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G:\.Clients All\Hugo\Proposals\North Star Wetland Bank\Prospectus\PROPOSAL_North Star Wetland Bank Prospectus - <br />052323.docx <br />2. Comment: Multiple wetland delineations have been completed on the site and <br />these delineation results contradict credit estimations provided in the Draft <br />Prospectus. While a degraded wetland is present, there is no delineation <br />confirming that areas adjacent to ditches are fully drained and non-wetland. <br />Therefore, there is no justification for 100 percent Re-establishment credit as <br />suggested. <br /> <br />Action: Existing wetland delineations were completed at the edges of the wetland <br />complex. No investigation has been conducted around the linear ditches or <br />throughout the middle of the complex. Additional delineation will need to be <br />completed throughout the site to determine whether the areas adjacent to the <br />ditches have retained wetland characteristics. The results of the wetland <br />delineation of the interior of the site will determine whether Restoration or <br />Enhancement credits are to be pursued. <br /> <br />3. Comment: The drainage present appears to be modest, with most ditches two <br />feet or less deep. This suggest the extent of hydrology degradation caused by <br />the ditches (and therefore restoration potential) is significantly less than shown in <br />the Draft Prospectus. If no drain tile is found a more appropriate hydrology <br />restoration zone would be limited only to corridors along ditches being disabled. <br />Areas beyond this relatively narrow drainage effect corridor would not be eligible <br />for Restoration credit (Re-establishment or Rehabilitation) but could be eligible <br />for Enhancement credit. <br /> <br />Action: There may be locations within the property that enhancement credit will <br />be requested, but not the whole property. We need to complete a level 2 <br />delineation to determine the actual existing wetlands within the entire project <br />limits because the previous delineations only demarked external boundaries. <br />With the new 2023 hydrology monitoring data, we’ll have a better idea of the <br />scope and effect of the existing ditches. During site visit on May 25, 2023, we <br />identified areas of spoil piles that will be defined in level 2 delineation as upland <br />that we will propose to remove for restoration credit. <br /> <br />4. Comment: Hydrology monitoring should be continued (possibly expanded) to <br />document baseline hydrology information in the beginning of the growing season <br />and to help the sponsor write appropriate hydrology performance standards for <br />this partially drained existing wetland. Hydrology information provided only <br />documented mid-summer to fall hydrology conditions. <br /> <br />Action: Wells have been installed on site for the 2023 growing season. <br /> <br />5. Comment: If the federal Enhancement credit action is used, the sponsor will face <br />significant challenges when controlling the monotypic reed canary grass areas <br />and other non-native or invasive species. Successfully controlling reed canary <br />grass, and other species, on a site this large and achieving acceptable native- <br />dominated plant community performance standard will be extremely difficult and <br />resource intensive, both in the short- and long-terms. Significant site preparation <br />and management work will be required, supplemental native seeding may be