BPDP for PN

Brooks Swamp BPDP Comment-Response
Neuse HUC# 03020201, Excluding Falls Lake 1 December 2023

Comment-Response for Brooks Swamp BPDP dated August 11, 2023
The following contains RestorEcology Neuse, LLC’s (RestorEcology) responses to comments from the NC
Division of Water Resources (DWR) dated December 12, 2023 on the Brooks Swamp Bank Parcel
Development Package (BPDP) dated August 11, 2023.
Page 1
1. General Comments:
-Nutrient offset credits are not allowed in the Restoration and Enhancement areas of the
swamp areas because they are not agricultural landuses. Remove all nutrient offsets from the
table and figures in these areas.
-Since restoration and enhancement within the wooded areas were primarily allowed if full
removal of privet was done and an Adaptive Management plan was established, it is
necessary to depict the areas of privet and canopy privet on the supporting figures w/ unique
color symbology and include a Privet Management Plan in the text of this Plan with its own
section. Must include a committment for how privet will be managed for 5 years of the
monitoring. Without full removal and an AMP, these areas will only be valid for Preservation
credits.
Response: Non Ag lands on the Parcel will only be used for Riparian Buffer Credits. Section 4.6
Privet Management Plan has been added as requested.
2. Add the DWR ID# which is 2023-0163 v2.
Response: Revised as requested.
Page 3
1. Include a figure showing "planted areas" that will be planted according to the tables included in the
plan (swamp/wet areas vs upland, privet areas, etc.)
Response: Added Planting Workplan as Figure 8.
Page 4
1. When referring to nutrient offsets, we can't use the word "mitigation". Mitigation only applies to
buffer.
Response: Revised as requested.
2. Remove text.
Response: Revised as requested.
3. Insert “mitigation”
Response: Revised as requested.
Brooks Swamp BPDP Comment-Response
Neuse HUC# 03020201, Excluding Falls Lake 2 December 2023

4. Insert “riparian”
Response: Revised as requested.
5. Insert “adjacent to two streams”
Response: Revised as requested.
6. Insert “riparian areas adjacent to streams.”
Response: Revised as requested.
7. Insert “and adjacent riparian areas out to a maximum of 200' landward from existing stream top of
banks.”
Response: Revised as requested.
8. Insert “nutrient offset credits”
Response: Revised as requested.
9. Insert “03020201 (excluding the Falls Watershed) to offset authorized impacts.”
Response: Revised as requested.
10. Insert “and depicts where riparian buffer credits and nutrient offset credits can be sold from this
site.”
Response: Revised as requested.
Page 6
1. This will need to be updated after updating the table
Response: Elected to remove this from the table since it duplicates the Project Credits Table.
Page 10
1. Insert “as they were observed during the DWR site visit in March along UT1,”
Response: Revised as requested.
2. There are 17 in the table, you have to plant what you list in the table. If only planting 6 species, you
have to list out those 6 species and DWR has to approve those 6 species as part of this plan review.
Include the approximate density of those 6. For the rest of the stems presented, you will need to
show as "possible substitutes" and then include the maximum density you will be planting those
substitutes if you needed them.
Response: Revised as requested.
3. No figure is included showing the proposed "planting area". Include a figure and reference it here.
Response: Revised as requested.
Brooks Swamp BPDP Comment-Response
Neuse HUC# 03020201, Excluding Falls Lake 3 December 2023

4. There is also privet in restoration areas. Describe how these areas will be handled. See viability
letter.
Response: Revised as requested.
5. Include a column for "tree/shrub" and fill in accordingly.
Response: Revised as requested.
6. You have to include exactly what you are planting. Pick the other species as "possible substitutes"
and include the density.
Response: Revised as requested.

Page 11
1. Add "shrub/tree" column and fill in accordingly.
Response: Revised as requested.
2. No figure is provided showing where the "Swamp wetland" areas are. Add this figure and reference
it here. Remember, this is being proposed as an "alternative" planting plan than what rule requires in
that you are wanting to plant "softwoods" such as Cypress and White Cedar. Therefore these two
species have to be site selected and just in wet areas. You will need to explain why these two species
need to be a part of the planting plan. and indicate where you will be planting them.
Response: Revised as requested.
3. DWR does not approve Tag Alder for nutrient offset or buffer mitigation projects since the goal is
not to add nutrients to soil but to remove it. Tag alder adds nutrients.
Response: Revised as requested.
4. Include a table showing what will be seeded on the site. Need to ensure that you are using
perennial and annual species in the seed mix.
Response: Revised as requested.
5. Push "December" back to a later date.
Response: Revised as requested.
6. Speak to privet removal on a broader level; wasn't the privet described in these areas as "complete
canopy"? need a privet management plan describing how the privet will be managed (see viability
letter) through site implementation and monitoring. See Figure comments as well where
Enhancement is being proposed.
Response: Revised as requested.
7. I don't see wetland tolerant species pointed out in Table 8.1. Maybe just use Table 8.2 for those.
Brooks Swamp BPDP Comment-Response
Neuse HUC# 03020201, Excluding Falls Lake 4 December 2023

Response: Revised as requested.
8. Need to speak to the barn area and the debris that was noted in the site viability letter around it.
Need to acknowledge that the barn footprint is excluded from credit area and is shown in a
supporting figure as "Non credit Area.”
Response: Upon further inspection, the “barn” mentioned in the viability letter is not intact and
is instead a collapsed shed. There is another, smaller collapsed shed within the same woodland
area. Both of these collapsed sheds will be removed and properly disposed as part of site
construction activities. The footprint of the sheds (approximately 15-ft x 15-ft for each) will be
seeded with a temporary cover mix after removal, and 2-4 trees will be planted within each
footprint to lessen invasive growth.
9. Add Section 4.6 to be a privet management plan.
Response: Revised as requested.
10. Is this 2% of the planted area?
Response: Yes, this is confirmed.
Page 12
1. Will you want to adopt the new monitoring schedule agreed to at the annual provider meeting,
where you only provide average vigor per plot and height data in years 1, 3 and 5 instead of every
year? All other monitoring date is still required for every year. Vigor would be measured as an average
per plot and Height will be measured per stem per plot.
Response: Yes, we will adopt the new monitoring schedule. Section 5.1 has been revised to
reflect this.
Page 13
1. The Project Credit Table has to be moved to this section. It is currently at the back of the Plan.
Response: Revised as requested.
Page 14
1. This will change after edits are made.
Response: Replaced this table with Project Credits Table.
Page 18
1. Show Barn footprint.
Response: Because the barn was found to be a collapsed shed upon further inspection, it will
instead be removed from the easement (See Page 11, #8 Comment Response).
Page 19, Figure 3
Brooks Swamp BPDP Comment-Response
Neuse HUC# 03020201, Excluding Falls Lake 5 December 2023

1. Change to "Credit Service Area"
Response: Revised as requested.
2. Insert “for Riparian Buffer Credits and Nutrient Offset Credits”
Response: Revised as requested.
Page 23, Figure 7
1. Show barn footprint as "non credit area" and remove from Preservation.
Response: Because the barn was found to be a collapsed shed upon further inspection, it will
instead be removed from the easement (See Page 11, #8 Comment Response).
2. This whole area in the woods shown as Restoration 0-100' needs to be shown as Restoration for
RBC only since it's not convertible to NOC. Change the symbology of these areas to differentiate
between Restoration for both vs Restoration for buffer only. Update the project credit table
accordingly.
Response: Revised as requested.
3. The privet removal needs to be represented more broadly. Maybe do this on the same figure I have
requested you show "Proposed Planting Area". That would be the best place to put it.
Response: Revised as requested.
4. This enhancement area is not convertible to NOC. Clarify in the legend as "Riparian Enhancement
for Buffer Credit.”
Response: Revised as requested.
5. This area needs to be shown as Restoration for RBC only since it's not convertible to NOC.
Response: Revised as requested.
6. Change to riparian preservation for buffer credit.
Response: Revised as requested.
7. Once you fix the orange areas that are not in Ag land and change to represent "non-ag Riparian
Restoration" vs Restoration areas in ag. fields, you can then change to "Riparian Restoration for Buffer
Credit". Make sure the table is updated accordingly.
Response: Revised as requested.
8. Change to Riparian Enhancement for Buffer Credit.
Response: Revised as requested.
9. Change to Riparian Enhancement for Nutrient Offset.
Response: Revised to “Riparian Restoration for NOC.”
Brooks Swamp BPDP Comment-Response
Neuse HUC# 03020201, Excluding Falls Lake 6 December 2023

Page 24, Riparian Zones Figure
1. Label the 200’ line.
Response: Revised as requested.
2. Label the 100’ line.
Response: Revised as requested.
3. What is this line representing? It's not blue or pink as shown in the legend.
Response: This gray line differentiated the UT1 vs. UT2 areas. Changed it to blue so that it isn’t
as visible.
4. Change "buffer" to "Riparian" and add other changes as requested on previous figure.
Response: Revised as requested.
5. The TOB is not presented here. Add it.
Response: Revised as requested.
Page 25, Monitoring Plan Figure
1. Move this plot inwards closer to the 100' line.
Response: Revised as requested
2. Label widths.
Response: Revised as requested
3. Call out privet areas or privet management areas, call out swamp/wetland areas.
Response: Revised as requested
4. Label width
Response: Revised as requested
5. What is this line representing?
Response: This line divides the credit areas between UT1 and UT2. Changed the color to make
the line less visible.
6. Add a plot to this restoration area since it's privet heavy and we need monitoring date here.
Response: See revised Figure 10: the Privet Management Area represents 11% of the Parcel
acreage. There is already a monitoring plot in the Privet Management Area of Non Ag Riparian
Restoration in the southwest corner of the Parcel, as well as a plot in the Non Ag Riparian Enhancement
Area. These represent 25% of the Parcel monitoring plots, which seems adequate to RestorEcology for
monitoring these areas. Would request that no additional plot be added in the Privet Management
Area.
Brooks Swamp BPDP Comment-Response
Neuse HUC# 03020201, Excluding Falls Lake 7 December 2023

7. Update legend and symbology based on comments made previously.
Response: Revised as requested
Page 29, Project Credits Table
1. This table is hard to compare to the supporting credit figure.
Response: Revised as requested
2. Check no per the MBI
Response: Revised as requested
3. Check NO per the MBI
Response: Revised as requested
4. Move to section 7.0
Response: Revised as requested
5. Differentiate Non-ag Riparian Restoration from Ag Riparian Restoration on these rows so that I can
tell where the total area is being measured. For the non-ag riparian restoration rows, check "NO" for
the "Convertible to Nutrient Offset" column.
Response: Revised as requested
6. Remove the ft2 that makes up the footprint of the barn.
Response: Because the barn was found to be a collapsed shed upon further inspection, it will
instead be removed from the easement (See Page 11, #8 Comment Response).
7. Change project ID to be version 2.
Response: Revised as requested

BROOKS SWAMP
Bank Parcel Development Package

RESTORECOLOGY NEUSE, LLC
Version 2
December 21, 2023
DWR# 2023-0163v2
HUC: 03020201
Neuse River Basin, Excluding Falls Lake Watershed
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 1 December 2023

Table of Contents
1.0 Project Introduction ......................................................................................................................................... 3
1.1 Project Description .................................................................................................................................................... 3
2.0 Mitigation Project Summary .................................................................................................................................... 3
2.1 Project Goals .............................................................................................................................................................. 3
2.2 Existing Parcel Conditions ......................................................................................................................................... 4
2.3 Site Viability for Buffer Mitigation and Nutrient offset........................................................................................... 5
2.4 Watershed Characterization ..................................................................................................................................... 6
2.5 Soils ............................................................................................................................................................................. 6
2.6 Existing Vegetative Communities ............................................................................................................................. 7
2.7 Threatened and Endangered Species ....................................................................................................................... 8
2.8 Cultural Resources ..................................................................................................................................................... 8
2.9 FEMA Floodplain Compliance ................................................................................................................................... 8
2.10 Parcel Location, Parcel Constraints, and Access .................................................................................................... 8
2.11 Other Environmental Conditions ............................................................................................................................ 8
3.0 Site Protection Instrument ...................................................................................................................................... 9
4.0 Mitigation Work Plan ............................................................................................................................................... 9
4.1 Parcel Preparation ..................................................................................................................................................... 9
4.2 Riparian Area Restoration Activities ......................................................................................................................... 9
4.3 Riparian Area Enhancement Activities ................................................................................................................... 11
4.4 Riparian Area Preservation Activities ..................................................................................................................... 11
4.5 DWR As-Built Evaluation ......................................................................................................................................... 12
4.6 Privet Management Plan ......................................................................................................................................... 12
5.0 Monitoring and Maintenance Plan ........................................................................................................................ 12
5.1 Monitoring Protocol ................................................................................................................................................ 12
5.2 Parcel Maintenance ................................................................................................................................................. 13
5.3 Easement Boundaries .............................................................................................................................................. 13
6.0 Financial Assurance and Long-Term Management ................................................................................................ 13
6.1 Financial Assurances ................................................................................................................................................ 13
6.2 Long-Term Management ......................................................................................................................................... 14
7.0 Project Credit Potential ......................................................................................................................................... 14
7.1 Riparian Buffer Credits ............................................................................................................................................ 14
7.2 Nutrient Offset Credits ............................................................................................................................................ 14
8.0 References ............................................................................................................................................................. 15

Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 2 December 2023

Tables
Table 1.0 - Water Quality and Ecology Goals for the Parcel
Table 2.0 - Parcel Summary
Table 3.0 - Site Viability Summary
Table 4.0 - Drainage Areas and Land Uses
Table 5.0 - Soil Types
Table 6.0 - Existing Vegetation
Table 7.0 - Site Protection Instrument
Table 8.1 - Planting List for Upland
Table 8.2 - Planting List for Swamp Wetland
Table 8.3 - Permanent Seed Mix
Table 9.0 – Brooks Swamp, #2023-0163v2, Project Credit Table

Figures
Figure 1 – Vicinity Map
Figure 2 – Site Map
Figure 3 – Service Area Map
Figure 4 – USGS Topographic Map
Figure 5 – Watershed Map
Figure 6 – Soils Map
Figure 7 – Credit Areas Map
Figure 8 – Planting Workplan
Figure 9 – Riparian Zones Map
Figure 10 – Monitoring Plan

Appendices
Appendix A – Current Land Use Photographs
Appendix B – Historical Aerials
Appendix C – Stream Determination
Appendix D – Buffer Viability
Appendix E – Regulatory Correspondence
Appendix F – Other Environmental Conditions

Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 3 December 2023

1.0 Project Introduction
The Brooks Swamp Buffer Mitigation and Nutrient Offset Bank Parcel (the Parcel) is proposed in the
Neuse River Basin HUC# 03020201, excluding the Falls Lake Watershed (Neuse 01). The Parcel (NC
Division of Water Resources [DWR]# 2023-0163v2) is being developed under the Mitigation Banking
Instrument (MBI) made and entered into by RestorEcology Neuse, LLC (RestorEcology) and the NC
Department of Environmental Quality – Division of Water Resources (DWR). This Bank Parcel
Development Package (BPDP) has been prepared in accordance with the MBI and applicable State of NC
Regulations (15A NCAC 02B .0295 and §.0703).
The Parcel has received a Stream Determination Letter dated March 1, 2023, and a Site Viability Letter
dated June 27, 2023.
1.1 Project Description
The Parcel is located west of Old Mt. Olive Highway in unincorporated Wayne County, North Carolina
near the Dudley township (Lat/Lon Coordinates: 35.2487418°N, 78.0413133°W). Directions to the Parcel
are included in Figure 1. The property containing the Parcel has historically been cropland and that is
the ongoing use. The Parcel is in the Neuse 01, within the Brooks Swamp 12-digit HUC 030202011401,
and Brooks Swamp is the named receiving stream immediately south of the Parcel.
To develop the Parcel as a Neuse 01 riparian buffer mitigation and nutrient offset bank, approximately
9.2 acres of riparian cropland adjacent to two streams will be planted with native hardwood trees and
shrubs. This will lessen nutrient inputs into the streams from agricultural activities and provide restored
stream buffers and adjacent riparian areas out to a maximum of 200' landward from existing stream top
of banks. Existing wooded riparian areas adjacent to streams within the Parcel will be preserved and
enhanced, resulting in a total Parcel size of approximately 11.1 acres (Figure 2). Riparian buffer credits
and nutrient offset credits will be generated by the Parcel and sold to permittees in the Neuse 03020201
(excluding the Falls Watershed) to offset authorized impacts. The Parcel Service Area Map is provided as
Figure 3 and depicts where riparian buffer credits and nutrient offset credits can sold from this site.
2.0 Mitigation Project Summary
2.1 Project Goals
The overarching goals of the Parcel are to improve water quality and ecology in streams by restoring and
expanding a hardwood riparian corridor. These improvements will positively affect Brooks Swamp,
which flows to Thoroughfare Swamp and eventually into the Neuse River. Specific goals are described in
Table 1.0 as follows:
Table 1.0 - Water Quality and Ecology Goals for the Parcel
Water Quality and Ecology Goals Objectives
Decrease nutrient levels Converting cropland along the streams to a
restored hardwood riparian corridor will diminish
nutrient inputs directly into the streams and
provide a forested area where nutrient inputs can
be further reduced by biogeochemical processes
in the soil before entering the streams.
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 4 December 2023

Water Quality and Ecology Goals Objectives
Decrease sediment input Providing a restored hardwood riparian corridor
along the streams will filter and decrease
sediment flows from adjacent fields. Restoring
and preserving wooded floodplains along the
streams will allow for deposition of off-site
sediment sources in the floodplain.
Decrease water temperature and increase
dissolved oxygen concentrations
Increased shading of streams as the restored
hardwood forest matures will decrease water
temperatures and allow for increased dissolved
oxygen concentrations.
Restore appropriate terrestrial habitat Invasive seed sources in the Parcel will be treated
to promote establishment of a restored native
hardwood forest community.
Permanently protect Parcel The Parcel will be protected by a perpetual
conservation easement.

2.2 Existing Parcel Conditions
The Parcel has historically been used as cropland. Viable Parcel features and existing riparian conditions
are described as follows (see Figure 2 for feature references, and photos in Appendix A):
Unnamed Tributary (UT) 1: UT1 is a modified natural stream that flows north to south on the western
side of the Parcel before confluencing with Brooks Swamp. The UT1 centerline is the property and
Parcel boundary to the west. It is an intermittent stream, with cropland up to the banks on both sides
for most of its length. There is a small woodland area on the north end and a narrow strip of riparian
woodland (5 to 30 feet) on the south end. The cropland areas along the left bank of UT1 will be restored
via plantings described in Section 4.0.
UT2: UT2 is a perennial natural stream that flows northeast to southwest on the eastern side of the
Parcel before confluencing with Brooks Swamp. The UT2 centerline is the property and Parcel boundary
to the east. The stream’s right bank has a narrow existing riparian woodland ranging from 30 to 60 feet
wide, with a cropland area that extends out beyond 200 feet. The majority of the UT2 floodplain is low
and swampy, with scattered shrubs and trees amid herbaceous wetland vegetation. The cropland areas
along the right bank of UT2 will be restored via plantings described in Section 4.0.
As depicted in the historical aerial photographs provided in Appendix B, land use has remained relatively
unchanged since at least 1993. Cropland has been the primary agricultural use. As of the date of this
BPDP, the current land use of cropland has not changed since the Site Viability Letter issued June 27,
2023.
Table 2.0 below summarizes the Parcel information, credit yield, and project schedule anticipated.

Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 5 December 2023

Table 2.0 - Parcel Summary
Project Name Brooks Swamp
12-Digit Hydrologic Unit Code 030202011401
Watershed Neuse River Basin, Excluding Falls Lake
Location (Lat/Lon) 35.2487418°N, 78.0413133°W
Site Protection Instrument Conservation Easement to Long-Term Steward at
Closing Following BPDP and MBI Approval
BPDP Submittal Date December 21, 2023
Anticipated Planting Date February 20241
As-Built Report Date May 2024
MY1 Report Date November 2024
MY2 Report Date November 2025
MY3 Report Date November 2026
MY4 Report Date November 2027
MY5 Report Date November 2028
Anticipated Closeout Date June 2029
1Planting is anticipated to occur during the February 2024 – May 2024 planting season.
2.3 Site Viability for Buffer Mitigation and Nutrient offset
On January 19, 2023, DWR conducted an on-site review of Parcel stream features and issued a
Determination for Applicability to the Neuse Buffer Rules 15A NCAC 02B .0714 (Stream Determination
Letter, Appendix C) for the Parcel dated March 1, 2023. The Parcel was known at the time as the Price
Farm and has since been formally named Brooks Swamp Parcel.
On March 22, 2023, DWR conducted a site visit and issued a Site Viability Letter for the Parcel June 27,
2023 (Appendix D). The evaluation was made from Top of Bank (TOB) and landward 200 feet from each
feature for buffer mitigation pursuant to 15A NCAC 02B .0295 and for nutrient offset credits pursuant to
§.0703 using §.0295 to define the mitigation type determinations.
DWR’s evaluation of the features onsite and their associated mitigation determination for the riparian
areas are detailed in the Site Viability Letter in Appendix D. The following table summarizes the Parcel
features and the results of DWR’s evaluation:

Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 6 December 2023

Table 3.0 - Site Viability Summary
Parcel Feature Classification Buffer Credit Viability Nutrient Offset
Viability
UT1 Stream • Viable for Restoration (non-
forested fields and densely-
populated privet stands1)
• Viable for Preservation (forested
areas2)
• Viable (non-forested
fields3)
UT2 Stream • Viable for Restoration (non-
forested fields and densely-
populated privet stands1)
• Viable for Enhancement (partially
forested area with privet1)
• Viable for Preservation (forested
areas2)
• Viable (non-forested
fields3)
115A NCAC 02B .0295(n)
215A NCAC 02B .0295(o)(5)
3DWR, Methodology and Calculations for Nutrient Reduction associated with Riparian Buffer
Establishment

2.4 Watershed Characterization
The Parcel is located within the Neuse 01, on two unnamed tributaries to Brooks Swamp. The UT1 and
UT2 watersheds have a majority use of agriculture, with a mixture of residential, wooded, and
educational uses as well (Figure 4, Figure 5). The watersheds in Figure 5 were delineated using 2-foot-
interval topographic contours made available by NC One Map.
Table 4.0 - Drainage Areas and Land Uses
Feature Drainage Area (Ac) Land Uses1
UT1 66.3 56% Agricultural
39% Developed
5% Forested
UT2 317.9 62% Agricultural
13% Developed
25% Forested
1Land uses assessed via aerial photography.
2.5 Soils
The Parcel and its stream features are shown in Figure 6 on the Wayne County Soil Survey, dated 1974.
The following table describes Parcel soil types and descriptions:
Table 5.0 – Soil Types
Map Unit Name Description
NoB – Norfolk loamy
sand, 2 – 6% slopes
This well drained soil occurs on smooth sides of divides. Infiltration is
moderate, and surface runoff is medium. The seasonal high water table
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 7 December 2023

Map Unit Name Description
is at a depth greater than 60 inches. Needleleaf trees are recommended
in the soil survey for planting.
WaB – Wagram loamy
sand, 0 – 6% slopes
This well drained soil is on slightly convex, smooth and broad divides.
Infiltration is rapid, and surface runoff is slow. The seasonal high water
table is at a depth greater than 60 inches. The surface layer is prone to
low fertility.1 Needleleaf trees are recommended in the soil survey for
planting.
RyB2 – Ruston sandy
loam, 2 – 6% slopes,
eroded
This well drained soil occurs on smooth sides of divides. Infiltration is
moderately slow and surface runoff is medium. The seasonal high water
table is at a depth greater than 60 inches. Needleleaf trees are
recommended in the soil survey for planting.
Bb – Bibb sandy loam This poorly drained soil occurs on nearly-level floodplains. Infiltration is
moderate and surface runoff is slow, with ponding water in places and
frequent flooding. The seasonal high water table is at the surface. Wet-
tolerant broadleaf deciduous trees are recommended for planting.
1The ongoing cultivation at the Parcel should mitigate this tendency.
2.6 Existing Vegetative Communities
Existing vegetation in the Parcel consists of cropland, mature hardwood forest, and swamp. Typical
vegetation observed in the existing forest is summarized in Table 6.0.
Table 6.0 - Existing Vegetation
Scientific Name Common Name
Overstory
Quercus rubra Southern red oak1
Liriodendron tulipifera Tulip poplar1
Acer rubrum Red maple1
Morus rubra Mulberry
Nyssa aquatica Swamp blackgum
Quercus nigra Water oak
Fraxinus pennsylvanica Green ash
Pinus taeda Loblolly pine
Salix nigra Black willow
Understory
Liquidambar styraciflua Sweet gum1
Alnus serrulata Tag alder1
Prunus caroliniana Carolina cherrylaurel
Magnolia virginiana Sweetbay
Ligustrum sinense Chinese privet
Arundinaria gigantea Giant cane
Sassafras albidum Sassafras
Vitis labrusca Fox grape
Herbaceous
Vitis rotundifolia Muscadine grapevine1
Smilax rotundifolia Greenbrier1
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 8 December 2023

Scientific Name Common Name
Saururus cernuus Lizard tail1
Toxicodendron radicans Poison ivy
Woodwardia aerolata Netted chain fern
Athyrium felix-femina Common ladyfern
Microstegium
vimineum
Microstegium
1Dominant in forest layer.
2.7 Threatened and Endangered Species
RestorEcology initiated regulatory coordination with the U.S. Fish & Wildlife Service (USFWS) via letter
and self-certification on July 17, 2023 (see Appendix E). The Official Species List from (USFWS) contained
five species: tricolored bat (Perimyotis subflavus) – Proposed Endangered, red-cockaded woodpecker
(Picoides borealis) – Endangered, Neuse River waterdog (Necturus lewisi) – Threatened, Carolina
madtom (Noturus furiosus) – Endangered, and monarch butterfly (Danaus plexippus) – Candidate. As
part of coordination with the USFWS, RestorEcology also purchased a Natural Heritage Resource Report
from the NC Department of Natural and Cultural Resource – Natural Heritage Program (NCNHP) dated
July 13, 2023. The NCNHP Report identified no element occurrences intersecting with the Parcel. An
occurrence of the state-threatened Ironcolor shiner (Notropis chalybaeus) was noted within one mile of
the Parcel. As summarized in the Species Conclusion Table and confirmed in USFWS’ response dated
July 27, 2023, the Parcel is not likely to adversely affect any listed species (see Appendix E).
2.8 Cultural Resources
RestorEcology initiated regulatory coordination via letter to the NC Department of Natural and Cultural
Resources – State Historic Preservation Office (SHPO) dated July 17, 2023. SHPO responded via letter on
August 2, 2023 that SHPO is aware of no historic resources that would be affected by the Parcel
(Appendix E).
2.9 FEMA Floodplain Compliance
As mapped by the Wayne County GIS, a portion of the Parcel at the bottom/southern end of UT1 and
UT2 is within the 500-year and 100-year floodplain for Brooks Swamp. If required, a floodplain
development permit for the Parcel will be obtained from the Wayne County Planning Department
before planting and will be submitted to DWR along with the As-Built Report.
2.10 Parcel Location, Parcel Constraints, and Access
The Parcel is located west of Old Mt. Olive Highway and is accessed via an existing 30-foot-wide
ingress/egress easement (See Figure 2). The Parcel is located outside of the NCDOT 60-foot right-of-way
for Old Mt. Olive Highway. There are no utilities, easements, or constraints located within the Parcel.
UT1 is a ditched natural stream and ongoing ditch maintenance from the right bank west of the Parcel is
anticipated.
2.11 Other Environmental Conditions
A Lightbox – Environmental Data Resources (EDR) report was prepared on August 7, 2023. An excerpt
from the EDR Report is provided in Appendix F. The full report can be made available upon request by
the DWR. The Parcel was not listed in any of the databases searched by EDR. The Georgia Pacific Corp
Comp Hazardous Substance Disposal and State Hazardous Waste Site (Facility Id: NCD000813659) was
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 9 December 2023

mapped 0.71 – 0.74 miles northwest and at a higher elevation than the Parcel. An excerpt from the
Draft NPDES Permit# NC0090051 for the Georgia Pacific Dudley Plywood Facility (the Facility) at that
location is attached in Appendix F and shows permitted Outfall 001 entering an unnamed tributary to
Brooks Swamp north and downstream of the Parcel. As such, environmental conditions on the Parcel
associated with the Facility are not anticipated.
3.0 Site Protection Instrument
The Parcel will be protected via a perpetual conservation easement based on DWR’s latest template
available online. A DWR-approved Long-Term Steward (Steward) will be the Grantee on the easement,
such as Unique Places To Save, a 501(c)3 not-for-profit organization (UP2S). The parcel and landowner
information is summarized in Table 7.0 below:
Table 7.0 – Site Protection Instrument
Landowner Wayne County PIN Instrument Register of
Deeds Reference
Acreage to be
Protected
Daniel Ramsay and
Erica Ramsay
2584566186 Conservation
Easement
To be Recorded 11.1 Acres
4.0 Mitigation Work Plan
Native tree and shrub plantings will be used to establish hardwood forested corridors up to 200 feet
from top-of-bank on UT1 and UT2. Figure 7 depicts the credit-generating areas, Figure 8 depicts the
planting workplan, and Figure 9 depicts the riparian zones for the Parcel.
4.1 Parcel Preparation
The Parcel has historically been used for cropland and the feed corn planted in the summer of 2023 has
been harvested as of the date of this BPDP. The cornfield and ditch bank along UT1 will be bushhogged
to prepare for planting. Most of the riparian restoration areas will require minimal soil preparation
because they’ve been maintained in active agriculture. If sinkholes or unstable erosional areas are
observed along the streams, as they were observed during the DWR site visit in March along UT1, they
will be stabilized using methods such as minor grading, erosion control matting, live staking, straw bales,
and seeding with native grasses and forbs. Areas of poor herbaceous growth will be visually assessed
and fertilized prior to planting.
4.2 Riparian Area Restoration Activities
Riparian restoration areas in well-drained uplands throughout much of the Parcel (Figure 8) will be
restored using native bare-root plantings of trees and shrubs selected from Table 8.1. At least 7 of the
species listed in Table 8.1 will be planted based on commercial availability at the time of planting.
Table 8.1 - Planting List for Upland:
Species Common Name Approximate
Density1
Forest Layer Tree/Shrub
Betula nigra River birch 16% Overstory Tree
Liriodendron tulipifera Tulip poplar 14% Overstory Tree
Platanus occidentalis American sycamore 14% Overstory Tree
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 10 December 2023

Species Common Name Approximate
Density1
Forest Layer Tree/Shrub
Quercus nigra Water oak 14% Overstory Tree
Quercus michauxii Swamp chestnut oak 14% Overstory Tree
Magnolia virginiana Sweetbay 14% Understory Shrub
Diospyros virginiana Persimmon 14% Understory Tree
The following are alternate species if the first seven species are not commercially available.
Quercus falcata Southern red oak 14% Overstory Tree
Quercus pagoda Cherrybark oak 14% Overstory Tree
Quercus phellos Willow oak 14% Overstory Tree
Populus deltoides Eastern cottonwood 14% Overstory Tree
Quercus laurifolia Laurel oak 14% Overstory Tree
Tilia americana American basswood 14% Overstory Tree
Ulmus americana American elm 14% Overstory Tree
Prunus caroliniana Carolina cherry laurel 14% Understory Shrub
Morus rubra Red mulberry 14% Understory Shrub
Cornus amomum Silky dogwood 14% Understory Shrub
1Density will be determined by the commercially-available species at the time of planting.
In swampy portions of the Parcel along UT1 and UT2, which likely have long periods of seasonal
inundation and saturation associated with the Brooks Swamp floodplain (Figure 8), an alternative
planting list is proposed. These species have been selected based on high tolerance to inundation and
saturation in swamp settings. At least 5 of the tree and shrub species from Table 8.2 will be planted
based on commercial availability at the time of planting:
Table 8.2 – Planting List for Swamp Wetland
Species Common Name Approximate
Density1
Forest Layer Tree/Shrub
Taxodium distichum Bald cypress 20% Overstory Tree
Salix nigra Black willow 20% Overstory Tree
Nyssa aquatica Swamp blackgum 20% Overstory Tree
Quercus lyrata Overcup oak 20% Overstory Tree
Ilex decidua Possumhaw 20% Understory Shrub
The following are alternate species if the first five species are not commercially available.
Quercus michauxii Swamp chestnut oak 20% Overstory Tree
Magnolia virginiana Sweetbay 20% Understory Shrub
Chamaecyparis
thyoides
Atlantic white cedar 20% Overstory Tree
Cornus amomum Silky dogwood 20% Understory Shrub
1Density will be determined by the commercially-available species at the time of planting.
Trees and shrubs will be spaced at 9 feet by 9 feet during planting, which will provide a stem density of
529 stems per acre and is sufficient to meet the performance standards outlined in 15A NCAC 02B .0295
and the MBI of 260 planted trees and shrubs per acre at the end of five years. Stems will be mixed
before planting to promote diversity of bare root species across the Parcel. Due to the randomized
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 11 December 2023

mixing, some stems of the same species may be planted together. No single tree or shrub species will be
greater than 50% of the planted stems.
In areas without existing ground cover, a regionally appropriate seed mix of warm season grasses and
wildflowers will also be applied to provide permanent ground cover for soil stabilization and reduction
of sediment loss during rain events. Rye grass will also be included to provide temporary ground cover.
Table 8.3 describes the intended Ernst Conservation Seed Mix to be utilized:
Table 8.3 – Permanent Seed Mix

The proposed planting area includes the areas identified as Riparian Restoration for RBC (Ag and Non
Ag), Riparian Enhancement for RBC, and Riparian Restoration for NOC on Figure 7. Planting is scheduled
for the 2024 planting season (February 2024 – May 2024).
4.3 Riparian Area Enhancement Activities
The riparian enhancement area depicted in Figure 7 has been visually assessed for invasive species seed
sources and Chinese privet was observed. The privet will be completely removed through invasive
treatment, and supplemental planting of shade and wetland-tolerant species selected from Table 8.2
will be performed. See Section 4.6 for additional detail regarding privet management in this area.
4.4 Riparian Area Preservation Activities
Preservation areas have been visually assessed for invasive species seed sources. Scattered Chinese
privet was observed but was not dominant in either the overstory or understory, except along the field
edges. In the northern preservation area, as depicted on Figure 8, Chinese privet and chinaberry will be
treated during the as-built year to minimize spread to riparian restoration areas. In the southern
preservation area (Figure 8), Chinese privet will be managed in accordance with Section 4.6. Two
collapsed sheds, trash, and debris in the northern preservation area will be removed before the as-built
report is submitted.
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 12 December 2023

4.5 DWR As-Built Evaluation
Within 30 calendar days after completing the establishment of the buffer mitigation and nutrient offset
areas, the Sponsor will submit written notification to DWR documenting that all buffer mitigation and
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.
4.6 Privet Management Plan
The Privet Management Area is depicted on Figure 8 and is approximately 1.2 acres. The area is
characterized by dense privet along the field edge, along with areas of dense privet scattered
throughout the southern Preservation Area, Non Ag Riparian Restoration Area, and Non Ag Riparian
Enhancement Area. Before planting, canopy-sized specimens of Chinese privet will be cut down,
removed, and properly disposed. Stumps will be treated with triclopyr or an equivalent aquatic-safe
herbicide. Chinese privet in the understory that is reachable via spraying will be treated with either
triclopyr or glyphosate, in accordance with N.C. Forest Service (NCFS) management recommendations
(NCFS, 2010). During the as-built monitoring and Year 1 monitoring, privet kill efficacy will be assessed
during the site walkthroughs and areas of poor efficacy will be noted for additional treatment in the
following dormant season. Based on anticipated privet regrowth, additional treatments will be
performed as needed to limit privet within the Privet Management Plan area during the monitoring
period. Supplemental treatments are expected to take place during monitoring years 2 and 4. Success
for closeout in the Privet Management Area will be defined by an absence of canopy-sized privet, with
widely scattered privet sprouts (or no privet) in the understory.
5.0 Monitoring and Maintenance Plan
5.1 Monitoring Protocol
Permanent vegetation monitoring plots will be installed and assessed within the riparian restoration and
enhancement areas to measure the survival of planted trees and shrubs. The plots will be randomly
placed throughout the planted areas. A total of 8 plots will be randomly placed such that the plots are
representative of the riparian restoration and enhancement areas (Figure 10) and at least 2% of the
total planted area is monitored. The size of individual quadrants will be 100 square meters.
Vegetation assessments will be conducted and follow the Carolina Vegetation Survey (CVS) Level 2
Protocol for Recording Vegetation (2008). A reference photograph will be taken from the southwestern
corner of each of the 8 plots. Overview photographs will be taken each monitoring year and provided in
the annual reports. All planted stems in the plots will be marked with flagging tape and recorded.
The first annual monitoring activities will begin at the end of the first growing season, at least five
months after planting has been completed and no earlier than the fall season. Species composition and
survival rates will be evaluated on an annual basis by plot. The total number of volunteer woody stems
will also be documented and reported. In Monitoring Years 1, 3, and 5, planted stem height will be
measured and average vigor per plot will be recorded. Per the MBI, the measure of vegetative success
for the Parcel will be having an established density of at least 260 planted trees and shrubs per acre at
the end of the fifth year of monitoring, where no one species is greater than 50% of the established
planted stems. Appropriate and desirable native volunteer species may be included in the Parcel's
density to meet the performance standards with written DWR approval.
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 13 December 2023

A site walkthrough will be conducted each monitoring year to visually assess vegetative success and
Chinese privet regrowth throughout the Parcel. The results of the walkthrough and recommended
management actions, if any, will be included in the annual monitoring report.
The Sponsor shall submit the annual monitoring report to DWR by December 31st of each year for five
consecutive years and will follow the terms and conditions of the MBI regarding content.
5.2 Parcel Maintenance
If the Parcel or a specific component of the Parcel fails to achieve the success criteria outlined in Section
5.1, adaptive measures will be developed and appropriate remedial actions will be implemented.
Maintenance will be performed to correct problems on the Parcel that have a high likelihood of affecting
project success. Such items include, but are not limited to, fire, flooding, drought, or insects that cause
excess tree mortality. Implemented actions will be designed to achieve the success criteria and will
include a work schedule and updated monitoring criteria.
An herbicide application schedule may need to be implemented in the first few years of tree
establishment in the riparian restoration areas to prevent establishment of invasive species that may
out-compete the planted native vegetation. The only herbicides used on the Parcel will be aquatic-
approved herbicides that will be applied in accordance with North Carolina Department of Agriculture
rules and regulations.
The easement boundary will be checked annually as part of monitoring activities. Easement boundary
conditions as well as maintenance performed will be reported in the annual monitoring reports to DWR.
If mowing is deemed necessary by the Sponsor during the monitoring period, the Sponsor must receive
approval from DWR prior to conducting any mowing activities within Zone 1 and Zone 2 of the Neuse
River Basin buffers to ensure that no buffer violations occur.
5.3 Easement Boundaries
Easement boundaries will be marked to ensure clear distinction between the Parcel and adjacent
properties. Boundaries may be identified by marker, post, tree-blazing, or other means as allowed by
site conditions and/or the conservation easement prior to the DWR onsite As -Built evaluation for the
Task 2 credit release. Boundary markers that have been disturbed, damaged, or destroyed will be
repaired or replaced as needed. Contact information for the conservation easement holder will be
included on the easement markers.
6.0 Financial Assurance and Long-Term Management
6.1 Financial Assurances
Following approval of the BPDP, the Sponsor shall provide a Performance/Maintenance Bond (Bond)
from a surety company that is rated no less than an “A-” as rated by A.M. Best. The amount of the Bond
shall be 100% of the estimated cost for implementation of the riparian restoration and other related
activities for the construction of the Parcel, but not less than $150,000. Alternatively, in lieu of posting a
Bond, the Sponsor may elect to construct the Bank Parcel prior to the first credit release.
After completion of the riparian activities and construction activities on the Parcel, a separate Bond will
be secured for 100% of the estimated cost to implement the monitoring and maintenance plan, but not
less than $100,000 initially. Each Bond shall be renewed annually for a minimum of five years, and until
Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 14 December 2023

DWR has released all Riparian Buffer Credits and Nutrient Offset Credits to the Sponsor. Upon DWR
approval, the bond amount may be lowered each year based on the adjusted cost to complete the
monitoring and maintenance. Confirmation of bond renewal will be provided to DWR with each annual
monitoring report when applicable. DWR reserves the right to alter the credit release schedule if a
monitoring report is submitted without proof of bond renewal when applicable.
6.2 Long-Term Management
The Parcel will remain in private ownership, protected by a DWR-approved Long-Term Steward
(Steward), and will be managed under the terms detailed in a DWR-approved Conservation Easement
recorded with the Wayne County Register of Deeds. Among other requirements documented in the
Conservation Easement, the Steward will be responsible for periodic inspection of the Parcel to ensure
that the easement restrictions are upheld in perpetuity.
7.0 Project Credit Potential
7.1 Riparian Buffer Credits
All Riparian Buffer Credits have been determined based on the ratios and percentages provided in 15A
NCAC 02B. 0295 (m) and (n) following the guidance provided in the Clarified Procedures for Calculating
Buffer Mitigation Credits and Nutrient Offset Credits letter issued by the DWR (Clarified Procedures
Letter), including the most recent Project Credit Table Template provided by DWR and incorporated in
this BPDP as Table 9.0 below.
Riparian restoration on the Parcel that is performed on agricultural lands within the Parcel may be used
for either Riparian Buffer Credit or Nutrient Offset Credit, but not both. Riparian restoration,
enhancement, or preservation of Non Agricultural (Non Ag) lands on the Parcel can only be used for
Riparian Buffer Credit. Riparian Buffer Credit is defined as one (1) buffer credit per one square foot or
43,560 buffer credits per one acre.
7.2 Nutrient Offset Credits
The square footage of Nutrient Offset Credits on the Bank Parcel has been determined by applying the
applicable ratios as provided in 15A NCAC 02B. 0295(m) for a Restoration Site following the guidance
provided in the Clarified Procedures Letter and using the Project Credit Table Template. As documented
in these sources, the nitrogen (N) credit conversion rate for the Neuse 01 is 19.16394 square foot of
restored riparian buffer per pound of nitrogen. All riparian areas proposed for Nutrient Offset Credits
are a minimum of 50 feet from the top of the banks along viable features on land noted in a Site Viability
Letter as having agricultural use.

Brooks Swamp BPDP
Neuse HUC# 03020201, Excluding Falls Lake 15 December 2023

8.0 References
Lee, M. T., Peet, R. K., Roberts, S. D., & Wentworth, T. R. 2008. CVS- EEP Protocol for Recording
Vegetation Version 4.2. http://cvs.bio.unc.edu/protocol/cvs-eep-protocol-v4.2-lev1-5.pdf
DWR, 2008. Buffer Interpretation/ Clarification # 2008-019 — Memorandum.
https://edocs.deq.nc.gov/WaterResources/DocView.aspx?dbid=0&id=2580086
DWR, 2019. Clarified Procedures for Calculating Buffer Mitigation Credits and Nutrient Offset Credits for
Riparian Projects Regulated under 15A NCAC .0295 and 15A NCAC 02B .0240 – Memorandum.
https://edocs.deq.nc.gov/WaterResources/DocView.aspx?dbid=0&id=2582459.
DWR, 2023. Project Credit Table Template – Updated July 2023. https://www.deq.nc.gov/water-
quality/surface-water-protection/401/mitigation/project-credit-table-template-updated-july-2023
DWR. Methodology and Calculations for Nutrient Reduction associated with Riparian Buffer
Establishment.
https://files.nc.gov/ncdeq/Water%20Quality/Planning/NPU/Nutrient%20Offset%20Rule/Ag-Buffer-
Credit.pdf
NCDEQ, 2015. 15A NCAC 02B .0295. Mitigation Program Requirements for Protection and Maintenance
of Riparian Buffers. http://reports.oah.state.nc.us/ncac/title%2015a%20-
%20environmental%20quality/chapter%2002%20-
%20environmental%20management/subchapter%20b/15a%20ncac%2002b%20.0295.pdf
NCDEQ, 2020. 15A NCAC 02B .0703. Nutrient Offset Credit Trading.
http://reports.oah.state.nc.us/ncac/title%2015a%20-%20environmental%20quality/chapter%2002%20-
%20environmental%20management/subchapter%20b/15a%20ncac%2002b%20.0703.pdf
NCFS, 2010. Invasive Species Leaflet No. 2 – Ligustrum Sinense (Chinese privet), March 2010.
https://www.ncforestservice.gov/publications/Forestry%20Leaflets/IS02.pdf
NC One Map, 2023. Contours: 2’ Interval. Accessed online at
https://www.nconemap.gov/datasets/nconemap::contours-2-interval/about on August 10, 2023.
United States Department of Agriculture (USDA), 1974. Natural Resources Conservation Service, Soil
Survey for Wayne County, North Carolina. https://websoilsurvey.sc.egov.usda.gov/
Wayne County, NC GIS, 2023. Accessed online at https://wayne-county-gis-
waynecountync.hub.arcgis.com/ on August 10, 2023.
Brooks Swamp BPDP
Neuse HUC #03020201, Excluding Falls Lake December 2023

FIGURES

0 0.650.33 Km
0 0.30.15 Mi
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Parcel: Brooks Swamp
Figure 1: Vicinity Map
Burroughs
Pond
117
117
Cl
u
b
Kn
o
l
l
s

R
d
O 'B e r r y

R
d
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c
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t

R
id
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e

R
d
U
S
-
1
1
7
-
A
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T
Southern Wayne
Golf Course
Ol
d

M
t

O
l
i
v
e

H
w
y
Brewington Dr
Ru sk in R d
Sleepy Creek

R
d
Dudley
Bass Lake
Ol
d

M
t
Ol
i
v
e

H
w
y
K
e
l
l
y
S
p
ri
n
g
s

R
d
Parker

R
d
E ver
ett Rd
City of Goldsboro, State of North Carolina DOT, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US Census
Bureau, USDA
Brooks Swamp
Directions:
-From US Hwy 117 take the O'Berry Road
exit onto O'Berry Rd east and drive 0.8
miles.
-Turn right onto Old Mt. Olive Highway
and drive 1.3 miles. Turn right at gravel
driveway and proceed to Parcel.
Site Coordinates:
35.2487418°N, 78.0413133°W
0 0.10.05 Km
0 300150Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Parcel: Brooks Swamp
Figure 2: Site Map
Old

M
t

O
li
v
e

H
w
y
Ol
d

M
t

O
l
i
v
e

H
w
y
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA, NC OneMap, NC Center for Geographic
Information and Analysis, NC 911 Board
Legend
Treeline
Top of Bank
Property Boundary
Parcel Area
Access Easement
Scattered Debris
UT1
UT2
Brooks Swamp
0 2010Km
0 105Mi
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Parcel: Brooks Swamp
Figure 3: Service Area for Riparian Buffer
Credits and Nutrient Offset Credits
Esri, NASA, NGA, USGS, Sources: Esri, USGS, Esri, HERE, Garmin, SafeGraph,
FAO, METI/NASA, USGS, EPA, NPS
Legend
Credit Service Area
Neuse 03020201
Brooks Swamp
0 0.40.2 Km
0 1,000500Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Parcel: Brooks Swamp
Figure 4: Topographic Map
Copyright:© 2013 National Geographic Society, i-cubed
Legend
Parcel Area
Mount Olive Quadrangle
0 0.40.2 Km
0 1,000500Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Parcel: Brooks Swamp
Figure 5: Watershed Map
UT1
Watershed
66.3 AC
UT2 Watershed
317.9 AC
NC OneMap, NC Center for Geographic Information and Analysis, NC
911 Board
Legend
2' Elevation Contours
Parcel Area
Watersheds
0 0.40.2 Km
0 1,000500Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Parcel: Brooks Swamp
Figure 6: Soils Map
Natural Resources Conservation Service (NRCS), NCDOT Project ATLAS
SWEEP group, Copyright:© 2013 National Geographic Society, i-cubed
Legend
Parcel Area
Mount Olive Quadrangle
0 0.10.05 Km
0 200100Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Parcel: Brooks Swamp
Figure 7: Credit Areas
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA, NC CGIA, Maxar, Microsoft
Treeline
Top of Bank
Conservation Easement
Non Ag Riparian
Enhancement for RBC -
0-100'
Riparian Preservation
for RBC - 0-100'
Riparian Restoration for
RBC - 0-100'
Non Ag Riparian
Restoration for RBC -
0-100'
Riparian Preservation
for RBC - 101-200'
Riparian Restoration for
NOC - 101-200'
UT1
UT2
Privet Removal and
Supplemental Planting: Not
Convertible to Nitrogen
LEGEND
0 0.10.05 Km
0 200100Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Parcel: Brooks Swamp
Figure 8: Planting Workplan
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA, NC CGIA, Maxar, Microsoft
Legend
Treeline
Top of Bank
Conservation Easement
Access Easement
(Gravel)
Livestaking (1,000 LF,
Left Bank Only)
Invasive Treatment Area
Privet Management
Area
Planting Zones
Swamp Wetland
Enhancement
Swamp Wetland
Restoration
Upland Restoration
UT1
UT2
Two collapsed
sheds to remove
0 0.10.05 Km
0 200100Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
Parcel: Brooks Swamp
Figure 9: Riparian Zones
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA, NC CGIA, Maxar, Microsoft
Top of Bank
Conservation Easement
Riparian Zones
30' from Top of Bank
50' from Top of Bank
100' from Top of Bank
200' from Top of Bank
Non Ag Riparian Enhancement for
RBC - 0-100'
Riparian Preservation for RBC -
0-100'
Riparian Restoration for RBC - 0-100'
Non Ag Riparian Restoration for RBC
- 0-100'
Riparian Preservation for RBC -
101-200'
Riparian Restoration for NOC -
101-200'
UT1
UT2
200' Zone
100' Zone
Brooks Swamp BPDP
Neuse HUC #03020201, Excluding Falls Lake December 2023

APPENDICES
Brooks Swamp BPDP: Appendix A
Neuse HUC# 03020201, Excluding Falls Lake 1 December 2023

Appendix A: Brooks Swamp Photolog

Photo 1: UT1, 7/14/23

Photo 2: UT1 Left Bank Upland Restoration Area,
7/14/23
Photo 3: UT1 Preservation Area, 7/14/2023 Photo 4: UT2, 10/31/2022
Brooks Swamp BPDP: Appendix A
Neuse HUC# 03020201, Excluding Falls Lake 2 December 2023

Photo 5: UT2 Preservation Area, 7/14/23 Photo 6: UT2 Upland Buffer Restoration
Area, 4/19/2023
Photo 7: UT2 Swamp Buffer Restoration Area,
10/31/22
Photo 8: UT2 Buffer Enhancement Area, 10/31/22

0 0.10.05 Km
0 200100Feet
±
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet
2023
Parcel: Brooks Swamp
Historical Aerial: 1993
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA
Legend
Parcel Area
0 0.10.05 Km
0 200100Feet
±
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet
2023
Parcel: Brooks Swamp
Historical Aerial: 1998
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA
Legend
Parcel Area
0 0.10.05 Km
0 200100Feet
±
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet
2023
Parcel: Brooks Swamp
Historical Aerial: 2013
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA
Legend
Parcel Area
0 0.10.05 Km
0 200100Feet
±
Coordinate System: NAD 1983 StatePlane North Carolina FIPS 3200 Feet
2023
Parcel: Brooks Swamp
Historical Aerial: 2017
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA
Legend
Parcel Area
North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 1617 Mail Service Center Raleigh, North Carolina 27699-1617
919.707.9000

March 1, 2023 Project 20230163 Version 1 Wayne County Daniel and Erica Ramsay RestorEcology, LLC [e-mail]
Subject: Determination for Applicability to the Neuse Buffer Rules 15A NCAC 02B .0714
Project Name: Price Farm Mitigation Site
Address: Old Mount Olive Highway, Dudley, NC 28333
Location: Lat., Long: 35.248741, -78.041313 Dear Mr. Ramsay: On January 19, 2023, Shelton Sullivan of the Division of Water Resources (DWR) conducted an on-site review of feature(s) located on the Price Farm Mitigation Site at the request of RestorEcology, LLC to determine the presence of streams and the applicability of features on the site to the Neuse River Riparian Area Protection Rules, Title 15A North Carolina Administrative Code 02B .0714. The enclosed map(s) depict the feature(s) evaluated and this information is also summarized in the table below. Streams were evaluated for being ephemeral, at least intermittent, and for subjectivity to the Neuse River Riparian Area Protection Rules. Streams that are considered “Subject” have been located on the most recently published NRCS Soil Survey of Johnston County and/or the most recent copy of the USGS Topographic (at 1:24,000 scale) map(s), have been located on the ground at the site, and possess characteristics that qualify them to be at least intermittent streams. Features that are considered “Not Subject” have been determined to not be at least intermittent, not present on the property, or not depicted on the required maps.
This determination only addresses the applicability to the buffer rules within the
proposed property boundary and does not approve any activity within buffers or within
waters of the state. There may be other streams or features located on the property or
just off the property that were not evaluated or do not appear on the maps referenced
above. Any of the features on the site may be considered jurisdictional according to the
US Army Corps of Engineers and subject to the Clean Water Act.

The following table addresses the features observed and rated during the DWR site visit.
DocuSign Envelope ID: 167C2E1B-BB19-4DFC-B9DB-B7D85FA84612
Page 2 of 2 Price Farm. DWR 20230163 V1

Feature ID Feature Type: stream (ephemeral, intermittent, perennial), ditch, swale, wetland, other
Subject to Buffer Rules Start @ Stop @ Depicted on Soil Survey Depicted on USGS Topo
UT1 Modified Stream, at least intermittent Subject
Just south of road culvert, north of property boundary. Labeled UT1 Start.
Continues to confluence of Brooks Swamp Yes No
UT2 Stream, at least intermittent Subject Southeastern property boundary. Labeled UT2 Start.
Continues to confluence of Brooks Swamp Yes No
* E: Ephemeral, I: Intermittent, P: Perennial
This on-site determination shall expire five (5) years from the date of this letter.
Landowners or affected parties that dispute this determination made by the DWR may
request an appeal determination by the Director of Water Resources. An appeal request
must be made within sixty (60) calendar days of the date of this letter to the Director in
writing.
If sending via U.S. Postal Service: Division of Water Resources 401 & Buffer Permitting Branch Supervisor 1617 Mail Service Center Raleigh, NC 27699-1617
If sending via delivery service (UPS, FedEx, etc.) Division of Water Resources 401 & Buffer Permitting Branch Supervisor 512 N Salisbury St. Raleigh, NC 27604 This determination is final and binding as detailed above unless an appeal is requested within
sixty (60) calendar days of the date of this letter. If you have any additional questions or require additional information, please contact Shelton Sullivan at [e-mail] or 919-707-3636. This determination is subject to review as provided in G.S. 150B. Sincerely, Katie Merritt, Acting Supervisor 401 & Buffer Permitting Branch Attachments: Site Map with labels, NRCS Soil Survey, USGS Topographical Map cc: 401 & Buffer Permitting Branch, Laserfiche File 20230163 V1 DWR Washington Regional Office, via email Filename: 20230163_PriceFarm_Strem Det_Wayne_Co
DocuSign Envelope ID: 167C2E1B-BB19-4DFC-B9DB-B7D85FA84612
c:J

Legend
- Streams
DWR Determinations - Price Farm
Property Boundary Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetrVlap, Microsoft, Esri, HERE, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA, NC CGIA, Maxar, Microsoft 2022 0

155 310
Feet
Km
Coordinate System: NAD 1983 StatePlane North Carolina PIPS 3200 Feet 0 0.05 0.1
Not evaluated
UT1 Start below road
culvert, just off map
UT2 Start
Not evaluated
DocuSign Envelope ID: 167C2E1B-BB19-4DFC-B9DB-B7D85FA84612
Soil Survey, Wayne County NC

DocuSign Envelope ID: 167C2E1B-BB19-4DFC-B9DB-B7D85FA84612
USGS map

DocuSign Envelope ID: 167C2E1B-BB19-4DFC-B9DB-B7D85FA84612
North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 1611 Mail Service Center Raleigh, North Carolina 27699-1611
919.707.9000

June 27, 2023

RestorEcology, LLC
Attn: Daniel Ramsay
(via electronic mail: [e-mail] )

Re: Site Viability for Buffer Mitigation and Nutrient Offset – Brooks Swamp Site
Near 35.2487418, -78.0413133 located off Old Mt. Olive Highway in Dudley, NC
Neuse 03020201
Johnston County

Dear Mr. Ramsay,

On March 13, 2023, Katie Merritt, with the Division of Water Resources (DWR), received a request
from you on behalf of RestorEcology, LLC (RE) for a site visit near the above-referenced site in the
Neuse River Basin within the 8-digit Hydrologic Unit Code 03020201. The site visit was to
determine the potential for nutrient offset and buffer mitigation within a proposed conservation
easement boundary, which is more accurately depicted in the attached figure labeled “Figure 1 –
Brooks Swamp Parcel” prepared by RE. Another map, labeled “Figure 2 – Land Cover Aerial Photo:
2017” is also attached to depict land cover and privet areas and was prepared by RE and edited by
DWR. The proposed easement boundary on Figure 1, includes all riparian areas intended to be
proposed as part of the mitigation site. On March 22, 2023, Ms. Merritt performed a site assessment
of the subject site. Staff with RE were also present. The following site constraints/concerns were
observed:
• Sinks holes, erosional rills and other areas with active erosion were observed throughout
UT1. Stabilization efforts for active erosion and sink holes need to be addressed as part of
the riparian restoration plan.
• Invasives, such as privet, were observed in high densities along UT1 and UT2. Treatment of
invasive privet will be required as part of the riparian restoration plan. See Figure 2 for land
cover descriptions.
• Inundated floodplain areas along UT1 and UT2 are high risk for stem survivability. DWR
recommends RE proposed planting wetland tolerant species as part of the riparian restoration
plan.
• Trash and debris within the stream channel and/or riparian areas were observed onsite and
need to be removed as part of the riparian restoration plan. Stable structures, such as the barn
onsite, are not required to be removed from the riparian area but cannot be included within
credit generating square footage. See Figure 2 for approximate locations of structures and
debris.

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 and for
DocuSign Envelope ID: BB755ABF-4BFF-4454-AC92-1BCB3846E849
Brooks Swamp Site
RestorEcology
June 27, 2023

Page 2 of 3
nutrient offset credits pursuant to 15A NCAC 02B .0703 using 15A NCAC 02B .0295 to define the
mitigation type determinations.

1Subjectivity calls and stream origins for the features were determined by DWR in correspondence dated January 24, 2023 (DWR#
2022-1555) 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
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.
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.
8The confluence of a ditch to a stream is required to be secured with a conservation easement to preserve the hydrologic connectivity of
ditches to streams to be viable to generate buffer and/or nutrient offset credits
Feature Classification
onsite Subject
to
Buffer
Rule1
Riparian Land uses
adjacent to Feature
(0-200’)
Buffer
Credit
Viable
Nutrient
Offset
Viable3

Mitigation Type Determination w/in
riparian areas 4,5,8
UT1 Stream Yes A combination of non-
forested agricultural fields
and mature forest. Dense
privet along field edge at
southern boundary (see
Figure 2)

Yes2 Yes (non-
forested ag
fields only)
Non-forested fields - Restoration Site
per 15A NCAC 02B .0295 (n)

Forested areas – Preservation Site per
15A NCAC 02B .0295 (o)(5)

Density populated Privet - Restoration
Site per 15A NCAC 02B .0295 (n)
*must completely remove invasives, have
a management plan for invasives, &
supplementally plant with native trees

UT2 Stream Yes A combination of non-
forested agricultural fields
and mature forest.

- areas where densely
populated privet is the
only stem present (see
Figure 2)

-areas with clumps of
densely populated privet
but within partially
forested areas of scattered
hardwoods

Yes2 Yes (non-
forested ag
fields only)
Non-forested fields - Restoration Site
per 15A NCAC 02B .0295 (n)

Areas where privet is the majority canopy
– Restoration Site per 15A NCAC 02B
.0295 (n)
*must completely remove invasives, have
a management plan for invasives, &
supplementally plant with native trees

Forested areas (without Privet) –
Preservation Site per
15A NCAC 02B .0295 (o)(5)

Partially forested areas w/ clumps of
privet – Enhancement Site per 15A
NCAC 02B .0295 (n)
*must completely remove invasives, have
a management plan for invasives, &
supplementally plant with native trees

DocuSign Envelope ID: BB755ABF-4BFF-4454-AC92-1BCB3846E849
Brooks Swamp Site
RestorEcology
June 27, 2023

Page 3 of 3

Determinations provided in the table above were made using a proposed easement boundary showing
proposed mitigation areas and features shown on Figure 1 and Figure 2. The maps representing the
proposal for the site are attached to this letter and initialed by Ms. Merritt on June 27, 2023.
Substantial changes to the proposed easement boundary as well as any site constraints identified in
this letter that are not addressed in a riparian restoration plan, 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 June 27, 2025 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 [e-mail] if you have any questions regarding this
correspondence.
Sincerely,

Stephanie Goss, Supervisor
401 and Buffer Permitting Branch

Attachments: Figure 1 – Brooks Swamp Parcel; Figure 2 – Land Cover Aerial Photo 2017

cc: File Copy (Katie Merritt)

DocuSign Envelope ID: BB755ABF-4BFF-4454-AC92-1BCB3846E849
DocuSign Envelope ID: BB755ABF-4BFF-4454-AC92-1BCB3846E849
DocuSign Envelope ID: BB755ABF-4BFF-4454-AC92-1BCB3846E849

150 WRENN DR, #5842, CARY, NC 27512
T [phone] U WWW.RESTORECOLOGY.COM

From: Daniel Ramsay
RestorEcology Neuse, LLC (RestorEcology)
PO Box 5842
Cary, NC 27512
919-817-7378
[e-mail]

To: Ms. Kathryn Matthews
U.S. Fish and Wildlife Service
Raleigh Field Office
P.O. Box 33726
Raleigh, NC 27636-3726
July 17, 2023
Re: Online Project Review Request, Brooks Swamp Buffer and Nutrient Offset Bank Project,
Wayne County, North Carolina, NC Division of Water Resources (DWR) #20230163

Dear Ms. Matthews,

We have reviewed the referenced project using the North Carolina Field Office’s online project
review process and have followed all guidance and instructions in completing the review. We
completed our review on July 17, 2023 and are submitting our project review package in
accordance with the instructions for further review.

Our Proposed Action consists of: approximately 11.1 acres of cropland will be planted with native
hardwood trees to lessen nutrient inputs into the streams from agricultural activities and provide
restored stream buffers. Existing wooded stream buffers within the project area will be
preserved and enhanced. Waters of the U.S. permitting under Section 404/401 of the Clean
Water Act will not be required for the Project because ground-disturbing construction activities
and changes to Project streams are not proposed. Riparian buffer credits, nitrogen (lb) and
phosphorus (lb) will be generated by the Project, as regulated by the NC DWR. Credits will be
sold on the private mitigation bank market to offset development impacts within the Neuse River
Basin HUC #03020201, excluding Falls Lake Watershed. The project tree planting is expected to
be completed by winter 2024/2025.

2

The Project is located at 35.2487418°N, 78.0413133°W in the Neuse River Basin HUC #03020201
in Wayne County, NC. The location of the project and the action area are identified on the
enclosed USGS topographic map and aerial photo map.

There is no federal nexus, but project review has been requested by the NC DWR.

The enclosed project review package provides the information about the species, critical habitat,
and bald eagles considered in our review, and the species conclusions table included in the
package identifies our determinations for the resources that may be affected by the project.
For additional information, please contact Daniel Ramsay at the address listed above.

Sincerely,

Daniel Ramsay, PWS
Owner, RestorEcology

Enclosures:
1) ENTIRE PROJECT REVIEW PACKAGE
2) Other relevant project data/documents

□
□
□
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
P.O. Box 33726
Raleigh, NC 27636-3726 Date:
Self-Certification Letter
Project Name
IPaC Project Code: IPaC Record Locator #
Dear Applicant:
Thank you for using the U.S. Fish and Wildlife Service (Service) Raleigh Ecological
Services online project review process. By printing this letter in conjunction with your
project review package, you are certifying that you have completed the online project
review process for the project named above in accordance with all instructions
provided, using the best available information to reach your conclusions. This letter,
and the enclosed project review package, completes the review of your project in
accordance with the Endangered Species Act of 1973 (16 U.S.C. 1531-1544, 87 Stat.
884), as amended (ESA), and the Bald and Golden Eagle Protection Act (16 U.S.C.
668-668c, 54 Stat. 250), as amended (Eagle Act). This letter also provides
information for your project review under the National Environmental Policy Act of
1969 (P.L. 91-190, 42 U.S.C. 4321-4347, 83 Stat. 852), as amended. A copy of this
letter and the project review package must be submitted to this office for this
certification to be valid. This letter and the project review package will be maintained
in our records.
The species conclusions table in the enclosed project review package summarizes
your ESA and Eagle Act conclusions. Based on your analysis, mark all the
determinations that apply:
“no effect” determinations for proposed/listed species and/or
proposed/designated critical habitat; and/or
“may affect, not likely to adversely affect” determinations for proposed/listed
species and/or proposed/designated critical habitat; and/or
“no Eagle Act permit required” determinations for eagles.
Version 5/22/2023

Applicant Page 2
We certify that use of the online project review process in strict accordance with the
instructions provided as documented in the enclosed project review package results in
reaching the appropriate determinations. Therefore, we concur with the “no effect” or
“not likely to adversely affect” determinations for proposed and listed species and
proposed and designated critical habitat; the “may affect” determination for Northern
long-eared bat; and/or the “no Eagle Act permit required” determinations for eagles.
Additional coordination with this office is not needed. Candidate species are not
legally protected pursuant to the ESA. However, the Service encourages consideration
of these species by avoiding adverse impacts to them. Please contact this office for
additional coordination if your project action area contains candidate species.
Should project plans change or if additional information on the distribution of
proposed or listed species, proposed or designated critical habitat, or bald eagles
becomes available, this determination may be reconsidered. This certification letter is
valid for 1 year. Information about the online project review process including
instructions, species information, and other information regarding project reviews
within North Carolina is available at our website http://www.fws.gov. If you have any
questions, you can write to us at [e-mail] or please contact Leigh Mann of
this office at 919-856-4520, ext. 10.
Sincerely,
/s/Pete Benjamin
Pete Benjamin
Field Supervisor
Raleigh Ecological Services
Enclosures -project review package
Version 5/22/2023
Species Conclusions Table
Project Name: Brooks Farm Buffer and Nutrient Offset Bank Project

Date: July 17, 2023
Species / Resource Name Conclusion ESA Section 7 / Eagle Act Determination Notes / Documentation

Tricolored Bat
Perimyotis subflavus

Suitable roosting habitat
present – large
hardwood trees, no
current survey conducted
No effect
Cave habitat not present, tree removal
not proposed. No NCNHP element
occurrences present in the project
vicinity (one-mile radius).
Red-cockaded
Woodpecker
Picoides borealis
No suitable habitat
present.
No effect Few pines in project area, understory
dense. No RCW observed in 7/14/23
site visit.
Carolina Madtom
Noturus furiosus
No suitable habitat
present.
No effect Project streams are headwater, first
order streams 3-5 feet in bankfull
width with a sandy/mucky bottom.
Neuse River
Waterdog
Necturus lewisi
No suitable habitat
present.
No effect Project streams are headwater, first
order streams 3-5 feet in bankfull
width with a sandy/mucky bottom.

Monarch Butterfly
Danaus plexippus

Field edge habitat
present, but no milkweed
plants observed in
7/14/23 site visit
No effect Project activities entail tree planting
and a permanent conservation
easement along streams in cultivated
fields and woodland. These activities
are deemed to have a net beneficial
effect, if any. No NCNHP element
occurrences present in the project
vicinity.
Bald Eagle
Haliaeetus leucocephalus
Unlikely to disturb
nesting bald eagles
No Eagle Act Permit Required Not within 660 feet of large bodies of
water. No NCNHP element
occurrences present in the project
vicinity.
Critical Habitat No critical habitat present
Acknowledgement: I agree that the above information about my proposed project is true. I used all of the provided resources to make an
informed decision about impacts in the immediate and surrounding areas.

July 17, 2023
Signature /Title: Daniel Ramsay, Owner, RestorEcology Neuse, LLC Date
0 0.150.07 Km
0 400200Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Brooks Swamp Buffer and
Nutrient Offset Mitigation Bank
Old

M
t
Ol
i
ve
Hwy
Parker

R
d
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA, NC OneMap, NC Center for Geographic
Information and Analysis, NC 911 Board
Legend
Streams
Project Area
0 0.30.15 Km
0 800400Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Brooks Swamp Buffer and
Nutrient Offset Mitigation Bank
Copyright:© 2013 National Geographic Society, i-cubed
Legend
Project Area
Mount Olive Quadrangle
July 13, 2023
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Ecological Services Field Office
Post Office Box 33726
Raleigh, NC 27636-3726
Phone: [phone] Fax: [phone]
In Reply Refer To:
Project Code: 2023-0104366
Project Name: Brooks Swamp Buffer and Nutrient Offset Mitigation Project

Subject:List of threatened and endangered species that may occur in your proposed project
location or may be affected by your proposed project
To Whom It May Concern:
The enclosed species list identifies threatened, endangered, proposed and candidate species, as
well as proposed and final designated critical habitat, that may occur within the boundary of your
proposed project and/or may be affected by your proposed project. The species list fulfills the
requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of the
Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 et seq.). If your project area 
contains suitable habitat for any of the federally-listed species on this species list, the proposed
action has the potential to adversely affect those species.  If suitable habitat is present, surveys 
should be conducted to determine the species’ presence or absence within the project area.  The 
use of this species list and/or North Carolina Natural Heritage program data should not be
substituted for actual field surveys.  
New information based on updated surveys, changes in the abundance and distribution of
species, changed habitat conditions, or other factors could change this list. Please feel free to
contact us if you need more current information or assistance regarding the potential impacts to
federally proposed, listed, and candidate species and federally designated and proposed critical
habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the
Act, the accuracy of this species list should be verified after 90 days. This verification can be
completed formally or informally as desired. The Service recommends that verification be
completed by visiting the ECOS-IPaC website at regular intervals during project planning and
implementation for updates to species lists and information. An updated list may be requested
through the ECOS-IPaC system by completing the same process used to receive the enclosed list.
The purpose of the Act is to provide a means whereby threatened and endangered species and the
ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2) of the
Act and its implementing regulations (50 CFR 402 et seq.), Federal agencies are required to
utilize their authorities to carry out programs for the conservation of threatened and endangered
07/13/2023   2

species and to determine whether projects may affect threatened and endangered species and/or
designated critical habitat.
A Biological Assessment is required for construction projects (or other undertakings having
similar physical impacts) that are major Federal actions significantly affecting the quality of the
human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2)
(c)). For projects other than major construction activities, the Service suggests that a biological
evaluation similar to a Biological Assessment be prepared to determine whether the project may
affect listed or proposed species and/or designated or proposed critical habitat. Recommended
contents of a Biological Assessment are described at 50 CFR 402.12.
If a Federal agency determines, based on the Biological Assessment or biological evaluation, that
listed species and/or designated critical habitat may be affected by the proposed project, the
agency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Service
recommends that candidate species, proposed species and proposed critical habitat be addressed
within the consultation. More information on the regulations and procedures for section 7
consultation, including the role of permit or license applicants, can be found in the "Endangered
Species Consultation Handbook" at:
http://www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF
Migratory Birds: In addition to responsibilities to protect threatened and endangered species
under the Endangered Species Act (ESA), there are additional responsibilities under the
Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle Protection Act (BGEPA) to
protect native birds from project-related impacts. Any activity, intentional or unintentional,
resulting in take of migratory birds, including eagles, is prohibited unless otherwise permitted by
the U.S. Fish and Wildlife Service (50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)). For more
information regarding these Acts see https://www.fws.gov/birds/policies-and-regulations.php.
The MBTA has no provision for allowing take of migratory birds that may be unintentionally
killed or injured by otherwise lawful activities. It is the responsibility of the project proponent to
comply with these Acts by identifying potential impacts to migratory birds and eagles within
applicable NEPA documents (when there is a federal nexus) or a Bird/Eagle Conservation Plan
(when there is no federal nexus). Proponents should implement conservation measures to avoid
or minimize the production of project-related stressors or minimize the exposure of birds and
their resources to the project-related stressors. For more information on avian stressors and
recommended conservation measures see https://www.fws.gov/birds/bird-enthusiasts/threats-to-
birds.php.
In addition to MBTA and BGEPA, Executive Order 13186: Responsibilities of Federal Agencies
to Protect Migratory Birds, obligates all Federal agencies that engage in or authorize activities
that might affect migratory birds, to minimize those effects and encourage conservation measures
that will improve bird populations. Executive Order 13186 provides for the protection of both
migratory birds and migratory bird habitat. For information regarding the implementation of
Executive Order 13186, please visit https://www.fws.gov/birds/policies-and-regulations/
executive-orders/e0-13186.php.
07/13/2023   3

▪
▪
We appreciate your concern for threatened and endangered species. The Service encourages
Federal agencies to include conservation of threatened and endangered species into their project
planning to further the purposes of the Act. Please include the Consultation Code in the header of
this letter with any request for consultation or correspondence about your project that you submit
to our office.
Attachment(s):
Official Species List
Migratory Birds
07/13/2023   1

OFFICIAL SPECIES LIST
This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the
requirement for Federal agencies to "request of the Secretary of the Interior information whether
any species which is listed or proposed to be listed may be present in the area of a proposed
action".
This species list is provided by:
Raleigh Ecological Services Field Office
Post Office Box 33726
Raleigh, NC 27636-3726
[phone]
07/13/2023   2

PROJECT SUMMARY
Project Code:2023-0104366
Project Name:Brooks Swamp Buffer and Nutrient Offset Mitigation Project
Project Type:Restoration / Enhancement - Forest
Project Description:Converting agricultural fields to protected conservation area and planting
trees and shrubs along project streams.
Project Location:
The approximate location of the project can be viewed in Google Maps: https://
www.google.com/maps/@35.24667705,-78.04355093022687,14z
Counties:Wayne County, North Carolina
07/13/2023   3

1.
ENDANGERED SPECIES ACT SPECIES
There is a total of 5 threatened, endangered, or candidate species on this species list.
Species on this list should be considered in an effects analysis for your project and could include
species that exist in another geographic area. For example, certain fish may appear on the species
list because a project could affect downstream species.
IPaC does not display listed species or critical habitats under the sole jurisdiction of NOAA
Fisheries , as USFWS does not have the authority to speak on behalf of NOAA and the
Department of Commerce.
See the "Critical habitats" section below for those critical habitats that lie wholly or partially
within your project area under this office's jurisdiction. Please contact the designated FWS office
if you have questions.
NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an
office of the National Oceanic and Atmospheric Administration within the Department of
Commerce.
MAMMALS
NAME STATUS
Tricolored Bat Perimyotis subflavus
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/10515
Proposed
Endangered
BIRDS
NAME STATUS
Red-cockaded Woodpecker Picoides borealis
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/7614
Endangered
AMPHIBIANS
NAME STATUS
Neuse River Waterdog Necturus lewisi
There is final critical habitat for this species. Your location does not overlap the critical habitat.
Species profile: https://ecos.fws.gov/ecp/species/6772
Threatened
FISHES
NAME STATUS
Carolina Madtom Noturus furiosus
There is final critical habitat for this species. Your location does not overlap the critical habitat.
Species profile: https://ecos.fws.gov/ecp/species/528
Endangered
1
07/13/2023   4

INSECTS
NAME STATUS
Monarch Butterfly Danaus plexippus
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/9743
Candidate
CRITICAL HABITATS
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S
JURISDICTION.
YOU ARE STILL REQUIRED TO DETERMINE IF YOUR PROJECT(S) MAY HAVE EFFECTS ON ALL
ABOVE LISTED SPECIES.
07/13/2023   1

1.
2.
3.
MIGRATORY BIRDS
Certain birds are protected under the Migratory Bird Treaty Act and the Bald and Golden Eagle
Protection Act .
Any person or organization who plans or conducts activities that may result in impacts to
migratory birds, eagles, and their habitats should follow appropriate regulations and consider
implementing appropriate conservation measures, as described below.
The Migratory Birds Treaty Act of 1918.
The Bald and Golden Eagle Protection Act of 1940.
50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)
The birds listed below are birds of particular concern either because they occur on the
USFWS Birds of Conservation Concern (BCC) list or warrant special attention in your
project location. To learn more about the levels of concern for birds on your list and how this
list is generated, see the FAQ below. This is not a list of every bird you may find in this location,
nor a guarantee that every bird on this list will be found in your project area. To see exact
locations of where birders and the general public have sighted birds in and around your project
area, visit the E-bird data mapping tool (Tip: enter your location, desired date range and a species
on your list). For projects that occur off the Atlantic Coast, additional maps and models detailing
the relative occurrence and abundance of bird species on your list are available. Links to
additional information about Atlantic Coast birds, and other important information about your
migratory bird list, including how to properly interpret and use your migratory bird report, can be
found below.
For guidance on when to schedule activities or implement avoidance and minimization measures
to reduce impacts to migratory birds on your list, click on the PROBABILITY OF PRESENCE
SUMMARY at the top of your list to see when these birds are most likely to be present and
breeding in your project area.
NAME
BREEDING
SEASON
Bald Eagle Haliaeetus leucocephalus
This is not a Bird of Conservation Concern (BCC) in this area, but warrants attention
because of the Eagle Act or for potential susceptibilities in offshore areas from certain types
of development or activities.
Breeds Sep 1 to
Jul 31
Brown-headed Nuthatch Sitta pusilla
This is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions
(BCRs) in the continental USA
Breeds Mar 1
to Jul 15
Chimney Swift Chaetura pelagica
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
and Alaska.
Breeds Mar 15
to Aug 25
1
2
07/13/2023   2

1.
2.
NAME
BREEDING
SEASON
Prairie Warbler Dendroica discolor
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
and Alaska.
Breeds May 1
to Jul 31
Prothonotary Warbler Protonotaria citrea
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
and Alaska.
Breeds Apr 1 to
Jul 31
Red-headed Woodpecker Melanerpes erythrocephalus
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
and Alaska.
Breeds May 10
to Sep 10
Wood Thrush Hylocichla mustelina
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
and Alaska.
Breeds May 10
to Aug 31
PROBABILITY OF PRESENCE SUMMARY
The graphs below provide our best understanding of when birds of concern are most likely to be
present in your project area. This information can be used to tailor and schedule your project
activities to avoid or minimize impacts to birds. Please make sure you read and understand the
FAQ "Proper Interpretation and Use of Your Migratory Bird Report" before using or attempting
to interpret this report.
Probability of Presence ()
Each green bar represents the bird's relative probability of presence in the 10km grid cell(s) your
project overlaps during a particular week of the year. (A year is represented as 12 4-week
months.) A taller bar indicates a higher probability of species presence. The survey effort (see
below) can be used to establish a level of confidence in the presence score. One can have higher
confidence in the presence score if the corresponding survey effort is also high.
How is the probability of presence score calculated? The calculation is done in three steps:
The probability of presence for each week is calculated as the number of survey events in
the week where the species was detected divided by the total number of survey events for
that week. For example, if in week 12 there were 20 survey events and the Spotted Towhee
was found in 5 of them, the probability of presence of the Spotted Towhee in week 12 is
0.25.
To properly present the pattern of presence across the year, the relative probability of
presence is calculated. This is the probability of presence divided by the maximum
probability of presence across all weeks. For example, imagine the probability of presence
in week 20 for the Spotted Towhee is 0.05, and that the probability of presence at week 12
(0.25) is the maximum of any week of the year. The relative probability of presence on
week 12 is 0.25/0.25 = 1; at week 20 it is 0.05/0.25 = 0.2.
07/13/2023   3

3.
 no data survey effort breeding season probability of presence
The relative probability of presence calculated in the previous step undergoes a statistical
conversion so that all possible values fall between 0 and 10, inclusive. This is the
probability of presence score.
Breeding Season ()
Yellow bars denote a very liberal estimate of the time-frame inside which the bird breeds across
its entire range. If there are no yellow bars shown for a bird, it does not breed in your project
area.
Survey Effort ()
Vertical black lines superimposed on probability of presence bars indicate the number of surveys
performed for that species in the 10km grid cell(s) your project area overlaps. The number of
surveys is expressed as a range, for example, 33 to 64 surveys.
No Data ()
A week is marked as having no data if there were no survey events for that week.
Survey Timeframe
Surveys from only the last 10 years are used in order to ensure delivery of currently relevant
information. The exception to this is areas off the Atlantic coast, where bird returns are based on
all years of available data, since data in these areas is currently much more sparse.
SPECIES JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Bald Eagle
Non-BCC
Vulnerable
Brown-headed
Nuthatch
BCC - BCR
Chimney Swift
BCC Rangewide
(CON)
Prairie Warbler
BCC Rangewide
(CON)
Prothonotary
Warbler
BCC Rangewide
(CON)
Red-headed
Woodpecker
BCC Rangewide
(CON)
07/13/2023   4

▪
▪
▪
Wood Thrush
BCC Rangewide
(CON)
Additional information can be found using the following links:
Birds of Conservation Concern https://www.fws.gov/program/migratory-birds/species
Measures for avoiding and minimizing impacts to birds https://www.fws.gov/library/
collections/avoiding-and-minimizing-incidental-take-migratory-birds
Nationwide conservation measures for birds https://www.fws.gov/sites/default/files/
documents/nationwide-standard-conservation-measures.pdf
MIGRATORY BIRDS FAQ
Tell me more about conservation measures I can implement to avoid or minimize impacts
to migratory birds.
Nationwide Conservation Measures describes measures that can help avoid and minimize
impacts to all birds at any location year round. Implementation of these measures is particularly
important when birds are most likely to occur in the project area. When birds may be breeding in
the area, identifying the locations of any active nests and avoiding their destruction is a very
helpful impact minimization measure. To see when birds are most likely to occur and be breeding
in your project area, view the Probability of Presence Summary. Additional measures or permits
may be advisable depending on the type of activity you are conducting and the type of
infrastructure or bird species present on your project site.
What does IPaC use to generate the list of migratory birds that potentially occur in my
specified location?
The Migratory Bird Resource List is comprised of USFWS Birds of Conservation Concern
(BCC) and other species that may warrant special attention in your project location.
The migratory bird list generated for your project is derived from data provided by the Avian
Knowledge Network (AKN). The AKN data is based on a growing collection of survey, banding,
and citizen science datasets and is queried and filtered to return a list of those birds reported as
occurring in the 10km grid cell(s) which your project intersects, and that have been identified as
warranting special attention because they are a BCC species in that area, an eagle (Eagle Act
requirements may apply), or a species that has a particular vulnerability to offshore activities or
development.
Again, the Migratory Bird Resource list includes only a subset of birds that may occur in your
project area. It is not representative of all birds that may occur in your project area. To get a list
of all birds potentially present in your project area, please visit the Rapid Avian Information
Locator (RAIL) Tool.
What does IPaC use to generate the probability of presence graphs for the migratory birds
potentially occurring in my specified location?
07/13/2023   5

1.
2.
3.
The probability of presence graphs associated with your migratory bird list are based on data
provided by the Avian Knowledge Network (AKN). This data is derived from a growing
collection of survey, banding, and citizen science datasets.
Probability of presence data is continuously being updated as new and better information
becomes available. To learn more about how the probability of presence graphs are produced and
how to interpret them, go the Probability of Presence Summary and then click on the "Tell me
about these graphs" link.
How do I know if a bird is breeding, wintering or migrating in my area?
To see what part of a particular bird's range your project area falls within (i.e. breeding,
wintering, migrating or year-round), you may query your location using the RAIL Tool and look
at the range maps provided for birds in your area at the bottom of the profiles provided for each
bird in your results. If a bird on your migratory bird species list has a breeding season associated
with it, if that bird does occur in your project area, there may be nests present at some point
within the timeframe specified. If "Breeds elsewhere" is indicated, then the bird likely does not
breed in your project area.
What are the levels of concern for migratory birds?
Migratory birds delivered through IPaC fall into the following distinct categories of concern:
"BCC Rangewide" birds are Birds of Conservation Concern (BCC) that are of concern
throughout their range anywhere within the USA (including Hawaii, the Pacific Islands,
Puerto Rico, and the Virgin Islands);
"BCC - BCR" birds are BCCs that are of concern only in particular Bird Conservation
Regions (BCRs) in the continental USA; and
"Non-BCC - Vulnerable" birds are not BCC species in your project area, but appear on
your list either because of the Eagle Act requirements (for eagles) or (for non-eagles)
potential susceptibilities in offshore areas from certain types of development or activities
(e.g. offshore energy development or longline fishing).
Although it is important to try to avoid and minimize impacts to all birds, efforts should be made,
in particular, to avoid and minimize impacts to the birds on this list, especially eagles and BCC
species of rangewide concern. For more information on conservation measures you can
implement to help avoid and minimize migratory bird impacts and requirements for eagles,
please see the FAQs for these topics.
Details about birds that are potentially affected by offshore projects
For additional details about the relative occurrence and abundance of both individual bird species
and groups of bird species within your project area off the Atlantic Coast, please visit the
Northeast Ocean Data Portal. The Portal also offers data and information about other taxa besides
birds that may be helpful to you in your project review. Alternately, you may download the bird
model results files underlying the portal maps through the NOAA NCCOS Integrative Statistical
Modeling and Predictive Mapping of Marine Bird Distributions and Abundance on the Atlantic
Outer Continental Shelf project webpage.
07/13/2023   6

Bird tracking data can also provide additional details about occurrence and habitat use
throughout the year, including migration. Models relying on survey data may not include this
information. For additional information on marine bird tracking data, see the Diving Bird Study
and the nanotag studies or contact Caleb Spiegel or Pam Loring.
What if I have eagles on my list?
If your project has the potential to disturb or kill eagles, you may need to obtain a permit to avoid
violating the Eagle Act should such impacts occur.
Proper Interpretation and Use of Your Migratory Bird Report
The migratory bird list generated is not a list of all birds in your project area, only a subset of
birds of priority concern. To learn more about how your list is generated, and see options for
identifying what other birds may be in your project area, please see the FAQ "What does IPaC
use to generate the migratory birds potentially occurring in my specified location". Please be
aware this report provides the "probability of presence" of birds within the 10 km grid cell(s) that
overlap your project; not your exact project footprint. On the graphs provided, please also look
carefully at the survey effort (indicated by the black vertical bar) and for the existence of the "no
data" indicator (a red horizontal bar). A high survey effort is the key component. If the survey
effort is high, then the probability of presence score can be viewed as more dependable. In
contrast, a low survey effort bar or no data bar means a lack of data and, therefore, a lack of
certainty about presence of the species. This list is not perfect; it is simply a starting point for
identifying what birds of concern have the potential to be in your project area, when they might
be there, and if they might be breeding (which means nests might be present). The list helps you
know what to look for to confirm presence, and helps guide you in knowing when to implement
conservation measures to avoid or minimize potential impacts from your project activities,
should presence be confirmed. To learn more about conservation measures, visit the FAQ "Tell
me about conservation measures I can implement to avoid or minimize impacts to migratory
birds" at the bottom of your migratory bird trust resources page.
07/13/2023   7

IPAC USER CONTACT INFORMATION
Agency:Private Entity
Name:Daniel Ramsay
Address:150 Wrenn Drive #5842
City:Cary
State:NC
Zip:27512
Email [e-mail]
Phone:[phone]
NCNHDE-22648
July 13, 2023
Daniel Ramsay
RestorEcology, LLC
150 Wrenn Dr. #5842
Cary, NC 27512
RE: Brooks Swamp Buffer and Nutrient Offset Mitigation Project
Dear Daniel Ramsay:
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
Brooks Swamp Buffer and Nutrient Offset Mitigation Project
July 13, 2023
NCNHDE-22648
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
Freshwater Fish42759 Notropis chalybaeus Ironcolor Shiner 1946-06-27 H 3-Medium --- Threatened G4 S2S3
No Natural Areas are Documented Within a One-mile Radius of the Project Area
No Managed Areas are Documented Within a One-mile Radius of the Project Area
Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.org/help. Data query generated on July 13, 2023; source: NCNHP, Spring (April) 2023. 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
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7/27/23, 1:17 PM RestorEcology, LLC Mail - Re: Brooks Swamp Buffer and Nutrient Bank, IPAC # 2023-0104366
https://mail.google.com/mail/u/1/?ik=8f6548446f&view=pt&search=all&permthid=thread-f:1772592548503661122&simpl=msg-f:177259254850366112…1/2
Daniel Ramsay <[e-mail]>
Re: Brooks Swamp Buffer and Nutrient Bank, IPAC # 2023-0104366
2 messages
Matthews, Kathryn H <[e-mail]>Thu, Jul 27, 2023 at 12:39 PM
To: "[e-mail]" <[e-mail]>
Cc: "Mann, Leigh" <[e-mail]>
Hi Daniel,
Based on the informaon provided and other informaon available, it appears that the proposed acon is
not likely to adversely affect any federally-listed endangered or threatened species, their formally
designated crical habitat, or species currently proposed for lisng under the Act at this site. Thank you for
the opportunity to consult.
Sincerely,
Please note that I am teleworking Wednesday through Friday, every week. Email is the best way to reach
me. Thanks,
Kathy Mahews
NC Renewable Energy Coordinator &
Fish and Wildlife Biologist
U.S. Fish and Wildlife Service
551-F Pylon Drive
Raleigh, NC 27606
919-856-4520, x. 27
From: Daniel Ramsay <[e-mail]>
Sent: Monday, July 17, 2023 6:13 PM
To: Raleigh, FW4 <[e-mail]>
Subject: [EXTERNAL] Project Review Request, Brooks Swamp Buffer and Nutrient Bank, IPAC # 2023-0104366

This email has been received from outside of DOI - Use caution before clicking on links, opening attachments,
or responding.
Good afternoon,
I would like to request USFWS concurrence with the attached Online Project Review Package for Brooks Swamp Buffer
and Nutrient Offset Mitigation Bank Project, IPAC #2023-0104366, in Wayne County, NC. I look forward to receiving the
USFWS' response.
Regards,
7/27/23, 1:17 PM RestorEcology, LLC Mail - Re: Brooks Swamp Buffer and Nutrient Bank, IPAC # 2023-0104366
https://mail.google.com/mail/u/1/?ik=8f6548446f&view=pt&search=all&permthid=thread-f:1772592548503661122&simpl=msg-f:177259254850366112…2/2
Daniel
--
Daniel Ramsay, PWS
Owner
m: 919.817.7378 | www.restorecology.com
Brooks Swamp Coordination Letter - USFWS.pdf
5245K
Daniel Ramsay <[e-mail]>Thu, Jul 27, 2023 at 1:17 PM
To: "Matthews, Kathryn H" <[e-mail]>
Cc: "Mann, Leigh" <[e-mail]>
Hi Kathryn,
Thanks very much for the feedback. Have a great weekend.
Thanks,
Daniel
[Quoted text hidden]
150 WRENN DR, #5842, CARY, NC 27512
T [phone] U WWW.RESTORECOLOGY.COM
From: Daniel Ramsay
RestorEcology Neuse, LLC (RestorEcology)
PO Box 5842
Cary, NC 27512
919-817-7378
[e-mail]
To: Ms. Renee Gledhill-Earley
State Historic Preservation Office
4617 Mail Service Center
Raleigh, NC 27699-4617
Transmitted via email to: [e-mail]
July 17, 2023
Re: Project Review Request, Brooks Swamp Buffer and Nutrient Offset Bank Project (Brooks
Swamp), Wayne County, North Carolina, NC Division of Water Resources (DWR) #20230163
Dear Ms. Gledhill-Earley,
RestorEcology would like to request a project review for Brooks Swamp, a proposed riparian
buffer and nutrient offset restoration project regulated by the DWR. The Project is located at
35.2487418°N, 78.0413133°W in the Neuse River Basin (HUC 03020201). The location of the
project and the action area are identified on the enclosed USGS topographic map and aerial
photo map.
Our proposed action consists of: approximately 11.1 acres of cropland will be planted with native
hardwood trees and shrubs to lessen nutrient inputs into the streams from agricultural activities
and provide restored stream buffers. Existing wooded stream buffers within the project area will
be preserved or enhanced. Waters of the U.S. permitting under Section 404/401 of the Clean
Water Act will not be required for the Project because changes to Project streams are not
proposed. Riparian buffer credits and nitrogen (lb) will be generated by the Project. Credits will
be sold on the private mitigation bank market to offset development impacts within the Neuse

2
River Basin (HUC 03020201), excluding the Falls Lake Watershed. The project tree planting is
expected to be completed by winter 2024/2025.

Based on aerial photographs, USGS topographic maps, and our on-site review of the project area,
there are no historic properties (buildings, structures, districts, archaeological sites, or designed
landscape features that are listed in, or eligible for listing in, the National Register of Historic
Places, or that are 50 or more years old) within or immediately adjacent to the project area.

For additional information, please contact Daniel Ramsay at the address listed above.

Sincerely,

Daniel Ramsay, PWS
Owner, RestorEcology

Enclosures:
• USGS Topographic Map
• Aerial Photo Map

0 0.150.07 Km
0 400200Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Brooks Swamp Buffer and
Nutrient Offset Mitigation Bank
Old

M
t
Ol
i
ve
Hwy
Parker

R
d
Esri Community Maps Contributors, City of Goldsboro, State of North
Carolina DOT, © OpenStreetMap, Microsoft, Esri, HERE, Garmin,
SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, EPA, NPS, US
Census Bureau, USDA, NC OneMap, NC Center for Geographic
Information and Analysis, NC 911 Board
Legend
Streams
Project Area
0 0.30.15 Km
0 800400Feet
±
Coordinate System: NAD 1983 2011 StatePlane North Carolina FIPS 3200 Ft US
2023
Brooks Swamp Buffer and
Nutrient Offset Mitigation Bank
Copyright:© 2013 National Geographic Society, i-cubed
Legend
Project Area
Mount Olive Quadrangle

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper Office of Archives and History
Secretary D. Reid Wilson Deputy Secretary, Darin J. Waters, Ph.D.

Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898
August 2, 2023

Daniel Ramsay [e-mail]
RestorEcology Neuse, LLC
PO Box 5842
Cary, NC 27512

Re: Brooks Swamp Buffer and Nutrient Offset Bank, 27530-3930 Old Mt Olive Highway, Goldsboro,
Wayne County, ER 23-1625

Dear Mr. Ramsay:

Thank you for your letter of July 17, 2023, concerning the above-referenced undertaking. We have
reviewed the submittal and offer the following comments.

We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.

The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation’s Regulations for Compliance with Section 106 codified at 36
CFR Part 800.

Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill-Earley, environmental review coordinator, at 919-814-6579
or [e-mail]. In all future communication concerning this project, please cite the
above referenced tracking number.

Sincerely,

Ramona Bartos, Deputy
State Historic Preservation Officer

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
Brooks Swamp
0 Old Mt. Olive Highway
Dudley, NC 28333
Inquiry Number: 7410134.2s
August 07, 2023
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 Source Map A-7
Physical Setting Source Map Findings A-8
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.
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TC7410134.2s Page 1
EXECUTIVE SUMMARY
TC7410134.2s 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 (E2247 - 16), the ASTM Standard Practice for Limited
Environmental Due Diligence: Transaction Screen Process (E1528 - 22) or custom requirements developed
for the evaluation of environmental risk associated with a parcel of real estate.
TARGET PROPERTY INFORMATION
ADDRESS
0 OLD MT. OLIVE HIGHWAY
DUDLEY, NC 28333
COORDINATES
35.2466910 - 35˚ 14’ 48.08’’Latitude (North):
78.0430970 - 78˚ 2’ 35.14’’Longitude (West):
Zone 17Universal Tranverse Mercator:
769056.4UTM X (Meters):
3904211.0UTM Y (Meters):
141 ft. above sea levelElevation:
USGS TOPOGRAPHIC MAP ASSOCIATED WITH TARGET PROPERTY
13847247 MOUNT OLIVE, NCTarget Property Map:
2019Version Date:
13846641 SOUTHWEST GOLDSBORO, NCNorth Map:
2019Version Date:
AERIAL PHOTOGRAPHY IN THIS REPORT
20200930Portions of Photo from:
USDASource:
7410134.2s Page 2
1 GA-PACIFIC CORP COMP OLD MOUNT OLIVE HIGH SHWS Higher 3751, 0.710, NNE
Reg GA-PACIFIC CORP COMP NC HSDS Same 3907, 0.740, NNE
MAPPED SITES SUMMARY
Target Property Address:
0 OLD MT. OLIVE HIGHWAY
DUDLEY, NC 28333
Click on Map ID to see full detail.
MAP RELATIVE DIST (ft. & mi.)
ID DATABASE ACRONYMS ELEVATION DIRECTIONSITE NAME ADDRESS
EXECUTIVE SUMMARY
TC7410134.2s EXECUTIVE SUMMARY 7
STANDARD ENVIRONMENTAL RECORDS
Lists of state- and tribal (Superfund) equivalent sites
NC HSDS: The Hazardous Substance Disposal Sites list contains locations of uncontrolled and
unregulated hazardous waste sites. The file contains sites on the national priority list as well as the state
priority list. The data source is the North Carolina Center for Geographic Information and Analysis.
A review of the NC HSDS list, as provided by EDR, and dated 08/09/2011 has revealed that there is 1
NC HSDS site within approximately 1 mile of the target property.
PageMap IDDirection / Distance Address Equal/Higher Elevation ____________________ ________ ___________________ _____ _____
GA-PACIFIC CORP COMP NNE 1/2 - 1 (0.740 mi.) 0 8
Lists of state- and tribal hazardous waste facilities
SHWS: The State Hazardous Waste Sites records are the states’ equivalent to CERCLIS. These sites
may or may not already be listed on the federal CERCLIS list. Priority sites planned for cleanup using state
funds (state equivalent of Superfund) are identified along with sites where cleanup will be paid for by
potentially responsible parties. The data come from the Department of Environment & Natural Resources’
Inactive Hazardous Sites Program.
A review of the SHWS list, as provided by EDR, and dated 02/28/2023 has revealed that there is 1 SHWS
site within approximately 1 mile of the target property.
PageMap IDDirection / Distance Address Equal/Higher Elevation ____________________ ________ ___________________ _____ _____
GA-PACIFIC CORP COMP OLD MOUNT OLIVE HIGH NNE 1/2 - 1 (0.710 mi.) 1 8
Facility Id: NCD000813659
EXECUTIVE SUMMARY
TC7410134.2s EXECUTIVE SUMMARY 8
Due to poor or inadequate address information, the following sites were not mapped. Count: 1 records.
Site Name Database(s)____________ ____________
GA-PACIFIC CORP CHIP-N-SAW SHWS
EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.EDR Inc.
2
00
160
1 6 0
1
6
0
160
1 2
0
1
6
0
1 6 0
16
0
1 6 0
1 6 0
1 6 0
1
6
0
1 6 0 1
6
0
160
2 0
1 6 0
1 6 0
1
6 0
1
20 1 20
120
1
2
0120
120
160
1 6 0
16 0
1 6 0
160
1
6
0
1 6 0
160
16 0
MAP FINDINGSMap ID
Direction
EDR ID NumberDistance
EPA ID NumberDatabase(s)SiteElevation
678702.267144Area of feature in internal units squared:
3376.46011275Length of feature in internal units:
640Sites designated as superfund cleanup sites:
552116.75Y-value coordinate in feet:
2288399.75X-value coordinate in feet:
3376.45996093Total perimeter in coverage units:
678702.25Total area in coverage units:
Not reportedSuperfun Number:
1Site Type:
Not reportedCity:
Not reportedAddress:
GA-PACIFIC CORP COMPLYName:
HSDS:
3907 ft.
1/2-1
NNE , NC
Region N/A
HSDS NC HSDSGA-PACIFIC CORP COMPLY S102442728
Click here to access the North Carolina DEQ records for this facility:
Not reportedGeolocation Method:
Not reportedLat/Longitude:
NCD000813659EPAID:
DUDLEY, NCCity,State,Zip:
OLD MOUNT OLIVE HIGHWAYAddress:
GA-PACIFIC CORP COMPLYName:
SHWS:
3751 ft.
0.710 mi.
Relative:
Higher
Actual:
177 ft.

1/2-1 DUDLEY, NC
NNE OLD MOUNT OLIVE HIGHWAY N/A
1 SHWSGA-PACIFIC CORP COMPLY S104918995
TC7410134.2s Page 8
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mike Golden, Plant Manger
Georgia-Pacific Wood Products, LLC
139 Brewington Rd
Dudley, NC 28333
Dear Mr. Golden:
NORTH CAROLINA
Environmental Quality
April 5, 2022
Subject: Draft NPDES Permit NC0090051
Georgia Pacific Dudley Plywood Facility
Physical Chemical Not Classified WPCS
Wayne County
The Division has reviewed your request for the subject NPDES permit. Please review this draft carefully
to ensure a thorough understanding of the information, conditions, and requirements it contains.
The NPDES standard conditions (Parts II, III, and IV) that are a part of the permit are not included in this
draft document (cover, map, and Part I). The conditions are the same as in your current permit except that
agency and division names have been updated. The latest version is available at https://bit.ly/2BZ4xxx
and can be viewed online or downloaded as a PDF file.
With this notification, the Division will solicit public comment on this draft permit by publishing a notice
in newspapers having circulation in the general Wayne County area, per EPA requirements. Please
provide your comments, if any, to me at the address below no later than 30 days after receiving this
draft permit.
Following the 30-day public comment period, the Division will review all pertinent comments and take
appropriate action prior to issuing a final permit. If you have questions concerning the draft, please
contact me at 919-707-3618, or via e-mail at [[e-mail]].
Sincerely,
t(witc-ri,,,,,,,(__--
Derek Denard, Environmental Specialist
NPDES Compliance and Expedited Permitting
Division of Water Resources, NCDEQ
cc: NPDES File
WaRO / Robert Tankard [[e-mail]]
Wastewater Operator Certification Group [[e-mail]]
r:I_E
NORTH CAROLINA
Department of Environmental Duali
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919. 707.9000
Outfall 001
f
Esri Community Maps
Contributors, City of Goldsboro,
State of North Carolina DOT,
OpenStreetMap, Microsoft, Esri,
HERE, Garmin, SafeGraph,
GeoTechnologies, Inc, METI/NASA,
USGS, EPA, NPS, US Census
Bureau, USDA, NC CGIA, Maxar„
M icrosofr
Brooks Swamp
Outfall 001
UT to Brooks Swamp
arrr1,veN orri,
USGS The National Map: National Bpundaries Dataset, 3DEP Elevation
Program, Geographic Names Information System, National Hydrography
Dataset, National Land Cover Database, National. Structures Dataset, and
National Transportation Dataset; USGS Global Ecosystems; U.S. Census
Bureau TIGER/Line data; USFS-Road Data; Natural Earth Data; U.S.
Department of State Humanitarian Information Unit; and NOAA National
Centers for Environmental Information, U.S. Coastal Relief Model. Data
refreshed August, 2021.
N
Georgia Pacific Dudley Plywood Facility
NPDES Permit NC0090051
139 Brewington Dr, Dudley
Receiving Stream: UT to Brooks Swamp (Buck Swamp)
Stream Index: 27-54-5-2 Stream Class: WS-IV; NSW
River Basin: Neuse Sub -Basin #: 03-04-12
County: Wayne HUC: 030202011401
SCALE
1:24,000
Outfall 001: 35° 15' 36" N, -78° 02' 17" W
USGS Quad: SW Goldsboro, NC