20171122 Ver 2_GUC BPDP-DWR response_20190813

Strickland, Bev
From:
Merritt, Katie
Sent:
Tuesday, August 13, 2019 5:38 PM
To:
Ray Holz
Cc:
'Matthew Harrell'
Subject:
GUC BPDP
Hey Raymond,
Just digging my way through the GUC BPDP, a few things stood out to me pretty quickly. 1) No mention of phasing this
project, 2) Project Schedule on page 7, 3) Appendix D is referenced as being the survey of the PNG easements, 4) Green
Ash in planting plan. See details as follows:
1) This project should have been proposed as a phased project and we discussed this early in the planning phases. Parts
of this project are dependent on the completion of construction of the PNG Line 24, which has already been permitted
but not constructed. Bank work, including planting, will be delayed on parts of this project that are affected by this PNG
project. If RS does not propose phasing this project, then RS cannot proceed with any mitigation site work or planting
until after PNG Line 24 is completed. Thus, the BPDP and MBI will be written up to explain that in detail.
2) The project schedule is alarming in that it shows mitigation activities beginning as soon as Fall 2019, and RS has not
had a review of the BPDP or MBI, nor has the PNG line 24 been constructed as of today. RS needs a project schedule that
is more realistic. Based on current review times, site constraints, public notices, PNG line construction, etc, DWR review
may take several months prior to issuing approval of this BPDP & corresponding MBI.
3) Appendix D includes the scoping letters, but I couldn't find the surveyed easements for PNG line 42 and 24 as
referenced in 2.4.1.
4) Green Ash is currently not being accepted as an acceptable tree for planting plans in NC due to the potential harmful
effects of the Emerald Ash borer. Despite this pest seen more commonly in the Piedmont and western counties of NC,
there is still a potential of its harmful effects on the Green Ash throughout all of NC.
These are just the highlights of my quick look through the BPDP. Before I begin a more thorough review of the BPDP &
MBI, please indicate how RS plans to proceed based on the comments in 1-3 above.
Thanks,
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
Work Cell: 919-500-0683
Website:
512 N. Salisbury Street, Raleigh, NC 27620
1617 Mail Service Center, Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.