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BPDP for PN_EMH FarmMarch 31, 2023 Ms. Katie Merritt Nutrient Offset & Buffer Banking Coordinator 401 & Buffer Permitting Unit North Carolina Department of Environmental Quality 512 N. Salisbury Street, Raleigh, NC 27620 Raleigh, NC 27603 Re: EMH Farm– BPDP – Response to Ms. Katie Merritt and Mr. Blake Hartshorn Comments DWR Project No. 2022-1493 v1 Dear Ms. Merritt, Please find below the response to comments on the EMH Farm BPDP provided by March 15, 2023 from Ms. Katie Merritt and March 30, 2023 from Mr. Blake Hartshorn: 1.change ID# to 2022-1493v1 Re: Changed. 2.General Note: February 2023 is the proposed planting date. Please choose a more realistic planting date. Re: The site is now proposed to planted in April 2023. 3.in general, please make sure to use "Riparian Buffer Credits" or RBC when referring to credits from this bank. sometimes it says "credits" "Mitigation credits" or "buffer credits". please remain consistent and use terminology from MBI template. Re: All references have been updated to “RBC” or “Riparian Buffer Credits”. 4.General Note: Change "Bank" to be Parcel, Bank Parcel, or Site, as used in the MBI. Correct throughout the Plan accordingly. Re: “Bank Parcel” was used in the MBI, and the document has been updated accordingly. Additionally, “EMH Farms” has been changed to “EMH Farm” throughout to match the MBI. 5.add LLC to the name Re: Added. 6.once you declare the acronym for MBI, only refer back to "MBI" throughout. it says "Banking Instrument", "Instrument", etc...please remain consistent and use terminology from MBI template. Re: All references to the Mitigation Banking Instrument have been updated to “MBI”. 7.proposed Re: Added. 8.and two ephemeral channels Re: Added. 9.and ephemeral channels Clearwater Mitigation Solutions 604 Macon Place Raleigh, NC 27609 919-624-6901 clearwatermitigation@gmail.com Re: Added. 10.add the rule reference that allows riparian restoration for credit on Ephemeral channels. see viability letter. Re: A reference to rule 15A NCAC 02B .0295 (o)(7) was added. 11.Number: 1 Author: kymerritt Subject: Cross-Out Date: 3/15/2023 4:53:31 PM Re: Updated to “Bank Parcel” 12.and ephemeral channels Re: Added. 13.Number: 3 Author: kymerritt Subject: Inserted Text Date: 3/15/2023 4:53:19 PM Re: Removed. 14.Mitigation Re: Added. 15.there are no Ditches... Re: “Ditches” was removed. 16.ephemeral channels Re: Added. 17.Photos provided are from APril 2022. Describe these landuses as of today...explaining what has changed, if anything, to the landuse (are cattle still there, etc) Re: The following sentence was added: “Bank Parcel conditions in March 2023 remain as they were at the time the photos were taken with no changes in existing vegetation or land- use (i.e. active cattle pasture).” 18.Fescue is the dominant herbaceous on this site and is known to be an issue for stem health on many sites. It is highly recommended that the Sponsor propose a plan for managing the fescue on this site. Re: The paragraph was revised to discuss the planned site-wide fescue treatment. 19., and these areas will also be surveyed and included in the As-Built Report. Re: Added. 20.explain why it is believed that herbicide may be necessary - what is the Sponsor expecting to be an issue? Re: This paragraph was revised to specifically discuss the treatment of fescue and the discing of pasture areas proposed for planting. 21.Add information about the culverts on UT2 and UT3, and what is going to happen with the culvert in UT1 noted in the viabilty letter as being needed to be removed? Add those details here. If removing culverts, please provide how, if necessary, the stream banks will be stabilized after the culvert removal to prevent sediment or erosive banks. Clearwater Mitigation Solutions 604 Macon Place Raleigh, NC 27609 919-624-6901 clearwatermitigation@gmail.com Re: A paragraph describing additional restoration activities and their accompanying stabilization measures was added at the end of Section 3.1. 22.since Table 5 only shows trees, there is no performance standard for shrubs Number: 6 Author: kymerritt Subject: Cross-Out Date: 3/15/2023 5:05:37 PM Re: The reference to “shrubs” was removed. 23.whta is proposed to exclude cattle from the easement area? if fencing is proposed, show that fence boundary on corresponding figures. Re: A sentence was added indication that the landowner plans to abandon the surrounding pasture and will maintain existing fencing to permanently exclude cattle from the easement area. 24.If 11 species of trees are shown in the table, DWR expects 11 species to be planted. If anticipating to plant less than 11 species, you need to at least indicate the minimum # of species you will plant. you indicated only a minimum of 4 species...if that is true, DWR cannot confirm if the "% of Total Planted Tree" column would comply with the performance standard of "no one tree species will be greater than 50%". Additionally, with the minimum proposal of 4, the Sponsor is at risk for not meeting the performance standard for stem diversity if less than 4 species end up in plots or fail to thrive/survive. The standard in rule is 4, but hopefully the Sponsor is intending to plant more based on the comment above. However, at this time, the column on '% of total planted trees", which is required to include in this plan, is not accurate unless the Sponsor truly plants 11 species (all adding up to be 100%). Adjust the table accordingly and only show the number of species the Sponsor truly intends to plant. If not 11 species, then a minimum of X and of those X species show the % intending to plant. If any changes are needed to the planting list before planting, the Sponsor will need to submit a request to DWR for approval of that modified planting list. DWR will accept a FEW substitutions if the Sponsor wants to include those few potential substitutions in a Table 5b...but you must include the % those subs are intended to be utilized in the case you need those substitutions. Re: Trees have been ordered to be planted in April 2023. 11 species were ordered. Species and densities in the planting plan have been updated based on the confirmed order. 25.add a table showing anticipated seeding mixes. Re: Tables were added for proposed permanent and temporary seed mixes. 26.show the boundary of this fencing on supporting figures. and reference here if not on Figure 8 Re: The fencing boundary was added to Figure 6, and a reference to this figure was added. 27.and adjacent riparian areas Re: Added. 28.Riparian Re: Added. Clearwater Mitigation Solutions 604 Macon Place Raleigh, NC 27609 919-624-6901 clearwatermitigation@gmail.com 29.remove this table and refer back to the MBI for this. Re: The table was removed and a sentence was added referring to the MBI. 30.the Sponsor should take measures to ensure that plots are diverse (have 4 species represented as much as possible) and where a species does not represent more than 50% of the plot. All plots need to be representative of the planted diversity and density surrounding the plot and will be evaluated by DWR during the onsite AsBuilt Walkthru to ensure these criteria are met. All DWR comments provided on planting plan & monitoring are being provided under the following Rule reference 15A NCAC 02B .0295 (n)(2-4). Re: Understood. Tree species will be mixed well during planting to ensure maximum vegetative diversity. 31.add that the plots will be placed in accordance to how they are depicted in Figure 9. DWR approves the Plot placement at the BPDP review stage to make sure the randomization adequately represents the buffer credit areas and widths. Re: A statement was added indicating that the plots will placed in accordance with the locations depicted on Figure 9. 32.it says there are only plots in the riparian restoration areas, but there are also plots in the Enhancement areas. Please edit Re: The paragraph has been edited to include riparian enhancement areas. 33.and enhancement Re: Added. 34.revise the 30 day note to be more similar to the MBI language below Within 30 calendar days after completing the establishment of the buffer mitigation areas, the Sponsor will submit written notification to DWR documenting that all nutrient offset activities have been completed. Failure to submit written notification within 30 days may result in a modified credit release schedule or a delay in the issuance of credit releases. Notification shall include all the items as specified in the UBI. Re: This language was added and edited to suit this Bank Parcel. 35.add vigor as a parameter to the vegetation data to be collected. Re: Vigor was added as a collected parameter. 36.add language from the MBi template that speaks to this requirement of assigning the CE to a long term steward prior to the Year 4 monitoring... Re: The language regarding long-term stewardship from the MBI was added. 37.Number: 2 Author: kymerritt Subject: Cross-Out Date: 3/15/2023 5:10:37 PM Re: Removed. Clearwater Mitigation Solutions 604 Macon Place Raleigh, NC 27609 919-624-6901 clearwatermitigation@gmail.com 38.need to add that the contact information for the site will be on the placards Re: A sentence was added indicating that boundary markers will contain Bank Parcel contact information. 39.add that the easement will be clearly marked prior to the site walk by DWR required for the Task 2 credit release Re: Added. 40.speak to the 25% caps of the Ephemeral and Preservation credits and how that affected credit assets in the table. Re: A paragraph was added indicating that ephemeral and preservation credits account for 9.7% and 9.8% of the total area of buffer mitigation, respectively. 41.perpendicular and Re: Added. 42.move Table 7 to this section 6.0. Re: Table 7 was moved from Appendix A to Section 6.0. 43.only 1 credit ledger is necessary for this bank. edit accordingly. Re: This was revised. FIGURES – Response to Comments 44."Credit" Re: Added. 45.change to Riparian Buffer "Credit" Service Area Re: Changed. 46.change title to "Riparian Buffer Credit Determination" Re: Changed. 47.show the Ephemeral & Intermittent Origins on this map. Re: Ephemeral and Intermittent origins have been depicted by different colors. 48.For this particular site, it is not necessary to depict "Subject vs Non Subject or "Rural" in this map since it's already broken out in the Table 7, or the duplicative widths since the widths are already depicted at the bottom of legend. Need to depict "Non Subject" reaches as Ephemeral Channel. Clean up map accordingly. Re: The legend and map symbology were simplified to depict only “Riparian Restoration”, Riparian Enhancement”, and “Riparian Preservation”, with no color differentiation between buffer zones (distances) or subject vs. non-subject. 49.change "Buffer" to "Riparian" on all descriptions. Example: Riparian Restoration instead of "Buffer Restoration" Re: Changed. Clearwater Mitigation Solutions 604 Macon Place Raleigh, NC 27609 919-624-6901 clearwatermitigation@gmail.com 50.see comments on Figure 8 and apply to Figure 9 Re: The same changes that were made to Figure 8 were applied to Figure 9. 51.this table should show additional cells here for max totals including the 25% credit cap for Ephemerals. This is not the updated credit table. Replace with the most up-to-date credit table on the website. Re: The table was replaced with the most up-to-date credit table. 52.move table to be in Section 6 Re: The table was moved to Section 6.0. DWR Comments, Blake Hartshorn: 1.Either remove the sentence on substitutions or include a table 5b with what the substitutions species are with their corresponding percentages. Sponsor has to select what those "regionally appropriate native species" would be in order for DWR to approve the planting plan in this BPDP. Some "regionally appropriate species" may not be acceptable. Re: Per previous email correspondence, we have revised part of section 3.1 to read below, as we have verified the 11 proposed bare root tree species are readily available and there will be no substitutions. ORIGINAL Section 3.1 (paragraph 1): "Tree species planted across the Bank Parcel are anticipated to include a mixture of the species listed in Table 5. Species availability may result in the substitution of regionally appropriate native species." REVISED VERSION Section 3.1 (paragraph 1): "Tree species planted across the Bank Parcel will include a mixture of the species listed in Table 5. Eleven species of trees will be planted, and have been verified to be readily available." Regarding the herbaceous seed mix, in our experience, available seed-stock is highly variable, and if certain species are unavailable, they will often be replaced with appropriate seed-stock by the supplier, which is usually a higher percentage of another species on the list, and removing the unavailable species on the list and adjusting the percentage at as-built. It is not feasible to list all possible seed mix substitutions. However, the sentence has been revised to clarify that only herbaceous seed-mix species may be replaced, not woody stems, as follows: Clearwater Mitigation Solutions 604 Macon Place Raleigh, NC 27609 919-624-6901 clearwatermitigation@gmail.com “Seed availability may result in the substitution of a higher percentage of available seed species listed in Table 6A and lower percentage of unavailable seed mix listed in Table 6A.” 2."200 stems per acre" Re: Revised. 3.Do they need to specify that trees will be mixed or does their response (#30) satisfy that? Re: “Bare-root tree stock will be sufficiently mixed during planting to ensure diversity and that no one tree species will be greater than 50% of the established stems” is included in the description of riparian restoration activities (Section 3.1). 4.Fix table title. Re: Fixed. 5.Use the original figure 8 but only take out rural and non-subject information and keep the ephemeral coloring the way it is in this map. Re: Figure 8 has been revised. 6.See comments on figure 8 and apply to figure 9. Re: Figure 9 has been revised. Please do not hesitate to contact me with questions at 919-624-6901. Sincerely, Kevin Yates BANK PARCEL DEVELOPMENT PACKAGE EMH Farm Buffer Mitigation Bank Parcel Guilford County, NC Randleman Watershed – Cape Fear River Basin NCDWR Project No. 2022-1493v1 Sponsored by: Clearwater Mitigation Solutions POC: Kevin Yates Ph: 919-624-6901 604 Macon Place Raleigh, North Carolina Prepared by: Axiom Environmental, Inc. POC: Grant Lewis 218 Snow Avenue Raleigh, North Carolina 27603 March 2023 This mitigation plan was written in conformance with the following: North Carolina consolidated buffer mitigation rule 15A NCAC 02B .0295, effective November 1, 2015 and the Randleman Lake Buffer Protection Rule (15A NCAC 02B .0724) Bank Parcel Development Package Table of Contents page i EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 TABLE OF CONTENTS 1.0 INTRODUCTION...............................................................................................................4 1.1 BANK PARCEL LOCATION .............................................................................................................4 1.2 BANK PARCEL OVERVIEW ............................................................................................................5 1.3 PROJECT GOALS ........................................................................................................................5 2.0 PROJECT AREA – EXISTING CONDITIONS..........................................................................6 2.1 PHYSIOGRAPHY .........................................................................................................................6 2.2 BANK PARCEL FEATURES .............................................................................................................6 2.3 SOILS.......................................................................................................................................7 2.4 VEGETATION .............................................................................................................................7 2.5 THREATENED AND ENDANGERED SPECIES .......................................................................................8 2.6 CULTURAL RESOURCES................................................................................................................9 2.7 NORTH CAROLINA NATURAL HERITAGE ELEMENTS ...........................................................................9 2.8 FEMA ....................................................................................................................................9 2.9 UTILITIES..................................................................................................................................9 2.10 OTHER ENVIRONMENTAL CONDITIONS .........................................................................................9 3.0 RIPARIAN RESTORATION, ENHANCEMENT, AND PRESERVATION PLAN .......................... 10 3.1 RIPARIAN AREA RESTORATION ACTIVITIES.....................................................................................10 3.2 RIPARIAN BUFFER ENHANCEMENT ..............................................................................................12 3.3 RIPARIAN BUFFER PRESERVATION ACTIVITIES ................................................................................12 3.4 CREDIT RELEASE SCHEDULE........................................................................................................12 4.0 MONITORING AND MAINTENANCE PLAN ...................................................................... 12 4.1 MONITORING PROTOCOL ..........................................................................................................12 4.2 BANK PARCEL MAINTENANCE ....................................................................................................13 4.3 LONG-TERM MANAGEMENT PLAN ..............................................................................................13 4.4 EASEMENT BOUNDARIES AND FENCING ........................................................................................13 5.0 FINANCIAL ASSURANCE................................................................................................. 14 6.0 MITIGATION POTENTIAL ............................................................................................... 14 7.0 REFERENCES.................................................................................................................. 16 Bank Parcel Development Package Table of Contents page ii EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 TABLES Table 1. Ecological and Water Quality Goals.................................................................................5 Table 2. Project Features...............................................................................................................7 Table 3. Web Soil Survey Soils Mapped within the Site ................................................................7 Table 4. Threatened and Endangered Species...............................................................................8 Table 5. Proposed Bare-Root Planting Plan.................................................................................10 Table 6. Proposed Seed Mix.........................................................................................................11 Table 7. Project Credits................................................................................................................15 Bank Parcel Development Package Table of Contents page iii EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 APPENDICES Appendix A. Figures Figure 1. Site Location and Service Area Figure 2. USGS Topo Quad Figure 3. NRCS Soil Survey Figure 4. Historic Aerial Imagery Figure 5. Existing Conditions Figure 6. Restoration Plan Figure 7. Planting Plan Figure 8. Credit Determination Figure 9. Monitoring Plan Appendix B. Agency Letters/Correspondence NCDWR Stream Determination Letter, July 26, 2021 NCDWR Site Viability Letter, September 24, 2021 Appendix C. Data NCDWR SWIT Forms Site Photos Appendix D. Threatened and Endangered Species Data Summary Letter of Federally Protected Species Survey North Carolina Natural Heritage Program (NCNHP) Report USFWS IPaC Resource List Appendix E. Environmental Data Resources (EDR) Report Executive Summary Appendix F. Conservation Easement Bank Parcel Development Package page 4 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 1.0 INTRODUCTION Clearwater Mitigation Solutions, LLC (Sponsor) is pleased to provide this Bank Parcel Development Package (BPDP) for the EMH Farm Buffer Mitigation Bank (Bank Parcel). The Bank Parcel was made under terms and conditions of the proposed EMH Farm Mitigation Banking Instrument (MBI). The Bank Parcel isdesigned to provide riparian buffer mitigation credits(RBC) for unavoidable impacts due to development within the Randleman watershed of the Cape Fear River Basin per the Randleman Nutrient Strategy (15A NCAC 02B .0724). The Bank Parcel shall be planned and designed according to the MBI with NCDWR, and the Consolidated Mitigation Rule 15A NCAC 02B.0295, which became effective on November 1, 2015. StormwaterrunofffromtheBankParceldrainsdirectlytounnamedtributariestotheDeepRiver, just upstream from the Randleman Reservoir. According to the Final Cape Fear River Basin Restoration Priorities(NCEEP 2009),thiswatershed should be targeted for restoration to protect the critical area that ultimately drains into the WS-IV water supply at Randleman Reservoir. The proposedmitigationactivitieswillreducesedimentandnutrientlevelsandimprovewaterquality within the Bank Parcel and their downstream watersheds.The Bank Parcel includes the restoration, enhancement, and preservation of riparian areas along three unnamed tributaries and two ephemeral channels in Guilford County, NC. The sole purpose of the Bank Parcel is to provide RBC to mitigate for buffer impacts within the Randleman Lake Watershed, Hydrologic Unit Code (HUC) 03030003 and the NCDWR Sub-basin 03-06-08 of the Cape Fear River Basin. All riparian areaswere assessed byNCDWRduringan onsite visit to determine viabilityfor buffer mitigation (NCDWR Site Viability Letter, Appendix B). Approximately 26.69 acres will be protected with a permanent conservation easement. Of those 26.69 acres, 21.39 acres will be restored,1.16acreswillbeenhancedbysupplementallyplantingpartiallyforestedriparianareas, and2.90acreswillbepreserved. Riparian restoration/enhancementareawidthson streamsand ephemeral channels will extend out to a maximum of 200 feet from the top of bank with a minimum width of 20 from top of banks. Riparian buffer enhancement and preservation credits generated on this Bank Parcel are allowed pursuant to 15A NCAC 02B .0295 (n), 15A NCAC 02B .0295 (o)(5), and 15A NCAC 02B .0295 (o)(7). No nutrient offset credit will be generated on the Bank Parcel. Figure 8 shows the Credit Determination Map and Section 3.0 provides details of the mitigation determination on the Bank Parcel. 1.1 Bank Parcel Location Located in the South Atlantic/Gulf Region approximately 4 miles east of Archdale, NC in southwest Guilford County (Figure 1, Appendix A), the Bank Parcel is hydrologically situated withintheUSGS14-digitHUC03030003010050oftheCapeFearRiverBasinandRandlemanLake Watershed (North Carolina Division of Water Quality Subbasin Number 03-06-08). Directions to the Site from Raleigh, North Carolina. Head west on I-40 for 69 miles Just after Exit 220, stay left, following signs for I-85 Bus S Bank Parcel Development Package page 5 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 Continue onto I-85BL S/US-29 S/US-70 W, and travel 2.8 miles Take Exit 33 toward I-73 N/Groometown Road Keep left at the fork, following signs for Groometown Road Turn left onto Groometown Road The Site on the right after 5.7 miles o Site Latitude, Longitude 35.9194ºN, 79.8941ºW (WGS84) 1.2 Bank Parcel Overview The Bank Parcel encompasses 26.69 acres of land containing unnamed tributaries to Deep River. It is located in a region of the state dominated byagriculture and livestock but is also affected by urban runofffromnearbyArchdale andHighPoint. Restorationoftheriparianbufferisexpected to result in immediate water quality benefits within the vicinity of the Bank Parcel through the removal of livestock access to streams and ephemeral channels, as well as the establishment of riparian vegetation. UTs 1, 2, and 3 are present onsite and were deemed subject to the Randleman Lake Buffer Protection Rule (15A NCAC 02B .0724) by NCDWR in correspondence dated September 24, 2021 (NCDWR Site Viability Letter, Appendix B). The upper portion of UT2 (Feature E-1) and Feature E-2 are ephemeral streams and were determined to be not subject. The drainage areas of site streams range from 0.007 mi² to 0.24 mi². Additional present and historical land use practices including the maintenance and removal of riparian vegetation and the relocation, dredging and straightening of onsite streams resulted in degraded water quality and unstable channel characteristics (stream entrenchment, erosion, bank collapse, and stream aggradation). 1.3 Project Goals The major goals of the proposed riparian buffer mitigation project are to provide ecological and waterqualityenhancementstotheRandlemanwatershedbyrestoringtheriparianareatocreate a functional riparian corridor. Specific enhancements to water quality and ecological processes are outlined in Table 1. Table 1. Ecological and Water Quality Goals Goal Objective Decrease nutrient levels Nutrient input will be decreased by filtering runoff from the agricultural fields through restored native buffer zones. The off-site nutrient input will also be absorbed on-site by filtering flood flows through restored floodplain areas, where flood flows can disperse through native vegetation. Decrease Sediment Input Sediment from off-site sources will be captured by deposition on restored floodplain areas where native vegetation will slow overland flow velocities. Decrease water temperature and increase dissolved oxygen concentration Planted riparian trees will shade the streams as they mature reducing thermal pollution. Create appropriate riparian habitat Riparian areas adjacent to streams and ephemeral channels will be restored by planting native vegetation. Permanently protect the parcel from harmful uses A conservation easement will be recorded on the Bank Parcel. Bank Parcel Development Package page 6 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 2.0 PROJECT AREA – EXISTING CONDITIONS 2.1 Physiography Situated within the Southern Outer Piedmont portion of the Piedmont Ecoregion of North Carolina, the Bank Parcel’s regional physiography is characterized by dissected irregular plains; low rounded hills and ridges; and low to moderate gradient streams with mostly cobble, gravel, and sandy substrates. On-site elevations range from a high of 802-feet NGVD above the upper reaches of UT 2 to a low of approximately 750-feet NGVD at the Bank Parcel outfall (USGS High Point East, North Carolina 7.5-minute topographic quadrangle). Surrounding land use consists primarily of wooded and agricultural land, with some low-density residential housing (Figure 5, Appendix A). Historically, livestock have had indiscriminate access to most of the Parcel streams, resulting in degradation of stream banks. Riparian vegetation adjacent to tributaries is mainly herbaceous and disturbed due to livestock grazing and other maintenance activities. Mature forest exists at theupperreachofUT1,andasmallareaofdisturbedmatureforestislocatedatthedownstream extent of UT 1 (Figure 5, Appendix A). These conditions were confirmed by Katie Merritt (NCDWR) during the September 21, 2021 site visit and in the accompanying viability letter (Appendix B). 2.2 Bank Parcel Features The Bank Parcel includes three unnamed tributaries (UT 1-3) and two ephemeral reaches (E 1-2) (Figure 6, Appendix A) which flow to Randleman Reservoir. There is also an existing ditch (E 3) which is proposed to be plugged and filled as part of Bank Parcel restoration activities. The Randleman Reservoir is a regional water supply and stream buffer protection rules are in place throughout the watershed. Photos showing current site conditions (as of April 2022)of the Bank Parcel are provided in Exhibit C. Bank Parcel conditions remain as they were at the time the photos were taken with no changes in existing vegetation or land-use. The classification andsubjectivitycallsfortheBankParcelwere approvedbyNCDWRin anonsite visit with Sue Homewood on July 1, 2021. A letter dated July 26, 2021 sent by NCDWR indicated UTs 1, 2, and 3 are subject to the Randleman Lake Buffer Protection Rule (15A NCAC 02B .0724). The upper portion of UT2 (feature E-1) and Feature E-2 are ephemeral streams and were determined to be not subject (NCDWR Stream Determination Letter, Appendix B). An additional Site visit to determine viability for buffer mitigation was held with Katie Merritt on September 16, 2021. All features were determined to be viable for RBC generation per rule 15A NCAC 02B .0295 (NCDWR Site Viability Letter, Appendix A). Bank Parcel Development Package page 7 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 Table 2. Project Features NCDWR Feature ID In Field Classification Subject to Buffer Rules Riparian Buffer Credit Viable UT 1 Intermittent/Perennial Yes Yes UT 2 Intermittent/Perennial Yes Yes UT 3 Intermittent/Perennial Yes Yes E 1 Ephemeral No Yes E 2 Ephemeral No Yes E 3 Ditch < 3' depth No Yes* * Must meet contingencies per rule 15A NCAC 02B .0295 (8), however, no credit is proposed on this feature. 2.3 Soils Soils that occur within the Site, according to the Web Soil Survey (USDA 2022) are described in the following table. Table 3. Web Soil Survey Soils Mapped within the Site Map Unit Symbol Map Unit Name (Classification)Hydric Status Description ChA Chewacla loam (Fluvaquentic Dystrudepts) Non-hydric but may contain hydric inclusions This series consists of frequently flooded, somewhat poorly drainedsoilsfoundonfloodplainswith0-2percentslopes.The parent material is loamy alluvium derived from igneous and metamorphicrock.Depthtothewatertableis6-24inchesand depth to restrictive features is more than 80 inches. EnB, EnD Enon fine sandy loam (Ultic Hapludalfs) Non-hydric but may contain hydric inclusions This series consists of very deep, well drained, slowly permeablesoilsonridgetops. Theparentmaterialisresiduum weathered from mafic or intermediate igneous and high- grade metamorphic rocks such as diorite, gabbro, diabase, or hornblende gneiss or schist. Depth to bedrock is more than 60 inches. Slopes are 2-15 percent. HhB Helena-Sedgefield complex (Aquic Hapludults-Aquultic Hapludalfs) Non-hydric but may contain hydric inclusions This series consists of very deep, moderately well-drained, slowly permeable soils found on Piedmont ridges and hill slopes. The parent material is residuum weathered from a mixture of felsic, intermediate, or mafic igneous or high-grade metamorphic rock. Depth to the seasonal high-water table is 1.5 to 2.5 feet. MhB2 Mecklenburg sandy clay loam (Ultic Hapludalfs)Non-hydric This series consists of very deep, well drained, slowly permeable soils. The parent material is intermediate and mafic crystalline rocks of the Piedmont uplands. Depth to bedrock is more than 60 inches. Slopes are 2-25 percent. 2.4 Vegetation The Bank Parcel is characterized primarily by actively grazed pasture with scattered disturbed forest. Agricultural land is maintained for livestock grazing and has been planted with fescue (Festuca sp.). Natural recruits of dog fennel (Eupatorium capillifolium), clover (Trifolium spp.), blackberry (Rubus spp.), as well as other opportunistic herbaceous species grow sporadically throughout the Bank Parcel. The area surrounding the downstream reach of UT 1 is disturbed wetland, which is characterized by rushes (Juncus spp.), knotweed (polygonum spp), and sedges (Carex spp.). Disturbed forest is largely cleared of understory species due to livestock pruning Bank Parcel Development Package page 8 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 and is composed of sweetgum (Liquidambar styraciflua), red maple (Acer rubrum), eastern red cedar (Juniperus virginiana), various oaks (Quercus spp.), sycamore (Platanus occidentalis), and hornbeam (Carpinus caroliniana). 2.5 Threatened and Endangered Species Based on a search of the USFWS Information for Planning and Consultation (IPaC) database on September 7, 2022, two federally protected species are listed for the project area. Table 4 lists the federally protected species and indicates if potential habitat existswithin the Bank Parcelfor each; preliminary biological conclusions and summaries follow. Additionally, the bald eagle (Haliaeetus leucocephalus) is protected by the Bald and Golden Eagle Protection Act; however, habitat for the bald eagle is not present within the Bank Parcel. The IPaC resource list, NCNHP report, and summary letter of the federally protected species survey are included in Appendix D. Table 4. Threatened and Endangered Species Species Federal Status Habitat at Site Biological Conclusion Summary Small Whorled Pogonia (Isotria medeoloides)Threatened Yes No Effect Habitat exists in or near the project boundaries but will not be affected by restoration activities. Schweinitz’s sunflower (Helianthus schweinitzii)Endangered Yes No Effect Habitat exists in or near the project boundaries, but a survey concluded that no specimens are present. Small Whorled Pogonia (Isotria medeoloides) Small whorled pogonia is found in open, dry deciduous or mixed pine-deciduous forest, or along stream banks. Examples of areas providing suitable conditions (open canopy and shrub layer with a sparse herb layer) where small whorled pogonia has been found include old fields, pastures, windthrow areas, cutover forests, old orchards, and semi-permanent canopy breaks along roads, streams, lakes, and cliffs. In the Mountains and Piedmont of North Carolina, this speciesisusuallyfoundinassociationwithwhitepine(Pinusstrobus). Marginallysuitablehabitat is present in disturbed mixed hardwood areas within the project boundaries, but these areaswill not be adversely affected by restoration activities; therefore, this project will have No Effect on small whorled pogonia. Schweinitz’s sunflower (Helianthus schweinitzii) Schweinitz's sunflower is endemic to the Piedmont of North and South Carolina. The few sites where this rhizomatous perennial herb occurs in relatively natural vegetation are found in Xeric Hardpan Forests. The species is also found alongroadside rights-of-way,maintained power lines and other utility rights-of-way, edges of thickets and old pastures, clearings and edges of upland oak-pine-hickory woods and Piedmont longleaf pine forests, and other sunny or semi-sunny habitats where disturbances (e.g., mowing, clearing, grazing, storms, frequent fire) help create open or partially open areas for sunlight penetration to the ground. Suitable habitat is present within the project boundary, so a survey was conducted on September 15, 2022. The survey Bank Parcel Development Package page 9 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 determined that no individuals are present, and therefore this project will have No Effect on Schweinitz’s sunflower. 2.6 Cultural Resources The term “cultural resources” refers to prehistoric or historic archaeological sites, structures, or artifact deposits over 50 years old. “Significant” cultural resources are those that are eligible or potentially eligible for inclusion in the National Register of Historic Places. Evaluations of site significance are madewith reference tothe eligibilitycriteria of the National Register (36 CFR60) and in consultation with the North Carolina State Historic Preservation Office (SHPO). Field visits were conducted at the Bank Parcel in the spring and summer of 2022 to ascertain the presenceofstructuresorotherfeaturesthatmaybeeligibleforinclusionontheNationalRegister of Historic Places. No structures were identified within proposed easement boundaries; however, coordination with SHPO will occur prior to construction activities to determine if any significant cultural resources are present. 2.7 North Carolina Natural Heritage Elements A search of the North Carolina Natural Heritage Program (NHP) database was conducted to identify areas within or around the Bank Parcel that are already known to support rare species. According to NHP files, no federally or state-protected species are known to occur within or within a one-mile radius of the Bank Parcel. Additionally, the Randleman Lake managed area (Piedmont Triad Regional Water Authority) is located within one mile of the Bank Parcel (Appendix D). 2.8 FEMA Inspection of the FEMA Flood Insurance Rate Maps 3710773900J, Panels 7739 and 7738, effective June 18, 2007, indicates that the project is not located within a flood area. Therefore, a “Conditional Letter of Map Revision” (CLOMR) is not necessary for this Site. 2.9 Utilities No utilities are located within easement boundaries. A Duke Energy powerline right-of-way runs along the roadside adjacent to the eastern edge of the easement boundary, and a transmission line runs just north of the Bank Parcel (Figure 5, Appendix A). Bank Parcel restoration activities will not affect the adjacent utility easements. 2.10 Other Environmental Conditions An Environmental Data Resources, Inc (EDR) Radius Map Report with Geocheck was ordered for the Parcel on September 7, 2022. Neither the target property nor the adjacent properties were listed in any of the Federal, State, or Tribal environmental data bases searched by EDR. The executive summary of the EDR report is included in the Appendix E. Bank Parcel Development Package page 10 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 3.0 RIPARIAN RESTORATION, ENHANCEMENT, AND PRESERVATION PLAN Theriparianareawillberestoredthroughtherevegetationofnativeplantcommunities. Detailed analysis of plant communitiesand the plantingplan follow. The riparian restoration areaswillbe surveyed and information provided in the As-Built report. Areas where existing mature vegetationexistsareeligibleforriparianbufferenhancementandpreservationcredit,depending on existing stem density (Figure 8, Appendix A), and these areas will also be surveyed and included in the As-Built Report. 3.1 Riparian Area Restoration Activities Riparianarearestorationwillinvolveanherbaceoustreatmentofexistingfescuegrasses,shallow ripping ofpasture areas,whichwilloccur parallelto streamsand ephemeralchannelspromoting floodwater attenuation by increasing frictional resistance of floodwaters crossing Parcel floodplains, and planting appropriate native tree species along the riparian corridor throughout Bank Parcel riparian restoration areas (21.96 acres). Continued herbicide applications may be needed over the first few years of tree establishment in the riparian restoration areasto prevent encroachment of undesirable species, such as fescue, that may out-compete the planted native vegetation. Tree species planted across the Bank Parcel will include a mixture of the species listed in Table 5. Eleven species of trees will be planted, and have been verified to be readily available. Final species composition and density will be detailed in the As-built Report. Riparian Buffer Restoration will occur on the site as follows (Figure 8, Appendix A). Note that all areasofrestorationfromTOBto29feetwillextendaminimumof20feetfromTOB,andallareas of restoration from TOB to 200 feet will extend a minimum of 30 feet from the TOB. UT-1: TOB-29 feet, TOB-200 feet UT-2: TOB-200 feet UT-3: TOB-200 feet E-1: TOB-200 feet E-2: TOB-200 feet Table 5. Proposed Bare-Root Planting Plan Common Name Scientific Name % of Total Planted Trees Canopy Type River birch Betula nigra 17.5 Canopy Tulip Poplar Liriodendron tulipifera 10 Canopy Red mulberry Morus rubra 5 Midstory Black willow Salix nigra 5 Midstory Sycamore Platanus occidentalis 17.5 Canopy Mockernut hickory Carya tomentosa 5 Canopy Swamp chestnut oak Quercus michauxii 10 Canopy Water oak Quercus nigra 10 Canopy Willow oak Quercus phellos 10 Canopy Shumard oak Quercus shumardii 5 Canopy American elm Ulmus americana 5 Canopy Bank Parcel Development Package page 11 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 Trees will be planted at a density of approximately 680 stems per acre on 8-foot centers, sufficient to meet the performance standards outlined in Rule 15A NCAC 02B .0295 of 260 planted trees per acre at the end of five years of monitoring. In addition, bare-root tree stock will be sufficiently mixed during planting to ensure diversity and that no one tree species will be greater than 50% of the established stems. Planting is scheduled for April 2023. Several additional restoration activities are proposed on the Bank Parcel. Three total culverts will be removed: a non-functioning culvert on UT 1, and two functioning culverts on UT 2 and UT 3. The culverts will be removed mechanically with machinery, and impacted stream banks will be sloped at 3:1 grade, matted, seeded, and live-staked to ensure future stability. An existing ditch feature along the eastern boundary of the Bank Parcel (Feature E 3) will be plugged and filled for diffuse flow into UT 3. Graded/disturbed areas will be strawed and seeded to minimize sediment inputs. Minor bank stabilization is proposed, as needed, along UT3. This will include mechanically sloping at 3:1 grade, matting, seeding, and live-staking. Appropriate seed mixes of pollinator-attracting annual and perennial species will be applied to provide temporary and permanent ground cover for soil stabilization and reduction of sediment loss during rain events in areas without existing herbaceous cover, especially where earthwork is performed. Proposed seed mixes are listed in Tables 6A-B. Seed availability may result in the substitution of a higher percentage of available seed species listed in Table 6A and lower percentage of unavailable seed mix listed in Table 6A. The pasture area surrounding the Bank Parcel will be abandoned by the landowner after the restoration activities are complete, and existing fencing will be maintained to permanently exclude cattle from the conservation easement area. Additionally, a small section of fencing within the easement boundary will be removed. See Figure 6 (Appendix A) for details regarding additional restoration activities and fencing. Table 6A. Proposed Permanent Seed Mix Species Percent of Total Mix Purpletop (Tridens flavus)15% Little Bluestem (Schizachyrium scoparium)15% VA Wild Rye (Elymus virginicus)10% Bur Marigold (Bidens cernua)10% Lance-leaved Tickseed (Coreopsis lanceolata)10% Blackeye Susan (Rudbeckia hirta)10% Butterfly milkweed (Asclepias tuberosa)5% Purple coneflower (Echinacea purpurea)5% PA Smartweed (Polygonum pensylvanicum)5% Oxeye sunflower (Heliopsis helianthoides)5% Big Bluestem (Andropogon gerardii)5% Sensitive Pea (Chamaecrista nictitans)5% TOTAL 100% Table 6B. Proposed Temporary Seed Mix Species Application Rate Grain Rye (Secale cereale)100 lbs.per acre Brown Top Millet (Urochloa ramosa)40 lbs.per acre German Millet (Setaria italica)25 lbs.per acre Bank Parcel Development Package page 12 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 3.2 Riparian Buffer Enhancement Riparian buffer enhancement will include supplementally planting and permanently protecting existing riparian buffer and adjacent riparian areas from livestock via exclusionary fencing, cutting, clearing, filling, grading, and any similar activities that would affect the functionality of the riparian buffer (Figures 6, 7, and 8, Appendix A). These areas are primarily described as disturbedmixedhardwoods. Riparianbuffercreditssoughtintheenhancementareaareallowed pursuant to 15A NCAC 02B .0295 (n). The enhancement area will extend a maximum of 200 feet from the top of bank with a minimum width of 20 from top of banks. 3.3 Riparian Buffer Preservation Activities Riparian buffer preservation will include permanently protecting existing riparian buffer from cutting, clearing, filling, grading, and any similar activities that would affect the functionality of the riparian buffer. Areas specified for Preservation, as defined in 15A NCAC 02B .0295, are shown in Figure 8 (Appendix A). These areas are primarily described as mixed hardwoods, with the number of high value species above 200 stems per acre. They are areas where livestock are currently fenced out, and there has been little or no historic livestock access. 3.4 Credit Release Schedule Credit shall be released in accordance with the schedule described in the MBI. 4.0 MONITORING AND MAINTENANCE PLAN 4.1 Monitoring Protocol Permanent vegetation monitoring plots will be installed and evaluated within the riparian buffer restoration and enhancement areas to measure the survival of the planted trees. The plots will be 100 square meters each and will be randomly placed throughout the planted riparian areas. A total of nineteen (19)plots (2.08% of the restoration/enhancement credit generatingarea)will be establishedwithin theriparian restoration andenhancement areas,andtheirlocationswillbe in accordance with the locations depicted on Figure 9 (Appendix A). Vegetation assessmentswill be conducted and follow the Carolina Vegetation Survey (CVS) Level 2 Protocol for Recording Vegetation (Lee et. all, 2008). A reference photo will be taken from the origin point of each plot and provided in the annual reports. All planted stems will be marked with flagging tape and recorded. Plantingisscheduled forApril 2023. Within 30 calendardaysafter completingthe establishment of the buffer mitigation areas, the Sponsor will submit written notification to DWR documenting that all riparian buffer restoration and enhancement activities have been completed. Failure to submit written notification within 30 days may result in a modified credit release schedule or a delay in the issuance of credit releases. Notification shall include all the items as specified in the MBI. The first annual monitoring activitieswill 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. Bank Parcel Development Package page 13 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 Speciescomposition,height,survivalrates,andvigorwillbeevaluatedonanannualbasisbyplot. Thetotalnumberofvolunteerwoodystemswillalsobedocumentedandreported. Themeasure 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% of the established planted stems, and an established density of at least 260 planted trees per acre at the end of monitoring year five. Appropriate and desirable native volunteer species may be included in the Bank Parcel’s density to meet the performance standards with NCDWR approval. The Sponsor shall submit the annual monitoring report to NCDWR by December 31 of each year for five consecutive years and will follow the terms and conditions of the MBI. 4.2 Bank Parcel Maintenance In the event that the Bank Parcel or a specific component of the Bank Parcel fails to achieve success criteria as outlined in section 4.1A remedial action plan will be developed and implemented with the approval of NCDWR. Other vegetation maintenance and repair activities may include pruning,mulching, and fertilizing. If exotic invasive plant species require treatment, such species will be controlled by mechanical (physical removal with the use of a chainsaw) and/or chemical methods (aquatic approved herbicide) in accordance with North Carolina Department of Agriculture (NCDA) rules and regulations. The easement boundary will be checked annually as part of monitoring activities. Easement boundary conditions and any maintenance performed will be reported in the annual monitoring reportstoNCDWR. IfmowingisdeemednecessarybytheSponsorduringthemonitoringperiod, theSponsormustreceiveapprovalfromNCDWRpriortoconductinganymowingactivitieswithin Randleman Buffer Zones 1 and 2 to ensure that no buffer violations have occurred. 4.3 Long-Term Management Plan A Permanent Conservation Easement will preserve all areas and prohibit all use of the property inconsistent with its use as mitigation property including any activity that would materially alter the biological integrity of the Bank Parcel. The Sponsor agrees to transfer or assign the conservation easement and its interests in perpetuity to a qualified holder under NC General Statute ("GS") 121-34 et seq. and 170(h) of the Internal Revenue Code prior to the submittal of the Year 4 Monitoring Report. The holder shall be a land trust or stewardship program that will hold and enforce the conservation easement and the interests in perpetuity. The Sponsor shall choose a land trust or stewardship program that is accredited by the Land Trust Accreditation Commission and/or hasbeen approved byDWRprior to the end of the fourth year of monitoring period. A land trust must be certified under 501(c)(3) of the Internal Revenue Code. 4.4 Easement Boundaries and Fencing Easement boundarieswill be identified inthe 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. Boundarymarkerswillcontain contact information forthe BankParcel,and the easementwillbe Bank Parcel Development Package page 14 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 clearly marked prior to the Task 2 credit release DWR site-visit. Boundary markers disturbed, damaged, or destroyed will be repaired and/or replaced on an as needed basis. 5.0 FINANCIAL ASSURANCE Following approval of the EMH Farm Bank Parcel Development Package, the Sponsor shall provide a Performance Bond from a surety that is rated no less than an " A-" as rated by A. M. Best. The performance bond amount shall be 100% of the estimated cost for implementation of the project as described in the Bank Parcel Development Package, 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. In that case, no performance bond will be necessary. After completion of the restoration/ construction, a separate performance/ maintenance bond will be secured for 100% of the estimated cost to implement the monitoring and maintenance plan but not less than $ 100,000. The performance/ maintenance bond shall apply at the inception of the monitoring period for a term of one year and be extended annually for a minimum of five years. Upon DWR approval, this may be lowered each year based on the adjusted cost to complete the monitoring. Performance bonds for monitoring shall be renewed at least annually to cover the next year's monitoring period, with confirmation of renewal provided to DWR with each annual monitoring report when applicable.DWR reserves the right to alter the credit release schedule if monitoring reports are submitted without proof of bond renewals when applicable. 6.0 MITIGATION POTENTIAL TheEMHFarmMitigationBankParcelwillprovideRandlemanLakeRBCfordevelopmentimpacts within the Randleman Lake Watershed (Figure 8 and Table 7, Appendix A and NCDWR Site Viability Letter, Appendix B). The width of the credit-generating areas will begin at the most landward limit of the top ofbankor the rooted herbaceousvegetation and extend perpendicular and landward a maximum distance of 200 feet where the Sponsor is able. No credit-generating areas will be less than 20 feet in width from TOB. ConsolidatedMitigationRule15ANCAC02B.0295(o)(7)statesthat theareaofthemitigationsite on ephemeral channels shall comprise no more than 25 percent of the total area of buffer mitigation. Riparian buffer credit generated on ephemeral channels is 9.7 percent of the Bank Parcel’s total area of buffer mitigation. Additionally, Consolidated Mitigation Rule 15A NCAC 02B.0295 (o)(5) states that the area of preservation credit within a buffer mitigation site shall comprise of no more than 25 percent of the total area of buffer mitigation. The area of preservation credit comprises 9.8 percent of the Bank Parcel’s total area of buffer mitigation. The Sponsor will maintain a credit ledger, if applicable, for the Bank Parcel under the MBI for riparian buffer credits, both in square feet and acres. Table 1. EMH Farm, 2022‐1493v1, 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 (ft2) 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)  Buffer Rural Yes I / P Restoration 0‐100 UT1, UT2, UT3 474,646 474,646 1 100% 1.00000 Yes 474,646.000 N/A — — Buffer Rural Yes I / P Restoration 101‐200 UT1, UT2, UT3 350,155 350,155 1 33% 3.03030 Yes 115,551.266 N/A — — Buffer Rural Yes Ephemeral Restoration 0‐100 E1, E2 42,733 42,733 1 100% 1.00000 Yes 42,733.000 N/A — — Buffer Rural No Ephemeral Restoration 101‐200 E1, E2 64,327 64,327 1 33% 3.03030 Yes 21,227.931 N/A — — ——— Buffer Rural Yes I / P Enhancement 0‐100 UT1 19,941 19,941 2 100% 2.00000 Yes 9,970.500 N/A — — Buffer Rural Yes I / P Enhancement 101‐200 UT1 30,303 30,303 2 33% 6.06061 Yes 4,999.992 N/A — — Buffer Rural Yes I / P Enhancement 20‐29 UT1 74 74 2 75% 2.66667 Yes 27.750 N/A — — ——— ——— ——— ——— ——— ——— ——— ——— ——— ——— ——— Totals (ft2):982,180 982,180 669,156.438 0.000 0.000 Total Buffer (ft2):982,180 982,180 Total Nutrient Offset (ft2):0 N/A Total Ephemeral Area (ft2) for Credit:107,060 107,060 Total Eligible Ephemeral Area (ft2):277,099 9.7%Ephemeral Reaches as % TABM Enter Preservation Credits Below Total Eligible for Preservation (ft2):327,393 9.6%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 / P0‐100 UT1 74,102 74,102 10 100% 10.00000 7,410.200 Rural Yes I / P 101‐200 UT1 51,850 51,850 10 33% 30.30303 1,711.050 Rural Yes I / P20‐29 UT1 265 265 10 75% 13.33333 19.875 — — Preservation Area Subtotals (ft2):126,216 126,216 Square Feet Credits 931,861 654,158.197 50,318 14,998.242 126,216 9,141.125 1,108,396 678,297.564 Square Feet Credits Nitrogen:0.000 Phosphorus:0.0000 TOTAL AREA OF BUFFER MITIGATION (TABM) TOTAL NUTRIENT OFFSET MITIGATION Mitigation Totals Nutrient Offset: Preservation: Total Riparian Buffer: Cape Fear ‐ Randleman N/A N/A Restoration: Enhancement: Mitigation Totals 1.  The Randleman Lake buffer rules allow some ditches to be classified as subject according to 15A NCAC 02B .0250 (5)(a). last updated 08/03/2020 Bank Parcel Development Package page 16 EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 7.0 REFERENCES Griffith, G.E., J.M. Omernik, J.A. Comstock, M.P. Schafale, W.H. McNab, D.R. Lenat, T.F. MacPherson, J.B. Glover, and V.B. Shelbourne. 2002. Ecoregions of North Carolina and South Carolina. U.S. Geological Survey, Reston, Virginia. Information for Planning and Consultation (IPaC). 2022. United States Fish and Wildlife Service (online). Available: https://ipac.ecosphere.fws.gov/ (September 7, 2022). Randleman Lake Buffer Protection Rule 15A NCAC 02B .0724 Lee, M.T., R.K. Peet, S.D. Roberts, and T.R. Wentworth. 2008. CVS-EEP Protocol for Recording Vegetation, Level 1-2 Plot Version 4.2. Ecosystem Enhancement Program, North Carolina Department of Environment and Natural Resources. Natural Resources Conservation Service (NRCS). 2022. Web Soil Survey (online). Available: http://websoilsurvey.nrcs.usda.gov/app/ [August 31, 2022]. United States Department of Agriculture. Schafale, M.P. and A.S. Weakley. 2012. Classification of the Natural Communities of North Carolina: Fourth Approximation. North Carolina Natural Heritage Program, Division of Parks and Recreation, N.C. Department of Environment, Health, and Natural Resources. Raleigh, North Carolina. Bank Parcel Development Package Appendices EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 APPENDIX A FIGURES Figure 1. Site Location and Service Area Figure 2. USGS Topo Quad Figure 3. NRCS Soil Survey Figure 4. Historic Aerial Imagery Figure 5. Existing Conditions Figure 6. Restoration Plan Figure 7. Planting Plan Figure 8. Credit Determination Figure 9. Monitoring Plan Copyr ight :(c ) 201 8 G a rm in FIGU R E Dra wn b y: Da te: Sca le : Pro jec t N o.: KRJ MA R 2023 1:400,000 22-033 Tit le: Pro jec t: Pre pa red fo r: Guilford County, N C EMH FA RMBUFFERMITIGATIONBANK PAR CEL 1 ³ 0 10 205Mi le s Lege nd EM H F a rm s B a n k L o a ctio n US G S H yd ro lo g ic U n it 0 3 0 3 0 0 0 3 NC R ive r S u b b a sin s: 1 4 -d ig it H U C s Rip a ria n B u ffe r C re d it S e rvice A re a : R a n d le m a n L a ke Wa te rsh e d BAN K LOCATIONANDCREDITSERVICE A REA EM H Fa rms B uffe r Mi tig ati on B an k Gui l fo rd C o u nty U S GS H U C 0 3 03 0 00 30 1 00 50 35 .91 94 ºN , 7 9.8 94 1 ºW NC Ce nt er f or G eo gr aphic I nf orm a tion & An aylsis FIGU R E Dra wn b y: Da te: Sca le : Pro jec t N o.: KRJ MA R 2023 1:2000 22-033 Tit le: Pro jec t: Pre pa red fo r: Guilford County, N C EMH FA RMBUFFERMITIGATIONBANK PAR CEL 2 ³ 0 30 0 60 0150Fe e t Lege nd EM H F a rm s E a sem e n t = 2 6 .6 9 a c USGS TOPOQUAD(201 9) U T 1 (S u bj ec t) U S GS D ep ic ted U T 3 (S u bj ec t) U S GS N ot D ep i cte d E 2 (N ot S ub j ec t) U S GS N ot D ep i cte d E 1 (N ot S ub j ec t) U S GS N ot D ep i cte d U T 2 (S u bj ec t) U S GS N ot D ep i cte d E 3 (N ot S ub j ec t) U S GS N ot D ep i cte d NC Ce nt er f or G eo gr aphic I nf orm a tion & An aylsis FIGU R E Dra wn b y: Da te: Sca le : Pro jec t N o.: KRJ 1:2000 22-033 Tit le: Pro jec t: Pre pa red fo r: Guilford County, N C 3 ³ 0 30 0 60 0150Fe e t Lege nd EM H F a rm s E a sem e n t = 2 6 .6 9 a c NRC SSOIL SU RVEY(197 7) U T 1 (S u bj ec t) N R C S D ep ic ted U T 3 (S u bj ec t) N R C S N ot D ep i cte d E 2 (N ot S ub j ec t) N R C S N ot D ep i cte d E 1 (N ot S ub j ec t) N R C S N ot D ep i cte d U T 2 (S u bj ec t) N R C S N ot D ep i cte d E 3 (N ot S ub j ec t) N R C S N ot D ep i cte d MA R 2023 EMH FA RM SBUFFERMITIGATIONBANK PAR CEL FIGURE Drawn by: Date: Scale: Project No.: KRJ MAR 2023 1:2000 22-033 Title: Prepared for: Project: EMH FARM BUFFER MITIGATION BANK PARCEL Guilford County, NC 4 ³ HISTORICAERIALIMAGERY 20081998 1964 0 500 1,000250Feet 1993 Legend EMH Farms Easement = 26.69 ac ^_ ^_ ^_ ^_ NC Ce nt er f or G eo gr aphic I nf orm a tion & An aylsis FIGU R E Dra wn b y: Da te: Sca le : Pro jec t N o.: KRJ 1:2000 22-033 Tit le: Pro jec t: Pre pa red fo r: Guilford County, N C 5 ³ 0 30 0 60 0150Fe e t Lege nd Su b je ct P a rce l B ou n d a ry EM H F a rm s E a sem e n t = 2 6 .6 9 a c In te rm itte n t/P e re nn ia l S tre a m C h a nn e l Ep h e m e ra l C h a n ne l Ditch Existin g C u lve rte d C ro ssin g Existin g H a rd w o od F o re st Pa rtia lly F o re ste d A re a ^_Fo rm s Du ke E n e rg y R ig ht o f Wa y EXISTIN GCONDITIONSUT 1 (S u bj ec t) U T 3 (S u bj ec t) E 2 (N ot S ub j ec t) E 1 (N ot S ub j ec t) U T 2 (S u bj ec t) E 3 (N ot S ub j ec t) Fo rm #3 Sc ore : 28 Fo rm #2 Sc ore : 28 .5 Fo rm #1 Sc ore : 34 .5 MA R 2023 EMH FA RMBUFFERMITIGATIONBANK PAR CEL NC Ce nt er f or G eo gr aphic I nf orm a tion & An aylsis FIGU R E Dra wn b y: Da te: Sca le : Pro jec t N o.: KRJ 1:2000 22-033 Tit le: Pro jec t: Pre pa red fo r: Guilford County, N C 6 ³ 0 30 0 60 0150Fe e t Lege nd Su b je ct P a rce l B ou n d a ry EM H F a rm s E a sem e n t = 2 6 .6 9 a c In te rm itte n t/P e re nn ia l S tre a m C h a nn e l Ep h e m e ra l C h a n ne l Ditch Existin g C u lve rte d C ro ssin g Fe n cin g to b e M a in ta in e d F o r C a ttle E xclu sio n Fe n cin g to b e R e mo ve d Du ke E n e rg y R ig ht o f Wa y RESTOR ATIONPLANUT 1 (S u bj ec t) U T 3 (S u bj ec t) E 2 (N ot S ub j ec t) E 1 (N ot S ub j ec t) U T 2 (S u bj ec t) E 3 (N ot Su bje ct) - Th is fea tur e w ill be plu gg ed and fil led fo r di ffus e fl ow in to U T 3 . G ra ded / dis turb ed ar ea s w ill be stra we d and s eed ed . dk jfsd f Min or ba nk sta bili za tion w ill o cc ur a s nee de d alo ng thi s re ac h. Ba nks w ill b e s lop ed ba ck , ma tted , s ee de d, a nd liv e-s tak ed . dk jfsd f Exi stin g c ul ver ts (two fu nc tion in g o n U T2 an d UT 3, and o ne no n-fu nc tio nin g o n U T1 ) w ill be rem o ved . Ban ks wi ll b e s lop ed ba ck at 3:1 gr ad e, ma tted , see de d, and liv e-sta ked . MA R 2023 EMH FA RMBUFFERMITIGATIONBANK PAR CEL NC Ce nt er f or G eo gr aphic I nf orm a tion & An aylsis FIGU R E Dra wn b y: Da te: Sca le : Pro jec t N o.: KRJ 1:2000 22-033 Tit le: Pro jec t: Pre pa red fo r: Guilford County, N C 7 ³ 0 30 0 60 0150Fe e t Lege nd Su b je ct P a rce l B ou n d a ry EM H F a rm s E a sem e n t = 2 6 .6 9 a c Pro p o se d S tre a m C h a n n e l To p o f B a n k Ha rd w o o d P la n ting A re a (R e sto ra tion - E xistin g P a sture ) - 2 1 .9 6 a c Ha rd w o o d P la n ting A re a (E n h a n ce me n t - P a rtia lly F ore ste d A re a s) - 1 .1 7 a c Du ke E n e rg y R ig ht o f Wa y PLA NTINGPLAN U T 1 (S u bj ec t) U T 3 (S u bj ec t) E 2 (N ot S ub j ec t) E 1 (N ot S ub j ec t) U T 2 (S u bj ec t) MA R 2023 EMH FA RMBUFFERMITIGATIONBANK PAR CEL ! ! ! !! ! ! !!! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !! ! ! !! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !! ! ! ! ! ! ! ! ! ! ! !! ! ! !!!! !! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !! !! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !! !! ! ! ! ! ! ! !! !! ! !! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !!!!! ! ! ! ! ! ! ! ! ! ! ! NC Ce nt er f or G eo gr aphic I nf orm a tion & An aylsis FIGU R E Dra wn b y: Da te: Sca le : Pro jec t N o.: KRJ 1:2000 22-033 Tit le: Pro jec t: Pre pa red fo r: Guilford County, N C 8 ³ 0 30 0 60 0150Fe e t Lege nd EM H F a rm s E a sem e n t = 2 6 .6 9 a c In te rm itte n t/P e re nn ia l S tre a m C h a nn e l To p o f Ba n k Ep h e m e ra l C h a n ne l To p o f B an k Rip a ria n R e sto ra tio n , T OB -1 0 0 F e e t Rip a ria n R e sto ra tio n o n E p h e m e ra l C h a n n e l, TO B -1 0 0 F e et Rip a ria n R e sto ra tio n , T OB -1 0 0 F e e t Rip a ria n R e sto ra tio n o n E p h e m e ra l C h a n n e l, 1 0 1 -2 0 0 F e e t Rip a ria n E n h a n ce me n t, TO B -1 0 0 F e e t Rip a ria n E n h a n ce me n t, 1 0 1 -2 0 0 F ee t Rip a ria n E n h a n ce me n t, 2 0 -2 9 F e e t Rip a ria n P re se rvatio n , TO B -1 0 0 F e e t Rip a ria n P re se rvatio n , 1 0 1 -2 0 0 F e et Rip a ria n P re se rvatio n , 2 0 -2 9 F e e t To p o f B a n k to 2 0 -F e e t To p o f B a n k to 3 0 -F e e t To p o f B a n k to 5 0 -F e e t !!To p o f B a n k to 1 0 0-F e e t !!To p o f B a n k to 2 0 0-F e e t RIPA RIAN B UFFERCREDITDETERMINATION NC Ce nt er f or G eo gr aphic Inf or m at io n & Anay ls is NC Ce nt er f or G eo gr aphic Inf or m at io n & Anay ls is U T 1 U T 3 E 2 E 1 U T 2 MA R 2023 EMH FA RMBUFFERMITIGATIONBANK PAR CEL ! ! ! !! ! ! !!! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !! ! ! !! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !! ! ! ! ! ! ! ! ! ! ! !! ! ! !!!! !! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !! !! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !! !! ! ! ! ! ! ! !! !! ! !! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !!!!! ! ! ! ! ! ! ! ! ! ! ! ") ") ") ") ") ") ") ") ") ") ") ") ") ") ") ") ") ") ") 9 7 8 6 5 4 3 2 1 19 18 17 16 15 13 14 12 11 10 NC Ce nt er f or G eo gr aphic I nf orm a tion & An aylsis FIGU R E Dra wn b y: Da te: Sca le : Pro jec t N o.: KRJ 1:2000 22-033 Tit le: Pro jec t: Pre pa red fo r: Guilford County, N C 9 ³ 0 30 0 60 0150Fe e t Lege nd EM H F a rm s E a sem e n t = 2 6 .6 9 a c Rip a ria n R e sto ra tio n , T OB -1 0 0 F e e t Rip a ria n R e sto ra tio n o n E p h e m e ra l C h a n n e l, TO B -1 0 0 F e et Rip a ria n R e sto ra tio n , T OB -1 0 0 F e e t Rip a ria n R e sto ra tio n o n E p h e m e ra l C h a n n e l, 1 0 1 -2 0 0 F e e t Rip a ria n E n h a n ce me n t, TO B -1 0 0 F e e t Rip a ria n E n h a n ce me n t, 1 0 1 -2 0 0 F ee t Rip a ria n E n h a n ce me n t, 2 0 -2 9 F e e t Rip a ria n P re se rvatio n , TO B -1 0 0 F e e t Rip a ria n P re se rvatio n , 1 0 1 -2 0 0 F e et Rip a ria n P re se rvatio n , 2 0 -2 9 F e e t In te rm itte n t/P e re nn ia l S tre a m C h a nn e l To p o f Ba n k Ep h e m e ra l C h a n ne l To p o f B an k ")Pro p o se d Ve g e ta tio n M o n ito rin g P lots (1 9 To ta l) To p o f B a n k to 2 0 -F e e t To p o f B a n k to 3 0 -F e e t To p o f B a n k to 5 0 -F e e t !!To p o f B a n k to 1 0 0-F e e t !!To p o f B a n k to 2 0 0-F e e t MON ITORIN GPLAN MA R 2023 EMH FA RMBUFFERMITIGATIONBANK PAR CELUT 1 U T 3 E 2 E 1 U T 2 Bank Parcel Development Package Appendices EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 APPENDIX B AGENCY LETTERS/CORRESPONDENCE NCDWR Stream Determination Letter, July 26, 2021 NCDWR Site Viability Letter, September 24, 2021 July 26, 2021 Kevin Yates Clearwater Mitigation Solutions Delivered via email to: clearwatermitigation@gmail.com Subject: On-Site Determination for Applicability to the Randleman Lake Buffer Rules (15A NCAC 2B .0250) Subject Property: EMH Farm Mitigation Site, Guilford County Dear Mr. Yates: On July 1, 2021, at your request, Sue Homewood, Caitlin Caudle and Jordan Burbage conducted an on-site determination to review features located on the subject project for stream determinations with regards to the above noted state regulations. Kenan Jernigan with Axiom Environmental Inc. was also present during the site visit. The attached sketch accurately depicts the channels that were reviewed during the site visit as well as origin locations which were documented by Kenan Jernigan during the site visit. The channels that were reviewed and their subjectivity to the above cited rules are described in the table below. Please note that these regulations may be subject to change in the future. Feature Identifier Type of Feature Randleman Buffer Rules Subjectivity UT-1 Perennial Stream Subject UT-2 Intermittent Stream Subject UT-3 Intermittent Stream Subject E-1 Ephemeral Stream Not Subject E-2 Ephemeral Stream Not Subject E-3 Ditch conveying untreated stormwater to a buffered stream Subject The owner (or future owners) should notify the Division (and other relevant agencies) of this decision in any future correspondences concerning this property. This on-site determination shall expire five (5) years from the date of this letter. Page 2 of 2 Landowners or affected parties that dispute a determination made by the Division or Delegated Local Authority that a surface water exists and that it is subject to the buffer rule may request a determination by the Director. A request for a determination by the Director shall be referred to the Director in writing c/o 401 & Buffer Permitting Branch, 1650 Mail Service Center, Raleigh, NC 27699-1650. Individuals that dispute a determination by the Division or Delegated Local Authority that “exempts” surface water from the buffer rule may ask for an adjudicatory hearing. You must act within 60 days of the date that you receive this letter. Applicants are hereby notified that the 60-day statutory appeal time does not start until the affected party (including downstream and adjacent landowners) is notified of this decision. The Division recommends that the applicant conduct this notification in order to be certain that third party appeals are made in a timely manner. To ask for a hearing, send a written petition, which conforms to Chapter 150B of the North Carolina General Statutes to the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, N.C. 27699-6714. This determination is final and binding unless you ask for a hearing within 60 days. This letter only addresses the applicability to the buffer rules and does not approve any activity within Waters of the United States or Waters of the State or their associated buffers. If you have any additional questions or require additional information, please contact me at 336-776-9693 or sue.homewood@ncdenr.gov. Sincerely, Sue Homewood Winston-Salem Regional Office Enclosures: USGS Topo Map KCI Figure 10. Existing Conditions Map – DWR initialed/dated Cc: EMH Farm LLC c/o Ms. Emily Hiatt, 7109-A Harlow Dr, High Point NC 27263 Katie Merritt, DWR (via email) DWR, Winston-Salem Regional Office Guilford County, N C USGSTOPOGRAP HICMAP(High Point Ea st, 20 19 ) EMH FA RM LLCRIPARIAN B UFFERMITIGATION SITE FIGU R EDrawn by : Da te: Sca le: Pro jec t N o.: KRJ Mar 2021 19-008 Tit le:Pro jec t:Pre pa red fo r: 11:5000 Clea rwate rMitigationSolutions Leg end Easemen t = 2 6.6 ac 0 500 1,000250 Feet ¯ NC Ce nt er f or G eo gr aphic I nf orm a tion & Ana ylsis Guilford County, N C STR EA MDETERMINATION EMH FA RM SRIPARIAN B UFFERMITIGATION SITE FIGU R EDrawn by : Da te: Sca le: Pro jec t N o.: KRJ Jul 2021 19-008 Tit le:Pro jec t:Pre pa red fo r: 11:2000 Clea rwate rMitigationSolutions Leg end Potential Conserv ation Ea sement = 26.6 ac Intermitte nt/Peren nial Stre am Channel Ephemer al Chan nel 0 200 400100 Feet ¯ U T-1 U T-3 U T-2 E-1 E-3 (di tch ) E-2 N OT E: D e pi cte d s tre a m determ inations were field verified by M s. S ue H om ew o o d (N C DW R) on July 1, 2021. 7/26/2021 September 24, 2021 Kevin Yates Clearwater Mitigation Solutions (via electronic mail: clearwatermitigation@gmail.com ) Re: Site Viability for Buffer Mitigation – EMH Farm Site Near 5862 Groometown Rd, High Point, NC Randleman Lake Watershed Guildford County Dear Mr. Yates, On July 29, 2021, Katie Merritt, with the Division of Water Resources (DWR), received a request from you on behalf of Clearwater Mitigation Solutions (CMS) for a site visit near the above- referenced site in the Randleman Lake Watershed. The site visit was to determine the potential for riparian buffer mitigation within a proposed conservation easement boundary, which is more accurately depicted in the attached map labeled Figure 1 prepared by EMH. The proposed easement boundary in Figure 1, includes all riparian areas intended to be proposed as part of the mitigation site. On September 16, 2021, Ms. Merritt performed a site assessment of the subject site. Staff with CMS 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 15A NCAC 02B .0295 (effective November 1, 2015). Feature Classification onsite 1Subject to Buffer Rule Riparian Land uses adjacent to Feature (0-200’) Buffer Credit Viable 3Nutrient Offset Viable 2,273.02 lbs-N/acre 4,5Mitigation Type Determination w/in riparian areas UT1 Stream Yes Mostly non-forested pasture. Upstream is fully forested and downstream is partially forested (see map) An old culvert was located in the stream and needs to be removed 2Yes N/A Non-forested pasture - Restoration Site per 15A NCAC 02B .0295 (n) Forested Areas - Preservation Site per 15A NCAC 02B .0295 (o)(5) Partially Forested Areas – Enhancement Site per 15A NCAC 02B .0295 (n) DocuSign Envelope ID: 458687C3-6621-4063-A57B-CA20F98B44F8 EMH Farm Site Clearwater Mitigation Solutions September 24, 2021 Page 2 of 3 1Subjectivity calls for the features were determined by DWR in correspondence dated July 26, 2021 (DWR# -no ID) using the 1:24,000 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 for determining Nutrient Reductions associated with Riparian Buffer Establishment. Credits are calculated differently in the Jordan Lake Watershed. Phosphorus may be calculated separately. 4 Determinations made for this Site are determined 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. Easement breaks that disconnect the continuity of riparian restoration/enhancement/preservation result in no credit viable beyond the break. 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 15A NCAC 02B .0295 (o)(7). 7The area described as an Enhancement Site was assessed and determined to comply with all of 15A NCAC 02B .0295(o)(6). Cattle exclusion fencing is required to be installed around the mitigation area to get buffer credit under this part of the rule. Determinations provided in the table above were made using a proposed easement boundary showing proposed mitigation areas shown in Figure 1. The map representing the proposal for the site is attached to this letter and initialed by Ms. Merritt on September 24, 2021. Substantial changes to the Feature Classification onsite 1Subject to Buffer Rule Riparian Land uses adjacent to Feature (0-200’) Buffer Credit Viable 3Nutrient Offset Viable at 2,273.02 lbs-N/acre 4,5Mitigation Type Determination w/in riparian areas UT2 Stream Yes non-forested pasture grazed by cattle. Culvert needs to be removed from channel if not being used as a crossing Yes N/A Restoration Site per 15A NCAC 02B .0295 (n) Minor bank stabilization measures where erosion was noted onsite. UT3 Stream Yes non-forested pasture grazed by cattle. Yes N/A Restoration Site per 15A NCAC 02B .0295 (n) E-1 (starts @ Ephemeral No non-forested pasture grazed by cattle. Yes N/A Restoration Site per 15A NCAC 02B .0295 (o)(7) E-2 (starts @ 35.919306, -79.892575) Ephemeral No non-forested pasture grazed by cattle. Yes N/A Restoration Site per 15A NCAC 02B .0295 (o)(7) E-3 (starts @ 35.918515, -79.892390) Ditch <3’ depth (conveying SW to stream) Yes non-forested pasture grazed by cattle. *See Note N/A Restoration Site per 15A NCAC 02B .0295 (o)(8) *Buffer Mitigation Note – Assessment concludes the ditch meets 15A NCAC 02B .0295 (o)(8) (A, B, C, D & E). More information on the watershed is required to be provided in a mitigation plan for complete assessment. See rule. DocuSign Envelope ID: 458687C3-6621-4063-A57B-CA20F98B44F8 EMH Farm Site Clearwater Mitigation Solutions September 24, 2021 Page 3 of 3 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 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 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, 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 and/or nutrient offset mitigation 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 support estimates of load reduction, for review by the DWR to determine viability for nutrient offset in accordance with 15A NCAC 02B .0703. This viability assessment will expire on September 24, 2021 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 (919) 707-3637 if you have any questions regarding this correspondence. Sincerely, Paul Wojoski, Supervisor 401 and Buffer Permitting Branch PW/kym Attachments: Figure 1: Aerial Map cc: File Copy (Katie Merritt) DocuSign Envelope ID: 458687C3-6621-4063-A57B-CA20F98B44F8 NC Center for Geographic Information & Anaylsis Legend Potential Conservation Easement = 26.6 ac Intermittent/Perennial Stream Channel Ephemeral Channel UT-3 UT-1 E-2 UT-2 E-3 (ditch) E-1 NOTE: Depicted stream determinations were field verified ¯by Ms. Sue Homewood (NCDWR) on July 1, 2021. Feet 0 100 200 400 Prepared for: Clearwater Mitigation Solutions Project: EMH FARMS RIPARIAN BUFFER MITIGATION SITE Guilford County, NC Title: Drawn by: KRJ FIGURE 1 Date: Jul 2021 Scale: 1:2000 Project No.: 19-008 Forested Partially Forested DocuSign Envelope ID: 458687C3-6621-4063-A57B-CA20F98B44F8 Bank Parcel Development Package Appendices EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 APPENDIX C DATA NCDWR SWIT Forms Site Photos Bank Parcel Development Package Appendices EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 EMH Farm Site Photos (UT 1) Taken April 2022 Bank Parcel Development Package Appendices EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 EMH Farm Site Photos (UT 2, E 1, E 3) Taken April 2022 Bank Parcel Development Package Appendices EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 EMH Farm Site Photos (UT 3 and E 2) Taken April 2022 Bank Parcel Development Package Appendices EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 APPENDIX D THREATENED AND ENDANGERED SPECIES DATA Summary Letter of Federally Protected Species Survey North Carolina Natural Heritage Program (NCNHP) Report USFWS IPaC Resource List Axiom Environmental, Inc. 218 Snow Avenue, Raleigh, North Carolina 27603 423-400-8882 September 15, 2022 Mr. Kevin Yates Clearwater Mitigation Solutions 604 Macon Place Raleigh, NC 27609 Re: Federally Protected Species Survey 22-033 EMH Farms Buffer Mitigation Site, Guilford County Dear Mr. Yates: Axiom Environmental, Inc. (Axiom) is pleased to provide you with this summary letter of the results of a federally protected species survey at the EMH Farms Buffer Mitigation Bank (hereafter referred to as the Site, see figures in Appendix A, BPDP). The survey was conducted by Axiom biologists Allison Keith and Myles Lance on September 15, 2022. Protected Species The U.S. Fish and Wildlife Service (USFWS) Information for Planning and Consultation (IPaC) has identified two federally protected species to occur within or near the Site, Schweinitz’s sunflower (Helianthus schweinitzii) and Small Whorled Pogonia (Isotria medeoloides). In addition, the USFWS lists one species protected by the Bald and Golden Eagle Protection Act (BGPA), bald eagle (Haliaeetus leucocephalus). For each species, a brief discussion of habitat is included below along with the Biological Conclusion rendered based on survey results within the Site. Schweinitz’s sunflower  Habitat Description: Schweinitz's sunflower is endemic to the Piedmont of North and South Carolina. The few sites where this rhizomatous perennial herb occurs in relatively natural vegetation are found in Xeric Hardpan Forests. The species is also found along roadside rights-of-way, maintained power lines and other utility rights-of-way, edges of thickets and old pastures, clearings and edges of upland oak-pine-hickory woods and Piedmont longleaf pine forests, and other sunny or semi-sunny habitats where disturbances (e.g., mowing, clearing, grazing, storms, frequent fire) help create open or partially open areas for sunlight penetration to the ground.  Biological Conclusion: Suitable habitat for Schweinitz’s sunflower occurs within the Site along the margins of roadways, woodland edges, and the perimeter of agricultural fields. The USFWS has determined the optimal survey windows for the sunflower is late August Axiom Environmental, Inc. Mr. Kevin Yates Clearwater Mitigation Solutions September 15, 2022 Page 2 to October (or the first frost). A known population was visited and observed by Axiom biologist on September 15, 2022, prior to conducting surveys at the Site, and found this species to be in flower. Systematic surveys of suitable habitat were then conducted on Site by Axiom biologists on September 15, 2022 and identified no individuals. In addition, a review of N.C. Natural Heritage Program (NCNHP) records on September 8, 2022, indicates no known occurrence within 1.0 mile of the Site. This project will therefore have no effect on Schweinitz’s sunflower. Small Whorled Pogonia  Habitat Description: Small whorled pogonia is found in open, dry deciduous or mixed pine-deciduous forest, or along stream banks. Examples of areas providing suitable conditions (open canopy and shrub layer with a sparse herb layer) where small whorled pogonia has been found include old fields, pastures, windthrow areas, cutover forests, old orchards, and semi-permanent canopy breaks along roads, streams, lakes, and cliffs. In the Mountains and Piedmont of North Carolina, this species is usually found in association with white pine (Pinus strobus).  Biological Conclusion: The areas of disturbed mixed hardwoods within project boundaries are marginally suitable habitat for small whorled pogonia, however, proposed project activities are not anticipated to impact the understory in these areas. In addition, a September 8, 2022, review of the N.C. Natural Heritage Program (NCNHP) records indicates no occurrence of this within 1.0 mile of the Site, therefore, this project will have no effect on small whorled pogonia. Bald Eagle  Habitat Description: Habitat for bald eagle primarily consists of mature forest in proximity to large bodies of open water for foraging. Large, dominant trees are utilized for nesting sites, typically within 1.0 mile of open water.  Biological Conclusion: A review of aerial photography reveals several small ponds within one mile of the Site that may be large enough and sufficiently open to be considered potential feeding and roosting habitat. An investigation of onsite trees found no eagles or eagle nests. A September 8, 2022 review of the NCNHP records indicates no occurrence of this species within 1.0 mile of the Site. This project will therefore have no effect on bald eagle. Axiom Environmental, Inc. Mr. Kevin Yates Clearwater Mitigation Solutions September 15, 2022 Page 3 Please let us know if you have any questions concerning our findings. We appreciate the opportunity to provide you with these services. Yours truly, AXIOM ENVIRONMENTAL, INC. Allison Keith Project Scientist   NCNHDE-19281 September 8, 2022 Allison Keith Axiom Environmental 218 Snow Ave Raleigh, NC 27603 RE: EMH Farms; 22-033 Dear Allison Keith: The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide information about natural heritage resources for the project referenced above. Based on the project area mapped with your request, a query of the NCNHP database indicates that there are no records for rare species, important natural communities, natural areas, and/or conservation/managed areas within the proposed project boundary. Please note that although there may be no documentation of natural heritage elements within the project boundary, it does not imply or confirm their absence; the area may not have been surveyed. The results of this query should not be substituted for field surveys where suitable habitat exists. In the event that rare species are found within the project area, please contact the NCNHP so that we may update our records. The attached ‘Potential Occurrences’ table summarizes rare species and natural communities that have been documented within a one-mile radius of the property boundary. The proximity of these records suggests that these natural heritage elements may potentially be present in the project area if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one-mile radius of the project area, if any, are also included in this report. If a Federally-listed species is found within the project area or is indicated within a one-mile radius of the project area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS) for guidance. Contact information for USFWS offices in North Carolina is found here: https://www.fws.gov/offices/Directory/ListOffices.cfm?statecode=37. Please note that natural heritage element data are maintained for the purposes of conservation planning, project review, and scientific research, and are not intended for use as the primary criteria for regulatory decisions. Information provided by the NCNHP database may not be published without prior written notification to the NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of NCNHP data may not be redistributed without permission. The NC Natural Heritage Program may follow this letter with additional correspondence if a Dedicated Nature Preserve, Registered Heritage Area, Land and Water Fund easement, or Federally- listed species are documented near the project area. If you have questions regarding the information provided in this letter or need additional assistance, please contact Rodney A. Butler at rodney.butler@ncdcr.gov or 919-707-8603. Sincerely, NC Natural Heritage Program Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One-mile Radius of the Project Area EMH Farms Project No. 22-033 September 8, 2022 NCNHDE-19281 Element Occurrences Documented Within a One-mile Radius of the Project Area Taxonomic Group EO ID Scientific Name Common Name Last Observation Date Element Occurrence Rank Accuracy Federal Status State Status Global Rank State Rank Vascular Plant 12428 Berberis canadensis American Barberry 1956-09-09 H 3-Medium ---Special Concern Vulnerable G3G4 S2 No Natural Areas are Documented Within a One-mile Radius of the Project Area Managed Areas Documented Within a One-mile Radius of the Project Area Managed Area Name Owner Owner Type Randleman Lake Piedmont Triad Regional Water Authority Private Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.org/help. Data query generated on September 8, 2022; source: NCNHP, Q2, July 2022. Please resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database. Page 2 of 3 Powered by TCPDF (www.tcpdf.org) Page 3 of 3 Bank Parcel Development Package Appendices EMH Farm Buffer Mitigation Bank Parcel Clearwater Mitigation Solutions Guilford County, North Carolina March 2023 APPENDIX E ENVIRONMENTAL DATA RESOURCES (EDR) REPORT EXECUTIVE SUMMARY FORM-LBE-MGA ®kcehCoeG htiw tropeR ™paM suidaR RDE ehT 6 Armstrong Road, 4th floor Shelton, CT 06484 Toll Free: 800.352.0050 www.edrnet.com EMH Farms 5860 Groometown Road High Point, NC 27263 Inquiry Number: 7110565.2s September 07, 2022 TABLE OF CONTENTS SECTION PAGE Executive Summary ES1 Overview Map 2 Detail Map 3 Map Findings Summary 4 Map Findings 8 Orphan Summary 9 Government Records Searched/Data Currency Tracking GR-1 GEOCHECK ADDENDUM Physical Setting Source Addendum A-1 Physical Setting Source Summary A-2 Physical Setting SSURGO Soil Map A-5 Physical Setting Source Map A-13 Physical Setting Source Map Findings A-15 Physical Setting Source Records Searched PSGR-1 Thank you for your business. 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TC7110565.2s Page 1 EXECUTIVE SUMMARY TC7110565.2s EXECUTIVE SUMMARY 1 A search of available environmental records was conducted by Environmental Data Resources, Inc (EDR). The report was designed to assist parties seeking to meet the search requirements of EPA’s Standards and Practices for All Appropriate Inquiries (40 CFR Part 312), the ASTM Standard Practice for Environmental Site Assessments (E1527-21), the ASTM Standard Practice for Environmental Site Assessments for Forestland or Rural Property (E 2247-16), the ASTM Standard Practice for Limited Environmental Due Diligence: Transaction Screen Process (E 1528-14) or custom requirements developed for the evaluation of environmental risk associated with a parcel of real estate. TARGET PROPERTY INFORMATION ADDRESS 5860 GROOMETOWN ROAD HIGH POINT, NC 27263 COORDINATES 35.9190560 - 35ˆ 55’ 8.60’’Latitude (North): 79.8943390 - 79ˆ 53’ 39.62’’Longitude (West): Zone 17Universal Tranverse Mercator: 599756.6UTM X (Meters): 3975335.0UTM Y (Meters): 801 ft. above sea levelElevation: USGS TOPOGRAPHIC MAP ASSOCIATED WITH TARGET PROPERTY 13840509 HIGH POINT EAST, NCTarget Property Map: 2019Version Date: 13702498 PLEASANT GARDEN, NCEast Map: 2019Version Date: AERIAL PHOTOGRAPHY IN THIS REPORT 20140827, 20140705Portions of Photo from: USDASource: 7110565.2s Page 2 NO MAPPED SITES FOUND MAPPED SITES SUMMARY Target Property Address: 5860 GROOMETOWN ROAD HIGH POINT, NC 27263 Click on Map ID to see full detail. MAP RELATIVE DIST (ft. & mi.) ID DATABASE ACRONYMS ELEVATION DIRECTIONSITE NAME ADDRESS EXECUTIVE SUMMARY TC7110565.2s EXECUTIVE SUMMARY 3 TARGET PROPERTY SEARCH RESULTS The target property was not listed in any of the databases searched by EDR. DATABASES WITH NO MAPPED SITES No mapped sites were found in EDR’s search of available ("reasonably ascertainable ") government records either on the target property or within the search radius around the target property for the following databases: STANDARD ENVIRONMENTAL RECORDS Lists of Federal NPL (Superfund) sites NPL National Priority List Proposed NPL Proposed National Priority List Sites NPL LIENS Federal Superfund Liens Lists of Federal Delisted NPL sites Delisted NPL National Priority List Deletions Lists of Federal sites subject to CERCLA removals and CERCLA orders FEDERAL FACILITY Federal Facility Site Information listing SEMS Superfund Enterprise Management System Lists of Federal CERCLA sites with NFRAP SEMS-ARCHIVE Superfund Enterprise Management System Archive Lists of Federal RCRA facilities undergoing Corrective Action CORRACTS Corrective Action Report Lists of Federal RCRA TSD facilities RCRA-TSDF RCRA - Treatment, Storage and Disposal Lists of Federal RCRA generators RCRA-LQG RCRA - Large Quantity Generators RCRA-SQG RCRA - Small Quantity Generators RCRA-VSQG RCRA - Very Small Quantity Generators (Formerly Conditionally Exempt Small Quantity Generators) Federal institutional controls / engineering controls registries LUCIS Land Use Control Information System EXECUTIVE SUMMARY TC7110565.2s EXECUTIVE SUMMARY 4 US ENG CONTROLS Engineering Controls Sites List US INST CONTROLS Institutional Controls Sites List Federal ERNS list ERNS Emergency Response Notification System Lists of state- and tribal (Superfund) equivalent sites NC HSDS Hazardous Substance Disposal Site Lists of state- and tribal hazardous waste facilities SHWS Inactive Hazardous Sites Inventory Lists of state and tribal landfills and solid waste disposal facilities SWF/LF List of Solid Waste Facilities OLI Old Landfill Inventory DEBRIS Solid Waste Active Disaster Debris Sites Listing LCID Land-Clearing and Inert Debris (LCID) Landfill Notifications Lists of state and tribal leaking storage tanks LAST Leaking Aboveground Storage Tanks LUST Regional UST Database INDIAN LUST Leaking Underground Storage Tanks on Indian Land LUST TRUST State Trust Fund Database Lists of state and tribal registered storage tanks FEMA UST Underground Storage Tank Listing UST Petroleum Underground Storage Tank Database AST AST Database INDIAN UST Underground Storage Tanks on Indian Land State and tribal institutional control / engineering control registries INST CONTROL No Further Action Sites With Land Use Restrictions Monitoring Lists of state and tribal voluntary cleanup sites VCP Responsible Party Voluntary Action Sites INDIAN VCP Voluntary Cleanup Priority Listing Lists of state and tribal brownfield sites BROWNFIELDS Brownfields Projects Inventory ADDITIONAL ENVIRONMENTAL RECORDS Local Brownfield lists US BROWNFIELDS A Listing of Brownfields Sites EXECUTIVE SUMMARY TC7110565.2s EXECUTIVE SUMMARY 5 Local Lists of Landfill / Solid Waste Disposal Sites SWRCY Recycling Center Listing HIST LF Solid Waste Facility Listing INDIAN ODI Report on the Status of Open Dumps on Indian Lands ODI Open Dump Inventory DEBRIS REGION 9 Torres Martinez Reservation Illegal Dump Site Locations IHS OPEN DUMPS Open Dumps on Indian Land Local Lists of Hazardous waste / Contaminated Sites US HIST CDL Delisted National Clandestine Laboratory Register US CDL National Clandestine Laboratory Register PFAS PFAS Contamination Site Listing Local Land Records LIENS 2 CERCLA Lien Information Records of Emergency Release Reports HMIRS Hazardous Materials Information Reporting System SPILLS Spills Incident Listing IMD Incident Management Database SPILLS 90 SPILLS 90 data from FirstSearch SPILLS 80 SPILLS 80 data from FirstSearch Other Ascertainable Records RCRA NonGen / NLR RCRA - Non Generators / No Longer Regulated FUDS Formerly Used Defense Sites DOD Department of Defense Sites SCRD DRYCLEANERS State Coalition for Remediation of Drycleaners Listing US FIN ASSUR Financial Assurance Information EPA WATCH LIST EPA WATCH LIST 2020 COR ACTION 2020 Corrective Action Program List TSCA Toxic Substances Control Act TRIS Toxic Chemical Release Inventory System SSTS Section 7 Tracking Systems ROD Records Of Decision RMP Risk Management Plans RAATS RCRA Administrative Action Tracking System PRP Potentially Responsible Parties PADS PCB Activity Database System ICIS Integrated Compliance Information System FTTS FIFRA/ TSCA Tracking System - FIFRA (Federal Insecticide, Fungicide, & Rodenticide Act)/TSCA (Toxic Substances Control Act) MLTS Material Licensing Tracking System COAL ASH DOE Steam-Electric Plant Operation Data COAL ASH EPA Coal Combustion Residues Surface Impoundments List PCB TRANSFORMER PCB Transformer Registration Database RADINFO Radiation Information Database HIST FTTS FIFRA/TSCA Tracking System Administrative Case Listing DOT OPS Incident and Accident Data EXECUTIVE SUMMARY TC7110565.2s EXECUTIVE SUMMARY 6 CONSENT Superfund (CERCLA) Consent Decrees INDIAN RESERV Indian Reservations FUSRAP Formerly Utilized Sites Remedial Action Program UMTRA Uranium Mill Tailings Sites LEAD SMELTERS Lead Smelter Sites US AIRS Aerometric Information Retrieval System Facility Subsystem US MINES Mines Master Index File ABANDONED MINES Abandoned Mines FINDS Facility Index System/Facility Registry System DOCKET HWC Hazardous Waste Compliance Docket Listing UXO Unexploded Ordnance Sites ECHO Enforcement & Compliance History Information FUELS PROGRAM EPA Fuels Program Registered Listing AIRS Air Quality Permit Listing ASBESTOS ASBESTOS COAL ASH Coal Ash Disposal Sites DRYCLEANERS Drycleaning Sites Financial Assurance Financial Assurance Information Listing NPDES NPDES Facility Location Listing UIC Underground Injection Wells Listing AOP Animal Operation Permits Listing MINES MRDS Mineral Resources Data System CCB Coal Ash Structural Fills (CCB) Listing SEPT HAULERS Permitted Septage Haulers Listing PCSRP Petroleum-Contaminated Soil Remediation Permits EDR HIGH RISK HISTORICAL RECORDS EDR Exclusive Records EDR MGP EDR Proprietary Manufactured Gas Plants EDR Hist Auto EDR Exclusive Historical Auto Stations EDR Hist Cleaner EDR Exclusive Historical Cleaners EDR RECOVERED GOVERNMENT ARCHIVES Exclusive Recovered Govt. Archives RGA HWS Recovered Government Archive State Hazardous Waste Facilities List RGA LF Recovered Government Archive Solid Waste Facilities List RGA LUST Recovered Government Archive Leaking Underground Storage Tank SURROUNDING SITES: SEARCH RESULTS Surrounding sites were not identified. Unmappable (orphan) sites are not considered in the foregoing analysis. EXECUTIVE SUMMARY TC7110565.2s EXECUTIVE SUMMARY 7 There were no unmapped sites in this report. 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