20170921 Ver 1_DWR Comments-Buffer Mit Plan_20180510

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Mitigation Plan Checklist for Riparian Buffer Restoration Mitigation Sites —created 7/15/13
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Credit Determination Table/Map
Verification that the site does not have an impact on threatened or endangered species
Verification that the site is not affected by on-site or nearby sources of contamination as provided
by Environmental Data Resources, Inc.
Verification that the site can be constructed on land if it is an archaeological site;
❑ A list of all permits that will be required and obtained prior to constructing the mitigation site for
nutrient offset and/or buffer mitigation (e.g. Sediment and Erosion Control Plan from Division of
Land Resources, NCG010000 Stormwater Permit from NCDWQ, 404 permit from the Army Corps
of Engineers and corresponding 401 Water Quality Certification from NCDWQ).
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Major Hill Riparian Buffer Mitigation Plan DWR# 2017-0921 - DWR staff (Katie Merritt) Comments:
• General comments
o Provide site photos in Appendix showing existing conditions of riparian areas proposed
for restoration & enhancement and include dates of photos taken
o Include the categorical exclusion or acknowledge that it has been done and approved by
DMS.
o Buffer assets are proposed within the relic pond bottom where a stream is proposed for
restoration. Please add details regarding pond preparation for planting - (breaching,
dam removal, drained, draw -down time, etc.), permitting, stabilization efforts, etc.
o UT -3 has a section Enhancement where only one side of the buffer is within the
easement. 15A NCAC 02B .0295 (o)(6) states that the permanent exclusion of grazing
livestock must be done such that the livestock are fenced out of the stream and its
adjacent buffer. This implies the fence must be installed in a manner to permanently
remove cattle from the stream, from both sides. RS needs to provide an explanation
why this section of UT -3 is proposed for enhancement along only one side and needs to
confirm that exclusionary fencing will be installed along the left and right banks of the
stream if requesting Enhancement credit.
o Show where RS is installing fencing on the parcel on Figure 5
o Note that this site cannot be used to generate nutrient offset credits. If nutrient offset
credits are proposed for this site, DMS must provide an asset table and corresponding
asset map that shows both "generated" and "delivered" credits. The Nitrogen &
Phosphorus delivery factors must be applied at mitigation plan stage and not at
closeout. Enhancement and Preservation credits generated on this site are not viable for
generating nutrient offsets.
• Section 3.2.3 states there will be shrubs planted within the 15' streamside area. Since this
includes buffer credit areas, will shrubs be included towards your performance standards? If so,
section 5.0 needs to include shrubs.
• Section 4.1-4.2:
o Attach the document that RS is referencing as the "monitoring template" as an Appendix
to this Plan.
o Describe what type of plots are being used (fixed, random, etc.)
o Add a statement clarifying that vegetation monitoring will begin no earlier than at least 5
months post -planting efforts.
o Add a statement that the monitoring will be for a period of five monitoring years or until
DWR approval.
o Clarify that the parameters being monitored are mainly for planted stems. If you want to
include volunteer species in the report, that's fine. Clarify that only "desirable volunteers
may be included to meet performance standards and upon DWR approval".
• Section 5.1 - 0295 (2)(E) indicates that the monitoring plan shall also include the "health and
average stem densities" (emphasis added). Add clarity to this section to meet the rule expectation
that vigor is an important parameter to note in the annual reports

• Section 5.0 - Instead of Success Criteria, please use "Performance Standards" to be consistent
with 15A NCAC 02B .0295.