20170537 Ver 2_Draft BPDP_20170601

Bank Parcel Development Plan
Hannah Bridge Mitigation Site
Johnston County, North Carolina
Neuse River Basin
HUC 03020201
Prepared By:
pres
Bank Sponsor: EBX-Neuse I, LLC,
302 Jefferson Street, Suite 110
Raleigh, NC 27605
919-829-9909
May 2017
Hannah Bridge Parcel Development Plan
Buffer/Nutrient Offset Site i May 2017

Table of Contents
1 INTRODUCTION ............................................................................................................................ 3
1.1 Parcel Location...........................................................................................................................3
1.2 Parcel Overview.........................................................................................................................
3
2 PROJECT AREA — EXISTING CONDITIONS
...........................................................................4
2.1 Physiography..............................................................................................................................4
2.2 Soils...........................................................................................................................................4
2.3 Vegetation..................................................................................................................................
6
2.4 Wetlands.....................................................................................................................................6
2.5 Threatened and Endangered Species..........................................................................................
7
2.6 Environmental and Cultural Constraints....................................................................................
8
2.7 FEMA Floodplain/Floodway Mapping......................................................................................
8
3 RESTORATION PLAN..................................................................................................................8
3.1 Riparian Restoration Activities..................................................................................................
8
3.2 Planting Plan..............................................................................................................................
9
3.3 Easement Boundaries and Fencing.............................................................................................9
4 MONITORING AND MAINTENANCE PLAN............................................................................9
4.1 Monitoring Protocol and Success Criteria..................................................................................9
4.2 Adaptive Management Plan.....................................................................................................10
4.3 Long Term Management Plan..................................................................................................10
5 FINANCIAL ASSURANCE..........................................................................................................10
6 MITIGATION POTENTIAL........................................................................................................11
7 REFERENCES...............................................................................................................................13
APPENDIX
Appendix A— Supporting Figures
Figure 1. Project Vicinity Map
Figure 2. USGS Topographic Map
Figure 3. National Wetlands Inventory Map
Figure 4. Historical Aerial Photography
Figure 5. Soils Map
Figure 6. FEMA Map
Figure 7. Existing Conditions
Figure 8. Conceptual Design Plan
Appendix B- Correspondence
Appendix C- Conservation Easement and Plat
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I INTRODUCTION
EBX—Neuse I, LLC (EBX), an entity of Resource Environmental Solutions (RES), is pleased to provide
this Bank Parcel Development Plan (BPDP) for the Hannah Bridge Riparian Buffer and Nutrient Offset
Mitigation Bank ("Parcel"). This Parcel is designed to provide riparian buffer and nutrient offset
mitigation credits for unavoidable impacts due to development within the Neuse River Basin, United
States Geological Survey (`USGS') 8 -digit Hydrologic Unit Code (HUC — 03020201). In addition, it
will also provide nutrient offset credits in the 03020201 HUC, excluding the Falls Lake Watershed, for
existing and proposed development requiring such mitigation. This BPDP is in accordance with the
Consolidated Buffer Mitigation Rule 15A NCAC 02B .0295 and 15A NCAC 0213.0240 as well as the
Hannah Bridge Mitigation Banking Instrument for Riparian Buffer Mjtigation and Nutrient Offset
Credits, made and entered into by EBX-Neuse 1, LLC acting as the Bank Sponsor (Sponsor), and the
North Carolina Department of Environmental Quality (NCDEQ) on . Supporting figures
can be found in Appendix A. The BPDP has also been designed in concurrence with the Hannah Bridge
Stream and Wetland Mitigation Bank. The mitigation plan for the Hannah Bridge Stream and Wetland
Mitigation Bank has been submitted and approved by the Interagency Review Team.
1.1 Parcel Location
The Parcel is located in Johnston County approximately five miles south of the town of Four Oaks, NC
(Figure 1). The Parcel is located within Neuse River Basin USGS 14 -digit HUC 03020201150020 and
North Carolina Division of Water Resources (NC DWR) Subbasin Number 03-04-04.
To access the Parcel from the town of Four Oaks, travel South on NC Hwy 96 and turn left on Green
Pasture Road. The coordinates of the site are 35.380025°N and -78.417046 °W.
1.2 Parcel Overview
The Parcel easement totals 46.2 acres and includes unnamed tributaries, and stormwater runoff from
adjacent pastures that flow directly to Hannah Creek. The drainage area of the Parcel is 1.39 mit. The
Parcel is located in an area dominated by agriculture, livestock, and residential land use. A majority of
the Parcel is utilized for livestock pasture. Additional land use practices including the maintenance and
removal of riparian vegetation and the relocation and the dredging and straightening of onsite streams
has resulted in degraded water quality and unstable channel characteristics.
The Hannah Bridge Mitigation Site is proposed to provide stream restoration and enhancement on
approximately 8,524 linear feet of streams and wetland restoration, enhancement, and preservation on
16.7 acres of wetlands within the conservation easement through a separate mitigation banking
instrument. Figure 7 shows the existing stream channel and wetland boundary and Figure 8 shows the
proposed stream and wetland mitigation areas for the stream and wetland mitigation bank. Restoration
of the riparian buffer is anticipated to result in immediate water quality benefits within the vicinity of the
Parcel through the removal of livestock access to Parcel streams. The riparian restoration activities
within the Parcel will also result in improved water quality within the downstream watershed.
The project area is comprised of two separate easement locations along multiple drainage features that
flow into Hannah Creek. The northern easement area captures a single tributary to Hannah Creek and a
portion of its headwaters. The southern easement area is separated from the northern area by an active
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agricultural field, and is divided into three different areas due to a utility crossing and a culvert crossing.
The northern portion of the project contains Reach TH3, while the southern portion is comprised of
Reaches HBI, HB2, HB3, HB4, HFI, and HF2. Stream determinations have been verified by NCDWR
staff during a site visit on April 8, 2015 (Appendix B).
The Parcel is being proposed to restore, enhance, and preserve stream systems with their adjacent
riparian buffers and their functions and values to compensate in appropriate circumstances for
unavoidable stream and riparian buffer impacts and nutrient load reduction requirements. The
buffer mitigation plan proposed on this Bank is being submitted for review under the
Consolidated Buffer Mitigation Rule 15A NCAC 02B .0295, as well as conditions specified in the
Hannah Bridge Riparian Buffer and Nutrient Offset Mitigation Banking Instrument.
2 PROJECT AREA — EXISTING CONDITIONS
2.1 Physiography
The Parcel is in the Coastal Plain Physiographic Province. Soils in the Coastal Plain region formed in
sediment deposits several millions of years ago by the ocean and streams; however, the floodplains
along the Neuse River consist of fairly recent deposits. These deposits are not as weathered as the
sediments in the Coastal Plain region. The site is located on the Hannah Creek floodplain and has a
gently rolling topography (Figure 2). Five unnamed tributaries on The Hannah Bridge Bank Parcel as
well as overland flow of stormwater drain into Hannah Creek just downstream of the Parcel. Natural
drainage patterns throughout the watershed have been altered by cultivation and dredging of the
channels. Within the proposed mitigation area, the channels drain surface water and groundwater from
the surrounding agricultural practices.
2.2 Soils
The Site is located in the Coastal Plain Physiographic Province. The soils within the Coastal Plain region
of Johnston County formed in sediments deposited several million years ago by the oceans and streams.
The flood plains along the Neuse River consist of relatively recent deposits of sediments that are not as
highly weathered as sediments in the Coastal Plain Region. Much of the county is well drained;
however, several areas are poorly drained.
The Johnston County Soil Survey shows several mapping units across the site. Map units include seven
soil series (Figure 5). The soil series found on the site are described below and summarized in Table 1.
Goldsboro sandy loam. This is a very deep, moderately drained soil found on uplands of the Coastal
Plain. Soils formed in fluviomarine deposits, and generally occur on slopes between 0-10%. Runoff is
negligible to medium and permeability is moderate. Major uses are cropland. Goldsboro sandy loams
occur along the stream near the middle of the proposed conservation easement.
Lynchburg sandy loam. This is a very deep, somewhat poorly drained soil that occurs on terraces and
flats of the Coastal Plain. They formed in fluviomarine deposits, and generally occur on slopes between
0-5%. Runoff is negligible and permeability is moderate. Major uses are cropland, pasture, and forest.
Lynchburg sandy loam occurs along the stream near the middle of the easement almost opposite of the
Goldsboro sandy loam.
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Bibb sandy loam. This is a very deep, poorly drained soil found on flood plains of the Coastal Plain.
Slopes are generally less than 2%. Soils formed in stratified sandy alluvium and have very slow runoff
with moderate permeability. The water table is generally within 8 inches of the surface for 6 to 11
months of the year. Bibb sandy loams occurs along the majority of the easement around the stream.
Gilead sandy loam. This is a very deep, moderate to well drained soil that occurs on ridges and terraces
of the Coastal Plain. They formed in clayey marine deposits, and generally occur on slopes between 2-8
%. Runoff is medium and permeability is moderate. Major uses are cropland. Gilead sandy loam
occurs within the South most wetland and southern end of the tributary inside of the proposed
conservation easement.
Rains sandy loam. This is a very deep, poorly drained soil that occurs on crests of the Coastal Plain.
They formed in Loamy and sandy marine deposits, and generally occur on slopes between 2-6 %.
Runoff is low and permeability is moderate. Major uses are cropland. Rains sandy loam occurs within
the North most wetland inside of the proposed conservation easement.
Uchee loamy course sand. This is a very deep, well -drained soil that occurs on flats and depressions of
the Coastal Plain. They formed in fluviomarine deposits, and generally occur on slopes between 0-2 %.
Runoff is negligible and permeability is moderate. Major uses are forest and cropland. Uchee loamy
sand occurs within the south wetland inside of the proposed conservation easement.
Altavista fine sandy loam. This is a very deep, moderately to well -drained soil that occurs on stream
terraces of the Coastal Plain. They formed in old loamy alluvium derived from igneous and
metamorphic rock, and generally occur on slopes between 0-3 %. Runoff is negligible and permeability
is moderate. Major uses are cropland. Altavista fine sandy loam occurs along the east boundary of the
proposed easement in wetland/stream area.
Table 1. Parcel Mapped Soil Series
Map
Unit
Map Unit Name
Percent
Drainage
Hydrologic
Landscape
Symbol
Hydric
Class
Soil Group
Setting
GoA
Goldsboro sandy
2 �0 °
Moderately
B
Flats, Marine
loam, 0 — 2% slopes
well
Terraces
Ly
Lynchburg sandy loam
6%
Somewhat
C
Flats, Marine
poorly
Terraces
Bb
Bibb sandy loam,
90%
Poorly
D
Floodplains
frequently flooded
Ra
Rains sandy loam
90%
Poorly
B/D
Flats, Marine
Terraces
Broad interstream
UcB
Uchee loamy coarse
0%
Well
C
divides on marine
sand
terraces, ridges on
marine terraces
GeB
Gilead sandy loam
0%
Moderate/Well
C
Marine terraces
AaA
Altavista fine sandy
9%
Moderate/Well
C
Stream Terraces
loam
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2.3 Vegetation
Current land use in the vicinity of the project is primarily agriculture and forest. Common species
include red maple (Acer rubrum), tulip poplar (Liriodendron tulipifera), sweetgum (Liquidambar
styraciflua), and swamp tupelo (Nyssa biflora). Invasive species are widespread throughout the majority
of the project area, most notably Chinese privet (Ligustrum sinense) and multiflora rose (Rosa
multiflora).
Riparian Restoration
Vegetation along the top of Reach HBI is active cattle pasture with pockets of common rush (Juncus
effusus) throughout the hydric areas. The left banks of HB3 and HB4 are also active cow pasture with
common rush and other disturbed herbaceous vegetation. There is no tree or sapling stratum in these
areas. Reaches TH1, TH2, and TH3 are also active pasture, but have sparse tree cover. Reaches HB2
and HF1 are characterized as bottomland hardwood forests, that vary from functional to disturbed based
on the degree of cattle access. Cattle do not have access to the streams from the southern parcels,
therefore the riparian buffer along the right bank of HB2 and the entirety of Reach HF 1 is in much better
condition with a full tree canopy. The confluence of 11134 and Hannah Creek at the downstream end of
the project is a cypress -gum swamp community with a fully developed canopy, but lower stem density
than seen in the other wooded reaches of the project. This area is dominated by swamp tupelo and bald
cypress (Taxodium distichum). Japanese stiltgrass (Microstegium vimineum) is very common throughout
the understory. Detailed observations of vegetation species, soils, and hydrology were recorded in each
community type.
2.4 Wetlands
The USFWS National Wetland Inventory Map (NWI) depicts three wetland areas within the site (Figure
3). A Freshwater Pond (PUBHh) is mapped within the mid -western part of the easement, a Freshwater
Forested/Shrub Wetland (PFO1 C) runs along HB4 in the northeastern part of the easement, and a
Palustrine, Forested, Broad -Leaved Deciduous Wetland (PFO IF) is located in the eastside of the
northern most portion of the easement.
A wetland delineation was performed in May 2016. Wetland boundaries were delineated using current
methodology outlined in the 1987 U.S. Army Corps of Engineers Wetland Delineation Manual (DOA
1987) and Regional Supplement to the U.S. Army Corps of Engineers Wetland Delineation Manual:
Atlantic and Gulf Coastal Plain Region (Version 2.0) (U.S. Army Corps of Engineers 2010). Soils were
characterized and classified using the Field Indicators of Hydric Soils in the United States, Version 7.0
(USDA-NRCS 2010). Wetland boundaries were marked with sequentially numbered wetland survey
tape (pink/black striped). The jurisdictional wetland boundaries are depicted on Figure 7.
Jurisdictional wetlands are present throughout the site. The wetlands are divided between heavily
disturbed and functional. The wetland mitigation treatment will include planting pastures as forested
wetlands, excluding livestock, and hydrologic uplift from grading out small ditches/swales and the
adjacent stream restoration. A notification of jurisdictional determination was received on USACE on
August 12, 2016.
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2.5 Threatened and Endangered Species
The US Fish and Wildlife Service (USFWS) database lists four endangered species for Johnston County,
North Carolina: red -cockaded woodpecker (Picoides borealis), Tar River spinymussel (Eliptio
steinstansana), dwarf wedgemussel (Alasmidonta heterodon), and Michaux's sumac (Rhus michauxii).
No protected species or potential habitat for protected species was observed during preliminary site
evaluations. RES submitted a request to USFWS for review and comments on the proposed Hannah
Bridge Mitigation Project on April 8, 2016 in regards to any potential impacts to threatened and
endangered species. A response from the USFWS received on May 5, 2016 stated that "the proposed
project is not likely to adversely affect and federally -listed endangered or threatened species, their
formally designated critical habitat, or species currently proposed for listing under the Act."
Documentation is included in Appendix B.
Table 2. Federally Protected Species in Johnston County
Common Name
Scientific name
Federal
Status
Habitat
Present
Record
Status
Vertebrate:
Red -cockaded woodpecker
Picoides borealis
E
No
Current
Bald eagle
Haliaeetus leucoce halus
BGPA
Yes
Current
Invertebrate•
Tar Rivers in mussel
Eli do steinstansana
E
No
Current
Dwarf wed emussel
Alasmidonta heterodon
E
No
Current
Vascular Plant:
Michaux's Sumac Rhus Michauxii E No Current
E = Endangered; BGPA = Bald and Golden Eagle Protection Act
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2.6 Environmental and Cultural Constraints
A review of the North Carolina State Historic Preservation Office GIS Web Service database revealed
that there are National Registered listings within a one -mile radius of the proposed project area. No
architectural structures or archeological artifacts have been observed or noted during preliminary
surveys of the site for restoration purposes. RES submitted a request to the NC State Historic
Preservation Office (SHPO) to search records to determine the presence of any areas of architectural,
historic, or archaeological significance that may be affected by the Hannah Bridge Mitigation Site on
April 8, 2016. In a letter dated April 4, 2016 the SHPO stated that they had "conducted a review of the
project and are aware of no historic resources which would be affected by the project." Correspondence
is provided in Appendix B.
2.7 FEMA Floodplain/Floodway Mapping
Reaches HB3 and HB4 are located within the FEMA 100 -year floodplain (Zone AE) of Hannah Creek,
and approximately 200 feet of the downstream end of Reach HB4 is located within the FEMA floodway.
However, no grading or construction activities are proposed along the portions of the project located
within the FEMA floodway. Therefore, it is not anticipated that a No -rise or CLOMR will be required
for the project. Hydrologic trespass is a not a concern for this project. While designing the Hannah
Bridge project, appropriate measures were taken to eliminate hydrologic trespass of the adjacent
agricultural fields and animal operations. The adjacent land use will not be affected by the proposed
design, and no detrimental impacts are expected beyond the easement limits.
3 RESTORATION PLAN
3.1 Riparian Restoration Activities
Riparian restoration adjacent to streams HBI, HB2, HB3, HB4, HFI, HF2, and TH3 shown in Figures 7
and 8, was approved by the DWR letter dated June 11, 2015 and attached in Appendix B. The
restoration of plant communities within the Parcel will not only provide stabilization and improve water
quality within the easement limits, but also provide ecological benefits to the entire watershed.
Vegetation within riparian buffers can vary depending on disturbance regime and adjacent community
types, so the protected buffer easement will be planted with appropriate native species observed in the
surrounding forest and species known to occur in similar environments. All riparian restoration activities
will commence in concurrence with the stream mitigation activities and not before. Therefore, the
mitigation area where riparian restoration is being performed may be altered slightly depending on the
approval of the Stream Mitigation Plan for the Stream Mitigation Bank. The riparian restoration areas
will be surveyed and information provided in the As -Built report.
The current land use adjacent to the majority of the streams on the Bank Parcel is pasture. Livestock will
be excluded from restoration areas by fencing installed to NRCS specifications. The Neuse buffer areas
will be planted from top of bank back at least 50' from the stream with bare root tree seedlings on an 8
by 8 foot spacing to achieve an initial density of 680 trees per acre. The buffered channels will provide
water quality and habitat functions within the sensitive Neuse River watershed. Some areas adjacent to
the forested areas may require maintenance due to the rapid regeneration of some species. Rapidly
regenerating species and invasive species may develop greater individual species density and create a
less diverse mix. Minimal maintenance is anticipated due to the past cultivation history.
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3.2 Planting Plan
Revegetation of the site will include treating invasive species growth and planting at least four native
hardwood bare root trees planted at a density to ensure 260 stems per acre at the completion of
monitoring. No one tree species will e greater than 50% of the established stems. Coastal Plain Small
Stream Swamp will be the target community type and will be used for all areas within the project. The
community is defined by Schafale and Weakely (1990). The initial planting of bare root trees will occur
in Spring 2018 or during stream restoration work (whichever comes last). Tree species specified for
planting on the Hannah Bridge Site are shown in Table 3.
Table 3. Hannah Bridge Site Tree Planting List
Common Name
Scientific Name
Indicator
Growth Rate
River Birch
Betula nigra
FACW
rapid
Willow Oak
Quercus phellos
FACW
rapid
Swamp Chestnut Oak
Quercus michauxii
FACW
moderate
Water Oak
Quercus nigra
FAC
rapid
American Sycamore
Platanus occidentalis
FACW
rapid
Swamp Tupelo
N ssa bi ora
OBL
moderate
Overcup Oak
Quercus l rata
OBL
moderate
Bald Cypress
Taxodium distichum
OBL
rapid
3.3 Easement Boundaries and Fencing
Easement boundaries will be identified in the field to ensure clear distinction between the Parcel and
adjacent properties. Boundaries may be identified by cattle fence, marker, bollard, post, tree -blazing, or
other means as allowed by site conditions and/or conservation easement. Boundary markers disturbed,
damaged, or destroyed will be repaired and/or replaced on an as needed basis. 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 to NC DWR.
4 MONITORING AND MAINTENANCE PLAN
4.1 Monitoring Protocol and Success Criteria
Riparian buffer vegetation monitoring will be based on the CVS-EEP Protocol for Recording
Vegetation Level 1-2 Plot Sampling Only Version 4.0. Annual vegetation monitoring will occur each
year during the fall season with the first year occurring at least 5 months from initial planting. As part of
the stream mitigation plan, twenty-five (25) vegetation monitoring plots will be installed a minimum of
100 mZ in size, and will cover at least two percent of the planted mitigation area. Eight (8) of these plots
will be located in buffer/nutrient offset areas. The following data will be recorded for all trees in the
plots: species, height, planting date (or volunteer), and grid location. The measures of vegetative success
for the Parcel will be the survival of at least 4 native hardwood tree species, where no one species is
greater than 50% of the established stems, established at a density of at least 260 planted trees per acre at
the end of Year 5. Native volunteer species may be included to meet the performance standards. Invasive
and noxious species will be monitored and treated so that none become dominant or alter the desired
community structure of the site. Initial plant maintenance may include a one-time mowing, prior to
initial planting to remove undesirable species. If mowing is deemed necessary by EBX during the
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monitoring period, EBX must receive approval by the DWR prior to any mowing activities to ensure that
no buffer violations have been performed. Failure to receive approval to mow within the Neuse buffer,
as defined in 15A NCAC 02B .0233, by the DWR could result in Neuse buffer violations and violations
of the conservation easement. If necessary, EBX will develop a species-specific treatment plan.
4.2 Adaptive Management Plan
In the event that the site, or a specific component of the site, fails to achieve the defined success criteria,
RES will develop necessary adaptive management plans and/or implement appropriate remedial actions
for the site in coordination with the NC DWR. Remedial actions will be designed to achieve the success
criteria specified previously, and will include identification of the causes of failure, remedial design
approach, work schedule, and monitoring criteria that will take into account physical and climatic
conditions.
4.3 Long Term Management Plan
EBX Neuse I, LLC, (EBX) acting as the Bank Sponsor, will record a Conservation Easement with the
Johnston County Register of Deeds Office. EBX will monitor the Site for a minimum of five years, or
until NC DWR approval. Riparian restoration outside of the mitigation area for buffer and nutrient offset
credits will be monitored in accordance with the monitoring protocol in the Selma Stream Mitigation
Plan. This BPDP provides detailed information regarding bank operation, including long term
management and annual monitoring activities, for review and approval by the NC DWR. The
Conservation Easement has been assigned to The North Carolina Wildlife Habitat Foundation
(NCWHF). All monitoring activities, including periodic inspections of the site to ensure restrictions
required in the Conservation Easement are upheld, are the responsibility of EBX until the Parcel is
transferred to the NCWHF. Endowment funds required to uphold the Hannah Bridge Bank Parcel
easement in perpetuity shall be negotiated prior to site transfer to the NCWHF.
The Bank Sponsor has ensured that the Conservation Easement allows for the implementation of an
initial monitoring phase, which will be developed during the design phase and conducted by the Bank
Sponsor. The Conservation Easement will allow for yearly monitoring and, if necessary, maintenance of
the Site during the initial monitoring phase. These activities will be conducted in accordance with the
terms and conditions of the Hannah Bridge Riparian Buffer and Nutrient Offset Mitigation Banking
Instrument made and entered into by EBX-Neuse I, LLC and NC DWR.
5 FINANCIAL ASSURANCE
The Sponsor will provide financial assurances in the form of Performance Bonds sufficient to assure
one -hundred percent (100%) completion of all mitigation work, required reporting and monitoring, and
any remedial work required. Financial assurances will be payable at the direction of the NC DWR to its
designee or to a standby trust. Financial assurances structured to provide funds to the NC DWR in the
event of default by the Bank Sponsor are not acceptable. The initial performance bond will be in the
amount of at least $150,000 and shall be able to cover 100% of the costs associated with construction of
the riparian restoration areas. The monitoring bond shall be in the amount of at least $100,000 and shall
be able to cover 100% of the costs associated with the monitoring and maintenance of the riparian
restoration areas for five years.
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6 MITIGATION POTENTIAL
The Hannah Bridge Site presents 46.2 acres of permanent conservation easement in Johnston County,
North Carolina. While this easement also encompasses areas for the Hannah Bridge Stream Mitigation
Bank, the purpose of the Hannah Bridge Riparian Buffer and Nutrient Offset Mitigation Bank is to
generate Neuse riparian buffer mitigation and nutrient offset. Once finalized, a conservation easement
and final recorded plat will be provided in Appendix C.
The width of the buffer/nutrient credit generation area will begin at the most landward limit of the top of
bank or the rooted herbaceous vegetation and extend landward to a maximum distance of 200 feet.
These rules are in accordance with Rule 15A NCAC 02B.0295; buffer preservation credits meet the
requirements described in Paragraph (m) subparagraph (2) (D) - Alternative Buffer Mitigation Options -
Preservation of Buffers on Subject Streams. According to the MBI, the generated nitrogen offset credit
per acre in the Neuse River watershed is 2,273.02 pounds per acre.
This Parcel has the potential to generate approximately 5.09 acres of riparian buffer restoration credits,
0.48 acres of riparian buffer enhancement credits, 1.85 acres of riparian buffer preservation credits, and
4.25 acres of nutrient offset credits. The riparian buffer mitigation credits generated will service Neuse
Buffer impacts within the USGS 8 -digit HUC 03020201 of the Neuse River Basin. The Nitrogen
nutrient offsets generated will service nutrient load reduction requirements where payments are
authorized in 15A NCAC 02B .0240 within the USGS 8 -digit HUC 03020201, excluding the Falls Lake
Watershed. The total potential mitigation credits that the Hannah Bridge Bank will generate are
summarized in Table 4; Figure 8.
Table 4. Proposed Mitigation Credits
Buffer Credit
Zone
Credit Type
Acreage
Credit Per Acre (sq ft)
Ratio
Mitigation Assets (sq ft)
Buffer Restoration
5.09
43,560
1:1
221,720
0-100'
Buffer
Enhancement
0.24
43,560
2:1
5,227
Buffer Preservation
1.46
43,560
10:1
61360
Buffer Restoration
N/A
N/A
N/A
N/A
101-
200'
Buffer
Enhancement
0.24
43,560
6:1
1 742
'
Buffer Preservation
0.39
43,560
30:1
566
TOTAL
1 7.42
1
1
1 235,616
Nutrient Credit
Zone
Credit Type
Acreage
Credit Per Acre (lbs)
Ratio
Mitigation Assests (lbs)
0-100'
Nitrogen
1.06
2,273.02
N/A
2,409.40
101-
200'
Nitrogen
3.19
2,273.02
N/A
7,250.93
TOTAL
4.25
9,660.34
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The Sponsor may use the 5.09 acres (221,720.00 ft) of riparian restoration areas for either Neuse buffer
credits or Nitrogen nutrient offset credits, but not both. The Sponsor must submit a written request and
receive written approval from DWR prior to any credit conversions and transfers to the buffer and
nutrient offset 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.
Available wetland mitigation credits (credits that have been released by the ACOE but not sold by the
Sponsor) that are generated from restoration, or enhancement within the riparian areas (top of bank —
200') adjacent to the streams on this Bank Parcel, and comply with 15A NCAC 02B .0295, may be
converted and transferred from wetland mitigation credits to Riparian Buffer Credits upon written
approval from the DWR.
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7 REFERENCES
NCDENR. 2009. "Neuse River Basinwide Water Quality Plan." Division of Water Quality. http://
http://portal.ncdenr.org/web/wq/psibpu/basin/neuse/2009. (October 2013).
NCDENR. 2010. "N.C. Wetland Assessment Method User Manual Version 4.1." N.C. Wetland
Functional Assessment Team.
NC Environmental Management Commission. 2014. Rule 15A NCAC 02B.0295 - Mitigation Program
Requirements for the Protection and Maintenance of Riparian Buffers.
Schafale, M.P. and A.S. Weakley. 1990. Classification of the Natural Communities of North Carolina,
Third Approximation. North Carolina Natural Heritage Program, Division of Parks and Recreation,
NCDENR, Raleigh, NC.
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Buffer/Nutrient Offset Site 13 May 2017

Appendix A. Supporting Figures
Figure 1. Project Vicinity Map
Figure 2. USGS Topographic Map
Figure 3. National Wetlands Inventory Map
Figure 4. Historical Aerial Photography
Figure 5. Soils Map
Figure 6. FEMA Map
Figure 7. Existing Conditions Map
Figure 8. Conceptual Design Plan
Figure 9. Service Area Map

4`byargn� �
d a
Smithfield
Marko
a ter, a
patkrng planlRd
�rABdel ad
Elevation Rd
Hannah Bridge Mitigation Site -P,,�
FO)r Oaks Latitude: 35.380621'N '
r Longitude: -78.417107°W
a
K
301,
�j�
[501
�Y
�I
i
�I
Aga �
',7u1; r+a'va
` F
ll �
Le
pend Q ��
Hannah Bridge Mitigation Site
50
TLW 03020201150020
FIGURE 1
wE
Project Vicinity Map
Hannah Bridge Mitigation Site
0 1 2
Johnston County, North Carolina Miles

f / -•=b -��` �---:1-. 4�_ � –i r �-^-ice � �' l � � ��Ci2�cam
■
O-
l s •�
tb dip
MA
IN
ham
Proposed Easement- 46.2 c
Target Parcels
FIGURE 2
USGS
f
.�
��� �✓`` /�' � r .tip' 1i`!'l./�/.caZis _ �. }��il��v'# !`l
— -----tin sa c+�uroa.�s���r�issnr�r .. �� JiYJ�� • • o ® G o � - o o .. o� - o - .
. -
Topographic
.. i
1,000 2,000 Hannah BridgeMitigation

N FIGURE 4
Legend Historical Aerial Photography
Hannah Bridge Mitigation Site
u Proposed Easement W E o 500 1,000
Feet
S 1 in. = 1000 ft.
fires

Legend
Proposed Easement
Non -hydric Soils
Soils with Hydric Inclusions
Hydric Soils
Ra
10f, AVE.
TO
?� vr,
kr
IF
p .2 *r t
Bb
AaA
i
>►` AlUC"
LYV d
S
GoA
f y",
16. Ly
Bb UcB r
UC
z
i
Symbol j Name I Symbol I Name
AaA Altavista fine sandy loam Ly Lynchburg sandy loam
Bb Bibb sandy loam Ra Rains sandy loam
GeB Gilead sandy loam UcB Uchee loamy coarse sand
GoA Goldsboro sandy loam
FIGURE 5
E Soils Map
0 300 600 Hannah Bridge Mitigation Site
Feet
Johnston County, North Carolina
Ly
r'- AaA rte- +�
Date: 5/24/2017
Drawn by: RTM
Checked by: BPB Ores

Icetaille
hleha
Hillsborough
chapel
Hill
Pitisboro
M
BuhM
cfeE'dT@aIX
a
Lm
r
40POJ
500
OF
OF
OAF
Lm
walker r: 1.11
azi
Le end c oll t
QBuffer Service Area- HUC 03020201
® Nutrient Service Area- HUC 03020201 excluding Falls Lake Watershed es: Esri, HERE, DeLorme, USGS, Intermap, INCREMENT P, NRCan, Esri
METI, Esri China (Hong Kong), Esri Ko ea, Esri (Thailand), Mapmylndia,
© OpenStreetMap contributors, and the GIS User Community
i
Figure 9.
Service Area Map
Hannah Bridge Mitigation Site
0 5 10 res
Miles
1 inch = 10 miles
r
40POJ
OF
OAF
walker r: 1.11
azi
Le end c oll t
QBuffer Service Area- HUC 03020201
® Nutrient Service Area- HUC 03020201 excluding Falls Lake Watershed es: Esri, HERE, DeLorme, USGS, Intermap, INCREMENT P, NRCan, Esri
METI, Esri China (Hong Kong), Esri Ko ea, Esri (Thailand), Mapmylndia,
© OpenStreetMap contributors, and the GIS User Community
i
Figure 9.
Service Area Map
Hannah Bridge Mitigation Site
0 5 10 res
Miles
1 inch = 10 miles

Appendix B. Correspondence

NCDENR
North Carolina [department of Environment and Natural Resources
Pat McCrory
Governor
April 24, 2015
EBX NEUSE 1 LLC
Daniel Ingram EBX (RES)
909 Capability Dr. Suite 3100
Raleigh, NC 27606
Donald R. van der Vaart
Secretary
Subject: Buffer Determination
NBRRO>r 15-144
Wake County
Determination Type:
Buffer Call
Isolated or EIP Call
Neuse (15A NCAC 213 .0233)
Start@
Stop@,
71❑ Ephemeralllntermi#terstlPerennial Determination
Tar -Pamlico (15A NCAC 26 .0259)
❑ Jordan (15A NCAC 2B
❑ Isolated Wetland Determination
.0267)
�JI
Project Name: Thomp[on Mitigation Bank
Location/Directions: Property is located at Green Pastures Rd. Johnston County, NC
Subject Stream: Hannah Creek
Determination Date: April 16, 2015
Staff: James Graham
Feature
Not
Subject
E/UP*
Start@
Stop@,
Soil
USGS
/Flag
Subject
To Buffers
Survey
Topo
To Buffers
A UT2
X
P
X
X
Reaches
A -C, F,
H
M UT2
X
P
X
X
Reach B
N UT2
X
Ditch
Reach E
N UT2
X
Ditch
Reach D
N UT2
X
Ditch
Reach G
UTl
X
Ditch--
Reacts A
UTI
X
Ditch
Reach B
One
- JViitura!!r�
North Carolina Division of Water Resources 1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone]
Internet: www.ncwatergualit)+,arg Location: 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper

Thompson Mitigation Bank
Wake County
April 24, 2015
Page 2 of 2
K
X
X
(Hannah
Wetland"
Creek)
(Riverine
Swamp
Forest)
L UT l
X
I
X
Reach C
J
X
Wetland**
X
X
Pond 1
X
X
Pond 2
X
X
Pond 3
X
*E/l/P - Ephemeral/Intermittent/Perennial
* *Feature J and K are wetlands Wetlands are subject to 404 permitting. Impacting a wetland by filling, dredging,
and/or draining can result in a Wetlands Standard Violation (15A NCAC 02.B 0231 (a), 15A NCAC 02B. 0231 (b).
Please contact US Army Corps. of Engineers for permitting information if needed.
Explanation: The feature(s) listed above has or have been located on the Soil Survey of Wake County, North
Carolina or the most recent copy of the USGS Topographic map at a 1:24,000 scale. Each feature that is checked
"Not Subject" has been determined not to be a stream or is not present on the properly. Features that are checked
"Subject" have been located on the property and possess characteristics that qualify it to be a stream. There may be
other streams located on your property that do not show up on the maps referenced above but, still may be
considered jurisdictional according to the US Army Corps of Engineers and/or to the Division of Water Resources
(DWR).
This on-site determination shall expire five (5) years from the date of this letter. Landowners or affected p&rties that
dispute a determination made by the DWR or Delegated Local Authority may request a determination by the
Director. An appeal request must be made within sixty (60) days of date of this ietter or from the date the affected
party (including downstream and/or adjacent owners) is notified of this letter. A request for a determination by the
Director shall be referred to the Director in writing. If sending via US Postal Service c/o Karen Higgins DWR — 401 &
Buffer Permitting Unit 1617 Mail Service Center Raleigh, NC 27699-1617. If sending via delivery service (TIPS, FedEx,
etc.) Karen Higgins DWR -- 401 & Buffer Permitting Unit 512 N. Salisbury Street Raleigh, NC 2760.
This determination is final and binding unless, as detailed above, you ask for a hearing or appeal within sixty (60)
days.
The owner/future owners should notify the Division of Water Resources (including any other Local, State, and
Federal Agencies) of this decision concerning any future correspondences regarding the subject property (stated
above). This project may require a Section 404/401 Permit for the proposed activity. Any inquiries should be
directed to the Division of Water Resources (Central Office) at (919)-807-6300, and the US Army Corp of Engineers
(Raleigh Regulatory Field Office) at (919)-554-4884.
If you have questions regarding this determination, please feel free to contact James Grab t [phone].
tRespec fully,
S1
Su r isor
y S th, pe v
Water Quality Section
Raleigh Regional Office
cc: RRO/SWP File Copy

r—M
UT1 Reach A, B Ditch
Not Subject to buffers
Pond 3
Not Subject to buffers
Feature J Wetland
Not Subject to buffers
, MEEMMML.
Feature L UTI Reach C
Intermittent
Not Subject to buffers
L�b
4iIS
lAO
Feature K Wetland Not Subject
to buffers (Riverine Swamp Forest)
w.►A
Pond 2
Not Subject to buffers
Feature A UT2 Reach A Perennial ;,J
Subject to buffers
0
Feature A UT2 Reach H'Perennial
Feature A UT2 Reach F Perennial Subject to buffers
Subject to buffers r
1 < i
Feature N UT2 Reach E,D,G Ditch
Not Subject to buffers
Feature A UT 2 Reach C Perennial
Subject to buffers
Feature M UT2 Reach B Perennial „
Subject to buffers
+■mow -
Gen _
j JRG 4/16/2015 15-144
:...
� f

Pond 3
Not Subject to buffers
l
Wetland
Feature J Wetland
Not Subject
buffers
to buffers
Pond 2
Not Subject to buffe
Pond 1
Not Subject to buffers
�UT 11
WI --LL III A
Rv -ac Im 6
0 312.5 625
m
WOMMML
rJJRG 4/.6/2015 15-14471
-V
1 250 1,8 `5
r
'A
7,600
Foot
Pond 2
Not Subject to buffe
-V
1 250 1,8 `5
r
'A
7,600
Foot

Pond 2
Not Subject to buffers
W—wk-4A,
__
Feature J Wetland
Not Subject to buffers
Pond 1
Not Subject to buffers
Feature A Perennial ;
Subject to buffers
Feature K Wetland Not Subject
to buffers
11
OftwCATil,
Feature A Perennial
Subject to buffers
JRG 4/16/2015 15-144
�r
Feature M UIT2 Reach B Perennial
Subject to buffers
W=mv W..—M A W,

A`4i`?AwA
NCDENR
North Carolina department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
June 11, 2015
Daniel Ingram
EBX Neuse I, LLC
909 Capability Drive, Suite 3100
Raleigh, NC 27606
(via electronic mail)
Re: Site Viability for Buffer Mitigation & Nutrient Offset--Thompson/Hannah Bridge Mitigation Site
Green Pastures Road near Hwy 96, Dunn, NC
Johnston County
Dear Mr. Ingram,
On April 8, 2015, Katie Merritt, with the Division of Water Resources (DWR), received a request from EBX
Neuse i, LLC (EBX) an affiliate of Resource Environmental Solutions (RES) for a site visit near the above -
referenced site to determine the potential for nutrient offset and Neuse riparian buffer mitigation. On April
16, 2015, Ms. Merritt performed a site assessment of the subject site, which is more accurately described in
the attached aerial map. If approved, mitigating this property could provide riparian buffer credits and/or
nutrient offset credits within the Neuse River Basin, 8 -digit Hydrologic Unit Code 03020201, with the
exception of the Falls Lake Watershed. The viability of this site for nutrient offset and riparian buffer
mitigation is determined based on the Umbrella Mitigation Banking Instrument signed by EBX and the DWR
on November 10, 2008. If EBX chooses to apply 15A NCAC 02B .0295 (Rule .0295) towards its buffer
mitigation, EBX will have to submit a Mitigation Banking Instrument (MBI) specific for this site.. The existing
Neuse Umbrella Mitigation Banking Instrument is not compatible for use of the temporary Rule .0295 for
buffer mitigation.
Ms. Merritt's evaluation of the property for buffer and nutrient offset mitigation is shown below:
Thompson Property
• A stream buffer determination letter was issued for the subject site by the DWR Raleigh Regional
Office on April 24, 2015.
• Streams and conveyances onsite drain offsite into Hannah Creek, a Riverine Swamp Forest.
• Land use adjacent to the streams and conveyances is described as grazed pasture from livestock.
Exclusion of cattle is required within the entire mitigation area.
• Features determined to be viable for generating nutrient offset credits were determined onsite to
be directly hydrologically connected to intermittent or perennial streams.
• Some streams determined to be viable for generating buffer credits were partially dependent on
the stream being restored through stream mitigation.
Division of Water Resources - 401 and Buffer Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterquality.org
An Equal Opportunity l Affirmative Action Employer — Made in part by recycled paper

• Buffer mitigation and nutrient offset cannot be proposed within the same square feet.
• The following table describes where nutrient offset and riparian buffer mitigation is viable for
generating mitigation credits:
Feature/
Reach
Classification
Buffer
Credit
Viability
Nutrient Offset
Viability at 2,273
lbs/acre
Type of Mitigation
Aa
Stream (P)
Yes
Yes
Restoration
Ac
Stream (P)
Yes
No
Preservation
Af
Stream (P)
Yes
Yes
Restoration, Enhancement
J
Wetland
No
No
N/A
La
Ditch
No
Yes
Restoration, Enhancement
Lb
Ditch
No
Yes
Restoration
Lc
Stream (1)
Yes
Yes
Restoration
Mb
Stream (P)
Yes
Yes
Restoration
Ne
Ditch
No
Yes
Restoration
Ng
Ditch
No
No
Not within mitigation area
No
Ditch
No
Yes
Enhancement in some areas
P1
Pond (not in-line)
No
No
N/A
P2
Pond (not in-line)
No
No
N/A
P3
Pond (not in-line)
No
No
N/A
Hannah
Creek
Riverine Swamp
No
Yes
Restoration
A map showing the project site and the features is provided and signed by Ms. Merritt on lune 11, 2015.
For any areas depicted as not being viable for nutrient offset credit above, EBX could propose a different
measure, along with supporting calculations and sufficient detail to support estimates of load reduction, for
review by the DWR to determine viability for nutrient offset according to 15A NCAC 02B .0240. Alternative
buffer mitigation options, such as Preservation, may be proposed under 15A NCAC 02B .0295 (m).
Please contact Katie Merritt at (919)-807-6371 if you have any questions regarding this correspondence.
Sincerely,
Karen Higgins, Supervisor
401 and Buffer Permitting Unit
KAH/km
Attachments: Site Map
cc:File Copy (Katie Merritt)

1 F
Lt'u rer RoourCes
UN NIOM,.MMLN.rAL ptJr W?y
May 23, 2017
Brad Breslow
Resource Environmental Solutions, LLC
302 Jefferson St.. Suite 110
Raleigh, NC 27605
(via electronic mail)
ROY COOPER
MIC'HAf_1_ S, RE"GAN
S. JAY ZIMN411RNIAN
Re: Site Viability for Buffer Mitigation & Nutrient Offset — Hannah Bridge Mitigation Site (HF2)
Green Pastures Rd near Hwy 96, Dunn, NC
Johnston County
Dear Mr. Breslow,
On May 15, 2017, Katie Merritt, with the Division of Wafter Resources (DWR), received a request
from Resource Environmental Solutions, LLC (RES) for a site visit near the above -referenced site in
the 8 -digit Hydrologic Unit Code 03024201 of the Neuse River Basin, outside of the Falls Lake
Watershed. This site visit was to determine the potential for riparian buffer mitigation and nutrient
offset along a feature that was originally not part of the viability assessment performed by DWR on
June 11. 2015. On May 16, 2017, Ms. Merritt performed a site assessment of the subject site, which
is more accurately shown in the attached aerial initialed by Ms. Merritt on May 23, 2017.
Ms. Merritt's evaluation of the feature onsite and its associated mitigation determination for the
riparian areas are provided in the table below. The evaluation was made from Top of Bank (TOB)
out to 200' from the feature for buffer mitigation pursuant to ISA NCAC O2B .0295 (effective
November 1, 2415) and for nutrient offset credits pursuant to 15A NCAC O2B .4240,
Feature
paWfication
'Subject
Riparian Land uses of
Buffer
Nutrient
Mitigation Tyne Determination w/in riparian
Feature
areas
to Buffer
Credit
Offset Viable
Rule*
0-200'
Viable
at 2.273
Its acre
HF2
ditch
No
Left Bank=,previous row
No
Yes
Restoration site per 15A NCAC 0 2 B .0 29 5 (n)
(ends
crop agriculture, early
at woodline)
successional sweet gums,
pines and maples with
invasives.
Right Bank= row crop
agriculture field
'This subjectivity call was determined by DWR using the 1:24,000 scale quadrangle topographic map prepared by USES
and the most recent printed version of the soil survey map prepared by the NRCS.
NC Division of Water Resources - Methodology and Calei,!lations_,Far detennining Nutrient Reductions associated with
Riparian Buffer Establishment
A map showing the project site and feature was provided by RES and was initialed by Ms. Merritt on
May 23, 2017. This letter should be provided in all stream, wetland. and/or buffer mitigation plans
for this Site.
atateafNortliCarolins I EnvironmentalQtrality I waterResourca's
1617 Mail Service Center I Raleigh, North Carolina 27649-1617
919 807 6300

Thompson/ Hannah Bridge Site (HF2)
RES
May 23, 2017
This letter does not constitute an approval of this site to generate mitigation credits. Pursuant to 15A
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.
Pursuant to 15A NCAC 02B .0240, a proposal regarding a proposed nutrient load -reducing measure
shall be submitted to DWR for approval prior to any mitigation activities in riparian areas and/or
surface waters
All vegetative plantings, performance criteria and other mitigation requirements for riparian
restoration, enhancement and preservation must follow the requirements in 15A NCAC 02B .0295 to
be eligible for buffer mitigation credits.
Please contact Katie Merritt at (919)-807-6371 if you have any questions regarding this
correspondence.
KAH/km
Attaclunents: Site Aerial
cc: File Copy (Katie Merritt)
Sincerely,
4
Daren Higgins, Supervisor
401 and Buffer Permitting Branch
h I c 212

btu. STATE ai
North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Pat McCrory
Secretary Susan Kluttz
April 14, 2016
Brad Breslow
RES
302 Jefferson Street, Suite 110
Raleigh, NC 27605
Office of Archives and History
Deputy Secretary Kevin Cherry
Re: Hannah Bridge Stream and Wetland Restoration, Johnston County, ER 16-0636
Dear Mr. Breslow:
Thank you for your letter of April 8, 2016, concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579 or
environmental.reviewgncdcr.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
Ramona M. Bartos
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

From:
Stancil, Vann F
To:
Brad Breslow
Subject:
RE: Hannah Bridge Mitigation Project
Date:
Monday, May 2, 2016 11:44:53 AM
Brad,
I've reviewed your information on the Hannah Bridge Site, located on tributaries to Hannah Creek in
Johnston County. There are no records for sensitive aquatic or terrestrial wildlife resources in the
vicinity of this project. We do not anticipate any issues to fish and wildlife from this project as long
as restoration activities are conducted properly. Thanks for the opportunity to review this and
please let me know if you have any questions or comments.
Vann Stancil // Research Coordinator
Habitat Conservation
NC Wildlife Resources Commission
215 Jerusalem Church Road
Kenly, North Carolina 27542
office: 919-284-5218
fax: [phone]
van n.stancil&ncwildlife.orq
ncwildlife.ora
f : IUVW9
From: Brad Breslow [mailto:[e-mail]]
Sent: Friday, April 08, 2016 1:46 PM
To: Stancil, Vann F <[e-mail]>
Subject: Hannah Bridge Mitigation Project
Mr. Stancil,
The Hannah Bridge Site has been identified by Resource Environmental Solutions, LLC (RES) to
provide compensatory mitigation for unavoidable stream and wetland impacts through the Neu -Con
Umbrella Mitigation Bank. The purpose of this letter is to request review and comment on any
possible issues that might emerge with respect to fish and wildlife associated with a potential stream
restoration project on the attached site (USGS site maps with approximate property lines and areas
of potential ground disturbance are enclosed). We thank you in advance for your timely response
and cooperation. You may return the comment to my attention at the address below. Please feel
free to contact me at bbreslowCcDres.us with any questions that you may have concerning the extent
of site disturbance associated with this project.
Sincerely,

Brad Breslow I Restoration Ecologist I Resource Environmental Solutions, LLC
302 Jefferson Street, Suite 110, Raleigh, NC 27605
Direct: 919.209.1062 1 Cell: 847.774.8404
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
May 5, 2016
Brad Breslow
Resource Environmental Solutions, LLC
302 Jefferson Street, Suite 1 I0
Raleigh, NC 27605
Re: Hannah Bridge Mitigation Project — Johnston County, NC
Dear Mr. Breslow:
This letter is to inform you that a list of all federally -protected endangered and t1ireatened species
with known occurrences in North Carolina is now available on the U.S, Fish and Wildlife
Service's (Service) web page at http://www.fNvs.gov/raleigh. Therefore. if you have prQjects that
occur within the Raleigh Field Office's area of responsibility (see attached county list), you no
longer need to contact the Raleigh Field Office for a list of federally -protected species.
Our web page contains a complete and frequently updated list of all endangered and threatened
species protected by the provisions of the Endangered Species Act of 1973, as amended (16
U_S.C. 1531 et seq.)(Act), and a list of federal species of concern 1 that are known to occur in
each county in North Carolina.
Section 7 of the Act requires that all federal agencies (or their designated non-federal
representative), in consultation with the Service, insure that any action federally authorized,
funded, or carried out by such agencies is not likely to jeopardize the continued existence of any
fe&,ially-listed endangered or threatened species. A biological assessm'e'nt or evaluation may be
prepared to fulfill that requirement and in determining whether- additional consultation with the
Service is necessary. In addition to the federally -protected species list, information on the
species' life histories and habitats and information on completing a Biological assessment or
evaluation and can be found on our web page at littp://www.fws.gov/raleigh. Please check the
Nveb site often for updated information or changes.
r The term "federal species of concern" refers to those species which the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their deli nation does
not necessarily imply that the species will eventually be proposed for listing as a federally endangzrzd or threatened
species. However, we recommend that all practicable measures be taken to avoid or minimize adverse impacts to
federal species of concern.

If your project contains suitable habitat for any of the federally -listed species known to be
present within the county where your project occurs, the proposed action has the potential to
adversely affect those species. As such, we recommend that surveys be conducted to determine
the species' presence or absence within the project area. The use of North Carolina Natural
Heritage program data should not be substituted for actual field surveys.
If you determine that the proposed action may affect (i.e., likely to adversely affect or not likely
to adversely affect) a federally -protected species, you should notify this office with your
determination, the results of your surveys, survey methodologies, and an analysis of the effects
of the action on listed species, including consideration of direct, indirect, and cumulative effects,
before conducting any activities that might affect the species. If you determine that the proposed
action will have no effect (i.e., no beneficial or adverse, direct or indirect effect) on federally
listed species, then you are not required to contact our office for concurrence (unless an
Environmental Impact Statement is prepared). However, you should maintain a complete record
of the assessment, including steps leading to your determination of effect, the qualified personnel
conducting the assessment, habitat conditions, site photographs, and any other related articles.
With regard to the above -referenced project, we offer the following remarks. Our comments are
submitted pursuant to, and in accordance with, provisions of the Endangered Species Act.
Based on the information provided and other information available, it appears that the proposed
action is not likely to adversely affect any federally -listed endangered or threatened species, their
formally designated critical habitat, or species currently proposed for listing under the Act at
these sites. We believe that the requirements of section 7(a)(2) of the Act have been satisfied for
your project. Please remember that obligations under section 7 consultation must be
reconsidered if. (1) new information reveals impacts of this identified action that may affect
listed species or critical habitat in a manner not previously considered; (2) this action is
subsequently modified in a manner that was not considered in this review; or, (3) a new species
is listed or critical habitat determined that may be affected by the identified action.
However, the Service is concerned about the potential impacts the proposed action might have
on aquatic species. Aquatic resources are highly susceptible to sedimentation. Therefore, we
recommend that all practicable measures be taken to avoid adverse impacts to aquatic species,
including implementing directional boring methods and stringent sediment and erosion control
measures. An erosion and sedimentation control plan should be submitted to and approved by
the North Carolina Division of Land Resources, Land Quality Section prior to construction.
Erosion and sedimentation controls should be installed and maintained between the construction
site and any nearby down -gradient surface waters. In addition, we recommend maintaining
natural, vegetated buffers on all streams and creeks adjacent to the project site.
The North Carolina Wildlife Resources Commission has developed a Guidance Memorandum (a
copy can be found on our website at (http://www.fws.gov/raleigh) to address and mitigate
secondary and cumulative impacts to aquatic and terrestrial wildlife resources and water quality_
We recommend that you consider this document in the development of your projects and in
completing an initiationpackage for consultation (if necessary).
1)

We Hope you find our web page useful and informative and that following the process described
above will reduce the time required, and eliminate the need, for general correspondence for
species' lists. If you have any questions or comments, please contact Emily Wells of this office
at [phone] ext. 25.
Sincerely,
Pte Benjamin
Field Supervisor

List of Counties in the Service's Raleigh Field Office Area of Responsibility
Alamance
Beaufort
Bertie
Bladen
Brunswick
Camden
Carteret
Caswell
Chatham
Chowan
Columbus
Craven
Cumberland
Currituck
Dare
Duplin
Durham
Edgecombe
Franklin
Gates
Granville
Greene
Guilford
Halifax
Harnett
Hertford
Hoke
Hyde
Johnston
Jones
Lee
Lenoir
Martin
Montgomery
Moore
Nash
New Hanover
Northampton
Onslow
Orange
Pamlico
Pasquotank
Pender
E
Perquimans
Person
Pitt
Randolph
Richmond
Robeson
Rockingham
Sampson
Scotland
Tyrrell
Vance
Wake
Warren
Washington
Wayne
Wilson

Appendix C. Conservation Easement and Plat
Note: This appendix will be updated as the easement deeds and plats become available.

MODEL CONSERVATION EASEMENT
January 18, 2001
Rev'd October 16, 2002
Rev'd August, 2003
Model Conservation Easement for use in preserving mitigation property. Language in
italics is instructional, and should be deleted when site-specific Conservation Easement
is prepared.
PERMANENT CONSERVATION EASEMENT
THIS CONSERVATION EASEMENT ("Conservation Easement") made this
day of , 200_ by and between
("Grantor") and (Grantee).
The designation Grantor and Grantee as used herein shall include said parties,
their heirs, successors and assigns, and shall include singular, plural, masculine, feminine
or neuter as required by context.
RECITALS
WHEREAS, Grantor owns in fee simple certain real property situated, lying and
being in County, North Carolina, more particularly
described in Exhibit A attached hereto and incorporated herein ("Property");
WHEREAS, Grantee is [either a public body of this state, an agency of the United
States, or a nonprofit corporation or trust whose purpose is the conservation of property],
and is qualified to be the Grantee of a conservation easement pursuant to N.C. Gen. Stat.
§ 121-35;
WHEREAS, Grantor and Grantee recognize the conservation, scenic, natural, or
aesthetic value of the property in its natural state, which includes the following natural
communities: [describe by wetland and/or stream type, as well as any associated buffers
or upland communities]. The purpose of this Conservation Easement is to maintain
wetland and/or riparian resources and other natural values of the Property, and prevent
the use or development of the Property for any purpose or in any manner that would
conflict with the maintenance of the Property in its natural condition.
[ For use when the mitigation is offered for impacts of a single individual or
general permit use] WHEREAS, the preservation of the Property is a condition of
Department of the Army permit Action ID issued by the Wilmington
District Corps of Engineers, required to mitigate for unavoidable stream and/or wetland
impacts authorized by that permit. Grantor and Grantee agree that third -party rights of
enforcement shall be held by the U.S. Army Corps of Engineers, Wilmington District

(Corps, to include any successor agencies), and that these rights are in addition to, and do
not limit, the rights of enforcement under said permit.
[Alternate paragraph for use when the conservation easement supports a
mitigation bank] WHEREAS, the preservation of the Property is required by a Mitigation
Banking Instrument for the [Name of Bank], Department of the Army Action ID [Action
ID number for the mitigation bank]. The Mitigation Bank is intended to be used to
compensate for unavoidable stream and/or wetland impacts authorized by permits issued
by the Department of the Army. Grantor and Grantee agree that third -party rights of
enforcement shall be held by the U.S. Army Corps of Engineers, Wilmington District
(Corps, to include any successor agencies), and that these rights are in addition to, and do
not limit, the rights of the parties to the Mitigation Banking Instrument.
NOW, THEREFORE, for and in consideration of the covenants and
representations contained herein and for other good and valuable consideration, the
receipt and legal sufficiency of which is hereby acknowledged, Grantor hereby
unconditionally and irrevocably grants and conveys unto Grantee, its heirs, successors
and assigns, forever and in perpetuity a Conservation Easement of the nature and
character and to the extent hereinafter set forth, over the Property described on Exhibit A,
together with the right to preserve and protect the conservation values thereof, as follows:
ARTICLE I.
DURATION OF EASEMENT
This Conservation Easement shall be perpetual. This conservation Easement is an
easement in gross, runs with the land and is enforceable by Grantee against Grantor,
Grantor's personal representatives, heirs, successors and assigns, lessees, agents and
licensees.
ARTICLE II.
PROHIBITED AND RESTRICTED ACTIVITIES
Any activity on, or use of, the Property inconsistent with the purpose of this
Conservation Easement is prohibited. The Property shall be preserved in its natural
condition and restricted from any development that would impair or interfere with the
conservation values of the Property.
Without limiting the generality of the foregoing, the following activities and uses
are expressly prohibited, restricted or reserved as indicated hereunder:
A. Disturbance of Natural Features. Any change disturbance, alteration or
impairment of the natural features of the Property or any introduction of non-native
plants and/or animal species is prohibited.
B. Construction. There shall be no constructing or placing of any building,
mobile home, asphalt or concrete pavement, billboard or other advertising display,

antenna, utility pole, tower, conduit, line, pier, landing, dock or any other temporary or
permanent structure or facility on or above the Property.
C. Industrial, Commercial and Residential Use. Industrial, residential and/or
commercial activities, including any right of passage for such purposes are prohibited.
D. Agricultural, Grazing and Horticultural Use. Agricultural, grazing, animal
husbandry, and horticultural use of the Property are prohibited.
E. Vegetation. There shall be no removal, burning, destruction, harming, cutting
or mowing of trees, shrubs, or other vegetation on the Property.
F. Roads and Trails. There shall be no construction of roads, trails or walkways
on the property; nor enlargement or modification to existing roads, trails or walkways.
G. Signage. No signs shall be permitted on or over the Property, except the
posting of no trespassing signs, signs identifying the conservation values of the Property,
signs giving directions or proscribing rules and regulations for the use of the Property
and/or signs identifying the Grantor as owner of the property.
H. Dumping or Storage. Dumping or storage of soil, trash, ashes, garbage, waste,
abandoned vehicles, appliances, machinery or hazardous substances, or toxic or
hazardous waste, or any placement of underground or aboveground storage tanks or other
materials on the Property is prohibited.
I. Excavation, Dredging or Mineral Use. There shall be no grading, filling,
excavation, dredging, mining or drilling; no removal of topsoil, sand, gravel, rock, peat,
minerals or other materials, and no change in the topography of the land in any manner
on the Property, except to restore natural topography or drainage patterns.
J. Water Quality and Drainage Pattern. There shall be no diking, draining,
dredging, channeling, filling, leveling, pumping, impounding or related activities, or
altering or tampering with water control structures or devices, or disruption or alteration
of the restored, enhanced, or created drainage patterns. In addition, diverting or causing
or permitting the diversion of surface or underground water into, within or out of the
easement area by any means, removal of wetlands, polluting or discharging into waters,
springs, seeps, or wetlands, or use of pesticide or biocides is prohibited.
K. Development Rights. No development rights that have been encumbered or
extinguished by this Conservation Easement shall be transferred pursuant to a
transferable development rights scheme or cluster development arrangement or
otherwise.
L. Vehicles. The operation of mechanized vehicles, including, but not limited to,
motorcycles, dirt bikes, all -terrain vehicles, cars and trucks is prohibited. [The Corps
will generally allow the use of vehicles on existing roads provided those roads are

identified by reference to a recorded map showing their location, configuration, and
size.]
M. Other Prohibitions. Any other use of, or activity on, the Property which is or
may become inconsistent with the purposes of this grant, the preservation of the Property
substantially in its natural condition, or the protection of its environmental systems, is
prohibited.
ARTICLE III
GRANTOR'S RESEVERED RIGHTS
The Grantor expressly reserves for himself, his personal representatives, heirs,
successors or assigns, the right to continue the use of the property for all purposes not
inconsistent with this Conservation Easement, including, but not limited to, the right to
quiet enjoyment of the Property, the rights of ingress and egress, the right to hunt, fish,
and hike on the Property, the right to sell, transfer, gift or otherwise convey the Property,
in whole or in part, provided such sale, transfer or gift conveyance is subject to the terms
of, and shall specifically reference, this Conservation Easement.
[For use when mitigation work (approved or required restoration, creation, or
enhancement)is to be done on the property]Notwithstanding the foregoing Restrictions,
Grantor reserves for Grantor, its successors and assigns, the right to construct wetland
and stream mitigation on the Property, in accordance with the [describe mitigation plan
by title, date and permit action id if a single mitigation site; if a mitigation bank, include
the language "detailed mitigation plan approved in accordance with the Mitigation
Banking Instrument for the Mitigation Bank.]
ARTICLE IV.
GRANTEE'S RIGHTS
The Grantee or its authorized representatives, successors and assigns, and the
Corps, shall have the right to enter the Property at all reasonable times for the purpose of
inspecting said property to determine if the Grantor, or his personal representatives, heirs,
successors, or assigns, is complying with the terms, conditions, restrictions, and purposes
of this Conservation Easement. The Grantee shall also have the right to enter and go
upon the Property for purposes of making scientific or educational observations and
studies, and taking samples. The easement rights granted herein do not include public
access rights.
ARTICLE V
ENFORCEMENT AND REMEDIES
A. To accomplish the purposes of this Easement, Grantee is allowed to prevent
any activity on or use of the Property that is inconsistent with the purposes of this
Easement and to require the restoration of such areas or features of the Property that may
be damaged by such activity or use. Upon any breach of the terms of this Conservation

Easement by Grantor that comes to the attention of the Grantee, the Grantee shall notify
the Grantor in writing of such breach. The Grantor shall have 30 days after receipt of
such notice to correct the conditions constituting such breach. If the breach remains
uncured after 30 days, the Grantee may enforce this Conservation Easement by
appropriate legal proceedings including damages, injunctive and other relief.
Notwithstanding the foregoing, the Grantee reserves the immediate right, without notice,
to obtain a temporary restraining order, injunctive or other appropriate relief if the breach
of the term of this Conservation Easement is or would irreversibly or otherwise
materially impair the benefits to be derived from this Conservation Easement. The
Grantor and Grantee acknowledge that under such circumstances damage to the Grantee
would be irreparable and remedies at law will be inadequate. The rights and remedies of
the Grantee provided hereunder shall be in addition to, and not in lieu of, all other rights
and remedies available to Grantee in connection with this Conservation Easement. The
costs of a breach, correction or restoration, including the Grantee's expenses, court costs,
and attorneys' fees, shall be paid by Grantor, provided Grantor is determined to be
responsible for the breach. The Corps shall have the same right to enforce the terms and
conditions of this easement as the Grantee.
B. No failure on the part of the Grantee to enforce any covenant or provision
hereof shall discharge or invalidate such covenant or any other covenant, condition, or
provision hereof or affect the right to Grantee to enforce the same in the event of a
subsequent breach or default.
C. Nothing contained in this Conservation Easement shall be construed to entitle
Grantee to bring any action against Grantor for any injury or change in the Property
resulting from causes beyond the Grantor's control, including, without limitation, fire,
flood, storm, war, acts of God or third parties, except Grantor's lessees or invitees; or
from any prudent action taken in good faith by Grantor under emergency conditions to
prevent, abate, or mitigate significant injury to life, damage to property or harm to the
Property resulting from such causes.
ARTICLE VI
MISCELLANEOUS
A. Warran . Grantor warrants, covenants and represents that it owns the
Property in fee simple, and that Grantor either owns all interests in the Property which
may be impaired by the granting of this Conservation Easement or that there are no
outstanding mortgages, tax liens, encumbrances, or other interests in the Property which
have not been expressly subordinated to this Conservation Easement. Grantor further
warrants that Grantee shall have the use of and enjoy all the benefits derived from and
arising out of this Conservation Easement, and that Grantor will warrant and defend title
to the Property against the claims of all persons.

B. Subsequent Transfers. The Grantor agrees to incorporate the terms of this
Conservation Easement in any deed or other legal instrument that transfers any interest in
all or a portion of the Property. The Grantor agrees to provide written notice of such
transfer at least thirty (30) days prior to the date of the transfer. The Grantor and Grantee
agree that the terms of this Conservation Easement shall survive any merger of the fee
and easement interests in the Property or any portion thereof and shall not be amended,
modified or terminated without the prior written consent and approval of the Corps.
C. Assignment. The parties recognize and agree that the benefits of this
Conservation Easement are in gross and assignable provided, however that the Grantee
hereby covenants and agrees, that in the event it transfers or assigns this Conservation
Easement, the organization receiving the interest will be a qualified holder under N.C.
Gen. Stat. § 121-34 et seq. and § 170(h) of the Internal Revenue Code, and the Grantee
further covenants and agrees that the terms of the transfer or assignment will be such that
the transferee or assignee will be required to continue in perpetuity the conservation
purposes described in this document.
D. Entire Agreement and Severability. This instrument sets forth the entire
agreement of the parties with respect to the Conservation Easement and supersedes all
prior discussions, negotiations, understandings or agreements relating to the Conservation
Easement. If any provision is found to be void or unenforceable by a court of competent
jurisdiction, the remainder shall continue in full force and effect.
E. Obligations of Ownership. Grantor is responsible for any real estate taxes,
assessments, fees, or charges levied upon the Property. Grantor shall keep the Property
free of any liens or other encumbrances for obligations incurred by Grantor. Grantee shall
not be responsible for any costs or liability of any kind related to the ownership,
operation, insurance, upkeep, or maintenance of the Property, except as expressly
provided herein. Nothing herein shall relieve the Grantor of the obligation to comply with
federal, state or local laws, regulations and permits that may apply to the exercise of the
Reserved Rights.
F. Extinguishment. In the event that changed conditions render impossible the
continued use of the Property for the conservation purposes, this Conservation Easement
may only be extinguished, in whole or in part, by judicial proceeding.
G. Eminent Domain. Whenever all or part of the Property is taken in the exercise
of eminent domain so as to substantially abrogate the Restrictions imposed by this
Conservation Easement, Grantor and Grantee shall join in appropriate actions at the time
of such taking to recover the full value of the taking, and all incidental and direct
damages due to the taking.
H. Proceeds. This Conservation Easement constitutes a real property interest
immediately vested in Grantee. In the event that all or a portion of this Property is sold,
exchanged, or involuntarily converted following an extinguishment or the exercise of
eminent domain, Grantee shall be entitled to the fair market value of this Conservation

Easement. The parties stipulate that the fair market value of this Conservation Easement
shall be determined by multiplying the fair market value of the Property unencumbered
by this Conservation Easement (minus any increase in value after the date of this grant
attributable to improvements) by the ratio of the value of this easement at the time of this
grant to the value of the Property (without deduction for the value of this Conservation
Easement) at the time of this grant. The values at the time of this grant shall be the values
used, or which would have been used, to calculate a deduction for federal income tax
purposes, pursuant to Section 170(h) of the Internal Revenue Code (whether eligible or
ineligible for such a deduction). Grantee shall use its share of the proceeds in a manner
consistent with the purposes of this Conservation Easement.
I. Notification. Any notice, request for approval, or other communication
required under this Conservation Easement shall be sent by registered or certified mail,
postage prepaid, to the following addresses (or such address as may be hereafter specified
by notice pursuant to this paragraph):
To Grantor:
[Name, address and fax number]
To Grantee:
[Name, address and fax number]
To the Corps:
[Name, address and fax number]
J. Failure of Grantee. If at any time Grantee is unable or fails to enforce this
Conservation Easement, or if Grantee ceases to be a qualified grantee, and if within a
reasonable period of time after the occurrence of one of these events Grantee fails to
make an assignment pursuant to this Conservation Easement, then the Grantee's interest
shall become vested in another qualified grantee in accordance with an appropriate
proceeding in a court of competent jurisdiction.
K. Amendment. This Conservation Easement may be amended, but only in a
writing signed by all parties hereto, and provided such amendment does not affect the
qualification of this Conservation Easement or the status of the Grantee under any
applicable laws, and is consistent with the conservation purposes of this grant.
L. [For use if there is a document describing the current condition of the
property. The language provided is applicable if there is a mitigation plan that
accurately describes the current condition and uses of the property. If there is not such a
plan, another document we agree is accurate and can be identified and is in our files can
be referenced.]Present Condition of the Property. The wetlands, scenic, resource,
environmental, and other natural characteristics of the Property, and its current use and
state of improvement, are described in Section , Appendix B of the Mitigation Plan,

dated , prepared by Grantor and acknowledged by the Grantor and
Grantee to be complete and accurate as of the date hereof. Both Grantor and Grantee
have copies of this report. It will be used by the parties to assure that any future changes
in the use of the Property will be consistent with the terms of this Conservation
Easement. However, this report is not intended to preclude the use of other evidence to
establish the present condition of the Property if there is a controversy over its use.
TO HAVE AND TO HOLD the said rights and easements perpetually unto Grantee for
the aforesaid purposes.
IN TESTIMONY WHEREOF, the Grantor has hereunto set his hand and seal, the day
and year first above written.
[Signatures of the Grantor and Grantee in appropriate form]