20190460 Ver 2_Stanly Solar_NWP Memo 20190410_20191008

- Environmental
Consulting &
Technology, Inc.
To: Lisa Federico, Stanly Solar, LLC.
From: Jessica Miller, ECT
CC: Val Locker, ECT
Date: April 10, 2019
Re: Stanly Solar Development: Summary of Non -Notifying Nationwide Permit 14
ECT Project No. 180411
Introduction
Environmental Consulting & Technology of North Carolina, PLLC (ECT) was contracted
by Stanly Solar, LLC (Stanly Solar) to oversee Clean Water Act Sections 404 and 401
surface water permitting for the proposed Stanly Solar Development (Project) located at
35.289750, -80.237230 in Stanly County, North Carolina (Attachment A). Based on the
limited quantity of proposed surface water impacts, the Project is eligible for authorization
under a non -notifying U.S. Army Corps of Engineers (USACE) Nationwide Permit (NWP)
14 for Linear Transportation Projects. Stanly Solar, LLC is required to adhere to the
applicable thresholds and conditions of the NWP 14.
Notification to the North Carolina Department of Environmental Quality, Division of
Water Resources (NC DWR) is required for Project authorization under Water Quality
General Certification No. 4135•
The Project activities as they relate to NWP general, regional general, activity -specific, and
regional activity -specific, as well as Water Quality Certification (WQC) general and
activity -specific conditions are summarized within this memo.
Project Activities
Surface water impacts for the Project are limited to three (3) stream crossings for the
installation of interior access roads that are necessary for the long-term maintenance of
the solar panels (Attachment A). Each stream crossing will require 30 linear feet of
permanent impacts for culvert and road installation, and 15 linear feet of temporary

impacts for construction. The Project will result in cumulative 135 linear feet of stream
impacts (0.005 acre), of which go linear feet are permanent (0.003 acre). The 45 linear
feet of temporary impacts will be restored to pre -construction grade, contours, and
condition following all permit conditions and Best Management Practices. The proposed
access roads will be composed of gravel to allow infiltration and minimize environmental
impact.
Nationwide Permit 14 Linear Transportation Projects
Per NWP 51 Land Based Renewable Energy Facilities, "Note 2: If the only activities
associated with the construction ... of a land-based renewable energy generation facility
[are to] construct... utility lines and/or road crossings, then NWP 12 and/or 14 shall be
used if those activities meet the terms and conditions of NWPs 12 or 14." NWP 14
authorizes activities required for crossings of Waters of the United States (WOTUS)
associated with the construction, expansion, modification, or improvement of linear
transportation projects where the discharge causes a loss of less than or equal 0.5 acre of
WOTUS. The permit additionally authorizes temporary structures, fills, and work
necessary to construct the linear transportation project.
Per NWP 14 activity -specific conditions, pre -construction notification for NWP 14 is
required when the loss of WOTUS exceeds o.1 acre or when there is a discharge in a special
aquatic site, including wetlands. As the proposed Project impacts are well below o.1 acre
and no discharged is proposed within special aquatic sites, notification to USACE is not
required.
Nationwide Permit General Condition 18. Endangered Species
The U.S. Fish and Wildlife Service (USFWS) Information for Planning and Consultation
System (IPaQ was reviewed for federally -listed species potentially -affected by activities at
the Project location. The IPaC search returned the federally -threatened northern long-
eared bat (Myotis septentrionalis), the federally -endangered Schweinitz's sunflower
(Helianthus schweinitzii), and the federal candidate species Georgia aster
(Symphyotrichum georgianum).
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Based on results of the IPaC and the presence of suitable habitat on-site, ECT conducted
a survey for the Schweinitz's sunflower and Georgia aster on October 30, 2018. No
evidence of these plants was found within the surveyed areas. Consultation with USFWS
was completed and USFWS concurred with the results of the survey in a letter dated
February 4, 2019. Summary pages from the Botanical Survey Report and coordination
documents with USFWS are provided in Attachment B.
In regard to the northern long-eared bat, USFWS recommended a tree cutting moratorium
of June 1 to July 31 to avoid adverse affects. USFWS determined that there would be no
effect for any other federally -listed species known in Stanly County.
Consultation with the North Carolina Wildlife Resources Commission (NCWRC) was
completed to evaluate potential affects to state -listed species. The NCWRC responded in
a letter dated October 22, 2018 that they have no records for state -listed species within the
proposed Project. The field survey conducted on October 30, 2018 was sent to NCWRC on
December 11, 2018. Coordination documents with NCWRC are also included in
Attachment B.
Recommendations:
If tree clearing is required to complete Project activities, trees will be cut between August
1 to May 30 to avoid impacts to the northern long-eared bat. USFWS and NCWRC
additionally provided recommended measures to support wildlife habitat on solar farms.
Stanly Solar, LLC will incorporate recommended measures where practicable and
appropriate on the site.
Nationwide Permit General Condition 20. Historic Properties
Coordination with the North Carolina State Historic Preservation Office (SHPO) was
completed in 2017 for a preliminary approximately 390.6 -acre study area. SHPO
recommended in a response letter dated August 31, 2017 that a comprehensive
archaeological survey be conducted prior to ground disturbing activities. Archaeological
Consultants of the Carolinas, Inc. (ACC), was contracted by Stanly Solar, LLC and
completed an archaeological survey of the preliminary study area in March and April of
2018. Sixteen (16) archaeological sites were identified during field investigations,
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including thirteen (13) prehistoric sites, one (1) historic house site, and two (2) historic
cemeteries. ACC determined that the thirteen (13) prehistoric resources have been
severely disturbed and/or are unlikely to yield significant data pertaining to the prehistory
or history of the area. ACC further determined that none of the prehistoric sites, the
house, nor the cemeteries are eligible for listing on the National Register of Historic
Places.
Recommendations:
The two cemetery sites are protected under state laws pertaining to abandoned
cemeteries. ACC recommended that a minimum io-meter buffer be established and
fenced around each cemetery for protection during future development of the area. The
proposed Project area has been reduced to exclude one (1) of the cemeteries
(*31ST256). Stanly Solar will either avoid the cemetery remaining within the study area
or install protective fencing as recommended by ACC. Coordination with SHPO
and summary pages from the archaeological survey report are provided in
Attachment C.
USACE Wilmington District NWP Regional Conditions
In 2017 the Wilmington District of USACE issued regional general conditions for all
NWPs as well as activity -specific regional conditions. The Project site is not located
within a designated trout watershed and does not contain designated critical habitat
or special designation waters.
The following is a summary of the applicable regional general conditions that must
• Stream bed loss is limited to less than 300 total linear feet.
be adhered to:
• As stream bed loss is limited to less than iso linear feet, notification and mitigation
are not required.
• Live concrete will not come into contact with WOTUS during construction of this
Project.
• Riprap stabilization will be used where natural design is not practicable. Where
riprap is used, filter cloth will be installed beneath the riprap unless the riprap is
keyed into the bank. The placement of riprap will be limited to areas identified for
permanent impacts within the site plan. Riprap material will consist of clean rock
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or masonry material and be clean and free from loose dirt or any pollutant except
in trace quantities that would not have an adverse environmental effect. Riprap
will be of a size sufficient to prevent its movement by natural forces under normal
circumstances.
• Culverts will be constructed/installed so as to promote the safe passage of fish and
other aquatic organisms, such as by burying the culvert to a depth that allows
aquatic passage during low flow conditions. The dimension, pattern, and profile of
the stream above and below the culvert will not be modified by altering the width
or depth of the stream profile. Culverts will be designed and constructed to
minimize destabilization and head cutting. The culvert width will be comparable
to the width of the stream channel.
• Areas of stream bed that are temporarily impacted during construction will be
restored to pre -project elevations and widths using natural streambed material to
a depth of at least 12 inches or to the bottom depth of the impacted area if shallower
than 12 inches. Areas of stream banks that are temporarily impacted will be
restored to pre -project grade and contours or beneficial grade and contours if the
original bank slope is steep and unstable. Natural materials and native plants will
be utilized in restoration.
USACE Wilmington District NWP 14 Activity -Specific Conditions
The following is a summary of the regional NWP 14 activity -specific conditions that must
be adhered to:
• No stream relocations are proposed with this Project.
• Stream crossings are from upland to upland and will not create uplands within
WOTUS.
• Discharges into WOTUS for temporary access fills and/or temporary road
crossings are less than iso linear feet.
NC DWR Water Quality General Certification No. 4135
NC DWR issued Water Quality General Certification No. 4135 on December 1, 2017 for
Section 401 Water Quality Certification for projects eligible for USACE NWP 14. As the
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proposed Project involves permanent and temporary impacts within streams, notification
to NC DWR for written approval is required.
The General Certification includes both activity -specific and general conditions for
projects and the following are applicable to this project:
• All parcels owned by the applicant that are part of the single and complete project
authorized by this Certification are buildable without additional impacts to
streams or wetlands.
• The proposed access roads are from natural high ground to natural high ground.
• No waste, spoil, solids, or fill of any kind will occur in wetlands or waters beyond
the footprint of the impacts as authorized by DWR. No state -regulated floodplain
buffers are located within the Project area.
• As the Project will involve less than 300 linear feet of loss of stream bed,
compensatory mitigation is not proposed.
• Construction activities will incorporate Best Management Practices for sediment
and erosion control. Design, installation, operation, and maintenance of sediment
and erosion control measures will meet specifications within the NCDOT Sediment
and Erosion Control Manual.
• Sediment and erosion control measures will not be placed in wetlands or waters
except within the footprint of temporary or permanent impacts authorized under
the Certification.
• Erosion control matting that incorporates plastic mesh and/or plastic twine will
not be used along streambanks, unless an exception is obtained from DWR.
• An NPDES Construction Stormwater Permit (NCGoi0000) will be obtained prior
to construction.
• Work in or adjacent to streams will be conducted so that the flowing stream does
not come in contact with the disturbed area.
• Culverts will be designed and installed such that the original stream profiles are
not altered and the culvert allows for aquatic life movement during low flows. The
dimension, pattern, and profile of the stream above and below a culvert will not be
modified by widening the stream channel or by reducing the depth of the stream
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in connection with the construction activating. For culverts with a diameter less
than 48 inches, the culvert will be installed such that 20% of the culvert diameter
is below the stream bed elevation. The establishment of native woody vegetation
and other soft stream bank stabilization techniques will be used where practicable.
• If needed, application of fertilizer within disturbed riparian areas will be conducted
at agronomic rates.
• If concrete is used during construction, all necessary measures will be taken to
prevent direct contact between uncured or curing concrete and waters of the state.
Water that inadvertently contacts uncured concrete will not be discharged to
waters of the state.
• All proposed temporary fill and culverts will be removed, and the impacted area
will be returned to natural conditions within 6o calendar days after the temporary
impact is no longer necessary. The impacted areas will be restored to original
grade, including each stream's original cross-sectional dimensions, planform
pattern, and longitudinal bed profile.
• All temporary pipes/culverts/rip-rap pads etc. in streams shall be installed as
outlined in the most recent edition of the North Carolina Sediment and Erosion
Control Planning and Design Manual or the NCDOT Best Management Practices
for Construction and Maintenance Activities so as not to restrict stream flow or
cause dis-equilibrium during use of this Certification.
• Rip -rap required for proper culvert placement, stream stabilization, or restoration
of temporarily disturbed areas will be restricted to the area directly impacted by
the approved construction activity. Rip -rap will be placed such that the original
stream elevation and streambank contours are restored and maintained.
Placement of rip -rap will not result in de -stabilization of the stream bed or banks
or in a manner that precludes aquatic life passage.
• Rip -rap used for stabilization will be of a size and density to prevent movement by
stream flows and will consist of clean rock or masonry material free of debris or
toxic pollutants. Rip -rap will not be installed in the stream bed except in specific
areas required for velocity control and to ensure structural integrity of bank
stabilization measures.
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• Mechanized equipment operated near surface waters will be inspected and
maintained regularly to prevent contamination of surface waters from fuels,
lubricants, hydraulic fluids, or other toxic materials.
• Any petroleum spill of 25 gallons or more, any spill regardless of amount that
causes a sheen on surface waters, any petroleum spill regardless of amount
occurring within loo feet of surface waters, and any petroleum spill less than 25
gallons that cannot be cleaned up within 24 hours will be reported in accordance
with NC G.S. 143-215.85 (b).
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Consulting &
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ATTACHMENT A
Stream Impact Maps

Legend: Note: The wetlands and streams depicted on the map are preliminary until reviewed
by the U.S. Army Corps of Engineers (USACE) and the North Carolina Department
Project Boundary (336 AC) + Data Point of Water Resources (NC DWR). The USACE and NC DWR share authority in the state
of North Carolina to determine the jurisdictional status of wetlands and streams.
PEM Wetland (0.685 AC) -- D Photo Point
Perennial Stream (3,893 LF)
Intermittent Stream (7,135 LF)
SOURCE: GOOGLE EARTH, 2018 (IMAGE DATED 3/30/18)
SCALE 0 125 250 DATE: 3/4/19 �r STANLY SOLAR, LLC STANLY SOLAR PROJECT �DEnvir`onmentalsConsulting
1" = 25® SOUTH ALBEMARLE AND TYSON TOWNSHIPS « Technology or
DR. BS IICH. JM STREAM IMPACT 227 SOUTHSIDE DRIVE, SUITE B A , North Carolina, PLLC
P.M. JM CHARLOTTE, NC 28217 STANLY COUNTY
BOOK __ OVERVIEW MAP The information contained this
this map is proprietary and confidential.
The use or disclosure of this information by you to third parties is
JOB 180477 NORTH CAROLINA prohibited by law and may give rise to civil or criminal liability.

LEGEND STANLY SOLAR — STREAM 7 IMPACT MAN
Intermittent Stream 7
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STANLY COUNTY, NORTH CAROLINA
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DATE: 3/29/2019

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intermittent stream _i _i STANLY COUNTY, NORTH CAROLINA
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ATTACHMENT B
Threatened and Endangered Species Information

MEMORANDUM
To:
Lisa Federico, Stanly Solar, LLC
From:
Amanda Mueller, ECT
CC:
Jessica Miller, ECT
Date:
December 7, 2018
Re:
Stanly Solar, LLC Botanical Survey
Stanly Solar, LLC (Stanly Solar) contracted Environmental Consulting & Technology of North
Carolina, PLLC (ECT) to conduct a botanical survey for two listed plant species on a site under
consideration for construction of a solar facility in Stanly County, North Carolina (Figure 1). U.S.
Fish and Wildlife Service (USFWS) requested this survey for Schweinitz's sunflower (Helianthus
schweinitzii); however, the North Carolina Wildlife Resource Commission (WRC) identified
Georgia aster (Symphyotrichum georgianum) as another species with potential to occur on site.
Therefore, ECT's survey included evaluation of both species.
BOTANICAL SURVEY METHODS
Schweinitz's sunflower is a perennial herb with a purplish stem and yellow flowers that typically
blooms from late -August to October. It is typically about 6.5 feet tall but can grow up to 16 feet.
Schweinitz's sunflower is found in full to partial sun in natural forest openings, grasslands, or in
maintained right of ways such as roadsides.
The Georgia aster is a perennial herb with composite flowers that typically blooms from late -
September to November. Stems are typically about 20 inches but can grow in clusters or clumps
up to 40 inches in height. Flowers are approximately 2 to 2.75 inches wide and consist of white
to reddish purple disk flowers and blueish violet ray petals. The Georgia aster can be found in
sunny open habitats, rocky forest edges, and right of ways (ROWs), such as roadsides.
The botanical survey was conducted on October 30, 2018, during the blooming seasons for both
the Georgia aster and Schweinitz's sunflower. Prior to the field survey, ECT biologists
familiarized themselves with the target species' habitat requirements and taxonomic details
through the use of published and online resources.
Areas of potential habitat for both species within the proposed project boundary were surveyed
by two qualified ECT biologists. Biologists traversed the site on foot and vehicle. During the
surveys, general habitats were characterized, and a list of plant species was compiled (Table 1).
RESULTS
No evidence of Schweinitz's sunflower or Georgia aster was found within the surveyed areas of
potential habitat. Table 1 presents a list of species noted during the surveys. The physical setting,
land use types, and vegetative communities encountered during the survey are described in the
following paragraphs. Attachment 1 contains representative photographs (locations are depicted
in Figure 1).
r � Envkonnie W Consulting
& Technology Of
C I WM CarolNta PLLC

MEMO
Lisa Federico
Stanly Solar, LLC
December 7, 2018
Page 2
The site primarily consists of agricultural fields, forested areas, and open fields. The site is mainly
forested on the northern, central, and northwestern portions, with open areas consisting of
transmission line ROWs and farm fields in the central portion, and farm fields in the northern
and western portions of the site. Land uses adjacent to the ROW include mixed hardwood forest,
agriculture, and previously cleared pine plantation. Attachment 1 presents representative
photographs, the locations of which, are depicted in Figure 1. Much of the survey area has been
previously disturbed, and several invasive species were encountered.
The open fields on the site consist of old farm fields maintained for hay production. Open areas
are dominated by grasses, including small carpetgrass (Arthraxon hispidus) and broomsedge
(Andropogon virginicus), as well as blackberry (Rubus spp.) and honeysuckle (Lonicera
japonica). Agricultural fields on the site were dominated by recently harvested cotton (Gossypium
spp.) or corn (Zea mays) crops.
Forested areas included an overstory dominated by Virginia pine (Pinus virginiana), loblolly pine
(Pinus taeda), tulip poplar (Liriodendron tulipifera), and white oak (Quercus alba). Dominant
species present within the sapling/shrub layer and understory include American beech (Fagus
grandifolia), American holly (Ilex opaca), Japanese stilt grass (Migrostegium vimineum),
greenbriar (Smilax rotundifolia), and dogfennel (Eupatorium capillifolium).
Table 1. List of Common Plant Species Observed at the Site
Acer rubrum
Red maple
Andro 0 on vir inicus
Broomsed e
Arthraxon his idus
Small car et rass
Bidens aristosa
Tickseed sunflower
Chrysopsis mariana
Maryland golden aster
nodon dactylon
Bermuda grass
Eu atorium ca illi olium
Dog fennel
Fa us americana
American beech
Gossypium spp.
Cotton
Ilex o aca
American Holl
Li ustrum sinense
Chinese privet
Liriodendron arboreum
Tulip poplar
Microste ium vimineum
Japanese stiltgrass
Ph tolacca americana
Pokeweed
Pinus taeda
Loblolly
Pinus vir iniana
Virginia Pine
Poa pratensis
Kentucky bluegrass
Quercus alba
White oak
Rubusspp.
Blackberry
Scir us cyperinus
Woolgrass
Smilax rotundi olia
Greenbriar
Taraxacum o cinale
Common dandelion
Toxicodendron radicans
Poison ivy
Zea mays
Corn
Source: r:Cl', 2018.
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QPP��ENT OF Tye, FISH LIFE
EIIVI E
d tip United States Department of the Interior
o
_ - FISH AND WILDLIFE SERVICE
�gRCH 3,%8� Asheville Field OfficeoMzd�"
160 Zillicoa Street Suite #B
Asheville, North Carolina 28801
February 4, 2019
Ms. Jessica Miller
ECT, Inc.
7208 Falls of Neuse Road, Suite 102
Raleigh, North Carolina 27615
Dear Ms. Miller:
Subject: Listed Species Assessment, for Proposed Stanly Solar, LLC Project, Adjacent to NC
Highway 52, near Misenheimer, Stanly County, North Carolina
On December 11, 2018, we received (via e-mail) your letter requesting our comments on the subject
project. Your email included a copy of the survey results from the project site for Schweinitz's
sunflower (Helianthus schweinitzii) which is currently federally listed as endangered. We have
reviewed the information that you presented and the following comments are provided in accordance
with the provisions of the National Environmental Policy Act (42 U.S.C.§ 4321 et seq.); the Fish and
Wildlife Coordination Act, as amended (16 U.S.C. 661-667e); the Migratory Bird Treaty Act, as
amended (16 U.S.C. 703); 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 presented, your client is proposing to construct a solar array on a site
that currently consists of forested and agricultural land. The forested areas consist of mixed
hardwood and pine and some area has been selectively thinned or cleared in the recent past. Your
letter did not include information regarding wetlands and/or streams that occur within the project
area.
Federally Listed Endangered and Threatened Species
As indicated in your letter, the project site contains suitable habitat for Schweinitz's sunflower. On
October 30, 2018, a survey for this species was conducted by ECT personnel in all areas of suitable
habitat. No evidence of Schweinitz's sunflower was found within the surveyed areas. We concur
with the survey results provided and believe the project will not adversely affect this species.
The prcj ect site also contains potential suitable habitat for northern long-eared bat (Myotis
septent� ionalis), which is currently federally listed as a threatened species. The clearing of trees for
construction of the project, staging areas, etc. could impact suitable maternity roost trees for northern
long-eared bats. The nearest known record for this species is about 70 -miles from the project site.
According to the new 4(d) rule implemented for the listing of northern long-eared bat, a cutting

Ms. Jessica Miller — ECT, Inc. 2
moratorium of June 1 -July 31 is recommended within areas of habitat for this species. Because: 1)
the project site is over 70 -miles away from the nearest known occurrence; and 2) there is a large
amount of suitable habitat in close proximity to the site and in the surrounding area, we believe the
any effects of the project on this species would be discountable and could concur with a "may affect
— not likely to adversely affect" determination for this project. We recommend the cutting
moratorium of June 1 -July 31 be implemented into the plans if possible. Though a "not likely to
adversely affect" determination would not be dependent on this action, the cutting moratorium is a
measure that can be implemented to further reduce the probability of "take" of this species.
Further, we believe a "no effect" determination is appropriate for all other federally listed species
that are known to occur in Stanly County. Therefore, we believe the requirements under section 7 of
the Act are fulfilled. 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.
Wildlife Resources
Although solar energy production is a fast-growing renewable energy source that can lessen overall
impacts to natural resources when compared to conventional energy sources (coal, oil, gas, etc.), we
believe solar farms can adversely affect valuable natural resources if they are not properly planned
and constructed. Impacts to natural resources from the construction, operation, and maintenance of
solar farms include: the removal of forests and riparian buffers; creation of monotypic habitat;
introduction of invasive species; use of herbicides; creation of large, clear open spaces; and barriers
created from fencing. We strongly recommend that impacts to the riparian buffer/forested area on
the southern portion of the project area be avoided to the greatest extent possible.
To offset the overall impacts of solar facilities and/or to increase the habitat and species diversity
within the solar facility area, we further recommend the following measures be implemented into
project design:
Throughout the site, sow native seed mixes with plant species that are beneficial to pollinators.
Taller -growing pollinator plant species should be planted around the periphery of the site and
anywhere on the site where mowing can be restricted during the summer months. Taller plants,
not mowed during the summer, would provide benefits to pollinators, habitat to
ground-nesting/feeding birds, and cover for small mammals. Low-growing/groundcover native
species should be planted under the solar panels and between the rows of solar panels. This
would provide benefits to pollinators while also minimizing the amount of maintenance, such as
mowing and herbicide treatment. Using a seed mix that includes milkweed species (milkweed is
an important host plant for monarch butterflies) is especially beneficial. The following Web site
provides a comprehensive list of native plant species that benefit pollinators:
http://www.xerces.oWlp-content/uploads/2014/09lMidAtlanticPlantList web.pdf
Additional information regarding site prep, plant species, seed mixes, and pollinator habitat
requirements can be provided upon request. The Service and the North Carolina Wildlife
Resources Commission have recently completed a guidance document titled "North Carolina
Technical Guidance for Native Plantings on Solar Sites". That document is included as an
attachment to our email along with this letter. We also offer our assistance with developing seed

Ms. Jessica Miller — ECT, Inc.
mixes that can be used in conjunction with fast growing erosion control seed mix for overall soil
stability and pollinator benefits.
2. Create openings in fencing to allow passage for small mammals and turtles.
3. If possible, the solar field should be designed with open areas spread throughout the project site
and planted and maintained with taller pollinator -friendly plant species. This practice would
benefit pollinators, create diversity throughout the site, and provide much-needed shelter islands
to aid in the movement of small mammals and birds.
4. Mitigate for the loss of forested habitat. Though the loss of forested habitat cannot be fully
mitigated when cleared for solar facilities, we believe measures should be implemented into the
design plans to offset the impacts of the project to the greatest extent practicable. We
recommend the construction and placement of bat and bird boxes throughout the site along with
perch poles that are large enough to be used by raptors.
Create habitat for a diversity of species in "screening" areas. In all areas of the site where
vegetative `screening' will be required, we recommend that a diverse selection of tree and shrub
species be used to create a hedgerow type habitat structure. Hedgerows typically include a
variety of tree and shrub species that vary in height, as opposed to hedges, which are usually
made up of a single species in a closely spaced row. The resulting layers of plants mimic a
woodland or forest edge, fulfilling different habitat functions for wildlife such as shelter, nesting
sites, and food sources. Recent studies suggest that hedgerows generally support a higher
diversity of pollinator species than surrounding landscapes, and provide a valuable forage
resource and corridor for movement of pollinators.
6. Provide nesting sites for pollinator species. Different pollinators have different needs for
nesting sites. Therefore, we recommend designing the solar facility to maintain a diverse array
of habitats to accommodate varied pollinators, from hummingbirds to butterflies to bees.
Hummingbirds typically nest in trees or shrubs while many butterflies lay eggs on specific host
plants. Most bees nest in the ground and in wood or dry plant stems. For additional information
and actions that can be taken to benefit pollinators please visit the following Web site:
http: //www. fws./pollinators/pollinatorpaSeL/yourhelp. html.
We appreciate the opportunity to provide comments on this project. Please contact Mr. Bryan
Tompkins of our staff at 828/258-3939, Ext. 240, if you have any questions. In any future
correspondence concerning this project, please reference our Log Number 4-2-19-082.
Sincerely,
- - original signed - -
Janet Mizzi
Field Supervisor

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
22 October 2018
Ms. Jessica Miller
Mr. Christopher Wu
Environmental Consulting & Technology of North Carolina, PLLC
7208 Falls of Neuse Road, Suite 102
Raleigh, North Carolina 27615
Subject: Informal Consultation
Stanly Solar
Albemarle, Stanly County, North Carolina
ECT No. 180477-0100
Dear Ms. Miller and Mr. Wu,
Biologists with the North Carolina Wildlife Resource Commission (NCWRC) received your letter on 24
September 2018 requesting information on the possible presence of threatened and endangered species
and their habitat at a proposed solar facility. Biologists with NCWRC have reviewed the provided
documents Comments are provided in accordance with certain provisions of the North Carolina
Environmental Policy Act (G.S. 113A-1 through 113A-10; 1 NCAC 25) and the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.).
Stanly Solar, LLC, is proposing to construct a solar facility on approximately 760 acres located east of St.
Martin Road and south-southwest of Mabry Road, south of Albemarle, Stanly County, North Carolina.
The site consists of agricultural fields, pasture, and forested areas. Solar projects should be sited to avoid
impacts to wetlands, streams, riparian buffers and priority wildlife habitat. We prefer solar facilities are
constructed primarily on agricultural lands and avoid clearing the forest to have less impact on aquatic
and terrestrial wildlife species.
Long Creek, Little Long Creek and their unnamed tributaries flow through or adjacent to the site. Long
Creek and Little Long Creek in the Yadkin — Pee Dee River basin are classified as Class C streams by the
N.C. Division of Water Resources (NCDWR).
Within the vicinity of the proposed project, we have records for the federal and state endangered (SE)
Schweinitz's sunflower (Helianthus schweinitzii); federal candidate and state threatened (ST) Georgia
aster (Symphyotrichum georgianum); federal species of concern (FSC) and SE Carolina creekshell
(Villosa vaughaniana); FSC and ST notched rainbow (Villosa constricta); FSC and state special concern
Carolina darter (Etheostoma collis); ST creeper (Strophitus undulatus); state significantly rare (SSR)
eastern creekshell (Villosa delumbis); and SSR prairie dock (Silphium terebinthinaceum). We have no
records within the proposed site; however, the lack of records from the site does not imply or confirm the
absence of federal or state -listed species. An on-site survey is the only definitive means to determine if
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
22 October 2018
Stanly Solar, LLC
Stanly County
the proposed project would impact federal or state rare, threatened, or endangered species. Any protected
species surveys should be conducted by biologists with both state and federal endangered species permits.
We recommend contacting the USFWS at [phone] to ensure that any issues related to federally -
protected species are addressed, and contacting Brena Jones, a nongame aquatic diversity coordinator for
NCWRC, at [phone] regarding aquatic species and surveys.
Solar facilities can mimic impervious surface with the largest impacts likely to be the hydrograph through
increased runoff and reduced infiltration. Infiltration reduction impacts are magnified in the Slate Belt
where there is already low natural groundwater recharge/levels. As a result, aquatic species would be
impacted through increased erosion and sedimentation, as well as possible increase in the frequency in
drying events.
We the following general recommendations to minimize impacts to aquatic and terrestrial wildlife
resources:
The project footprint should be surveyed for wetlands and streams to ensure there are no impacts
to surface waters. In addition to providing wildlife habitat, wetland areas and streams aid in flood
control and water quality protection. U.S. Army Corps of Engineers Section 404 Permits and
NCDWR Section 401 Certifications are required for any impacts to jurisdictional streams or
wetlands.
2. Maintain a minimum 100 -foot undisturbed, native, forested buffer along perennial streams, and a
minimum 50 -foot buffer along intermittent streams and wetlands. Maintaining undisturbed,
forested buffers along these areas will minimize impacts to aquatic and terrestrial wildlife
resources, water quality, and aquatic habitat both within and downstream of the project area.
Also, wide riparian buffers are helpful in maintaining stability of stream banks and for treatment
of pollutants associated with stormwater.
3. Reduce soil compaction under panel arrays and ensure adequate spacing between panels to allow
water to filter into the soils. Rain garden and other bioretention structures would reduce water
runoff.
4. Re -seed disturbed areas with seed mixtures that are beneficial to wildlife. Avoid fescue -based
mixtures because fescue is invasive and provides little benefit to wildlife. Consider planting
native, wildflower seed mixes that will create pollinator habitat within the project boundary.
Shade -tolerant plants that are within 12 to 18 inches can be selected for plantings both underneath
and around the solar panels. Pollinator habitat can also be created in buffer areas outside of the
panel region. Planting native vegetation can reduce costs of maintenance. Further
information and free technical guidance from the NCWRC is available upon request.
5. Fencing around large solar facilities can impact wildlife movements. We recommend using
wildlife -friendly fencing, such as leaving gaps at the bottom of the fence and avoid using barbed
wire.
6. Due to the decline in bat populations, we recommend avoiding tree clearing activities during the
maternity roosting season for bats (May 15 — August 15).
7. If overhead transmission lines will be installed, measures should be implemented to minimize
impacts to birds. These can include increasing line visibility, insulating wires to cover exposed
connections and increasing the distance between wires so no contact with ground or other
energized wire can be made. For more information, see
htip://www.fws.gov/birds/documents/powerlines.pdf.

Page 3
22 October 2018
Stanly Solar, LLC
Stanly County
8. Sediment and erosion control measures should be installed prior to any land clearing or
construction. The use of biodegradable and wildlife -friendly sediment and erosion control
devices is strongly recommended. Silt fencing, fiber rolls and/or other products should have
loose -weave netting that is made of natural fiber materials with movable joints between the
vertical and horizontal twines. Silt fencing or similar materials that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife
species. Excessive silt and sediment loads can have detrimental effects on aquatic resources
including destruction of spawning habitat, suffocation of eggs and clogging of gills.
9. Develop a plan that identifies the parry responsible for decommissioning the facility as well as the
conditions under which decommissioning will occur. In addition, the plan should emphasize that
all equipment must be removed from the site, and the land should be restored to pre -construction
conditions.
At this time, the information provided is not sufficient for our staff to make definitive recommendations
or conclusions concerning this project. Thank you for the opportunity to provide comments during the
early stages of this project. If I can be of additional assistance, please call [phone] or email
olivia.munzer&ncwildlife.oM.
Sincerely,
OG
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
cc: Brena Jones, NCWRC
Bryan Tompkins, USFWS

ATTACHMENT C
Historic and Cultural Resources Information

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona Ai. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
August 31, 2017
Officc of Archives and History
Deputy Secretary Kevin Cherry
Dennis Richter dennisksolterrapartners.c_om
Stanly Solar, LLC
2125 Southend Drive, Suite 450
Charlotte, NC 28203
Re: Stanly Solar, 50 MW Solar Photovoltaic Electric Generating Facility, 20217 Old Aquadale Road,
Albemarle, Stanly County, North Carolina, CH 17-1529
Dear Mr. Richter:
Thank you for your letter of August 3, 2017, concerning the above referenced project. We have reviewed
the information provided and offer the following comments:
No historic buildings will be affected by the proposed undertaking.
The project area consists of a tract of land located along the north side of Old Aquadale Road in
Albermarle. The current landuse includes agricultural fields, wooded areas with planted trees, and areas
that appear to have been recently logged. Long Creek borders the west side of the project area and several
unnamed tributaries drain the subject parcel. Topographically, much of the project area is sloped, though
there are several relatively level landforms and toe ridges above Long Creek. While there are no
previously recorded archaeological resources within the project area, there are two cemeteries and several
structures shown on topographic maps.
Prior to the initiation of any ground disturbing activities within the project area, we recommend that a
comprehensive archaeological survey be conducted by an experienced archaeologist. This
recommendation is based partly because there are presumably cemeteries located within the project area,
and because of the site potential based on the landforms and proximity to Long Creek. The purpose of this
survey will be to locate archaeological sites and make recommendations regarding the eligibility status of
each site in terms of the NRNP. Because much of the subject parcel is sloped, the entire project area may
not need to be intensively surveyed with systematic shovel tests. The entire project area should, however,
be investigated with pedestrian reconnaissance. Please note that our office now requests consultation with
the Office of State Archaeology Review Archaeologist to discuss appropriate field methodologies prior to
the archaeological field investigation. Please also note that cemeteries are protected under North Carolina
General Statute Chapter 65, and should be avoided if possible. If human skeletal remains are encountered
during construction, the provisions of North Carolina General Statute Chapter 70, Article 3 apply,
and construction activities should immediately cease the State Archaeologist, John Mintz, should be
contacted immediately.
Location: 109 Last Jones Street, Raleigh NC 27601 Mailing Address: 4617 \lail Service Center, Raleigh NC 27699-4617 Telephone/Fax; [phone]/807-6599

One paper copy and one digital copy (PDF) of all resulting archaeological reports, as well as one paper
copy and one digital copy (MS Word) of the North Carolina site form for each site recorded, should be
forwarded to the Office of State Archaeology through this office for review and comment as soon as they
are available and in advance of any construction or ground disturbance activities.
A list of archaeological consultants who have conducted or expressed an interest in contract work in
North Carolina is available at www.archaeology.nedcr.gov/nearch/resource/consultants.htm. The
archaeologists listed, or any other experienced archaeologist, may be contacted to conduct the
recommended survey.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comments,
please contact Renee Gledhill -Earley, environmental review coordinator, at 919-807- 6579 or
[e-mail]. In all future communication concerning this project, please cite the
above -referenced tracking number.
Sincerely,
Ramona Bartos4

Archaeological Survey of the
Stanly Solar Farm Tract,
Stanly County, North Carolina
Prepared for
Stanly Solar, LLC
Charlotte, North Carolina
Prepared by
Michael Keith O'Neal
Principal Investigator
Archaeological Consultants of the Carolinas, Inc.
2018

Management Summary
In March and April 2018, Archaeological Consultants of the Carolinas, Inc. (ACC), conducted an
archaeological survey of the Stanly Solar Farm tract located in Stanly County, North Carolina. This
investigation was requested by the North Carolina State Historic Preservation Office (SHPO). The goals of
this investigation were to identify all archaeological resources located within the project tract, assess those
resources for eligibility to the National Register of Historic Places (NRHP), and advance management
recommendations, as appropriate.
The project area measures 158.1 hectares (390.6 ac) in size and is located south of the town of
Albemarle. The tract is located on the north side of Old Aquadale Road. The tract boundaries are formed
by property lines that coincide with vegetation changes, fence lines, and Aquadale Road. The tract is
characterized by agricultural fields, planted pine forest, and logged areas.
Background research conducted at the Office of State Archaeology (OSA) located in Raleigh,
included a review of archaeological site forms, cultural resource reports, and historic maps of the project area.
No previously recorded archaeological sites are present within the project tract. A review of the Office of
Survey and Planning's website (HPOWEB) was also conducted to determine the presence of any recorded
architectural resources within the project tract.
Prior to beginning field work, factors such as soil drainage and topography were used to define
portions of the project tract that had high potential for the presence of archaeological deposits. These high
potential areas totaled approximately 58.8 hectares (145.4 ac) and were surveyed with shovel tests excavated
at 30 -meter intervals along parallel transects spaced 30 meters apart. The portions of the tract defined as
having low potential for the presence of archaeological deposits include drainages, wetlands, and areas of
steep slope. These portions of the tract were examined through pedestrian walkover with judgmentally placed
shovel tests.
Sixteen archaeological sites were identified during this field investigations (Table i.1). These sites
include 13 prehistoric sites, one historic house site, and two historic cemeteries. Prehistoric occupations are
mostly of indeterminate age, although Early through Late Archaic artifacts were identified at 31 ST259.
31 ST259 yielded is a dense scatter of Archaic artifacts and debitage. Despite the artifact density, 31 ST259
has been disturbed by logging and the creation of a logging road and work pad, as well as erosion. The
remaining prehistoric sites have small artifact assemblages and shallow deposits. The historic house site
contains a standing house and a barn and surface artifacts. All of these resources have been severely
disturbed and/or are unlikely to yield significant data pertaining to the prehistory or history of the area. Sites
31ST249** and 31ST256** are historic cemeteries dating to the nineteenth and twentieth centuries,
respectively. All of the identified archaeological sites are recommended not eligible for the NRNP. The two
cemetery sites are protected under state laws pertaining to abandoned cemeteries. It is recommended that a
minimum 10 meter (33 ft) buffer be established and fenced around each cemetery to insure their protection.
'_, Inc.' Stanly Solar Farm Tract
� Stanly County, North Carolina
Sw�
11

Table U. Summary of Archaeoloeical Sites Identified in the Proiect Tract.
Site Number
Description
NRHP Recommendation
31 ST244
Unknown Prehistoric Lithic Scatter
Not Eligible
31 ST245
Unknown Prehistoric Lithic Isolate
Not Eligible
31 ST246
Unknown Prehistoric Lithic Isolate
Not Eligible
31 ST247
Unknown Prehistoric Lithic Isolate
Not Eligible
31ST248**
Early to Middle 20t' Century House Site
Not Eligible
31ST249**
19' Century Cemetery
Not Eligible
31 ST250
Unknown Prehistoric Lithic Isolate
Not Eligible
31 ST251
Unknown Prehistoric Lithic Scatter
Not Eligible
31 ST252
Unknown Prehistoric Lithic Scatter
Not Eligible
31 ST253
Unknown Prehistoric Lithic Isolate
Not Eligible
31 ST254
Unknown Prehistoric Lithic Isolate
Not Eligible
31 ST255
Unknown Prehistoric Lithic Scatter
Not Eligible
31ST256**
20' Century Cemetery
Not Eligible
31 ST257
Unknown Prehistoric Lithic Isolate
Not Eligible
31ST258
Unknown Prehistoric Lithic Scatter
Not Eligible
31ST259
Early to Late Archaic Lithic Scatter
Not Eligible
'_. Inc.' Stanly Solar Farm Tract
� Stanly County, North Carolina
111

Chapter 3. Results of the Investigation
Background Research
Archaeological background research was conducted at the North Carolina site files located at the
Office of State Archaeology (OSA) in Raleigh. No previously recorded archaeological sites are present
within the project tract. One previously recorded archaeological site, the Old Freedom Cemetery
(31ST232**), is located within a 1.6 kilometer (1.0 mile) radius of the Stanly Solar Farm tract (Figure 3.1).
Despite the cemetery being recorded, no site form was available for this resource. The cemetery will not be
impacted by the proposed development. The background review did not identify any other archaeological
surveys conducted within 1.6 kilometers (1.0 mile) of the project tract.
Figure 3.1. Topographic map showing the project tract and previously recorded and newly recorded
archaeological sites (19 81 Albemarle, NC USGS 7.5 minute topographic quadrangle).
i Stanly Solar Farm Tract
z,�EC Inch
r Stanly County, North Carolina
17