BPDP for PN_EMH Farm

March 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
[e-mail]
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
[e-mail]
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
[e-mail]
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
[e-mail]
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
[e-mail]
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
[e-mail]
“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
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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
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")
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9
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1 19
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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: [e-mail]

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
[e-mail].

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: [e-mail] )

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 [phone] 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 [e-mail] 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.
Please contact EDR at 1-800-352-0050
with any questions or comments.
Disclaimer - Copyright and Trademark Notice
This Report contains certain information obtained from a variety of public and other sources reasonably available to Environmental Data
Resources, LLC. It cannot be concluded from this Report that coverage information for the target and surrounding properties does not exist
from other sources. This Report is provided on an "AS IS", "AS AVAILABLE" basis. NO WARRANTY EXPRESS OR IMPLIED IS MADE
WHATSOEVER IN CONNECTION WITH THIS REPORT. ENVIRONMENTAL DATA RESOURCES, LLC AND ITS SUBSIDIARIES,
AFFILIATES AND THIRD PARTY SUPPLIERS DISCLAIM ALL WARRANTIES, OF ANY KIND OR NATURE, EXPRESS OR IMPLIED,
ARISING OUT OF OR RELATED TO THIS REPORT OR ANY OF THE DATA AND INFORMATION PROVIDED IN THIS REPORT,
INCLUDING WITHOUT LIMITATION, ANY WARRANTIES REGARDING ACCURACY, QUALITY, CORRECTNESS, COMPLETENESS,
COMPREHENSIVENESS, SUITABILITY, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT,
MISAPPROPRIATION, OR OTHERWISE. ALL RISK IS ASSUMED BY THE USER. IN NO EVENT SHALL ENVIRONMENTAL DATA
RESOURCES, LLC OR ITS SUBSIDIARIES, AFFILIATES OR THIRD PARTY SUPPLIERS BE LIABLE TO ANYONE FOR ANY DIRECT,
INCIDENTAL, INDIRECT, SPECIAL, CONSEQUENTIAL OR OTHER DAMAGES OF ANY TYPE OR KIND (INCLUDING BUT NOT LIMITED
TO LOSS OF PROFITS, LOSS OF USE, OR LOSS OF DATA) INFORMATION PROVIDED IN THIS REPORT. Any analyses, estimates,
ratings, environmental risk levels, or risk codes provided in this Report are provided for illustrative purposes only, and are not intended to
provide, nor should they be interpreted as providing any facts regarding, or prediction or forecast of, any environmental risk for any property.
Only an assessment performed by a qualified environmental professional can provide findings, opinions or conclusions regarding the
environmental risk or conditions in, on or at any property.
Copyright 2022 by Environmental Data Resources, LLC. All rights reserved. Reproduction in any media or format, in whole or in part, of any
report or map of Environmental Data Resources, LLC, or its affiliates, is prohibited without prior written permission.
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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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