oak
2%
10 X 8
Canopy
Quercus laurifolia
Swamp laurel oak
5%
10 X 8
Canopy
Quercus lyrata
Overcup oak
5%
10 X 8
Canopy
Quercus michauxii
Swam chestnut oak
5%
10 X 8
Canopy
Quercus nigra
Water oak
3%
10 X 8
Canopy
Quercus pagoda
Cherr bark oak
2%
10 X 8
Canopy
Quercus phellos
Willow oak
5%
10 X 8
Canopy
Quercus shumardii
Shumard oak
5%
10 X 8
Canopy
Taxodium distichum
Bald cypress
5%
10 X 8
Canopy
Ulmus americana
American elm
2%
10 X 8
Canopy
Andropogon gerardii
Big bluestem
N/A
N/A
Herbaceous/
Permanent seed mix
Argostis alba
Redtop
N/A
N/A
Herbaceous/Permanent
seed mix
Carex vulpinoidea
Fox sedge
N/A
N/A
Herbaceous/
Permanent seed mix
Juncus effusus
Soft rush
N/A
N/A
Herbaceous/
Permanent seed mix
Juncus coriaceus
Leathery rush
N/A
N/A
Herbaceous/
Permanent seed mix
Panicum virgatum
Switchgrass
N/A
N/A
Herbaceous/
Permanent seed mix
Pennisetum glaucum
Pearl top millet
N/A
N/A
Herbaceous/
Permanent seed mix
Setaria italica
Foxtail millet
N/A
N/A
Herbaceous/
Permanent seed mix
Sorghastrum nutans
Indian grass
N/A
N/A
Herbaceous/
Permanent seed mix
A density of approximately 600 to 800 trees per acre is proposed for the initial planting and is
expected to be sufficient to meet the performance standards of 260 stems per acre after five years
outlined in Rule 15A NCAC 02B .0295. A minimum of eight species will be planted, and species
will be mixed to provide diversity of hardwood trees across the Site. No one tree species will be
greater than 50% of planted stems. Planted tree species may differ from species listed in Table 9
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due to availability of trees at the time of planting. A seed mix will be applied in areas where bare
soil or limited herbaceous vegetation is present. The seed mix will include native grasses and will
provide temporary and permanent ground cover for stabilization. The proposed planting area is
depicted as credit area on Figure 7. Planting is scheduled for installation in February 2025.
4.3 NCDWR As -Built Evaluation
Eco Terra will submit a written notification to NCDWR within 30-days following project planting
that all buffer and nutrient offset mitigation activities have been completed and the conservation
easement boundary has been marked. The credit release schedule may be modified or delayed if
written notice is not submitted within 30-days.
5.0 Monitoring and Maintenance Plan
5.1 Monitoring Protocol
Monitoring will occur in all seven years, but detailed monitoring reports will only be provided to
NCDWR in Monitoring Years 1, 3, and 5. Permanent vegetation monitoring plots will be installed
within the 22 acres of planted riparian buffer and nutrient offset areas to monitor survival of
planted trees. In order to adequately monitor the vegetation, the planted area will be monitored
in 100-m2 plots. A total of 12 fixed 100-m2 plots will be established and located in the riparian
buffer and nutrient offset credit areas (Figure 9). An additional six 100-m2 random plots will be
surveyed each year for a total of 18 vegetation plots.
Vegetation assessment will follow the Carolina Vegetation Survey (CVS) Level 2 Protocol for
Recording Vegetation (2008). A reference photo will be taken from the origin of each plot. All
planted stems will be flagged and recorded.
The measures of vegetative success for the Site will be survival of at least four native hardwood
tree species, where no one species is greater than 50 percent of stems, at a stem density of at
least 260 stems per acre after five years. Native volunteer species may be included to meet the
performance standards upon written approval by NCDWR. Invasive species will be monitored and
treated.
A visual assessment of the conservation easement will be performed each year. This inspection
will evaluate:
• Any potential encroachment;
• Effectiveness of invasive species management;
• Any potential beaver activity;
• Diffuse flow within restored buffer areas;
• Condition of easement markers; and
• Any land disturbance that may impact the restored buffer areas.
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Annual mowing between planted tree rows may occur for at least the first two growing seasons
to establish row integrity for site monitoring and subsequent supplemental planting and
herbaceous competition control.
5.2 Adaptive Management Plan
Remedial actions will be implemented as part of an adaptive management plan to address
components of the Site that are failing to meet success criteria. The source of failure and methods
needed to rectify the failure will be identified as part of the remedial actions.
6.0 Financial Assurance and Long -Term Management
6.1 Financial Assurances
Following approval of the Bonsai Mitigation Site NOBMP, Eco Terra will provide a Performance
Bond from a surety that is rated no less than an "A-" as rated by A.M. Best. The Performance Bond
amount will be 100% of the estimated cost for implementation of the Project as described in the
BPDP, but not less than $150,000. In lieu of posting the performance bond, Eco Terra may elect
to construct the project prior to the first credit release. In that case, no performance bond will be
necessary.
After completion of the restoration/construction, a separate Performance/Maintenance Bond will
be secured for 100% of the estimated cost to implement the maintenance and monitoring plan
for a term of one year and be extended annually for a minimum of five years. Upon NCDWR
approval, this may be lowered each year based on the adjusted cost to complete the monitoring.
Performance bonds for monitoring shall be renewed at least annually to cover the next year's
monitoring period, with confirmation of renewal provided to NCDWR with each annual
monitoring report, when applicable. NCDWR reserves the right to alter the credit release schedule
if monitoring reports are submitted without proof of bond renewals, when applicable.
6.2 Long Term Management Plan
Upon closeout of the project as approved by NCDWR, the Site conservation easement will be
transferred to an approved NCDWR long-term stewardship group. The larger parcel will remain
in private ownership. The long-term manager will be Southern Conservation Trust (SCT) and will
be responsible for periodic inspection of the Site to ensure that the restrictions documented in
the recorded easement are upheld in perpetuity.
7.0 Project Credits and Credit Release
This Site has the potential to generate up to 444,808 ftz of riparian buffer credits and 414,663 ft'
(21,637 Ibs of N and 1,393 Ibs of P) of nutrient offset credits within a 22.8-acre conservation
easement (Figure 7). The credits will be derived from riparian buffer restoration and will service
the Tar -Pam 01 watershed. The drainage area of the ditches D12, 13B, 14, and 15 are four times
the size of the riparian buffer restoration credit areas, in accordance with all portions of 15A NCAC
02B .0295 (o)(8). Also, some of the proposed riparian buffer credits, where allowed, can be
Bonsai Mitigation Site Draft NOBMP
ecolerra. Page 10

converted to nutrient offset credit in accordance with the Nutrient Offset Credit Trading Rule, 15A
NCAC 02B .0703. In accordance with the UMBI, any credit conversions must be calculated using
the guidance provided in the Clarified Procedures for Calculating Buffer Mitigation Credits and
Nutrient Offset Credits letter issued in November 2019 by NCDWR. Upon receiving written
approval from NCDWR, riparian buffer restoration credits, within the 0 to 200-foot zone along SE,
and 0 to 50-foot zone along D12, D1313, D14 and D15 can be converted to nutrient offset credit,
generating up to 27,045 Ibs of N and 1,741 Ibs of P offset credit. The total potential riparian buffer
mitigation and nutrient offset credits that the Project will generate were calculated using the
NCDWR "Project Credit Table Template (Updated July 2023)" and are presented in Table 10.
Figure 8 depicts riparian zones of 50, 100, and 200 feet from the top of bank to demonstrate width
requirements for crediting. There will be three credit ledgers: Riparian Buffer, Nitrogen, and
Phosphorus. Table 11 shows the credit release schedule per NCDWR requirements.
*10 Bonsai Mitigation Site Draft NOBMP
ecolerra. Page 11

Table 10. Bonsai Mitigation Site, Riparian Buffer and Nutrient Offset
Tar -Pamlico 03020101
Project Area
N Credit Conversion Ratio (ft2/pound)
P Credit Conversion Ratio (ft2/pound)
19.16394
297.54099
Credit Type
Location
Subject? (enter
NO if
ephemeral or
ditch'
Feature Type
Mitigation Activity
Min -Max Buffer
Width (ft)
Feature Name
2
Total Area (k)
Total (Creditable)
Area of Buffer
2
Mitigation (ft)
Initial Credit
Ratio (x:l)
%Full Credit
Final Credit
Ratio (x:l)
Convertible to
Riparian
Buffer?
Riparian Buffer
Credits
Convertible to
Nutrient Offset?
Delivered
Nutrient
Offset: N (Ibs)
Delivered
Nutrient
Offset: P (Ibs)
Buffer
Rural
Yes
I / P
Restoration
0-100
Stream E (SE)
204,497
204,497
1
100%
1.00000
Yes
204,497.000
Yes
10,670.927
687.290
Buffer
Rural
Yes
I/ P
Restoration
101-200
Stream ELSE)
109,698
109,698
1
33%
3.03030
Yes
36,200.376
Yes
5,724.188
368.682
Buffer
Rural
No
Ditch
Restoration
0-50
D12
51,506
51,506
1
100%
1.00000
Yes
51,506.000
Yes
2,687.652
173.106
Nutrient Offset
Rural
No
Ditch
Restoration
0-100
D12
51,616
51,616
1
1 100%
1.00000
No
-
Yes
2,693.392
173.475
Nutrient Offset
Rural
No
Ditch
Restoration
101-200
D12
49,594
49,594
1
33%
3.03030
No
-
Yes
2,587.881
166.680
Buffer
Rural
No
Ditch
Restoration
0-50
D13B
70,706
70,706
1
100%
1.00000
Yes
70,706.000
Yes
3,689.534
237.634
Nutrient Offset
Rural
No
Ditch
Restoration
0-100
D13B
77,214
77,214
1
100%
1.00000
No
-
Yes
4,029.130
259.507
Nutrient Offset
Rural
No
Ditch
Restoration
101-200
D13B
72,421
72,421
1
33%
3.03030
No
-
Yes
3,779.025
243.398
Buffer
Rural
No
Ditch
Restoration
0-50
D14
43,216
43,216
1
100%
1.00000
Yes
43,216.000
Yes
2,255.069
145.244
Nutrient Offset
Rural
No
Ditch
Restoration
0-100
D14
38,144
38,144
1
100%
1.00000
No
-
Yes
1,990.405
128.197
Buffer
Rural
No
Ditch
Restoration
0-50
D15
38,683
38,683
1
100%
1.00000
Yes
38,683.000
Yes
2,018.531
130.009
Nutrient Offset
Rural
No
Ditch
Restoration
0-100
D15
88,647
88,647
1
100%
1.00000
No
-
Yes
4,625.719
297.932
Nutrient Offset
Rural
No
Ditch
Restoration
101-200
D15
37,027
37,027
1
33%
3.03030
No
-
Yes
1,932.118
124.443
Totals (ft2):
Total Buffer (ft2):
Total Nutrient Offset (ft2):
932,969
1 932,969
444,808.376 48,683.571 3,135.597
528,306
518,306
414,663
N/A
Total Ephemeral Area (ft) for Credit
Total Eligible Ephemeral Area (ft)
Enter Preservation Credits Below Total Eligible for Preservation (ft)
x
Credit Type Location Subject? Feature Type Mitigation Activity Min-MaWidth (ftBu)ffer
Feature Name
Preservation Area Subtotals
TOTAL AREA OF BUFFER MITIGATION (TABM)
Mitigation Totals
Square Feet
Credits
Restoration:
518,306
444,808.376
Enhancement:
0
0.000
Preservation:
0
0.000
Total Riparian Buffer:
518,306
444,808.376
TOTAL NUTRIENT OFFSET MITIGATION
Mitigation Totals
I Square Feet
Credits
Nutrient Offset:
Nitrogen:
414,663
21,637.670
I Phosphorus:
1,393.632
NOW Bonsai Mitigation Site
ecoJterra.
0
0
129,577
0.0%
172,769
0.0%
Total Area (sf)
Total (Creditable)
Area for Buffer
Mitigation (ft2)
0
0
phemeral Reaches as % TABM
'reservation as % TABM
Initial Credit %Full Credit Final Credit Riparian
Ratio (x:l) Ratio (x:1) 1 Buffer Credits
Draft BPDP
Page 12

Table 11: Credit Release Schedule
% Credit Available
Task
Project Milestone
for Sale
BPDP Approved by DWR, Conservation Easement
1
Recorded* and Financial Assurance Posted
20
Mitigation Site Earthwork, Planting and Installation of
2
Monitoring Devices Completed
20
Monitoring Financial Assurance Posted and Approval of
3
As -Built Report
10
4
Monitoring Report #1: Approved by the DWR*
10
5
Monitoring Report #2: Approved by the DWR*
10
6
Monitoring Report #3: Approved by the DWR*
10
Item 13(1) of Section X in the Eco Terra Tar -Pamlico 01
UMBI has been completed and approved by NCDWR.
5
No remaining credits released until the conservation easement has been assigned to an
approved long-term steward.
8
Monitoring Report #4: Approved by the DWR*
5
Monitoring report #5: Approved by NCDWR final site visit
9
by DWR has been conducted.
10
Total:
100
* DWR Approval provided upon a determination that the site is meeting success criteria contained within
the approved BPDP
*410 Bonsai Mitigation Site Draft NOBMP
ecolerra. Page 13

8.0 References
Federal Emergency Management Act (FEMA). 2007. DFIRM 3720389200K.
Federal Emergency Management Act (FEMA). 2007. DFIRM 3720388200K.
Lee, Michael, R. Peet, S. Roberts, and T. Wentworth. 2008. CVS-EEP Protocol for Recording
Vegetation. Version 4.2.
Natural Resources Conservation Service (NRCS). 2024. Web Soil Survey.
http://websoilsurvey.nres.usda.gov/app/HomePage.htm
North Carolina Division of Mitigation Services (NCDMS). 2018 Tar -Pamlico River Basin
Restoration Priorities.
North Carolina Division of Water Quality (NCDWQ). 2010. Methodology for Identification of
Intermittent and Perennial Streams and Their Origins. Version 4.11. Raleigh.
North Carolina Division of Water Quality (NCDWQ). 2011. Surface Water Classifications.
http://portal.ncdenr.org/web/wq/ps/csu/classifications.
North Carolina Environmental Management Commission. 2014. Rule 15A NCAC 02B .0295
Mitigation Program Requirements for the Protection and Maintenance of Riparian
Buffers.
North Carolina Environmental Management Commission. 2020. Rule 15A NCAC 02B .0703
Mitigation Program Requirements for the Protection and Maintenance of Riparian
Buffers.
North Carolina Environmental Management Commission. 2020. Rule 15A NCAC 02B .0734 Tar -
Pamlico River Basin: Nutrient Sensitive Waters Management Strategy: Protection and
Maintenance of Existing Riparian Buffers.
North Carolina Natural Heritage Program. 2024. Data Explorer. Department of Natural and
Cultural Resources, Raleigh, North Carolina.
Schafale, M.P. 2023. Guide to the Natural Communities of North Carolina: Fourth Approximation.
Natural Heritage Program, Division of Parks and Recreation, N.C. Department of
Environment, Health, and Natural Resources. Raleigh, NC. 1,219 pp.
U.S. Department of Agriculture Soil Conservation Service. 1979. Soil Survey Edgecombe County,
North Carolina.
U.S. Fish and Wildlife Service (USFWS), 2024. Information and Planning Consultation (IPaC).
httl2s://ecos.fws.gov/ipac
%10 Bonsai Mitigation Site Draft NOBMP
ecolerra. Page 14

Figure 1: Vicinity Map
Bonsai Mitigation Site I Battleboro, NC
aA
x
r
,y
C Highway
/
4
/
Battleboro
Drake
/
Ford's Colony
/
Country Club at
/
Rocky Mount
/
Pkv+y /
aromas A
e.". /
r
Go R
y I
Cherry
Crossroads
Phillips
Crossroads
/ NC Highway 97 VW
CO
�V /
�etAv l =_-
51
*404-0
ecolerra. -0%
Gethsemane
Wrendale
Dunbar
33
i
e-------
Rocky Mount a
a / Hartsease
CL
a Brake
Kungsbor�O�i,
State of North Carolina TEsTonnTom, Garmin, SafeGraph,
Cl/ West GeoTechnologies, Inc, METI/NASA, SGS, EPA, NPS, USDA, USFWS
CO/
Edgecombe
N
JW 0 1 2 Miles
Source: ESRI Streets Basemap
0 Proposed Conservation Easement

Lake
Gaston
a�
Falls
Durham Reservoir
c Rocky Mot
Ca. Raleigh a ` r'r•_•'.
Project• •
Goldsboro
lNAS� U Sc 5o G6 So M�S�

Figure 3: Existing Conditions
Bonsai Mitigation Site I Battleboro, NC
`W
eco,�erres
N — Ditch
0 150 300 Feet - c - Stream
Source: ESRI Aerial Bosemop, Sub -meter Top of Bank
—vhb„
= Proposed Conservation Easement

Figure 4: USGS Topographic Map
Bonsai Mitigation Site I Battleboro, NC
am
Stu
lyateTT3nk
or
V
Y,
f'NMMM"�
N 4W 0 1,000 2,000 Feet
Source: USA Topomops
*404-0
ecf ,rferrc. ---* hb,
Ci
%
3 National Geographic ociety, i-cubed
= Proposed Conservation Easement

Figure 5: Drainage Area
Bonsai Mitigation Site I Battleboro, NC
�`,�
ecolerra®
"6" hb
N
O
N
V
M
R
Q_
N CM Proposed Conservation Easement 0 Ditch 12 Drainage Area (5.45 ac)
40
0 750 1,500 Feet — Ditch 0 Ditch 13B Drainage Area (6.73 ac)
c c Stream 0 Ditch 14 Drainage Area (3.97 ac)
0 Stream E Drainage Area (205 ac) 0 Ditch 15 Drainage Area (3.55 ac)
Source: NC Onemap 2027 Aerial, Sub -meter Top of Bank, Stream Stats Drainage Areas

Figure 6: NRCS 1979 Soil Survey Map
Bonsai Mitigation Site I Battleboro, NC
StB
StB
eB
eco,1erra® '�rhb
e .100
Y.
� * y
YY
tI3 aS Jim 1
M
} A ca A
4
t y* 'a
A 3A
'gA
{�-yy
* V
N
0 375 750 Feet
Source: 7979 NRCS Soil Survey, Map Sheets 6 & 9,
3
g
Proposed Conservation Easement
r
CD
i
i
t

Figure 7: Mitigation Credit
Bonsai Mitigation Site I Battleboro, NC
eco,1erra® fhb
-"att/eb
g t•t,R,a��`
c '
uu
„
{l({
i� tf/ � •. ���1
!h �
0)
A'-
6�
R- da off NoAh, Ca cha DOoT,
• - .. EM, To, tromp GaNwo , Saffa5rraph,
• SSF Sp NCB CSC IA, Max-9r, tiMi aosaft
Ditch
N - c� - Strea m
0 125 250 Feet 0-50' Ditch Riparian Restoration for RBC
0 51-100' Ditch Riparian Restoration for NOC
0-100' Subject Stream Riparian Restoration for RBC
101-200' Subject Stream Riparian Restoration for RBC
Source: ESRI Aeriol Bosemop, Sub -meter Top of Bonk
0 101-200' Ditch Riparian Restoration for NOC
Non -Diffuse Flow Deduction
0
v
io
2
Q

*4010— Figure 8: Riparian Buffer Zones �°'�;'
Bonsai Mitigation Site I Battleboro, NC eC0,1errc. Vhb
QN
0 125 250 Feet
Source: NC Onemap 2021 Aerial, Sub -meter Top of Bank
- - Ditch
c c Stream
0 0-30'
0 31-50'
0 51-100'
0 101-200'
Q Proposed Conservation Easement

VOW
Figure 9: Monitoring Plan e cflt'e rras 'VIlb,.
Bonsai Mitigation Site I Battleboro, NC
a
N - - Ditch 0 0-50' Ditch Riparian Restoration for RBC
0 125 250 Feet c Stream 0 51-100' Ditch Riparian Restoration for NOC
Vegetation Monitoring Plots 0 0-100' Subject Stream Riparian Restoration for RBC
0 Proposed Conservation Easement 0 101-200' Subject Stream Riparian Restoration for RBC
0 101-200' Ditch Riparian Restoration for NOC
Non -Diffuse Flow Deduction
Source: ESRI Basemap, Sub -meter Top of Bank

Appendix A

Bonsai Mitigation Site
Edgecombe County, NC
Site Photographs - Taken February 26, 2024
Ditch 12 (1312)
Ditch 14 (D14)
Stream SE
Bonsai Mitigation Site
Site Photographs
Ditch 13B (D1313)
Ditch 15 (D15)
Field Conditions
VHB Project No. 39077.36
Page 1 of 1

Appendix B

`A0
11
eco,kerres 4%hb
1951 Historical Aerial
Bonsai Mitigation Site I Battleboro, NC
19
r �a
Esri Community ps Contributors, State of North Carolina DOT,
OpenStre Map, Microsoft, Esri, TomTom, Garmin, SafeGraph,
GeoTechn, ogies, Inc, METI/NASA, USGS, EPA, NIPS, US Census
Bureau, USDA, USFWS
ON
QN
0 300 600 Feet
Source: USGS Data Explorer Single Frame Aerial
= Proposed Conservation Easement

1974 Historical Aerial
Bonsai Mitigation Site I Battleboro, NC
W �.
ecoterrc. —vI b„
�y "+j'
.
0
w
01 Ji
g - Esri Community Maps C ntributors, State of North CarolinalMOT;
OpenStreetMap, icrosoft, Esri, TomTom, Garmin, SafeGra,Rh,
GeoTechnologie Inc, METI/NASA, USGS, EPA, NPS, US Census
Bureau, USDA, USFWS
QN Proposed Conservation Easement
0 300 600 Feet
N
Source: USGS Data Explorer Single Frame Aerial

Appendix C

DocuSign Envelope ID: D1EOA9EC-BO4B-4B15-BED8-C92B7OA73625
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Scott Frederick
Eco Terra LLC
scott0ecoterra.com
NORTH CAROLINA
Environmental Quality
April 7, 2022
Project 20220112 V1
Edgecombe County
Subject: Applicability to the Tar -Pam River Basin Buffer Rules 15A NCAC 02B .0734
Project: Falling Run Buffer Site
Address: Near 3817 Battleboro-Leggett Rd., Battleboro, NC 27809, Edgecombe County, NC
Location: Lat., Long: 35.995822,-77.678946
Dear Mr. Frederick:
On February 28, 2022, Shelton Sullivan of the Division of Water Resources (DWR) conducted
an on -site review of features located on the Falling Run Buffer Site in Edgecombe County to
determine the applicability of features on the site to the Tar -Pamlico River Basin Riparian
Area Protection Rules, Title 15A North Carolina Administrative Code 02B .0734.
The enclosed map(s) depict the feature(s) evaluated and this information is also summarized
in the table below. Streams were evaluated for being ephemeral, at least intermittent, and
for subjectivity to the Tar -Pam River Basin Riparian Area Protection Rules. Streams that are
considered "Subject" have been located on the most recently published NRCS Soil Survey of
Person County and/or the most recent copy of the USGS Topographic (at 1:24,000 scale)
map(s), have been located on the ground at the site, and possess characteristics that qualify
them to be at least intermittent streams. Features that are considered "Not Subject" have
been determined to not be at least intermittent, not present on the property, or not depicted
on the required maps.
This determination only addresses the applicability to the buffer rules within the
proposed easement and does not approve any activity within buffers or within waters
of the state. There may be other streams, wetlands, ponds, or other features located
on the property that appear or do not appear on the maps referenced above. Any of
the features on the site may be considered jurisdictional according to the US Army
Corps of Engineers and subject to the Clean Water Act.
The following table addresses the features observed and rated during the DWR site visit. See
attached map and key provided by Scott Frederick with Eco Terra Partners LLC
North Carolina Department of Environmental Quality I Division of Water Resources
E Q 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA _
D.prh.M W UM �m l Iz /� 919.707.9000

DocuSign Envelope ID: D1EOA9EC-BO4B-4B15-BED8-C92B7OA73625
Page 2 of 3
Falling Run Buffer Site
Project 20220112 VA
Feature Type:
stream
(ephemeral,
Subject to
Depicted
Depicted
Feature ID
intermittent,
Buffer
Start @
Stop @
on
on
perennial), ditch,
Rules
Soil Survey
USGS Topo
Swale, wetland,
other
Start Point
Stream- at least
indicated on map,
Stream A
intermittent
Yes
Green/Blue,
Stream E
Yes
Yes
Ditch/Stream
transition
Start Point
Stream- at least
indicated on map,
Confluence
Stream B
intermittent
Yes
Green/Blue,
with Stream E
Yes
Yes
Ditch/Stream
transition
Start Point
Stream- at least
indicated on map,
Confluence
Stream C
intermittent
No
Green/Blue,
with Stream E
Yes
Yes
Ditch/Stream
transition
Start Point
Stream- at least
indicated on map,
Confluence
Stream D
intermittent
Yes
Green/Blue,
with Stream E
Yes
Yes
Ditch/Stream
transition
Continues
Present at western
beyond the
Stream- at least
property
eastern
Stream E
intermittent
Yes
boundary; blue line
property
Yes
Yes
boundary at
on map
Goose Hollow
Ln.
Continues
Start Point
beyond the
Stream- at least
indicated on map,
eastern
Stream F
intermittent
Yes
Green/Blue,
property
Yes
Yes
Ditch/Stream
boundary at
transition
Goose Hollow
Ln.
Partial,
Continues
Upper leg
Starts beyond
beyond the
Partial,
Stream G
Stream- at least
only, see
western project
western
Upper leg
No
intermittent
yellow on
boundary
property
only, see
boundary,
map
map
flows north
Green
Ditches, ponds,
See the map
Labeled
or drainage
No
provided by Eco
See map
Partial
Partial
Features
features
Terra LLC
on Map
* E: Ephemeral, I: Intermittent, P: Perennial
This on -site determination shall expire five (5) years from the date of this letter.
Landowners or affected parties that dispute this determination made by the DWR may
request an appeal determination by the Director of Water Resources. An appeal request

DocuSign Envelope ID: D1EOA9EC-BO4B-4B15-BED8-C92B7OA73625
Page 3 of 3
Falling Run Buffer Site
Project 20220112 VA
must be made within sixty (60) calendar days of the date of this letter to the Director in
writing.
If sending via U.S. Postal Service:
Paul Wojoski - DWR 401 & Buffer
Permitting Branch Supervisor
1617 Mail Service Center
Raleigh, NC 27699-1617
If sending via delivery service (UPS, FedEx, etc.)
Paul Wojoski - DWR 401 & Buffer
Permitting Branch Supervisor
512 N Salisbury St.
Raleigh, NC 27604
This determination is final and binding as detailed above unless an appeal is requested within
sixty (60) calendar days of the date of this letter.
If you have any additional questions or require additional information, please contact Shelton
Sullivan at shelton.sullivangncdenr.gov or 919-707-3636. This determination is subject to
review as provided in G.S. 150B.
Sincerely,
DOCUSS gnn�e/d by:
�GiwG WOtOOki
949D91BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
Attachments: Site Map with labels, USGS Topographical Map, NRCS Soil Survey
cc: 401 & Buffer Permitting Branch Laserfiche File
Jordan Burbage, [e-mail]
Billy Dean Bulluck, Jr., 3806 Battleboro-Leggett Rd., Battleboro, NC 27809
Filename: 20220112V.1_StreamCALLs_FallingRunBufferSite_EdgecombeCo

DocuSian Envelope ID: D1EOA9EC-BO4B-4B15-BED8-C92B7OA73625

DocuSign Envelope ID: D1EOA9EC-BO4B-4B15-BED8-C92B7OA73625
USGS Map
Refer to labeled aerial map
Shelton Sullivan, DWR, 2/28/22

DocuSign Envelope ID: D1EOMEC-130413-41315-BED&C92137OA73625
aA i
.■ We
[7gA I E a 1
We
r; A
StB ` We Bo
1 7 We
t B e� C a ,D
CeB p
StB Ca We g
StB B
AaA We
• Ro aA
AaA
AaA AaA
CeB R4
`9
• �-9 A a
AaA W k B
a DMA
AaA
nee T aB
T r StB
)gq Ro
AaA.
s'
AaA
Legend '•' TaB
9 wkB Wkg
Q Proposed Conservation Easement AaA
NC GI , Maxar
Ilk Ro i
Figure 3: Soil Survey
Falling Run Buffer Site N
WL
PIN: 3891193663
Tar -Pamlico 03020101 s
35°59'46.86"N 77040'37.65"W
eco terra® Edgecombe County, NC 0 375 750 1,500
1979 Soil Survey of Edgecombe County, NC 06iiWOMMOMM09 Feet
Map Sheets #6, #9

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
August 23, 2022
(replaces letter dated August 1, 2022 and corrects mitigation determination for Ditch #22 &
Ditch 29h only)
Scott Frederick
EcoTerra Partners, LLC
(via electronic mail: scott s,ecoterra.com )
Re: Site Viability for Buffer Mitigation & Nutrient Offset — Falling Run Site
Near 35.992195,-77.674569 off 3806 Battleboro Legget Rd, Battleboro, NC
Tar -Pamlico River Basin 03020101
Edgecombe County
Dear Mr. Frederick,
On April 18, 2022, Katie Merritt, with the Division of Water Resources (DWR), received a request
from you on behalf of Eco Terra, LLC (EcoTerra) for a site visit near the above -referenced site in the
Tar -Pamlico River Basin within the 8-digit Hydrologic Unit Code 03020101. The site visit was to
determine the potential for riparian buffer mitigation and nutrient offset within a proposed Easement
Boundary, which is more accurately shown in the attached map labeled "Figure 1: Site Map" (Figure
1) prepared by EcoTerra. On June 8, 2022, Ms. Merritt performed a site assessment of the subject
site. Staff with Eco Terra were also present.
Ms. Merritt's evaluation of the features onsite and their associated mitigation determination for the
riparian areas are provided in the table below. This evaluation was made from Top of Bank (TOB)
and landward 200' from each feature for buffer mitigation pursuant to 15A NCAC 02B .0295
(effective November I, 2015) and for nutrient offset credits pursuant to 15A NCAC 02B .0703.
Feature
Classification
'Subiect
Riparian Land uses
Buffer
'Nutrient
4,15Miti ate ion Type Determination w/in
onsite
adjacent to Feature
Credit
Offset
to
riparian areas
0( 200')
Buffer
Viable
Viable
Rule
SA,SB,SD,
Streams
Yes
non -forested agricultural
Yes
Yes (non-
Non -forested fields - Restoration Site per
SE,
fields.
forested
15A NCAC 02B .0295 (n)
fields only)
D E Q�� North Carolina Department of Environmental Quality I Dieision of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
fJOFiTH CAROLINA
i�wu�.Nardo.air\ r 919 707.9000

Falling Run Site
EcoTcrra
August 23, 2022
Feature
Classification
'Subject
to
Riparian Land uses
adjacent to Feature
Buffer
Credit
3Nutrient
Offset
"Mitigation Tvpe Determination w/in
onsite
riparian areas
Buffer
0{ 200')
Viable
Viable
Rule
SC
Stream
Yes
Left bank forested: right
2Yes
Yes (non-
Non -forested fields - Restoration Site per
bank non -forested
forested
15A NCAC 02B .0295 (n)
agricultural fields
fields only)
Forested Areas — Preservation Site per
15A NCAC 02B .0295 (o)(5)
SF
Stream
Yes
Combination of forested
'Yes
Yes (non-
Non -forested fields - Restoration Site per
pasture and non -forested
forested ag
15A NCAC 02B .0295 (n)
agricultural fields
fields only)
Forested Pasture — Enhancement Site per
15A NCAC 02B .0295 (o)(6)
SG
Stream
No
Non -forested agricultural
'Yes
Yes (non-
Non -forested fields - Restoration Site per
fields within the proposed
forested
15A NCAC 02B .0295 (n)
CE but includes forested
fields only)
areas beyond the CE
Forested Areas — Preservation Site per
boundary
15A NCAC 02B .0295 (o)(5)
27,22,18,16.
Ditches <3'
No
Non -forested agricultural
*See
Yes
Restoration Site per 15A NCAC 02B
15,14,13,121
fields
note
.0295 (o)(8)
1 1,10,7,5,4,2
(see ditch
*Buffer Mitigation Note — Assessment
origins on
concludes the ditch meets 15A NCAC
attached
02B .0295 (o)(8) (A, B, C, D & E). More
map)
information is required to be provided
in a mitigation plan for complete
assessment. See rule.
3,29b
Ditch
No
Non -forested agricultural
No
Yes
Restoration Site per 15A NCAC 02B
>3' depth
fields
.0295 (n)
29a
Ditch
No
Historically forested areas
No
Yes (left
Restoration Site per 15A NCAC 02B
(starts it,
>3' depth
with established berm right
bank ag
.0295 (n)
35.994831,
bank; Left bank is non-
fields only)
-77.683947)
forested agricultural fields
30
Ditch
No
Non -forested agricultural
No
Yes (right
Restoration Site per 15A NCAC 02B
>3' depth
fields right bank only
bank ag
.0295 (n)
fields only)
Page 2 of 4

Falling Run Site
EcoTerra
August 23, 2022
Feature
Classification
'Subject
Riparian Land uses
Buffer
3Nutrient
15Mitigation Type Determination w/in
onsite
to
ad iacent to Feature
Offset
riparian areas
Credit
0f 200,1
Buffer
Viable
Viable
Rule
1, ]A,2A,6,8,
Ditches
No
Non -forested agricultural
No
No
Either not present or not directly
8A,9,17,19,
fields.
hydrologically connected to a stream
20,21,22A,
23,23A,24,
25,26,27A,
28,31,32
'Subjectivity calls for the features were determined by DWR in correspondence dated April 7, 2022 using the 1:24,000 scale quadrangle
topographic map prepared by USGS and the most recent printed version of the soil survey map prepared by the NRCS .
'The area of preservation credit within a buffer mitigation site shall comprise of no more than 25 percent (25%) of the total area of buffer
mitigation per 15A NCAC 0295 (o)(5) and 15A NCAC 0295 (o)(4). Site cannot be a Preservation Only site to comply with this rule.
INC Division of Water Resources - Methodology and Calculations for determining Nutrient Reductions associated with Riparian Buffer
Establishment
4 Determinations made for this Site are determined based on the proposal provided in maps and figures submitted with the request.
s All features proposed for buffer mitigation or nutrient offset, must have a planted conservation easement established that includes the
tops of channel banks when being measured perpendicular and landward from the banks, even if no credit is viable within that riparian
area
brhe area of the mitigation site on ephemeral channels shall comprise no more than 25 percent (25%) of the total area of buffer
mitigation per 15A NCAC 02B .0295 (o)(7).
Determinations provided in the table above were made using a proposed easement boundary showing
proposed mitigation areas in Figure 1. A map representing the proposal for the site is attached to this
letter and is initialed by Ms. Merritt on August 1, 2022. Substantial changes to the proposed
easement boundary could affect the Site's potential to generate buffer and nutrient offset credits.
This letter does not constitute an approval of this Site to generate buffer and nutrient offset credits.
Pursuant to 15A NCAC 02B .0295, a mitigation proposal and a mitigation plan shall be submitted to
DWR for written approval prior to conducting any mitigation activities in riparian areas and/or
surface waters for buffer mitigation credit. Pursuant to 15A NCAC 02B .0703, a proposal regarding a
proposed nutrient load -reducing measure for nutrient offset credit shall be submitted to DWR for
approval prior to any mitigation activities in riparian areas and/or surface waters.
All vegetative plantings, performance criteria and other mitigation requirements for riparian
restoration, enhancement and preservation must follow the requirements in 15A NCAC 02B .0295 to
be eligible for buffer and/or nutrient offset mitigation credits. For any areas depicted as not being
viable for nutrient offset credit above, one could propose a different measure, along with supporting
calculations and sufficient detail to support estimates of load reduction, for review by the DWR to
determine viability for nutrient offset in accordance with 15A NCAC 02B .0703.
This viability assessment will expire on August 23, 2024 or upon approval of a mitigation plan
by the DWR, whichever comes first. This letter should be provided in any nutrient offset,
buffer, stream or wetland mitigation plan for this Site.
Page 3 of 4

Falling Run Site
EcoTerra
August 23, 2022
Please contact Katie Merritt at [phone] if you have any questions regarding this
correspondence.
Sincerely,
Paul Wojoski, Supervisor
401 and Buffer Permitting Branch
PW/kym
Attachments: "Site Map" (Figure 1)"
cc: File Copy (Katie Merritt)
Page 4 of 4

Appendix D

From:
Matthews, Kathryn H
To:
Heather Smith
Cc:
Casey Bardier
Subject:
Re: Fw: [EXTERNAL] Bonsai Mitigation Site
Date:
Tuesday, August 2, 2022 3:41:25 PM
Attachments:
imaae001.Dna
image002.pno
imaae003.Dna
image004.pno
imaae005.Dna
Hi Heather,
Thank you for submitting the Bonsai site through the self -certification process. The Service
concurs with your species determinations. Please provide this email to others as needed to
other agencies for their knowledge. Thanks,
Please note that I am teleworking Wednesday through Friday, every week. Email is the best
way to reach me. Thanks,
Kathy Matthews
NC Renewable Energy Coordinator &
Fish and Wildlife Biologist
U.S. Fish and Wildlife Service
551-F Pylon Drive
Raleigh, NC 27606
919-856-4520, x. 27
From: Heather Smith <[e-mail]>
Sent: Monday, July 25, 2022 2:47 PM
To: Raleigh, FW4 <[e-mail]>
Cc: Casey Bardier <[e-mail]>
Subject: [EXTERNAL] Bonsai Mitigation Site
This email has been received from outside of DOI - Use caution before clicking on
links, opening attachments, or responding.
Please find the attached self -certification for a mitigation site in Edgecombe County.
Thanks,
Heather Smith, LSS

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
September 14, 2022
Scott Frederick
Eco Terra
117 Centrewest Court
Cary, NC 27513
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
scottAccoterra.com
Re: Falling Run/Bonsai mitigation site, 35.998851,-77.677884, Battleboro, Edgecombe County,
ER 22-1462
Dear Mr. Frederick:
Thank you for your email of August 24, 2022, regarding the above -referenced undertaking. We have
reviewed the submittal and offer the following comments.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or environmental.review(cncdcr.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
Ramona Bartos, Deputy
(� State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

Falling Run Mitigation Site
Not Reported
Battleboro, NC 27809
Inquiry Number: 6969216.2s
May 06, 2022
6 Armstrong Road, 4th floor
Shelton, CT 06484
(rEDR ° Toll Free: 800.352.0050
www.edrnet.com
FORM-LBE-BCS

TABLE OF CONTENTS
SECTION
PAGE
Executive Summary
ES1
OverviewMap-----------------------------------------------------------
2
DetailMap--------------------------------------------------------------
3
Map Findings Summary
4
MapFindings------------------------------------------------------------
8
Orphan Summary---------------------------------------------------------
12
Government Records Searched/Data Currency Tracking- - - - - - - - - - - - - -
- - - - - - - - - - - - GR-1
GEOCHECK ADDENDUM
Physical Setting Source Addendum
A-1
Physical Setting Source Summary
A-2
Physical Setting SSURGO Soil Map -------------------------------------------
A-5
Physical Setting Source Map------------------------------------------------
A-13
Physical Setting Source Map Findings
A-15
Physical Setting Source Records Searched
PSGRA
Thank you for your business.
Please contact EDR at 1-800-352-0050
with any questions or comments.
Disclaimer - Copyright and Trademark Notice
This Report contains certain information obtained from a variety of public and other sources reasonably available to Environmental Data
Resources, Inc. It cannot be concluded from this Report that coverage information for the target and surrounding properties does not exist from
other sources. NO WARRANTY EXPRESSED OR IMPLIED, IS MADE WHATSOEVER IN CONNECTION WITH THIS REPORT. ENVIRONMENTAL
DATA RESOURCES, INC. SPECIFICALLY DISCLAIMS THE MAKING OF ANY SUCH WARRANTIES, INCLUDING WITHOUT LIMITATION,
MERCHANTABILITY OR FITNESS FOR A PARTICULAR USE OR PURPOSE. ALL RISK IS ASSUMED BY THE USER. IN NO EVENT SHALL
ENVIRONMENTAL DATA RESOURCES, INC. BE LIABLE TO ANYONE, WHETHER ARISING OUT OF ERRORS OR OMISSIONS, NEGLIGENCE,
ACCIDENT OR ANY OTHER CAUSE, FOR ANY LOSS OF DAMAGE, INCLUDING, WITHOUT LIMITATION, SPECIAL, INCIDENTAL,
CONSEQUENTIAL, OR EXEMPLARY DAMAGES. ANY LIABILITY ON THE PART OF ENVIRONMENTAL DATA RESOURCES, INC. IS STRICTLY
LIMITED TO A REFUND OF THE AMOUNT PAID FOR THIS REPORT. Purchaser accepts this Report "AS IS". Any analyses, estimates, ratings,
environmental risk levels or risk codes provided in this Report are provided for illustrative purposes only, and are not intended to provide, nor
should they be interpreted as providing any facts regarding, or prediction or forecast of, any environmental risk for any property. Only a Phase I
Environmental Site Assessment performed by an environmental professional can provide information regarding the environmental risk for any
property. Additionally, the information provided in this Report is not to be construed as legal advice.
Copyright 2020 by Environmental Data Resources, Inc. All rights reserved. Reproduction in any media or format, in whole
or in part, of any report or map of Environmental Data Resources, Inc., or its affiliates, is prohibited without prior written permission.
EDR and its logos (including Sanborn and Sanborn Map) are trademarks of Environmental Data Resources, Inc. or its affiliates. All other
trademarks used herein are the property of their respective owners.
TC6969216.2s Page 1

EXECUTIVE SUMMARY
A search of available environmental records was conducted by Environmental Data Resources, Inc (EDR).
The report was designed to assist parties seeking to meet the search requirements of EPA's Standards
and Practices for All Appropriate Inquiries (40 CFR Part 312), the ASTM Standard Practice for
Environmental Site Assessments (E1527-21), the ASTM Standard Practice for Environmental Site
Assessments for Forestland or Rural Property (E 2247-16), the ASTM Standard Practice for Limited
Environmental Due Diligence: Transaction Screen Process (E 1528-14) or custom requirements developed
for the evaluation of environmental risk associated with a parcel of real estate.
TARGET PROPERTY INFORMATION
ADDRESS
NOT REPORTED
BATTLEBORO, NC 27809
COORDINATES
Latitude (North):
Longitude (West):
Universal Tranverse Mercator:
UTM X (Meters):
UTM Y (Meters):
Elevation:
35.9962450 - 35- 59' 46.48"
77.6812290 - 77- 40' 52.42"
Zone 18
258302.5
3986656.8
68 ft. above sea level
USGS TOPOGRAPHIC MAP ASSOCIATED WITH TARGET PROPERTY
Target Property Map: 13720764 HARTSEASE, NC
Version Date: 2019
North Map: 13837663 WHITAKERS, NC
Version Date: 2019
AERIAL PHOTOGRAPHY IN THIS REPORT
Portions of Photo from: 20140521
Source: USDA
TC6969216.2s EXECUTIVE SUMMARY 1

MAPPED SITES SUMMARY
Target Property Address:
NOT REPORTED
BATTLEBORO, NC 27809
Click on Map ID to see full detail.
MAP
ID SITE NAME ADDRESS
DATABASE ACRONYMS
RELATIVE DIST (ft. & mi.)
ELEVATION DIRECTION
1
COOL SPRING SAND & G
US MINES
Lower
16, 0.003, SE
A2
PHILLIPS MIDDLE SCHO
4371 BATTLEBORO-LEGG LUST
Higher
976, 0.185, NNW
A3
PHILLIPS MIDDLE SCHO
ROUTE 2 BOX 1 UST
Higher
1148, 0.217, NNW
6969216.2s Page 2

EXECUTIVE SUMMARY
TARGET PROPERTY SEARCH RESULTS
The target property was not listed in any of the databases searched by EDR.
DATABASES WITH NO MAPPED SITES
No mapped sites were found in EDR's search of available ("reasonably ascertainable ") government
records either on the target property or within the search radius around the target property for the
following databases:
STANDARD ENVIRONMENTAL RECORDS
Lists of Federal NPL (Superfund) sites
NPL National Priority List
Proposed NPL---------------- Proposed National Priority List Sites
NPL LIENS Federal Superfund Liens
Lists of Federal Delisted NPL sites
Delisted NPL National Priority List Deletions
Lists of Federal sites subject to CERCLA removals and CERCLA orders
FEDERAL FACILITY---------. Federal Facility Site Information listing
SEMS Superfund Enterprise Management System
Lists of Federal CERCLA sites with NFRAP
SEMS-ARCHIVE Superfund Enterprise Management System Archive
Lists of Federal RCRA facilities undergoing Corrective Action
CORRACTS------------------ Corrective Action Report
Lists of Federal RCRA TSD facilities
RCRA-TSDF RCRA - Treatment, Storage and Disposal
Lists of Federal RCRA generators
RCRA-LQG RCRA - Large Quantity Generators
RCRA-SQG------------------ RCRA - Small Quantity Generators
RCRA-VSQG RCRA - Very Small Quantity Generators (Formerly Conditionally Exempt Small Quantity
Generators)
Federal institutional controls / engineering controls registries
LUCIS------------------------ Land Use Control Information System
TC6969216.2s EXECUTIVE SUMMARY 3

EXECUTIVE SUMMARY
US ENG CONTROLS--------. Engineering Controls Sites List
US INST CONTROLS Institutional Controls Sites List
Federal ERNS list
ERNS Emergency Response Notification System
Lists of state- and tribal (Superfund) equivalent sites
NC HSDS-------------------- Hazardous Substance Disposal Site
Lists of state- and tribal hazardous waste facilities
SHWS Inactive Hazardous Sites Inventory
Lists of state and tribal landfills and solid waste disposal facilities
SWF/LF List of Solid Waste Facilities
DEBRIS---------------------- Solid Waste Active Disaster Debris Sites Listing
OLI Old Landfill Inventory
LCID Land -Clearing and Inert Debris (LCID) Landfill Notifications
Lists of state and tribal leaking storage tanks
LAST ----------------- Leaking Aboveground Storage Tanks
INDIAN LUST Leaking Underground Storage Tanks on Indian Land
LUST TRUST ----------------- State Trust Fund Database
Lists of state and tribal registered storage tanks
FEMA UST------------------- Underground Storage Tank Listing
AST AST Database
INDIAN UST Underground Storage Tanks on Indian Land
State and tribal institutional control / engineering control registries
INST CONTROL-------------. No Further Action Sites With Land Use Restrictions Monitoring
Lists of state and tribal voluntary cleanup sites
VCP Responsible Party Voluntary Action Sites
INDIAN VCP------------------ Voluntary Cleanup Priority Listing
Lists of state and tribal brownfield sites
BROWNFIELDS-------------- Brownfields Projects Inventory
ADDITIONAL ENVIRONMENTAL RECORDS
Local Brownfield lists
US BROWNFIELDS A Listing of Brownfields Sites
Local Lists of Landfill / Solid Waste Disposal Sites
SWRCY Recycling Center Listing
TC6969216.2s EXECUTIVE SUMMARY 4

EXECUTIVE SUMMARY
HIST LF---------------------- Solid Waste Facility Listing
INDIAN ODI Report on the Status of Open Dumps on Indian Lands
DEBRIS REGION 9 Torres Martinez Reservation Illegal Dump Site Locations
ODI-------------------------- Open Dump Inventory
IHS OPEN DUMPS Open Dumps on Indian Land
Local Lists of Hazardous waste / Contaminated Sites
US HIST CDL Delisted National Clandestine Laboratory Register
US CDL---------------------- National Clandestine Laboratory Register
PFAS PFAS Contamination Site Listing
Local Land Records
LIENS 2 CERCLA Lien Information
Records of Emergency Release Reports
HMIRS-----------------------
Hazardous Materials Information Reporting System
SPILLS
Spills Incident Listing
IMD
Incident Management Database
SPILLS 90-------------------.
SPILLS 90 data from FirstSearch
SPILLS 80
SPILLS 80 data from FirstSearch
Other Ascertainable Records
RCRA NonGen / NLR
RCRA - Non Generators / No Longer Regulated
FUDS------------------------
Formerly Used Defense Sites
DOD
Department of Defense Sites
SCRD DRYCLEANERS
State Coalition for Remediation of Drycleaners Listing
US FIN ASSUR--------------.
Financial Assurance Information
EPA WATCH LIST
EPA WATCH LIST
2020 COR ACTION
2020 Corrective Action Program List
TSCA------------------------
Toxic Substances Control Act
TRIS
Toxic Chemical Release Inventory System
SSTS
Section 7 Tracking Systems
ROD-------------------------
Records Of Decision
RMP
Risk Management Plans
RAATS
RCRA Administrative Action Tracking System
PRP--------------------------
Potentially Responsible Parties
PADS
PCB Activity Database System
ICIS
Integrated Compliance Information System
FTTS-------------------------
FIFRA/ TSCA Tracking System - FIFRA (Federal Insecticide, Fungicide, & Rodenticide
Act)/TSCA (Toxic Substances Control Act)
MLTS
Material Licensing Tracking System
COAL ASH DOE-------------.
Steam -Electric Plant Operation Data
COAL ASH EPA
Coal Combustion Residues Surface Impoundments List
PCB TRANSFORMER
PCB Transformer Registration Database
RADINFO--------------------
Radiation Information Database
HIST FTTS
FIFRA/TSCA Tracking System Administrative Case Listing
DOT OPS
Incident and Accident Data
CONSENT-------------------
Superfund (CERCLA) Consent Decrees
INDIAN RESERV
Indian Reservations
FUSRAP
Formerly Utilized Sites Remedial Action Program
UMTRA----------------------
Uranium Mill Tailings Sites
TC6969216.2s EXECUTIVE SUMMARY 5

EXECUTIVE SUMMARY
LEAD SMELTERS____________
Lead Smelter Sites
US AIRS
Aerometric Information Retrieval System Facility Subsystem
ABANDONED MINES
Abandoned Mines
FINDS ------------------------
Facility Index System/Facility Registry System
DOCKET HWC
Hazardous Waste Compliance Docket Listing
ECHO
Enforcement & Compliance History Information
UXO--------------------------
Unexploded Ordnance Sites
FUELS PROGRAM
EPA Fuels Program Registered Listing
AIRS
Air Quality Permit Listing
ASBESTOS__________________
ASBESTOS
COAL ASH
Coal Ash Disposal Sites
DRYCLEANERS
Drycleaning Sites
Financial Assurance_ _ _ _ _ _
_ _ _ _ Financial Assurance Information Listing
NPDES
NPDES Facility Location Listing
UIC
Underground Injection Wells Listing
AOP--------------------------
Animal Operation Permits Listing
SEPT HAULERS
Permitted Septage Haulers Listing
CCB
Coal Ash Structural Fills (CCB) Listing
PCSRP-----------------------
Petroleum -Contaminated Soil Remediation Permits
MINES MRDS
Mineral Resources Data System
EDR HIGH RISK HISTORICAL RECORDS
EDR Exclusive Records
EDR MGP EDR Proprietary Manufactured Gas Plants
EDR HistAuto ---------------- EDR Exclusive Historical Auto Stations
EDR Hist Cleaner EDR Exclusive Historical Cleaners
EDR RECOVERED GOVERNMENT ARCHIVES
Exclusive Recovered Govt. Archives
RGA HWS Recovered Government Archive State Hazardous Waste Facilities List
RGA LF---------------------- Recovered Government Archive Solid Waste Facilities List
RGA LUST Recovered Government Archive Leaking Underground Storage Tank
SURROUNDING SITES: SEARCH RESULTS
Surrounding sites were identified in the following databases
Elevations have been determined from the USGS Digital Elevation Model and should be evaluated on
a relative (not an absolute) basis. Relative elevation information between sites of close proximity
should be field verified. Sites with an elevation equal to or higher than the target property have been
differentiated below from sites with an elevation lower than the target property.
Page numbers and map identification numbers refer to the EDR Radius Map report where detailed
data on individual sites can be reviewed.
Sites listed in bold italics are in multiple databases.
Unmappable (orphan) sites are not considered in the foregoing analysis.
TC6969216.2s EXECUTIVE SUMMARY 6

EXECUTIVE SUMMARY
STANDARD ENVIRONMENTAL RECORDS
Lists of state and tribal leaking storage tanks
LUST: The Leaking Underground Storage Tank Incidents Management Database contains an inventory
of reported leaking underground storage tank incidents. The data come from the Department of Environment, &
Natural Resources' Incidents by Address.
A review of the LUST list, as provided by EDR, and dated 01/28/2022 has revealed that there is 1 LUST
site within approximately 0.5 miles of the target property.
Equal/Higher Elevation
PHILLIPS MIDDLE SCHO
Incident Phase: CO
Product Type: PETROLEUM
Incident Number: 39357
Current Status: File Located in House
Address Direction / Distance Map ID Page
4371 BATTLEBORO-LEGG NNW 1/8 - 1/4 (0.185 mi.) A2 8
Lists of state and tribal registered storage tanks
UST: The Underground Storage Tank database contains registered USTs. LISTS are regulated under
Subtitle I of the Resource Conservation and Recovery Act (RCRA). The data come from the Department of
Environment & Natural Resources' Petroleum Underground Storage Tank Database.
A review of the UST list, as provided by EDR, and dated 04/08/2022 has revealed that there is 1 UST
site within approximately 0.25 miles of the target property.
Equal/Higher Elevation
PHILLIPS MIDDLE SCHO
Facility Id: 00-0-0000016263
ADDITIONAL ENVIRONMENTAL RECORDS
Address Direction / Distance Map ID Page
ROUTE 2 BOX 1 NNW 1/8 - 1/4 (0.217 mi.) A3 10
Other Ascertainable Records
US MINES: Mines Master Index File. The source of this database is the Dept. of Labor, Mine Safety
and Health Administration.
A review of the US MINES list, as provided by EDR, has revealed that there is 1 US MINES site within
approximately 0.25 miles of the target property.
Lower Elevation Address Direction / Distance Map ID Page
COOL SPRING SAND & G SE 0 - 1/8 (0.003 mi.) 1 8
Database: US MINES, Date of Government Version: 11/02/2021
Mine ID:: 3102203
TC6969216.2s EXECUTIVE SUMMARY 7

EXECUTIVE SUMMARY
There were no unmapped sites in this report.
TC6969216.2s EXECUTIVE SUMMARY 8

Appendix E

SOUTHERN
CONSERVATION
TRUST
Eco Terra, LLC February 26, 2024
Attn: Jordan Burbage
117 Centrewest Ct,
Cary, NC 27513
Delivered electronically: [e-mail]
Re: Bonsai Mitigation Site
NC DWR Project # 2022-0112
Mr. Burbage,
It is the Southern Conservation Trust's intent to serve as holder of a permanent
conservation easement on approximately 22.8 acres in Edgecombe County, North
Carolina as part of the Bonsai Mitigation Project (for Nutrient Offset and Riparian
Buffer Mitigation) that you, Eco Terra, sponsor. We understand that you are in the
submittal phase of the mitigation plan for this project, and that this project is a
smaller component of a larger proposed work site. We plan to work with you as
the project moves forward and are ready to assume responsibility for holding the
easement as soon as it is ready to be recorded.
We are also agreeable to and intend to serve as the Ion 4-4,300
term manager upon
project closeout. We estimate we will need approximately as a long-term
endowment for the responsibilities you have summarized to date, including
boundary inspection, easement enforcement, and signage repair. Please don't
hesitate to reach out for discussion if adjustments need to be made to meet new
mitigation plan or third party requirements.
Our 501(c)(3) nonprofit land trust is a qualified easement holder and committed
to elevating nature through exceptional stewardship. We hold conservation
easements and own and manage fee simple property throughout the state of
North Carolina. We are prepared and well-equipped to carry out the long term
management responsibilities detailed in the plan you have proposed.
We look forward to working with you, the North Carolina Division of Water
Resources, and landowner partners on this important mitigation project in the
Tar -Pamlico River Basin HUC-8 03020101.
Please reach out to us at the contact information below for questions or
clarification.
Regards,
Gi kl"�k
esse Woodsmith
DIRECTOR OF CONSERVATION & STEWARDSHIP
SOUTHERN CONSERVATION TRUST
E: [e-mail]
P: 770-486-7774 EXT. 2 -CONSERVATION
W: WWW.SCTLANDTRUST.ORG

Property: Bonsai Buffer Project (Edgecombe County, NC)
22.8 ac
Requested by SCT: $34,300
A. Estimations
Travel Expenses
Miles from office to property (one-way)
34.0
In this case miles from closest existing SCT
easement in Pitt County, NC, 34 mi and 42 min away.
(SCT owned property within 2.5 hrs (free lodging).)
Average travel time in hours to property (one-way)
0.8
Time from nearest CE (42-45 min... 0.75 used)
Reimbursement per mile
$0.650
The IRS issues standard mileage rates based on the
Other reimbursable travel expenses (e.g., tolls, parking,
$190.00
2 meals & Hotel (Budgeting for needing to stay at a
meals, lodging)
hotel in area. 2.5 hours from SCT lodging at owned
property in Pinehurst, NC. May work out, may not to
stay there each time based on monitoring other
properties.)
Annual Monitoring Expenses
For monitoring, calculate based on Stewardship
Coordinator (Staff #2) lead. This was previously
entered backwards, with Cons/Stew Director lead
(Staff #1). For violations & amendments, will be
Cons/Stew Director lead.
Staff #1: Hours of preparation time per inspection
0.00
Staff #1: Hours of monitoring time per inspection -excluding
0.00
travel time
Staff #1: Hours of reporting and follow up
0.5
Staff #2: Hours of preparation time per inspection
1.5
Staff #2: Hours of monitoring time per inspection -excluding
1.00
Smaller size
Staff #2: Hours of reporting and follow up per inspection
1.0
Other Staff: Hours per inspection
0.0
Equipment and supplies per inspection
$10.00
Easement holders may depreciate the costs of
equipment (e.g., gps device, camera, computer) as
appropriate for the equipment and its use for each
property.
Number of regular monitoring visits per year
1
Number of cars used per monitoring trip
1
Staff may travel separately to the property

Consultant costs per year
$0.00
Depending on the features of the property and the
easement, the holder occasionally may need outside
expertise.
Drive By and Flyover Monitoring Expenses used occasional)
Number of drive -by monitoring trips per year
0.25
Occasional monitoring from the public road is
sometimes desirable to supplement on -site
inspections. (average rounded to 1 in 4 visits)
Staff #1: Average time (in hours) needed per drive -by
monitoring trip (excluding travel time to and from the
0.00
Staff #2: Average time (in hours) needed per drive -by
monitoring trip (excluding travel time to and from the
0.25
Cost of aerial flyover
$10.00
Some organizations use aerial monitoring to
supplement onsite visits. We fly the drone we own.
Cost for incidentals and depreciation.
There will be an aerial flyover approximately every
years
3
For example, entering the number 20 would mean the
land trust expects 1 aerial flyover per 20 years.
Landowner Communication Expenses
1 landowner, standard communication
Staff #1: Hours per year
0.75
Staff #2: Hours per year
1.00
Other Staff: Hours per year
0.00
Materials and supplies per year
$0.00
For example, printing of educational materials and
postage
Landowner Communication Expenses: Change in
Landowner
These costs should reflect the time and costs
associated with one change in ownership. Stew
Coordinator Lead (Staff #2).
Staff #1: Hours for establishing a relationship with new
landowners, excluding travel time
1.00
Staff #2: Hours for establishing a relationship with new
landowners, excluding travel time
2.00
Other staff: Hours for establishing a relationship with new
0.50
Staff #1: Number of site visits needed to establish a
relationship with new landowner
0.00
This number may reflect an average for all properties
and therefore is not necessarily a whole number.

Staff #2: Number of site visits needed to establish a
0.5
Reduced to 0.5 because these are generally planned
relationship with new landowner
for the next annual monitoring visit with the new
landowner and not a second visit during the same
year.
Supplies
$0.00
For example, a copy of the easement and materials
about the land trust's stewardship program
It is estimated that there will be one change in land
30.0
This should not be zero.
ownership every years
Review of Reserved and Permitted Rights and
The conservation easement document may specify
Approvals
that the landowner will pay for the land trust's costs at
the time of review. If this is the case, enter zeros in
this section.
It is estimated that there will be one review every years
30.0
If the easement does not contain reserved or
permited rights, place a zero here.
Staff #1: Hours needed per action subject to review
1.00
Staff #2: Hours needed per action subject to review
2.00
Other staff: Hours needed per action subject to review
1.00
Staff #1: Number of site visits required to complete one
0.00
Staff #2: Number of site visits required to complete one
1.00
Consultant costs per review
$0.00
Land Trust Initiated Amendment Expenses
If the landowner seeks an easement amendment, the
landowner would normally be expected to pay the
costs associated with the amendment at the time of
amendment. SCT has received feedback that prior
estimates were too low and have thus been
increased, as well as ocassional legal costs, for most
prudent long-term defense.
Staff #1: Hours needed to complete an amendment,
7.00
Occasionally a holder will want to initiate an
excluding travel time
amendment. The Pennsylvania Land Trust
Association has little empirical data on the costs of
these amendments, and no information on their
Staff #2: Hours needed to complete an amendment,
0.00
excluding travel time

Other staff: Hours needed to complete an amendment
1.00
Staff #1: Number of visits required per amendment
1.00
Staff #2: Number of visits required per amendment
0.00
It is estimated that there will be one land trust initiated
amendment every years.
50
Got the feedback to increase the frequency.
Legal Expenses
Legal fees per year
$250.00
Minor and miscellaneous legal expenses may be
incurred as the easement holder seeks to reconcile
monitoring findings with easement terms, the
landowner seeks clarification on easement terms, etc.
These costs are expected to occur with no particular
frequency. Many attorneys SCT works with donate
their time, but this is not always the case.
Minor Violation Incidents (resolved without resort to the
On buffer projects with straightforward terms, this is re
It is estimated that there will be one minor violation every
years.
10.0
This should not be zero. Increased on this one minorly
because of site layout complexity
Staff #1: Hours needed to address the violation, excluding
travel time
4.00
Staff #2: Hours needed to address the violation, excluding
travel time
2.00
Other staff: Hours needed to address the violation
0.50
Staff #1: Number of site visits required per violation
1.00
Staff #2: Number of site visits required per violation
0.00
Legal costs per incident
$500.00
Consultant costs per incident
$0.00
Depending on the complexity and provisions of the
easement, easement holders should plan for the
costs of hiring a consultant.
Major Violation Incidents (requiring litigation)
Reduced for buffer project type
It is estimated that there will be one major violation every
years
50
This should not be zero

Average cost to address major violation (staff, attorney,
court fees & other)
$10,000
Got the feedback not to reduce beyond —$10k.
Conservation defense insurance annual premium
$0.00
It is not our practice to insert this here - this line is
from another organization's template.
Annual Rate of Return
Average annual return on Stewardship Fund investments
less inflation rate
4.00%
Staff and Overhead Rates
Staff #1 Conservation Director: Hourly rate, including
$31.00
Staff #2 Stewardship Coordinator: Hourly rate, including
benefits
$27.00
Other Staff Executive Director: Hourly rate, including
benefits
$67.00
Office overhead costs (rent, insurance, equipment) as a
5%
Stewardship Needs -Final Calculations (This will automatically calculate
based on your entries in the estimations section)
Annual stewardship costs (including the cost to $1,172
respond to minor violations)
Endowment needed to fully cover annual $29,288
stewardship costs
Annual costs needed to defend against major $200
violations
Endowment needed to fund easements against $5,000
major violations
Total $34,288.18
Formulas used in this calculator to calculate total stewardship needs (the formalas are here to show users how total stewardship needs
These are all calculated automatically, you don't need to do anything! Formulae Used

Staff Costs
Executive Director: Hourly rate, including overhead and
$67.00
B94+(B94*B97)
Director of Conservation: Hourly rate, including overhead
$31.00
B95+(B95*B97)
Field Biologist: Hourly rate, including overhead and benefits
$27.00
B96+(B96*B97)
Travel Costs
Roundtrip mileage cost
$44.20
B15*B17*2
Other reimbursable travel expenses
$190.00
B18
Staff #1: Cost of staff time to travel to and from eased
$100.50
(13112*B16*2)
Staff #2: Cost of staff time to travel to and from eased
$46.50
(13113*B16*2)
Total Annual
Stewardship
Costs
Formulae
Annual Monitoring Costs
Staff time per regular inspection
$188.50
((B21+B22+B23)*B112)+((B24+B25+B26)*B113)+(B2
Travel costs per regular inspection
$234.20
(6117+13118)*B30
Consultant costs per regular inspection
$0.00
B31
Supplies per regular inspection
$10.00
B28
Annualized cost of drive -by monitoring
$246
IF(B34=0,0,(B35*B119)+(B36*B120)+B117+13118)
Annualized cost of aerial flyover
$3
IF(B38=0,0,(1/B38)*B37)
Total annual monitoring costs
$681.86
(13124+13125+B127)*B29+B128+B129
Annual Costs of General Landowner Communications
Staff time
$81.25
(1341*13112)+(B42*B113)+(B43*B114)
Supplies
$0.00
B44
Total costs of general landowner communications
$81.25
13133+13134
Annualized Costs of Landowner Communications -Change
in Landownership
Staff time
$165.75
(1347*13112)+(B48*B113)+(B49*B114)+(B50*B119)+(B
Travel costs
$117.10
B50*(B117+13118)+B51*(13117+13118)
Supplies
$0.00
B52
Likelihood of a new landowner in any given year
3%
1/1353
Annualized cost associated with new landowner
$9.43
(13138+13139+13140)*13141
Annualized Costs for Review of Reserved and Permitted Rights and Approvals
Staff costs $202.50 13112*B57 + B113*B58 + B114*B59 + B60*B119 + B

Travel costs
$234.20
(B60*(B117+B118))+(B61*(B117+B118))
Consultant Costs
$0.00
B62
Likelihood of an exercise of a reserved right in any given
3%
IF(B56=0,0,1/B56)
Annualized cost for review and approval of reserved rights
$14.56
(B145+B146+B147)*B148
Annual Costs of Holder Initiated Amendments
Staff time per amendment
$596.50
(B65*B112)+(B66*B113)+(B67*B114)+(B68*B119)+(B
Travel costs per amendment
$234.20
(B68*(B117+B118))+(B69*(B117+B118))
Likelihood of a holder initiated amendment in any given year
2%
1/B70
Total annualized holder initiated amendment costs
$16.61
(B153+B154)*B155
Annual Legal Costs
Legal fees per year
$250.00
B73
Total annual legal costs
$250.00
B159
Total Annual Regular Stewardship Expenses
$1,053.71
C130+C135+C142+C149+C156+C160
C. Calculation of Costs Associated with Violations
Minor Violations
Staff costs to address violation
$444.00
(B112*B77)+(B113*B78)+(B114*B79)+(B80*B119)+(B
Travel costs
$234.20
(B80*(B117+B118))+(B81*(B117+B118))
Legal costs
$500.00
B82
Likelihood of violation in any given year
10%
1/B76
Total annualized cost to deal with minor violations
$117.82
(B167+B168+B169)*B170
Major Violations
Cost to address violation
$10,000
B87
Likelihood of major violation in any given year
2%
1/B86
Annualized cost to deal with major violations
$200.00
B174*B175
D. Endowment Calculations
Annual stewardship and minor violation costs
$1,172
C162+C171

Average annual return on stewardship fund investments less
4.00%
B91
Endowment needed to cover annual stewardship costs
$29,288.18
C182/C183
Annual costs needed to defend against major violations
$200.00
C176
Avera e annual return on stewardship fund investments less
4.00%
B91
Endowment needed to fund easements a ainst major
$5,000.FO
C187/C188