Swiftie Buffer Plan - DWR Review

From:
Merritt, Katie
To:
Menefee -Dunn. Barbara A
Subject:
FW: Swiftie Buffer Plan - DWR Review
Date:
Tuesday, April 23, 2024 1:01:44 PM
Attachments:
Swiftie DWR Comment summarv.odf
Please file this email thread and the attached document in 1 PDF and file as "Mitigation Plan" for the
Document Type metadata in 2023-0026v1.
Thanks!
From: Merritt, Katie
Sent: Friday, March 22, 2024 12:02 PM
To: Catherine Manner<[e-mail]>
Cc: Davis, Erin B CIV SAW <[e-mail]>; Tugwell, Todd J CIV USARMY CESAW (US)
<[e-mail]>; Polizzi, Maria <[e-mail]>
Subject: Swiftie Buffer Plan - DWR Review
Hey Catherine,
Pursuant to Titles 15A NCAC 02B .0295 and 15A NCAC 02B .0703, a provider shall submit a
project plan proposal to the Division of Water Resources (Division) for review and approval
that includes specific elements of the project. On September 21, 2023 (resubmitted February
21, 2024), Water & Land Solutions, LLC (WLS) submitted a draft Buffer Mitigation & Nutrient
Offset Plan (Plan) for the Swiftie site, to the Division, for review and approval. This Plan is
Appendix I of the Swiftie Stream & Wetland Mitigation Plan. 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 WLS during this busy time, I have provided my comments
in a different format. Attached are the comments & edits provided within the actual PDF of a
condensed Plan (without Appendices) as well as a comment summary.
When WLS is ready to submit their final project Plan, please include a summary of all WLSs'
responses to the DWR comments acknowledging how WLS addressed the comments. Please
upload the final Plan using our Mitigation Project Information Upload Form through this link:
https://edocs.deq.nc.g_ov/Forms/Mitigation_ Information_ Upload.
Please note the DWR ID## 2023-0026 (version 1) 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.
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: httl2s://deq.nc.gov/about/divisions/water-resources/water-quality_permitting/401-
buffer-permitting-branch
512 N. Salisbury Street, Raleigh, NC 27620
1617 Mail Service Center, Raleigh, 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.

ID# * 20230026 Version * t
Select Reviewer: "
Katie Merritt
Initial Review Completed Date 02/26/2024
Mitigation Project Submittal - 2/21/2024
Is this a Prospectus, Technical Proposal or a New Site?*
Type of Mitigation Project: *
Stream Wetlands Buffer Nutrient Offset
(Select all that apply)
Project Contact Information
.......................
Contact Name: *
Catherine Roland
Project Information
ID#:* 20230026
Existing 10#
Project Type:
Project Name:
County:
DIMS Mitigation Bank
Swiftie
Edgecombe
Document Information
Yes No
Email Address: *
[e-mail]
Version:* t
Existing Version
Mitigation Document Type:
Mitigation Plans
File Upload: Swiftie Draft BPDP All.pdf 5.69MB
Please upload only one POF of the complete file that needs to be submitted...
Signature
Print Name: * Catherine Roland
Signature:
rrt/rrtei<r , i0'/r��rr�'

Swiftie Buffer Mitigation & Nutrient offset Plan
Riparian Buffer & Nutrient Offset Mitigation Bank
DWR 420230026 v1
Edgecombe, North Carolina
Tar River Basin (HUC 03020101)
DRAFT September 2023
.;iye- "��`> a:. • a-tq' -. •ry - f.. yS.r' r M
'..r• ,r
l�
Prepared by
WATER & LAND SOLUTIONS
7721 SIX FORKS ROAD, SUITE 130, RALEIGH, NC 27615
(9191 614 - 5111 1 waterlandsolutions.com

Summary of Comments on 20230026 Ver 1_Swiftie Draft
BPDP_AI1_20240221.pdf
Page: 5
Number: 1 Author: kymerritt
Subject: Sticky Note Date: 3/19/2024 1:58:49 PM
this MBi is incorrectly referred
to on page 10 in section 3 as the "Stream MBI".
Number: 2Author: kymerritt
Subject: Inserted Text Date: 3/19/2024 1:13:04 PM
proposed
Number: 3Author: kymerritt
Subject: Inserted Text Date: 3/19/2024 1:17:52 PM
0703
�Number:4Author: kymerritt
Subject: Inserted Text Date: 3/19/2024 1:21:18 PM
April 1, 2020 and
Number: SAuthor: kymerritt
Subject: Inserted Text Date: 3/19/2024 1:21:32 PM
respectively
Number: 6Author: kymerritt
Subject: Inserted Text Date: 3/19/2024 1:18:01 PM
Stream & Wetland
Number: 7Author: kymerritt
Subject: Inserted Text Date: 3/19/2024 1:18:25 PM
Stream & Wetland
QNumber: 8Author: kymerritt
Subject: Sticky Note Date: 3/19/2024 1:21:05 PM
We cannot use "Mitigation" to
describe nutrient offset because it is not a type of compensatory mitigation.
Number: 9Author: kymerritt
Subject: Inserted Text Date: 3/19/2024 1:20:08 PM
This Nutrient Offset & Buffer
Mitigation Plan is included as Appendix I of the Stream & Wetland Mitigation Plan.
—]Number: 10 Author: kymerritt Subject: Cross -Out Date: 3/19/2024 1:20:23 PM
Number: 11 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:20:21 PM
mitigation
JNumber: 12 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:21:53 PM
credit
Number: 13 Author: kymerritt Subject: Cross -Out Date: 3/19/2024 1:23:29 PM
Number: 14 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:23:46 PM
in a conservation easement when combining this project with the stream and wetland mitigation project
Number: 15 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:25:00 PM
The Parcel is intended to generate stream, wetland, riparian buffer and nutrient offset credits.

Number: 1 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:25:48 PM
that are proposed in the Stream & Wetland mitigation plan.
Number: 2Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:27:12 PM
The upper reach of S100 was determined to be an ephemeral channel by DWR.

Page: 7
Number: 1 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:27:48 PM
S700 is not being proposed in this Plan.
gPNumber: 2Author: kymerritt Subject: Sticky Note Date: 3/19/2024 1:29:14 PM
make sure "Stream & Wetland Mitigation Plan" is accurately differentiated from this Plan throughout. There are references to a "Plan" that could be confused
with the stream plan. Just make sure we know which plan is being referenced

Page: 10
Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/19/2024 1:39:22 PM
let's clarify "Bank" since it hasn't been yet in the text. i recommend the following:
Stream & Wetland Mitigation Bank and Nutrient Offset & Buffer Mitigation Bank (hereby referred to as "Swiftie Bank")

Page: 11
Number: 1 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:55:41 PM
Swiftie
QNumber: 2Author: kymerritt Subject: Sticky Note Date: 3/19/2024 1:33:08 PM
has anything changed with the listing that would reclassify the bat to endangered now?
QNumber: 3Author: kymerritt Subject: Sticky Note Date: 3/19/2024 1:34:12 PM
Will there be an impact on planting or construction dates/planning if the bat's listing had changed to endangered?
QNumber: 4Author: kymerritt Subject: Sticky Note Date: 3/19/2024 1:39:50 PM
you already say in the Introduction that this project is called a "Parcel". You did not call it a "Bank". I did recommend text change to section 2.5 to call out
"Swiftie Bank" to be all-inclusive of the entire project. So in this sentence, it should be "Swiftie Bank" based on the context after it. It can be very confusing
reading through the plan when there is inconsistency usage of terminology. Make sure the Intro of the Plan is clear on the meanings of "Parcel", "Bank", "MBI",
"Plan", etc. With combo projects, the wording and references need to be clear to differenitate between the Stream/Wetland project and the Buffer/Nutrient
Offset project.
QNumber: 5Author: kymerritt Subject: Sticky Note Date: 3/19/2024 1:39:03 PM
Either call it in section 2.5 as "Swiftie Bank" or call it "Bank Parcel". Then change everything to either be "Swiftie Bank" or "Bank Parcel"
QNumber: 6Author: kymerritt Subject: Sticky Note Date: 3/19/2024 1:42:48 PM
culverts (s100, D3), existing road (on D1) and berms (adjacent to S100) are also constraints on this site in that the site needs to address them in order to be viable
to generate the credit types being proposed. Look at the Site Viability letter and address additional constraints here
QNumber: 7Author: kymerritt Subject: Sticky Note Date: 3/19/2024 1:43:42 PM
approval is only granted through the approval of this mitigation plan, not a site viability letter.
Number: 8Author: kymerritt Subject: Cross -Out Date: 3/19/2024 1:48:03 PM
it Number: 9Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:43:22 PM
assessed
IV Number: 10 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:47:59 PM
the Site Viabilitv Letter
[,-]Number: 11 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:43:17 PM
and agricultural ditches
IV Number: 12 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:56:13 PM
❑� Number: 13 Author: kymerritt Subject: Cross -Out Date: 3/19/2024 1:56:18 PM
QNumber: 14 Author: kymerritt Subject: Sticky Note Date: 3/19/2024 1:56:44 PM
the was already referred to as "MBI" in the Introduction
[,-]Number: 15 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 1:56:59 PM
Mitigation
Number: 16 Author: kymerritt Subject: Cross -Out Date: 3/19/2024 1:56:54 PM
[,-]Number:17 Author:
(MBI)
Inserted Text Date: 3/19/2024 1:59:44 PM
Maybe WLS would like to add clarification in the Introduction and in this section that there is a "USACE MBI" and a "DWR MBI" or a "Stream/Wetland
MBI" and a "Buffer/Nutrient Offset MBI".
Just a recommendation on how you can use both butjust clarify which one you are referring to. Whichever way you choose to differentiate these,
continue the change throughout the rest of the document. Should probably use the right distinction in the Stream/Wetland Plan as well.

Page: 12
Q Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:26:16 PM
a "riparian buffer" to DWR refers to the rule definition of "TarPamlico Buffer", which has a Zone 1 and Zone 2 maximum width of 50'. sinfe you are restoring well
beyond the riparian buffer on most streams, you have to further define those areas as "riparian areas".
[,-]Number: 2Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:02:18 PM
and adjacent riparian areas
QNumber: 3Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:05:11 PM
add additional details here regarding culvert removal, road removal and relocation off 5100, what will be done to remove compaction along that road bed, berm
removal off 5200, filling ditches in riparian areas (example: off 5200), etc. see viability letter for verbiage pertaining to expectations that determine whether a
feature can generate credits or not then address here.
QNumber:4Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:09:08 PM
i want to make sure that the top soils are not being just dedicated to wetland credit areas or streamside buffer zones. It has been observed on sites in the past,
that the good soil will be removed from the riparian areas and utilized for stream and wetland restoration purposes... thus, leaving the areas generating buffer or
nutrient offset in the wider riparian width areas, void of healthy soils - resulting in vegetation issues (low vigor, stunted growth, bare soils, low herbacous
coverage, etc). Please address how WLS will ensure this doesn't happen.
❑+ Number: 5Author: kymerritt Subject: Cross -Out Date: 3/19/2024 2:05:48 PM
[,-]Number: 6Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:06:05 PM
Parcel, including the areas where riparian buffer and nutrient offset credits are being generated.
QNumber: 7Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:11:06 PM
how is WLS proposing to maintain diffused flow? explain. If wanting to use the clarification memo, speak to that and add to the appendix.
[,-]Number: 8Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:15:48 PM
Most of the riparian restoration efforts will take place adjacent to mitigated streams, constructed per the approved Stream and Wetland Mitigation Plan.
QNumber: 9Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:34:07 PM
which mitigation plan?
Number: 10 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:21:38 PM
L�J riparian
Number: 11 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:22:05 PM
where riparian buffer and nutrient offset credits are proposed,
❑t Number: 12 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:23:57 PM
These ditches include the ditch located along the upper reach of 5200, but do not include D2, D3 and D4, which are going to remain as they are and
planted.
you can look at viability letter for reference.
QNumber: 13 Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:30:14 PM
need to add a statement here that riparian buffer credits are being proposed under 15A NCAC 02B .0295 (o)(2)
QNumber: 14 Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:33:43 PM
Ditches are not labeled correctly. Go to the site viability letter and use the labels of the ditches as they were provided in the letter. Update all figures and the
corresponding Project Credit Table accordingly. There should be "D2, D3 and D4". D1 is not a ditch, it is an ephemeral channel being allowed to be submitted
for review under 0295 (o)(7). You will need to add a paragraph explaining how D1 meets the rule for generating buffer credits. You do NOT have to do this part
for D1 if you decide NOT to request any buffer credit off D1. According to the Project Credit Table, WLS is not proposing buffer credits off D1.
❑] Number: 15 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:35:57 PM
stream
❑+ Number: 16 Author: kymerritt Subject: Cross -Out Date: 3/19/2024 2:37:23 PM
Number: 17 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:37:20 PM
the Site Viability Letter
This rule reference does not speak to ditches being used for nutrient offset credits. What allows these credits is the Site Viability Letter and the DWR
MBI.
Number: 18 Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:37:40 PM
offset

Page: 13
Q Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:35:13 PM
rules says "the area of the buffer shall be measured perpendicular to the length of the valley being restored"
Edit your sentence to read this way.
Number: 2Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:38:49 PM
riparian buffer
[,-]Number: 3Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:39:14 PM
as depicted in the credit release schedule proposed in the MBI.
QNumber: 4Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:40:19 PM
add D1 details next:
"D1 was determined to be an ephemeral channel by DWR and begins upstream of S100....
QNumber: 5Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:24:44 PM
why will riparian buffer restoration along ditches be less than 50? riparian restoration on figures is showing much farther than 50', and it looks like only nutrient
offset is being proposed off ditches. Explain.
QNumber: 6Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:43:54 PM
there is no existing condition treeline provided in Figures. DWR has to have this in order to make sure the Preservation vs Restoration credit areas are able to
be compared to what is submitted in the AsBuilt Report Survey. The existing treeline today, before trees are cleared for stream restoration, will look different
on the AsBuilt Survey... therefore it is required on combo projects for the Provider to have a treeline for the Mitigation Plan and to then overlay that existing
condition tree line with the asbuilt survey so that the forested areas today are still presented as "forested" at AsBuilt and measured for buffer preservation
credit totals and NOT buffer restoration credit totals. do not change from Mitigation Plan to Asbuilt. make sure this treeline is overlayed on the asbuilt
survey.
QNumber: 7Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:45:54 PM
5200 was shown to have Preservation in the Site Viability letter, and isn't referenced in this section. Why? There is also a berm and a ditch located within the
forested areas off 5200 that, even if no preservation buffer credits are being sought in the forested areas, the berm and the ditch present in the riparian zone
must be addressed in order to get the restoration credits proposed in the fields.
QNumber: 8Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:46:18 PM
why isn't "riparian buffer credit areas" referenced here too?
it Number: 9Author: kymerritt Subject: Inserted Text Date: 3/19/2024 2:46:36 PM
riparian

Page: 14
-_ Number: 1 Author: blake.hartshorn Date: 2/26/2024 11:13:08 AM-05'00'
This will be updated per USACE comment #20 in the NCIRT comments regarding the WLS Swiftie Mitigation Bank
rip Number: 2Author:
Note Date: 3/19/2024 2:49:50 PM
there are two things missing from the table that is needed to determine if the planting plan meets expectations in Rule:
1) add the anticipated planting density of each species
2) add a column for "Tree/Shrub" and label each species accordingly.
Aren't some of these trees normally considered a subcanopy tree?
Need to add a figure to this Plan showing the "Planted Area". and then reference this figure in this section. If there are also plan sheets from the stream &
wetland plan that should also be referenced here, add those as well.
QNumber: 3Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:53:18 PM
All of these trees are required to be planted. If they are mentioned in this table, Dwr will inspect the site at asbuilt walk (task 2) to make sure this list was used in
its entirety. therefore, 14 species must be planted. If this is not hte plan, then WLS needs to modify this table to address this comment. If planning to plant less
than 14 species, then include another list of requested substitutions if a species isn't availbale. Along with that substitution list, you will have to include the
anticipated planting density you intend to plant it as to make sure you aren't exceeding the performance std of " no species is greater than 50W
gbNumber: 4Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:50:37 PM
Species substitutions must be coordinated by DWr and the USACE FIRST.
❑� Number: 5Author: kymerritt Subject: Cross -Out Date: 3/20/20244:34:08 PM
[,-]Number:6Author:kymerritt Subject: Inserted Text Date: 3/20/2024 4:34:16 PM
❑� Number: 7Author: kymerritt Subject: Cross -Out Date: 3/20/2024 4:34:22 PM
[,-]Number:8Author:kymerritt Subject: Inserted Text Date: 3/20/2024 4:34:40 PM
where riparian buffer credits and nutrient offset credits are being generated,
�Number:9Author: kymerritt Subject: Cross -Out Date: 3/20/20244:37:23 PM
[,-]Number: 10 Author:
Inserted Text Date: 3/20/2024 4:36:10 PM
[,-]Number: 11 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 11:04:23 AM
Vegetation data in plots located within the coastal headwater valley restoration areas will be collected for seven consecutive years in order to comply with the
expectations of the performance standards established on coastal headwater streams.
_ Number: 12 Author: blake.hartshorn Date: 2/26/2024 11:13:08 AM-05'00'
The number of vegetation plots will be updated after the final planted acreage is determined.

Page: 15
vo Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/20/2024 4:42:01 PM
monitoring expectations were voted on in our annual meeting in November 2023. In addition to the monitoring protocol, average vigor per plot must also be
collected, per plot, and reported in Years 1, 3 & 5. Additionally, height must also be collected, per stem, per plot and reported in Years 1, 3, & 5. All other data is
to be collected each year as normally expected.
Modify text within this section to address the additional monitoring expectations.
Number: 2Author: kymerritt Subject: Sticky Note Date: 3/22/2024 11:05:07 AM
specify the plots that this section will apply to. There should be Plot numbers or at least a reference to the figure where these plots are shown. it also doesn't
appear that some of the HWV buffer restoration credits are being measured off the right reach of S200
QNumber: 3Author: kymerritt Subject: Sticky Note Date: 3/20/20244:43:57 PM
specify which plots that this section will apply to. There should be Plot numbers or at least a reference to the figure where these plots are shown.

Page: 17
* Number: 1 Author: kymerritt Subject: Cross -Out Date: 3/20/2024 4:44:52 PM
VNumber: 2Author:kymerritt Subject: Inserted Text Date: 3/20/2024 4:44:48 PM
stream, wetland, buffer
VNumber: 3Author: kymerritt Subject: Inserted Text Date: 3/20/2024 4:45:14 PM
activities
Number: 4Author: kymerritt Subject: Cross -Out Date: 3/20/2024 4:45:59 PM
❑� Number: 5Author: kymerritt Subject: Cross -Out Date: 3/20/20244:45:40 PM
[,—]Number:6Author:kymerritt Subject: Inserted Text Date: 3/20/2024 4:45:38 PM
fully implemented according to both of the mitigation plans, including all plantings,
[,—]Number: 7Author: kymerritt Subject: Inserted Text Date: 3/20/2024 4:46:44 PM
. Notification to DWR shall include information
[,—]Number:8Author:kymerritt Subject: Inserted Text Date: 3/20/2024 4:46:56 PM
adequately
V Number: 9Author: kymerritt Subject: Inserted Text Date: 3/20/2024 4:47:13 PM
Plan
❑i Number: 10 Author: kymerritt Subject: Inserted Text Date: 3/20/2024 4:47:30 PM
Plan
Number: 11 Author: kymerritt Subject: Inserted Text Date: 3/20/2024 4:47:24 PM
Plan
[,—]Number: 12 Author: kymerritt Subject: Inserted Text Date: 3/20/2024 4:47:21 PM
and Riparian Buffer Credits
QNumber: 13 Author: kymerritt Subject: Sticky Note Date: 3/20/20244:47:54 PM
DWR does not have a template
❑� Number: 14 Author: kymerritt Subject: Cross -Out Date: 3/20/2024 4:47:45 PM
[,—]Number: 15 Author: kymerritt Subject: Inserted Text Date: 3/20/2024 4:48:12 PM
to seven
Number: 16 Author: kymerritt Subject: Cross -Out Date: 3/20/2024 4:48:26 PM
[,—]Number: 17 Author: kymerritt Subject: Inserted Text Date: 3/20/2024 4:48:39 PM
the Ephemeral channel (D1) and
QNumber: 18 Author: kymerritt Subject: Sticky Note Date: 3/20/20244:50:22 PM
assignment is required by Year 4, whereas the official transfer of responsibilities to a long term steward can be later, at issuance of final credit release. some of
the langauge in this section may conflict with this expectation in the MBI, update accordingly as needed.
QNumber: 19 Author: kymerritt Subject: Sticky Note Date: 3/20/20244:51:19 PM
Acknowledge that there are trails located within the CE but that these trails will not bisect the riparian areas or features where riparian buffer and nutrient offset
credits are being proposed.

Page: 20
Number: 1 Author: kymerritt Subject: Inserted Text Date: 3/20/2024 4:54:11 PM
are convertible
VNumber: 2Author:kymerritt Subject: Inserted Text Date: 3/20/2024 4:53:57 PM
Some
wNumber: 3Author: kymerritt Subject: Sticky Note Date: 3/20/20244:59:37 PM
add a statement here as follows:
the credit type, mitigation activity and associated buffer mitigaiton and nutrient offsets are presented in Table 6. Credits that are convertible between buffer
and nutrient offset is also presented.

Page: 21
,Lr
Number: 1 Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:00:28 PM
All requests for credit conversions and transfers must be made in writing with written approval received by DWR prior to adding or removing credits from the
project's credit ledgers.
❑� Number: 2Author: kymerritt Subject: Cross -Out Date: 3/20/2024 5:01:28 PM
V Number: 3Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:02:41 PM
4
[,-]Number: 4Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:01:26 PM
and buffer preservation credits;
Number: 5Author: kymerritt Subject: Cross -Out Date: 3/20/2024 5:02:19 PM
Number: 6Author: kymerritt Subject: Cross -Out Date: 3/20/2024 5:03:33 PM
Number: 7Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:03:04 PM
buffer restoration credits excluding coastal headwater buffer areas; one for
[,-]Number: 8Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:03:28 PM
and one for Phosphorus nutrient offset credits.

W
Table 6. [Swiftie Mitigation Bank], 12023l0026 v1], Project Credits
P Credit Conversion Ratio lft'lpound)
Total Ephemeral Area J1ta) for Credit
Total Efigi ble Ephemeral Area [ft') 1 z 0.0
El Preservation Credits Below
CRdb Type I LaaUpn I Syb]lctl Feature TyPe Mltlgatlen ActivitY I Min hSdffer
TOTAL AREA OF BUFFER MITIGATION {TARMI
Mitigation Totals
Square Feet
Credits
Reslaratfon:
�464.3851�Enhancement-
MOLD
Preservation:Total
Riparian Buffer:49,a66.fi67
TOTAL NUTRIENT OFFSET
MITIGATION
Mitigation Totals
Square Feet
Credits
Nutrient ofESM: NICYogen:
Phos horns:
1. The Randleman Lae u er rules
Ip s,52a
allow some
1q 715.17,
3,527.3ao
led
last updated 08/03/2020
5300
Ablu
Preservation Area Subtatals Ift'):I 5%,6TT [ 596,677
as subject according to lsA Ncae B2B.BxsB (s}(a}.
Reaches as %TASM
in as % TABM
R tie xet}t I %FUIICrctllt I FI-Ilydl� I RIPCRd8t

Page: 22
*Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:12:56 AM
Add a figure to the Plan showing the 50, 100 and 200' width boundaries around features. At this time, this Plan does not have this boundary map and
therefore DWR cannot confirm that this table is accurate. Just having the widths color coded on Figure 6 and 8 isn't acceptable for this level of review
needed.
QNumber: 2Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:06:27 PM
nutrient offset credits within 101-200 are not convertible to RBC, change those to "NO". (See MBI) The only way to obtain RBC within those widths is request
them at Mit Plan stage and then check "YES" for Nutrient Offset convertible. If you do that, then you have to update the figures where you made the change to
the credit type requested.
QNumber: 3Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:04:43 PM
correct the labeling of the ditches to match the site viability letter.
❑V Number: 4Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:04:36 PM
D1
J Number: 5Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:04:38 PM
D1
V Number: 6Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:06:37 PM
NO
IV Number: 7Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:06:42 PM
NO
Number: 8Author: kymerritt Subject: Inserted Text Date: 3/20/2024 5:06:50 PM
NO
QNumber: 9Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:11:07 PM
S200 was determined to be "Not Subject", correct?
Q Number: 10 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:10:32 AM
according to figure 6, HWV restoration doesn't start until furtter downstream on S200, with enhancement upstream. Shouldn't some of these S200 credits be
normal I/P restoration?
QNumber: 11 Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:07:53 PM
this red number is showing that the amount of preservation credits you entered below has exceeded the 25% threshold. remove the preservation credits below
until this show 25.0% and is no longer red.
QNumber: 12 Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:09:11 PM
this is your maximum ft2 allowable for Preservation. you have exceeded that by 96.4% instead of 25%
QNumber: 13 Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:08:48 PM
The maximum ft2 you are allowed to deem as "Total (Creditable Area of Buffer Mitigation) is 154,795.
QNumber: 14 Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:09:27 PM
leave all these areas as they are only adjust the next column over.
QNumber: 15 Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:10:24 PM
S200 was observed as having preservation worthy areas in the site viability letter. is no preservation being proposed for RBC?
QNumber: 16 Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:11:56 PM
at this time, DWR cannot confirm whether these credit area totals double dip with any other credit types because Figure 6 is not complete. Figure 6 needs to
look more like Figure 8.

Page: 25
*Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:12:36 PM
change this to read "Nutrient Offset & Buffer Credit Service Area"
QNumber: 2Author: kymerritt Subject: Sticky Note Date: 3/20/2024 5:12:54 PM
change to "Credit' Service Area

Q Approximate Project Boundary
Parcel Boundary
Existing Roads a
Ephemeral Stream
— Existing Stream
Existing PJD Ditches _
Existing PJD Wetland (v )
Existing Hydric Soil
Open Water Feature
G Existing Culverts a
--- Existing Utility (powerline) t itoo
C,,
. I]WR Stream Reach Stop (52oc. ;W02
? — Hydric Soil
Ephemeral 1 (Ditch.1%
OWR Stream Origin-(S100j 33
Ca
G
to
3., a)
�
At
0
r ovvF
r4
IN
f- I'
500 1,000 2000,1
ph _ 11
•r Fee[
1 inch = 1,000 feet N
Swiftie Mitigation Project
8
Figure
WATER & LAND
HUC8 Tar -Pam 01 - 03020101
Edgecombe County, North Carolina
Ex tirM Mac
p
5
SSOLUTIONSs
Map Projection: NA>7_t883_StatePlan e_North_Carolina_FIPS_3200_Feel
Date: 2120/2024 _7

Page: 29
*Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:52:28 AM
this needs to be labeled to include "Conservation Easement"
Q Number: 2Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:48:42 AM
label any existing roads that are being planned to be rerouted or removed from the easement.
ipNumber: 3Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:34:44 AM
not necessary to include anything on this map except what is necessary for buffer or nutrient offset. therefore, remove " PJD" terminology, inlcuding the
wetlands & hydric soils. Add
Q Number: 4Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:38:13 AM
add the existing Treeline to this map. this is required to have at Mit Plan stage on combo projects where the treeline will change at asbuilt after the
riparian corridor has been cleared for stream restoration activities. This is important because your Restoration vs Preservation was determined on existing
treeline conditions. This treeline will have to be an overlay on the asbuilt survey to ensure that Preservation vs Restoration are derived from the original
treeline at existing conditions and not what the treeline looks like at asbuilt. DWR cannot determine whether the Preservation vs Restoration areas are
accurately depicted in this Plan without having the treeline shown on the figure.
QNumber: 5Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:30:33 AM
the site viability letter shows a berm here. This berm is also required to be addressed in order for credits to be obtained in the fields. Show the berm and
make sure to reference this figure within the Text of the plan
Number: 6Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:31:14 AM
change all labels of features to match the labeling in the Site Viability Letter. these labels should not change through planning stage.
Number: 7Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:32:00 AM
the "existing road" doesn't seem to be depicted here. Make sure to show that it extends through the easement as existing conditions.
Number: 8Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:29:26 AM
i thinkn this is better to be labeled "Existing Conditions Map" and is consistent with other Plans. I do not see where you include a Figure labeled Existing
Conditions but this Figure seems to fit that category.

t
_ Approximate Project BcUry Stream Mitigation Buffer Dd Nutrient IYIIL1gatio ,
ParqlBundary ® — Restoration Coastal HWV Buffer
Wetland HWV Restoration Restoration 0-100 ft
rxisiiilu El_ P Enhancement Coastal HWV Buffer
9 - Restoration 101-200 ft
— Preservation
BU I16i'11 storation 10 0 ft
1z ' Ditch 13 No Credit
06-16 15 ervation 14 Oft >-
- • - To Remain 17 hemeral Sfzcd���� 16 _ _ _
Positive Drainag(o ° 20 2 zzlC 1 0-100 ff'on 1 19 -200ft
To be Filled
ii 1 z3 -200 ft
s200-RI
1;R2 wag
ti r 0�
�•i*y� EW031
phemeral 1 -,�
5100-R1 _
• - u- too,_ 33
s2 0 a-R3
S100-R3
5200-R4
Was W04
5300-R1 r`
S300-R2
yy0
— won
3
N
Y
W
i
`eek W05
Feet
J `� - fir► 1 i 1 inch = 1,000 feet N
Figure
WATER & LAND
Swiftie Mitigation Project
HUC8 Tar -Pam 01 - 03020101
Edgecombe County, North Carolina
Proposed
a gufFer Map
136
SOLUTIONS
1 Map Projeelion: NA0_1983_StatePlane_North_Cam1ina_FIPS_3200_Fee4
Date: 2f2012024

Page: 30
vo Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:14:50 AM
project boundary needs to read "Proposed Conservation Easement"
[,-]Number: 2Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:25:31 AM
Mitigation
V Number: 3Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:25:44 AM
Offset
rip Number: 4Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:28:34 AM
add a label for "Existing Trails
❑� Number: 5Author: kymerritt Subject: Cross -Out Date: 3/22/2024 9:53:25 AM
[,-]Number: 6Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:53:49 AM
Mitigation
ripNumber: 7Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:38:41 AM
remove wetland type, and replace with "Wetland Credits" and only show where wetland credits are being proposed. We do not need to know what type of
wetland credit is proposed. this will also help m ake the figures less busy and easier to decipher. I would suggest not using a color, like Green, that already
resembles a shade of color you chose to represent buffer and nutrient offset credits.
Number: 8Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:53:59 AM
Wetland Credits proposed
Number: 9Author: kymerritt Subject: Cross -Out Date: 3/22/2024 9:53:37 AM
[,-]Number: 10 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:46:28 AM
for Buffer credit
IV Number: 11 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:46:00 AM
❑+ Number: 12 Author: kymerritt Subject: Cross -Out Date: 3/22/2024 10:39:15 AM
[,-]Number: 13 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 10:39:27 AM
es
[,-]Number: 14 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:46:44 AM
for Buffer Credit
❑i Number: 15 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:46:36 AM
Riparian
it Number: 16 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 10:15:30 AM
Channel
rqb Number: 17 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:27:48 AM
what does Positive Drainage mean? Are these ditches also, and are they remaining or being filled? Manipulated for better drainage?
Number: 18 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:46:51 AM
Riparian
Number: 19 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:46:59 AM
for Buffer Credit
❑� Number: 20 Author: kymerritt Subject: Cross -Out Date: 3/22/2024 9:52:41 AM
❑� Number: 21 Author: kymerritt Subject: Cross -Out Date: 3/22/2024 9:47:10 AM
[,-]Number: 22 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:47:24 AM
Riparian Restoration for Nutrient Offset
IV Number: 23 Author: kymerritt Subject: Inserted Text Date: 3/22/2024 9:47:35 AM
Riparian Restoration for Nutrient Offset
rqb Number: 24 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:51:40 AM
change all labels to match the Site Viability Letter. remove all WO labels and stream reaches. this is irrelevant for this Plan and can give too much information
such that it confuses what is being reviewed for this specific Buffer Plan.
Comments from page 30 continued on next page

_ Approximate Project BcUry Stream Mitigation Buffer, and Nutrient MIL196LIU111 ;•f F;
Parcel Boundary — Restoration Coastal HWV Buffer
Wetland die a HWV Restoration Restoration 0-100 ft
EXisii1llu Enhancement Coastal HWV Buffer
` - — Preservation
= Restoration 101-200 ft
Sulfur Restoration 0-100 ft
Existing Ditch No Credit
Su -Nei Preservation 0-100ft >-
- - To Remain Ephemeral Suvato
Bufitn' Preservation 101-200ft
Positive Drainag(o o
tdutrierrt 0-100 ff
To be Filled
Nuirici 1i 101-200 ft
k
Saaa-R1
25 1• _R2 waa
W03
Ephemeral 27 25 f
_ r
a
5100-R1
30 8 '1 29 33
S1 as-R2 - r
s200-R3
5100-R3
` p 5200-R4
d,i r
Was woo s,
S300-R1 �f
S300-R2
1, o
31
• — 00
, r
R '
3
N „
U
• Sk,�� C`eek W05
0 500 1,000 2-000
'I � ee[
J `� - fir► i 1 inch = 1.000 feet N
Figure
WATER & LAND
Swiftie Mitigation Project
HUC8 Tar -Pam 01 - 03020101
Edgecombe County, North Carolina
32 ❑posed
a Buffet Map
33
1[3It
SOLUTIONS
Map Projection: NAO_1983_StatePlane_North_Camlina_FIPS_3200_Fee!
Date: 2f2012024

Q Number: 25 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:57:13 AM
this blue is supposed to be depicted Coastal HWV buffer credits but that shouldn't start until the Coastal HWV Restoration which is orange, right?
QNumber: 26 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:00:50 AM
add teh berm here and address it to be graded out, stablized and planted
QNumber: 27 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:17:10 AM
sinec you are claiming nutrient offset off this ephemeral channel, i have left out a lot of comments that normally would have to be addressed if you were
requesting buffer credits off this ephemeral. If you make changes here, it will result in a lot of additional changes, figures, text, etc to your revised Plan
before i can approve it. I woudl suggest not making changes here.
Q Number: 28 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:59:03 AM
this green should be orange and showing nutrient off the Ephemeral, measured perpendicular and landward from the feature until that feature changes to
I/P 5100
QNumber: 29 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:38:05 AM
depict the Valley width measurement off HWV reaches. or include on a different figure.
Q Number: 30 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:59:23 AM
this blue should be orange as well for the same reasons
QNumber: 31 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:54:33 AM
add a call out to this area to explain why no restoration for buffer credits is depicts here.
QNumber: 32 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:15:00 AM
this map seems to be showing credit assets, therefore it should be labeled "Swiftie Credit Concept Map". Remember, this map and Figure 8 shoudl match
fofr where credit types (for buffer and nutrient offset) are being depicted. Also, this figure HAS to match how credits are represented in your Project Credit
Table.
This table is most important to show specific types of buffer and nutrient offset credits. but it shouldn't be that specific for showing your stream and
wetland credits. This map needs ALL the things to show me your RBC and NOC. Just show me the bare minimum for Stream & Wetland. That's what the
comments are trying to address.
Q Number: 33 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 9:20:04 AM
Figure 6 and Figure 8 need to match for symbology of credits represented. Update both maps based on comments below for Figure 6 (and some
comments may be redundant on Figure 8)

i -ea
1
OApproximate Project BJ 2 ® ollinator Mead — tream Mitigation 0 Wetland Mitigation
Existing Utility powerline) _ �xist Existing Ditch HWV Restoration Restoration
�lEJQ!!p!1 E!!i!a!l ©m
- a
a Existing Culvert [to remain] — - To Remain Enhancement
13 Existing Culvert [to be removed] Positive Drainage — Preservation Noi i-Rip6L
Existing Roads O9 To be Filled No Credit Frem vatiun
Open Water Feature Ephemeral Stream 10
1p
y 7• �- 4A` R
Swift Creek PRM
As -built Stream `• , S200-R1
} r
Od,
11
_ wQi 12 520D-s
Ephemera 19
hr'
• F
S100-RI
S100-R2
S100-R3
-A W06 woa
S200-R3
5200-1t4
Pollinatoi
IMeadow
Y• �
Swift Creek PRM Easement Boundary
:I-
wift Creek PRM As -built Stream
W05
D 600 1,000 2,000
Fee[
Aft t inch = 1,DD6 feet N
16
Swiftie Mitigation Project Propos� Figure
WATER & LAND HUC8 Tar -Pam 01 - 03020101 Feature
SOLUTIONS Edgecombe County, North Carolina 7
1 Map Projeeeion: NA0_1983_S[atePlane_North_Cam1ina_FIPS_3200_Fee4 Date: 2+2U:2024

Page: 31
Q Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:45:11 AM
also include where Hardwood trees are planted
QNumber: 2Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:22:37 AM
change to include Conservation Easement
[,-]Number: 3Author: kymerritt Subject: Inserted Text Date: 3/22/2024 10:25:10 AM
Approach
QNumber:4Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:10:50 AM
only show one color to depict all areas where wetland credits are proposed. you can choose hatching or dots if you'd prefer not to use a specific color.
whichever is easiest for DWR to depict where wetland credits are
Number: 5Author: kymerritt Subject: Cross -Out Date: 3/22/2024 10:37:00 AM
IV Number: 6Author: kymerritt Subject: Inserted Text Date: 3/22/2024 10:07:35 AM
Wetland Credits
*Number: 7Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:32:14 AM
add "Areas to Planted" and depict in the figure. If there plan sheets that go into more detail of the planted areas, just make sure the text in the Plan
reference those additional plan sheets. But this figure doesn't have to be as detailed as the plan sheets since you liekly have those already.
❑+ Number: 8Author: kymerritt Subject: Cross -Out Date: 3/22/2024 10:06:10 AM
[,-]Number: 9Author: kymerritt Subject: Inserted Text Date: 3/22/2024 10:35:45 AM
to Remain
Add "Existing Roads to be relocated" and show where they will be relocated. Especicaly the road that bisects D1 and S100
QNumber: 10 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:34:51 AM
add Buffer Mitigation and list only one color depicts everywhere you are proposing buffer credits (widths and mitigation activity are not important for this
figure, just show buffer credits as all one color)
Add Nutrient Offset and list only one color to depict everywhere you are proposing nutrient offset credits (width and mitigation activity are not important
for this figure)
This may be the best figure to also show the width boundaries around each feature 50', 100' 200'. If WLS proposes a different figure for this that's fine too.
Q Number: 11 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:24:08 AM
same comment to be addressed on this figure regarding labeling of features.
QNumber: 12 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:26:58 AM
Figure 5 doesn't show an open water feature off 5200. Is WLS creating this area to be open water or was this blue supposed to be the "Riparian
Enhancement" blue?
Q Number: 13 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:12:43 AM
according to Figure 6, there are some areas where buffer crefdits are not being captured for Preservation along 5300-112, aren't they being used towards
the stream preservation credit?
QNumber: 14 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:24:44 AM
are these existing roads going to be called out as Internal Accesses in the easement, where no vehicular use is allowed? or, are they going to be changed
to easement breaks?
Q Number: 15 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:29:30 AM
general comment about trails and roads in the CE:
Trails and roads should be represented as Access easements and deeded with the CE, with no credits being proposed within the footprint of these areas or
in the riparian zone. Where trails and roads cross or bisect riparian areas, it could result in that being a non -viable site for credits. Since no roads or trails
are being proposed in areas generating buffer and nutrient offsets, DWR isjust making this comment in case there are future sites where this comes up in
your mitigation planning.
Q Number: 16 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:32:56 AM
a better label for this map based on the information provided as well as what is missing on other features, would be "Mitigation & Planting Plan". this will
need to match what is anticipated to be in the IRT plan.

Figure
5wiftie Mitigation Project
Proposed
WATER & LAN ❑
HUC8 Tar -Pam 01 - 03020101
Edgecombe County, North Carolina
Monitoring Map
8
SOLUTIONS
Map Projection: NAO_1983_Sta[ePlan e_Nor[h_Carolina_FIPS_3200_Feel
Date: 2f2O12024

Page: 32
Q Number: 1 Author: kymerritt Subject: Sticky Note Date: 3/22/2024 11:00:34 AM
remove everything and change to just show wetland credit areas
QNumber: 2Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:59:58 AM
you do not need to show stream & wetland monitoring (crest guage, flow gauge, etc. The appropriate place to include a map like that is in the Stream/
Wetland Plan and labeled Swiftie Concept Monitoring Map or somethign similar. having too much info on this map may make the other requirements this
map should have, hard to see or understand. Just make sure you do include a more detailed monitoring map in with that Stream Plan.
QNumber: 3Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:49:56 AM
differentiate between regular DWR plots and those tied to the Coastal HWV performance standards (7 years vs 5) We need to know exactly where and
how many of these plots will be monitoring past the year 5.
QNumber:4Author: kymerritt Subject: Sticky Note Date: 3/19/2024 2:56:49 PM
make sure the Monitoring Reports differentiate a Coastal HW Plot from the other plots so that we make sure the appropriate performance standards are applied.
QNumber: 5Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10.44:13 AM
this map should not include Existing ditches that were filled. This map should show post construction conditions to be expected when we go to the site for
that Task 2 credit release or if we go to the site during monitoring. only show ditches that should be there when we visit the site in its post construction
condition.
QNumber: 6Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:52:09 AM
this map needs to match Figure 6. whatever changes are made to Figure 6 to address comments made by DWR, they need to be made on this figure as
well.
QNumber: 7Author: kymerritt Subject: Sticky Note Date: 3/22/2024 10:50:57 AM
as noted, i think these are not coastal HWV plots and that the blue color should be either nutrient offset or regular buffer restoration. Am i missing
something?
QNumber: 8Author: kymerritt Subject: Sticky Note Date: 3/22/2024 11:07:39 AM
i do not understand why there are Shared plots with another Agency in nutrient offset credit only areas or where there are just buffer credit areas. Shared
plots have always just been where riparian areas for stream credits are being monitored. And, unless there are non-standard buffer widths being applied to
get more stream credits, then that's usually just the first 50' riparian zone. Is WLS seeking non-standard buffer widths towards their stream credits?? If so,
then this means you cannot double dip beyond the 50' riparain width boundary and can only get stream credit beyond that distance. please explain, as this is
confusing to me. I do understand why there would be shared plots adjacent to HWV restoration.
Also to be noted: WLS needs to know that the performance standards for dWR plots (whether shared or not) have to meet the performance stds for DWR if
those areas are generated buffer or nutrient credit.
QNumber: 9Author: kymerritt Subject: Sticky Note Date: 3/22/2024 11:03:09 AM
this area of buffer restoration looks only to be 0-50, but it's hard to tell without the boundary layers turned on for 50. 100 & 200. Is there a particular
reason why the 51-100 assume width category is not being represented as Preservation as well?

Attachment B — Photo Lag

1:05 PM
8123/23 1:08 PM
4.
2
-
_
{
Ditch 1 looking downstream
at transition to 5100.
Ditch 2 looking downstream at confluence with 5100.
8123/23 2:30 PM
�`
_ P
r
�
_r
a.
Ditch 3 looking downstream
at transition to S300.
Ditch 4 looking downstream towards S400.