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Nature Coast Estuarine/Freshwater Mitigation Bank

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Nature Coast Estuarine/Freshwater Mitigation Bank Nature Coast Estuarine/Freshwater Mitigation Bank (NCEMB) – Application # 737290 October 23, 2017 Response Responses to August 21, 2017 Clarification of Received Information (CLAR) items: SITE INFORMATION: 1. The District received a letter from the Division of Historical Resources (DHR), a branch of the Florida Department of State, on January 30, 2017. Florida's Coastal Management Program (FCMP) allows the DHR the opportunity to determine a project's compliance with the enforceable statutes of this program that are within its jurisdiction. This letter stated that the project area has not been surveyed for archaeological and historical properties and DHR recommends “that the project area be subjected to a professional cultural resources assessment survey.” Please provide any correspondence from DHR in regards to the results of the cultural resource report completed by Environmental Services, Inc. on July 11, 2017. This information was indicated as being needed for the DHR to determine whether the proposed project is consistent with the enforceable statutes of FCMP. Applications for projects found to be inconsistent with the enforceable statutes of the FCMP are required to be denied. You are requested to coordinate directly with the DHR to resolve any concerns that they may have regarding the results of July 11, 2017 work. (Chapter 373.428, F.S.) Please see attached correspondence from DHR (Attachment 1). There are no concerns to be resolved. ENVIRONMENTAL CONSIDERATIONS: 2. The submitted wetland mitigation bank ledger to be utilized for future credit withdrawals should be modified to list the number and type of mitigation credits in the proposed mitigation bank as required under Rule 62-342.470 (5), F.A.C. The ledger was updated to include the types of mitigation credit; however, the number of credits was missing. The number of credits will need to be included in the ledger once the UMAM analysis and scoring is finalized. Please make the appropriate revision to the wetland mitigation bank ledger. [Rule 62-342.450, F.A.C. and 62-342.470(5), F.A.C.] The wetland mitigation ledger has been updated to include the credits. Please see attached (Attachment 2). 3. After review of revised Figure 7 of the environmental report, the proposed custom service area includes two watershed boundaries (Upper Coastal and Tampa Bay) on the plan view and not hydrologic unit codes (HUC). Please revise Figure 7 to include the HUC boundary limits, outside of the Upper Coastal Watershed, as discussed with District staff. Also, please provide detailed information and documentation, including sources of information, regarding the determination of the boundary limits of the proposed custom mitigation bank service area within the Tampa Bay region. As previously stated, please take note that the portion of the customized service area within the Tampa Bay watershed will only apply to the Estuarine Forested and Estuarine Herbaceous credits within Parcel B. HUC boundaries should not be modified when delineating the custom service area within the Tampa Bay region. This information is needed to demonstrate that the proposed wetland mitigation bank provides exceptional ecological value such that adverse impacts to wetlands outside the Upper Coastal Basin could reasonably be expected to be adequately offset by the Mitigation Bank because of local ecological and hydrological conditions. Contact Joe Andress at extension 2073 to discuss this matter. [Rule 62-342.600 (2), F.A.C.] Please see the revised Figure 7 as discussed on October 18, 2017 (Attachment 3), and an updated narrative justifying the inclusion of designated units within the Tampa Bay Watershed HUC 03100206 in NCEMB’s service area for estuarine wetland impacts (Attachment 4). 4. Please revise Figures 10a and 10b to include correct identifiers, as represented on the baseline data report, for all transect locations being sure to provide one identifier for each transect. There are transect locations with no identifiers and two identifiers associated with one transect on these figures (e.g. Figure 10b). Be sure to also revise Figure 10a labeling the transect identifiers as represented on the baseline report. Please identify the location of V-B10 and V-B11 on Figure 10b as the transect data was included in the baseline report but not shown on this figure (Figure 10b). Information from the baseline data report is missing for transect V-B1 as shown on Figure 10b. Please provide baseline data for transect V-B1. [Rule 62-342.450, F.A.C.] Figure 10b erroneously contained a couple of transect lines that should have been removed when the living shoreline planting plan was removed. The Baseline Report Tables and Figures 10a-10b have been appropriately relabeled. Please see attached Tables and Figures 10a and 10b (Attachment 3). 5. Please revise the UMAM scoring rounding up to the nearest hundredth for only the final calculation to determine the functional gain for each assessment area. The submitted UMAM scoring rounded to the nearest hundredth for each separate calculation. District staff may have further questions and/or comments once the revised UMAM scoring is submitted and the total UMAM functional gain credit is accurately identified. [Rule 62-342.450, F.A.C. and Rule 62-345.500 F.A.C.] Please see attached revised UMAM Table 8 per the meeting discussion with SWFWMD on October 18, 2017. As a result of these adjustments, Tables 4-5, page 28 of the Mitigation Plan were updated (Attachment 4), as well as the UMAM Part II credit totals to correspond to the adjusted final credits identified on Table 8 (Attachment 2). 6. Please provide a certified cost estimate based on a third party performing the work at the fair market value of services. The certified cost estimate needs to include all the information required under 62-342.700 (10), F.A.C. The submitted cost estimate is also missing information (e.g. taxes, tree thinning/mechanical shrub reduction, etc.). The submitted cost estimate, which was signed and sealed by the engineer-of-record, includes itemized costs which are not comparable for the anticipated work type including all construction and implementation activities, as well as, annualized cost for labor/application/chemicals associated with nuisance and exotic species control. Provide information (e.g. herbicide application methodology) and/or documentation justifying the cost per acre associated with the construction and implementation, as well as, annualized cost for labor/application/chemicals associated with nuisance and exotic species control. Also, a cost for feral hog harvest associated the construction and implementation cost estimate, as well as, annualized cost estimate needs to be added to the cost estimates. The burn plan identifies a prescribed burn rotational cycle of 2-8 years; therefore, please revise annualized cost estimate to include a 2 year burn regime and provide justification for this cost (prescribed burn). Please take note that Parcels A and B are not contiguous areas and costs, including but not limited to, transportation, labor, etc. should differ between these two parcels. All activities (feral hog removal, tree thinning/mechanical shrub reduction, etc.), for both parcels (Parcels A and B) should have a cost identified on the cost estimate tables. Once a certified cost estimate is submitted further questions and/or comments may need to be addressed [Rule 62-342.700 (10), F.A.C]. As discussed during the October 18, 2017 meeting with SWFWMD, please see attached narrative documentation describing the basis for the approved NCEMB cost estimates (Attachment 4). The estimated cost tables for construction and perpetual management include appropriate information for the NCEMB in accordance with the proposed plans and schedules. They were submitted and signed/sealed by an engineer via engineer manifest as required by SWFWMD. 7. The revised “Hunt Plan” identifies that “Hunting will be limited to the NCLLC and its family or NCLLC guests.” Please remove the comment “…or a limited number of “hunt club members is authorized,” within Section 1.4, entitled “Summary of Proposed Mitigation” of the environmental report. District staff was informed that the hunting activity would be limited to family members and/or friends of the family….. The Mitigation Plan: Section 1.4 is revised to remove the comment “or a limited number…” (Attachment 4). 8. LiDAR elevation data was missing for a portion of the assessment area identified as W3r along the main channel of Sam’s Bayou on Figure 5b-2. Please revise Figure 5B-2 providing LiDAR data for this area along Sam’s Bayou. Also, a 20-foot Noncredit Zone was not identified along the edge of water for a portion of assessment area W3r near the main channel of Sam’s Bayou as represented on Figure 5b; therefore, please provide information explaining why a 20-foot noncredit Zone was not applied to this area(s)…. LIDAR elevation data is not missing from a portion of the assessment area identified as W4e along the main channel of Sams Bayou. As demonstrated during the October 18, 2017 meeting with SWFWMD, the data was present, was incorporated, and was identified but was not visible on the submitted 8½x11 figure scale. Figures 5b-5b-2 are acceptable as provided pursuant to the meeting with SWFWMD on October 18, 2017. OPERATION AND MAINTENANCE AND LEGAL DOCUMENTATION: 9. Please address the following comments from the District’s Survey Department and make the necessary revisions or provide the requested documentation regarding the submitted draft conservation easement and title commitment: a. The Draft Conservation Easement Exhibit A contains scriveners errors found on the first page of the “Legal Description—Nature Coast Mitigation Bank” which must be corrected, also, each page of the legal description needs to have page numbers that make it part of the Draft Conservation Easement. A description of the scriveners errors will be provided under separate cover to the applicant’s consultant….
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