20220293 Ver 2_240510 - Britt & Hales 2022-0293v2 As-Built Report MY0_20240510

As-Built & Baseline Monitoring Report
Britt & Hales Nutrient Offset & Riparian Buffer
Mitigation Site
Neuse River Basin
HUC 03020201 (excluding the Falls Watershed)
Wayne County, North Carolina
NCDWR Project #: 2022-0293 V2
SPONSORED BY:PREPARED BY:PREPARED FOR:
117 Centrewest Court
Cary, NC 27513
621 Hillsborough St, Suite 500
Raleigh, NC 27603
1617 Mail Service Center
Raleigh, NC 27699-1617
MAY 2024
RESPONSE TO COMMENTS > ECT22001
621 Hillsborough Street, Suite 500, Raleigh, NC 27603 / 919. 361. 5000 creating experiences through experience
May 8, 2024
Blake Hartshorn
Katie Merritt
NCDEQ – DWR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: Britt & Hales As-Built & Baseline Monitoring Report
Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
NCDWR Project #2022-0293 V2
Response to Review Comments
ECT22001
The following are the response comments for the above-mentioned project. Our response comments are in bold.
NCDEQ – DWR REVIEW
Blake Hartshorn 919. 707. 3684
Katie Merritt 919. 707. 3637
Page Label 6:
There were several issues brought up during the as built walk. Refer to those issues and describe how Eco Terra
attended to those issues (i.e. the banks of the features needing to be planted and several spots of bare area
needing seeding). Refer to those spots in a map as well.
McAdams Response: The text has been revised to reference Section 2.3 where recommendations from the
as-built site walk and follow-up actions have been summarized. Figure 4 - Monitoring Map has been
updated to show areas that were reseeded and hand planted following the site walk.
Page Label 11:
The compliance action plan has been finalized by DWR. Incorporate the final draft of the CAP into the As-Built
report by referencing it in Section 6 and adding it into the Appendix of the report. Sign the action plan before
resubmitting the As-Built Report Final Draft addressing DWR's comments.
McAdams Response: The signed CAP has been added to Appendix B and is referenced in Section 6.0. It has
also been added to Table 4.
RESPONSE TO COMMENTS > ECT22001
creating experiences through experience 2 of 2
Page Label 12: The modified credit release is provided in the CAP as Part II of the CAP. Reference it as "Part II of the CAP" and
then refer to where in the Appendix you have added it to the report.
McAdams Response: Section 6.1 has been revised to reference the modified credit release provided in the
Compliance Action Plan as Part II of the CAP provided in Appendix B.

Page Label 17: UT2, UT3 need different symbology than UT1 as depicted on survey and match credit table.
McAdams Response: Figure 3 - Credit Generation & Vegetation Plot Map has been revised to show a
different linetype for the Non-Subject Stream (UT1) and Subject Streams (UT2 + UT3).

Page Label 18: Point out where culvert was removed and where seeding/planting and erosion controls were needed as results
from the as Built walk.
McAdams Response: Figure 4 – Monitoring Map has been revised to show where the culvert was
removed, additional seeding was conducted to stabilize erosion, and where additional bare roots trees
were hand-planted.

Page Label 19: Delete amounts in the total creditable buffer column that are not convertible to RBC.
McAdams Response: The Project Credits (Table 5) has been revised to remove the areas not convertible to
riparian buffer credit.

Consideration of this response is greatly appreciated. If you should have any questions or require additional
information, please do not hesitate to contact me at 919.361.5000.

Sincerely,
MCADAMS

Kerry Bray, PE
Senior Project Manager, Water Resources

KB/kt

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TABLE OF CONTENTS
AS-BUILT & BASELINE MONITORING REPORT ......................................................................................................... I
BRITT & HALES NUTRIENT OFFSET & RIPARIAN BUFFER MITIGATION SITE .............................................................. I
1.0 MITIGATION PROJECT SUMMARY ................................................................................................................. 4
1.1 INTRODUCTION ........................................................................................................................................ 4
1.2 PROJECT GOALS ....................................................................................................................................... 4
1.3 EXISTING CONDITIONS AND PARCEL VIABILITY ................................................................................................. 5
2.0 RESTORATION ACTIVITIES ............................................................................................................................. 6
2.1 PARCEL PREPARATION ............................................................................................................................... 6
2.2 RESTORATION ACTIVITIES ........................................................................................................................... 7
3.0 PROJECT CREDIT POTENTIAL ......................................................................................................................... 8
4.0 ANNUAL MONITORING AND PERFORMANCE CRITERIA ................................................................................ 9
4.1 PERFORMANCE STANDARDS........................................................................................................................ 9
4.2 VEGETATION ........................................................................................................................................... 9
4.3 PHOTO REFERENCE STATIONS.................................................................................................................... 10
4.4 VISUAL ASSESSMENTS ............................................................................................................................. 10
4.5 ANNUAL REPORTING PERFORMANCE CRITERIA .............................................................................................. 10
4.6 PARCEL MAINTENANCE ............................................................................................................................ 11
4.7 PARCEL BOUNDARY MAINTENANCE ............................................................................................................ 11
5.0 FINANCIAL ASSURANCES ............................................................................................................................ 11
6.0 COMPLIANCE ACTION PLAN ........................................................................................................................ 11
6.1 MODIFIED CREDIT RELEASE SCHEDULE ........................................................................................................ 12
7.0 REFERENCES................................................................................................................................................ 13
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Tables
Table 1: Water Quality and Ecological Goals and Objectives
Table 2: Project Attributes
Table 3: Planted Tree Species
Table 4: Timeline of Project Activities, Notifications and Approvals
Table 5: Project Credit Table
Table 6: Planted and Total Stem Counts
Table 7: Vegetation Performance Standards Summary
Appendices
Appendix A. Figures and Project Credit Table
Figure 1 - Vicinity Map
Figure 2 - Credit Service Area Map
Figure 3 - Credit Generation & Vegetation Plot Map
Figure 4 – Monitoring Map
Table 5: Project Credit Table
Appendix B. NCDWR Correspondence
NCDWR Applicability to the Neuse River Basin Buffer Rules Letter – April 19, 2022
NCDWR Site Viability for Buffer Mitigation and Nutrient Offset Letter – June 15, 2022,
2022
Notification and Request for Site Visit Letter – April 24, 2023
NCDWR Notification of Non-Compliance – May 4, 2023
NCDWR Compliance Action Plan – April 22, 2024
Appendix C. As-Built Survey
Appendix D.Vegetation Plot Data
Table 6: Planted and Total Stem Counts
Table 7: Vegetation Performance Standards Summary
Vegetation Plot Photographs
Appendix E.Site Photographs
Appendix F.Recorded Conservation Easement
Appendix G. Financial Assurances
Performance/Maintenance Bond
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1.0 Mitigation Project Summary
1.1 Introduction
The Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site (Parcel) is located near Mount
Olive, NC, in the Upper Falling Creek watershed of the Neuse River Basin. The project site is
approximately 6.5 miles northwest of the Town of Mount Olive and 1.7 miles south of US Highway
13 on McArthur Pond Road in Wayne County, NC (Figure 1). The Bank Parcel Development
Package (BPDP) was approved under the Britt and Hales Mitigation Banking Instrument (MBI)
between the North Carolina Division of Water Resources (NCDWR) and Eco Terra, LLC, the Bank
Sponsor (Eco Terra or Sponsor).
The Parcel is approximately 24.7 acres (ac) or 1,076,524 square feet (sf) of a 180-ac tract that
encompasses a series of forked, interconnected ditches and unnamed tributaries to Falling Creek.
The project is located within the Neuse River Basin hydrological unit code (HUC) 03020201,
excluding the Falls Watershed. The BPDP was approved for riparian buffer and nutrient offset
credit in the service area designated by Neuse River Basin HUC 03020201, excluding the Falls
Watershed (Figure 2). The Parcel is in the headwaters of three unnamed tributaries and three
agricultural ditches that converge and flow into an unnamed tributary to Falling Creek,
approximately 1.8 miles downstream of the project area, and subsequently into the Neuse River.
According to the as-built survey and most recent, at time of BPDP review and approval, DWR
Buffer Mitigation Calculation Tool V.5 (updated November 2022), the Parcel is expected to
generate 333,957.870 riparian buffer credits (RBC) and 33,148.872 pounds (lbs) of nitrogen
nutrient offset credits (NOC).
The Parcel addresses agricultural runoff by reducing sediment and nutrient loading into the
unnamed tributaries and Falling Creek. Falling Creek is classified as Water Supply (WS-IV) and
Nutrient Sensitive Waters (NSW) by NCDWR with an impairment for dissolved oxygen. The project
area and surrounding areas are open agricultural land, primarily farmed for row crops. The project
improves terrestrial habitats along the streams and ditches by establishing and preserving the
riparian buffers and adjacent riparian areas and allowing the land to undergo a natural succession
to a forested community. The project restores forested riparian buffers and adjacent riparian areas
a minimum width of 50 feet from tops of banks and extend out to a maximum of approximately
200 feet from the project features (streams and ditches) and will remove rotating crops and
fertilizer inputs. The restored riparian buffer and adjacent riparian areas filters agricultural runoff
from the surrounding farm fields and provide shading to reduce stream temperatures and
improve aquatic habitat. Invasive vegetation will be managed as needed within the project area
to promote native vegetation.
1.2 Project Goals
The major goal of the proposed buffer and adjacent riparian area restoration is to improve water
quality through ecological enhancements within the Neuse River Basin. This is being
accomplished with specific goals to address agricultural runoff, including nutrients and sediment,
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restore terrestrial habitat and protect the project parcel in perpetuity. Specific goals and
objectives are outlined in Table 1.
Table 1: Water Quality and Ecological Goals and Objectives
Goal Objective
Reduce nutrient loading
Establish and restore riparian buffers and adjacent
riparian areas to filter runoff and subsurface flows from
adjacent agricultural fields. Remove fertilizer input
through conversion of agricultural field to forested
riparian buffer.
Reduce sediment loading
Establish and restore riparian buffers and adjacent
riparian areas to filter runoff from adjacent agricultural
fields. Provide vegetative bank stabilization to decrease
sediment input.
Decrease water temperature and
increase dissolved oxygen
Establish a wide riparian corridor with canopy closure to
filter nutrients and provide stream shading, reducing
water temperature and increasing concentration of
dissolved oxygen.
Restore terrestrial habitat Plant riparian corridor with native vegetation and manage
invasives.
Protect project in perpetuity Implement and record a conservation easement on the
Parcel.
1.3 Existing Conditions and Parcel Viability
The restored Parcel has converted approximately 22.2 acres of agricultural row crop fields to
forested buffers and riparian areas along three unnamed tributaries (UT1, UT2 and UT3) and three
agricultural ditches (Ditch A1, B1 and B2). Additionally, this project will preserve approximately
0.2 acres of existing forested riparian area along UT1. All credit areas have been protected in
perpetuity by a recorded conservation easement of approximately 24.7 acres in total area. Refer
to Figure 3 and Appendix A for the Credit Generation & Vegetation Plot Map.
Ditch A1 emerges from a farm road to the south of the Parcel, flows north along the eastern
border of the Parcel before turning west through the project area transitioning into UT1. UT1, an
intermittent stream, continues to flow west, turns to the north before it merges with UT2 which
continues northward as UT3 to the Parcel terminus. Ditches B1 and B2 flow east and west,
respectively, until the transition/confluence with UT2, an intermittent stream. UT2 flows west to
the confluence with Ditch B2, turns north and then northeast through the site until its confluence
with UT1. It should be noted the centerline of Ditch A1 forms the eastern boundary of the
conservation easement. The Parcel is composed of and surrounded entirely by agricultural fields
with the exception of two small wetland areas with existing trees and vegetation that have been
preserved along UT1 and Ditch A1.
Project attributes associated with the Parcel are outlined in Table 2.
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Table 2: Project Attributes
Project Name Britt & Hales Nutrient Offset & Riparian Buffer Mitigation
Site
Hydrologic Unit Code 03020201
River Basin Neuse
Service Area Neuse 03020201, excluding the Falls Watershed
Geographic Location (Lat, Long)35.254653, -78.164589
Site Protection Instrument MB P, PG 82-I
Type of Credits Riparian Buffer and Nutrient Offset
Total Credits 333,957.870 RBC1
33,148.872 lbs N NOC2
BPDP Date April 2023
Initial Planting Date March 2023
Baseline Report Date October 2023
MY1 Report Date December 2023
MY2 Report Date December 2024
MY3 Report Date December 2025
MY4 Report Date December 2026
MY5 Report Date December 2027
1 Riparian Buffer Credit (RBC)
2 Nutrient Offset Credit (NOC)
NCDWR staff visited the project Parcel on March 4, 2022 to review features and determine
applicability to the Neuse River Basin Riparian Area Protection Rules, Title 15A NCAC 02B .0714.
NCDWR issued the official Stream Call Determination letter on April 19, 2022. On May 19, 2022,
NCDWR staff re-visited the site to determine the potential for riparian buffer mitigation and
nutrient offset within the proposed easement boundary per 15A NCAC 02B .0295 and 15A NCAC
02B .0703, respectively. NCDWR issued the official Site Viability letter on June 15, 2022. A copy
of both the “Applicability to the Neuse River Basin Buffer Rules” and “Site Viability for Buffer
Mitigation and Nutrient Offset” letters issued by NCDWR are provided in Appendix B. NCDWR
staff visited the project Parcel on May 8, 2023 to verify as-built conditions. A few issues were
discussed during the as-built site walk and subsequently addressed as summarized in Section 2.3.
2.0 Restoration Activities
2.1 Parcel Preparation
The existing erosion and sink hole noted as areas of concern in the Site Viability for Buffer
Mitigation & Nutrient Offset letter dated June 15, 2022 were stabilized with minor bank grading,
and temporary and permanent seeding. Bank stabilization was applied to isolated areas along
the banks of Ditch B1, UT2 and where the 30-inch RCP culvert was removed and relocated out of
the easement. Additionally, the concrete debris and trash that existed along the forested area
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that was converted to a riparian preservation area was removed and stabilized with hand-planted
trees and temporary and permanent seeding.
Prior to the riparian restoration, the land was in agricultural row crop production, therefore the
site preparation required minimal soil disturbance. Soil ripping occurred in mechanically planted
rows to break up plow pans and compacted soils and where farm paths were planted. A limited
number of invasive plants were present and treated with an aquatic-safe herbicide that was
applied by a licensed NC pesticide applicator.
2.2 Restoration Activities
The Parcel was planted between March 30 and April 1, 2023, in accordance with the draft BPDP
and MBI, which were ultimately approved April 21, 2023. The entire area proposed for restoration
and development of nutrient offset and riparian buffer credits was planted with native tree species
and permanent seeding to convert the active farming area to a vegetated riparian corridor.
Because the land within the Parcel had been historically used for agricultural row crop production,
it required minimal soil disturbance to install the plants. Planting activities utilized both
mechanical and manual methods depending on site conditions. Bare root trees were well mixed
in the bags prior to being planted to ensure adequate distribution across the Parcel and installed
at an approximate spacing of 6 feet by 10 feet. It is expected that the initial planted density will
be sufficient in meeting the performance standards outlined in the Rule 15A NCAC 02B .0295 and
in the approved MBI of 260 trees per acre at the end of five years. Table 3 provides a summary
of the tree species and permanent seeding planted along with their density and composition
which matches the proposed planting plan in the approved BPDP.
Table 3: Planted Tree Species
Scientific Name Common
Name
Planting
Zone*
Number + Density
Planted
% of
Total
Carpinus caroliniana American
Hornbeam MMF/SSS 1000 (43 stems/acre)6%
Diospyros virginiana Persimmon MMF/SSS 1500 (65 stems/acre)9%
Fraxinus
pennsylvanica Green Ash SSS 500 (22 stems/acre)3%
Nyssa biflora Swamp Tupelo SSS 500 (22 stems/acre)3%
Nyssa sylvatica Blackgum MMF 1000 (43 stems/acre)6%
Platanus occidentalis Sycamore MMF/SSS 2000 (86 stems/acre)12%
Quercus lyrata Overcup Oak SSS 1000 (43 stems/acre)6%
Quercus michauxii Swamp
Chestnut Oak MMF/SSS 2500 (108 stems/acre)15%
Quercus nigra Water Oak MMF/SSS 1500 (65 stems/acre)9%
Quercus pagoda Cherrybark
Oak MMF 1500 (65 stems/acre)9%
Quercus phellos Willow Oak MMF/SSS 2700 (116 stems/acre)16%
Quercus shumardii Shumard Oak MMF 1000 (43 stems/acre)6%
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Andropogon gerardi Big bluestem Permanent
Seed Mix
Panicum virgatum Switchgrass Permanent
Seed Mix
Sorghastrum nutans Indiangrass Permanent
Seed Mix
*SSS-small stream swamp; MMF-mesic hardwood forest
2.3 Post-Restoration Activities
NCDWR staff visited the site on May 8, 2023 to conduct the as-built site walk during which several
items were discussed and subsequently addressed. The original mechanical planting did not
include plants along the top of banks at several locations. On May 31, 2023, Eco Terra hand-
planted bare root trees per the following NCDWR direction:
2 rows (including one at top of bank) along southern side of Ditch A1
1 row at top of bank along northern side of Ditch A1
1 row at top of bank along northern side of Ditch B1
1 row at top of bank along southern and northern sides of Ditch B2
1 row at top of bank along northern side of UT1
2 rows (including one at top of bank) along western side of UT2
Add plantings to last row and install 1 row at top of bank along eastern side of UT2
1 row at top of bank along southern side of UT2 to confluence with UT3
1 row at top of bank along western side of UT3
Increase density of plantings at top of bank along eastern side of UT3’s upper reach
Three areas were noted for additional seeding to stabilize and monitor for potential erosion. Eco
Terra reseeded the following areas several times with millet to stabilize:
Bare spot where piled concrete was removed from preservation area
Bare area within northern section of parcel on western side of UT3
Bare banks where culvert was removed
3.0 Project Credit Potential
The potential project credits are based on the top of bank of the three unnamed tributaries (UT1,
UT2 and UT3) and three agricultural ditches (Ditch A1, B1 and B2). All areas within 200-linear feet
landward of the top of bank were planted (with the exception of the preservation area adjacent
to UT1) and accounted as either riparian buffer credit or nutrient offset credit with the exception
of the area where diffuse flow cannot be attained from Ditch A1. The entire conservation
easement boundary was planted; however, a credit deduction has been calculated for the 60-
degree angle where Ditch A1 enters the easement boundary. Refer to Figure 3 for a depiction of
the Riparian Buffer and Nutrient Offset Credit areas for the Parcel. Riparian restoration adjacent
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to the streams is primarily intended to be used to generate RBC out to 100 feet and to generate
NOCs beyond 100 feet in width. RBC’s generated from preservation areas are capped at 25% of
the total area. The Parcel’s preservation area represents 1.9% of total area. Riparian restoration
adjacent to the ditches will be used to generate NOC because they are not viable to generate RBC.
Potential mitigation credits are based upon the most recent, at time of BPDP review and approval,
NCDWR Buffer Mitigation Calculation Tool v5 (updated November 2022) and the as-built survey
(Appendix C). There were no major deviations from the approved BPDP. Credit calculations based
on the as-built survey resulted in a slight reduction in credit area from what was previously
calculated via GIS in the approved BPDP. This equated to a reduction of 0.835 lbs N NOC and
411.914 RBC’s. The project’s credit potential is depicted in the Project Credit Table (Table 5,
Appendix A).
4.0 Annual Monitoring and Performance Criteria
The maintenance and monitoring plan has been developed to demonstrate required performance
standards and success criteria are met and project goals and objectives are achieved.
4.1 Performance Standards
The performance standards for the project follow approved criteria presented in the Buffer
Mitigation Rule (15A NCAC 02B .0295). Annual monitoring and semi-annual site visits will be
conducted to assess the condition of the finished project. Performance standards will be
evaluated throughout the five-year post-construction monitoring period and summarized
annually in the monitoring report. The annual report will provide project data and chronicle issues
that arise during the five-year monitoring period. The first growing period will be documented in
the first annual report to be completed in the fall 2023. Eco Terra will submit annual monitoring
reports to NCDWR by December 31st of each year for at least 5 consecutive years until project
close-out and will follow the terms and conditions of the approved Britt & Hales MBI. Although
the approved credit release schedule has been modified due to cited non-compliance with the
Parcel (see Section 6.0 for more details), the vegetation data for Monitoring Year 1 will be
submitted to NCDWR by December 31, 2023 despite no credit release for Year 1. Performance
criteria includes standardized vegetation plot establishment and annual monitoring for planted
stems including individual plot photo documentation, overall site photo documentation, biannual
visual assessments for project status and easement integrity including herbaceous and/or invasive
species competition, stem mortality, stand health, incidental damage from agricultural equipment,
and stem loss or damage from natural causes such as fire, disease, or animal impacts. Figure 3
(Appendix A) illustrates the location of the project easement, permanent vegetation plots/photo
points, as well as overall site photo points.
4.2 Vegetation
Eighteen (18) 10-meter by 10-meter permanent vegetation plots were established according to
the most recent Carolina Vegetation Survey (CVS) – NC Ecosystem Enhancement Program (EEP)
Protocol for Recording Vegetation, V4.2 (2008). Representative vegetation plots were established
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within the restored riparian buffer and adjacent riparian areas at a minimum density of 2% of the
planted area. In order to meet performance standards and determine stem health, species, height,
planting date and vigor have been documented for each monitoring plot. Vegetation assessments
were completed in April 2023 following the CVS-EEP Level I protocol. Baseline data collection
resulted in a planted stem density ranging from 526 - 809 stems per acre which surpasses the
performance standard requiring survival of 260 stems per acre at the end of the five-year
monitoring period. Baseline or monitoring year zero (MY0) vegetation stem data is included in
Table 6 (Appendix D).
Additional vegetative success criteria to ensure that plots are diverse is the survival of at least four
native hardwood tree species where no one species represents more than 50% of the planted
stems. The Parcel’s baseline plot data shows 12 native hardwood species with a minimum of 4
distinct species per plot and an individual species maximum equal to 47% percent composition
of the planted stems. Upon NCDWR approval, desirable native volunteer species may be included
in the overall tree density for the Parcel to meet performance standards and success criteria.
4.3 Photo Reference Stations
The vegetation plots were photographed from the southwest corner (origin) of each plot. Nine
additional Parcel reference photos were taken at designated points along the conservation
easement boundary providing an overall view of the Parcel and documenting project success.
Refer to Appendix D and E for vegetation plot and Parcel reference photo documentation,
respectively. All photo points locations were georeferenced for map production to provide a
consistent means for photo replication annually and in the event a plot or photo location must be
reestablished during the monitoring period. Photo orientation (direction and/or bearing) were
recorded as well as approximate vertical position for consistency in photo logging.
4.4 Visual Assessments
Additional observations were made of site conditions and vegetation conditions for the restored
areas outside of the monitoring plots. This biannual effort will be made to appropriately monitor
changing site conditions and address any issues ensuring Bank success and performance criteria
are met after the monitoring period. Any site problems will be noted and discussed in the annual
reports and monitored biannually to ensure performance criteria are met following any remedial
action.
4.5 Annual Reporting Performance Criteria
All monitoring reports, including this baseline report, will be compiled and submitted to NCDWR
annually in accordance with the approved MBI. Annual monitoring will occur for a minimum of
five years or until performance criteria are met.
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4.6 Parcel Maintenance
Any site observations identified through the vegetation plot monitoring or visual assessments,
whereby performance criteria is not being met, will be documented in the annual reports with
recommended adaptive measures. NCDWR will be notified, and if necessary, Eco Terra will
collaborate with NCDWR to develop the adaptive measures or remedial actions for
implementation to correct the performance criteria deficiency. Any adaptive measures
implemented will be designed to achieve the performance success criteria and monitoring
measures will be adjusted accordingly, if necessary. Any Parcel maintenance activities will be
included in annual monitoring reports. As noted in the approved BPDP, effective herbicide
application is critical to success of restoration areas, primarily historical agricultural land.
Herbicides approved for aquatic environments will be applied as necessary and in accordance with
the NCDA rules and regulations by a qualified NC licensed pesticide/herbicide applicator. Prior
approval from NCDWR is required if mowing within Zones 1 and 2 of the Neuse River basin buffers
is deemed necessary.
4.7 Parcel Boundary Maintenance
Conservation easement boundaries were marked in the field with 6-foot U-channel posts to
ensure clear distinction between the Parcel and adjacent properties. Long-term stewardship signs
were attached to the posts and placed at approximate 200-foot intervals along the outer
perimeter of the Parcel to identify the conservation easement. All easement boundaries will be
visually assessed twice per year as part of the monitoring protocol. Boundary markers incidentally
destroyed, damaged or disturbed will be repaired and/or replaced as needed during the
monitoring period and in the future under the long-term trustee management. Any easement
encroachment or performed maintenance will be documented in the annual monitoring reports.
5.0 Financial Assurances
After BPDP approval and prior to the first credit release, Eco Terra, LLC secured a
Performance/Maintenance bond in the penal amount of 100 percent of the estimated cost, but
not less than $150,000. The Financial Assurance was fully approved by NCDWR and signed by Mr.
Richard Rogers Jr., NCDWR Director, on May 16, 2023. Upon NCDWR approval, the penal sum
may be lowered each year based on the adjusted cost to complete monitoring activities.
Performance bonds for monitoring shall be secured annually for a minimum of five (5) years to
cover the next year’s monitoring period, with confirmation of renewal provided to NCDWR with
each annual monitoring report (when applicable). The Performance/Maintenance bond will be in
place until NCDWR has released all RBC and NOC to the Bank Sponsor. A copy of the secured
Performance/Maintenance bond is provided in Appendix G.
6.0 Compliance Action Plan
The Parcel was initially planted from March 30 to April 1, 2023. Parcel preparation activities
(vegetation plot installations, easement boundary demarcation and signage) occurred on March
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29, 2023. Eco Terra acknowledges that these actions took place prior to written NCDWR approval
of the Britt & Hales MBI and BPDP on April 21, 2023. On May 4, 2023 NCDWR issued a Notification
of Non-Compliance to Eco Terra, LLC for commencing mitigation activities prior to receiving
NCDWR approval of the Britt & Hales MBI and BPDP. On April 22, 2024 NCDWR issued the
Compliance Action Plan Agreement between NCDWR and Eco Terra to address non-compliance
with the MBI and BPDP. The NCDWR Non-Compliance correspondence and Compliance Action
Plan Agreement is included in Appendix B. A timeline of all the activities, notifications, and
approvals associated with the project is presented in Table 4.
Table 4: Timeline of Project Activities, Notifications and Approvals
NCDWR Stream Determination Site Visit March 4, 2022
NCDWR Stream Determination Letter April 19, 2022
NCDWR Site Viability Evaluation May 19, 2022
NCDWR Site Viability Letter June 15, 2022
Initial Planting Activities March 30 – April 1, 2023
Parcel Preparation Activities March 29, 2023
MBI Final Draft Submittal March 9, 2023
BPDP Final Draft Submittal March 28, 2023
MBI and BPDP Public Notice March 31 - April 14, 2023
MBI and BPDP Approval April 21, 2023
Notification of Mitigation Activities and Site Walk Request April 24, 2023
NCDWR Notification of Non-Compliance May 4, 2023
NCDWR As-Built Site Walk May 8, 2023
Additional Parcel Planting and Restoration Activities May 31, 2023
NCDWR Compliance Action Plan Issued April 22, 2024
Due to the Site’s cited non-compliance, NCDWR will not proceed with the issuance of credit
releases for the proposed buffer mitigation credits and proposed nutrient offset credits for Year
1 monitoring. However, Eco Terra, LLC will still submit Year 1 monitoring data by December 31,
2023. The Site’s credit release schedule has been modified to reflect these changes.
6.1 Modified Credit Release Schedule
The modified credit release is provided in the Compliance Action Plan as Part II of the CAP which
can be referenced in Appendix B.
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
13Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed May 2024
7.0 References
15A NCAC 02B .0295 Mitigation Program Requirements for Protection and Maintenance of
Riparian Buffers. 2015.
15A NCAC 02B .0703 Nutrient Offset Credit Trading. 2020.
15A NCAC 02B .0714 Neuse River Basin: Nutrient Sensitive Waters Management Strategy:
Protection and Maintenance of Existing Riparian Buffers. 2020
Eco Terra, LLC. (2023). Britt and Hales Mitigation Bank Parcel Development Package. NCDWR.
Raleigh, NC.
Eco Terra, LLC. (2023). Britt and Hales Mitigation Banking Instrument in the Neuse River Basin for
Nutrient Offset and Riparian Buffer Mitigation Credits pursuant to the Neuse River Basin Nutrient
Management Strategy. NCDWR. Raleigh, NC
Lee, M.T., Peet, R.K., Roberts, S.D., & Wentworth, T.R. 2008. CVS-EEP Protocol for Recording
Vegetation Version 4.2. Available at:http://cvs.bio.unc.edu/protocol/cvs-eep-protocol-v4.2-lev1-
2.pdf
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed May 2024
APPENDIX A
Figures and Project Credit Table
BRITT & HALES NUTRIENT O FFSET &RIPARIAN BUFFER MITIG ATION SITEVICINITY MAP
FIG URE1Prepared For:Drawn By: KABDate: 3/2/2023Project No.: ECT22001Scale:
Wayne C ounty, N C
Legend
Conservation Easement
UT1
UT2 ±
Project Site
Wa yn e C ounty
0 0.2 0.40.1
Miles
Neuse 03020201, excluding Falls Watershed 1 in = 0.2 miles
£¤70
£¤117
§¨¦40
§¨¦95
BRITT & HALES NUTRIENT O FFSET &RIPARIAN BUFFER MITIG ATION SITE
CREDIT SERVICE AREA MAP
FIG URE2
Prep ared For:Drawn By: KABDate: 3/2/2023Project No.: ECT22001Scale:
Wayne C ounty, N C
Legend
8-Digit HUC 03020201RBC & NOC Service Area - Neuse 03020201, excluding Falls WatershedConservation Easement
UT1
UT2
±
0 10 205
Miles
Neuse 03020201, excluding Falls Watershed 1 in = 10 miles
Project Site
Table 5. Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Bank, NCDWR Project # 2022-0293 V2 , Project Credits
Project Area
N Credit Conversion Ratio (ft2/pound)
P Credit Conversion Ratio (ft2/pound)
Credit Type Location
Subject? (enter
NO if
ephemeral or
ditch 1)
Feature Type Mitigation Activity Min-Max Buffer
Width (ft)Feature Name Total Area (ft2)
Total (Creditable)
Area of Buffer
Mitigation (ft2)
Initial Credit
Ratio (x:1)% Full Credit Final Credit
Ratio (x:1)
Convertible to
Riparian
Buffer?
Riparian Buffer
Credits
Convertible to
Nutrient Offset?
Delivered
Nutrient Offset:
N (lbs)
Delivered
Nutrient
Offset: P (lbs)
Buffer Rural No I / P Restoration 0-100 UT1 85,294 85,294 1 100%1.00000 Yes 85,294.000 Yes 4,450.755 —
Buffer Rural Yes I / P Restoration 0-100 UT2, UT3 247,193 247,193 1 100%1.00000 Yes 247,193.000 Yes 12,898.861 —
———
Nutrient Offset Rural No I / P Restoration 101-200 UT1 41,505 0 1 33%No —Yes 2,165.786 —
Nutrient Offset Rural Yes I / P Restoration 101-200 UT2, UT3 170,050 0 1 33%No —Yes 8,873.436 —
———
Nutrient Offset Rural No Ditch Restoration 0-100 Ditch A1, B1, B2 262,410 0 1 100%No —Yes 13,692.904 —
Nutrient Offset Rural No Ditch Restoration 101-200 Ditch A1, B1, B2 161,298 0 1 33%No —Yes 8,416.745 —
Buffer Rural No Ditch Restoration 0-100
Diffused Flow
Deduction (Ditch
A1)
2,197 0 1 100%No —No ——
———
Totals (ft2):969,947 332,487 332,487.000 50,498.488 0.000
Total Buffer (ft2):334,684 332,487
Total Nutrient Offset (ft2):635,263 N/A
Total Ephemeral Area (ft2) for Credit:0 0
Total Eligible Ephemeral Area (ft2):85,743 0.0%Ephemeral Reaches as % TABM
Enter Preservation Credits Below Total Eligible for Preservation (ft2):111,561 1.9%Preservation as % TABM
Credit Type Location Subject?Feature Type Mitigation Activity Min-Max Buffer
Width (ft)Feature Name Total Area (sf)
Total (Creditable)
Area for Buffer
Mitigation (ft2)
Initial Credit
Ratio (x:1)% Full Credit Final Credit
Ratio (x:1)
Riparian
Buffer Credits
Buffer Rural No I / P 0-100 UT1 6,894 6,894 5 100%5.00000 1,378.800
Buffer Rural No I / P 101-200 UT1 1,395 1,395 5 33%15.15152 92.070
Preservation Area Subtotals (ft2):8,289 8,289
Square Feet Credits
332,487 332,487.000
0 0.000
8,289 1,470.870
340,776 333,957.870
Square Feet Credits
Nitrogen:33,148.872
Phosphorus:0.000
Neuse 03020201 - Outside Falls Lake
19.16394
N/A
Restoration:
Enhancement:
Mitigation Totals
635,263
TOTAL AREA OF BUFFER MITIGATION (TABM)
TOTAL NUTRIENT OFFSET MITIGATION
Mitigation Totals
Nutrient Offset:
Preservation:
Total Riparian Buffer:
1. The Randleman Lake buffer rules allow some ditches to be classified as subject according to 15A NCAC 02B .0250 (5)(a).
last updated 08/03/2020
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed May 2024
APPENDIX B
NCDWR Correspondence
ID#* 20220293 Version* 2
Select Reviewer:
Katie Merritt
Initial Review Completed Date 04/27/2023
Mitigation Project Submittal - 4/25/2023
Is this a Prospectus, Technical Proposal or a New Site?* Yes No
Type of Mitigation Project:*
Stream Wetlands Buffer Nutrient Offset
Select all that apply)
Project Contact Information
Contact Name: * Email Address:
Michael Beinenson [e-mail]
Project Information
ID#: * 20220293 Version:* 2
Existing ID# Existing Version
Project Type: DMS Mitigation Bank
Project Name: Britt & Hales Mitigation Site
County: Wayne
Document Information
Mitigation Document Type:*
Mitigation As -Built Plans
File Upload: 2023.04.24 Britt + Hales Notification Letter.pdf 17.11 MB
Please upload only one PDF of the complete file that needs to be submitted...
Signature
Print Name:* Kerry Bray
Signature:
C4 taJ
117 Centrewest Court, Cary, NC 27513 | EcoTerra.com
April 24, 2023
To: Katie Merritt, Nutrient Offset & Buffer Banking Coordinator
NC Division of Water Resources
401 & Buffer Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
From: Michael Beinenson, President
Eco Terra, LLC
117 Centrewest Court
Cary, NC 27513
Re: Notification & Request for Site Visit
MBI Task 2 Site Visit
Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
Neuse River Basin HUC 03020201 (excluding the Falls Watershed)
Wayne County, NC
NCDWR Project #: 2022-0293 v2
Eco Terra is providing written notification that all nutrient offset and riparian buffer
activities have been completed at the Britt & Hales Nutrient Offset & Riparian Buffer
Mitigation Site per the requirements of the approved Mitigation Banking Instrument
MBI). Eco Terra is requesting a site visit by DWR to complete the requirements of MBI
Task 2 for credit release.
The Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site (Parcel) is located near
Mount Olive, NC, in the Upper Falling Creek watershed of the Neuse River Basin. The
project site is approximately 6.5 miles northwest of the Town of Mount Olive and 1.7
miles south of US Highway 13 on McArthur Pond Road in Wayne County, NC (Figure 1).
The Parcel is approximately 24.7 acres (1,076,524 sf) of a 180-acre tract that
encompasses a series of forked, interconnected ditches and unnamed tributaries to
Falling Creek. The Parcel was restored to provide ecological and water quality
enhancements to the Neuse River Basin HUC 03020201, excluding the Falls Watershed
Figure 2) by restoring and preserving riparian buffers and adjacent riparian areas along
three unnamed tributaries (UT1, UT2 and UT3) and three ditches (Ditch A1, B1 and B2).
The Parcel provides riparian buffer mitigation credits by protecting the riparian area from
top of bank to a minimum 30-foot width and maximum 100-foot width along the
117 Centrewest Court, Cary, NC 27513 | EcoTerra.com
streams (UT1, UT2 and UT3). Buffer mitigation credits are also generated through
preservation of a riparian area adjacent to UT1 for a minimum 30-foot width and
maximum 200-ft width. The Parcel provides nutrient offset credits by protecting the
riparian area from the 100-foot offset from top of banks along the streams and minimum
50-foot width along the ditches, to a maximum 200-foot width (Figure 7). Tables 1 and 2
provide project attributes and viability information.
Table 1: Project Attributes
Project Name Britt & Hales Nutrient Offset & Riparian Buffer Mitigation
Site
Hydrologic Unit Code 03020201
River Basin Neuse
Service Area Neuse 03020201, excluding the Falls Watershed
Geographic Location (Lat, Long) 35.254653, -78.164589
Site Protection Instrument MB P, PG 82-I
Type of Credits Riparian Buffer and Nutrient Offset
Total Credits 334,369.784 RBC1
33,149.707 NOC2
BPDP Date April 2023
Initial Planting Date April 2023
Baseline Report Date May 2023
MY1 Report Date December 2023
MY2 Report Date December 2024
MY3 Report Date December 2025
MY4 Report Date December 2026
MY5 Report Date December 2027
1 Riparian Buffer Credit (RBC)
2 Nutrient Offset Credit (NOC)
Table 2: Project Features and Viability
Feature Name Classification Riparian Buffer
Credit Viable
Nutrient Offset
Viable
UT1 (A*) Stream Yes Yes
UT2 (B*) Stream Yes Yes
UT3 (C*) Stream Yes Yes
Ditch A1 Ditch>3’ No Yes
Ditch B1 Ditch>3’ No Yes
Ditch B2 Ditch>3’ No Yes
Feature Name per NC DWR letters
117 Centrewest Court, Cary, NC 27513 | EcoTerra.com
The Parcel was planted between March 30 and April 1, 2023, in accordance with the
approved Bank Parcel Development Package (BPDP) and MBI. The entire area proposed
for restoration and development of nutrient offset and riparian buffer credits was
planted with native tree species and permanent seeding. The land within the Parcel had
historically been used for agricultural row crop production, therefore minimal soil
disturbance was required to install the plants. Planting activities utilized both mechanical
and manual methods. Soil ripping occurred in mechanically planted rows to break up
plow pans and compacted soils and where farm paths were planted. Areas immediately
adjacent to the top of banks were not ripped to prevent soil erosion and runoff from
entering the surface water. A limited number of invasive plants were present and treated
with an aquatic-safe herbicide that was applied by a licensed NC pesticide applicator.
Bare root trees were well mixed in the bags prior to being planted and installed at a
spacing of 6 feet by 10 feet, resulting in a stem density of 720 stems per acre. Table 3
provides a summary of the tree species planted along with their density and composition
which matches the proposed planting plan in the approved BPDP.
Table 3: Tree Species Planted
Scientific Name Common
Name
Planting
Zone*
Number + Density
Planted
of
Total
Carpinus caroliniana American
Hornbeam MMF/SSS 1000 (43 stems/acre) 6%
Diospyros virginiana Persimmon MMF/SSS 1500 (65 stems/acre) 9%
Fraxinus
pennsylvanica Green Ash SSS 500 (22 stems/acre) 3%
Nyssa biflora Swamp Tupelo SSS 500 (22 stems/acre) 3%
Nyssa sylvatica Blackgum MMF 1000 (43 stems/acre) 6%
Platanus occidentalis Sycamore MMF/SSS 2000 (86 stems/acre) 12%
Quercus lyrata Overcup Oak SSS 1000 (43 stems/acre) 6%
Quercus michauxii Swamp
Chestnut Oak MMF/SSS 2500 (108 stems/acre) 15%
Quercus nigra Water Oak MMF/SSS 1500 (65 stems/acre) 9%
Quercus pagoda Cherrybark
Oak MMF 1500 (65 stems/acre) 9%
Quercus phellos Willow Oak MMF/SSS 2700 (116 stems/acre) 16%
Quercus shumardii Shumard Oak MMF 1000 (43 stems/acre) 6%
Andropogon gerardi Big bluestem Permanent
Seed Mix
Panicum virgatum Switchgrass Permanent
117 Centrewest Court, Cary, NC 27513 | EcoTerra.com
Seed Mix
Sorghastrum nutans Indiangrass Permanent
Seed Mix
SSS-small stream swamp; MMF-mesic hardwood forest
The existing erosion and sink hole noted as areas of concern in the Site Viability for
Buffer Mitigation & Nutrient Offset letter dated 6/15/2022 were stabilized with minor
bank grading, and temporary and permanent seeding. It was determined that erosion
control matting was not necessary which is a deviation from what was proposed for
stabilization in the approved BPDP. Bank stabilization was applied to isolated areas
along the banks of Ditch B1, UT2 and where the 30-inch RCP culvert was removed and
relocated out of the easement. Additionally, the cement, debris and trash noted in the
letter was also removed from the riparian preservation area.
Following planting, permanent vegetation monitoring plots were established within the
restoration areas to document the survival and vigor of planted trees. A total of eighteen
18) plots were positioned within the planted restoration area according to Figure 7 in
the approved BPDP. The vegetation plots are marked in the field by PVC pipes installed
at each corner of the approximate 10-meter by 10-meter plot.
Easement boundaries were marked in the field with 6-foot U-channel posts to ensure
clear distinction between the Parcel and adjacent properties. Long-term stewardship
signs were attached to the posts and placed at approximate 200-foot intervals along the
outer perimeter of the Parcel to identify the conservation easement. There are no
changes to the conservation easement boundary nor the amount of Riparian Buffer and
Nutrient Offset Credits from what was proposed in the approved BPDP.
Photographs were taken within the vegetation plots and at select points to document
the conservation easement boundary as depicted in the Monitoring Map (Figure 9). A
selection of photographs is attached.
Attachments:
Photographs
Vicinity Map (Figure 1)
Credit Service Area Map (Figure 2)
Credit Generation and Vegetation Plot Map (Figure 7)
Monitoring Map (Figure 9)
10/31/23, 2:40 PM Eco Terra Mail - Notification of Non-Compliance - Britt & Hales MBI/BPDP
https://mail.google.com/mail/u/2/?ik=9d4a624ac4&view=pt&search=all&permmsgid=msg-f:1764993914078600978&simpl=msg-f:1764993914078600978 1/2
Michael Beinenson <[e-mail]>
Notification of Non-Compliance - Britt & Hales MBI/BPDP
Merritt, Katie <[e-mail]>Thu, May 4, 2023 at 3:42 PM
To: "[e-mail]" <[e-mail]>
Cc: Jordan Burbage <[e-mail]>, "Hartshorn, Blake" <[e-mail]>, "Goss, Stephanie"
<[e-mail]>, Norton Webster <[e-mail]>
Good Afternoon Michael,
DWR received the attached documentation from McAdams notifying DWR that the Britt & Hales site was fully planted and
ready for DWR to assess site conditions for the Task 2 milestone according to the MBI. According to the attached
notification letter, Eco Terra planted this site March 30, 2023 & April 1, 2023. The Bank Parcel Development Package
(BPDP) was approved on April 21, 2023 and the Mitigation Banking Instrument (MBI) was signed by Eco Terra on March
31, 2023 and DWR on April 21, 2023.

Eco Terra did not have an approved Banking Instrument (required under 15A NCAC 02B .0295 and 15A NCAC 02B
.0703), nor did they have an approved BPDP for the site (required under 15A NCAC 02B .0295 and 15A NCAC 02B
.0703) prior to conducting activities for buffer mitigation and nutrient offset credits. Both rules referenced above clearly
state that an approved plan by DWR is required prior to conducting activities for buffer mitigation or nutrient offset credits.
Secondly, Eco Terra submitted an MBI and BPDP to DWR that contained inaccurate and falsified information.

Eco Terra is in non-compliance with 15A NCAC 02B .0295
Eco Terra is in non-compliance with 15A NCAC 02B .0703
Eco Terra is in non-compliance with the Approved Britt & Hales BPDP - submitted to DWR by Eco Terra on March 29,
2023, public noticed on March 31 and approved by DWR on April 21
Eco Tera is in non-compliance with the Approved Britt & Hales MBI – submitted to DWR by Eco Terra on March 31, 2023,
public noticed on March 31 and approved on April 21.

At this time, DWR will not be able to proceed with the issuance of credit releases for the proposed buffer mitigation credits
and proposed nutrient offset credits until these matters have been discussed. DWR will discuss the non-compliance
issues with Eco Terra and DWR management in the near future prior to determining further actions needed.

Thank you for your attention to this matter,
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
10/31/23, 2:40 PM Eco Terra Mail - Notification of Non-Compliance - Britt & Hales MBI/BPDP
https://mail.google.com/mail/u/2/?ik=9d4a624ac4&view=pt&search=all&permmsgid=msg-f:1764993914078600978&simpl=msg-f:1764993914078600978 2/2
Website: https://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.

20220293 Ver 2_2023.04.24 Britt + Hales Notification Letter_20230425.pdf
17477K
Michael Beinenson
President
04/25/2024
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed May 2024
APPENDIX C
As-Built Survey
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed May 2024
APPENDIX D
Vegetation Plot Data
Table 6: Vegetation Plot Data
Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
DWR Project No. 2022-0293v2
Monitoring Year 0 – 2023
Planted Total Planted Total Planted Total Planted Total
Carpinus caroliniana American hornbeam Tree 1 1 2 2
Diospyros virginiana Persimmon Tree 1 1 1 1 3 3
Fraxinus pennsylvanica Green ash Tree 1 1 5 5 3 3
Nyssa biflora Swamp tupelo Tree 1 1
Nyssa sylvatica Blackgum Tree 2 2 1 1
Platanus occidentalis Sycamore Tree 1 1 3 3 1 1
Quercus lyrata Overcup oak Tree 2 2
Quercus michauxii Swamp chestnut oak Tree 5 5 1 1 2 2 2 2
Quercus nigra Water oak Tree 2 2 1 1 1 1 1 1
Quercus pagoda Cherrybark oak Tree 5 5 1 1 1 1
Quercus phellos Willow oak Tree 2 2 2 2 2 2 1 1
Quercus shumardii Shumard oak Tree 2 2 1 1 3 3 1 1
13 13 20 20 16 16 15 15
13 20 16 15
526 809 647 607
11 10 9 9
38%25%19%20%
1.3 1.3 1.2 1.7
39 41 36 51
Planted Total Planted Total Planted Total Planted Total
Carpinus caroliniana American hornbeam Tree 2 2
Diospyros virginiana Persimmon Tree 1 1 2 2 1 1
Fraxinus pennsylvanica Green ash Tree 1 1
Nyssa biflora Swamp tupelo Tree
Nyssa sylvatica Blackgum Tree 1 1 1 1
Platanus occidentalis Sycamore Tree 1 1 2 2 1 1
Quercus lyrata Overcup oak Tree 4 4 2 2
Quercus michauxii Swamp chestnut oak Tree 1 1 2 2 7 7 5 5
Quercus nigra Water oak Tree 2 2 3 3 2 2
Quercus pagoda Cherrybark oak Tree 2 2 3 3
Quercus phellos Willow oak Tree 2 2 7 7 4 4
Quercus shumardii Shumard oak Tree 4 4 1 1 2 2
15 15 18 18 15 15 18 18
15 18 15 18
607 728 607 728
9 6 5 7
27%39%47%28%
1.2 1.3 1.6 1.7
36 41 48 51Average Plot Height (cm)
Common Name Tree / Shrub Veg Plot 5 Veg Plot 6
Performance Standard
Current Year Stem Count
Stems/Acre
Species Count
Dominant Species Composition (%)
Veg Plot 7 Veg Plot 8
Current Year Stem Count
Stems/Acre
Species Count
Dominant Species Composition (%)
Average Plot Height (cm)
Veg Plot 3 Veg Plot 4Scientific Name Common Name Tree / Shrub Veg Plot 1
Average Plot Height (ft)
Average Plot Height (ft)
Performance Standard
Scientific Name
Veg Plot 2
Page 1 of 3
Table 6: Vegetation Plot Data
Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
DWR Project No. 2022-0293v2
Monitoring Year 0 – 2023
Planted Total Planted Total Planted Total Planted Total
Carpinus caroliniana American hornbeam Tree 1 1
Diospyros virginiana Persimmon Tree 2 2 4 4
Fraxinus pennsylvanica Green ash Tree 3 3 3 3
Nyssa biflora Swamp tupelo Tree
Nyssa sylvatica Blackgum Tree 1 1 1 1
Platanus occidentalis Sycamore Tree 1 1 1 1
Quercus lyrata Overcup oak Tree 2 2
Quercus michauxii Swamp chestnut oak Tree
Quercus nigra Water oak Tree 3 3 1 1 5 5 2 2
Quercus pagoda Cherrybark oak Tree 3 3
Quercus phellos Willow oak Tree 2 2 2 2 6 6 4 4
Quercus shumardii Shumard oak Tree 6 6 2 2 3 3
14 14 14 14 15 15 15 15
14 14 15 15
566 566 607 607
4 7 5 6
43%21%40%27%
1.3 1.3 1.2 1.7
39 41 36 51
Planted Total Planted Total Planted Total Planted Total
Carpinus caroliniana American hornbeam Tree 2 2 1 1 1 1
Diospyros virginiana Persimmon Tree 1 1 5 5 2 2 2 2
Fraxinus pennsylvanica Green ash Tree 2 2
Nyssa biflora Swamp tupelo Tree
Nyssa sylvatica Blackgum Tree 1 1 1 1
Platanus occidentalis Sycamore Tree 1 1 2 2
Quercus lyrata Overcup oak Tree 1 1
Quercus michauxii Swamp chestnut oak Tree 3 3 2 2 3 3 4 4
Quercus nigra Water oak Tree 2 2 2 2 2 2
Quercus pagoda Cherrybark oak Tree 3 3 1 1
Quercus phellos Willow oak Tree 3 3 3 3 2 2
Quercus shumardii Shumard oak Tree 4 4 2 2 4 4
16 16 15 15 16 16 15 15
16 15 16 15
647 607 647 607
7 6 8 7
25%33%19%27%
1.2 1.3 1.2 1.7
36 41 36 51
Dominant Species Composition (%)
Scientific Name Common Name Tree / Shrub Veg Plot 9 Veg Plot 12
Performance Standard
Current Year Stem Count
Stems/Acre
Species Count
Veg Plot 10 Veg Plot 11
Veg Plot 16
Performance Standard
Current Year Stem Count
Stems/Acre
Species Count
Veg Plot 14Scientific Name Common Name Tree / Shrub Veg Plot 13
Average Plot Height (ft)
Average Plot Height (ft)
Dominant Species Composition (%)
Average Plot Height (cm)
Veg Plot 15
Average Plot Height (cm)
Page 2 of 3
Table 6: Vegetation Plot Data
Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
DWR Project No. 2022-0293v2
Monitoring Year 0 – 2023
Planted Total Planted Total
Carpinus caroliniana American hornbeam Tree
Diospyros virginiana Persimmon Tree 2 2
Fraxinus pennsylvanica Green ash Tree 1 1 2 2
Nyssa biflora Swamp tupelo Tree
Nyssa sylvatica Blackgum Tree
Platanus occidentalis Sycamore Tree 1 1
Quercus lyrata Overcup oak Tree 1 1
Quercus michauxii Swamp chestnut oak Tree 4 4 6 6
Quercus nigra Water oak Tree 1 1 2 2
Quercus pagoda Cherrybark oak Tree 2 2
Quercus phellos Willow oak Tree 2 2 5 5
Quercus shumardii Shumard oak Tree 2 2
14 14 17 17
14 17
566 688
7 6
29%35%
1.3 1.3
39 41
Scientific Name Common Name Tree / Shrub Veg Plot 17 Veg Plot 18
Average Plot Height (cm)
Performance Standard
Current Year Stem Count
Stems/Acre
Species Count
Dominant Species Composition (%)
Average Plot Height (ft)
Page 3 of 3
Table 7: Vegetation Performance Standards Summary
Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
DWR Project No. 2022-0293v2
Monitoring Year 0 – 2023
Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive
Monitoring Year 7
Monitoring Year 5
Monitoring Year 3
Monitoring Year 2
Monitoring Year 1
Monitoring Year 0 526 11 1.3 0 809 10 1.3 0 647 9 1.2 0
Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive
Monitoring Year 7
Monitoring Year 5
Monitoring Year 3
Monitoring Year 2
Monitoring Year 1
Monitoring Year 0 607 9 1.7 0 607 9 1.2 0 728 6 1.3 0
Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive
Monitoring Year 7
Monitoring Year 5
Monitoring Year 3
Monitoring Year 2
Monitoring Year 1
Monitoring Year 0 607 5 1.6 0 728 7 1.7 0 566 4 1.3 0
Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive
Monitoring Year 7
Monitoring Year 5
Monitoring Year 3
Monitoring Year 2
Monitoring Year 1
Monitoring Year 0 566 7 1.3 0 607 5 1.2 0 607 6 1.7 0
Veg Plot 7 Veg Plot 8 Veg Plot 9
Veg Plot 10 Veg Plot 11 Veg Plot 12
Veg Plot 1 Veg Plot 2 Veg Plot 3
Veg Plot 4 Veg Plot 5 Veg Plot 6
Page 1 of 2
Table 7: Vegetation Performance Standards Summary
Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
DWR Project No. 2022-0293v2
Monitoring Year 0 – 2023
Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive
Monitoring Year 7
Monitoring Year 5
Monitoring Year 3
Monitoring Year 2
Monitoring Year 1
Monitoring Year 0 647 7 1.2 0 607 6 1.3 0 647 8 1.2 0
Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive Stems/Acre # Species Avg Ht (ft)% Invasive
Monitoring Year 7
Monitoring Year 5
Monitoring Year 3
Monitoring Year 2
Monitoring Year 1
Monitoring Year 0 607 7 1.7 0 566 7 1.3 0 688 6 1.3 0
Veg Plot 13 Veg Plot 14 Veg Plot 15
Veg Plot 16 Veg Plot 17 Veg Plot 18
Page 2 of 2
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site

Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed

Veg Plot 1 – 4/3/23 Veg Plot 2 – 4/3/23
Veg Plot 3 – 4/3/23 Veg Plot 4 – 4/3/23
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site

Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed

Veg Plot 5 – 4/3/23 Veg Plot 6 – 4/3/23
Veg Plot 7 – 4/3/23
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site

Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed

Veg Plot 8 – 4/3/23 Veg Plot 9 – 4/3/23
Veg Plot 11 – 4/3/23 Veg Plot 10 – 4/3/23
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site

Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed

Veg Plot 13 – 4/3/23
Veg Plot 14 – 4/3/23 Veg Plot 15 – 4/3/23
Veg Plot 12 – 4/3/23
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site

Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed

Veg Plot 16 – 4/3/23 Veg Plot 17 – 4/3/23
Veg Plot 18 – 4/3/23
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed May 2024
APPENDIX E
Site Photographs
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site

Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed

Site Photo Point 1 – 4/4/23 Site Photo Point 2 – 4/4/23
Site Photo Point 3 – 4/4/23 Site Photo Point 4 – 4/4/23
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site

Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed

Site Photo Point 5 – 4/4/23 Site Photo Point 6 – 4/4/23
Site Photo Point 7 – 4/4/23 Site Photo Point 8 – 4/4/23
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site

Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed

Site Photo Point 9 – 4/4/23
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed May 2024
APPENDIX F
Recorded Conservation Easement
Eco Terra, LLC | Britt & Hales Nutrient Offset & Riparian Buffer Mitigation Site
Britt & Hales As-Built & Baseline Monitoring Report
HUC 03020201, Excluding Falls Watershed May 2024
APPENDIX G
Financial Assurances