DWR Comment Summary_BufferPlan

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Mitigation Plan Checklist for Riparian Restoration Mitigation Sites -created 7/15/13
6"'6'WR Stream Determination
` T DWR Site Viability Letter
'i_Site Location
®Directions including Lat & Long
Ua- 8-digit HUC &/or 14 digit (if applicable)
�ounty
�e MC approved Soil map, Topo and Aerial Maps
Project Name:
—a,= (I "W-L
Reviewed By:
A&h l
DWR # �� 7
Date Li
FA
1\ be Sub -watershed where applicable
l' Existing Site Conditions w/ photos ✓ �St
❑ All proposed mitigation activities, including a brief summary of stream and/orE'tlandmiitigation w/ ,
a detailed planting plan "add 1 6+d I s R d —1 �1 `o4 a i 1�,'
Sl W,.-a KA can P��
monitoring & Maintenance Plan -- a PIC+ -AObo'cmu—) P;�
i�V'��
rMAQWJimr
`��inancial Assurance (if applicable)
V,Associated buffer and/pr nutrient offset credit calcs, which shall include credit eneration, service (_
area, etc. ~ �! 0 '1'ti � �I�YYUf� ��T 4A J
(Ft�Credit Determination Table/Map
�,J?— Verification that the site does not have an impact on threatened or endangered species
—B— Verification that the site is not affected by on -site or nearby sources of contamination as provided
` t✓ by Environmental Data Resources, Inc.
❑ Verification that the site can be constructed on land if it is an archaeological ical site;
g
(� A list of all permits that will be required and obtained prior to constructing the mitigation site for
nutrient offset and/or buffer mitigation (e.g. Sediment and Erosion Control Plan from Division of
Land Resources, NCGO10000 Stormwater Permit from NCDWQ, 404 permit from the Army Corps
of Engineers and corresponding 401 Water Quality Certification from NCDWQ).

1D#* 20220664 Version* 2
Select Reviewer:
Katie Merritt
Initial Review Completed Date 12/04/2023
Mitigation Project Submittal - 11/28/2023
1s 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:
Jeremiah Dow
Project Information
ID#:* 20220664
Existing ID#
Project Type:
Project Name
County:
DMS Mitigation Bank
Casey Creek
Wayne
Yes No
Email Address: *
[e-mail]
Version: * 2
Existing Version
Document. Information
...................
Mitigation Document Type:
Miligallon Plans
File Upload: CaseyCreek_100597_FD_BufferMP_2023.pdf 1$.85MB
Please upload only one POF of the complete file that needs to be submitted...
Signature
Print Name: * Jeremiah Dow
Signature:

NUTRIENT OFFSET & CASEY CREEK MITIGATION SITE
Wayne County, NC
BUFFER MITIGATION
PLAN Neuse River Basin
HUC 03020201
October 2023
USACE Action ID: SAW-2022-01239
NCDWR ID No. 20220664 v2
NCDEQ Contract No. 210201-01
RFR#: 16-20210201 (Issued: 7/7/2021)
DMS ID No. 100597
PREPARED FOR:
470
NC Department of Environmental Quality
Division of Mitigation Services
1652 Mail Service Center
Raleigh, NC 27699-1652

Summary of Comments on CaseyCreek
BufferPlan_DWRed its. pdf
Page: 7
QNumber: 1 Author: kymerritt
Subject: Sticky Note Date: 5/16/2024 11:49:58 AM
clarify what is meant by "Site" here?
ITI Number: 2 Author: kymerritt
Subject: Inserted Text Date: 5/16/2024 11:49:41 AM
nutrient offset and
FilNumber: 3 Author: kymerritt
Subject: Inserted Text Date: 5/16/2024 11:51:52 AM
designed and to be constructed
Number: 4 Author: kymerritt
Subject: Inserted Text Date: 5/16/2024 11:50:19 AM
the Nutrient Offset Trading Rule
*Number: 5 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:00:16 PM
throughout the Plan, there is inconsistency on what project is being referenced. there is usage of "Site", "Project", "riparian mitigation project",
riparian buffer mitigation project, nutrient offset and buffer project, etc. address the inconsistencies. recommended to say "nutrient offset &
buffer mitigation project (hereinafter referred to as "riparian restoration project") or something similar
DWR did not add comments on this issue throughout the plan so DMS will need to make sure the plan is updated accordingly throughout to
address this comment.
Number: 6 Author: kymerritt Subject: Cross -Out Date: 5/16/2024 11:50:21 AM
QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 11:51:00 AM
add the appendix that this plan is located in wihtin the stream plan
Number: 8 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 11:56:48 AM
DWR assumes based on maps and tables that the minimum width of 50' from top of banks is being achieved on all features across the whole site.
however, it was noted in IRT comments from Maria w/ DWR commend 2 (d) that there is about 4% of riparian buffers that are less than 50'?
explain the discrepancy here and why the tables and figures don't represent areas less than 50.
Areas less than 50' are not convertible to nutrient offset and must be called out and differentiated from the other width categories in the credit
table.
FT
Number: 9 Author: kymerritt Subject: Inserted Text Date: 5/16/2024 11:54:02 AM
a minimum of 50 feet and a maximum of
QNumber: 10 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 11:51:36 AM
acknowledge that this is a DMS project somwhere in Section 1.0 including the DMS ID#
QNumber: 11 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 11:52:57 AM
is "project" referenced here different that the "riparian mitigation project" referenced in the second paragraph of section 1.1? explain and clarity
the reference.
JilNumber: 12 Author: kymerritt Subject: Inserted Text Date: 5/16/2024 12:01:36 PM
by restoration and preserving the riparian areas adjacent to mitigated streams.
QNumber: 13 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:01:06 PM
in section 1.0 this is referred to as "riparian buffer mitigation project"
[ilNumber: 14 Author: kymerritt Subject: Inserted Text Date: 5/16/2024 12:00:27 PM
riparian

Page: 8
*Number: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:02:26 PM
this project was referred to on page 1 as "nutrient offset and buffer mitigation project" not "buffer mitigation and nutrient offset porject".
Be consistent throughout on the naming conventions (same as previous comments on page 1)

sm
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:04:03 PM
i don't mind the 14 digit HUC but it shouldn't be more than 12 digits represented in this table. we dont' use the 14 digit huc layer on our DWR
GIS maps for the Neuse River Basin so I'm not sure how the 14 digit HUC was determined for this site. Either way, rmeove to include only the 12
digit
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:04:35 PM
this memo should be attached to the Plan in an appendix and then referenced accordingly.
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:13:23 PM
Ditch B was determined to be viable for NOC in the field based on existing conditions. If Ditch B is going to be modified to carry water in a
different direction than how it currently carries water to Meeting Branch, then the ditch is no longer viable. Altering the connection of a ditch to
the Stream on any project can kick a ditch out from viable for credits.

Page: 10
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:14:40 PM
Site? what is meant by "Site?
T1Number: 2 Author: kymerritt Subject: Cross -Out Date: 5/16/2024 12:13:33 PM
Number: 3 Author: kymerritt Subject: Cross -Out Date: 5/16/2024 12:13:36 PM

Page: 13
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:26:16 PM
there were drain tiles called out on the viability letter. explain how drain tiles will be removed and where they are located.
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:30:54 PM
creation of a internal crossing needs to be referenced, is it culverted or a ford, any culvert removals?
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:31:58 PM
if the miniimum widths are 50, which is implied by the credit table and corresponding figures, why does it cite 20' here? explain and address
accordingly as noted in previous comments about widths.
QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:27:44 PM
include details on what is being used to fill the borrow pit, how big is the borrow pit, how is this area going to be stabilized, will there be stems
planted in this borrow pit footprint?
QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:24:51 PM
Explain in Detail in Section 4.1 of this Plan, how Ditch B is being modified from its current condition and why (existing ditch depth, constructed
ditch depth, existing width of ditch, constructed width of ditch, etc. The stream plan calls this area out as a "Coastal Plain Swale", but this
reference is not used in this Plan. Why? Explain what a Coastal Plain Swale is.
Reference plan sheet 1.8 from the stream plan which shows the intended asbuilt design, add 1.8 to Appendix E and reference it accordingly in
section 4.1. When DWR staff met with Wildlands at an IRT mtg recently, Wildlands explained that the ditch was not being modified to redirect
flows away from the stream and is not being modified in a way that changes the ditch's existing top of bank locations or channel "length". This
needs to be explained in detail in 4.1 (or add it's own section if needed).
keep in mind that ditches must remain in their existing footprint from Viability letter to Asbuilt in order to remain viable to generate nutrient
offset credits. therefore, in order for this ditch to generate nutrient offset credits, the EXISTING top of bank of Ditch B is required to be used to
determine credits generated off Ditch B. this area cannot change at AsBuilt. Wherever the Top of bank measurement is at Plan stage, even if
top of bank changes slightly during construction of the Coastal Plain Swale, the credits cannot be larger than they were at Plan stage. Explain
how this will be achieved and how it is represented in the table.
DWR is not opposed to the proposal of Ditch B to a Coastal Plan Swale. But without the specific details of how this is being achieved, DWR
cannot approve the Plan
-Number: 6 Author: kymerritt Subject: Inserted Text Date: 5/16/2024 12:28:02 PM
riparian areas or
QNumber: 7 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:30:10 PM
there is a ditch coming into Casey Creek on the map (see Figure 7 for comments) and DWR did not see this ditch. Explain its existing hydrological
connection (or not) to Casey Creek and what is being proposed on this ditch as part of the buffer and stream plans.

Page: 14
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 11:33:47 AM
bald cypress is not a hardwood species and doesn't meet the rule requirement of "hardwood trees". Remove from the table, or select this tree as
being proposed to be planted but not counted towards performance criteria of stems per acre.
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 11:31:32 AM
the composition of the species in this table is 100%, but the statement about only planting 8 species would not yield 100%. Include the 8 that
Wildlands intends to plant if available (include their composition up to 100%) and include the remaining stems as "possible substitutions"
indicating what the composition will be of each substitution in the case they are used for planting.
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 11:31:53 AM
While DWR does appreciate the language regarding 15% will be the max composition of any one stemplanted, and that none will be over 50%,
this has been determined to not fullfill the intent of a proposed planting plan. DWR needs to know the exact stems and # intended to plant
shall all things work in your favor, and then any remaining stems desired to plant in case there is a need for substitutions. Modify text and table
accordingly and corresponding plan sheet.
QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:38:16 PM
Figure 7 shows a small ag field where restoration for both buffer and nutrient offset along Casey Creek (see comment on figure 7) is being
proposed. However, this area is not shown in Appendix E on plan sheet 3.2 as being prposed to be planted. Explain and address accordingly.
Number: 5 Author: kymerritt Subject: Cross -Out Date: 5/16/2024 12:33:50 PM
Jil Number: 6 Author: kymerritt Subject: Inserted Text Date: 5/16/2024 12:33:53 PM
project

Page: 15
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:54:55 PM
site? does this inlude the stream components too?
T1Number: 2 Author: kymerritt Subject: Cross -Out Date: 5/16/2024 12:55:02 PM
jil Number: 3 Author: kymerritt Subject: Inserted Text Date: 5/16/2024 12:55:06 PM
Mitigation
In Number: 4 Author:
QNumber:5 Author:
what is the Planted Area?
Subiect: Inserted Text
Subiect: Stickv Note
Date: 5/16/2024 12:55:47 PM
Date: 5/16/2024 1:04:45 PM
Number: 6 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:54:18 PM
how is data collected and reported in the Plan? provide the tool being used to export data for reports.

Page: 17
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:06:25 PM
do you mean Project? site? etc??
Number: 2 Author: kymerritt Subject: Cross -Out Date: 5/16/2024 1:06:11 PM
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:06:48 PM
add the appendix reference.
QNumber: 4 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:15:21 PM
explain how much ft2 is being deducted off each ditch for non -diffused flow. show the calculation depicting how you got the total number in the
project credit table of 2793
QNumber: 5 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:05:40 PM
acknowledge whether non-std buffers are being applied for the stream credits.
if there are any areas <50, they must be called out here.

Table 10: Casey Creek Mitigation Site - Project Credit Table
Neuse 03020201 - Outside Falls Lake
Project Area
N Credit Conversion Ratio (ft'/pound)
P Credit Conversion Ratio (ft'/pound)
19.16394
N/A
Subject?(enter
Total
Delivered
Credit Type
Location
NO if
Feature Type
Mitigation
Min -Max Buffer
Feature Name
Total Area (fill
(Creditable)
Initial Credit
%Full Credit
Final Credit
Convertible
to Riparian
Riparian
Buffer
Convertible
to Nutrient
Nutrient
ephemeral or
ditch')
Activity
Width (ft)
Area of Buffer
Mitigation (it')
Ratio (x:1)
Ratio (x:1)
Buffer?
Credits
Offset?
Offset: N
(Ibs)
Buffer
Rural
Yes
I / P
Restoration
0-100
Casey Creek,
317,307
317,307
1
100%
1.00000
Yes
317,307.000
Yes
16,557.503
Afton Branch
Buffer
Rural
No
UP P
Restoration
0-100
Martha Branch
31,875
31,875
1
100%
1.00000
Yes
31,875.000
Yes
1,663.280
Nutrient Offset
Rural
Yes
UP P
Restoration
0-100
Casey Creek,
73,941
73,941
1
100%
1.00000
Yes
73,941.000
Yes
3,858.340
Afton Branch
Nutrient Offset
Rural
Yes
I / P
Restoration
101-200
Casey Creek,
83,681
83,681
1
33%
3.03030
Yes
27,614.758
Yes
4,366.586
Afton Branch
Nutrient Offset
Rural
No
Ditch
Restoration
0-300
Ditch B
18,291
1
100%
1.00000
No
—
Yes
954.449
Diffuse Flo
Buffer
Rural
No
Ditch
Restoration
0-50
Deduction
1 2,793
1
300%
1.00000
Na
—
No
—
Z Totals (ft2):
527,887
506,803
450,737.758 27,400.158
Total Buffer
(1 t2):
351,974
349,181
175,913
N/A
Total Nutrient
Offset (ff2):
Total Ephemeral Area
(ftt) for Credit:
Total Eligible
Ephemeral Area (ftt):
Enter Preservation Credits Below Total Eligible for
Preservation (IT
Mitigation
Min -Max
Credit Type
Location
Subject?
Feature Type
Activity
Buffer Width
Feature Name
(ft)
Rural
Yes
I / P
0-100
Casey Creek
Rural
No
I/P
0-100
Martha Branch
Rural
I Yes
I / P
101-200
Casey Creek
Preservation Area
Subtotals (ftt):
WCasey Creek Mitigation Site Nutrient Offset & Buffer Mitigation Plan
DMS ID No. 100597 Page 12 October 2023
0
0
117,325
0.0%
117,325
25.0%
Total Area (sf)
Total
(Creditable)
Area for Buffer
Mitigation (ft')
375,113
91,941
25,684
25,384
67,663
0
468,460
117,325
Preservation as %TABM
Initial Credit
Final Credit
Riparian
Ratio (x:l)
%Full Credit
Ratio (x:1)
Buffer
Credits
10
100%
10.00000
9,194.100
5
100%
5.00000
5,076.800
10
33%
—

Page: 18
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:14:09 PM
identify the ditches where this is being applied.
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:30:39 PM
add a separate row for the borrow pit footprint which was not in agricultural land use and is not convertible to noc. just viable for RBC.

O�7able il: Casey Creek Mitigation Site -Total Area of Buffer and Nutrient Offset Mitigation
TOTAL AREA OF BUFFER MITIGATION (TABM)
Mitigation Totals
Square Feet
Credits
Restoration:
349,181
349,182.000
Enhancement:
0
0.000
Preservation:
117,325
14,270.900
Total Riparian Buffer:
I 466,S06
363,452.900
TOTAL NUTRIENT OFFSET MITIGATION
Mitigation Totals
Nutrient Nitrogen:
Offset: Phosphorus:
Square Feet
175,913
Credits
9,179.375
0.000
WCasey Creek Mitigation Site Nutrient Offset & Buffer Mitigation Plan
DIMS ID No. 100597 Page 13 October 2023

Page: 19
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:13:15 PM
this should be Table 10. The project credit table is not intended to be split into two tables, but represented as one table as a whole.

Page: 23
Number: 1 Author: kymerritt Subject: Inserted Text Date: 5/16/2024 1:15:46 PM

Project Location
Conservation Easement
NCDOT Right of Way
Existing Wetlands
®
Old Borrow Pit
-
Perennial Project Stream
Intermittent Project Stream
-
Project Ditch
f
-
Non -Project Ditch
Non -Project Streams
— -- —
Utility Line
3
C�
Existing Culvertso
` 1
W,
� # r
± � 4
�+-►117
rlr�-
�+ i��,
N
®
W I L D L A N D 5 Ll Casey Creek Mitigation Site
E N G IN E E R I N G 0 225 450 Feet Nutrient Offset and Buffer Mitigation Plan
l I I Neuse River Basin (03020201)
Wayne County, NC

Old Borrow Pit
to be filled and
planted within
50' of Casey
Creek
ONW I LD LANDS
ENGINEERING
4'
'.q
R 1
4 st
1
� Cti
as
yc'
r
i�
r0
Casey Greek
0 250
500 Feet
J
a
'jRltflt'j
Q Project Location
r Conservation Easement
Internal Crossing
NCDOT Right of Way
® Old Borrow Pit
- Stream Mitigation
Swale Pilot Channel
- Ditch
- Non -Project pitch
Mitigation Approach
Riparian Restoration for Nutrient Offset
Credit (0'-10(1')
Riparian Restoration for Nutrient Offset
Credit (101'-200')
Riparian Restoration for Buffer Credit
(0'-100')
Riparian Preservation for Buffer Credit
(within 25%TABM) (0%100')
Riparian Preservation for Buffer Credit
(within 25%TABM) (101'-200')
Not for Credit
---- Surveyed Tree Line
--- Utility Une
Nan -Project Streams
Figure 7. Buffer Mitigation 4 cept Map
Casey Creek gation Site
Nutrient Offset and Buffer Mitigation Plan
Neuse River Basin (03020701)
Wayne County, NC

Page: 28
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:27:32 PM
is Ditch A in or out of the Easement boundary?
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:29:56 PM
the footprint of the borrow pit is not in agriculture and cannot be converted to nutrient offset as implied in the credits table but acurately depicted
in this figure. call out the borrow pit footprint in the project credit table and cite "no" for not convertible to NOC, and in Section 9.0
QNumber: 3 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:34:32 PM
remove the Orange representing restoration for noc in this area. This area was not in agricultural landuses and are not viable for noc, only buffer.
update and modifiy the plan and tables accordingly.
F11Number: 4 Author: kymerritt Subject: Inserted Text Date: 5/16/2024 1:24:43 PM
& Nutrient Offset

O
Figure 8. Riparian Buffer Zones Map
W I L D L A N D S Casey Creeic Mitigation site
E N G I N E E R I N G 0 250 500 Feet Nutrient Offset and Buffer Mitigation Plan
I Neuse River Basin (03020701)
Wayne County, NC

Project Location
Conservation Easement
Internal Crossing
] NCDOT Right of Way
ILLLJ Old Borrow Pit
- Stream Mitigation
Swale Pilot Channel
- Ditch
- Non -Project Ditch
Mitigation Approach
Ifi•
Riparian Restoration for Nutrient Offset Credit
s
(0'-100')
Riparian Restoration for Nutrient Offset Credit -
)loll-2001) -yJ\
Riparian Restoration for Buffer Credit (0'-500
Riparian Preservation for Buffer Credit {within }` 0 /
25%TAB M) (0'-100')
Riparian Preservation for Buffer Credit (within
25%TABM) (101'-200') oo
Not for Credit ❑ f.i,�o .* 3
0 vegetation Plot O 1.
-- - Surveyed Tree Line
r
-- Utility Line
Non -Project Streams 2
.
I
,.
1
1
_ t 1
1
� 1.
1 1
1 �}
11 \
-a
1
1
I 4 f
I
i
i+ +
1 � •i3
I
13
r .r—'�'r— '•pL O i
4
y l'
Figure 9. Monitoring Components Map
W I L D L A N D S Casey Creek Mitigation site
ENGINEERING 0 250 500 Feet Nutrient Offset and Buffer Mitigation Plan
I II ICI Neuse River Basin (03020201)
Wayne County, NC

Page: 30
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:37:36 PM
are all these plots DWR only plots or are some or all of these plots also being shared with the USACE?
QNumber: 2 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 1:36:39 PM
call out this feature consistent with stream plan

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Page: 36
QNumber: 1 Author: kymerritt Subject: Sticky Note Date: 5/16/2024 12:52:46 PM
this area is proposed for riparian restoration credits but is not proposed for planting. explain and update accordingly in the Plan.