Buffer Plan For PN

September 16, 2024

401 & Buffer Permitting Unit
North Carolina Department of Environmental Quality
Attn: Katie Merritt
512 N. Salisbury Street
Raleigh, NC 27620

RE: WLS Responses to DWR Review Comments Regarding Appendix I of the Swiftie Stream & Wetland
Mitigation Plan, DWR ID # 2023-0026 v1, Tar-Pamlico River Basin, Cataloging Unit 03020101,
Edgecombe County, NC
Dear Ms. Merritt:
Water & Land Solutions, LLC (WLS) is pleased to provide our written responses to the comments dated
August 22, 2024, regarding the Final Draft Swiftie Buffer Mitigation & Nutrient Offset Plan. We are
providing our written responses to the DWR’s review comments below, which includes editing and
updating the Swiftie Buffer Mitigation & Nutrient Offset Plan and associated deliverables accordingly. The
DWR review comments are copied below in bold text, followed by the appropriate response from WLS in
regular text:
Page 9.
1. Add date November 1, 2015 to text. WLS Response: The text in the Plan has been updated.
2. Added a period. WLS Response: The text in the Plan has been updated.
Page 15.
1. Should this say Swiftie Bank? WLS Response: Throughout the document the Swiftie Nutrient
Offset and Buffer Mitigation Bank Parcel is referred to as “Parcel”.
Page 16.
1. Replace stream channel with top of bank. WLS Response: The text in the Plan has been
updated.
2. Add text that states “and the banks stabilized”. WLS Response: The text in the Plan has been
updated.
3. Should this say Swiftie Bank? WLS Response: The text in the Plan has been updated to say
throughout the project area.

Page 17.
1. Replace 15A NCAC 02B .0295 (o)(7) with the text “the Site Viability letter issued by DWR”. WLS
Response: The text in the Plan has been updated.
2. Replace 15A NCAC 0295 (o)(8) with the text “the Site Viability letter issued by DWR”. WLS
Response: The text in the Plan has been updated.
Page 20.
1. Explain how the number of plots meets the 2% planted area and how many of them are for
buffer and nutrient offset. WLS Response: The total planting for the entire project is
approximately 98.2 acres, 81.4 acres are within 200ft of the stream in credible stream and
wetland areas. The 81.4 acres will be planted at 680 stems per acre within zone 1 and 2 for the
buffer of the stream and wetland areas. There is a pollinator meadow (seen on figure 7) that is
outside of the creditable buffer area but inside the conservation easement. It is approximately
16.8 acres and will be planted with a pollinator mix. There are 27 vegetation plots for the buffer
and nutrient offset portion of the project which is 2% of the nutrient and buffer planted area.
This can be seen on figure 8 as the purple, red and yellow plots.
Page 27.
1. S200 is not subject. WLS Response: This has been updated in table 6.

July 9, 2024

401 & Buffer Permitting Unit
North Carolina Department of Environmental Quality
Attn: Katie Merritt
512 N. Salisbury Street
Raleigh, NC 27620

RE: WLS Responses to DWR Review Comments Regarding Appendix I of the Swiftie Stream & Wetland
Mitigation Plan, DWR ID # 2023-0026 v1, Tar-Pamlico River Basin, Cataloging Unit 03020101,
Edgecombe County, NC
Dear Ms. Merritt:
Water & Land Solutions, LLC (WLS) is pleased to provide our written responses to the comments dated
March 22nd, 2024, regarding the Draft Swiftie Buffer Mitigation & Nutrient Offset Plan. We are providing
our written responses to the DWR’s review comments below, which includes editing and updating the
Swiftie Buffer Mitigation & Nutrient Offset Plan and associated deliverables accordingly. The DWR review
comments are copied below in bold text, followed by the appropriate response from WLS in regular text:
Page 7.
1. S700 is not being proposed in this Plan. WLS Response: The text in the Plan has been updated
to reflect that S500, S600 and S700 are not included in the Plan.
2. Make sure "Stream & Wetland Mitigation Plan" is accurately differentiated from this Plan
throughout. There are references to a "Plan" that could be confused with the stream plan.
Just make sure we know which plan is being referenced. WLS Response: The text in the Plan
has been updated to clearly differentiate between documents.
Page 11 (in the report page 10).
1. Has anything changed with the listing that would reclassify the bat to endangered now? WLS
Response: There has been no official reclassification of the Tricolored bat as of April 2024. The
Tricolored bat is still listed as proposed endangered.
2. Will there be an impact on planting or construction dates/planning if the bat's listing had
changed to endangered? WLS Response: There will be no impact on planting if the bat listings
change to endangered. The construction of the project could potentially be affected if the bat is
listed as endangered, depending on the guidance that is released.
3. Culverts (s100, D3), existing road (on D1) and berms (adjacent to S100) are also constraints on
this site in that the site needs to address them in order to be viable to generate the credit
types being proposed. Look at the Site Viability letter and address additional constraints here.
WLS Response: Text has been added to page 10 discussing the constraints and how they will be
addressed during construction.
Page 12 (in the report page 11).
1. Add additional details here regarding culvert removal, road removal and relocation off S100,
what will be done to remove compaction along that road bed, berm removal off S200, filling
ditches in riparian areas (example: off S200), etc. see viability letter for verbiage pertaining to
expectations that determine whether a feature can generate credits or not...then address
here. WLS Response: Text has been added to page 11 to add detail about culvert removal, road
removal and compaction, the relocation of S100, and the removal of the berm adjacent to S200.
2. I want to make sure that the top soils are not being just dedicated to wetland credit areas or
streamside buffer zones. It has been observed on sites in the past, that the good soil will be
removed from the riparian areas and utilized for stream and wetland restoration
purposes...thus, leaving the areas generating buffer or nutrient offset in the wider riparian
width areas, void of healthy soils - resulting in vegetation issues (low vigor, stunted growth,
bare soils, low herbaceous coverage, etc). Please address how WLS will ensure this doesn't
happen. WLS Response: Topsoil will not be removed from areas generating buffer or nutrient
offset credit. The construction plans include notes to not denude any areas of topsoil. Graded
areas must have native topsoil stockpiles and then evenly spread the topsoil after grading and
prior to planting.
3. How is WLS proposing to maintain diffused flow? explain. If wanting to use the clarification
memo, speak to that and add to the appendix. WLS Response: There is no concentrated flow
into S200-R2 and S200-R3. Throughout the Swiftie project area all ditches entering the
conservation easement will be backfilled and planted to promote diffuse flow prior to entering
riparian buffer mitigation and nutrient offset areas. Therefore, no credit removal is required due
to non-diffuse flow. Concentrated flow enters at the top of S200-R1, but no buffer credit is being
proposed in the first 100 ft, therefore no credit will be removed in the 0.1-acre non-diffuse flow
exclusion area. This area will be planted in conjunction with the stream and wetland mitigation
activities. Figure 6 shows all ditches to be backfilled.
4. Ditches are not labeled correctly. Go to the site viability letter and use the labels of the ditches
as they were provided in the letter. Update all figures and the corresponding Project Credit
Table accordingly. There should be "D2, D3 and D4". D1 is not a ditch, it is an ephemeral
channel being allowed to be submitted for review under 0295 (o)(7). You will need to add a
paragraph explaining how D1 meets the rule for generating buffer credits. You do NOT have to
do this part for D1 if you decide NOT to request any buffer credit off D1. According to the
Project Credit Table, WLS is not proposing buffer credits off D1. WLS Response: The naming of
the ditches have been updated. WLS is not proposing buffer credit on D1.
Page 13 (in the report its page 12)
1. Why will riparian buffer restoration along ditches be less than 50? riparian restoration on
figures is showing much farther than 50', and it looks like only nutrient offset is being
proposed off ditches. Explain. WLS Response: This was a typo, this sentence has been removed
from the document. This text has been added in replacement “Nutrient offset efforts along
ditches will be to a maximum width of 200 ft.”
2. S200 was shown to have Preservation in the Site Viability letter, and isn't referenced in this
section. Why? There is also a berm and a ditch located within the forested areas off S200 that,
even if no preservation buffer credits are being sought in the forested areas, the berm and the
ditch present in the riparian zone must be addressed in order to get the restoration credits
proposed in the fields. WLS Response: WLS is no longer proposing preservation credit adjacent
to S200-R1 because of overlapping wetland credits. WLS will only be proposing riparian
restoration for Nutrient Offset credit in the fields adjacent to S200-R1. The berm adjacent to
S200-R1 will be graded down and the surrounding ditches will be filled and planted during
construction.
3. There is no existing condition treeline provided in Figures. DWR has to have this in order to
make sure the Preservation vs Restoration credit areas are able to be compared to what is
submitted in the AsBuilt Report Survey. The existing treeline today, before trees are cleared
for stream restoration, will look different on the AsBuilt Survey...therefore it is required on
combo projects for the Provider to have a treeline for the Mitigation Plan and to then overlay
that existing condition tree line with the asbuilt survey so that the forested areas today are
still presented as "forested" at AsBuilt and measured for buffer preservation credit totals and
NOT buffer restoration credit totals. do not change from Mitigation Plan to Asbuilt. make sure
this treeline is overlayed on the asbuilt survey. WLS Response: The tree line has been provided
on Figure 5.
Page 14 (in the report its page 13)
1. There are two things missing from the table that is needed to determine if the planting plan
meets expectations in Rule: 1) add the anticipated planting density of each species. 2) add a
column for "Tree/Shrub" and label each species accordingly. Aren't some of these trees
normally considered a subcanopy tree? Need to add a figure to this Plan showing the "Planted
Area". and then reference this figure in this section. If there are also plan sheets from the
stream & wetland plan that should also be referenced here, add those as well. WLS Response:
The planting plan has been updated in the Plan and is shown on Figure 7.
2. All of these trees are required to be planted. If they are mentioned in this table, Dwr will
inspect the site at asbuilt walk (task 2) to make sure this list was used in its entirety.
therefore, 14 species must be planted. If this is not the plan, then WLS needs to modify this
table to address this comment. If planning to plant less than 14 species, then include another
list of requested substitutions if a species isn't available. Along with that substitution list, you
will have to include the anticipated planting density you intend to plant it as to make sure you
aren't exceeding the performance std of " no species is greater than 50%" WLS Response: The
planting plan has been updated in the Plan.
Page 15 (report page 14):
1. Monitoring expectations were voted on in our annual meeting in November 2023. In addition
to the monitoring protocol, average vigor per plot must also be collected, per plot, and
reported in Years 1, 3 & 5. Additionally, height must also be collected, per stem, per plot and
reported in Years 1, 3, & 5. All other data is to be collected each year as normally expected.
Modify text within this section to address the additional monitoring expectations. WLS
Response: The criteria above has been added into the Plan in section 4.1.
2. Specify the plots that this section will apply to. There should be Plot numbers or at least a
reference to the figure where these plots are shown. it also doesn't appear that some of the
HWV buffer restoration credits are being measured off the right reach of S200. WLS Response:
A sentence stating how many vegetation plots are located in areas of single thread stream
restoration has been added to section 4.2. The buffer areas adjacent to the headwater stream
restoration in S200-R3 have been corrected.
3. Specify which plots that this section will apply to. There should be Plot numbers or at least a
reference to the figure where these plots are shown. WLS Response: A sentence stating how
many vegetation plots are located in areas of single thread stream restoration has been added
to section 4.3.
Page 17 (report page 17):
1. Assignment is required by Year 4, whereas the official transfer of responsibilities to a long
term steward can be later, at issuance of final credit release. some of the language in this
section may conflict with this expectation in the MBI, update accordingly as needed. WLS
Response: This section has been updated to state: At closing of the conservation easement the
long term steward will be assigned. The conservation easement will allow for annual monitoring
and maintenance of the Project during the monitoring phase by WLS. Upon DWR issuance of
the final credit release as described in the credit release schedule of the MBI, the Project
stewardship responsibilities will be officially transferred to a DWR approved long-term steward.
2. Acknowledge that there are trails located within the CE but that these trails will not bisect the
riparian areas or features where riparian buffer and nutrient offset credits are being
proposed. WLS Response: A sentence about the trails within the conservation easement has
been added to section 4.9.
Page 22 (buffer table):
1. Add a figure to the Plan showing the 50, 100 and 200' width boundaries around features. At
this time, this Plan does not have this boundary map and therefore DWR cannot confirm that
this table is accurate. Just having the widths color coded on Figure 6 and 8 isn't acceptable for
this level of review needed. WLS Response: A figure showing the 50, 100, and 200 buffer zones
has been added, Figure 6.
Page 29 (Figure 5):
WLS Response: This figure has been updated to comply to all comments.
Page 30 (Figure 6):
WLS Response: This figure has been updated to comply to all comments.
1. What does Positive Drainage mean? Are these ditches also, and are they remaining or being
filled? Manipulated for better drainage? WLS Response: Positive drainage means that these
ditches will be partly filled to direct water into the conservation easement.
Page 31 (Figure 7):
WLS Response: This figure has been updated to comply to all comments.
Page 32 (Figure 8):
1. I do not understand why there are Shared plots with another Agency in nutrient offset credit
only areas or where there are just buffer credit areas. Shared plots have always just been
where riparian areas for stream credits are being monitored. And, unless there are non-
standard buffer widths being applied to get more stream credits, then that's usually just the
first 50' riparian zone. Is WLS seeking non-standard buffer widths towards their stream
credits?? If so, then this means you cannot double dip beyond the 50' riparian width
boundary and can only get stream credit beyond that distance. please explain, as this is
confusing to me. I do understand why there would be shared plots adjacent to HWV
restoration. WLS Response: WLS is not seeking additional non-standard buffer width stream
credits. The IRT requested all areas planted with trees be monitored and documented in stream
and wetland monitoring reports. These plots will have the same success criteria despite being
outside the typical 50-foot buffer zone or wetland areas. So, they are considered shared plots
with IRT and DEQ.

Swiftie Buffer Mitigation & Nutrient Offset Plan
Riparian Buffer & Nutrient Offset Mitigation Bank
DWR #20230026 v1
Edgecombe, North Carolina
Tar River Basin (HUC 03020101)
September 2024

Prepared by:

Swiftie Buffer Mitigation & Nutrient Offset Plan
Page 2
Table of Contents
1 Introduction ............................................................................................................................................... 4
1.1 Project Location ............................................................................................................................ 4
1.2 Project Description ........................................................................................................................ 4
2 Project Area - Existing Conditions .............................................................................................................. 5
2.1 Reach Descriptions ........................................................................................................................ 5
2.2 Existing Wetlands .......................................................................................................................... 6
2.3 Soils ............................................................................................................................................... 6
2.4 Existing Vegetative Communities ................................................................................................. 8
2.5 Threatened and Endangered Species ........................................................................................... 9
2.6 Cultural Resources ...................................................................................................................... 10
2.7 Constraints .................................................................................................................................. 10
2.8 FEMA Floodplain / Floodway Mapping ....................................................................................... 10
3 Proposed Tar-Pamlico Buffer & Nutrient Offset Restoration Plan .......................................................... 10
3.1 Parcel Preparation ...................................................................................................................... 11
3.3 Riparian Restoration ................................................................................................................... 12
3.4 Riparian Preservation .................................................................................................................. 13
3.6 Planting ....................................................................................................................................... 13
4 Monitoring and Maintenance Plan .......................................................................................................... 15
4.1 Monitoring Protocol .................................................................................................................... 15
4.2 Performance Standards for Vegetation Adjacent to Single-Thread Streams ............................. 15
4.3 Performance Standards for Vegetation Adjacent to Coastal Headwater Streams ..................... 15
4.4 Performance Standard for Coastal Headwater Streams ............................................................. 16
4.5 Photo Reference Stations ........................................................................................................... 17
4.6 Visual Assessment ....................................................................................................................... 17
4.7 Reporting Performance Criteria .................................................................................................. 17
4.8 Adaptive Management Plan ....................................................................................................... 17
4.9 Conservation Easement and Long-Term Management Plan ...................................................... 18
4.10 Financial Assurances ................................................................................................................... 19
5 Credit Release Schedule ........................................................................................................................... 19
6 Mitigation Potential ................................................................................................................................. 20
7 Citations ..................................................................................................................................................... 1

Swiftie Buffer Mitigation & Nutrient Offset Plan
Page 3

Figures
Figure 1 .................................................................................................................... Credit Service Area Map
Figure 2 ......................................................................................................................... Project Location Map
Figure 3 .................................................................................................................................. NRCS Soils Map
Figure 4 .................................................................................................................................. Floodplain Map
Figure 5 .................................................................................................................... Existing Conditions Map
Figure 6 ............................................................................................................... Swiftie Credit Concept Map
Figure 7 ..................................................................................................... Mitigation and Planting Plan Map
Figure 8 ................................................................................................................ Proposed Monitoring Map

Attachments
Attachment A ........................................................................................... DWR Determinations and Viability
Attachment B .................................................................................................................................. Photo Log

Swiftie Buffer Mitigation & Nutrient Offset Plan
Page 4
1 Introduction
The Swiftie Nutrient Offset and Buffer Mitigation Bank Parcel (“Parcel”) is proposed under the terms and
conditions of the proposed Swiftie Nutrient Offset and Buffer Mitigation Banking Instrument (“DWR
MBI”), made and entered into by Water and Land Solutions, LLC (WLS), acting as Bank Sponsor
(“Sponsor”), and the North Carolina Department of Environmental Quality (NCDEQ) Division of Water
Resources (DWR). The Parcel shall be planned and designed according to the MBI, 15A NCAC 02B .0703,
and the Consolidated Buffer Mitigation Rule 15A NCAC 02B .0295, which became effective on April 1, 2020
and November 1, 2015. Respectively the Buffer Mitigation and Nutrient Offset Plan (“Plan”) will be
designed in concurrence with the Swiftie Stream & Wetland Mitigation Bank (SAW-2019-00631). The
mitigation plan for the Swiftie Stream & Wetland Mitigation Bank has been submitted to the Interagency
Review Team and a prospectus has been approved. This Buffer Mitigation and Nutrient Offset Plan is
included as Appendix I of the Stream & Wetland Mitigation Plan.

This Parcel is proposed to provide riparian buffer mitigation and nutrient offset credits for unavoidable
impacts due to development in the Tar-Pamlico River Basin, United States Geologic Survey (USGS) 8-digit
Hydrologic Unit Code (HUC) 03020101. The Parcel credit service area is depicted in Figure 1.
1.1 Project Location
The Parcel (35.9984° N, -77.6062° W) is located in Edgecombe County, North Carolina (Figure 2) within
the Upper Tar River Basin (8-digit HUC 03020101). The Parcel will have an estimated 315 acres in a
conservation easement when combining this project with the stream and wetland mitigation project. The
Parcel is located directly adjacent to and on the same property as the Swift Creek Permittee Responsible
Mitigation (PRM) project (SAW-2016-02338). The Swift Creek PRM site is being used to mitigate impacts
associated with the CSX Transportation, Inc’s Carolina Connector Intermodal Terminal project, located
along the western edge of Edgecombe County and north of the City of Rocky Mount. The Parcel is intended
to generate stream, wetland, riparian buffer and nutrient offset credits.
To access the site from Raleigh, NC, follow I-40 East, take exit 14 for US-64 E/US-264 E toward Rocky
Mt/Wilson, then continue onto I-87. Continue onto US-64 E, take exit 470 for NC-97/Atlantic Ave, turn
right onto NC-97 E/Atlantic Ave, then turn right onto NC-97 E. Turn left onto New Hope Church Rd, turn
right onto Battleboro-Leggett Rd, turn left onto Speights Chapel Rd, turn right onto White Oak Swamp Rd,
and finally turn right onto NC-33 E. The site will be on the right in four miles between the existing CSX
mainline and Old Battleboro Road.
1.2 Project Description
The Parcel encompasses land along unnamed tributaries to the Tar-Pamlico River in Edgecombe County,
NC and is in row crop agricultural and silvicultural land use. Historically, the project stream reaches have
been extensively ditched to promote rapid drainage from the adjacent farm fields. This disturbance has
resulted in stream channel incision and a permanent disconnection from the streams’ relic floodplain.
Most of the project stream reaches have been completely or partially cleared with some areas of forested
or successional riparian buffer. Currently, the project reaches act as significant sources of nutrient
contamination to the project watershed and Swift Creek.
Swiftie Buffer Mitigation & Nutrient Offset Plan
Page 5

The Parcel will restore Tar-Pamlico buffers and other riparian areas in order to reduce non-point source
discharge of contaminants into streams and agricultural ditch channels within the Tar-Pamlico River basin.
The Parcel is comprised of two easement sections and is approximately 315 acres, which includes the
stream and wetland mitigation areas that are proposed in the Stream & Wetland mitigation plan. The
Parcel streams drain directly to White Oak Swamp and Swift Creek which are listed as ‘WS-IV’ and ‘NSW’
(Water Supply, Nutrient Sensitive Waters) waters according to the North Carolina Division of Water
Resources (NCDWR) (2018).
Out of the 315 acres, 13.37 acres will be restored for Tar-Pamlico buffer credit and 25.9 acres will be
restored for nutrient offset restoration credit. In general, Tar-Pamlico buffer widths will extend a
minimum width of 50 feet from the top of stream banks, while nutrient offset restoration area widths will
extend out to a maximum of 200 feet from the top of the channel or ditch bank. The buffer restoration
credit adjacent to coastal headwater stream mitigation is classified as alternative mitigation under Rule
15A NCAC 02B .0295 (o)(2) and is discussed in Section 3.2. The DWR performed an onsite Site Viability for
Buffer Mitigation and Nutrient Offset on March 8, 2023 (letter dated June 26, 2023) for the Parcel
(Attachment A). The buffer mitigation and nutrient offset viability will be based on the proposed site
conditions.
2 Project Area - Existing Conditions
2.1 Reach Descriptions
S100: S100 is a small headwater tributary that has been historically manipulated and channelized;
however, appears to generally be within the natural valley/low point along most of its length. The valley
slope is approximately 0.8 percent, and the drainage area is 41 acres. The majority of the drainage area
for S100 is in active agricultural management. The upper reach of S100 was determined to be an
ephemeral channel by DWR. The riparian buffer along upper S100 is actively maintained within
agricultural fields and woody vegetation in the lower end. The lower section in the wooded area has
downcut to the natural floodplain elevation but remains mostly stable. S100 drains into the PRM project
easement.
S200: S200 is a small headwater tributary that begins at an existing culvert crossing under NC Hwy 33 and
flows southeast as an intermittent headwater tributary. S200 has a valley slope of 0.7 percent and
drainage area of 90 acres. Based on field observations, the headwater channel and floodplain have been
ditched in an attempt to drain surface hydrology for agricultural use. The historic channel manipulation in
the upper section has led to poor bedform diversity. The lower reach is mostly stable with limited bank
erosion observed in a few localized areas. Successional native woody vegetation was observed along most
of this reach; however, Chinese privet was also documented along the reach.
S300: S300 is a headwater tributary that originates from a heavily ditched area containing hydric soils.
The stream has been channelized and straightened along its upper length. The upper portion of S300 is
highly incised and lacks natural bedform features. The valley slope is approximately 0.5 percent, and the
natural drainage area is 44 acres which excludes the ditched non-riparian wetland area. Although the
lower reach is moderately incised, it is mostly stable and experiencing minimal lateral instability and bank
Swiftie Buffer Mitigation & Nutrient Offset Plan
Page 6
erosion. The riparian buffer along the entire length of S300 is partially to mostly wooded, and the
understory contains limited invasive species vegetation, mainly Chinese privet.
S400: S400 begins downstream of an existing culvert under a farm access road. S400 has been channelized
and straightened along much of its length, as evidenced by the spoil piles and levees along the floodplain.
S400 lacks natural bedform features until the stream begins downcutting towards the Swift Creek
floodplain and meander cutoff. This reach exhibits localized streambank erosion and associated soil loss.
The valley slope is approximately 0.9 percent, and the drainage area is 468 acres. The majority of the
drainage area for S400 is within active agricultural fields with an adjacent forested area. The riparian
buffer along the entire length is partially wooded. This reach is not proposed for stream mitigation credit.
S500: S500 begins immediately downstream of the PRM project boundary and connects with a restored
stream system that flows towards the Swift Creek floodplain. S500 has a valley slope of 0.3 percent and
drainage area of 279 acres. Based on field observations, the channel gently meanders across relic meander
cutoffs and backwater sloughs, although portions of the channel and floodplain areas appear to have been
historically ditched. The reach is stable and native woody vegetation was observed along a majority of this
area. S500 is not part of the Plan but is part of the Stream and Wetland Mitigation Plan.
S600: S600 continues downstream of S500 and eventually flows off the project boundary towards its
confluence with Swift Creek. S600 has a valley slope of 0.3 percent and drainage area of 348 acres. Similar
to S500, the channel gently meanders across relic meander cutoffs and backwater sloughs, although some
channel and floodplain areas appear to have been historically ditched. The reach is stable and native
woody vegetation was observed along most of this section. S600 is not part of the Plan but is part of the
Stream and Wetland Mitigation Plan.
S700: S700 is a small headwater tributary that flows directly into White Oak Swamp. The valley slope is
approximately 0.9 percent, and the drainage area is 33 acres. The reach is stable and exhibits minimal
bank erosion. The channel appears to be within its natural valley and the existing buffer is well vegetated.
This headwater stream and wetland system is considered to be high functioning and the existing riparian
buffer helps to filter pollutants (nutrients) that would otherwise drain to White Oak Swamp. S700 is not
part of the Plan but is part of the Stream and Wetland Mitigation Plan.
2.2 Existing Wetlands
Based on preliminary site investigations, including hand-augered soil borings, it is likely that jurisdictional
wetlands were once present throughout the headwater stream valleys. The extent of the existing wetland
areas was determined by the valley crenulations and overall bottom widths. When on-site streams were
straightened and/or dredged, groundwater elevations were altered such that many of the historic
wetlands along the stream fringe were drained and lost. These areas have been utilized for agriculture
(row crop) production over the past fifty years and have lost most of their historic wetland function. A
preliminary jurisdictional determination package is provided in Appendix F of the Stream and Wetland
Mitigation Plan.
2.3 Soils
The Parcel is located in the Inner Coastal Plain Physiographic Region. As shown on the NRCS Soils Map
(Figure 3), there are fifteen main soil types on the Parcel: Altavista fine sandy loam (AaA), Ballahack fine
Swiftie Buffer Mitigation & Nutrient Offset Plan
Page 7

sandy loam (Ba, hydric), Chewacla silt loam (Cc), Conetoe loamy sand (CeB), Dogue fine sandy loam (DgA),
Goldsboro fine sandy loam (GoA), Norfolk loamy sand (NoB), Rains fine sandy loam (RaA, hydric), Roanoke
loam (Ro, hydric), State loamy sand (StB), Tarboro loamy sand (TaB), Wagram loamy sand (WaB), Wahee
fine sandy loam (We), Wehadkee silt loam (Wh, hydric), and Wickham sandy loam (WkB). The Parcel soils
are commonly defined by a sandy loam surface layer, with predominantly sandy and loamy subsoil
alluvium located along floodplains and stream terraces.
Table 1. Project Soil Types
Soil Name Hydric % of
easement Description
Altavista fine
sandy loam (AaA) No 9.0
Moderately well drained soil on stream terraces. Slopes
from 0 to 3 percent. Hydrologic Soil Group (HSG): C and
runoff class is low.
Ballahack fine
sandy loam (Ba) Yes 2.4
Very poorly drained soil in floodplains and flats on stream
terraces. Slopes from 0 to 2 percent. HSG: B/D and runoff
class is very high.
Chewacla silt loam
(Cc) No 10.0
Somewhat poorly drained soil in floodplains. Slopes from
0 to 2 percent HSG: B/D and runoff class is low. Can have
frequent flooding.
Conetoe loamy
sand (CeB) No 3.8 Well drained soil on ridges of stream terraces. Slopes
from 0 to 4 percent HSG: A and runoff class is very low.
Dogue fine sandy
loam (DgA) No 7.0
Moderately well drained soil on flats of stream and
marine terraces. Slopes from 0 to 3 percent. HSG: C and
runoff class is low.
Goldsboro fine
sandy loam (GoA) No 0.3
Moderately well drained soil on broad interstream
divides & flats of marine terraces. Slopes from 0 to 2
percent. HSG: B and runoff class is low.
Norfolk loamy
sand (NoB) No 0.4
Well drained soil on broad interstream divides & flats of
marine terraces. Slopes from 2 to 6 percent. HSG: A and
runoff class is medium.
Rains fine sandy
loam, Southern
Coastal Plain (RaA)
Yes 0.1
Poorly drained soil on broad interstream divides, Carolina
bays, & flats of marine terraces. Slopes from 0 to 2
percent. HSG: B/D and runoff class is low.
Roanoke loam (Ro) Yes 33.9
Poorly drained soil on backswamps and depressions of
stream terraces. Slopes from 0 to 2 percent. HSG: C/D
and runoff class is low. Frequent ponding for brief periods
is common.
State loamy sand
(StB) No 3.5 Well drained soil on stream terraces. Slopes from 0 to 4
percent. HSG: B and runoff class is low.
Tarboro loamy
sand (TaB) No 20.3
Somewhat excessively drained soil on ridges of stream
terraces. Slopes from 0 to 6 percent. HSG: A and runoff
class is very low.
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Wagram loamy
sand (WaB) No 1.6
Well drained soil on ridges & broad interstream divides of
marine terraces. Slopes from 0 to 6 percent. HSG: A and
runoff class is low.
Wahee fine sandy
loam (We) No 1.8
Somewhat poorly drained soil on flats of marine & stream
terraces. Slopes from 0 to 2 percent. HSG: C/D and runoff
class is very high.
Wehadkee silt
loam (Wh) Yes 3.1
Poorly drained soil in depressions on floodplains. Slopes
from 0 to 2 percent. HSG: B/D and runoff class is very
high. Frequently flooded.
Wickham sandy
loam (WkB) No 1.0 Well drained soil on stream terraces. Slopes from 0 to 4
percent. HSG: B and runoff class is low.
2.4 Existing Vegetative Communities
The current use within the project area is primarily agriculture fields and forested wetlands. The
northeastern portion on the site closest to Highway 33 has a horseshoe-shaped area of forested wetlands
that encompasses S200. The natural community in the agricultural fields adjacent to the project area has
been effectively removed through tillage, ditching, agriculture, and silviculture. These practices have
removed native vegetation and altered the hydrology of the site in order for row-crops to be successful.
The southwestern portion of the proposed easement includes large wetlands, located within the
floodplain of Swift Creek & White Oak Swamp. Prior to anthropogenic land disturbances, the riparian
vegetation community likely consisted of Bottomland Hardwoods in the floodplain of Swift Creek/White
Oak Swamp and a Mesic Mixed Hardwood community in the existing agricultural fields and forested area
encompassing S200 (Schafale, 2012).

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Table 2. Existing Site Vegetation
Common Name Scientific Name
Canopy Vegetation
Red maple Acer rubrum
Sweetgum Liquidambar styraciflua
River birch Betula nigra
Loblolly pine Pinus taeda
Tulip poplar Liriodendron tulipifera
Slippery elm Ulmus rubra
Understory & Woody
Shrubs
Sweetgum Liquidambar styraciflua
Red maple Acer rubrum
Southern wax myrtle Morella cerifera
American sycamore Platanus occidentalis
River birch Betula nigra
Loblolly pine Pinus taeda
Slippery elm Ulmus rubra
White oak Quercus alba
Chinese privet Ligustrum sinense

Herbaceous & Vines
Giant cane Arundinaria gigantea
Switchgrass Panicum virgatum
Netted chain fern Woodwardia areolata
Japanese stiltgrass Microstegium vimineum
Roundleaf greenbrier Smilax rotundifolia
Cinnamon fern Osmundastrum cinnamomeum
False nettle Boehmeria cylindrica
Poison ivy Toxicodendron radicans
Invasives Chinese privet Ligustrum sinense

Invasive Species
There is not a significant presence of invasive species vegetation in the buffer and nutrient credit areas.
Within the wooded areas there are small clusters of Chinese privet (Ligustrum sinense). After restoration,
these areas will be monitored, and any invasive plants found within the project boundary will be treated
to prevent expansion and establishment of a substantial invasive community. This will allow for a healthy,
native riparian and upland plant community to dominate the area and help prevent future establishment
of invasive species vegetation.
2.5 Threatened and Endangered Species
Based on a review of the US Fish and Wildlife Service (USFWS) database and IPAC, there are currently five
federally listed threatened and endangered species known to occur in Edgecombe County: Neuse River
Waterdog (Necturus lewisi), Carolina Madtom (Noturus furiosus), Atlantic Pigtoe (Fusconaia masoni), Tar
River Spinymussel (Parvaspina steinstansana), and Yellow Lance (Elliptio lanceolata). The Neuse River
Waterdog and the Carolina Madtom are present in Swift Creek adjacent to the Stream & Wetland
Mitigation Bank and Buffer Mitigation and Nutrient Offset Bank (“Swiftie Bank”), and there is the potential
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for both species to be found in the lower tributaries of the Bank. The stretch of Swift Creek adjacent to
the Swiftie Bank is also critical habitat for the Neuse River Waterdog and Carolina Madtom. A net survey
in July 2018 captured a Tricolored bat (Perimyotis subflavus) near the Bank bounday. The Tricolored bat
is proposed for listing as an endangered species and a decision to list may be made as soon as September
2023. If the Tricolored bat is listed prior to the construction of the Bank, WLS will reinitiate the
consultation of USFWS. Project implementation is not anticipated to have a negative impact on these
listed species.
2.6 Cultural Resources
In accordance with the National Historic Preservation Act, WLS investigated and confirmed that the
proposed project area and property do not contain, nor are they adjacent to, any properties listed in the
National Register of Historic Places or the North Carolina State Historic Preservation Office (NCSHPO).
The nearest site is the Edward Cotton House (HPO Site ID: ED0721) which is approximately 0.8 miles from
the project site. On-site investigations and discussions with the previous landowners have not disclosed
any potential resources or occurrences of this type on the property. Therefore, the proposed project
activities should have no effect on any historic properties eligible for listing in the National Register, and
SHPO did not have any comments.
2.7 Constraints
The Swiftie Bank conservation easement is located on the same parcel as the conservation easement of
the Swift Creek PRM Site. The Swiftie Bank easement will abut the Swift Creek PRM easement in a few
areas. There are no existing utility corridors on the Parcel. There is an overhead powerline easement
located outside of the conservation easement at the top of S200. At the bottom of D1 there is a culvert
under an existing farm road. At the top of D3 there is a culvert under an existing farm road. During
construction both culverts will be removed and the channel will be stabilized. Lastly there is an existing
berm on the left bank of S200, during construction the berm will be graded down and removed. Existing
conditions can be seen on Figure 5.
2.8 FEMA Floodplain / Floodway Mapping
A majority of the Parcel is located within a FEMA regulated floodplain (Zone ‘AE’ and the Floodway) (Figure
4). While it is not anticipated that there will be issues associated with FEMA permitting or documentation,
WLS will coordinate with the local floodplain administrator as needed and prepare the required
documentation to obtain approval for any FEMA regulated impacts. In addition, the project will be
designed so that any increase in flooding will be contained within the project boundary and will not impact
adjacent landowners; therefore, hydrologic trespass will not be a concern.
3 Proposed Tar-Pamlico Buffer & Nutrient Offset Restoration Plan
Riparian restoration adjacent to the streams and agricultural ditches was assessed by the DWR in the Site
Viability Letter dated June 26, 2023 (Attachment A). This Parcel is also being proposed as a stream and
wetland mitigation bank, and restoration of riparian areas will be accomplished through the goals and
methods outlined by the Swiftie Stream and Wetland Mitigation Banking Instrument (USACE MBI), Swiftie
Mitigation Plan (SAW-2019-00631) and the DWR MBI. All riparian restoration mitigation activities along
Swiftie Buffer Mitigation & Nutrient Offset Plan
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channels will begin from the tops of the banks and extend a maximum of 200 feet perpendicular to the
top of bank where possible pursuant to 15A NCAC 02B .0295 (effective November 1, 2015) and for nutrient
offset credits pursuant to 15A NCAC 02B .0240.

All applicable federal, state, and local documentation, permits, and/or authorizations will be acquired as
part of implementing the above-mentioned mitigation plan and will be provided to DWR as part of the
As-Built Report, including Section 401, Section 404 and Sediment and Erosion Control permits. The
restoration of the Parcel will require converting existing agriculture land use practices within riparian
areas adjacent to streams and ditches into a dense and diverse vegetated riparian forest. The riparian
areas will be replanted with appropriate native tree species. The restoration of the riparian buffer and
adjacent riparian areas will provide stabilization and improve water quality to tributaries that drain
directly to Swift Creek and White Oak Swamp.
3.1 Parcel Preparation
The current land uses adjacent to the streams and ditches proposed for riparian restoration are primarily
non-forested croplands (Figure 5). The riparian restoration areas will require limited site preparation in
addition to the stream and wetland construction. Headwater stream restoration activities will include
excavating a broader floodplain at or slightly above the existing bed elevation and will seek to restore
groundwater hydrology and connection of surface flows. The design concept will address the current
channel’s dimension, pattern, and profile to create stable conditions. Wetland restoration activities will
include minimal grading and blending of microtopography. The culvert at the end of D1 will be removed
and the banks stabilized. At the confluence of D1 and D2 where S100 begins, the stream will be restored
using a headwater stream restoration approach. The existing farm road adjacent to D1 and D2 will be
removed from the conservation easement, the area will be ripped and disked to address soil compaction.
The berm adjacent to S200 will be graded down and the surrounding ditches will be filled and planted.
The culvert at the top of D3 will be removed and the banks stabalized.

After construction activities, the soil will be subsoiled (ripped), and topsoil will be placed back over all
areas where it was removed due to construction grading , including the areas where riparian buffer and
nutrient offset credits are being generated. Topsoil will not be removed or borrowed from areas
generating buffer or nutrient offset credit. The construction plans include notes to not denude any areas
of topsoil. Graded areas must have native topsoil stockpiles and then evenly spread the topsoil after
grading and prior to planting. Site preparation will also include select herbicide treatments or mechanical
clearing to remove undesirable underbrush or invasive species as needed.

There is no concentrated flow into S200-R2 and S200-R3. Throughout the project area all ditches entering
the conservation easement will be backfilled and planted to promote diffuse flow prior to entering
riparian buffer mitigation and nutrient offset areas. Therefore, no credit removal is required due to non-
diffuse flow. Concentrated flow enters at the top of S200-R1, but no buffer credit is being proposed in the
first 100 ft, therefore no credit will be removed in the 0.1-acre non-diffuse flow exclusion area. This area
will be planted in conjunction with the stream and wetland mitigation activities. Figure 6 shows all ditches
to be backfilled.

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The Sponsor might utilize mechanical equipment periodically in the first few years after planting to
enhance vegetative growth. Mowing will not take place within the first 50 feet (Zone A) of restored buffer
after planting unless absolutely necessary. Additionally, selective applications of a pre-emergent herbicide
will be used to control weedy competition.
3.3 Riparian Restoration
Most of the riparian restoration efforts will take place adjacent to mitigated streams, constructed per the
approved Stream & Wetland Mitigation Plan. A headwater valley restoration approach is proposed for
S100-R1 and S200-R3. Headwater stream restoration activities will seek to restore groundwater hydrology
and connection of surface flows. All existing ditches within the riparian areas where riparian buffer and
nutrient offset credits are proposed, will be filled such that diffuse flow and positive site drainage will be
maintained as shown on the proposed grading plan in the Stream & Wetland Mitigation Plan. These
ditches include the ditch located along the upper reach of S200, but do not include D1, D2, D3, and D4,
which will remain in their existing condition, but will be planted. Riparian buffer credits are being
proposed under 15A NCAC 02B .0295 (o)(2). The headwater valley restoration of S100-R1 will end near
the field edge as the valley turns southwest towards White Oak Swamp. At this location, the channel will
gradually transition into S100-R2 a single thread ‘C5’ stream type using appropriate riffle-pool morphology
and grade control to accommodate vertical drops towards the remnant meander cutoff. On S200-R3,
headwater valley restoration will end and transition into S200-R4 a single thread channel. S200-R1 will a
single thread channel and is proposed for stream enhancement. The surrounding ditches will be filled and
planted and the berm adjacent to S200-R1 will be graded. S200-R4 flows into D3 before flowing into S300.
S300 is a single thread channel.
Starting at the upstream end of S300-R1, enhancement activities such as geolifts with brush toes and
brushy riffles in combination with streambank grading will be strategically placed along the reach to
stabilize the banks and stream.
D1 was determined to be an ephemeral channel that begins above S100, it is viable for nutrient credit per
the Site Viability letter issued by DWR. D2, D3, and D4 are viable for nutrient offset credits per )the Site
Viability letter issued by DWR. Figure 6 depicts the nutrient offset and buffer restoration plan based on
existing top of bank conditions. Figure 7 depicts the planting plan. The riparian buffer credits that are
located adjacent to headwater valley restoration will be measured perpendicular to the length of the
valley being restored and will be reported in the As-Built Report. These riparian credits will be withheld
until the As-Built survey has been finalized as depicted in the credit release schedule proposed in the MBI.
The revegetation plan for the entire riparian restoration area will include permanent seeding, planting
bare root trees, live stakes, and controlling invasive species growth. If temporary seeding is applied from
November through April, rye grain will be used and applied at a rate of 130 pounds per acre. If applied
from May through October, temporary seeding will consist of browntop millet, applied at a rate of 40
pounds per acre. The permanent seed mix will consist of a riparian seed mix and wetland seed mix. The
riparian restoration efforts along the project streams will be adjacent to reconstructed stream banks and
will extend perpendicular from top of bank a minimum of 50 feet to a maximum of 200 feet. The riparian
restoration efforts along the project ditches will extend perpendicular from top of bank a minimum width
of 50 feet to a maximum width of 200 feet. Nutrient offset efforts along ditches will be to a maximum
width of 200ft.
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The riparian restoration activities will occur at the same time as the stream mitigation activities and not
before. Therefore, the mitigation area where riparian restoration is being performed may be altered
slightly depending on the implementation of the Swiftie Bank. The riparian restoration areas will be
surveyed, and the resulting information provided in the As-Built report and As-Built Survey. The As-Built
report will also include any deviations that were made to the approved Plan.
3.4 Riparian Preservation
Riparian buffer preservation will include permanently protecting existing forested riparian areas with a
conservation easement. This will include the left and right bank on the bottom section of S100-R3, the left
and right bank of the bottom of S300-R1 and S300-R2 and the left bank of S400.

No more than 25 percent of the total area of buffer mitigation will be used for preservation credit pursuant
to 15A NCAC 0295 (o)(5) and 15A NCAC 0295 (o)(4), and preservation buffer areas in excess will be
protected in the conservation easement and not applied for credit. Buffer preservation can only generate
buffer mitigation credit and is not transferrable into nutrient offset credits.
3.6 Planting
The specific species composition to be planted was selected based on the community type, observation
of occurrence of species in riparian buffers adjacent to the Parcel, and best professional judgement on
species establishment and anticipated site conditions in the early years following project implementation.

Trees will be planted at a density sufficient to meet the performance standards outlined in Rule 15A NCAC
02B 0295 of 260 hardwood trees per acre at the end of five years for the nutrient offset and riparian buffer
credit areas. The performance standards for the riparian restoration areas on the coastal headwater
streams will be 210 hardwood trees per acre at the end of seven years. No one tree species will be greater
than 50 percent of the established stems. An appropriate riparian seed mix will also be applied to provide
temporary ground cover for soil stabilization and reduction of sediment loss during rain events in areas
disturbed by stream and wetland construction as necessary. This will be followed by an appropriate
permanent seed mixture. Planting is scheduled for Winter 2025 and the list of species proposed are shown
in Table 3; however, the actual planting list will be provided in the As-Built report. The planting plan can
be seen on Figure 7.

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Table 3. Planting List
Scientific Name Common Name Tree Type Wetland
Indicator
Max
Percentage
of Planting
Approximate
Tree Planting
Density
(trees/acre)
Zone 1 – Riparian and Wetland Bare Root Planting Species (8’ x 8’ spacing – 680 trees per acre)
Betula nigra River birch Canopy FACW 20% 136
Nyssa sylvatica Black gum Canopy FAC 15% 102
Platanus occidentalis American sycamore Canopy FACW 20% 136
Quercus michauxii Swamp Chestnut Oak Canopy FACW 15% 102
Quercus phellos Willow oak Canopy FACW 15% 102
Taxodium distichum Bald cypress Canopy OBL 15% 102
Zone 2 – Buffer Restoration Bare Root Planting Species (8’ x 8’ spacing – 680 trees per acre)
Betula nigra River birch Canopy FACW 20% 136
Platanus occidentalis American sycamore Canopy FACW 20% 136
Liriodendron tulipifera Tulip poplar Canopy FACU 15% 102
Quercus alba White oak Canopy FACU 15% 102
Quercus phellos Willow oak Canopy FACW 15% 102
Carpinus caroliniana Ironwood Subcanopy FAC 15% 102
Approved Species Available for Inclusion and/or Substitution (If included Species to not Exceed Density
Listed)
Quercus nigra Water oak Canopy FAC 15% 102
Quercus lyrata Overcup oak Canopy OBL 15% 102
Cornus amomum Silky dogwood Subcanopy FACW 10% 68
Ulmus americana American elm Canopy FAC 10% 68
Fagus grandifolia American beech Canopy FACU 10% 68
Note: Final species selection may change due to availability at the time of planting. Any substitute or additional
species will come from the approved list above. Any species not from the list above will be coordinated between WLS,
DWR and USACE and the planting contractor prior to the procurement of seeding stock. No bare root species will
exceed 20% of total planting.
Note: Final species selection may change due to refinement or availability at the time of planting. Species
substitutions will be coordinated between WLS and planting contractor prior to the procurement of seeding stock.

Scientific Name Common Name Wetland Tolerance Seeding Rate
(lb/acre)
Permanent Seed Mix
Scirpus cyperinus Woolgrass OBL 1.5
Dichanthelium clandestinum Deer tongue FACW 1.5
Elymus virginicus Virginia wildrye FAC 1.5
Panicum virgatum Switchgrass FAC 2.5
Schizachyrium scoparium Little blue stem FACU 2.5
Rudbeckia hirta Black-eyed susan FACU 1.5
Echinacea purpurea Coneflower NI 1.5
Juncus effusus Soft rush OBL 1.0
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4 Monitoring and Maintenance Plan
4.1 Monitoring Protocol
Permanent vegetation monitoring plots will be installed and evaluated within the riparian restoration
areas where riparian buffer credits and nutrient offset credits are being generated, to measure the
survival of the planted trees. Riparian buffer vegetation monitoring will be based on the Carolina
Vegetation Survey-Ecosystem Enhancement Program Protocol for Recording Vegetation: Level 1-2 Plot
Sampling Only Version 4.2 (Lee, 2006). Annual vegetation monitoring will occur each year for a minimum
of five years and will be conducted during the fall season with the first year occurring at least five months
from initial planting. Vegetation data in plots located within the coastal headwater valley restoration areas
will be collected for seven consecutive years in order to comply with the expectation of the performance
standards established on coastal headwater streams. Twenty-seven vegetation monitoring plots will be
installed, and will be 100 meters squared in size, and will cover at least two percent of the riparian
restoration area. Plots will be randomly placed throughout the planted riparian areas. The approximate
location of the plots is shown in Figure 8. Photos will be taken from all photo points each monitoring year
and provided in the annual reports. All planted stems will be marked with flagging tape and recorded. All
of the vegetation plots in Figure 8 will be monitored for both the buffer and nutrient bank and the stream
and wetland bank. There will be additional vegetation plots for the stream and wetland bank.

Planting is scheduled for winter 2025. The first annual monitoring activities will commence at the end of
the first growing season, at least five months after planting has been completed and no earlier than the
fall season. The following data will be recorded for all trees in the plots: species, common name, height,
planting date (or volunteer), and grid location. The average vigor per plot will be collected per plot and
reported in Year 1, 3, and 5. Height will be collected per stem, per plot and reported in Year 1, 3, and 5.
The total number of volunteer woody stems will also be documented and reported.
4.2 Performance Standards for Vegetation Adjacent to Single-Thread Streams
The measures of vegetative success for the Parcel will be the survival of at least four native hardwood
tree species, where no one species is greater than 50 percent of the established stems, established at a
density of at least 260 planted trees per acre at the end of Year 5. Appropriate native volunteer stems of
native hardwood tree species may be included to meet the performance standards upon DWR approval.
There will be 23 vegetation plots installed adjacent to single thread streams, see Figure 8. The Sponsor
shall submit the annual monitoring report to DWR by December 31st of each year for five consecutive
years and will follow the terms and conditions of the DWR MBI.
4.3 Performance Standards for Vegetation Adjacent to Coastal Headwater Streams
The measures of vegetative success for the Parcel will be the survival of at least four native hardwood
tree species, where no one species is greater than 50 percent of the established stems, established at a
density of at least 260 planted trees per acre at the end of Year 5 and 210 hardwood trees per acre at the
end of Year 7 for riparian restoration areas adjacent to coastal headwater stream restoration. The seven
years of monitoring only applies to the areas receiving credit under Rule 15A NCAC 02B .0295 (o)(2) for
buffer mitigation. Appropriate native volunteer stems of native hardwood tree species may be included
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Page 16
to meet the performance standards upon DWR approval. There will be four vegetation plots installed
adjacent to coastal headwater streams, see Figure 8. The Sponsor shall submit the annual monitoring
report to DWR by December 31st of each year for seven consecutive years and will follow the terms and
conditions of the DWR MBI.
4.4 Performance Standard for Coastal Headwater Streams
The performance standards for the coastal headwater streams will be detailed in the Stream and Wetland
Mitigation Plan in Sections 8.2 and 9.1.4. Performance standards must be met each monitoring year for a
minimum of seven years to comply with 15A NCAC 02B .0295 (o)(2) for buffer mitigation. Confirmation
from the USACE that stream performance standards have been met will need to be provided to DWR by
the Sponsor prior to issuance of credit releases for riparian buffer credit along the coastal headwater
streams. The success criteria for the coastal headwater streams include channel formation within the
valley or crenulation that must be documented through identification of field indicators consistent with
those listed below, and continuous surface water flow within the valley or crenulation must be
documented to occur every year for at least 30 consecutive days during the prescribed monitoring period.

Headwater Stream Monitoring
Channel Formation: During monitoring years 1 through 4, the preponderance of evidence must
demonstrate a concentration of flow indicative of channel formation within the topographic low point of
the valley or crenulation as documented by the following indicators:
• Scour (indicating sediment transport by flowing water)
• Sediment deposition (accumulations of sediment and/or formation ripples)
• Sediment sorting (sediment sorting indicated by grain-size distribution with the primary path of
flow)
• Multiple observed flow events (must be documented by gauge data and/or photographs)
• Destruction of terrestrial vegetation
• Presence of litter and debris
• Wracking (deposits of drift material indicating surface water flow)
• Vegetation matted down, bent, or absent (herbaceous or otherwise)
• Leaf litter disturbed or washed away
During monitoring years 5 through 7, the stream must successfully meet the requirements above and the
preponderance of evidence must demonstrate the development of stream bed and banks as documented
by the following indicators:
• Bed and banks (may include the formation of stream bed and banks, development of channel
pattern such as meander bends and/or braiding at natural topographic breaks, woody debris, or
plant root systems)
• Natural line impressed on the bank (visible high-water mark)
• Shelving (shelving of sediment depositions indicating transport)
• Water staining (staining of rooted vegetation)
• Change in plant community (transition to species adapted for flow or inundation for a long
duration, including hydrophytes)
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• Changes in character of soil (texture and/or chroma changes when compared to the soils abutting
the primary path of flow).
4.5 Photo Reference Stations
Photographs will be taken within the project area once a year to visually document stability for five years
following construction. Permanent markers will be established and located with GPS equipment so that
the same locations and view directions on the Parcel are photographed each year. Visual inspections and
photos will be taken to ensure that restored riparian areas are being maintained and compliant.
4.6 Visual Assessment
Visual assessments should support the specific performance standards for each metric as described
above. Visual assessments will be performed within the Parcel on a semi-annual basis during the five-year
monitoring period. Problem areas with vegetative health will be noted (e.g., low stem density, vegetation
mortality, invasive species, or encroachment). Areas of concern will be mapped and photographed
accompanied by a written description in the annual report. Problem areas will be re-evaluated during
each subsequent visual assessment. Should remedial actions be required, recommendations will be
provided in the annual monitoring report.
4.7 Reporting Performance Criteria
Within 30 calendar days after the Parcel has been completed and all stream, wetland, buffer and nutrient
offset activities have been fully implemented according to both mitigation plans, including all plantings,
WLS will submit a written notification to NCDWR. Notification to NCDWR shall include information that
documents that all activities have been completed and that the conservation easement has been marked
adequately. The documentation will include the following:
• Short summary of activities completed as required per the approved Plan;
• Figures representing all riparian restoration, riparian enhancement and riparian preservation
activities where applicable;
• Figures representing location of all monitoring plots installed;
• Detailed planting plan- including type of species planted, density of species planted, and any
modifications to the planting plan from what was approved in the Plan;
• Description of how the conservation easement boundaries were marked;
• Any major changes to the conservation easement boundary or to the amount of Nutrient
Offset Credits and Riparian Buffer Credits from what was proposed in the approved in the
Plan.
Complete monitoring reports will be prepared in the fall of each monitoring year and submitted to
NCDWR. The monitoring period will extend five to seven years beyond the completion of site planting or
until performance criteria have been met.
4.8 Adaptive Management Plan
In the event the site or a specific component of the site fails to achieve the necessary performance
standards as specified in the approved Plan, the Sponsor shall notify and coordinate with NCDWR to
develop a remedial action plan. The remedial action plan should describe the source or reason for the
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Page 18
failure, a concise description of the corrective measures that are proposed, and a time frame for the
implementation of the corrective measures.
4.9 Conservation Easement and Long-Term Management Plan
The Parcel will be protected in perpetuity by a recorded conservation easement. The conservation
easement is designed to ensure that the Ephemeral channel (D1), and D2, D3 and D4 remain hydrologically
connected to Streams S100-R1, S300 and S400. Within the conservation easement there are walking
paths. These walking paths will not bisect the riparian areas or features where riparian buffer and nutrient
offset credits are being proposed. At closing of the conservation easement, the long term steward will be
assigned. The conservation easement will allow for annual monitoring and maintenance of the Project
during the monitoring phase by WLS. Upon DWR issuance of the final credit release as described in the
credit release schedule of the DWR MBI, the Project stewardship responsibilities will be officially
transferred to a DWR approved long-term steward. WLS has partnered with Broad Water Innovations
(BWI) as the long-term steward for the Project site (See Appendix D of the Stream and Wetland Mitigation
Plan for conservation easement template and long-term stewardship agreement letter).
Broad Water Innovations
Attn: Tee Clarkson
2108 Laburnum Avenue, Suite 115
Richmond, VA 23227

This party shall serve as conservation easement holder and long-term steward for the property and will
conduct periodic inspection of the Project to ensure that restrictions required in the conservation
easement are upheld. Any endowment funds for the conservation easement and deed restrictions shall
be negotiated prior to transfer to the responsible party. Funding will be supplied by the responsible party
on a yearly basis until such time and endowments are established. The use of funds from the Endowment
Account is governed by NC General Statute GS 113A-232(d) (3). Payments and interest gained by the
endowment fund may be used only for stewardship, monitoring, stewardship administration, and land
transaction costs, if applicable. The management activities will be conducted in accordance with the terms
and conditions of the approved DWR MBI as agreed to by WLS.
The conservation easement plat will depict all relevant ditch centerlines, top of banks, and riparian zones.
The conservation easement boundaries will be identified in the field to ensure a clear distinction between
the Parcel and adjacent properties. Boundaries may be identified by a fence, marker, bollard, post, tree
blazing, or other means as allowed by site conditions and/or conservation easement. Boundaries will be
marked with signs identifying the property as a conservation site and will include the name of the long-
term steward. All boundary markers will be installed prior to the submittal of Task 2 of the DWR MBI. The
easement boundary will be checked annually as part of monitoring activities, and the conditions, as well
as any maintenance performed, will be reported in the annual monitoring reports.

The land required for riparian area planting, management, and stewardship of the project includes
portions of the parcel listed in Table 4. Palustrine Group LLC owns the property. WLS will place a
conservation easement of 315 acres on the parcel and it will be recorded at the Edgecombe County
Register of Deeds. BWI will be noted on the conservation easement as the Grantee.

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Table 4. Existing Property Owner
Owner of Record
N/F
PIN County Site Protection
Instrument
Deed Book
and Page
Numbers
Acreage
Protected
Palustrine Group LLC
(Owned by WLS) 4812-20-1970 Edgecombe Conservation
Easement
Book: 1773
Page: 0006 315
4.10 Financial Assurances
Following approval of the Plan, WLS will provide financial assurances in the form of a Performance Bond
from a surety that is rated no less than “A-” as rated by A.M. Best. Financial assurances will be payable at
the direction of the NCDWR to its designee or to a standby trust. The initial performance bond will be for
100 percent of the implementation costs, but not less than $150,000. In lieu of posting the performance
bond, the Sponsor may elect to construct the project prior to the first credit release.

After completion of the construction and monitoring devices, a monitoring bond for $100,000 will be
secured to implement the monitoring and maintenance of the riparian restoration areas for a minimum
of seven years.

Performance bonds for monitoring shall be renewed to cover the next year’s monitoring period, with
confirmation of renewal provided to NCDWR with each annual monitoring report when applicable.
NCDWR reserves the right to alter the credit release schedule if monitoring reports are submitted without
proof of bond renewals when applicable.
5 Credit Release Schedule
Upon submittal of all appropriate documentation by the Sponsor, and subsequent approval by DWR, it is
agreed that the mitigation credits associated with the Parcel will be released as described in the DWR MBI
and Table 5. The total buffer credits proposed adjacent to constructed headwater valley streams will be
dependent on the approval of the IRT to construct. The stream site will have to be constructed in its
entirety and an As-Built Report and survey submitted to the IRT prior to DWR granting approval to
generate buffer credits under Rule 15A NCAC 02B .0295 (o)(2). The area of the buffer credits shall be
measured perpendicular to the length of the valley being restored.

Swiftie Buffer Mitigation & Nutrient Offset Plan
Page 20
Table 5. Credit Release Schedule for Riparian Buffer and Nutrient Offset Credits
Task Project Milestone
% Nutrient
Offset and
Riparian
Buffer
Credit
Release
% Riparian
Buffer Credit
Release within
Coastal
Headwater
Areas
1
Instrument and Plan Approved by DWR, Conservation
Easement Recorded and Assigned*, Financial Assurance
Posted, and Draft Stream & Wetland Mitigation Plan
Approved by IRT
25 No Credit
2
Mitigation Site Earthwork, Planting and Installation of
Monitoring Devices Completed, and all Applicable Permits
Obtained
20 No Credit
3 Monitoring Financial Assurance Posted and Approval of As-
Built Report 10 30
4 Monitoring Report #1 Approved by the DWR** and financial
assurance renewed 10 10
5 Monitoring Report #2 Approved by the DWR** and financial
assurance renewed 10 10
6 Monitoring Report #3 Approved by the DWR** and financial
assurance renewed 10 5
7 Monitoring Report #4 Approved by the DWR** and financial
assurance renewed 5 5
8
Monitoring Report #5 Approved by the DWR*, financial
assurance renewed for coastal headwater buffer areas, and
final site visit by DWR has been conducted for nutrient offset
areas
10 20
9 Monitoring Report #6 Approved by the DWR** and financial
assurance renewed for coastal headwater buffer areas N/A 10
10
Monitoring Report #7 Approved by the DWR** and final site
visit by DWR has been conducted for coastal headwater buffer
areas
N/A 10
Total 100 100
* For specification, please see Section V of the MBI
**DWR approval provided upon a determination that the site is meeting success criteria contained within the approved Plan
6 Mitigation Potential
Out of 315 acres that will be protected with a permanent conservation easement, 12.37 acres (538,623
ft²) are proposed to generate riparian buffer credits, and 25.9 acres (58,864.513 lbs. Nitrogen and
3,791.329lbs. Phosphorus) are proposed to generate nutrient offset credits. Some of riparian restoration
mentioned above are convertible for either nutrient offset credit or buffer mitigation credit, but not both.
The remaining acres within the Conservation Easement will be used for wetland and stream mitigation
pursuant to the Swiftie Mitigation Bank.

The credit type, mitigation activity and associated buffer mitigation and nutrient offset are presented in
Table 6. Credits that are convertible between buffer and nutrient offset is also present. All request for
Swiftie Buffer Mitigation & Nutrient Offset Plan
Page 21

credit conversions and transfers must be in writing with written approval received by DWR prior to adding
or removing credits form the project’s credit ledgers. With each conversion and transfer request
submitted to the DWR, the Sponsor will provide all updated credit ledgers showing all transactions that
have occurred up to the date of the request.

The Sponsor will maintain four credit ledgers: one for coastal headwater buffer credits and buffer
preservation credits, one for buffer restoration credits excluding coastal headwater buffer areas, one for
Nitrogen nutrient offset credits, one for Phosphorus nutrient offset credits. The total potential nutrient
offset credits and riparian buffer credits that the Parcel will generate is summarized in Table 6.

Table 6. [Swiftie Mitigation Bank], [20230026 v1], 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 (ft 2)
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)
Nutrient Offset Rural No Ephemeral Restoration 0-100 D1 98,496 98,496 1 100% 1.00000 No —Yes 5,139.653 331.033
Nutrient Offset Rural No Ephemeral Restoration 101-200 D1 108,396 108,396 1 33% 3.03030 No —Yes 5,656.248 364.306
Nutrient Offset Rural No Ditch Restoration 0-100 D2 100,306 100,306 1 100% 1.00000 No —Yes 5,234.101 337.117
Nutrient Offset Rural No Ditch Restoration 101-200 D2 105,572 105,572 1 33% 3.03030 No —Yes 5,508.888 354.815
Buffer Rural Yes Coastal
Headwater Restoration 0-100 S100 127,393 127,393 1 100% 1.00000 Yes 127,393.000 No ——
Buffer Rural Yes Coastal
Headwater Restoration 101-200 S100 109,517 109,517 1 33% 3.03030 Yes 36,140.646 No ——
Buffer Rural Yes I / P Restoration 0-100 S100 17,123 17,123 1 100% 1.00000 Yes 17,123.000 Yes 893.501 57.548
Nutrient Offset Rural Yes I / P Restoration 101-200 S100 21,767 21,767 1 33% 3.03030 No —Yes 1,135.831 73.156
Nutrient Offset Rural No Ditch Restoration 0-100 D3 96,304 96,304 1 100% 1.00000 No —Yes 5,025.271 323.666
Nutrient Offset Rural No Ditch Restoration 101-200 D3 117,045 117,045 1 33% 3.03030 No —Yes 6,107.565 393.374
Buffer Rural Yes I / P Restoration 0-100 S300 83,670 83,670 1 100% 1.00000 Yes 83,670.000 Yes 4,366.012 281.205
Nutrient Offset Rural Yes I / P Restoration 101-200 S300 149,345 149,345 1 33% 3.03030 No —Yes 7,793.022 501.931
Nutrient Offset Rural No Ditch Restoration 0-100 D4 112,535 112,535 1 100% 1.00000 No —Yes 5,872.227 378.217
Nutrient Offset Rural No Ditch Restoration 101-200 D4 158,734 158,734 1 33% 3.03030 No —Yes 8,282.952 533.486
Buffer Rural No Coastal
Headwater Restoration 0-100 S200 5,802 5,802 1 100% 1.00000 Yes 5,802.000 No ——
Buffer Rural No Coastal
Headwater Restoration 101-200 S200 60,462 60,462 1 33% 3.03030 Yes 19,952.480 No ——
Nutrient Offset Rural No I / P Restoration 101-200 S200 59,576 59,576 1 33% 3.03030 Yes 19,660.100 Yes 3,108.755 200.228
———
———
Totals (ft2):1,532,043 1,532,043 309,741.226 64,124.026 4,130.082
Total Buffer (ft2):403,967 403,967
Total Nutrient Offset (ft2):1,128,076 N/A
Total Ephemeral Area (ft2) for Credit:0 0
Total Eligible Ephemeral Area (ft2):134,656 0.0%Ephemeral Reaches as % TABM
Enter Preservation Credits Below Total Eligible for Preservation (ft2):134,656 25.0%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 Yes I / P 0-100 S300 170,786 134,656 10 100% 10.00000 13,465.600
Rural Yes I / P 101-200 S300 208,423 0 10 33%—
Rural Yes I / P 0-100 S400 79,398 0 10 100%—
Rural Yes I / P 101-200 S400 87,415 0 10 33%—
Rural Yes I / P 0-100 S100 32,676 0 10 100%—
Rural Yes I / P 101-200 S100 21,071 0 10 33%—
Preservation Area Subtotals (ft2):599,769 134,656
Square Feet Credits
403,967 290,081.126
0 0.000
134,656 13,465.600
538,623 303,546.726
Square Feet Credits
Nitrogen:58,864.513
Phosphorus:3,791.329
Tar-Pamlico 03020101
19.16394
297.54099
Restoration:
Enhancement:
Mitigation Totals
1,128,076
TOTAL AREA OF BUFFER MITIGATION (TABM)
TOTAL NUTRIENT OFFSET MITIGATION
Mitigation Totals
Nutrient
Offset:
Preservation:
Total Riparian Buffer:
Page 23
7 Citations
Lee, T.L, Peet, R.K., Roberts, S.D., and Wentworth, T.R. 2006. CVS-EEP Protocol for Recording Vegetation,
Version 4.2. http://cvs.bio.unc.edu/protocol/cvs-eep-protocolv4.2- lev1-2.pdf.
NC Environmental Management Commission. 2014. Rule 15A NCAC 02B.0295 - Mitigation Program
Requirements for the Protection and Maintenance of Riparian Buffers.
Schafale, M.P. 2012. Guide to the Natural Communities of North Carolina, Fourth Approximation. North
Carolina Natural Heritage Program, Division of Parks and Recreation, NCDENR, Raleigh, NC.
United States Department of Agriculture (USDA), Natural Resources Conservation Service (NRCS) Soil
Survey Division. 1979. Soil Survey, Edgecombe County, NC.
United States Department of Interior, Fish and Wildlife Service (USFWS). Threatened and Endangered
Species in North Carolina (County Listing). Edgecombe County. 2023.

Figures
Figure 1 .................................................................................................................... Credit Service Area Map
Figure 2 ......................................................................................................................... Project Location Map
Figure 3 .................................................................................................................................. NRCS Soils Map
Figure 4 .................................................................................................................................. Floodplain Map
Figure 5 .................................................................................................................... Existing Conditions Map
Figure 6 ............................................................................................................... Swiftie Credit Concept Map
Figure 7 ............................................................................................................. Mitigation and Planting Plan
Figure 8 ................................................................................................................ Proposed Monitoring Map

!(
SiteLocation
HUC8 - Upper Tar (03020101)
Figure1Credit Service
Area Map
Date: 3/28/2024
!(Site Location
Nutrient Offset and Buffer
Credit Service Area
´0 10 205
Miles
1 inch = 10 miles
Map Projection: NAD_1983_StatePlane_North_Carolina_FIPS_3200_Feet
Swiftie Mitigation Project
HUC8 Tar-Pam 01 - 03020101
Edgecombe County, North Carolina
Palustrine Group LLC
4812-20-1970
Tar River Land Conservancy
4812-33-5285
±0 1,500 3,000
Feet
Figure2Swiftie Mitigation Project
HUC8 Tar-Pam 01 - 03020101
Edgecombe County, North Carolina
Map Projection: NAD_1983_StatePlane_NC_FIPS_3200_Feet
Project
Location Map
!(
o
o
PITT CO
HALIFAX CO
NASH CO
MARTIN CO
EDGECOMBE CO
Lower Tar03020103
Fishing03020102
Upper Tar03020101
Lower Roanoke03010107
Contentnea03020203
Proposed Conservation Easement
Parcel Boundary
!(Project Location
Vicinity Streams (NHD)
HUC-8
5-Mile Aviation Zone
o Airport
Edgecombe County
NC Counties
0 5 10
Miles075150Miles
Project is located in:
HUC8 - 03020101
HUC12 - 030201010803
Date: 2/20/2024
Legend
Service Layer Credits: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)
OpenStreetMap contributors, and the GIS User Community
36.00490, -77.60111
Figure3NRCS Soil
Survey Map
Date: 4/3/2024
Proposed Conservation Easement
Parcel Boundary
´0 1,000 2,000500
Feet
1 inch = 1,000 feet
Imagery data source: EDR
Map Projection: NAD_1983_StatePlane_North_Carolina_FIPS_3200_Feet
Swiftie Mitigation Project
HUC8 Watershed 03040207
Edgecombe County, North Carolina
White OakSwamp Rd
33
S300
S6
0
0
Swift Cr
e
e
k
S500
S400
Wh
i
t
e

O
a
k

S
w
a
m
p
S700
S20
0
S100
Figure4FEMA
Floodplain Map
Date: 4/3/2024
Proposed Conservation Easement
Parcel Boundary
Existing Stream
Existing Ditch
FEMA Floodzone
100-yr (Zone AE)
Floodway (Zone AE)
500-yr (Zone X)
´0 1,000 2,000500
Feet
1 inch = 1,000 feet
Map Projection: NAD_1983_StatePlane_North_Carolina_FIPS_3200_Feet
Swiftie Mitigation Project
HUC8 Tar-Pam 01 - 03020101
Edgecombe County, North Carolina
"/"
"/"
"/"
"/"
White OakSwamp Rd
33DWR Stream Origin (S100)
S400
S300
S200
DWR StreamReach Stop (S200)
DWR Stream Origin (S300)
D1
S100
D2
D3
D4
Road to beRemoved
Existing Bermto be Removed
Figure5Existing
Conditions Map
Date: 4/9/2024
Proposed Conservation Easement
Parcel Boundary
Treeline
Existing Road
Existing Berm
Road to be Re-routed
Ephemeral Stream
Existing Stream
Existing Ditches
Existing Wetland
"/"Existing Culverts
Existing Utility (powerline)
´0 1,000 2,000500
Feet
1 inch = 1,000 feet
Map Projection: NAD_1983_StatePlane_North_Carolina_FIPS_3200_Feet
Swiftie Mitigation Project
HUC8 Tar-Pam 01 - 03020101
Edgecombe County, North Carolina
S100 S200
S300
D1
S400
D2
D3
D4
Figure6Swiftie Credit
Concept Map
Date: 4/16/2024
Stream Mitigation
Restoration
HWV Restoration
Enhancement
Preservation
No Credit
Ephemeral ChannelDitches
To Remain
Positive Drainage
To be Filled
Wetland Mitigation
Wetland Credits ProposedBuffer Mitigation and Nutrient Offset
Coastal HWV Buffer Restoration 0-100 ft
Coastal HWV Buffer Restoration 101-200 ft
Riparian Restoration for Buffer Credit 0-100 ft
Riparian Preservation for Buffer Credit 0-100ft
Riparian Preservation for Buffer Credit 101-200ft
Riparian Restoration for Nutrient Offset 0-100 ft
Riparian Restoration for Nutrient Offset 101-200 ft
´0 500 1,000250
Feet
1 inch = 500 feet
Map Projection: NAD_1983_StatePlane_North_Carolina_FIPS_3200_Feet
Swiftie Mitigation Project
HUC8 Tar-Pam 01 - 03020101
Edgecombe County, North Carolina
Proposed Conservation
Easement
Riparian Buffer Zone
50 foot
100 foot
200 foot
S100
S200
S300
D1
PollinatorMeadow
D2
D3
D4
S400
Figure7Mitigation and
Planting Plan
Date: 4/16/2024
Proposed Conservation Easement
Parcel Boundary
Existing Utility (powerline)
Existing Roads to Remain
Existing Roads Re-route
Pollinator MeadowPlanting Areas
Zone 1
Zone 2
Ephemeral ChannelExisting Ditch
To Remain
Positive DrainageStream Mitigation
Stream Credits Proposed
Wetland Mitigation
Wetland Credits ProposedBuffer Mitigation
Proposed Buffer AreaNutrient Offset
Proposed Nutrient Area
´0 1,000 2,000500
Feet
1 inch = 1,000 feet
Map Projection: NAD_1983_StatePlane_North_Carolina_FIPS_3200_Feet
Swiftie Mitigation Project
HUC8 Tar-Pam 01 - 03020101
Edgecombe County, North Carolina
___
")
___
")
___
")
")
")
")
")
")
")
")
")
")
")
")
")
")
")
")
")
")
")
")")
")
")
___
")
")
___
")
")
")
")
")
___
")
")
")
")
")
")
33
S300
D1
S200
S400
S100
D2
D3
D4
Figure8Proposed
Monitoring Map
Date: 4/16/2024
Stream Mitigation
Restoration
HWV Restoration
Enhancement
Preservation
No Credit
Ephemeral Stream
Existing Ditches
Buffer Mitigation and Nutrient Offset
Coastal HWV Buffer Restoration 0-100 ft
Coastal HWV Buffer Restoration 101-200 ft
Riparian Restoration for Buffer Credit 0-100 ft
Riparian Preservation for Buffer Credit 0-100ft
Riparian Preservation for Buffer Credit 101-200ft
Riparian Restoration for Nutrient Offset 0-100 ft
Riparian Restoration for Nutrient Offset 101-200 ftWetland Mitigation
Wetland Credits Proposed
´0 500 1,000250
Feet
1 inch = 500 feet
Map Projection: NAD_1983_StatePlane_North_Carolina_FIPS_3200_Feet
Swiftie Mitigation Project
HUC8 Tar-Pam 01 - 03020101
Edgecombe County, North Carolina
Proposed Conservation Easement
Parcel Boundary
")USACE Vegetation Plot (11)
")DWR Vegetation Plot 5-yr Monitoring (16)
")USACE/DWR 7-yr Monitoring Joint Vegetation Plot (4)
")USACE/DWR Joint Vegetation Plot (7)
___USACE Random Transect Plot (6)
Attachment A – DWR Determination and Viability

ROY COOPER
Governor
ELIZABETH S. BISER
Secrerary
RICHARD E. ROGERS, JR . NORTH CAROLINA
Environmental Quality D/recror
June 26, 2023
Water & Land Solutions, LLC
Attn: Catherine Roland
(via electronic mail: cat herine(a),waterl an dsolutions.com )
Re: Site Viability for Buffer Mitigation and Nutrient Offset -Swiftie Site
Near 35.996211, -77.6053 located off NC 33W in Tarboro, NC
Tar-Pamlico 03020101
Edgecombe County
Dear Ms. Roland,
On February l, 2023, Katie Merritt, with the Division of Water Resources (DWR), received a request
from you on behalf of Water & Land Solutions, LLC (WLS) for a site visit near the above-referenced
site in the Tar-Pamlico River Basin within the 8-digit Hydrologic Unit Code 03020 IO I. The site visit
was to determine the potential for nutrient offset and buffer mitigation within a proposed
conservation easement boundary, which is more accurately depicted in the attached map labeled
"Figure 9 -Proposed Buffer Map" (Figure 9) prepared by WLS and edited by DWR. The proposed
easement boundary on the Figure 9, includes all riparian areas intended to be proposed as part of the
mitigation site. This site is also being proposed as a stream and wetland mitigation site and therefore
stream bank instability or presence of erosional rills within riparian areas were not addressed. Figure
1 labeled "Existing Aquatic Resources Map" prepared by WLS and edited by DWR was also used
for this site viability assessment and is attached to this letter. On March 8, 2023, Ms. Merritt
performed a site assessment of the subject site. Staff with WLS were also present.
Ms. Merritt's evaluation of the features onsite and their associated mitigation determination for the
riparian areas are provided in the table below. This evaluation was made from Top of Bank (TOB)
and landward 200' from each feature for buffer mitigation pursuant to I SA NCAC 02B .0295 and for
nutrient offset credits pursuant to 15A NCAC 02B .0703 using I SA NCAC 02B .0295 to define the
mitigation type determinations. North C'arol111a D�partment of l·m 1ron111ental Qualtt) I DI\ ision of Water Hes ourc·es 512 North Salisbul) St reet I 1611 Mail Sm ice ( enter I Ralei gh North Carolina 27 69Q-1611 919 707 90()() DocuSign Envelope ID: 445ACE81-B3B0-4327-9B65-22142C79D570
Feature Classification Subject onsite !Q Buffer
Rule 1
DI Ephemeral No
D2 Ditch <3' No
SI00 Stream Yes
(starts at
confluence
w/DI &
D2)
S200 Stream No
D3 Ditch >3' No
Ends at
S300 origin
S300 Stream Yes
(see map)
D4 Ditch >3' No
Ril!arian Land uses Buffer
adjacent to Feature Credit
(0-200') Viable
Non-forested agricultural Yes6
fields
Non-forested agricultural *see note
fields
Mostly non-forested Yes 2
agricultural fields;
Forested at field edge to
W04 label
Combination of mature Yes2
forest with row crop
agriculture beyond the
wood line. A benn and
lateral ditches are present
that require removal (see
maps)
Existing utility line is
present
Non-forested agricultural No
fields
Combination of non-Yes2
forested agricultural fields
and forested areas
Combination of non-No
forested agricultural fields
and mature forest (see
map)
Page 2 of 4
Nutrient
Offset
Viable3
Yes
Yes
Yes (non-
forested ag
fields only)
Yes (non-
forested ag
fields only)
Yes
Yes (non-
forested ag
fields only)
Yes (non-
forested ag
fields only)
Swiftie Site EBX
June 26, 2023
Miti�ation T:rne Determination w/in
riparian areas 4•5•8
Non-forested fields -Restoration Site
per I SA NCAC 028 .0295 (o)(7)
Non-forested fields -Restoration Site
per 15A NCAC 028 .0295 (0)(8)
*Buffer Mitigation Note -Assessment
concludes the ditch meets I SA NCAC
028 .0295 (0)(8) (A, B, C, D & E). More
infonnation is required to be provided in
a mitigation plan for complete
assessment. See rule.
Non-forested fields -Restoration Site
per ISA NCAC 028 .0295 (n)
Forested areas -Preservation Site per
15A NCAC 02B .0295 (o)(5)
Non-forested fields -Restoration Site
per 15A NCAC 028 .0295 (o)(3)
Forested areas -Preservation Site per
ISA NCAC 028 .0295 (o)(4)
Viable for generating only if berm is
graded down and ditches within riparian
areas are fi lied and planted. No credits
within existing utility line.
Non-forested fields -Restoration Site
per I SA NCAC 02B .0295 (n)
Non-forested fields -Restoration Site
per I SA NCAC 02B .0295 (n)
Forested areas -Preservation Site per
15A NCAC 028 .0295 (o)(5)
Non-forested fields -Restoration Site
per I SA NCAC 028 .0295 (n)
DocuSign Envelope ID: 445ACE81-B3B0-4327-9B65-22142C79D570
Feature Classification Subject Riparian Land uses onsite !Q adjacent to Feature
Buffer (0-200')
Rule 1
S400 Stream Yes Right Bank is forested;
Left Bank in non-forested
agricultural fields but is
not included in the project
Buffer Nutrient
Credit Offset
Viable Viable3
Yes2 No
Swiftie Site
EBX
June 26, 2023
Miti11ation T:rne Determination w/in
riparian areas 4•5•8
Preservation Site per I SA NCAC 02B
.0295 (o)(5)
1Subjectivity calls and stream origins for the features were determined by DWR in correspondence dated May 3, 2017 (DWR# 2016-
1271) and June 16, 2017 using the I :24,000 scale quadrangle topographic map prepared by USGS and the most recent printed version
of the soil survey map prepared by the NRCS. 2The area of preservation credit within a buffer mitigation site shall comprise of no more than 25 percent (25%) of the total area of buffer
mitigation per 15A NCAC 0295 (o)(5) and 15A NCAC 0295 (o)(4). Site cannot be a Preservation Only site to comply with this rule.
3NC Division of Water Resources -Methodology and Calculations/or determining Nutrient Reductions associated with Riparian Buffer
Establishment 4 Determinations made for this Site are detennined based on the proposal provided in maps and figures submitted with the request.5 All features proposed for buffer mitigation or nutrient offset, must have a planted conservation easement established that includes the
tops of channel banks when being measured perpendicular and landward from the banks, even if no credit is viable within that riparian
area. 6The area of the mitigation site on ephemeral channels shall comprise no more than 25 percent (25%) of the total area of buffer
mitigation per I SA NCAC 02B .0295 (o)(7). 7The area described as an Enhancement Site was assessed and detennined to comply with all of I SA NCAC 02B .0295(0)(6). Cattle
exclusion fencing is required to be installed around the mitigation area to get buffer credit under this part of the rule. 8The confluence of a ditch to a stream is required to be secured with a conservation easement to preserve the hydrologic connectivity of
ditches to streams to be viable to generate buffer and/or nutrient offset credits
Determinations provided in the table above were made using a proposed easement boundary showing
proposed mitigation areas and features shown on Figure 9 and Figure 1. The maps representing the
proposal for the site are attached to this letter and initialed by Ms. Merritt on June 26, 2023.
Substantial changes to the proposed easement boundary as well as any site constraints identified in
this letter, could affect the Site's potential to generate buffer mitigation and nutrient offset credits.
This letter does not constitute an approval of this Site to generate buffer and nutrient offset credits.
Pursuant to I SA NCAC 02B .0295, a mitigation proposal and a mitigation plan shall be submitted to
DWR for written approval prior to conducting any mitigation activities in riparian areas and/or
surface waters for buffer mitigation credit. Pursuant to 15A NCAC 02B .0703, a proposal regarding a
proposed nutrient load-reducing measure for nutrient offset credit shall be submitted to DWR for
approval prior to any mitigation activities in riparian areas and/or surface waters.
All vegetative plantings, perfotmance criteria and other mitigation requirements for ripa1ian
restoration, enhancement and preservation must follow the requirements in I SA NCAC 02B .0295 to
be eligible for buffer and/or nutrient offset mjtigation credits. For any areas depicted as not being
viable for nutrient offset credit above, one could propose a different measure, along with supporting
calculations and sufficient detail to suppo11 estimates of load reduction, for review by the DWR to
determine viability for nutrient offset in accordance with I SA NCAC 02B .0703.
Page 3 of 4
DocuSign Envelope ID: 445ACE81-B3B0-4327-9B65-22142C79D570
Swiftie Site EBX
June 26, 2023
This viability assessment will expire on June 26, 2025 or upon approval of a mitigation plan by
the DWR, whichever comes first. This letter should be provided in any nutrient offset, buffer,
stream or wetland mitigation plan for this Site.
Please contact Katie Merritt at [phone] if you have any questions regarding this
correspondence.
Sincerely,
Stephanie Goss, Supervisor
40 I and Buffer Permitting Branch
Attachments: Figure I -Existing Aquatic Resources Map (edited by DWR); Figure 9-Proposed
Buffer Map
cc: File Copy (Katie Merritt)
Page 4 of 4
DocuSign Envelope ID: 445ACE81-B3B0-4327-9B65-22142C79D570
500 1,000 2,000
---c::::===:1-----•Feet
1 inch = 1,000 feet
Existing Aquatic
Resources Map
Figure
1
DocuSign Envelope ID: 445ACE81-B3B0-4327-9B65-22142C79D570
Riparian Restoration
Riparian Restoration
Riparian Restoration
Riparian Preservation
Riparian Preservation
0
Map Projection: NAO_ 1983_StatePlane_Nor1h_Carobna_FIPS_3200_Feet
500 1,000
1 inch = 1,000 feet
Proposed
Buffer Map
Date: 1/2512023
2,000
� Feet
N
Figure
9
DocuSign Envelope ID: 445ACE81-B3B0-4327-9B65-22142C79D570
Attachment B – Photo Log

D1 looking downstream at transition to S100.D2 looking downstream at confluence with S100.
D3 looking downstream at transition to S300.D4 looking downstream towards S400.
Berm on the floodplain on S200-R2. Seen on the right in this
photo.
Ditch to be filled adjacent to S100-R3.
Culvert to be removed from D3.Existing road and culvert that will be removed between D1
and D2.
S300 looking upstream in the enhancement section.S300 looking upstream in preservation section.
S400 looking upstream. Existing road that will be removed between D1 and D2.