Great Meadow Buffer Plan-DWR Review

From: Merritt, Katie
To: Menefee -Dunn. Barbara A
Subject: FW: Great Meadow Buffer Plan-DWR Review
Date: Friday, June 7, 2024 3:48:51 PM
Attachments: DWR CommentSummary BufferPlan.pdf
Barbara please file the attached PDF with the email below. Metadata for Document Type is
"Mitigation Plans" and use the Subject of this email for the File Name. Thank you!
From: Merritt, Katie
Sent: Friday, June 7, 2024 3:46 PM
To: Kaitlyn Hogarth <[e-mail]>
Cc: Tugwell, Todd J CIV USARMY CFSAW (US)<[e-mail]>; Polizzi, Maria
<[e-mail]>; Davis, Erin B CIV SAW <[e-mail]>
Subject: Great Meadow Buffer Plan-DWR Review
Hey Kaitlyn,
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 November 13, 2023, Wildlands Holdings
VIII, LLC (Wildlands) submitted a draft Buffer Mitigation & Nutrient Offset Plan (Plan) for the
Great Meadow site, to the Division, for review and approval. This Plan is Appendix 10 of the
Great Meadow Stream 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 Wildlands 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 Wildlands is ready to submit their final project Plan, please include a summary of all
Wildlands' responses to the DWR comments acknowledging how Wildlands addressed the
comments. Please upload the final Plan using our Mitigation Project Information Upload Form
through this link: https://edocs.deq.nc.gov/Forms/Miti ag tion_Information_Upload.
Please note the DWR ID## 2021-1423 (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
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.

Summary of Comments on Great Meadow Buffer
Plan_DWREdits.pdf
Page: 1
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:29:25 AM
specify somewhere on this page that this is Appendix 10

Page: 3
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:31:57 AM
the Project Credit Table is labeled Table 10 & 11 in the text, but it should only be one table. update references throughout the report accordingly.
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:39:28 AM
there is no existing conditions figure. add one and reference in section 2.2. this figure should show existing treelines, existing fencelines, any culverts, and
existing stream lines and ponds where applicable. as well as privet stands that were noted in the viabilty letter.

Number: 1 Author: kymerritt Subject: Inserted Text Date: 6/7/2024 12:15:20 PM
stream mitigation project proposed under the
JNumber: 2Author: kymerritt Subject: Inserted Text Date: 6/7/2024 11:33:31 AM
which has been submitted to the InterAgency Review Team for their review and approval. This Buffer Plan is Appendix 10 of the Great Meadow Stream
Mitigation Plan.
TINumber: 3Author: kymerritt Subject: Inserted Text Date: 6/7/2024 12:16:05 PM
adjacent to mitigated streams

Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:19:17 PM
i forgot to make this comment on hatch's hill, but please address on that plan too...
We don't want the 14 digit HUC info on these Buffer Plans. We need the 12 digit HUC - it can be useful if anyone ever wanted to buy credits within their
12 digit HUC impact area, because they get a "discount" on their mitigation requirement. Remove the 14 and replace with the 12
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:18:39 PM
add the 8- digit HUC here
Number: 3Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:19:33 PM
this may needs edits to the FINAL draft

Page: 7
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:20:24 PM
add text referencing the site viability letter as well.
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:35:16 AM
acknowledge that these areas were determined using the existing conditions treeline survey provided in Figure 7.
Is it important to note, that DWR does not recommend that provider's use aerial imagery to determine treelines at existing condition. If aerial imagery was
used, Wildlands should want to gather a more accurate representation of the treeline for their existing condition (onsite GPS). This treeline shown in this
Buffer Plan is how your credits will be determined in the Mit Plan as well as in the AsBuilt Report. The treeline survey taken for the MP is to be overlayed with
the AsBuilt survey on all Combo projects, so that all existing treelines at pre -construction represent where the Provider was allowed to generate
"Enhancement & Preservation" vs 'Restoration" areas. Since this is a combo project, it is known that the treeline will disappear in some areas along stream
corridors as part of the restoration plan. Therefore, tree lines at AsBuilt do not necessarily adequately represent buffer credit assets. Make sure this is done
correctly.
JNumber: 3Author: kymerritt Subject: Inserted Text Date: 6/7/202412:20:43 PM
though installation of fencing...
�Number:4Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:21:26 PM
there are no "non subject" streams on this site. they were all determined to be Subject to the buffer rules per the letters you reference.
Oumber: 5Author: kymerritt Subject: Inserted Text Date: 6/7/2024 12:20:51 PM
Number: 6Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:36:48 AM
acknowledge that these areas were determined using the existing conditions treeline survey provided in the corresponding figure.
Number: 7Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:35:52 AM
the Project Credit table should not be broken into two tables. it is one table with two sections. Change the table to only be Table 10 and correct references
from Table 11 to be Table 10
Number: 8Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:22:26 PM
this text implies that Figure 5 includes "current landuse", but it only shows in the Legend "Watershed area". Update the Figure or correct the text.

Page: 11
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:25:15 PM
these crossings do not appear to be "easement breaks" but instead just Internal crossings. Explain.
But, why wouldn't the crossings be breaks in the CE? Why include them within the CE at all? Is this a requirement by the IRT?
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:24:00 PM
according to the Plan, both gates and fencing are proposed within the crossigns. Is this correct?
Number: 3Author: kymerritt Subject: Inserted Text Date: 6/7/2024 12:23:34 PM
and fencing
it Number: 4Author: kymerritt Subject: Inserted Text Date: 6/7/2024 12:24:22 PM
mitigated streams

Page: 12
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:32:06 PM
need to speak about the invasive Privet stands noted in the Viability letter and address those in this section or in a separate section labeled "Invasive
Management". Wildlands was allowed to get Restoration credit in these two privet areas as long as they are cut, treated and planted with native. Explain
what Wildlands is doing in these two areas and what credit types will be sought. Update Figures, Table 10, etc, accordingly, depending on this repsonse to
this comment.
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:40:52 AM
the composition of the species in this table is 1001/6, but the statement on page 10 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.

Page: 13
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:41:34 AM
While DWR does appreciate the language regarding 15% will be the max composition of any one stem planted, 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.
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:29:12 PM
there are 2-3 areas on the site viability area noted as Enhancement under (n) of the Rule where supplemental planting is required. .
Number: 3Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:28:56 PM
make sure all the Enhancement areas noted in the Site Viability letter are depicted on Figure 7, currently they are not all depicted

Page: 14
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:42:32 AM
explain how the 15 plots meets the 2% planted area requirement for plots (generating buffer and nutrient offset)
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:33:28 PM
in November providers were allowed to vote for monitoring report changes in what was required to be collected and reported with each report. Modify this
paragraph to be consistent with the decisions that were made to include Height per Stem per Plot in Years 1, 3, & 5 and reporting Average Vigor per plot in
years 1, 3 & 5. All other qualitative and quantitative data is required to be submitted each year. However, since this is a combo project, if Wildlands wants to
propose a different plan for submitting Height and Vigor, that could align with what is required to be submitted to the USACE, please let me know and
explain how that data will be collected and reported to DWR.

Page: 15
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:35:34 PM
Doesn't the long term steward usually get chosen at Task 1 on Combo project? If so, the language about Year 4 isn't necessary and should be replaced
with language applicable to this site. Especially if Task 1 credit release on the schedule in the MBI is going to be showing 25% instead of the 20%. Explain
�Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:36:20 PM
i don't believe this <0.1 acre describes buffer credit. maybe it was meant to say 'nutrient offset credit?

Page: 16
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:44:42 AM
Reiterate that the existing condition treeline survey submitted in this Buffer Plan will be overlayed on the AsBuilt survey to ensure that existing treelines at
pre -construction (not asbuilt treelines) will be used in determining rbc and noc.
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:37:25 PM
since on this site, Restoration and Enhancement via supplemental planting (under (n) of the rule) are convertible to NOC, they will be on the same ledger.
JNumber: 3Author: kymerritt Subject: Cross -Out Date: 6/7/2024 12:37:44 PM
JNumber: 4Author: kymerritt Subject: Inserted Text Date: 6/7/2024 12:37:35 PM
Enhancement and
Number: SAuthor: kymerritt Subject: Sticky Note Date: 6/7/2024 11:46:20 AM
it is not mentioned here that non-std buffer widths are used towards calculating stream mitigation. however, instead of assuming this is accurate, please
add languge in this section specifically stating that

Table 10: Great Meadow NuMeirt Offset and eviler hi tiMien Bank - Projtxt Gedll Tatar [--[
TaPPamllLo 03020101
Prober Area a L.J
N&tdii Cpr "[ Rahn(Wjpvundl
P Credit Conrerssan Bodo fftrlpoundl
Total
19.16394
297-54099
[rant NO
Mi[rMa% JCrEditahle) Initial Final Oellyned 09PI—ed
Riparian [onsrertihle
.C}edlt Type
tooatlon
!1
Poptura
Type
to RipaFlhle
9SiRer Tole Area RTee Of Credit Creek Nytritrd MrieM
Mid;atlon ARivlty FeaSure Name %Full Credit to Riparian Brdfrr Sv Nulrfent
Width Buffer Had. Rath Offset:N OFlset:P
�Ilenleral
(ft'l
Buffer? Credits OR4e[7
a dRdr r]
[ft] Mi6;ation (.11 (x:11 {Iles} {I6s}
vel AV
Buffer
Rural
Yes
ilp
EN]arru[nrrl[yia
20-29
Shard Branch
26 26
2
75%
2-66667
Yes
9-750
Ro
Catdeadusion
Gideon Swamp
Butter
Rural
Yes
IIP
Enhancementyla
SwIft Creek, Shard
743,330
745,390
2
100%
MOM
yes372,]fi3.000
No
—
—
Came Exclusion
Branch Branch Fisher
stand, Fox Branch
Erdlamement Nn
Gideon Swamp,
Butter
Rural
Yes
IIP
Cottle ExdLrsmn
101400
Swift Creek, Fisher
Stanch, Fox Bra
2072
24,372
2
33%
SA6061
Yes
"21.377
No
—
—
Buffer
Rural
Yes
PIP
Enhancement
0-MG
Fua M.,a 2
4,419
4,419
2
1WK
2-OMM
Yes
2,M9-SOB
UE
—
—
Buffer
Rural
Yes
PIP
Restoration
20-29
Shard Branch
287
267
1
75%
1-33333
Yes
215-251
No
—
—
Buffer
Rural
Yrs
I)P
Restoration
0.50
Shard Branch
Z336
2,336
1
100%
IA0000
Yes
2,336-000
No
Gideon Swamp,
Nulrienl
Rural
Yes
IIP
Restoration
R10O
S.& Croak, Shard
674,OOB
-
1
10016
1-00000
Yes
674,000.000
Yes
35,17A63B
2,265-261
Offset
Stanch, FishN
BreuCh Far Branch
Nutxlent
Hurd
Year.
IIP
ft Stmatiw
101.200
SuNk Creek GldepP
203,242
1
33%
3A3030
N4
—
70
5,367.306
346.984
Offset
Swam Foe Branch
Tpnh(h21:
1,S94,z19
115$4M
1,055,SGA 7II d0„557.944 2,61L245
776y970
776,970
ow ewr.r IR25:
Tow..
777,2SO
WA
Taal NvWvm Whet IR21=
Tool Ephemeral Area IiFY for Credit:
0
0
Texas Eligible Ephemeral arse IM1'l:
211,911
0.0%
Ephemeral Rearhe5 a4X TABM
Tnal Elylhk fee P+aemeel (WI:
MS M
7-6%
PM—tien a%TABM
TA1M
Crc4i[T7pr L.—I.. Suhjett7
Fraxvr
Mirlpation Attlriry Mln-Max Sutter w'Neh Ih)
EeMMYe Nell!'
Total
ICMditebar}
1na41 Credit
%Ivy
final Ged"a
frlparHn evlNl
Type
4r IrQ
�efop pufhr
Ratlp p:1}
CTedit
RHIp Ix:ll
Credef
Mftwii­ Ih9
Rural Yes
PIP
0•k00
Fm Branch, Shard Branch,
75,673
78,573
10
a0ms
10.D000D
7,567.300
Swlh Creek
--
-
Prctervaupn bet SUClprak
7n,673
78,673
IR'I:
.A� Great Meadow Mltlpdon Sank Parcel
Nutrient Offset & 8uffer Mdip[Ipn Plan
w Hi1CO3 MCI
Page 14
November 2023

Page: 17
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:42:37 PM
email me the Raw Data sheet at your earliest convenience.
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:44:09 PM
according to the viability letter there was also enhancement off Shard Branch. I also think the ft2 of enhancement off Fox branch should be higher when
comparing the Enhancement areas on the Viability Letter. Explain why those other areas are not represented in this table.
Number: 3Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:44:44 PM
this type of Enhancemetn is shown in the viability letter as being convertible for either NOC or RBC. Check yes

Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 11:48:05 AM
the Project Credit Table is only 1 table, not separated into 2 tables. It wil either be Table 10 based on other comments made in the beginning of the Plan.

Page: 22
;Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:41:49 PM
the conservation easement boundary for this project has changed substantially from what was included for the Site Viability Letter. I need a figure showing
where the original easement boundary was so that I am able to compare it with the proposed CE to make sure there are no issues with credit
determination. You can use this map to reference that originally proposed CE boundary. Based on my preliminary review, i don't forsee any major issues,
but I'd need to have it called out and shown in this Buffer Plan for another reviewjust in case.
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 12:39:05 PM
can this map be the Existing Conditions Map? If so, change title and add any additional existing uses that are relevant. update references throughout the
text.

Figure 7. Buffer Credits Map
� ; W I L D L A N D S Great Meadow Mitigation Bank Parcel
�/ E N G I N E E R I N G 6 350 700 Feet Nutrient Of set & Buffer Mitigation Plan
I i I r I Tar -Pamlico River Basin 10303(M2)
Nash County, NC

Page: 26
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:13:58 PM
crossings don't appear to be easement "breaks" as described in text. But should they be breaks?
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:17:55 PM
there is a privet stand in this vicinity identified in the viability letter. call the privet stand out on the figure and address within the text of the Riparian
restoration how this will be addressed to generate the credit types allowed vs proposed. See viability letter.
*Number: 3Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:14:50 PM
an area within this vicinity was determined to be "Enhancement" under (n) of 0295. It is not shown as that here. Explain.
qpNumber:4Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:17:52 PM
there is a privet stand in this vicinity identified in the viability letter. call the privet stand out on the figure and address within the text of the Riparian
restoration how this will be addressed to generate the credit types allowed vs proposed. See viability letter.
vo Number: 5Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:14:37 PM
an area within this vicinity was determined to be "Enhancement" under (n) of 0295. It is not shown as that here. Explain.
Number: 6Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:19:31 PM
this area is not measured correctly for credit. the width of the riparian area is measured from landward perpendicular from tob. therefore, where not
being perpendicular from TOB and where easement is not secured from TOB, change to "no credit" area.
Number: 7Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:20:59 PM
a linear area within this vicinity along Swift Creek was called out as cattle exclusion on the viability letter due to multiple rows of trees along the banks
riparian zone. Why is this area shown as Restoration instead?
qo Number: 8Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:23:10 PM
this pond bisects the riparian restoration (similar to how it was with Oberry Road project). therefore credit proposed above the pond are not allowed.
Remove the credit shown above the pond and adjust the project credit table accordingly.
Number: 9Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:21:21 PM
confirm that credits proposed along Cooper Road are not within the DOT R.O.W
Number: 10 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:27:21 PM
usually there is a "TOB" depicted on the legend so that it shows DWR that the provider isn't including the stream footprint within the credit generating
area. It also shows upon the AsBuilt survey too. I recommend just labeling the streams as "proposed TOB" to avoid confusion. Does Wildlands have
another suggestion?
hNumber: 11 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:25:07 PM
is stream mitigation being performed on Gideon swamp as depicted in this legend? from reading the text within the Plan, no mitigation was being
proposed. Maybe change the width of the stream lines to suggest not being mitigated?? Not sure how best to represent as to not imply the wrong
message. or is this stream just being "enhanced" by removing cattle?
Number: 12 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:25:56 PM
was this by Computer or other means? Onsite?

Figure 8- Riparian Buffer Zones Map
ktW I L I] L A N D S Great Meadow Mitigation Site
wr ENGINEERING Nutrient Offset & Buffer Mitigation Plan
d 350 700 Feet Tar -Pamlico River Basin {03030002]
Nash County, NC

Page: 27
Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:28:25 PM
this shows that a portion of credit is beyond the 200' maximum width.

Figure 5- Monitoring Components Map
W I L D L A N D S Great Meadow Mitigation Bank Parcel
E N G 1 N E E R! N G p 35a 70p FNutrient OfReamIic & efel Mitigation Pi3n
Feet Tar -Pam River Basin {0303Wp2]
4 i F ii
Nash Coun[y, NC

zM
vo Number: 1 Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:30:13 PM
add the two privet stands on this map showing "privet maintenance areas". I understand there may be privet maintenance areas across the entire site, but
these two areas were specifically called out for the Buffer Plan to address since it affects the credit type awarded within those areas.
Number: 2Author: kymerritt Subject: Sticky Note Date: 6/7/2024 3:28:59 PM
separate out the DWR only plots from the DWR/USACE Shared plots

3
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-
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SHARD BRANCH'
U
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SWIFT CREEK
r
d
uluSm RF ox�M.Y \
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- fmip0
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