Appendix K - Federal and State TE Species Survey

Piedmont Lithium Carolinas, Inc. I Response to DEMLR Additional Information Request
Appendices
PIEDMONT
LITHIUM
K
Appendix K: Federally and
State -Threatened and
Endangered Species Survey

hdrinc.com
Memo
Date: November 4, 2021 — rev. November 8, 2021
Project: PLCI Carolina Lithium Project
To: Patrick Brindle — Piedmont Lithium Carolinas, Inc.
From: Kelly Thames — HDR
Blake Hartshorn — HDR
Subject: Federally and State -Threatened and Endangered Species Survey
Piedmont Lithium Carolinas, Inc. (PLCI) intends to develop an open pit lithium mine and
chemical conversion operation, known as the Carolina Lithium Project, approximately 1
mile east of the Town of Cherryville, North Carolina. The Carolina Lithium Project includes
1,548 acres located south of Hephzibah Church Road, and west of Aderholdt Road, in
Gaston County (Appendix A, Figures 1 and 2). The surveyed area referenced herein
("Project Site" or "Site") encompasses a 929-acre area, which includes approximately 228
acres that is outside of the 1,548-acre Carolina Lithium Project area. In 2018, HDR
conducted a Threatened and Endangered Species survey of a 971-acre area immediately
adjacent to the 929-acre survey area referenced herein. HDR's 2018 Threatened and
Endangered Species Survey report of the original 971-acre survey area is included in
Appendix B along with associated correspondence from the United States Fish and
Wildlife Service (USFWS) regarding a 2019 Clean Water Act Section 404 permit action.
This memo presents the findings of a threatened and endangered species habitat
assessment conducted by HDR for PLCI to support planning efforts for the Project Site's
development. HDR's approach to this study involved conducting a desktop review of
publicly available data as well as on -site surveys to evaluate potential habitat presence or
absence for federally and state -protected species. The following information provides a
summary of HDR's methods and findings of the desktop review and on -site field
reconnaissance.
Description of Project Site
The Project Site consists of undeveloped planted cropland, residential areas, animal
pastures, mixed hardwood forest, bottomland hardwood forest, multiple forested wetlands,
and multiple jurisdictional streams. (Appendix A, Figure 2). Much of the project Site
exhibited planted pines, cattle disturbance, highly modified understory, or timber and
agricultural practices with heavy disturbance.
440 S. Church St, Suite 1000, Charlotte, NC 28202-2075
[phone]

Carolina Lithium Project I Piedmont Lithium Carolinas, Inc. ���
Threatened and Endangered Species Memorandum
Dominant woody species consist of loblolly pine (Pinus taeda), tulip poplar (Liriodendron
tulipifera), sweetgum (Liquidambar styraciflua), and multiple oak (Quercus spp.) and
hickory species (Carya spp.) in the canopy layer. The understory is composed primarily of
red maple (Acer rubrum), American beech (Fagus grandifolia), sweetgum, Chinese privet
(Ligustrum sinense), box elder (Acer negundo), American holly (Ilex opaca), and black
cherry (Prunus serotina). Herbaceous and vine species include greenbrier (Smilax
rotundifolia), Japanese honeysuckle (Lonicera japonica), goldenrods (Solidago spp.),
poison ivy (Toxicodendron radicans), Virginia creeper (Parthenocissus quinquefolia),
blackberry (Rubus sp.), giant cane (Arundinaria gigantea), and wild ginger (Hexastylis
spp.).
Desktop Review
HDR consulted the U.S. Fish and Wildlife (USFWS) Information for Planning and
Consultation (IPaC) database for federally listed species with potential to occur on or in
the vicinity of the Project Site (Appendix C). HDR also consulted the North Carolina
Natural Heritage Program (NCNHP) Data Explorer database to evaluate the potential
occurrence for federally protected species within the Project Site in addition to the list of
federally protected species for Gaston County.
Federally listed species on the USFWS IPaC Resources List include northern long-eared
bat (Myotis septentrionalis), bog turtle (Clemmys muhlenbergii), and dwarf -flowered
heartleaf (Hexastylis naniflora). The NCNHP Project Report (NCNHDE-15909; Appendix
C) referenced a "Documented Occurrence" of Michaux's sumac (Rhus michauxii) that was
observed prior to 1917. The IPaC Resources List also lists the wood thrush (Hylocichla
mustelina) as a migratory bird species with potential to occur within the Site. According to
the USFWS IPaC Resources List, no USFWS-designated Critical Habitat is located within
the Project Site.
Table 1 summarizes listed species included on the IPaC Resources List, federally
protected species in Gaston County, and those listed in NCHNP Database.
Table 1. Federally and State -Protected Species with Potential to Occur within the Project Site
qu
Birds
Nests at tops of large, mature trees near
Bald eagle Haliaeetus large rivers, lakes, and marshes BGEPA No
leucocephalus containing small animals, fish, and
carrion.
Mammals
Page12

Carolina Lithium Project I Piedmont Lithium Carolinas, Inc. ���
Threatened and Endangered Species Memorandum
'ommon Name Scientific Name IF W
�� Habitat
ir W
Uses most cover types available to
Little brown bat Myotis lucifugus them in a variety of ecosystems. Lakes Winter= No
and streams seem to play a significant Summer = Yes
factor in habitat use.
Winter habitat includes caves,
Northern long- Myotis abandoned mines, and cave -like
Winter= No
eared bat spetentrionalis structures; summer habitat includes
T Summer = Yes
dead and living trees with exfoliating
bark and crevices.
Perimyotis Associated with forested landscapes, Winter= No
Tricolored bat subflavus often in open woods. Also found over UR Summer = Yes
water and adjacent to water edges.
Reptiles
Unpolluted emergent and scrub/shrub
Bog turtle
Clemmys
wetlands such as shallow spring -fed
T No
muhlenbergii
fens, sphagnum bogs, swamps, marshy
meadows, and wet pastures.
Insects
Habitat includes open fields and
Monarch
Danaus
meadows during the breeding season.
butterfly
plexippus
Adults use a wide variety of flowering
C Yes
plants throughout migration and
breeding.
Plants
Acidic soils along bluffs and adjacent
Dwarf -flowered
Hexastylis
slopes, in boggy areas next to streams
T Yes
heartleaf
naniflora
and creek heads, and along the slopes
of nearby hillsides and ravines.
Symohyotrichum
Lives in woodlands or piedmont prairies
Georgia aster
dominated by native plants, with acidic
C Yes
georgianum
soils that vary from sand to heavy clay.
Grows in sandy or rocky open woods in
Michaux's
Rhus michauxii
association with basic soils. Survives
E Yes
sumac
best in areas where some form of
disturbance has provided an open area.
Schweinitz's Helianthus In full to partial sun and in areas with
sunflower schweinitzii poor soils, such as thin clays that vary E Yes
from wet to dry.
1. BGEPA (Bald and Golden Eagle Protection Act): Federally protected under the Bald and Golden Eagle Protection Act.
E (Endangered): Any species which is in danger of extinction throughout all or a significant portion of its range. Endangered species are
protected by the take prohibitions of section 9 under the ESA.
T (Threatened): Any species or subspecies that is likely to become an endangered species within the foreseeable future
UR (Under Review): Species that have been petitioned for listing and for which a 90 day finding has not been published or for which a 90
day substantial has been published but a 12 Month finding have not yet been published in the Federal Register.
C (Candidate): A species under consideration for official listing for which there is sufficient information to support listing.
Page 13

Carolina Lithium Project I Piedmont Lithium Carolinas, Inc. ���
Threatened and Endangered Species Memorandum
Field Reconnaissance Results
Field visits were conducted on April 27 and 28, May 5-7, May 17 and 18, May 25 and 28,
June 4, and October 11, 2021 by HDR scientists trained in the identification of various
animal and plant species, including habitat types. Surveyed areas included undeveloped
planted cropland, open fields, mixed hardwood forest, forested floodplains, forested
wetlands, and jurisdictional streams. (Appendix A, Figure 2).
During the field reconnaissance, HDR scientists concluded that suitable habitat was
present for the monarch butterfly, dwarf -flowered heartleaf, Georgia aster, Michaux's
sumac, and Schweinitz's sunflower. Suitable winter habitat for the little brown bat, northern
long-eared bat, and tricolored bat was not observed, but potential summer habitat was
identified. Suitable habitat for the bald eagle and bog turtle was not identified. Species -
specific observations are provided below.
Bald Eagle (Haliaeetus leucocephalus)'
Bald eagles prefer habitats near larger bodies of waters such as lakes, large rivers, and
the shorelines of sounds and bays. This species prefers tall, isolated trees for perching
and nesting. The bald eagle is best surveyed February -March. No suitable habitat for bald
eagles was observed within the Project Site during HDR's field surveys; therefore, the
proposed project would have no effect on this species.
Little Brown Bat (Myotis lucifugus)2
Little brown bats are typically habitat generalists. They use most cover types available to
them in a variety of ecosystems including caves, trees, rocks, and wood piles as roost
sites. The majority of their foraging activity is associated with aquatic habitats; therefore,
lakes and streams seem to play a significant role in habitat use. The little brown bat
typically hibernates in humid caves and mines in the winter. Suitable winter habitat for little
brown bats was not observed within the Project Site during HDR's field surveys; however,
suitable summer habitat is present within the forested portions of the Site. The proposed
project may affect, but not likely to adversely affect, this species.
Northern long-eared bat (Myotis septentrionalis)3
Northern long-eared bats spend the winters hibernating in caves, abandoned mines, or
cave -like structures and buildings. In the summer, the species roosts in dead and living
trees with exfoliating bark in mature forests with open understory near sources of water.
Suitable winter habitat for northern long-eared bats was not observed within the Project
1 https://www.fws.gov/birds/management/managed-species/bald-and-golden-eagle-information.php
2 https://www.fws.gov/southeast/pdf/fact-sheeUlittle-brown-bat.i)df
3 https://www.fws.gov/cookeville/bats.htmI
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Carolina Lithium Project I Piedmont Lithium Carolinas, Inc. ���
Threatened and Endangered Species Memorandum
Site during HDR's field surveys; however, suitable summer habitat is present within the
forested portions of the Site. The project is greater than 0.25 miles from any known
hibernacula sites and greater than 150 feet from any known, occupied maternity roost
trees; therefore, incidental take that may result from project activities is exempt under the
4(d) rule for this species. Therefore, proposed project may affect, but is not likely to
adversely affect, this species.
Tricolored Bat (Perimyotis subflavus)4
The tricolored bat's habitat is typically associated with forested landscapes, often in open
woods. They typically hibernate in caves, mines and even buildings during the winter.
Their summer roosting sites include caves, rock crevices, trees, and barns. Tricolored bats
feed where insect populations are highest, such as rivers or lakes as well as more open
foraging sites with higher tree canopies. Suitable winter habitat for tricolored bats was not
observed within the Project Site during HDR's field surveys; however, suitable summer
habitat is present within the forested portions of the Site. There are no known occurrences
of this species within the project site according to the IPaC Resource List and the NCNHP
Project Report. Therefore, the proposed project may affect, but is not likely to adversely
affect, this species.
Bog Turtle (Clemmys muhlenbergii)5
Bog turtles inhabit open, unpolluted emergent and scrub/shrub wetlands such as shallow
spring -fed fens, sphagnum bogs, swamps, marshy meadows, and wet pastures. They
prefer areas with ample sunlight, high evaporation rates, high humidity in the near -ground
microclimate, and perennial saturation of portions of the ground. No suitable habitat for the
bog turtle was observed within the Project Site during HDR's field surveys. Therefore, the
proposed project would have no effect on this species.
Monarch Butterfly (Danaus plexippus)6
In North America the eastern population of the monarch butterfly migrate north to the
United States and Canada in March from the mountains of central Mexico. This species is
typically found in open grass areas during the breeding season. Adult monarchs use a
wide variety of flowering plants throughout migration and breeding. Important nectar
sources during the spring migration typically include tickseeds (Coreopsis spp.), Viburnum
spp., Phlox spp., and early blooming milkweeds. Important nectar sources during fall
migration include goldenrods (Solidago spp.), asters (Symphyotrichum spp. and Eurybia
spp.), gayfeathers (Liatris spp.), and coneflowers (Echinacea spp.). The optimal survey
window for this species is August -December. Suitable habitat for monarch butterfly is
4 https://www.fws.gov/southeast/pdf/fact-sheet/tri-colored-bat.pdf
5 https://www.fws.gov/northeast/nvfo/es/bogturtle.htm
6 https://www.fws.gov/pollinators/features/Monarch Butterfly.html
Page 15

Carolina Lithium Project I Piedmont Lithium Carolinas, Inc. ���
Threatened and Endangered Species Memorandum
present within the Project Site; however, no individuals were observed during HDR's field
surveys. Therefore, the proposed project may affect, but is not likely to adversely affect,
this species.
Dwarf -flowered heartleaf (Hexastylis naniflora)'
Dwarf -flowered heartleaf typically grows in acidic soils, preferably Pacolet soils, along
north -facing bluffs and adjacent slopes, in boggy areas next to streams and creek heads,
and along slopes. The dwarf -flowered heartleaf is best surveyed during March -May.
Suitable habitat for Dwarf -flowered heartleaf is present in Pacolet soils along slopes
throughout the Project Site, but no individual species were observed during HDR's field
surveys in the survey window (Appendix A, Figure 2). Areas identified as not being
suitable for this species were due to a number of factors such as the presence of pine
plantations, cattle disturbance, highly modified understory, or timber and agricultural
practices with heavy disturbance. Therefore, the proposed project would have no effect on
this species.
Georgia Aster (Symohyotrichum georgianum)
Georgia aster lives in woodlands or piedmont prairies dominated by native plants, with
acidic soils that vary from sand to heavy clay. The species prefers open, sunny areas. The
optimal survey window is early October -mid November. Suitable habitat for Georgia aster
is present within the Project Site; however, no individuals were observed during the survey
window; therefore, the proposed project would have no effect on this species.
Michaux's Sumac (Rhus michauxii)8
Michaux's sumac grows in sandy or rocky open woods in association with basic soils. This
plant survives best in areas where some form of disturbance has provided an open area.
Highway rights -of -way, roadsides, and on the edges of artificially maintained clearings is
preferred habitat. The survey window for this species is May -October. Suitable habitat for
Michaux's sumac is present within the Project Site in open areas of disturbance; however,
no species were observed during the survey window; therefore, the proposed project
would have no effect on this species.
Schweinitz's Sunflower (Helianthus schweinitzii)9
Schweinitz's sunflower occurs in full to partial sun and is found in areas with poor soils,
such as thin clays that very from wet to dry. This species is often found along roadside
rights -of -way, maintained power lines and other utility rights -of -way, edges of thickets and
old pastures, clearings and edges of upland oak -pine -hickory woods and Piedmont
7 https://www.fws.gov/southeast/pdf/fact-sheet/dwarf-flowered-heartleaf.pdf
8 https://www.fws.gov/raleigh/species/es michauxs sumac.html
9 https://www.fws.gov/raleigh/species/es schweinitz sunflower.html
Page 16

Carolina Lithium Project I Piedmont Lithium Carolinas, Inc. ���
Threatened and Endangered Species Memorandum
longleaf pine forests, and other sunny or semi -sunny habitats where disturbance help
create open or partially open areas for sunlight. Favored soils for this species include
Iredell, Enon, Badin, Cecil, Misenheimer, Gaston, and Zion soils. HDR biologists visited a
known off -site population of Schweinitz's sunflower prior to conducting the field survey.
The optimal survey window for this species is late August -October. Suitable habitat for
Schweinitz's sunflower is present within the Project Site; however, no individual of the
species were observed during the survey window. Therefore, the proposed project would
have no effect on this species.
Summary
Based on HDR's desktop review of the USFWS IPaC Resource List and NCNHP Project
Report, GIS files, and field surveys, the project would have no effect on the bald eagle or
bog turtle due to lack of suitable habitat. The project may affect but is not likely to
adversely affect the little brown bat, northern long-eared bat, and tricolored bat due to
presence of summer roosting habitat located on the site (forested areas); winter habitat
was not observed. Species -specific bat surveys were not conducted as part of this review.
Suitable habitat was identified for the dwarf -flowered heartleaf, Georgia aster, Michaux's
sumac, and Schweinitz's sunflower within the Project Site. Surveys for these species
occurred during the appropriate flowering window and no individuals of these species were
observed; therefore, the proposed project would not affect these species (Appendix A,
Figure 2).
Little brown bat and tricolored bat are under review species by the USFWS and monarch
butterfly and Georgia aster are candidate species for listing as federally listed species.
These species are not legally protected under the Threatened and Endangered Species
Act, including section 7, unless they are formally proposed or listed as endangered or
threatened. The prohibition against jeopardy and taking a listed species under section 9 of
the Act applies as soon as the listing becomes effective, regardless of the stage of
completion of the proposed action.
If clearing of suitable summer habitat for northern long-eared bat is necessary, it is
recommended to be performed during winter months or the "unoccupied" months when the
bat would not be roosting in forested areas (between November 1 and April 1)10 as a
conservation measure for this species. Nevertheless, the project is greater than 0.25 miles
from any known hibernacula sites and greater than 150 feet from any known, occupied
maternity roost trees; therefore, incidental take that may result from project activities is
exempt under the 4(d) rule for this species.
10 https://www.fws.gov/midwest/Endangered/mammals/inba/surveys/pdf/FINAL%20Range-
wide%201Bat%20Survev%20Guidelines%203.23.20.pdf (USFWS Indiana Bat Survey Guidelines applies to the northern
long-eared bat)
Page 17

Carolina Lithium Project I Piedmont Lithium Carolinas, Inc. ���
Threatened and Endangered Species Memorandum
It is recommended to reseed disturbed areas with pollinator seed mixes that would benefit
monarch species as well as other pollinator species.
Attachments:
Appendix A — Figures and Representative Photographs
Appendix B — HDR's 2018 Threatened and Endangered Species Survey Report and
Associated USFWS Correspondence
Appendix C — IPaC Resource List, NCNHP Project Report (NCNHDE-15909), and
USFWS List for Gaston County
Page 18

Carolina Lithium Project I Piedmont Lithium Carolinas, Inc.
Threatened and Endangered Species Memorandum
Appendix A
Figures and Representative
Photographs

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FN PIEDMONT PROJECT VICINITY
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PIEDMONT THREATENED & ENDANGERED SPECIES REVIEW AREA
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Photograph 7 — Representative suitable Schweinitz's Sunflower habitat.
Facing North

Carolina Lithium Project I Piedmont Lithium Carolinas, Inc.
Threatened and Endangered Species Memorandum
Appendix B
HDR's 2018 Threatened and
Endangered Species Survey
Report and Associated USFWS
Correspondence

FN
December 21, 2018
Mr. Byron Hamstead
U.S. Fish and Wildlife Service
Asheville Ecological Services Field Office
160 Zillicoa Street
Asheville, NC 28801
RE: Threatened and Endangered Species Survey
Piedmont Lithium Project
Gaston County, North Carolina
Introduction
Piedmont Lithium intends to develop a site east of Cherryville, North Carolina as a hard rock lithium
mine. The Piedmont Lithium site includes 971 acres and is centered around 1501 Hephzibah
Church Road in unincorporated Gaston County, North Carolina (Figure 1).
The project proposes to construct open pit mine areas, waste rock areas, a concentrator plant site,
appropriate National Pollutant Elimination Discharge System (NPDES) Best Management Practices
(BMPs), and internal access roads (Figure 2). The internal access roads will utilize existing roads
(Hephzibah Church Road and Whitesides Road), as well as construct new ones. No impacts to
Beaverdam Creek, Little Beaverdam Creek, or the Federal Emergency Management Act (FEMA)
100-year floodplain are proposed.
Threatened and Endangered Species Desktop Review
HDR conducted a desktop review of protected species likely to occur on or in the vicinity of the
proposed Piedmont Lithium site. Species addressed include those listed under the Endangered
Species Act, critical habitat designated under the Endangered Species Act, and species listed as
threatened, endangered, or of other conservation concern by state natural resource agencies.
HDR consulted the U.S. Fish and Wildlife (USFWS) Information for Planning and Consultation
(IPaC) database and the North Carolina Natural Heritage Program (NCNHP) Data Explorer for a list
of federally protected species with potential to occur within and in proximity to the project site. Table
1 summarizes species that are federally listed in both databases and have the potential to be
located in proximity to the project site.
The USFWS IPaC report summarizes species and trust resources under the USFWS's jurisdiction
that are known or expected to be on or near the project area (IPac Resource List, attached). The
NCNHP Project Report (NCNHDE-7459, attached) summarizes occurrences of federally and state -
protected species, critical habitat, and managed areas that have been documented within a one -
mile radius of the Project Area. The NCNHP Data Explorer query revealed that no known
occurrences of federally protected species have been documented within the Project Area;
however, one historical occurrence (pre-1917) of a federally protected species occurs within a one -
mile radius of the Project Area.
hdrinc.com 440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
[phone]

Piedmont Lithium
USFWS Correspondence
December 21. 2018
Bald eagle
Reptiles
Bog turtle
Mammals
Northern
long-eared
bat
Plants
Dwarf -
flowered
heartleaf
Haliaeetus BGPA NCNHP Nests at tops of large, mature trees near No
leucocephalus large rivers, lakes, and marshes containing
small animals, fish, and carrion'
Glyptemys T (S/A) NCNHP Open, groundwater -supplied (spring -fed), No
muhlenbergii graminoid dominated wetlands along
riparian corridors or on seepage slopes; wet
pastures and drainage ditches2
Myotis T NCNHP, Hibernates in caves and mines during No-
septentrionalis USFWS winter; roosts under bark, in cavities or hibernacula;
crevices in trees and snags during summer' Yes- roosting
Hexastylis
naniflora
Schweinitz's Helianthus
sunflower schweinitzii
T NCNHP,
Acidic soils along bluffs and adjacent Yes
USFWS
slopes; in boggy areas next to streams and
creek heads, along the slopes of nearby
hillsides and ravines4
E NCNHP,
Areas with poor soils in forest openings, No
USFWS
grasslands, or disturbed areas such as
roadsides and utility rights -of -ways
Michaux's Rhus E NCNHP Sandy or rocky, open, upland woods on No
sumac michauxii acidic or circumneutral, well -drained sandy
or loamy soils; sandy or submesic loamy
swales and depressions in the Sandhills
region; disturbed areas such as maintained
roadsides and utility rights -of -ways
https://ecos.fws.gov/docs/federal register/fr181odf
2 https://www.qpo.qov/fdsys/pkq/FR-1997-11-04/pdf/97-29088.i)df#i)age=1
3 https://www.qpo.qov/fdsys/pkq/FR-2015-04-02/1)df/2015-07069.1)df
4 https://www.fws.gov/raleigh/species/es dwarf -flowered heartleaf.html
5 https://ecos.fws.gov/docs/federal register/fr1852.0df
s https://ecos.fws.gov/docs/federal register/fr1601.pdf
Pedestrian Survey Results and Suitable Habitat
On March 151h and 20th and on April 4th and 18th, 2018 HDR environmental scientists, conducted
pedestrian surveys of the site to verify the presence or absence of potential habitat for federally
threatened and endangered species that may occur on the site. Additional field work has been
conducted on the site during two visits each in August, October, and November 2018, including
continued observation for habitat and individuals listed in Table 1. None have been identified to
date.
Three areas that were not accessible during the 2018 surveys will be reviewed in 2019 (Figure 3).
During the 2018 March, April, August, October, and November surveys, no suitable habitat for the
bald eagle, bog turtle, Schweinitz's sunflower, or Michaux's sumac were identified and none of
these species were observed during the field surveys. However, suitable habitat for the dwarf -
flowered heartleaf was identified (Figure 3) during the March field efforts and subsequently
Page 12

Piedmont Lithium
USFWS Correspondence
December 21. 2018
surveyed for the species during the April field efforts. Utilizing topographic and soil survey GIS files,
target areas for the dwarf -flowered heartleaf were identified on Pacolet soils on north facing slopes
prior to field work. These areas were surveyed in the field and suitable habitat for the species was
identified (Figure 3). The field work was conducted during the appropriate flowering window (March -
May) for dwarf -flowered heartleaf and although other species of Hexastylis were observed, no
individuals of dwarf -flowered heartleaf were identified. Areas identified as not being suitable for this
species were due to a number of factors such as the presence of pine plantations, cattle
disturbance, highly modified understory, or timber and agricultural practices with heavy disturbance.
These areas were still carefully observed during periodic field work throughout this timeframe for
individuals of dwarf -flowered heartleaf and none were identified.
The project was also reviewed in accordance with the northern long-eared bat (NLEB) Standard
Local Operating Procedures for Endangered Species (SLOPES) between the USACE, Wilmington
District, and the Asheville and Raleigh U.S. Fish and Wildlife Service (Service) Offices, and
determined that the project is located outside of the highlighted areas/red 12-digit HUCs and
activities in the project limits do not require prohibited incidental take; as such, this project meets
the criteria for the 4(d) rule and any associated take is exempted/excepted. As established in the
NLEB SLOPES, this project does not require prohibited intentional take of the NLEB and it meets
the criteria for the 4(d) rule.
Effect Determination
Based on the desktop review of the IPaC and NCNHP Project Report, GIS files, and field reviews,
the project will have no effect on the bald eagle, bog turtle, Schweinitz's sunflower, or Michaux's
sumac. The project may affect, but is not likely to adversely affect the northern long-eared bat.
The suitable habitat identified for the dwarf -flowered heartleaf within the proposed project has been
surveyed for the species during the appropriate flowering window — no individuals of the species
were observed. The three remaining areas to be reviewed will not be impacted by the proposed
project (Figures 2 and 3); therefore, the project will have no effect on the dwarf -flowered heartleaf.
The results of the additional surveys will still be provided once completed.
Page 13

Piedmont Lithium
USFWS Correspondence
December 21. 2018
We ask that you review the project area based on the attached information to determine if there will
be any adverse impacts to federally protected species. If you have any questions or require
additional information, please contact me at 704-338-6710 or KelIy.Thames(c�hdrinc.com.
Sincerely,
Kelly TIC rn PWS Thomas Blackwell, PWS
Environmental Scientist Project Manager/Environmental Scientist
Attachments: Figure 1. Project Vicinity
Figure 2. Preferred Site Layout
Figure 3. Threatened and Endangered Species Review Area
IPaC Resource List
NCNHP Project Report (NCNHDE-7459)
cc
Page 14
Mr. Allen Ratzlaff, USFWS

LEGEND
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USER: KTHAMES - DATE: 1212012018

LEGEND
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PIEDMONT LITHIUM PROJECT
PIEDMONT PREFERRED SITE LAYOUT
LITHIUM
FIGURE 2
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USER: KTHAMES - DATE: IMOM18

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USER: KTHAMES - DATE: 12/20/2018

11 /6/2018
IPaC
IPaC: Explore Location
U.S. Fish & Wildlife Service
IPaC resource list
Last login September 21, 2018 06:11 AM MDT
This report is an automatically generated list of species and other resources such as critical habitat
(collectively referred to as trust resources) under the U.S. Fish and Wildlife Service's (USFWS)
jurisdiction that are known or expected to be on or near the project area referenced below. The list
may also include trust resources that occur outside of the project area, but that could potentially be
directly or indirectly affected by activities in the project area. However, determining the likelihood
and extent of effects a project may have on trust resources typically requires gathering additional
site -specific (e.g., vegetation/species surveys) and project -specific (e.g., magnitude and timing of
proposed activities) information.
Below is a summary of the project information you provided and contact information for the USFWS
office(s) with jurisdiction in the defined project area. Please read the introduction to each section
that follows (Endangered Species, Migratory Birds, USFWS Facilities, and NWI Wetlands) for
additional information applicable to the trust resources addressed in that section.
Location
Gaston County, North Carolina
Local office
Asheville Ecological Services Field Office
L [phone]
18 [phone]
160 Zillicoa Street
Asheville, NC 28801-1082
http://www.fws.gov/nc-es/es/countyfr.html
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11/6/2018 IPaC: Explore Location
Endangered species
This resource list is for informational purposes only and does not constitute an analysis of
project level impacts.
The primary information used to generate this list is the known or expected range of each species.
Additional areas of influence (AOI) for species are also considered. An AOI includes areas outside of
the species range if the species could be indirectly affected by activities in that area (e.g., placing a
dam upstream of a fish population, even if that fish does not occur at the dam site, may indirectly
impact the species by reducing or eliminating water flow downstream). Because species can move,
and site conditions can change, the species on this list are not guaranteed to be found on or near
the project area. To fully determine any potential effects to species, additional site -specific and
project -specific information is often required.
Section 7 of the Endangered Species Act requires Federal agencies to "request of the Secretary
information whether any species which is listed or proposed to be listed may be present in the area
of such proposed action" for any project that is conducted, permitted, funded, or licensed by any
Federal agency. A letter from the local office and a species list which fulfills this requirement can
only be obtained by requesting an official species list from either the Regulatory Review section in
IPaC (see directions below) or from the local field office directly.
For project evaluations that require USFWS concurrence/review, please return to the IPaC website
and request an official species list by doing the following:
1. Draw the project location and click CONTINUE.
2. Click DEFINE PROJECT. _
3. Log in (if directed to do so).
4. Provide a name and description for your project.
5. Click REQUEST SPECIES LIST.
Listed speciesl and their critical habitats are managed by the Ecological Services Program of the U.S.
Fish and Wildlife Service (USFWS) and the fisheries division of the National Oceanic and Atmospheric
Administration (NOAA Fisheries).
Species and critical habitats under the sole responsibility of NOAA Fisheries are not shown on this
list. Please contact NOAA Fisheries for species under their jurisdiction.
1. Species listed under the Endangered Species Act are threatened or endangered; IPaC also shows
species that are candidates, or proposed, for listing. See the listing status page for more
information.
2. 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.
The following species are potentially affected by activities in this location:
Mammals
NAME STATUS
https://ecos.fws.gov/ipac/location/MRW16CW4MNCFXC25A4ZI14VZVI/resources 2/7

11 /6/2018
IPaC: Explore Location
Northern Long-eared Bat Myotis septentrionalis Threatened
No critical habitat has been designated for this species.
https://ecos.fws.gov/ecp/species/9045
Flowering Plants
NAME STATUS
Dwarf -flowered Heartleaf Hexastylis naniflora Threatened
No critical habitat has been designated for this species.
https://ecos.fws.gov/ecp/species/2458
Schweinitz's Sunflower Helianthus schweinitzii Endangered
No critical habitat has been designated for this species.
https://ecos.fws.gov/ecp/species/3849
Critical habitats X0
Potential effects to critical habitat(s) in this location must be analyzed along with the endangered
species themselves.
NW) %P
THERE ARE NO CRITICAL HABITATS AT THIS LOCATION.
�i
l
Migratory birds
Certain birds are protected under the Migratory Bird Treaty Act! and the Bald and Golden Eagle
Protection Acts.
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.
1. The Migratory Birds Treaty Act of 1918.
2. The Bald and Golden Eagle Protection Act of 1940.
Additional information can be found using the following links:
Birds of Conservation Concern http://www.fws.gov/birds/management/managed-species/
birds-of-conservation-concern.php
Measures for avoiding and minimizing impacts to birds
http://www.fws.gov/birds/management/project-assessment-tools-and-guidance/
conservation-measures.php
Nationwide conservation measures for birds
http://www.fws.gov/migratorybirds/pdf/management/nationwidestandardconservationmeasures.pdf
https://ecos.fws.gov/ipac/location/MRW16CW4MNCFXC25A4ZI14VZVI/resources 3/7

11 /6/2018
IPaC: Explore Location
THERE ARE NO MIGRATORY BIRDS OF CONSERVATION CONCERN EXPECTED TO OCCUR AT THIS LOCATION.
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 and/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 migratory birds potentially occurring 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 AKIN 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 E-bird Explore Data Tool.
or
What does IPaC use to generate the probability of presence graphs for the migratory birds potentially
occurring in my specified location?
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 . ,( _0
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.
LI-a
How do I know if a bird is breeding, wintering, migrating or present year-round in my project 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 refer to the following resources: The Cornell Lab of Ornithology All About Birds Bird Guide, or
(if you are unsuccessful in locating the bird of interest there), the Cornell Lab of Ornithology Neotropical Birds
guide. 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:
1. "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);
2. "BCC - BCR" birds are BCCs that are of concern only in particular Bird Conservation Regions (BCRs) in the
continental USA; and
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11 /6/2018
IPaC: Explore Location
3. "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.
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. em%"%01
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.
Facilities
National Wildlife Refuge lands
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11 /6/2018
IPaC: Explore Location
Any activity proposed on lands managed by the National Wildlife Refuge system must undergo a
'Compatibility Determination' conducted by the Refuge. Please contact the individual Refuges to
discuss any questions or concerns.
THERE ARE NO REFUGE LANDS AT THIS LOCATION.
Fish hatcheries
THERE ARE NO FISH HATCHERIES AT THIS LOCATION.
Wetlands in the National Wetlands Inventory"1�
Impacts to NWI wetlands and other aquatic habitats may be subject to regulation under Section 404
of the Clean Water Act, or other State/Federal statutes.
For more information please contact the Regulatory Program of the local U.S. Army Corps of
Engineers District. 141,
WETLAND INFORMATION IS NOT AVAILABLE AT THIS TIME
This can happen when the National Wetlands Inventory (NWI) map service is unavailable, or for very
large projects that intersect many wetland areas. Try again, or visit the NWI map to view wetlands at
this location.
Data limitations, 0\
The Service's objective of mapping wetlands and deepwater habitats is to produce reconnaissance level
information on the location, type and size of these resources. The maps are prepared from the analysis of high
altitude imagery. Wetlands are identified based on vegetation, visible hydrology and geography. A margin of error
is inherent in the use of imagery; thus, detailed on -the -ground inspection of any particular site may result in
revision of the wetland boundaries or classification established through image analysis.
The accuracy of image interpretation depends on the quality of the imagery, the experience of the image analysts,
the amount and quality of the collateral data and the amount of ground truth verification work conducted.
Metadata should be consulted to determine the date of the source imagery used and any mapping problems.
Wetlands or other mapped features may have changed since the date of the imagery or field work. There may be
occasional differences in polygon boundaries or classifications between the information depicted on the map and
the actual conditions on site.
Data exclusions
Certain wetland habitats are excluded from the National mapping program because of the limitations of aerial
imagery as the primary data source used to detect wetlands. These habitats include seagrasses or submerged
aquatic vegetation that are found in the intertidal and subtidal zones of estuaries and nearshore coastal waters.
Some deepwater reef communities (coral or tuberficid worm reefs) have also been excluded from the inventory.
These habitats, because of their depth, go undetected by aerial imagery.
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11 /6/2018
Data precautions
IPaC: Explore Location
Federal, state, and local regulatory agencies with jurisdiction over wetlands may define and describe wetlands in a
different manner than that used in this inventory. There is no attempt, in either the design or products of this
inventory, to define the limits of proprietary jurisdiction of any Federal, state, or local government or to establish
the geographical scope of the regulatory programs of government agencies. Persons intending to engage in
activities involving modifications within or adjacent to wetland areas should seek the advice of appropriate federal,
state, or local agencies concerning specified agency regulatory programs and proprietary jurisdictions that may
affect such activities.
Foy
https://ecos.fws.gov/ipac/location/MRW16CW4MNCFXC25A4ZI14VZVI/resources 7/7

m mom Roy Cooper, Governor
■� NC DEPARTMENT OF 5usi Hamilton, Secretary
■moms NATURAL AND CULTURAL RESOURCES
s mom Walter Clark, director, Land and Water Stewardship
NCNHDE-7459
November 6, 2018
Jessica Tisdale
H D R
555 Fayetteville Street
Raleigh, NC 27601
RE: Piedmont Lithium
Dear Jessica Tisdale:
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
A query of the NCNHP database indicates that there are records for rare species, important natural
communities, natural areas, and/or conservation/managed areas within the proposed project
boundary. These results are presented in the attached 'Documented Occurrences' tables and map.
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 documented within the project area or 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/Di rectory/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.
Also please note that the NC Natural Heritage Program may follow this letter with additional
correspondence if a Dedicated Nature Preserve, Registered Heritage Area, Clean Water
Management Trust Fund easement, or an occurrence of a Federally -listed species is 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 rod ney.butler(a)ncdcr.gov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPAR71MEN7 OF {NATURAL AND CULTURAL RESOURCES
fl 121 W. JONES STREET, RALEIGH. NC 27603 • 16S1 MAIL SERVICE CENTER, RALEIGH. NC 27699
OFC 919.707.9120 • FAX 919.707,9121

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Intersecting the Project Area
Piedmont Lithium
November 6, 2018
NCNHDE-7459
No Element Occurrences are Documented within the Project Area
There are no documented element occurrences (of medium to very high accuracy) that intersect with the project area. Please note, however, that although the
NCNHP database does not show records for rare species within the project area, it does not necessarily mean that they are not present; it may simply mean that
the area has not been surveyed. The use of Natural Heritage Program data should not be substituted for actual field surveys if needed, particularly if the project
area contains suitable habitat for rare species. If rare species are found, the NCNHP would appreciate receiving this information so that we may update our
database.
No Natural Areas are Documented within the Project Area
Managed Areas Documented Within Project Area
Managed Area Name Owner mm� Owner Type
Catawba Lands Conservancy Easement Catawba Lands Conservancy Private
Catawba Land Conservancy Easement Friday Farm Edward and Carolyn Friday Private
Addition
NOTE: If the proposed project intersects with a conservation/managed area, please contact the landowner directly for additional information. If the project intersects with a Dedicated Nature Preserve
(DNP), Registered Natural Heritage Area (RHA), or Federally -listed species, NCNHP staff may provide additional correspondence regarding the project.
Definitions and an explanation of status designations and codes can be found at httos://ncnhde.natureserve.ora/content/help. Data query generated on November 6, 2018; source: NCNHP, Q4 Oct 2018.
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 4

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mile Radius of the Project Area
Piedmont Lithium
November 6, 2018
NCNHDE-7459
Element Occurrences Documented Within a One -mile Radius of the Project Area
Taxonomic EO ID Scientific Name Common Name ast Element Accuracy Federal State Global State
Group 2 JObservation Occurrence Status Status Rank Rank
Date Rank
Butterfly 34493 Neonympha helicta Helicta Satyr 1940-06-15 H 5-Very --- Significantly G3G4 Sl?
Low Rare
Freshwater Fish32493 Etheostoma Seagreen Darter 2012-05-01 E 3-Medium --- Significantly G4 S3
thalassinum Rare
Vascular Plant 12037 Rhus michauxii Michaux's Sumac 1917-Pre H 5-Very Endangered Endangered G2G3 S2
Low
No Natural Areas are Documented Within a One -mile Radius of the Project Area
Managed Areas Documented Within a One -mile Radius of the Project Area
Managed Area Name lmwwner 111W Owner Ty
Catawba Lands Conservancy Easement Catawba Lands Conservancy Private
Catawba Land Conservancy Easement Friday Farm Edward and Carolyn Friday Private
Addition
Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.org/content/help. Data query generated on November 6, 2018; source: NCNHP, Q4 Oct 2018.
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 3 of 4

GASTON —
God
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November 6, 2018
Project Boundary
Buffered Project Boundary
Managed Area (MAREA)
NCNHDE-7459: Piedmont Lithium
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W il1 K�et Rd
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1:39,352
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Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS,
FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan,
MET, Esri China (Hong Kong), swisstopo, © OpenStreetMap contributors, and
the GIS User Community
Page 4 of 4

ua
United States Department of the InteriorSERVIUE
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa StreetFl
Asheville, North Carolina 28801
September 23, 2019
David Schaeffer
U.S. Army Corps of Engineers
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, North Carolina 28262
Dear Mr. Schaeffer:
Subject: Piedmont Lithium Mine Project; Gaston County, North Carolina
Log No. 4-2-19-038
The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in the
Applicant's correspondence dated December 21, 2019, and the public notice issued January 17,
2019, wherein you solicit our comments regarding project -mediated impacts to federally
protected species. We submit the following comments in accordance with the provisions of the
Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661-667e); the National
Environmental Policy Act (42 U.S.C. §4321 et seq.); and section 7 of the Endangered Species
Act of 1973, as amended (16 U.S.C. 1531-1543) (Act).
Project Description
According to the information provided, the Applicant proposes to develop a lithium mine on 963
acres of land in Cherryville, North Carolina to support the demand for a domestic source of
battery grade lithium hydroxide. The project would entail the construction of an open pit, waste
rock area, concentrator plant facility, and appurtenant access infrastructure that would result in
impacts to 6,385.5 linear feet of stream channel and 0.18 acre of wetlands. The site is dominated
by successional forest and agricultural lands. Multiple streams (Beaverdam Creek, Little
Beaverdam Creek, and their unnamed tributaries) and wetlands occur onsite.
Federally Listed Endangered and Threatened Species
Suitable summer roosting habitat may be present in the project area for the federally threatened
northern long-eared bat (Myotis septentrionalis). However, the final 4(d) rule for this species
(effective as of February 16, 2016), exempts incidental take of this animal associated with
activities that occur greater than 0.25 miles from a known hibernation site, and greater than 150
feet from a known, occupied maternity roost during the pup season (June 1 — July 31). Based on
the information provided, the project (which may or may not require tree clearing) would occur
at a location where any incidental take that may result from associated activities is exempt under
the 4(d) rule for this species. Although not required, we encourage you to avoid associated tree
clearing activities during the maternity roosting season from May 15 — August 15, and
particularly during the pup season for this species (June 1— July 31).

The Applicant indicated that suitable habitat for the federally threatened dwarf -flowered
heartleaf (Hexastylis naniflora) occurs onsite. However, surveys conducted during its optimal
survey window did not detect evidence for this species. Therefore, we believe that project -
mediated impacts to this species would be insignificant and discountable and would concur with
an action agency determination that project -mediated impact may affect, but are not likely to
adversely affect this species.
Based on the information provided, no suitable habitat occurs onsite for any other federally
protected species. Therefore, we believe the requirements under section 7 of the Act are fulfilled
and we require no further action at this time. However, obligations under section 7 of the Act
must be reconsidered if. (1) new information reveals impacts of this identified action that may
affect listed species or critical habitat in a manner not previously considered, (2) this action is
subsequently modified in a manner that was not considered in this review, or (3) a new species is
listed or critical habitat is determined that may be affected by the identified action.
Indirect Impacts and Miti-ag tion
We appreciate the Applicant's effort to avoid/minimize direct impacts to Little Beaverdam and
Beaverdam Creeks via mining buffer setbacks (per Gaston County ordinance) and proposed 100-
foot stream buffer. We are concerned about indirect impacts to onsite reaches of these streams,
wetlands, and project -receiving waters via dewatering operations and/or stress to the aquifer.
Groundwater modelling indicates that impacts are reasonably certain to occur, suggesting that
baseflow of onsite streams will decrease up to 10% in some reaches (e.g. Little Beaverdam
Creek via dewatering of Central Pit). Moreover, project operations would likely exacerbate low -
flow drought conditions that may occur during the estimated lifespan of mine operation (>10
years).
Recent evaluations of the crayfish fauna in the area suggest the presence of undescribed species
in the South Fork Catawba River watershed. At this time, relatively little is known about these
taxa with regards to their taxonomy, distribution, ecology, and life history. These crayfish taxa
are not currently afforded legal protection under the Act, but proactive conservation measures
may preclude the need to list them in the future.
Proposed mitigation measures (purchase of mitigation credits via North Carolina Division of
Mitigation Services), may not be best suited to address project -mediated impacts to stream flow
and habitat loss for narrow endemic species. We encourage the Applicant to consider a
voluntary contribution to an organization or fund that would facilitate conservation for
crayfishes. For example, the North Carolina Museum of Natural Sciences (NCMNS) is an
organization with programs and staff that have the expertise, research capacity, and routinely
coordinate with wildlife management agencies to support conservation activities. Friends of the
Museum is a nonprofit organization whose purpose is to support the NCMNS, and is capable of
receiving and dispersing funds towards the conservation of crayfish (and other natural
resources).
2

The Service appreciates the opportunity to provide these comments. Please contact Mr. Byron
Hamstead of our staff at 828/258-3939, Ext. 42225, if you have any questions. In any future
correspondence concerning this project, please reference our Log Number 4-2-19-038.
Sincerely,
- - original signed - -
Janet Mizzi
Field Supervisor
3

Carolina Lithium Project I Piedmont Lithium Carolinas, Inc.
Threatened and Endangered Species Memorandum
Appendix C
IPaC Resource List and NCNHP
Project Report (NCNHDE-15909)

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Ecological Services Field Office
160 Zillicoa Street
Asheville, NC 28801-1082
Phone: [phone] Fax: [phone]
http://www.fws.gov/nc-es/es/couniyfr.html
In Reply Refer To:
Consultation Code: 04EN1000-2022-SLI-0033
Event Code: 04EN1000-2022-E-00094
Project Name: Piedmont Lithium Mine
".41 &WIMIYUFF
XEF4' N'• 6
October 15, 2021
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 attached 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. Although not required by
section 7, many agencies request species lists to start the informal consultation process and begin
their fulfillment of the requirements under section 7(c) of the Endangered Species Act (Act) of
1973, as amended (16 U.S.C. 1531 et seq.).
This list, along with other helpful resources, is also available on the U.S. Fish and Wildlife
Service (Service) —Asheville Field Office's (AFO) website: https://www.fws.gov/raleigh/species/
cntylist/nc counties.html. The AFO website list includes "species of concern" — species that
could potentially be placed on the federal list of threatened and endangered species in the future.
Also available are:
Design and Construction Recommendations
https://www.fws.gov/asheville/htmis/project review/Recommendations.html
Optimal Survey Times for Federally Listed Plants
https://www.fws.gov/nc-es/plant/plant survey.html
Northern long-eared bat Guidance
https://www.fws.gov/asheville/htmis/project review/NLEB in WNC.html
Predictive Habitat Model for Aquatic Species
https://www.fws.gov/asheville/htmls/Maxent/Maxent.html
New information based on updated surveys, changes in the abundance and distribution of
species, changed habitat conditions, or other factors could require modifications of these lists.

10/15/2021 Event Code: 04EN1000-2022-E-00094
Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the Act,
the accuracy of the species lists 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 or the AFO website (the AFO website dates each
county list with the day of the most recent update/change) 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 or by going to the AFO website.
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
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 and on our office's website
at https://www.fws.gov/asheville/htmis/project review/assessment guidance.html.
If a Federal agency (or their non-federal representative) 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:H
www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF.
Though the bald eagle is no longer protected under the Endangered Species Act, please be aware
that bald and golden eagles are protected under the Bald and Golden Eagle Protection Act (16
U.S.C. 668 et seq.), and projects affecting these species may require additional consultation (see
https://www.fws.gov/southeast/our-services/permits/eagles/). Wind energy projects should
follow the wind energy guidelines (http://www.fws.gov/windenergy/) for minimizing impacts to
migratory birds (including bald and golden eagles) and bats.
Guidance for minimizing impacts to migratory birds for projects including communications
towers (e.g., cellular, digital television, radio, and emergency broadcast) can be found at: http://
www.fws.gov/migratoI3 birds/CurrentBirdlssues/Hazards/towers/towers.htm;
http://www.towerkill.com; and http://www.fws.gov/migratoI3Lbirds/CurrentBirdlssues/Hazards/
towers/comtow.html.

10/15/2021 Event Code: 04EN1000-2022-E-00094 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 Tracking Number 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
• Wetlands

10/15/2021 Event Code: 04EN1000-2022-E-00094
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:
Asheville Ecological Services Field Office
160 Zillicoa Street
Asheville, NC 28801-1082
[phone]

10/15/2021 Event Code: 04EN1000-2022-E-00094 2
Project Summary
Consultation Code: 04EN1000-2022-SLI-0033
Event Code: Some(04EN1000-2022-E-00094)
Project Name: Piedmont Lithium Mine
Project Type: MINING
Project Description: Develop a lithium mining facility and chemical plant for processing
Project Location:
Approximate location of the project can be viewed in Google Maps: https:
www.google.com/maps/035.3863755,-81.28738928744646,14z
a3J�r
Counties: Gaston County, North Carolina

10/15/2021 Event Code: 04EN1000-2022-E-00094 3
Endangered Species Act Species
There is a total of 4 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
Fisheries1, 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
Northern Long-eared Bat Myotis septentrionalis
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/9045
Reptiles
NAME
Bog Turtle Clemmys muhlenbergii
Population: U.S.A. (GA, NC, SC, TN, VA)
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/6962
Insects
NAME
Monarch Butterfly Danaus plexippus
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/9743
611KIW R
Threatened
STATUS
Similarity of
Appearance
(Threatened)
STATUS
Candidate

10/15/2021 Event Code: 04EN1000-2022-E-00094 4
Flowering Plants
NAME
Dwarf -flowered Heartleaf Hexasrylis nani flora
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/2458
STATUS
Threatened
Critical habitats
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S
JURISDICTION.

10/15/2021 Event Code: 04EN1000-2022-E-00094
Migratory Birds
Certain birds are protected under the Migratory Bird Treaty Act! and the Bald and Golden Eagle
Protection Act2.
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.
1. The Migratory Birds Treaty Act of 1918.
2. The Bald and Golden Eagle Protection Act of 1940.
3. 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
Wood Thrush Hylocichla mustelina Breeds May 10 to Aug 31
This is a Bird of Conservation Concern (BCC) throughout its range in the
continental USA and Alaska.
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 (■)

10/15/2021 Event Code: 04EN1000-2022-E-00094
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:
1. 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.
2. 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.
3. 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 (1)
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.
■ probability of presence breeding season I survey effort — no data
SPECIES JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC

10/15/2021 Event Code: 04EN1000-2022-E-00094 3
Wood Thrush
BCC Rangewide
(CON)
Additional information can be found using the following links:
■ Birds of Conservation Concern http://www.fws.govibirds/management/managed-species/
birds-of-conservation-concern.php
■ Measures for avoiding and minimizing impacts to birds http://www.fws.gov/birds/
management/proj ect-assessment-tools-and-guidance/
conservation-measures.php
■ Nationwide conservation measures for birds http://www.fws.gov/migratorybirds/pdf/
management/nationwidestandardconservationmeasures.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 migratory birds potentially occurring 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 AKN Phenology Tool.
What does IPaC use to generate the probability of presence graphs for the migratory birds
potentially occurring in my specified location?

10/15/2021 Event Code: 04EN1000-2022-E-00094 4
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, migrating or present year-round in my
project 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 refer to the following resources: The Cornell Lab
of Ornithology All About Birds Bird Guide, or (if you are unsuccessful in locating the bird of
interest there), the Cornell Lab of Ornithology Neotropical Birds guide. 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:
1. "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);
2. "BCC - BCR" birds are BCCs that are of concern only in particular Bird Conservation
Regions (BCRs) in the continental USA; and
3. "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.

10/15/2021 Event Code: 04EN1000-2022-E-00094
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 Lorin.
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.

10/15/2021 Event Code: 04EN1000-2022-E-00094 1
Wetlands
Impacts to NWI wetlands and other aquatic habitats may be subject to regulation under Section
404 of the Clean Water Act, or other State/Federal statutes.
For more information please contact the Regulatory Program of the local U.S. Army Corps of
Engineers District.
Please note that the NWI data being shown may be out of date. We are currently working to
update our NWI data set. We recommend you verify these results with a site visit to determine
the actual extent of wetlands on site.
FRESHWATER EMERGENT WETLAND
■ PEM1A
FRESHWATER FORESTED/SHRUB WETLAND
■ PF01A
■ PF01C
RIVERINE
■ R4SBC
■ R2UBH

Roy Cooper, Governor
■'■1111111■
■! 0 RUC DEPARTMENT OF
■ami■■ NATURAL AND CULTURAL RESOURCES
■ENNN
October 4, 2021
Johanna Velasquez
HDR Inc
440 S. Church Street
Charlotte, NC 28202
RE: PLI Mine and Plant
Dear Johanna Velasquez:
D. Reid Wilson, Secretary
Wafter Clark
Director, Division of Land and Water Stewardship
NCNHDE-15909
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
A query of the NCNHP database indicates that there are records for rare species, important natural
communities, natural areas, and/or conservation/managed areas within the proposed project
boundary. These results are presented in the attached `Documented Occurrences' tables and map.
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 documented within the project area or 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:
httl2s://www.fws.ciov/offices/Di rectory/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.
Also please note that 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 an occurrence of a Federally -listed species is 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 rod nev.butler(a)ncdcr.gov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPAR7MEN7 OF NATURAL AND CULTURAL RESOURCES
fl 121 W. JONES STREET, RALEIGH. NC 27603 • 1GS1 MAIL SERVICE CENTER, RALEIGH. NC 27699
OFC 919.707.9120 • FAX 919.707,9121

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Intersecting the Project Area
PLI Mine and Plant
October 4, 2021
NCNHDE-15909
Element Occurrences Documented Within Project Area _
axonomic Scientific am ommon Name Last Element Accuracy Federal State Global State
Group Observation Occurrence Status Status Rank Rank
Date Rank
Freshwater Fish32493 Etheostoma Seagreen Darter 2012-05-01 E 3-Medium --- Significantly G4 S3
thalassinum Rare
No Natural Areas are Documented within the Project Area
Managed Areas Documented Within Project Area
Managed Area Name Owner Owner Ty
Catawba Lands Conservancy Easement Catawba Lands Conservancy Private
NOTE: If the proposed project intersects with a conservation/managed area, please contact the landowner directly for additional information. If the project intersects with a Dedicated Nature Preserve
(DNP), Registered Natural Heritage Area (RHA), or Federally -listed species, NCNHP staff may provide additional correspondence regarding the project.
Definitions and an explanation of status designations and codes can be found at httrJs://ncnhde.natureserve.or./q help. Data query generated on October 4, 2021; source: NCNHP, Q2 July 2021. 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 4

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mile Radius of the Project Area
PLI Mine and Plant
October 4, 2021
NCNHDE-15909
Element Occurrences Documented Within a One -mile Radius of the Project Area
Taxonomic EO ID Scientific Name Common Name ast Element Accuracy Federal State Global State
Group Observation Occurrence Status Status Rank Rank
Date Rank
Freshwater Fish32493 Etheostoma Seagreen Darter 2012-05-01 E 3-Medium --- Significantly G4 S3
thalassinum Rare
Vascular Plant 12037 Rhus michauxii Michaux's Sumac 1917-Pre H 5-Very Endangered Endangered G2G3 S2
Low
No Natural Areas are Documented Within a One -mile Radius of the Project Area
Managed Areas Documented Within a One -mile Radius of the Project Area
Managed Area Name Owner Owner Type
Catawba Lands Conservancy Easement Catawba Lands Conservancy Private
City of Cherryville Open Space City of Cherryville Local Government
Definitions and an explanation of status designations and codes can be found at httos://ncnhde.natureserve.ora/helr). Data query generated on October 4, 2021; source: NCNHP, Q2 July 2021. 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 3 of 4

NCNHDE-15909: PLI Mine and Plant
October 4, 2021 1:42,489
Project Boundary o 0.35 0.� 1.4 mi
Buffered Project Boundary o o.s 1 2 km
Managed Area (MAREA) Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS,
FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan,
METI, Esri China (Hong Kong), (c) OpenStreetMap contributors, and the GIS
User Community
Page 4 of 4

11/3/21, 1:02 PM Listed species believed to or known to occur in Gaston, North Carolina
i, U.S. Fish & Wildlife Service
ECOS
ECOS / Species Reports / Species County Report
Listed species believed to or known to occur in
Gaston, North Carolina
The following report contains species that are known to or are believed to occur in this
county, based on the species current range, as defined by the USFWS. The definition of
current range that the FWS uses is the general geographic area where we know or
suspect that a species currently occurs.
This list of species by county cannot be used for consultation purposes. To obtain an
official list of species that should be considered during consultation, please visit IPaC.
n Csv
Show 10 entries
7 Species Listings
Group Name
Search:
Population Status
monarch
Insects butterfly Wherever Candidate 3
(Danaus found
plex(ippus)
Flowering Georgia aster Wherever Resolved
(Symphyotrichum 4
Plants geurgianum) found Taxon
Dwarf -flowered
Flowering heartleaf Wherever Threatened 4
Plants (Hexastylis found
naniflora)
Schweinitz's
Flowering sunflower Wherever Schweinitz'.,
Plants (Helianthus found Endangered 4 Sunflower
schweinitzii)
https://ecos.fws.gov/ecp/report/species-listings-by-current-range-county?fips=37071 1 /2

11/3/21, 1:02 PM Listed species believed to or known to occur in Gaston, North Carolina
bog turtle
U.S.A. (GA,
Similarity of
Reptiles (Clemmys
NC, SC, TN,
Appearance 4
muhlenbergii)
VA)
(Threatened)
Little brown bat
Wherever
Under
Mammals
(Myotis lucifugus)
found
5
Review
Tricolored bat
Wherever
Under
Mammals (Perimyotis
found
5
Review
subflavus)
Showing 1 to 7 of 7 entries
Previous 1a Next
https://ecos.fws.gov/ecp/report/species-listings-by-current-range-county?fips=37071 2/2