20141149 Ver 9 _AsBuilt Review _20180904

Strickland, Bev
From:
Sent:
To:
Cc:
Subject:
Hey Raymond/Worth,
Merritt, Katie
Tuesday, September 04, 2018 2:54 PM
'Ray Holz'
'Worth Creech'
Benton Branch AsBuilt Review
I have finalized my review of the Benton Branch As -Built Report received on June 4, 2018. As a result of my review, I
found that the report lacked in a few details as well as clarity of work actually done on the site. This information will be
necessary for DWR to approve the report. Comments regarding the report are provided below:
1. Section 2.0
a. doesn't provide any status of where the project stands with regards to the USACE. Was it constructed
the way it was approved to be constructed? Any As -built report submitted or approved? Etc. This
information is important to us, because we cannot approve this report without knowing whether the
stream & wetland mitigation was completed and approved by the USACE.
b. Details regarding stream restoration efforts are not provided. Please indicate if all of the stream
restoration or enhancement work (see Figure 6 of BPDP) was done in compliance with permits and
corresponding mitigation plan. If any changes occurred from what was proposed in the BPDP, please
acknowledge those.
c. On the Summary page RS acknowledges that the E&SC plan from Land Quality was approved. However,
no plan is provided in the report and RS doesn't provide information on how they implemented the
approved plan. This is important to us, considering a large portion of this site was created during
construction and earth movement could lead to substantial sediment loss into streams.
2. Section 3.0
Mitigation amounts changed slightly (see Table 1) from what was provided in the BPDP. Please explain
why the mitigation amounts changed. If this change was a result of streams or wetlands not being
constructed as proposed, please provide a figure showing a comparison between the As -Built Figure 5
and the BPDP Figure 6.
b. Please note: the Enhancement and Preservation credits need to be on the same credit ledger (see page
4 bottom of page)
3. Section 4
a. This section states that 20 plots were installed. However, only 11 plots were noted in the BPDP as
proposed to be installed. Please explain the need for more plots and provide a Figure showing which of
the 20 plots are intended to be used for monitoring of buffer & nutrient offset credit areas.
b. 4.4—This paragraph describes what RS intends to do to mark the boundaries. However, since this is an
Asbuit, please indicate what RS actually did to mark the boundaries.
If you have any questions, please let me know. A response to the comments above can be provided via email back to
me.
Thank you,
Katie
"please note my phone number has changed"

Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
401 & Buffer Permitting Unit
North Carolina Department of Environmental Quality
Office: 919-707-3637
Website: http://portal.ncdenr.org/web/wq/401bufferpermitting
1_..._..:..._.lis u.iry Stireet, Raleigh NC760
1617 Mail Service Center. Paleicah. NC 27699-1617
Email correspondence to and from this ackIress is , rrblect to the
North a„-mfina Public Records Law and may be c.lisr;frrsed to thirdparties,