20160450 Ver 1_401 Application_20160516

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May 6, 2016
Kleinfelder
Attn: Mr. Jonathan Orvatez
8933 Western Way, Ste 12
Jacksonville, FL 32256
PAT MCCRORY
DONALD R. VAN DER VAART
Subject: REQUEST FOR ADDITIONAL INFORMATION
Piedmont Natural Gas line 33 Replacement Project
Dear Mr. Orvatez:
Seu ernij
S. JAY ZIMMERMAN
l Are( im
DWR # 16-0450
Robeson County
On May 2, 2016, the Division of Water Resources (Division) received your application
requesting a Individual Water Quality Certification from the Division for the subject project.
The Division has determined that your application is incomplete and cannot be processed.
The application is on -hold until all of the following information is received:
Need more copies of the application (401 WQC and Isolated)
Pursuant to 15A NCAC 02H .0502 and G.S. 143-215.3D(e), the Division requires
four (4) complete application packages, to begin the proper consideration of an
application. We received 0 complete copies of the application. Please submit 4
additional copies of the application. We are also still waiting on the $570 fee that
was mentioned (would be sent in under separate cover) in the documents that you
did send in.
Pursuant to Title 15A NCAC 02H .0502(e) the applicant shall furnish all of the above
requested information for the proper consideration of the application. If all of the requested
information is not received in writing at the address below within 30 calendar days of
receipt of this letter, the Division will be unable to process the application and it will be
returned. The return of this project will necessitate reapplication to the Division for
approval, including a complete application package and the appropriate fee.
Please be aware that you have no authorization under Section 401 of the Clean Water Act
for this activity and any work done within waters of the state may be a violation of North
Carolina General Statutes and Administrative Code.
Please contact Sheri Montalvo at 919-807-6303 or sheri.montalvo a�ncdenr qov if you have
any questions or concerns.
State of North Carolina I Environmental Quality I Water Resources 1401 & Buffer Penn] Ring
1617 Mail service Center I Raleigh, North Carolina 27699-1617
919 707 6300

DWR # 16-0450
Request for Additional Info
Page 2 of 2
Sincerely,
'ate
Karen Higgins, Supery
401 & Buffer Permitting Unit
cc: USACE Wilmington Regulatory Field Office
DWR FRO 401 file
DWR 401 & Buffer Permitting Unit file
Filename 160450Piedmontnaturalgasline33replacementproject(Robeson)_HOLD

("KL E/NFEL DER
Bright People Right Solutions
TRANSMITTAL
To: Sheri Montalvo Date:
State of North Carolina Environmental Quality Reference No -
Water Resources Division Copies to -
401 & Buffer Permitting
1617 Mad Service Center
Raleigh, North Carolina 27699-1617
Subject: Piedmont Natural Gas Line 33 Individual Water Quality Certification
5/24/16
20161666 001/60-2000
KLF File
We are sending the following: ® Attached ❑ Under separate cover I
Via:
❑ Messenger/Courier
❑ First Class Mad
® FedEx
❑ United Parcel
❑ DHL
❑ Lone Star Overnight
❑ Freight
❑ Other
Transmitted:
® As Requested
❑ For Approval
❑ For Your Use
❑ For Review & Comment
Remarks: Four (4) Complete Application
By: L
Jon than Oravetz, Project Manager

13
US Army Corps
Of Engineers
Wilmington District
PUBLIC NOTICE
Issue Date: May 18, 2016
Comment Deadline: June 20, 2016
Corps Action ID Number: SAW -2016-00586
The Wilmington District, Corps of Engineers (Corps) received an application from
Piedmont Natural Gas seeking Department of the Army authorization to open -cut trench
a 0.96 -mile section of natural gas pipeline through 1.93 -acres of forested, non -tidal
wetlands, associated with the construction of an approximately 4.7 -mile natural gas
distribution pipeline, in St. Pauls, Robeson County, North Carolina.
Specific plans and location information are described below and shown on the attached
plans. This Public Notice and all attached plans are also available on the Wilmington
District Web Site at:
http://www.saw.usace.army.mil/Missions/Re ug_latorvPermitProgram.aspx
Applicant:
AGENT (if applicable):
Authority
Piedmont Natural Gas
c/o: Edward Dietrich
4720 Piedmont Row Drive
Charlotte, North Carolina 28210
Kleinfelder, Inc.
Attn: Jonathan Oravetz
8933 Western Way, Suite 12
Jacksonville, Florida 32256
FILE COPY
The Corps evaluates this application and decides whether to issue, conditionally issue, or
deny the proposed work pursuant to applicable procedures of the following Statutory
Authorities:
® Section 404 of the Clean Water Act (33 U.S.C. 1344)
❑ Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. 403)
❑ Section 103 of the Marine Protection, Research and Sanctuaries Act of 1972
(33 U.S.C. 1413)
Version 2.11.2014

Location
Directions to Site: The western -most portion of the right-of-way (ROW) is located just
northeast of the intersection of Russell Road and Lombardy Village Road, and travels
east-northeast to Ireland Road, where it will reconnect with the existing gas pipeline
ROW, in St. Pauls, Robeson County, North Carolina.
Project Area (acres): 6.5 -acres Nearest Town: St. Pauls
Nearest Waterway: Big Marsh Swamp River Basin: Lumber
Latitude and Longitude: 34.852544 N, -79.065465 W
Existing Site Conditions
The project site is a 0.96 -mile section of an overall 4.7 -mile long natural gas pipeline
ROW located within existing utility line ROW and new alignment. The overall ROW
travels through pine plantation, hardwood forests, and residential and agricultural
developments. The pipeline will begin at a tie-in to Piedmont Natural Gas' existing Line
5 at the projects western end and extends southeast to a distribution line along Covington
Farm Road, in Robeson County, North Carolina. The proposed line will be an upgrade to
an 8 -inch pipeline from the existing 3 -inch pipeline being constructed to serve several
new commercial and light industrial developments being built in the area.
Previous Department of the Army actions for this project include the following:
SAW -2016-00586 - Nationwide Permit (NWP) 12 for the construction of a natural gas
pipeline. The NWP authorized most of the 4.7 -mile long ROW, except for the 0.96 -mile
section in question, which the applicant stated they were originally going to use
horizontal directional drilling (HDD) methods to cross, but they determined this to be
unfeasible.
Applicant's Stated Purpose
The basic project purpose is to construct a new utility line. The overall project purpose is
to construct a 1.1 -mile section of natural gas pipeline ROW on new alignment to serve
new commercial/industrial developments in and around St. Pauls, North Carolina.
Project Description
The project involves the open -cut trenching of approximately 1.1 -miles of an 8 -inch
natural gas pipeline on new ROW. Approximately 1.96 -acres of palustrine, forested
wetlands will be cleared through a 0.96 -mile section of the new ROW. The ROW
includes a 30 -foot wide maintained ROW and a 20 -foot wide temporary construction
easement.
Version 2.11.2014

Avoidance and Minimization
The applicant provided the following information in support of efforts to avoid and/or
minimize impacts to the aquatic environment: The applicant has reduced impacts to
jurisdictional waters of the U.S., including wetlands, to the maximum extent practicable.
Original proposed project impacts were for the conversion of 2.86 -acres of forested
wetlands within a 70 -foot wide ROW (50 -foot permanently maintained and 20 -foot
temporary construction). A reduction of the permanently maintained ROW from 50 -feet
to 30 -feet reduced overall wetland impacts to 1.96 -acres. The applicant determined that
the use of HDD methodologies were proven to be unsuccessful for this crossing due to
the subsurface geology of the area and the distance involved.
Compensatory Mitigation
The applicant offered the following compensatory mitigation plan to offset unavoidable
functional loss to the aquatic environment: To offset unavoidable conversion impacts to
0.96 -acre of non -tidal, forested wetlands, the applicant proposes to purchase mitigation
bank credits from the Stone Farm Regional Mitigation Bank at a 1:1 ratio. It should be
noted that previously permitted unavoidable project impacts were mitigated through
mitigation bank credit purchases from Stone Farm Regional Mitigation Bank.
Essential Fish habitat
Pursuant to the Magnuson -Stevens Fishery Conservation and Management Act, this
Public Notice initiates the Essential Fish Habitat (EFH) consultation requirements. The
Corps' initial determination is that the proposed project would not effect EFH or
associated fisheries managed by the South Atlantic or Mid Atlantic Fishery Management
Councils or the National Marine Fisheries Service.
Cultural Resources
Pursuant to Section 106 of the National Historic Preservation Act of 1966, Appendix C of
33 CFR Part 325, and the 2005 Revised Interim Guidance for Implementing Appendix C,
the District Engineer consulted district files and records and the latest published version
of the National Register of Historic Places and initially determines that:
❑ Should historic properties, or properties eligible for inclusion in the National
Register, be present within the Corps' permit area; the proposed activity requiring
the DA permit (the undertaking) is a type of activity that will have no potential to
cause an effect to an historic properties.
® No historic properties, nor properties eligible for inclusion in the National
Register, are present within the Corps' permit area; therefore, there will be no
Version 2.11.2014

historic properties affected. The Corps subsequently requests concurrence from
the SHPO (or THPO).
❑ Properties ineligible for inclusion in the National Register are present within the
Corps' permit area; there will be no historic properties affected by the proposed
work. The Corps subsequently requests concurrence from the SHPO (or THPO).
❑ Historic properties, or properties eligible for inclusion in the National Register,
are present within the Corps' permit area; however, the undertaking will have no
adverse effect on these historic properties. The Corps subsequently requests
concurrence from the SHPO (or THPO).
❑ Historic properties, or properties eligible for inclusion in the National Register,
are present within the Corps' permit area; moreover, the undertaking may have an
adverse effect on these historic properties. The Corps subsequently initiates
consultation with the SHPO (or THPO).
❑ The proposed work takes place in an area known to have the potential for the
presence of prehistoric and historic cultural resources; however, the area has not
been formally surveyed for the presence of cultural resources. No sites eligible
for inclusion in the National Register of Historic Places are known to be present
in the vicinity of the proposed work. Additional work may be necessary to
identify and assess any historic or prehistoric resources that may be present.
The District Engineer's final eligibility and effect determination will be based upon
coordination with the SHPO and/or THPO, as appropriate and required, and with full
consideration given to the proposed undertaking's potential direct and indirect effects on
historic properties within the Corps-indentified permit area.
Endangered Species
Pursuant to the Endangered Species Act of 1973, the Corps reviewed the project area,
examined all information provided by the applicant and consulted the latest North
Carolina Natural Heritage Database. Based on available information:
❑ The Corps determines that the proposed project would not affect federally listed
endangered or threatened species or their formally designated critical habitat.
❑ The Corps determines that the proposed project may affect federally listed
endangered or threatened species or their formally designated critical habitat.
The Corps initiates consultation under Section 7 of the ESA and will not
make a permit decision until the consultation process is complete.
® The Corps is not aware of the presence of species listed as threatened or
endangered or their critical habitat formally designated pursuant to the
Version 2.11.2014

Endangered Species Act of 1973 (ESA) within the project area. The Corps will
make a final determination on the effects of the proposed project upon additional
review of the project and completion of any necessary biological assessment
and/or consultation with the U.S. Fish and Wildlife Service and/or National
Marine Fisheries Service.
Other Required Authorizations
The Corps forwards this notice and all applicable application materials to the appropriate
State agencies for review.
North Carolina Division of Water Resources (NCDWR): The Corps will generally not
make a final permit decision until the NCDWR issues, denies, or waives the state
Certification as required by Section 401 of the Clean Water Act (PL 92-500). The receipt
of the application and this public notice, combined with the appropriate application fee, at
the NCDWR Central Office in Raleigh constitutes initial receipt of an application for a
401 Certification. A waiver will be deemed to occur if the NCDWR fails to act on this
request for certification within sixty days of receipt of a complete application. Additional
information regarding the 401 Certification may be reviewed at the NCDWR Central
Office, 401 and Buffer Permitting Unit, 512 North Salisbury Street, Raleigh, North
Carolina 27604-2260. All persons desiring to make comments regarding the application
for a 401 Certification should do so, in writing, by to:
NCDWR Central Office
Attention: Ms. Karen Higgins, 401 and Buffer Permitting Unit
(USPS mailing address): 1650 Mail Service Center, Raleigh, NC 27699-1650
Or,
(physical address): 512 North Salisbury Street, Raleigh, North Carolina 27604
North Carolina Division of Coastal Management (NCDCM):
❑ The application did not include a certification that the proposed work complies
with and would be conducted in a manner that is consistent with the approved
North Carolina Coastal Zone Management Program. Pursuant to 33 CFR 325.2
(b)(2) the Corps cannot issue a Department of Army (DA) permit for the
proposed work until the applicant submits such a certification to the Corps and
the NCDCM, and the NCDCM notifies the Corps that it concurs with the
applicant's consistency certification. As the application did not include the
consistency certification, the Corps will request, upon receipt„ concurrence or
objection from the NCDCM.
Version 2.11.2014

® Based upon all available information, the Corps determines that this application
for a Department of Army (DA) permit does not involve an activity which would
affect the coastal zone, which is defined by the Coastal Zone Management (CZM)
Act (16 U.S.C. § 1453).
Evaluation
The decision whether to issue a permit will be based on an evaluation of the probable
impacts including cumulative impacts of the proposed activity on the public interest.
That decision will reflect the national concern for both protection and utilization of
important resources. The benefit which reasonably may be expected to accrue from the
proposal must be balanced against its reasonably foreseeable detriments. All factors
which may be relevant to the proposal will be considered including the cumulative effects
thereof; among those are conservation, economics, aesthetics, general environmental
concerns, wetlands, historic properties, fish and wildlife values, flood hazards, flood plain
values (in accordance with Executive Order 11988), land use, navigation, shoreline
erosion and accretion, recreation, water supply and conservation, water quality, energy
needs, safety, food and fiber production, mineral needs, considerations of property
ownership, and, in general, the needs and welfare of the people. For activities involving
the discharge of dredged or fill materials in waters of the United States, the evaluation of
the impact of the activity on the public interest will include application of the
Environmental Protection Agency's 404(b)(1) guidelines.
Commenting Information
The Corps of Engineers is soliciting comments from the public; Federal, State and local
agencies and officials, including any consolidated State Viewpoint or written position of
the Governor; Indian Tribes and other interested parties in order to consider and evaluate
the impacts of this proposed activity. Any comments received will be considered by the
Corps of Engineers to determine whether to issue, modify, condition or deny a permit for
this proposal. To make this decision, comments are used to assess impacts on endangered
species, historic properties, water quality, general environmental effects and the other
public interest factors listed above. Comments are used in the preparation of an
Environmental Assessment (EA) and/or an Environmental Impact Statement (EIS)
pursuant to the National Environmental Policy Act (NEPA). Comments are also used to
determine the need for a public hearing and to determine the overall public interest of the
proposed activity.
Any person may request, in writing, within the comment period specified in this notice,
that a public hearing be held to consider the application. Requests for public hearings
shall state, with particularity, the reasons for holding a public hearing. Requests for a
public hearing shall be granted, unless the District Engineer determines that the issues
raised are insubstantial or there is otherwise no valid interest to be served by a hearing.
Version 2.11.2014

The Corps of Engineers, Wilmington District will receive written comments pertinent to
the proposed work, as outlined above, until 5pm, June 20, 2016. Comments should be
submitted to John N. Policarpo, Wilmington Regulatory Field Office,
69 Darlington Avenue, Wilmington, North Carolina 28403 , at [phone].
Version 2.11.2014

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KLE/NFEL DER
Bright People. Right solutions
TRANSMITTAL
To- NC DWR WBSCP Unit Date:
c/o Jennifer Burdett Reference No.
1650 Mail Service Center Copies to.
Raleigh, North Carolina 27699-1650
Subject: Line 33 Individual Permit Water Quality Certification
May 2, 2016
We are sending the following: ® Attached ❑ Under separate cover
Permit Fee $570 00
RECEIVED
MAY 0 6 21,i
9ENR•LAND QUALITY
STORMWA'rER PERMITTING
Via:
❑ Messenger/Courier
❑ First Class Mad
® FedEx
❑ United Parcel
❑ DHL
❑ Lone Star Overnight
❑ Freight
❑ Other
Transmitted.
❑ As Requested
❑ For Approval
® For Your Use
❑ For Review & Comment
a
By:
atnan Uravetz

Montalvo, Sheri A
From: Higgins, Karen
Sent: Thursday, May 05, 2016 2:32 PM
To: Turlington, Chad
Cc: Montalvo, Sheri A, Burdette, Jennifer a
Subject: RE. 16-0066 Piedmont Natural Gas (PNG) Line 33 Pipeline Replacement Modification
Follow Up Flag: Follow up
Flag Status: Flagged
Chad -
Well, if you got the NW and we got the IP, why don't we make yours a v2 like we were going to and we'll
make the IP a new #. We have to ask for stuff for the IP and wait on the public notice anyway so you should
still be able to issue yours before ours. If you can scan a copy of what you got and email it to Sheri or put it in
Laserfiche, Sheri can do what she needs to in BIMS to make it a v2.
Thanks -
Karen
Karen Higgins
401 & Buffer Permitting Branch Supervisor
Division of Water Resources
Department of Environmental Quality
919 807-6360 office
karen higgms(a�ncdenr gov
512 N Salisbury Street, Suite 942-E, Raleigh, NC 27604
1617 Mail Service Center, Raleigh, NC 27699-1617
0'.
—Nothing Compares,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Turlington, Chad
Sent: Thursday, May 05, 2016 7:33 AM
To: Higgins, Karen <[e-mail]>
Subject: RE: 16-0066 Piedmont Natural Gas (PNG) Line 33 Pipeline Replacement Modification
Karen,
Last Friday I received a request to modify the original 401 in my office., I haven't been in the office long enough to look
at it yet though. I just figured it had been sent to Raleigh as well. How do we need to handle this?
From: Higgins, Karen
Sent: Wednesday, May 04, 2016 2:35 PM
To: Turlington, Chad <chad.turlin ton ,ncdenr.gov>

Cc: Montalvo, Sheri A <sheri.montalvoAncdenr gov>
Subject: RE: 16-0066 Piedmont Natural Gas (PNG) Line 33 Pipeline Replacement Modification
Hey Chad -
We just got the IP application for this project that's now three projects... I thought the NW 12 was coming in
first and that was going to be the 2016-0066 v2 but it looks like we got this one first? I only ask b/c we were
going to have whichever came in first as the v2 that would replace the previous 401. We can do it either way,
just want to make sure we don't have multiple 401 approvals covering the same impact!
Thanks -
Karen
Karen Higgins
401 & Buffer Permitting Branch Supervisor
Division of Water Resources
Department of Environmental Quality
919 807-6360 office
karen higgins(d.)ncdenr gov
512 N Salisbury Street, Suite 942-E, Raleigh, NC 27604
1617 Mail Service Center, Raleigh, NC 27699-1617
--Nothing Compares -
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Montalvo, Sheri A
Sent: Wednesday, May 04, 2016 2:26 PM
To: Higgins, Karen <karen hig ins ,ncdenr.gov>
Subject: FW. 16-0066 Piedmont Natural Gas (PNG) Line 33 Pipeline Replacement Modification
From: Turlington, Chad
Sent: Thursday, March 31, 2016 11:37 AM
To: Montalvo, Sheri A <sheri.montalvogncdenr.gov>
Subject: 16-0066 Piedmont Natural Gas (PNG) Line 33 Pipeline Replacement Modification
Sheri,
You will be receiving a modification application for project number 16-0066 in the near future. Karen and I discussed
this morning that no application fee would be required for this project. Please let me know if you have any questions.
Chad Turlington
Environmental Specialist
Division of Water Resources — Water Quality Regional Operations Section, Fayetteville Regional Office
North Carolina Department of Environmental Quality

910-433-3320 office
chad turlington(a ncdenr gov
225 Green Street
Suite 714
Fayetteville, NC 28301
K'ZI-_ Nolhinq Compare-,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties

(000,-
KL E/IVFEL OER
8nght People Right Solutions
20160450
April 28, 2016
NC DWR WBSCP Unit
c/o Jennifer Burdett
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
RE: Piedmont Natural Gas Line 33 Replacement Project, Robeson County, North Carolina
KLF# 20161666.001 A
Ms. Burdett,
On behalf of Piedmont Natural Gas, Kleinfelder is requesting issuance of a 401 Water Quality Certification
for the Line 33 Replacement Project associated with the U.S. Army Corps of Engineers (ACOE) Individual
Permit. The permit application has been submitted to the ACOE, and a copy of the application is provided
as an enclosure. The project will result in 1.93 acres of permanent conversion impacts, and will be mitigated
through the purchase of credits at the Stone Farm Mitigation Bank.
A permit fee in the amount of $570 will be provided under separate cover.
Thank you in advance for your time and consideration of this request. Please contact me at my office 904-
358-9171 or at ioravetz(a)Kleinfelder.com.
Regards,
q --a- 01 -0p -
Jonathan Oravetz
Project Manager
Attachments:
Individual Permit Application
10Y 0 2 2016
8933 Western Way, Suite 12, Jacksonville, FL 32256 p 1904.538.9171 f 1904.538.9172

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PNG LINE 33 REPLACEMENT
ROBESON COUNTY, NORTH CAROLINA
404 INDIVIDUAL PERMIT APPLICATION:
ENVIRONMENTAL SUPPORT DOCUMENT
20163469 001 A RAL 16038071 April 22, 2016
©2016 Kleinfelder

PNG LINE 33 REPLACEMENT
ROBESON COUNTY, NORTH CAROLINA
404 INDIVIDUAL PERMIT APPLICATION:
ENVIRONMENTAL SUPPORT DOCUMENT
1.0 INTRODUCTION..................................................................................................1
2.0 EXISTING CONDITIONS..................................................................................... 3
2.1 Topography................................................................................................3
2.2 Soils...........................................................................................................3
2.3 Land Use................................................................................................... 5
3.0 PROPOSED PROJECT....................................................................................... 7
4.0 ENVIRONMENTAL CONSIDERATIONS............................................................. 8
4.1 Alternative Plan Analysis........................................................................... 8
4.2 Avoidance and Minimization of Impacts ..................................................... 9
4.3 Fish, Wildlife, Listed Species and their Habitats......................................10
4.4 Water Quality Impacts..............................................................................10
4.5 Public Interest..........................................................................................11
4.6 Historic and Cultural Resources..............................................................11
4.7 Mitigation Plan.........................................................................................11
5.0 SUMMARY.........................................................................................................12
FIGURES
Figure 1
Project Location Map
Figure 2
Soil and USGS Topographical Maps
Figure 3
Land Cover / Land Use Map
Figure 4
Jurisdictional Resource Impacts
Figure 5
Alternatives Analysis
EXHIBITS
Exhibit A Preliminary Jurisdictional Determination Form
Exhibit B Stone Farm Mitigation Bank - Credit Request Acceptance Letter
Exhibit C Land Owner Information
20163469 001A RAL 16038071 April 22, 2016
©2016 Kleinfelder

1.0 INTRODUCTION
Piedmont Natural Gas (PNG) operates Line 33 (3 inch diameter) in Robeson County,
North Carolina, between Lumber Bridge and St. Pauls. Its western terminus is at Line
5, just west of NC 71 and its eastern terminus is at St. Pauls' city gate on NC 20, where
Line 33 connects to the interstate pipeline system. PNG is replacing Line 33 with an 8
inch diameter pipe to accommodate anticipated demand from an economic
development project in the region, which involves a new Sanderson Farms chicken
processing plant in St. Pauls along NC 20.
The U.S. Army Corps of Engineers (ACOE) previously authorized NWP #12 for 0.32
acre of wetland conversion impacts associated with a 3 -mile transmission segment of
Line 33, located between the city gate and Covington Farm Rd (SAW -2016-00101).
Additionally, NWP #12 was authorized for a 4.7 -mile distribution segment, between
Covington Farm Rd. and existing PNG Line 5 (SAW -2016-00586). The latter project
avoided wetland impacts through use of horizontal directional drilling (HDD), but
required temporary impact to 60 linear feet of perennial tributary.
The subject permit application requests authorization for wetland conversion impacts
associated with re-routing 0.96 miles of the existing Line 33 between Strawberry Lane
and the end of Ireland Dr. (Figure 1). PNG proposes to re-route this length of pipe
within a 1.1 mile long project area located south of the current easement. In order to
construct this route, 1.93 acres of wetland conversion will occur within a 50 -foot wide
limit of disturbance.
The applicant previously intended to avoid wetland impacts on this segment of the
project through use of HDD. However, property access constraints subsequently
necessitated a bend in the re-routed line, within the jurisdictional wetland area (Figure
2). The resulting point of inflection (PI) would require a second HDD line, which would
require wetland clearing and substrate impacts, thereby diminishing the environmental
20163469 001A RAL16038071 Page 1 April 22, 2016
©2016 Kleinfelder

benefits of using HDD technology. As a result, HDD is no longer practical for this
segment of the project.
The subject Individual Permit application is being submitted to request authorization for
forested wetland conversion impacts associated with traditional open -cut installation of
the re-routed pipe. This submittal additionally requests a Preliminary Jurisdictional
Determination for the project area.
20163469.001A RAL16038071 Page 2 April 22, 2016
©2016 Kleinfelder

2.0 EXISTING CONDITIONS
The 6.5 -acre project area is located near the intersection of Russell Rd. and Lombardy
Village Rd. near Lumber Bridge in north -central Robeson County (Figure 1).
A Jurisdictional Determination field visit was conducted for this project with John
Policarpo of the ACOE on March 1, 2016. Wetland determination data forms in the
wetland impact area and adjacent upland were completed, as well as an updated
Preliminary JD form. These are enclosed as Exhibit A.
2.1 Topography
The topography of the project area is flat to gently sloping, with elevations varying only
slightly from 188 to 195 NGVD. The project area slopes slightly from west to east with a
depression in the middle. A USGS Topographic Quadrangle map is provided as Figure
2.
2.2 Soils
The Robeson County Soil Survey (U.S.D.A., Soil Conservation Service, 1978) indicates
the following soil types within the project area (Figure 2):
Coxville loam (Co) — This soil is composed of 95% Coxville components (85% drained;
10% undrained). This soil type is found on broad, low flats or in Carolina bays. Natural
drainage is poor, with a seasonal high water table at or just below the surface from
November to April. Most of this soil series is forested or, if drained, used for crop and
pastureland. This soil meets hydric criteria.
Lynchburg sandy loam (Ly) - This soil is composed of a 94% non -hydric Lynchburg
component. This soil type is found on nearly level, broad, smooth plains. Natural
drainage is somewhat poorly drained; however this soil type is not flooded or ponded.
20163469.001A RAL16038071 Page 3 April 22, 2016
©2016 Kleinfelder

The seasonal high water table is about 18 inches below the surface from November to
April. This soil does not meet hydric criteria.
Norfolk Loamy Sand (NoA) — This soil is composed of a 95% non -hydric Norfolk
component. This soil type is found on nearly level to gently sloping, broad, smooth
plains. The soil is well -drained, with a seasonal high water table more than 5 feet below
the surface. This soil type does not meet hydric criteria.
Pocalla loamy sand (PoB) — This soil is composed of a 90% non -hydric Pocalla
component. This soil type is found on broad, smooth plains and is considered
excessively drained. The seasonal high water table is more than 5 feet below the
surface. Most of the mapping unit is in crop and pastureland, with some forested
pockets. This soil does not meet hydric soil criteria.
Rains sandy loam (Ra) — This soil is composed of 82% Rains components and 8%
Pantego components. This soil type is found on broad, low flats; natural drainage is
poor and some areas are subject to ponding for brief periods. The seasonal high water
table is at or just below the surface from November to April. About half this soil series is
used for crop and pastureland, with the remaining acreage in forest. This soil meets
hydric criteria.
Wagram loamy sand (WaB) — This soil is composed of a 95% non -hydric Wagram
component. This soil type is found on plains next to drainage -ways and on broad,
smooth ridges. The soil is well -drained, with a seasonal high water table more than 5
feet below the surface. Most of the mapping unit is in crop and pastureland, with some
forested pockets. This soil does not meet hydric soil criteria.
Federally jurisdictional wetlands were identified within areas mapped as Coxville loam
and Rains sandy loam. Wetland locations and descriptions are provided in the sections
that follow.
20163469 001A RAL16038071 Page 4 April 22, 2016
©2016 Kleinfelder

2.3 Land Use
Land uses and vegetative communities within the project area were classified and
mapped in accordance with the Land Cover and Land Use Categories developed by the
NC Center for Geographic Information and Analysis [CGIA] (Figure 3).
Uplands
Uplands within the project area consist of natural communities and man-made
improvements, as described below.
Agricultural Land
The Agricultural Land category includes crops and pastureland. In the project area,
most of this area is cultivated with soybeans.
Actively Managed Forest Stands
This category includes lands managed for silviculture. The canopy is dominated by
loblolly pine (Pinus taeda), with an understory of sweetgum (Liquidambar styraciflua),
and tulip poplar (Liriodendron tulipifera). Common ground cover includes creeping
blueberry (Vaccinium crassifolium) and Japanese honeysuckle (Lonicera japonica).
Mixed Deciduous -Coniferous Forestland
This forested category consists of previously disturbed lands that have regenerated into
a mixed forest of loblolly pine and various hardwoods. Common hardwoods include
water oak (Quercus nigra), sweetgum, red maple (Acer rubrum), and tulip poplar. The
understory can include American holly (Ilex opaca), dogwood (Cornus florida) Chinese
privet (Ligustrum sinense), horse sugar (Symplocos tinctoria). Herbs and vines can
include cranefly orchid (Tipularia discolor), Christmas fern (Polystichum acrostichoides),
yellow jessamine (Gelsemium sempervirens), and greenbrier (Smilax rotundifolia).
Wetlands
Wetlands within the project area consist of a low-lying Carolina Bay community.
20163469.001A RAL16038071 Page 5 April 22, 2016
©2016 Kleinfelder

Hardwood Swamp (bay and wet pocosins)
Carolina bay communities are non -riparian wet hardwood flats found throughout the
southeastern coastal plain of North Carolina. In the project area, the bay swamp has
been historically manipulated for silvicultural activities. A large central portion was
recently harvested. Common canopy species include loblolly pine, water oak,
sweetgum, and red maple. The understory is dominated by horse sugar, sweet bay
(Magnolia virginiana), and highbush blueberry (Vaccinium corymbosum). The vine layer
is thick, especially in the recently harvested areas, and includes laurel greenbrier
(Smilax laurifolia), greenbrier, and grape (Vitis rotundifolia).
20163469 001 A RAL16038071 Page 6 April 22, 2016
©2016 Kleinfelder

3.0 PROPOSED PROJECT
The project entails abandoning approximately 0.96 miles (5,069 linear feet) of existing
right-of-way (ROW) which was built near a residential area, and re-routing the new
length of pipeline to the south. The re-route is 1.1 miles long and rejoins the existing
easement just east of the residential area. The project area is 6.5 acres in total size,
consisting of a 50 ft. construction ROW (Figure 4).
The project involves open -cut pipe installation and clearing in the 50ft construction
ROW. Within the construction ROW, a 30 ft. wide section will be permanently
maintained to provide a clear line -of -sight. Construction of the new line will result in
1.93 acres of permanent wetland conversion (Figure 4). The project has been designed
using the narrowest footprint that will safely allow access for installation of the pipeline
while not bisecting properties and allowing for future maintenance activities.
Within the 50 ft. wide project area, clearing will consist of mechanized tree and
understory removal as needed to facilitate construction. Construction work in the
wetland will be conducted from timber matting to minimize ground disturbance.
Following construction, impacted uplands will be stabilized and vegetated. Wetlands
will be seeded with an appropriate wetland plant mix upon pipe installation.
Mitigation to offset the 1.93 acres of wetland conversion impact is discussed in detail in
Section 4.7.
20163469 001A RAL 16038071 Page 7 April 22, 2016
©2016 Kleinfelder

0
4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 Alternative Plan Analysis
The following Alternative Analysis outlines the process by which the current proposed
route, or Preferred Alternative, was chosen (Figure 5). The proposed route is
dependent on the location of the existing easement, since it was determined that
paralleling the existing line, where possible, would reduce jurisdictional impacts for the
replacement project as a whole.' ' ,
No Build Alternative: The no -build alternative considers that the existing 3" natural gas
pipeline will not be replaced with a new 8" pipe. Up-sizing of the pipeline is needed to
accommodate increased demand from industrial development in the project vicinity. IN
addition, the diameter of the existing line is too small to be cleaned and maintained
effectively. Lastly, the existing line is reaching the end of its life span and could pose a
safety risk the longer it remains operational given its age and condition. The no -build
alternative presents resource availability, pipeline maintenance, and safety challenges.
Therefore, this alternative was rejected.
Alternative #1: The first alternative follows the existing easement through a mobile
home park along Ireland Drive (private road). This alternative is the shortest (0.96 mile)
and would avoid jurisdictional wetland impacts. However, this route is not feasible
because it passes through a residential area where the homes are clustered very close
to the existing easement. The existing corridor is not wide enough to accommodate the
new line alongside the existing pipe. Moving the homes is prohibitive since existing
wells and septic fields would also need to be avoided. In addition, two landowners at
the end of Ireland Drive declined access to their property. Based on these challenges,
Alternative #1 was rejected as impractical.
Alternative #2: The second alternative, which is the current proposed and preferred
alternative, dips south of the mobile home park, gradually working back north to re join
the existing pipeline easement. This alternative is approximately 1.1 miles long, and
20163469.001A RAL16038071 Page 8 April 22, 2016
©2016 Kleinfelder

crosses a large (53 acre) forested wetland. Based on a wetland delineation, the impact
is 1.93 acres of forested wetland conversion, which will be mitigated through an off-site
mitigation bank. This alternative would require less land disturbance and forest clearing
than the longest alternative, avoids the residential area, and has been approved by all
associated landowners. As a result, this alternative was chosen.
Alternative #3: The third alternative runs north of the mobile home park, gradually
working back south to re -join the existing pipeline easement. Due to residential
development along the route, this alternative is the longest at approximately 1.9 miles.
Using National Wetland Inventory (NWI) data, the amount of forested wetland
conversion for this alternative is expected to be the same or greater than Alternative # 2
but would require more land disturbance and forest clearing. As a result, this alternative
was rejected.
4.2 Avoidance and Minimization of Impacts
Wetland disturbance has been minimized to the greatest extent practical while still
allowing for a viable project. No permanent wetland fill impacts are proposed for this
project. All jurisdictional impacts result from temporary open -cutting for pipe installation.
Impacts include forested wetland conversion within a 50 ft. wide limit of disturbance.
Once construction is complete, the installation trench will be backfilled with excavated
material and re -seeded with a wetland plant mix to stabilize the area.
Only 30 ft. of the 50 ft. permanent easement will be maintained as herbaceous
vegetation following construction. Since the wetland will not be filled and sources of
hydrology will remain unaltered, the impact area will maintain wetland function after
construction. Nevertheless, the applicant proposes to mitigate for the entire 1.93 acre
permanent wetland conversion impact area (Section 4.7).
20163469 001A RAL16038071 Page 9 April 22, 2016
©2016 Kleinfelder

4.3 Fish, Wildlife, Listed Species and their Habitats
Kleinfelder biologists conducted surveys for federally listed species and their habitats
within the project area during site inspections on July 30 and August 21, 2015. There
are currently three species listed as federally threatened or endangered in Robeson
County (Table 1):
TABLE 1. FEDERALLY PROTECTED SPECIES LISTED FOR ROBESON COUNTY
FEDERAL
COMMONNAME SCIENTIFIC NAME DESIGNATION
American alligator Alligator mississippiensis Threatened No
Red -cockaded Picoides borealis Endangered Potential foraging
woodpecker only
Michaux's sumac Rhus michauxii Endangered No
There was a small amount of foraging habitat for red -cockaded woodpecker in the
actively managed pine plantation in the western section of the project area, but no
nesting habitat was present within a half mile and no birds or cavities were observed
during surveys. Furthermore, a report from the NC Natural Heritage Program database
on 3/22/2016 did not identify any occurrences of federally listed species (including Bald
Eagle) recorded within the project area or within 1 -mile of the project area. Therefore, it
is likely this project will have no effect on these species.
No surface water features were observed within the project area and no impacts to fish
or other aquatic organisms are anticipated. Current wildlife utilization is composed of
common species found within southeast North Carolina. The resulting land cover within
the new easement will allow for the continued use of adjacent habitats within the area
for most species and the proposed project is not anticipated to adversely impact wildlife
or their habitat in the area.
4.4 Water Quality Impacts
No storm water management system is necessary for this project as no storm water
run-off is anticipated from the project. To eliminate potential for water quality impacts
during construction, a siltation fence will be installed on either side of the wetland where
20163469 001A RAL16038071 Page 10 April 22, 2016
©2016 Kleinfelder

the gas line is proposed to cross it. Inside the siltation fence, a water bar and trench
plug will be installed to reduce water flow velocity and isolate material in the trench,
respectively.
4.5 Public Interest
No public resources are affected by this proposed project. This project will maintain a
transmission gas pipeline that provides natural gas to local customers. The applicant
has secured easements on all affected properties. There is no public access to the
area for any type of recreational activities.
4.6 Historic and Cultural Resources
No historic or cultural resources were observed within the proposed project area. In
addition, the State Historic Preservation Office's HPOWeb GIS Service website
indicates no documented historic structures within or adjacent to the project area.
4.7 Mitigation Plan
Following construction, the impact area will continue to provide wetland habitat,
although 1.93 acres will be permanently converted from forested to herbaceous habitat.
The project will not cause a long-term alteration to wetland hydrology or water quality.
Therefore, the applicant proposes to mitigate for the 1.93 acre wetland impact at a 1:1
ratio.
Mitigation will be accomplished through the purchase of credits from an off-site
mitigation bank. Stone Farm Regional Mitigation Bank is located in the Lumber River
basin and is currently approved for use in 8 -digit hydrologic unit codes (HUC) 03040206
& 03040207. The project area lies in HUC 03040203. Given that other mitigation banks
are not available in the Lumber River basin, the ACOE has previously approved the use
of Stone Farm for this project. The mitigation acceptance letter is enclosed as Exhibit B.
20163469 001A RAL 16038071 Page 11 April 22, 2016
©2016 Klemfelder

5.0 SUMMARY
Information and materials contained herein are submitted in request to authorize
temporary wetland open -cut impacts and permanent forested wetland conversion
impacts associated with replacing and re-routing Line 33. The total project area
(including permanent easement and temporary workspace) comprises 6.5 acres, of
which 1.93 acres consists of jurisdictional wetlands. Following construction, impacted
uplands will be stabilized and vegetated as shown on the site plans. Mitigation for the
proposed impacts will be accomplished through purchase of credits from an off-site
mitigation bank at a 1:1 ratio.
20163469 001A RAL 16038071 Page 12 April 22, 2016
©2016 Kleinfelder

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EXHIBIT A
Preliminary Jurisdictional Determination Form

ATTACHMENT A
PRELIMINARY JURISDICTIONAL DETERMINATION FORM
BACKGROUND INFORMATION
A. REPORT COMPLETION DATE FOR PRELIMINARY JURISDICTIONAL
DETERMINATION (JD):
B. NAME AND ADDRESS OF PERSON REQUESTING PRELIMINARY JD:
Amy James, Kleinfelder Inc
3500 Gateway Centre Dr Suite 200, Morrisville NC 27560
C. DISTRICT OFFICE, FILE NAME, AND NUMBER:
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION:
Piedmont Natural Gas Line 33 replacement (transmission), near intersection of Russell Rd and Lombardy Village Rd , Lumber Bridge NC
(USE THE ATTACHED TABLE TO DOCUMENT MULTIPLE WATERBODIES AT DIFFERENT
SITES)
State: NC County/parish/borough: Robeson City: Lumber Bridge/Shannon
Center coordinates of site (lat/long in degree decimal format):
Lat. 34858405 ON; Long. -79061934 OW.
Universal Transverse Mercator:
Name of nearest waterbody: Bis Marsh Swamp
Identify (estimate) amount of waters in the review area:
Non -wetland waters:
linear feet: width (ft) and/or acres.
Cowardin Class:
Stream Flow:
Wetlands: 1 93 acres.
Cowardin Class: PFO
Name of any water bodies on the site that have been identified as Section 10
waters:
Tidal:
Non -Tidal:
1
,V

E. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL
APPLY):
❑ Office (Desk) Determination. Date:
❑ Field Determination. Date(s):
THAT
SUPPORTING DATA. Data reviewed for preliminary JD
(check all that apply - checked items should be included in case file and,
where checked and requested, appropriately reference sources below):
❑v Maps, plans, plots or plat submitted by or on behalf of the
applicant/consultant:
❑✓ Data sheets prepared/submitted by or on behalf of the
appIi' nt/consultant.
u Office concurs with data sheets/delineation report.
❑ Office does not concur with data sheets/delineation report.
❑ Data sheets prepared by the Corps:
❑ Corps navigable waters' study:
❑ U.S. Geological Survey Hydrologic Atlas:
❑ USGS NHD data
❑ USGS 8 and 12 digit HUC maps
❑✓ U.S. Geological Survey map(s). Cite scale & quad name: 1 24,000, Rennert quad
❑✓ USDA Natural Resources Conservation Service Soil Survey.
Citation: Robeson County, 1978
❑ National wetlands inventory map(s). Cite name:
❑ State/Local wetland inventory map(s):
❑ FEMA/FIRM maps:
N1
100 -year Floodplain Elevation is:
(National Geodectic Vertical Datum of 1929)
❑ Photographs: ❑ Aerial (Name & Date): or
❑ Other (Name & Date):
❑ Previous determination(s). File no. and date of response letter:
❑ Other information (please specify):
2

1. The Corps of Engineers believes that there may be jurisdictional waters of the
United States on the subject site, and the permit applicant or other affected party
who requested this preliminary JD is hereby advised of his or her option to
request and obtain an approved jurisdictional determination (JD) for that site.
Nevertheless, the permit applicant or other person who requested this
preliminary JD has declined to exercise the option to obtain an approved JD in
this instance and at this time.
2. In any circumstance where a permit applicant obtains an individual permit, or
a Nationwide General Permit (NWP) or other general permit verification requiring
"pre -construction notification" (PCN), or requests verification for a non -reporting
NWP or other general permit, and the permit applicant has not requested an
approved JD for the activity, the permit applicant is hereby made aware of the
following: (1) the permit applicant has elected to seek a permit authorization
based on a preliminary JD, which does not make an official determination of
jurisdictional waters; (2) that the applicant has the option to request an approved
JD before accepting the terms and conditions of the permit authorization, and
that basing a permit authorization on an approved JD could possibly result in less
compensatory mitigation being required or different special conditions; (3) that
the applicant has the right to request an individual permit rather than accepting
the terms and conditions of the NWP or other general permit authorization; (4)
that the applicant can accept a permit authorization and thereby agree to comply
with all the terms and conditions of that permit, including whatever mitigation
requirements the Corps has determined to be necessary; (5) that undertaking
any activity in reliance upon the subject permit authorization without requesting
an approved JD constitutes the applicant's acceptance of the use of the
preliminary JD, but that either form of JD will be processed as soon as is
practicable; (6) accepting a permit authorization (e.g., signing a proffered
individual permit) or undertaking any activity in reliance on any form of Corps
permit authorization based on a preliminary JD constitutes agreement that all
wetlands and other water bodies on the site affected in any way by that activity
are jurisdictional waters of the United States, and precludes any challenge to
such jurisdiction in any administrative or judicial compliance or enforcement
action, or in any administrative appeal or in any Federal court; and (7) whether
the applicant elects to use either an approved JD or a preliminary JD, that JD
will be processed as soon as is practicable. Further, an approved JD, a proffered
individual permit (and all terms and conditions contained therein), or individual
permit denial can be administratively appealed pursuant to 33 C.F.R. Part 331,
and that in any administrative appeal, jurisdictional issues can be raised (see 33
C.F.R. 331.5(a)(2)). If, during that administrative appeal, it becomes necessary
to make an official determination whether CWA jurisdiction exists over a site, or
to provide an official delineation of jurisdictional waters on the site, the Corps will
provide an approved JD to accomplish that result, as soon as is practicable.

This preliminary JD finds that there "may be" waters of the United States on the
subject project site, and identifies all aquatic features on the site that could be
affected by the proposed activity, based on the following information:
IMPORTANT NOTE: The information recorded on this form has not
necessarily been verified by the Corps and should not be relied up
later jurisdictional determinations. A
Signature and date of
Regulatory Project Manager
(REQUIRED)
4
+2 �-(6
Sibnature and date of
p rson requesting preliminary JD
(IREQUIRED, unless obtaining
the signature is impracticable)

Site Name
Latitude
Longitude
Estimated Amount of
Class of Aquatic
Aquatic Resource in
Resource
Project Area
Russell Rd.
34.857149
-79.078887
1.93 acres
Non section 10 --
Wetland
wetland

WETLAND DETERMINATION DATA FORM — Atlantic and Gulf Coastal Plain Region
Project/Site Piedmont Natural Gas Line 33 City/County Robeson Sampling Date 3/1/2016
Applicant/Owner Piedmont Natural Gas/Teresa Collins State NC Sampling Point Russel Rd wetland
Investigator(s) Amy James, Kleinfelder Inc 'Section, Township, Range Lumber Bridge
Landform (hillslope, terrace, etc ) Local relief (concave, convex, none) concave Slope (%) 0
Subregion (LRR or MLRA) LRR P Lat 34 857568 Long -79 080834 Datum
Soil Map Unit Name Coxville loam NWI classification PFO
Are climatic / hydrologic conditions on the site typical for this time of year? Yes X No (If no, explain in Remarks)
Are Vegetation Soil or Hydrology significantly disturbed? Are "Normal Circumstances" present? Yes X No
Are Vegetation Soil or Hydrology naturally problematic? (If needed, explain any answers in Remarks )
SUMMARY OF FINDINGS — Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Yes X No Is the Sampled Area
Hydric Soil Present? Yes x No within a Wetland? Yes X No
Wetland Hydrology Present? Yes x No
Remarks
Non -riparian Carolina bay system
HYDROLOGY
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two required)
❑ Surface Soil Cracks (136)
❑ Sparsely Vegetated Concave Surface (138)
Primary Indicators (minimum of one is required, check all that apply)
❑ Surface Water (Al) Aquatic Fauna (613)
Q High Water Table (A2)
111
Marl Deposits (B15) (LRR U)
❑ Drainage Patterns (610)
Saturation (A3)
tu-f
LJ Hydrogen Sulfide Odor (Cl)
❑ Moss Trim Lines (616)
�Q
LJ Water Marks (131)
II Oxidized Rhizospheres along Living Roots (C3)
❑ Dry -Season Water Table (C2)
Sediment Deposits (62)
Q Presence of Reduced Iron (C4)
0 Crayfish Burrows (C8)
_ Drift Deposits (133)
II Recent Iron Reduction in Tilled Soils (C6)
❑ Saturation Visible on Aerial Imagery (C9)
Q Algal Mat or Crust (134)
❑ Thin Muck Surface (C7)
❑ Geomorphic Position (D2)
a Iron Deposits (85)
0 Other (Explain in Remarks)
❑ Shallow Aquitard (D3)
a Inundation Visible on Aerial Imagery
(137)
❑ FAC -Neutral Test (D5)
Q Water -Stained Leaves (139)
❑ Sphagnum moss (D8) (LRR T, U)
Field Observations:
Surface Water Present? Yes
No X Depth (inches)
Water Table Present? Yes X
No Depth (inches) 0
Saturation Present? Yes X
No Depth (inches) 0
Wetland Hydrology Present? Yes X No
includes capillary fringe)
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available
Remarks
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

VEGETATION (Four Strata) — Use scientific names of plants.
Sampling Point Russel Rd wet
Remarks (If observed, list morphological adaptations below)
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0
Absolute Dominant Indicator
Dominance Test worksheet:
Tree Stratum (Plot size 30 ft x 30 ft )
% Cover Species? Status
Number of Dominant Species
1 Pinus taeda
40
Y FAC
That Are OBL, FACW, or FAC 6 (A)
2 Liquidambar styraciflua
30
Y FAC
Total Number of Dominant
3 Acer rubrum
15
N FAC
Species Across All Strata 5 (B)
4
Percent of Dominant Species
5
That Are OBL, FACW, or FAC 100 (A/B)
6
7
Prevalence Index worksheet:
8
Total % Cover of- Multiply by
85
= Total Cover
OBL species x 1 =
50/o of total cover 42 s
20/o o of total cover 17
FACW species x 2=
Sapling/Shrub Stratum (Plot size 30 ft x 30 ft )
FAC species x 3 =
1 Symplocos tinctoria
30
Y FAC
FACU species x 4 =
2 Acer rubrum
25
Y FAC
UPL species x 5 =
3 Liqwdambar styraci0ua
10
N FAC
Column Totals (A) (B)
4'
Prevalence Index = B/A =
5
Hydrophytic Vegetation Indicators:
6
❑ 1 - Rapid Test for Hydrophytic Vegetation
7
g 2 - Dominance Test is >50%
8
❑ 3 -Prevalence Index is :53 0+
65
= Total Cover
12 Problematic Hydrophytic Vegetation' + (Explain)
50% of total cover 325
20% of total cover 13
Herb Stratum (Plot size 30 ft x 30 ft )
Indicators of hydric soil and wetland hydrology must
1 Symplocos tinctona
5
Y FAC
be present, unless disturbed or problematic
2
Definitions of Four Vegetation Strata:
3
Tree — Woody plants, excluding vines, 3 in (7 6 cm) or
4
more in diameter at breast height (DBH), regardless of
5
height
6
Sapling/Shrub — Woody plants, excluding vines, less
7
than 3 in DBH and greater than 3 28 ft (1 m) tall
8
Herb — All herbaceous (non -woody) plants, regardless
9
of size, and woody plants less than 3 28 ft tall
10
Woody vine — All woody vines greater than 3 28 ft in
11
height
12
5
= Total Cover
50% of total cover
20% of total cover
Woody Vine Stratum (Plot size 30 ft x 30 ft )
1 Smilax rotundifolia
10
Y FAC
2
3
4
5
Hydrophytic
10
= Total Cover
Vegetation
50% of total cover
20% of total cover
Present? Yes x No
Remarks (If observed, list morphological adaptations below)
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

SOIL
Sampling Point Russel Rd Wel
le Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)
Depth Matrix Redox Features
(inches) Color (moist) % Color (moist) % Type Loc Texture Remarks
0-12 10YR 3/1 100 sandy clay loam
ape C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sand Grains
Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)
❑ Histosol (Al)
❑ Histic Epipedon (A2)
❑ Black Histic (A3)
❑ Hydrogen Sulfide (A4)
❑ Stratified Layers (A5)
D Organic Bodies (A6) (LRR P, T, U)
D 5 cm Mucky Mineral (A7) (LRR P, T, U)
D Muck Presence (A8) (LRR U)
D 1 cm Muck (A9) (LRR P, T)
L] Depleted Below Dark Surface (A11)
❑ Thick Dark Surface (Al2)
Coast Prairie Redox (A16) (MLRA 150A)
Sandy Mucky Mineral (S1) (LRR O, S)
Sandy Gleyed Matrix (S4)
HSandy Redox (S5)
Stripped Matrix (S6)
L] Dark Surface (S7) (LRR P, S, T, U)
Restrictive Layer (if observed):
Type
Depth (inches)
Remarks
2Location PL=Pore Lining, M=Matrix
Indicators for Problematic Hydric Soils':
Polyvalue Below Surface (S8) (LRR S, T, U)
1 cm Muck (A9) (LRR O)
Thin Dark Surface (S9) (LRR S, T, U)
T❑
u 2 cm Muck (A10) (LRR S)
Loamy Mucky Mineral (F1) (LRR O)
El Reduced Vertic (F18) (outside MLRA 150A,B)
Loamy Gleyed Matrix (F2)
Piedmont Floodplain Soils (F19) (LRR P, S, T)
Depleted Matrix (F3)
��-I
u Anomalous Bright Loamy Soils (F20)
Redox Dark Surface (F6)
(MLRA 15313)
❑
Depleted Dark Surface (F7)
Red Parent Material (TF2)
Redox Depressions (F8)
D Very Shallow Dark Surface (TF12)
Marl (F10) (LRR U)
D Other (Explain in Remarks)
Depleted Ochric (F11) (MLRA 151)
Iron -Manganese Masses (F12) (LRR O, P, T)
3Indicators of hydrophytic vegetation and
Umbric Surface (F13) (LRR P, T, U)
wetland hydrology must be present,
Delta Ochric (F17) (MLRA 151)
unless disturbed or problematic
Reduced Vertic (F18) (MLRA 150A, 15013)
Piedmont Floodplain Soils (F19) (MLRA 149A)
Anomalous Bright Loamy Sods (F20) (MLRA 149A, 153C, 153D)
Hydric Soil Present? Yes X No
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

WETLAND DETERMINATION DATA FORM — Atlantic and Gulf Coastal Plain Region
Project/Site Piedmont Natural Gas Line 33 City/County Robeson Sampling Date 3/1/2016
Applicant/Owner Piedmont Natural Gas/DOT ROW State NC Sampling Point Russel Rd upland
Investigator(s) Amy James, Kleinfelder Inc Section, Township, Range Lumber Bridge
Landform (hlllslope, terrace, etc ) Local relief (concave, convex, none) concave (next to road fill slope) Slope (%) 0
Subregion (LRR or MLRA) LRR P Lat 34 858449 Long -79 082048 Datum
Soil Map Unit Name Wagram loamy sand NWI classification
Are climatic / hydrologic conditions on the site typical for this time of year? Yes X No (If no, explain in Remarks )
Are Vegetation Soil or Hydrology significantly disturbed? Are "Normal Circumstances" present? Yes X No
Are Vegetation Soil or Hydrology naturally problematic? (If needed, explain any answers in Remarks )
SUMMARY OF FINDINGS — Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Yes X No
Is the Sampled Area
Hydric Soil Present? Yes No x within a Wetland? Yes No X
Wetland Hydrology Present? Yes No x
Remarks
HYDROLOGY
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two required)
❑ Surface Soil Cracks (136)
❑ Sparsely Vegetated Concave Surface (B8)
❑ Drainage Patterns (1310)
Primary Indicators (minimum of one is required check all that apply)
❑
Q
Surface Water (Al) ❑ Aquatic Fauna (613)
High Water Table (A2) Q Marl Deposits (B15) (LRR U)
Q
Saturation (A3)
Q Hydrogen Sulfide Odor (C1)
Q Moss Trim Lines (616)
Water Marks (131)
Q Oxidized Rhlzospheres along Living Roots (C3)
1.1 Dry -Season Water Table (C2)
III --Q
Sediment Deposits (132)
Q Presence of Reduced Iron (C4)
0 Crayfish Burrows (C8)
_
Drift Deposits (133)
Q Recent Iron Reduction In Tilled Soils (C6)
❑ Saturation Visible on Aerial Imagery (C9)
a
Algal Mat or Crust (64)
❑ Thin Muck Surface (C7)
❑ Geomorphic Position (D2)
a
Iron Deposits (135)
Other (Explain in Remarks)
Q Shallow Aquitard (D3)
Q
Inundation Visible on Aerial Imagery (137)
II FAC -Neutral Test (D5)
a
Water -Stained Leaves (139)
❑ Sphagnum moss (D8) (LRR T, U)
Field Observations:
Surface Water Presents Yes
No X Depth (inches)
Water Table Present? Yes
No x Depth (inches)
Saturation Present? Yes
No x Depth (inches)
Wetland Hydrology Present? Yes No X
includes capillary fringe)
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available
Remarks
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

VEGETATION (Four Strata) — Use scientific names of plants. ,
Sampling Point Russell Rd upi
Remarks (If observed, list morphological adaptations below)
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0
Absolute Dominant Indicator
Dominance Test worksheet:
Tree Stratum (Plot size 30 ft x 30 ft )
% Cover Species? Status
Number of Dominant Species
1 Ligwdambar styraciflua
40
Y FAC
That Are OBL, FACW, or FAC 6 (A)
2 Pinus taeda
10
Y FAC
Total Number of Dominant
3
Species Across All Strata 6 (B)
4
Percent of Dominant Species
5
That Are OBL, FACW, or FAC 100 (A/B)
6
7
Prevalence Index worksheet:
8
Total % Cover of Multiply by
50
= Total Cover
OBL species x 1 =
50% of total cover 25
20% of total cover 10
FACW species x 2 =
Sapling/Shrub Stratum (Plot size 30 ft x 30 ft )
FAC species x 3 =
1 Liquidambar styraciflua
25
Y FAC
FACU species x 4 =
2 Ligustrum sinense
15
Y FAC
UPL species x 5 =
3 Morella cenfera
5
N FACW
Column Totals (A) (B)
4
Prevalence Index = B/A =
5
Hydrophytic Vegetation Indicators:
6
❑ 1 - Rapid Test for Hydrophytic Vegetation
7
2 - Dominance Test is >50%
8
3 -Prevalence Index Is 53 0'
45
= Total Cover
Q Problematic Hydrophytic Vegetation (Explain)
50% of total cover 225
20% of total cover 9
Herb Stratum (Plot size 30 It x 30 ft )
'Indicators of hydric soil and wetland hydrology must
1 Lomcera japonica
20
Y FAC
be present, unless disturbed or problematic
2
Definitions of Four Vegetation Strata:
3
Tree — Woody plants, excluding vines, 3 in (7 6 cm) or
4
more in diameter at breast height (DBH), regardless of
5
height
6
Sapling/Shrub — Woody plants, excluding vines, less
7
than 3 in DBH and greater than 3 28 ft (1 m) tall
8
Herb — All herbaceous (non -woody) plants, regardless
9
of size, and woody plants less than 3 28 ft tall
10 "
Woody vine — All woody vines greater than 3 28 ft in
11
height
12
20
= Total Cover
50% of total cover.
20% of total cover
Woody Vine Stratum (Plot size 30 ft x 30 ft )
1 Lonicera japonica
10
Y FAC
2
3
4
5
Hydrophytic
10
= Total Cover
Vegetation
50% of total cover
20% of total cover
Present? Yes x No
Remarks (If observed, list morphological adaptations below)
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

SOIL
Profile Description: (Describe to the depth needed to
Sampling Point Russell Rd upl
or confirm the absence of indicators.)
Depth Matrix Redox Features
(inches) Color (moist) % Color (moist) % Type Loc Texture Remarks
0-12+ 10YR 3/1 100 loamy sand 50% coated
'Type C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sand Grains
Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)
❑ Histosol (Al)
Histic Epipedon (A2)
Black Histic (A3)
Hydrogen Sulfide (A4)
HStratified Layers (A5)
Organic Bodies (A6) (LRR P, T, U)
H5 cm Mucky Mineral (A7) (LRR P, T, U)
n
Muck Presence (A8) (LRR U)
1 cm Muck (A9) (LRR P, T)
❑ Depleted Below Dark Surface (Al 1)
❑ Thick Dark Surface (Al2)
Coast Prairie Redox (A16) (MLRA 150A)
Sandy Mucky Mineral (S1) (LRR O, S)
L] Sandy Gleyed Matrix (S4)
Sandy Redox (S5)
Stripped Matrix (S6)
Dark Surface (S7) (LRR P, S, T, U)
Restrictive Layer (if observed):
Type
Depth (inches)
Remarks
2Location PL=Pore Lining, M=Matnx
Indicators for Problematic Hydric Soils':
Polyvalue Below Surface (S8) (LRR S, T, U)
❑ 1 cm Muck (A9) (LRR O)
Thin Dark Surface (S9) (LRR S, T, U)
2 cm Muck (Al 0) (LRR S)
Loamy Mucky Mineral (F1) (LRR O)
-t Reduced Vertic (F18) (outside MLRA 150A,B)
Loamy Gleyed Matrix (F2)
T
u Piedmont Floodplain Sods (F19) (LRR P, S, T)
_E]
Depleted Matrix (F3)
Anomalous Bright Loamy Soils (F20)
Redox Dark Surface (F6)
(MLRA 153B)
Depleted Dark Surface (F7)❑
-1 Red Parent Material (TF2)
Redox Depressions (F8)
U Very Shallow Dark Surface (TF1 2)
Marl (F10) (LRR U)
D Other (Explain in Remarks)
Depleted Ochnc (F11) (MLRA 151)
Iron -Manganese Masses (F12) (LRR O, P, T)
3Indicators of hydrophytic vegetation and
Umbnc Surface (F13) (LRR P, T, U)
wetland hydrology must be present,
Delta Ochnc (F17) (MLRA 151)
unless disturbed or problematic
Reduced Vertic (F18) (MLRA 150A, 150B)
Piedmont Floodplain Sods (F19) (MLRA 149A)
Anomalous Bright Loamy Sods (F20) (MLRA 149A, 153C, 153D)
Hydric Soil Present? Yes No X
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

EXHIBIT B
Stone Farm Mitigation Bank
Credit Request Acceptance Letter

STONE FARM REGIONAL MITIGATION BANK
CREDIT REQUEST ACCEPTANCE
Date: March 28, 2016
Piedmont Natural Gas
4720 Piedmont Row Dr.
Charlotte, NC 38210
Project Name: Line 33 Replacement (Transmission IP)
Expiration of Acceptance: September 28, 2016
SFMB Number:
Dear: Mr. Dietrich
DRAFT
Stone Farm Mitigation Bank, LLC
11 Causeway Drive
Ocean Isle Beach, NC 28469
The purpose of this letter is to notify you that the Stone Farm Regional Mitigation Bank (Bank) is willing to
accept payment for impacts associated with the above referenced project Please note that this decision
does not assure that the payment will be approved by the permit issuing agencies as mitigation for project
impacts. It is the responsibility of the applicant to contact these agencies to determine if payment to the
Bank will be approved. It is also the responsibility of the applicant to determine the appropriate credit ratios
that will be required for the corresponding wetland and/or stream impacts You must also comply with all
other state, federal or local government permits, regulations or authorizations associated with the proposed
activity.
This acceptance is valid for six (6) months from the date of this letter and is not transferable If we have not
received payment for the accepted credits of the issued 404 Permit/401 Certification/CAMA permit
within this time frame, this acceptance will expire. Predicated on the total payment due to the Bank, as
set forth herein, a ten (10) percent non-refundable deposit is due at the time of acceptance by the Bank It is
the applicant's responsibility to send copies of their permits to the Bank Once the Bank receives a copy of
the permit(s), an invoice will be issued based on the information identified below. Payment must be made
prior to conducting the authorized work It is the applicants responsibility to ensure that the credit types and
amounts identified below are consistent with the compensatory mitigation requirements of the permit(s)
issued The Bank and/or its agents are not responsible for determining the applicant's mitigation
requirements.
Based on the mformatTon supplied by the applicant, the impacts that may require compensatory mitigation
are summarized in the following table.
Note that the impact and credit totals above were provided by the applicant It is the applicant's
responsibility to provide accurate information (including the requested mitigation credits). The Bank and/or
its agents are not responsible for determining the required credit amounts. The Bank's decision to accept
credits is based upon the information provided by the applicant. The Bank is not liable for any credit
shortage should the applicant's required mitigation credits exceed the amount specked in the above table
Based upon the type and amounts of credits requested above, the following payment must be provided to
the Bank prior to issuance of credits:
Cl! Location
Stream (ft.)
Wetlands ac.)
Non -riparian
Ri anan
Impact
03040203
286
Credits
2.90
Note that the impact and credit totals above were provided by the applicant It is the applicant's
responsibility to provide accurate information (including the requested mitigation credits). The Bank and/or
its agents are not responsible for determining the required credit amounts. The Bank's decision to accept
credits is based upon the information provided by the applicant. The Bank is not liable for any credit
shortage should the applicant's required mitigation credits exceed the amount specked in the above table
Based upon the type and amounts of credits requested above, the following payment must be provided to
the Bank prior to issuance of credits:

Credit Type Unit Per Unit Credit Fee
Sub -Total
Stream 0 $296.00
$000
Nonnparian Wetland 2.9 $26,418.00
$76,612.20
Riparian Wetland 0 $40,256.00
$0.00
Total Payment Due
Non-refundable Deposit
Balance Due Upon invoice
$76,612.20
$7,661.22
$68,950.98
Upon receipt of full payment, the Bank will take responsibility for providing the compensatory mitigation. If
the regulatory agencies require mitigation credits greater than indicated above, and should the applicant
want the Bank to provide such credits, it is the applicant's responsibility to submit an additional credit
request form to the Bank.
If you have any questions or need additional information, please contact Paula Buis at 910-579-7300 or
pbuis@ladane com.
Sincerely,
ax
Paula Buis
Stone Farm Mitigation Bank, LLC
cc: NCDWQ-Raleigh
USACE
NCDWQ-Local
Agent

EXHIBIT C
Land Owner Information

Line 33 3" line replacement landowners for individual permit.
Robeson County PIN
Owner
Deed
Mailing Address
Book/Page
947055554300
William Mast
787/303
1910 Ross Mill Rd
Henderson, NC 27536
Jeremy and Eden
1274 Lombardy Village
947053424000*
Locklear
1126/777
Rd., Shannon,
NC 28386
947052835500*
Teresa Collins et al.
710/345
PO BOX 387
Shannon, NC 28386
947072435400
Mark Locklear
1116/874
10142 Rennert Rd
Shannon, NC 28386
Jasper and John
261 Ireland Dr.
947072508400
Gray
1193/206
Lumber Bridge, NC
28357
*indicates jurisdictional impact on property

U.S. ARMY CORPS OF ENGINEERS
APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT
OMB APPROVAL NO 0710-0003
EXPIRES 28 FEBRUARRYY 2 200133
33 CFR 325 The proponent agency is CECW-CO-R
Public reporting for this collection of information is estimated to average 11 hours per response, including the time for reviewing instructions, searching
existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information Send comments regarding
this burden estimate or any other aspect of the collection of information, including suggestions for reducing this burden, to Department of Defense,
Washington Headquarters, Executive Services and Communications Directorate, Information Management Division and to the Office of Management and
Budget, Paperwork Reduction Project (0710-0003) Respondents should be aware that notwithstanding any other provision of law, no person shall be
subject to any penalty for fading to comply with a collection of information if it does not display a currently valid OMB control number Please DO NOT
RETURN your form to either of those addresses Completed applications must be submitted to the District Engineer having jurisdiction over the location of
the proposed activity
PRIVACY ACT STATEMENT
Authorities Rivers and Harbors Act, Section 10, 33 USC 403, Clean Water Act, Section 404, 33 USC 1344, Marine Protection, Research, and Sanctuaries
Act, Section 103, 33 USC 1413, Regulatory Programs of the Corps of Engineers, Final Rule 33 CFR 320-332 Principal Purpose Information provided on
this form will be used in evaluating the application for a permit Routine Uses This information may be shared with the Department of Justice and other
federal, state, and local government agencies, and the public and may be made available as part of a public notice as required by Federal law Submission
of requested information is voluntary, however, if information is not provided the permit application cannot be evaluated nor can a permit be issued One set
of original drawings or good reproducible copies which show the location and character of the proposed activity must be attached to this application (see
sample drawings and/or instructions) and be submitted to the District Engineer having jurisdiction over the location of the proposed activity An application
that is not completed in full will be returned
(ITEMS 1 THRU 4 TO BE FILLED BY THE CORPS)
1 APPLICATION NO
2 FIELD OFFICE CODE
3 DATE RECEIVED
4 DATE APPLICATION COMPLETE
(ITEMS BELOW TO BE FILLED BY APPLICANT)
5 APPLICANT'S NAME
8 AUTHORIZED AGENT'S NAME AND TITLE (agent is not required)
First - Edward Middle - Last - Dietrich
First - Jonathan Middle - Last - Oravetz
Company - Piedmont Natural Gas
Company - Kleinfelder
E-mail [e-mail]
E-mail [e-mail]
6 APPLICANT'S ADDRESS
9 AGENT'S ADDRESS
Address-
Address- 8933 Western Way STE 12
City - Charlotte State - NC Zip - 28210 Country -
City - Jacksonville State - FL Zip - 32256 Country -
7 APPLICANT'S PHONE NOs w/AREA CODE
10 AGENTS PHONE NOs w/AREA CODE
a Residence b Business c Fax
a Residence b Business c Fax
704-731-4459
904-538-9171
STATEMENT OF AUTHORIZATION
11 1 hereby authorize, Laura Mills to act in my behalf as my agent in the processing of this application and to furnish, upon request,
supplemental information in support of this permit application
SIGNATURE OF APPLICANT DATE
NAME, LOCATION, AND DESCRIPTION OF PROJECT OR ACTIVITY
12 PROJECT NAME OR TITLE (see instructions)
Line 33 Replacement
13 NAME OF WATERBODY, IF KNOWN (if applicable)
14 PROJECT STREET ADDRESS (if applicable)
Big Marsh Swamp
Address
15 LOCATION OF PROJECT
Latitude -N 34 857 Longitude -W 79 079
City - State- Zip -
16 OTHER LOCATION DESCRIPTIONS, IF KNOWN (see instructions)
State Tax Parcel ID Municipality
Section - Township - Range -
ENG FORM 4345, OCT 2012 PREVIOUS EDITIONS ARE OBSOLETE Page 1 of 3

17 DIRECTIONS TO THE SITE
From I-95 take exit 33 to Blanchard Rd, go west on Blanchard Rd then west onto Lumber Bridge Rd. Turn left on Crenshaw Road, then
right onto Russell Road, project intersects Russell Rd.
18 Nature of Activity (Description of project, include all features)
Clearing of forested wetland for installation of pipeline replacement. See Environmental Support Document for additional details.
19 Project Purpose (Describe the reason or purpose of the project, see instructions)
Replacement of pipeline. See Environmental Support Document for additional details.
USE BLOCKS 20-23 IF DREDGED AND/OR FILL MATERIAL IS TO BE DISCHARGED
20 Reason(s)for Discharge
No discharge
21 Type(s) of Material Being Discharged and the Amount of Each Type in Cubic Yards
Type Type Type
Amount in Cubic Yards Amount in Cubic Yards Amount in Cubic Yards
No discharge
22 Surface Area in Acres of Wetlands or Other Waters Filled (see instructions)
Acres No Fill - 1.93 acres of conversion of forested to herbaceous wetlands.
or
Linear Feet
23 Description of Avoidance, Minimization, and Compensation (see instructions)
See Environmental Support Document
ENG FORM 4345, OCT 2012 Page 2 of 3

24 Is Any Portion of the Work Already Complete? F]Yes FX�No IF YES, DESCRIBE THE COMPLETED WORK
25 Addresses of Adjoining Property Owners, Lessees, Etc., Whose Property Adjoins the Waterbody (if more than can be entered here, please attach a supplemental list)
a Address-
City - State - Zip -
b Address-
City - State - Zip -
c Address-
City - State - Zip -
d Address-
City - State - Zip -
e Address-
City - State - Zip -
26 List of Other Certificates or Approvals/Denials received from other Federal, State, or Local Agencies for Work Descnbed in This Application
AGENCY TYPE APPROVAL' IDENTIFICATION DATE APPLIED DATE APPROVED DATE DENIED
NUMBER
Would include but is not restricted to zoning, building, and flood plain permits
27 Application is hereby made for permit or permits to authorize the work described In this application I certify that this Information In this application is
complete and accurate I further certify that I possess the authonty to undertake the work described herein or am acting as the duly authorized agent of the
applicant
SIGNATURE OF APPLICANT DATE SIGNATURE OF AGENT DATE
The Application must be signed by the person who desires to undertake the proposed activity (applicant) or it may be signed by a duly
authorized agent if the statement in block 11 has been filled out and signed.
18 U S C Section 1001 provides that- Whoever, in any manner within the jurisdiction of any department or agency of the United States
knowingly and willfully falsifies, conceals, or covers up any trick, scheme, or disguises a material fact or makes any false, fictitious or
fraudulent statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious or
fraudulent statements or entry, shall be fined not more than $10,000 or imprisoned not more than five years or both.
ENG FORM 4345, OCT 2012 Page 3 of 3

KDER
�1 ���
PNG LINE 33 REPLACEMENT
ROBESON COUNTY, NORTH CAROLINA
404 INDIVIDUAL PERMIT APPLICATION:
ENVIRONMENTAL SUPPORT DOCUMENT
20163469 001A RAL16038071 April 22, 2016
©2016 Klemfelder

PNG LINE 33 REPLACEMENT
ROBESON COUNTY, NORTH CAROLINA
404 INDIVIDUAL PERMIT APPLICATION:
ENVIRONMENTAL SUPPORT DOCUMENT
1.0 INTRODUCTION..................................................................................................1
2.0 EXISTING CONDITIONS..................................................................................... 3
2.1 Topography................................................................................................3
2.2 Soils........................................................................................................... 3
2.3 Land Use................................................................................................... 5
3.0 PROPOSED PROJECT....................................................................................... 7
4.0 ENVIRONMENTAL CONSIDERATIONS............................................................. 8
4.1 Alternative Plan Analysis........................................................................... 8
4.2 Avoidance and Minimization of Impacts ..................................................... 9
4.3 Fish, Wildlife, Listed Species and their Habitats......................................10
4.4 Water Quality Impacts..............................................................................10
4.5 Public Interest..........................................................................................11
4.6 Historic and Cultural Resources..............................................................11
4.7 Mitigation Plan.........................................................................................11
5.0 SUMMARY.........................................................................................................12
FIGURES
Figure 1 Project Location Map
Figure 2 Soil and USGS Topographical Maps
Figure 3 Land Cover / Land Use Map
Figure 4 Jurisdictional Resource Impacts
Figure 5 Alternatives Analysis
EXHIBITS
Exhibit A Preliminary Jurisdictional Determination Form
Exhibit B Stone Farm Mitigation Bank - Credit Request Acceptance Letter
Exhibit C Land Owner Information
20163469 001A RAL 16038071 April 22, 2016
©2016 Klemfelder

1.0 INTRODUCTION
Piedmont Natural Gas (PNG) operates Line 33 (3 inch diameter) in Robeson County,
North Carolina, between Lumber Bridge and St. Pauls. Its western terminus is at Line
5, just west of NC 71 and its eastern terminus is at St. Pauls' city gate on NC 20, where
Line 33 connects to the interstate pipeline system. PNG is replacing Line 33 with an 8
inch diameter pipe to accommodate anticipated demand from an economic
development project in the region, which involves a new Sanderson Farms chicken
processing plant in St. Pauls along NC 20.
The U.S. Army Corps of Engineers (ACOE) previously authorized NWP #12 for 0.32
acre of wetland conversion impacts associated with a 3 -mile transmission segment of
Line 33, located between the city gate and Covington Farm Rd (SAW -2016-00101).
Additionally, NWP #12 was authorized for a 4.7 -mile distribution segment, between
Covington Farm Rd. and existing PNG Line 5 (SAW -2016-00586). The latter project
avoided wetland impacts through use of horizontal directional drilling (HDD), but
required temporary impact to 60 linear feet of perennial tributary.
The subject permit application requests authorization for wetland conversion impacts
associated with re-routing 0.96 miles of the existing Line 33 between Strawberry Lane
and the end of Ireland Dr. (Figure 1). PNG proposes to re-route this length of pipe
within a 1.1 mile long project area located south of the current easement. In order to
construct this route, 1.93 acres of wetland conversion will occur within a 50 -foot wide
limit of disturbance.
The applicant previously intended to avoid wetland impacts on this segment of the
project through use of HDD. However, property access constraints subsequently
necessitated a bend in the re-routed line, within the jurisdictional wetland area (Figure
2). The resulting point of inflection (PI) would require a second HDD line, which would
require wetland clearing and substrate impacts, thereby diminishing the environmental
20163469 001A RAL 16038071 Page 1 April 22, 2016
©2016 Klemfelder

benefits of using HDD technology. As a result, HDD is no longer practical for this
segment of the project.
The subject Individual Permit application is being submitted to request authorization for
forested wetland conversion impacts associated with traditional open -cut installation of
the re-routed pipe. This submittal additionally requests a Preliminary Jurisdictional
Determination for the project area.
20163469.001A RAL16O38071 Page 2 April 22, 2016
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2.0 EXISTING CONDITIONS
The 6.5 -acre project area is located near the intersection of Russell Rd. and Lombardy
Village Rd. near Lumber Bridge in north -central Robeson County (Figure 1).
A Jurisdictional Determination field visit was conducted for this project with John
Policarpo of the ACOE on March 1, 2016. Wetland determination data forms in the
wetland impact area and adjacent upland were completed, as well as an updated
Preliminary JD form. These are enclosed as Exhibit A.
2.1 Topography
The topography of the project area is flat to gently sloping, with elevations varying only
slightly from 188 to 195 NGVD. The project area slopes slightly from west to east with a
depression in the middle. A USGS Topographic Quadrangle map is provided as Figure
2.
2.2 Soils
The Robeson County Soil Survey (U.S.D.A., Soil Conservation Service, 1978) indicates
the following soil types within the project area (Figure 2):
Coxville loam (Co) — This soil is composed of 95% Coxville components (85% drained;
10% undrained). This soil type is found on broad, low flats or in Carolina bays. Natural
drainage is poor, with a seasonal high water table at or just below the surface from
November to April. Most of this soil series is forested or, if drained, used for crop and
pastureland. This soil meets hydric criteria.
Lynchburg sandy loam (Ly) - This soil is composed of a 94% non -hydric Lynchburg
component. This soil type is found on nearly level, broad, smooth plains. Natural
drainage is somewhat poorly drained; however this soil type is not flooded or ponded.
20163469 001A RAL16038071 Page 3 April 22, 2016
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The seasonal high water table is about 18 inches below the surface from November to
April. This soil does not meet hydric criteria.
Norfolk Loamy Sand (NoA) — This soil is composed of a 95% non -hydric Norfolk
component. This soil type is found on nearly level to gently sloping, broad, smooth
plains. The soil is well -drained, with a seasonal high water table more than 5 feet below
the surface. This soil type does not meet hydric criteria.
Pocalla loamy sand (PoB) — This soil is composed of a 90% non -hydric Pocalla
component. This soil type is found on broad, smooth plains and is considered
excessively drained. The seasonal high water table is more than 5 feet below the
surface. Most of the mapping unit is in crop and pastureland, with some forested
pockets. This soil does not meet hydric soil criteria.
Rains sandy loam (Ra) — This soil is composed of 82% Rains components and 8%
Pantego components. This soil type is found on broad, low flats; natural drainage is
poor and some areas are subject to ponding for brief periods. The seasonal high water
table is at or just below the surface from November to April. About half this soil series is
used for crop and pastureland, with the remaining acreage in forest. This soil meets
hydric criteria.
Wagram loamy sand (WaB) — This soil is composed of a 95% non -hydric Wagram
component. This soil type is found on plains next to drainage -ways and on broad,
smooth ridges. The soil is well -drained, with a seasonal high water table more than 5
feet below the surface. Most of the mapping unit is in crop and pastureland, with some
forested pockets. This soil does not meet hydric soil criteria.
Federally jurisdictional wetlands were identified within areas mapped as Coxville loam
and Rains sandy loam. Wetland locations and descriptions are provided in the sections
that follow.
20163469.001A RAL16O38071 Page 4 April 22, 2016
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2.3 Land Use
Land uses and vegetative communities within the project area were classified and
mapped in accordance with the Land Cover and Land Use Categories developed by the
NC Center for Geographic Information and Analysis [CGIA] (Figure 3).
Uplands
Uplands within the project area consist of natural communities and man-made
improvements, as described below.
Agricultural Land
The Agricultural Land category includes crops and pastureland. In the project area,
most of this area is cultivated with soybeans.
Actively Managed Forest Stands
This category includes lands managed for silviculture. The canopy is dominated by
loblolly pine (Pinus taeda), with an understory of sweetgum (Liquidambar styraciflua),
and tulip poplar (Liriodendron tulipifera). Common ground cover includes creeping
blueberry (Vaccinium crassifolium) and Japanese honeysuckle (Lonicera japonica).
Mixed Deciduous -Coniferous Forestland
This forested category consists of previously disturbed lands that have regenerated into
a mixed forest of loblolly pine and various hardwoods. Common hardwoods include
water oak (Quercus nigra), sweetgum, red maple (Acer rubrum), and tulip poplar. The
understory can include American holly (Ilex opaca), dogwood (Cornus florida) Chinese
privet (Ligustrum sinense), horse sugar (Symplocos tinctoria). Herbs and vines can
include cranefly orchid (Tipularia discolor), Christmas fern (Polystichum acrostichoides),
yellow jessamine (Gelsemium sempervirens), and greenbrier (Smilax rotundifolia).
Wetlands
Wetlands within the project area consist of a low-lying Carolina Bay community.
20163469 001A RAL 16038071 Page 5 April 22, 2016
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Hardwood Swamp (bay and wet pocosins)
Carolina bay communities are non -riparian wet hardwood flats found throughout the
southeastern coastal plain of North Carolina. In the project area, the bay swamp has
been historically manipulated for silvicultural activities. A large central portion was
recently harvested. Common canopy species include loblolly pine, water oak,
sweetgum, and red maple. The understory is dominated by horse sugar, sweet bay
(Magnolia virginiana), and highbush blueberry (Vaccinium corymbosum). The vine layer
is thick, especially in the recently harvested areas, and includes laurel greenbrier
(Smilax laurifolia), greenbrier, and grape (Vitis rotundifolia).
20163469.001A RAL16O38071 Page 6 April 22, 2016
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3.0 PROPOSED PROJECT
The project entails abandoning approximately 0.96 miles (5,069 linear feet) of existing
right-of-way (ROW) which was built near a residential area, and re-routing the new
length of pipeline to the south. The re-route is 1.1 miles long and rejoins the existing
easement just east of the residential area. The project area is 6.5 acres in total size,
consisting of a 50 ft. construction ROW (Figure 4).
The project involves open -cut pipe installation and clearing in the 50ft construction
ROW. Within the construction ROW, a 30 ft. wide section will be permanently
maintained to provide a clear line -of -sight. Construction of the new line will result in
1.93 acres of permanent wetland conversion (Figure 4). The project has been designed
using the narrowest footprint that will safely allow access for installation of the pipeline
while not bisecting properties and allowing for future maintenance activities.
Within the 50 ft. wide project area, clearing will consist of mechanized tree and
understory removal as needed to facilitate construction. Construction work in the
wetland will be conducted from timber matting to minimize ground disturbance.
Following construction, impacted uplands will be stabilized and vegetated. Wetlands
will be seeded with an appropriate wetland plant mix upon pipe installation.
Mitigation to offset the 1.93 acres of wetland conversion impact is discussed in detail in
Section 4.7.
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4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 Alternative Plan Analysis
The following Alternative Analysis outlines the process by which the current proposed
route, or Preferred Alternative, was chosen (Figure 5). The proposed route is
dependent on the location of the existing easement, since it was determined that
paralleling the existing line, where possible, would reduce jurisdictional impacts for the
replacement project as a whole.
No Build Alternative: The no -build alternative considers that the existing 3" natural gas
pipeline will not be replaced with a new 8" pipe. Up-sizing of the pipeline is needed to
accommodate increased demand from industrial development in the project vicinity. IN
addition, the diameter of the existing line is too small to be cleaned and maintained
effectively. Lastly, the existing line is reaching the end of its life span and could pose a
safety risk the longer it remains operational given its age and condition. The no -build
alternative presents resource availability, pipeline maintenance, and safety challenges.
Therefore, this alternative was rejected.
Alternative #1: The first alternative follows the existing easement through a mobile
home park along Ireland Drive (private road). This alternative is the shortest (0.96 mile)
and would avoid jurisdictional wetland impacts. However, this route is not feasible
because it passes through a residential area where the homes are clustered very close
to the existing easement. The existing corridor is not wide enough to accommodate the
new line alongside the existing pipe. Moving the homes is prohibitive since existing
wells and septic fields would also need to be avoided. In addition, two landowners at
the end of Ireland Drive declined access to their property. Based on these challenges,
Alternative #1 was rejected as impractical.
Alternative #2: The second alternative, which is the current proposed and preferred
alternative, dips south of the mobile home park, gradually working back north to re join
the existing pipeline easement. This alternative is approximately 1.1 miles long, and
20163469.001A RAL16038071 Page 8 April 22, 2016
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crosses a large (53 acre) forested wetland. Based on a wetland delineation, the impact
is 1.93 acres of forested wetland conversion, which will be mitigated through an off-site
mitigation bank. This alternative would require less land disturbance and forest clearing
than the longest alternative, avoids the residential area, and has been approved by all
associated landowners. As a result, this alternative was chosen.
Alternative #3: The third alternative runs north of the mobile home park, gradually
working back south to re join the existing pipeline easement. Due to residential
development along the route, this alternative is the longest at approximately 1.9 miles.
Using National Wetland Inventory (NWI) data, the amount of forested wetland
conversion for this alternative is expected to be the same or greater than Alternative # 2
but would require more land disturbance and forest clearing. As a result, this alternative
was rejected.
4.2 Avoidance and Minimization of Impacts
Wetland disturbance has been minimized to the greatest extent practical while still
allowing for a viable project. No permanent wetland fill impacts are proposed for this
project. All jurisdictional impacts result from temporary open -cutting for pipe installation.
Impacts include forested wetland conversion within a 50 ft. wide limit of disturbance.
Once construction is complete, the installation trench will be backfilled with excavated
material and re -seeded with a wetland plant mix to stabilize the area.
Only 30 ft. of the 50 ft. permanent easement will be maintained as herbaceous
vegetation following construction. Since the wetland will not be filled and sources of
hydrology will remain unaltered, the impact area will maintain wetland function after
construction. Nevertheless, the applicant proposes to mitigate for the entire 1.93 acre
permanent wetland conversion impact area (Section 4.7).
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4.3 Fish, Wildlife, Listed Species and their Habitats
Kleinfelder biologists conducted surveys for federally listed species and their habitats
within the project area during site inspections on July 30 and August 21, 2015. There
are currently three species listed as federally threatened or endangered in Robeson
County (Table 1):
TABLE 1. FEDERALLY PROTECTED SPECIES LISTED FOR ROBESON COUNTY
FEDERAL
COMMONNAME SCIENTIFIC NAME DESIGNATION
American alligator Alligator mississippiensis Threatened No
Red -cockaded Picoides borealis Endangered Potential foraging
woodpecker only
Michaux's sumac Rhus michauxii Endangered No
There was a small amount of foraging habitat for red -cockaded woodpecker in the
actively managed pine plantation in the western section of the project area, but no
nesting habitat was present within a half mile and no birds or cavities were observed
during surveys. Furthermore, a report from the NC Natural Heritage Program database
on 3/22/2016 did not identify any occurrences of federally listed species (including Bald
Eagle) recorded within the project area or within 1 -mile of the project area. Therefore, it
is likely this project will have no effect on these species.
No surface water features were observed within the project area and no impacts to fish
or other aquatic organisms are anticipated. Current wildlife utilization is composed of
common species found within southeast North Carolina. The resulting land cover within
the new easement will allow for the continued use of adjacent habitats within the area
for most species and the proposed project is not anticipated to adversely impact wildlife
or their habitat in the area.
4.4 Water Quality Impacts
No storm water management system is necessary for this project as no storm water
run-off is anticipated from the project. To eliminate potential for water quality impacts
during construction, a siltation fence will be installed on either side of the wetland where
20163469 001A RAL16038071 Page 10 April 22, 2016
©2016 Kleinfelder

the gas line is proposed to cross it. Inside the siltation fence, a water bar and trench
plug will be installed to reduce water flow velocity and isolate material in the trench,
respectively.
4.5 Public Interest
No public resources are affected by this proposed project. This project will maintain a
transmission gas pipeline that provides natural gas to local customers. The applicant
has secured easements on all affected properties. There is no public access to the
area for any type of recreational activities.
4.6 Historic and Cultural Resources
No historic or cultural resources were observed within the proposed project area. In
addition, the State Historic Preservation Office's HPOWeb GIS Service website
indicates no documented historic structures within or adjacent to the project area.
4.7 Mitigation Plan
Following construction, the impact area will continue to provide wetland habitat,
although 1.93 acres will be permanently converted from forested to herbaceous habitat.
The project will not cause a long-term alteration to wetland hydrology or water quality.
Therefore, the applicant proposes to mitigate for the 1.93 acre wetland impact at a 1:1
ratio.
Mitigation will be accomplished through the purchase of credits from an off-site
mitigation bank. Stone Farm Regional Mitigation Bank is located in the Lumber River
basin and is currently approved for use in 8 -digit hydrologic unit codes (HUC) 03040206
& 03040207. The project area lies in HUC 03040203. Given that other mitigation banks
are not available in the Lumber River basin, the ACOE has previously approved the use
of Stone Farm for this project. The mitigation acceptance letter is enclosed as Exhibit B.
20163469.001A RAL16038071 Page 11 April 22, 2016
©2016 Kleinfelder

5.0 SUMMARY
Information and materials contained herein are submitted in request to authorize
temporary wetland open -cut impacts and permanent forested wetland conversion
impacts associated with replacing and re-routing Line 33. The total project area
(including permanent easement and temporary workspace) comprises 6.5 acres, of
which 1.93 acres consists of jurisdictional wetlands. Following construction, impacted
uplands will be stabilized and vegetated as shown on the site plans. Mitigation for the
proposed impacts will be accomplished through purchase of credits from an off-site
mitigation bank at a 1:1 ratio.
20163469 001A RAL16038071 Page 12 April 22, 2016
©2016 Kleinfelder

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EXHIBIT A
Preliminary Jurisdictional Determination Form

ATTACHMENT A
PRELIMINARY JURISDICTIONAL DETERMINATION FORM
BACKGROUND INFORMATION
A. REPORT COMPLETION DATE FOR PRELIMINARY JURISDICTIONAL
DETERMINATION (JD):
B. NAME AND ADDRESS OF PERSON REQUESTING PRELIMINARY JD:
Amy James, Kleinfelder Inc
3500 Gateway Centre Dr Suite 200, Morrisville NC 27560
C. DISTRICT OFFICE, FILE NAME, AND NUMBER:
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION:
Piedmont Natural Gas Line 33 replacement (transmission), near intersection of Russell Rd and Lombardy Village Rd, Lumber Bridge NC
(USE THE ATTACHED TABLE TO DOCUMENT MULTIPLE WATERBODIES AT DIFFERENT
SITES)
State: NC County/parish/borough: Robeson City: LumberBridge/Shannon
Center coordinates of site (lat/long in degree decimal format):
Lat. 34858405 ON; Long. -79081934
Universal Transverse Mercator:
Name of nearest waterbody: Big Marsh swamp
&TATA
Identify (estimate) amount of waters in the review area:
Non -wetland waters:
linear feet: width (ft) and/or acres.
Cowardin Class:
Stream Flow:
Wetlands: 1 93 acres.
Cowardin Class: PFo
Name of any water bodies on the site that have been identified as Section 10
waters:
Tidal:
Non -Tidal:
1

E. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT
APPLY):
❑ Office (Desk) Determination. Date:
❑ Field Determination. Date(s):
SUPPORTING DATA. Data reviewed for preliminary JD
(check all that apply - checked items should be included in case file and,
where checked and requested, appropriately reference sources below):
0 Maps, plans, plots or plat submitted by or on behalf of the
applicant/consultant:
❑✓ Data sheets prepared/submitted by or on behalf of the
applicant/consultant.
❑ Office concurs with data sheets/delineation report.
❑ Office does not concur with data sheets/delineation report.
❑ Data sheets prepared by the Corps:
❑ Corps navigable waters' study:
❑ U.S. Geological Survey Hydrologic Atlas:
❑ USGS NHD data
❑ USGS 8 and 12 digit HUC maps
a
U.S. Geological Survey map(s). Cite scale & quad name: 1 24,000, Rennert quad
❑✓ USDA Natural Resources Conservation Service Soil Survey.
Citation: Robeson County, 1978
❑ National wetlands inventory map(s). Cite name:,
❑ State/Local wetland inventory map(s):
❑ FEMA/FIRM maps:
❑ 100 -year Floodplain Elevation is:
(National Geodectic Vertical Datum of 1929)
❑ Photographs: ❑ Aerial (Name & Date): or
❑ Other (Name & Date):
❑ Previous determination(s). File no. and date of response letter:
❑ Other information (please specify):

1. The Corps of Engineers believes that there may be jurisdictional waters of the
United States on the subject site, and the permit applicant or other affected party
who requested this preliminary JD is hereby advised of his or her option to
request and obtain an approved jurisdictional determination (JD) for that site.
Nevertheless, the permit applicant or other person who requested this
preliminary JD has declined to exercise the option to obtain an approved JD in
this instance and at this time.
2. In any circumstance where a permit applicant obtains an individual permit, or
a Nationwide General Permit (NWP) or other general permit verification requiring
"pre -construction notification" (PCN), or requests verification for a non -reporting
NWP or other general permit, and the permit applicant has not requested an
approved JD for the activity, the permit applicant is hereby made aware of the
following: (1) the permit applicant has elected to seek a permit authorization
based on a preliminary JD, which does not make an official determination of
jurisdictional waters; (2) that the applicant has the option to request an approved
JD before accepting the terms and conditions of the permit authorization, and
that basing a permit authorization on an approved JD could possibly result in less
compensatory mitigation being required or different special conditions; (3) that
the applicant has the right to request an individual permit rather than accepting
the terms and conditions of the NWP or other general permit authorization; (4)
that the applicant can accept a permit authorization and thereby agree to comply
with all the terms and conditions of that permit, including whatever mitigation
requirements the Corps has determined to be necessary; (5) that undertaking
any activity in reliance upon the subject permit authorization without requesting
an approved JD constitutes the applicant's acceptance of the use of the
preliminary JD, but that either form of JD will be processed as soon as is
practicable; (6) accepting a permit authorization (e.g., signing a proffered
individual permit) or undertaking any activity in reliance on any form of Corps
permit authorization based on a preliminary JD constitutes agreement that all
wetlands and other water bodies on the site affected in any way by that activity
are jurisdictional waters of the United States, and precludes any challenge to
such jurisdiction in any administrative or judicial compliance or enforcement
action, or in any administrative appeal or in any Federal court; and (7) whether
the applicant elects to use either an approved JD or a preliminary JD, that JD
will be processed as soon as is practicable. Further, an approved JD, a proffered
individual permit (and all terms and conditions contained therein), or individual
permit denial can be administratively appealed pursuant to 33 C.F.R. Part 331,
and that in any administrative appeal, jurisdictional issues can be raised (see 33
C.F.R. 331.5(a)(2)). If, during that administrative appeal, it becomes necessary
to make an official determination whether CWA jurisdiction exists over a site, or
to provide an official delineation of jurisdictional waters on the site, the Corps will
provide an approved JD to accomplish that result, as soon as is practicable.

This preliminary JD finds that there "may be" waters of the United States on the
subject project site, and identifies all aquatic features on the site that could be
affected by the proposed activity, based on the following information:
IMPORTANT NOTE: The information recorded on this form has not
necessarily been verified by the Corps and should not be relied upon for
later jurisdictional determinations.
Signature and date of
Regulatory Project Manager
(REQUIRED)
4
Signature and date of
person requesting preliminary JD
(REQUIRED, unless obtaining
the signature is impracticable)

Site Name
Latitude
Longitude
Estimated Amount of
Class of Aquatic
Aquatic Resource in
Resource
Project Area
Russell Rd.
34.857149
-79.078887
1.93 acres
Non section 10 --
Wetland
wetland

WETLAND DETERMINATION DATA FORM — Atlantic and Gulf Coastal Plain Region
Project/Site Piedmont Natural Gas Line 33 City/County Robeson Sampling Date 3/1/2016
Applicant/Owner Piedmont Natural Gas/Teresa Collins State NC Sampling Point Russel Rd wetland
Investigator(s) Amy James, Kleinfelder Inc Section, Township, Range Lumber Bridge
Landform (hillslope, terrace, etc ) Local relief (concave, convex, none) concave Slope (%) 0
Subregion (LRR or MLRA) LRR P Lat 34 857568 Long -79080834 Datum
Soil Map Unit Name Coxville loam NWI classification PFO
Are climatic / hydrologic conditions on the site typical for this time of years Yes X No (If no, explain in Remarks )
Are Vegetation , Soil or Hydrology significantly disturbed? Are "Normal Circumstances" present? Yes X No
Are Vegetation , Soil or Hydrology naturally problematic? (If needed, explain any answers in Remarks )
SUMMARY OF FINDINGS — Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Yes X No
Is the Sampled Area
Hydric Soil Presents Yes x No
within a Wetland? Yes X No
Wetland Hydrology Present? Yes x No
Remarks
Non -riparian Carolina bay system
HYDROLOGY
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two required)
❑ Surface Soil Cracks (136)
❑ Sparsely Vegetated Concave Surface (138)
Primary Indicators (minimum of one is required check all that apply)
❑
Surface Water (A1) ❑ Aquatic Fauna (1313)
El
High Water Table (A2)
Q Marl Deposits (1315) (LRR U)
❑ Drainage Patterns (610)
IJ
Saturation (A3)
Q Hydrogen Sulfide Odor (C1)
❑ Moss Trim Lines (1316)
--Q
Water Marks (131)
Q Oxidized Rhizospheres along Living Roots (C3)
❑ Dry -Season Water Table (C2)
III
Sediment Deposits (132)
Q Presence of Reduced Iron (C4)
❑ Crayfish Burrows (C8)
_
Drift Deposits (B3)
Q Recent Iron Reduction in Tilled Soils (C6) Jl
Saturation Visible on Aerial Imagery (C9)
LI�.1I
Algal Mat or Crust (134)
❑ Thin Muck Surface (C7)
Q Geomorphic Position (D2)
1.1
Iron Deposits (135)
Other (Explain in Remarks)
❑ Shallow Aquitard (D3)
❑
Inundation Visible on Aerial Imagery
(137)
❑ FAC -Neutral Test (D5)
❑
Water -Stained Leaves (139)
❑ Sphagnum moss (D8) (LRR T, U)
Field Observations:
Surface Water Present? Yes
No X Depth (inches)
Water Table Present? Yes X
No Depth (inches) o
Saturation Present? Yes X
No Depth (inches) o
Wetland Hydrology Present? Yes X No
includes capillary fringe)
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available
Remarks
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

VEGETATION (Four Strata) — Use scientific names of plants.
Sampling Point Russel Rd Wet
Remarks (If observed, list morphological adaptations below)
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region —Version 2 0
Absolute Dominant Indicator
Dominance Test worksheet:
Tree Stratum (Plot size 30 it x 30 it )
% Cover Species? Status
Number of Dominant Species
1 Pinus taeda
40
Y FAC
That Are OBL, FACW, or FAC 6 (A)
2 Liquidambar styraci0ua
30
Y FAC
3 Acer rubrum
15
N FAC
Total Number of Dominant
a
Species Across All Strata (B)
4
Percent of Dominant Species
5
That Are OBL, FACW, or FAC 100 (A1B)
6
7
Prevalence Index worksheet:
8
Total % Cover of Multiply by
85
= Total Cover
OBL species x 1 =
50% of total cover 425
20% of total cover 17
FACW species x 2 =
Sapling/Shrub Stratum (Plot size 30 ft x 30 ft )
FAC species x 3 =
1 Symplocos tinctona
30
Y FAC
FACU species x 4 =
2 Acer rubrum
25
Y FAC
UPL species x 5 =
Column Totals (A) (B)
3 Liqu+dambar styraciflua 10 N FAC
4
Prevalence Index = B/A =
5
Hydrophytic Vegetation Indicators:
6
❑ 1 - Rapid Test for Hydrophytic Vegetation
7
L1 2 - Dominance Test is >50%
8
❑ 3 - Prevalence Index is 53 0'
65
= Total Cover
12 Problematic Hydrophytic Vegetation' (Explain)
50% of total cover 325
20% of total cover 13
Herb Stratum (Plot size 30 ft x 30 ft )
'Indicators of hydric soil and wetland hydrology must
1 Symplocos tinctoria
5
Y FAC
be present, unless disturbed or problematic
2
Definitions of Four Vegetation Strata:
3
Tree — Woody plants, excluding vines, 3 In (7 6 cm) or
4
more in diameter at breast height (DBH), regardless of
5
height
6
Sapling/Shrub — Woody plants, excluding vines, less
7
than 3 in DBH and greater than 3 28 ft (1 m) tall
8
Herb —AII herbaceous (non -woody) plants, regardless
g
of size, and woody plants less than 3 28 ft tall
10.
Woody vine — All woody vines greater than 3 28 ft in
11
height
12
5
= Total Cover
50% of total cover
20% of total cover
Woody Vine Stratum (Plot size 30 ft x 30 ft )
1 Smilax rotunddolia
10
Y FAC
2
3
4
5
Hydrophytic
10
= Total Cover
Vegetation
50% of total cover
20% of total cover
Present? Yes x No
Remarks (If observed, list morphological adaptations below)
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region —Version 2 0

SOIL
Sampling Point Russel Rd Wet
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)
Depth Matrix Redox Features
(inches) Color (moist) % Color (moist) % Type Loc Texture Remarks
0-12 1 OYR 3/1 100 sandy day loam
'Type C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sand Grains
Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)
❑ Histosol (Al)
Hlstic Epipedon (A2)
Black Histic (A3)
❑ Hydrogen Sulfide (A4)
HStratified Layers (A5)
Organic Bodies (A6) (LRR P, T, U)
5 cm Mucky Mineral (A7) (LRR P, T, U)
Muck Presence (A8) (LRR U)
❑ 1 cm Muck (A9) (LRR P, T)
❑ Depleted Below Dark Surface (A11)
❑ Thick Dark Surface (Al2)
Coast Prairie Redox (A16) (MLRA 150A)
Sandy Mucky Mineral (S1) (LRR O, S)
❑ Sandy Gleyed Matrix (S4)
❑Sandy Redox (S5)
Stripped Matrix (S6)
❑ Dark Surface (S7) (LRR P, S, T, U)
Restrictive Layer (if observed):
Type
Depth (inches)
Remarks
Location PL=Pore Lining, M=Matrix
Indicators for Problematic Hydric Soils':
Polyvalue Below Surface (S8) (LRR S, T, U)
❑
1 cm Muck (A9) (LRR O)
Thin Dark Surface (S9) (LRR S, T, U)
EReduced
2 cm Muck (A10) (LRR S)
Loamy Mucky Mineral (F1) (LRR O)
Vertic (F18) (outside MLRA 150A,B)
Loamy Gleyed Matrix (F2)
Piedmont Floodplain Soils (F19) (LRR P, S, T)
Depleted Matrix (F3)
TEl
u
Anomalous Bright Loamy Soils (F20)
Redox Dark Surface (F6)
(MLRA 153B)
Depleted Dark Surface (F7)❑
-I Red Parent Material (TF2)
Redox Depressions (F8)
u Very Shallow Dark Surface (TF 12)
Marl (F10) (LRR U)
Other (Explain In Remarks)
Depleted Ochric (F11) (MLRA 151)
Iron -Manganese Masses (F12) (LRR O, P, T)
3Indicators of hydrophytic vegetation and
Umbric Surface (F13) (LRR P, T, U)
wetland hydrology must be present,
Delta Ochric (F17) (MLRA 151)
unless disturbed or problematic
Reduced Vertic (F18) (MLRA 150A, 1506)
Piedmont Floodplain Soils (F19) (MLRA 149A)
Anomalous Bright Loamy Soils (F20) (MLRA 149A, 153C, 153D)
Hydric Soil Present? Yes X No
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

WETLAND DETERMINATION DATA FORM — Atlantic and Gulf Coastal Plain Region
Project/Site Piedmont Natural Gas Line 33 City/County Robeson Sampling Date 3/1/2016
Applicant/Owner Piedmont Natural Gas/DOT ROW State NC Sampling Point Russel Rd upland
Investigator(s) Amy James, Kleinfelder Inc Section, Township, Range Lumber Bridge
Landform (hillslope, terrace, etc ) Local relief (concave, convex, none) concave (next to road fill slope) Slope (%) 0
Subregion (LRR or MLRA) LRR P Lat 34 858449 Long -79 082048 Datum
Soil Map Unit Name Wagram loamy sand NWI classification
Are climatic / hydrologic conditions on the site typical for this time of year? Yes X No (If no, explain in Remarks )
Are Vegetation Soil or Hydrology significantly disturbed? Are "Normal Circumstances" present? Yes X No
Are Vegetation Soil or Hydrology naturally problematic? (If needed, explain any answers in Remarks )
SUMMARY OF FINDINGS — Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Yes X No Is the Sampled Area
Hydric Soil Present? Yes No x within a Wetland? Yes No X
Wetland Hydrology Present? Yes No x
Remarks,
HYDROLOGY
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two required)
❑ Surface Soil Cracks (136)
❑ Sparsely Vegetated Concave Surface (88)
Primary Indicators (minimum of one is required, check all that apply)
❑ Surface Water (A1) ❑ Aquatic Fauna (1313)
Q High Water Table (A2)
Q Marl Deposits (615) (LRR U)
❑ Drainage Patterns (610)
Q Saturation (A3)
Q Hydrogen Sulfide Odor (Cl)
❑ Moss Trim Lines (1316)
Water Marks (131)
Q Oxidized Rhizospheres along Living Roots (C3)
❑ Dry -Season Water Table (C2)
Ill❑
Sediment Deposits (132)
Q Presence of Reduced Iron (C4)
0 Crayfish Burrows (C8)
Drift Deposits (133)
_II Recent Iron Reduction in Tilled Soils (C6)
II Saturation Visible on Aerial Imagery (C9)
Q� Algal Mat or Crust (134)
❑ Thin Muck Surface (C7)
Q Geomorphic Position (D2)
1.1 Iron Deposits (135)
0 Other (Explain in Remarks)
❑ Shallow Aquitard (D3)
Q Inundation Visible on Aerial Imagery (137)
FAC -Neutral Test (D5)
u Water -Stained Leaves (B9)
1l
Sphagnum moss (D8) (LRR T, U)
Field Observations:
Surface Water Present? Yes
No X Depth (inches)
Water Table Present? Yes
No x Depth (inches)
Saturation Present? Yes
No x Depth (inches)
Wetland Hydrology Present? Yes No X
includes capillary fringe)
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available
Remarks
J
1
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

VEGETATION (Four Strata) — Use scientific names of plants.
Sampling Point Russell Rd upl
Remarks (If observed, list morphological adaptations below)
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0
Absolute Dominant Indicator
Dominance Test worksheet:
Tree Stratum (Plot size 30 It x 30 f< )
% Cover Species? Status
Number of Dominant Species
1 Liqwdambar styraciflua
40
Y FAC
That Are OBL, FACW, or FAC 6 (A)
2 Pinus taeda
10
Y FAC
Total Number of Dominant
3
Species Across All Strata 6 (B)
4
Percent of Dominant Species
5
That Are OBL, FACW, or FAC 100 (A/B)
6
7
Prevalence Index worksheet:
8
Total % Cover of Multiply by
50
= Total Cover
OBL species x 1 =
50% of total cover 25
20% of total cover 10
FACW species x 2 =
Sapling/Shrub Stratum (Plot size 30 ft x 30 ft )
FAC species x 3 =
1 Liguidambar styraciflua
25
Y FAC
FACU species x4=
2 Ligustrum sinense
15
Y FAC
UPL species x 5 =
3 Morella cenfera
5
N FACW
Column Totals (A) (B)
4
Prevalence Index = B/A=
5
Hydrophytic Vegetation Indicators:
6
111 - Rapid Test for Hydrophytic Vegetation
7
g 2 - Dominance Test is >50%
8
a 3 - Prevalence Index is s3 0'
45
= Total Cover
Q Problematic Hydrophytic Vegetation (Explain)
50% of total cover 225
20% of total cover 9
Herb Stratum (Plot size 30 ft x 30 ft )
'Indicators of hydric sod and wetland hydrology must
1 Lomcera japonica
20
Y FAC
be present, unless disturbed or problematic
2
Definitions of Four Vegetation Strata:
3
Tree — Woody plants, excluding vines, 3 in (7 6 cm) or
4
more in diameter at breast height (DBH), regardless of
5
height
6
Sapling/Shrub — Woody plants, excluding vines, less
7
than 3 in DBH and greater than 3 28 ft (1 m) tall
8
Herb — All herbaceous (non -woody) plants, regardless
9
of size, and woody plants less than 3 28 ft tall
10
Woody vine — All woody vines greater than 3 28 ft in
11
height
12
20
= Total Cover
50% of total cover
20% of total cover
Woody Vine Stratum (Plot size 30 ft x 30 ft )
1 Lonicera japonica
10
Y FAC
2
3
4
Hydrophytic
5
10
= Total Cover
Vegetation
50% of total cover
20% of total cover
Present? Yes x No
Remarks (If observed, list morphological adaptations below)
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

SOIL
Sampling Point Russell Rd upl
be to the depth needed to document the indicator or confirm the absence of indicators.)
Depth Matrix Redox Features
(inches) Color (moist) % Color (moist) % Type' Loc Texture Remarks
0-12+ 10YR 3/1 100 loamy sand 50% coated
'Type C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sa
Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)
❑ Histosol (A1)
Histic Epipedon (A2)
Black Histic (A3)
Hydrogen Sulfide (A4)
HStratified Layers (A5)
Organic Bodies (A6) (LRR P, T, U)
H5 cm Mucky Mineral (A7) (LRR P, T, U)
Muck Presence (A8) (LRR U)
1 cm Muck (A9) (LRR P, T)
❑ Depleted Below Dark Surface (Al 1)
❑ Thick Dark Surface (Al 2)
Coast Prairie Redox (A16) (MLRA 150A)
Sandy Mucky Mineral (S1) (LRR 0, S)
❑ Sandy Gleyed Matrix (S4)
Sandy Redox (S5)
D Stripped Matrix (S6)
❑ Dark Surface (S7) (LRR P, S, T, U)
Restrictive Layer (if observed):
Type
Depth (inches)
2Location PL=Pare Lining, M=Matrix
Indicators for Problematic Hydric Soils':
Polyvalue Below Surface (S8) (LRR S, T, U) ❑ 1 cm Muck (A9) (LRR 0)
Thin Dark Surface (S9) (LRR S, T, U) 11 2 cm Muck (A10) (LRR S)
Loamy Mucky Mineral (F1) (LRR 0)
Reduced Vertic (F18) (outside MLRA 150A,B)
Loamy Gleyed Matrix (F2)
�U-I
Piedmont Floodplain Soils (F19) (LRR P, S, T)
Depleted Matrix (F3)
Tu'I
u
Anomalous Bright Loamy Soils (F20)
Redox Dark Surface (F6)
(MLRA 153B)
Depleted Dark Surface (F7)Red
Parent Material (TF2)
Redox Depressions (F8)
U Very Shallow Dark Surface (TF 12)
Marl (F10) (LRR U)
D Other (Explain in Remarks)
Depleted Ochric (F11) (MLRA 151)
Iron -Manganese Masses (F12) (LRR 0, P, T)
3Indicators of hydrophytic vegetation and
Umbric Surface (F13) (LRR P, T, U)
wetland hydrology must be present,
Delta Ochric (F17) (MLRA 151)
unless disturbed or problematic
Reduced Vertic (F18) (MLRA 150A, 150B)
Piedmont Floodplain Soils (F19) (MLRA 149A)
Anomalous Bright Loamy Soils (F20) (MLRA 149A, 153C, 153D)
Hydric Soil Present? Yes No X
US Army Corps of Engineers Atlantic and Gulf Coastal Plain Region — Version 2 0

EXHIBIT B
Stone Farm Mitigation Bank
Credit Request Acceptance Letter

STONE FARM REGIONAL MITIGATION BANK
CREDIT REQUEST ACCEPTANCE
Date: March 28, 2016
Piedmont Natural Gas
4720 Piedmont Row Dr.
Charlotte, NC 38210
Project Name: Line 33 Replacement (Transmission IP)
Expiration of Acceptance: September 28, 2016
SFMB Number:
Dear: Mr Dietrich
DRAFT
Stone Farm Mitigation Bank, LLC
11 Causeway Drive
Ocean Isle Beach, NC 28469
The purpose of this letter is to notify you that the Stone Farm Regional Mitigation Bank (Bank) is willing to
accept payment for impacts associated with the above referenced project Please note that this decision
does not assure that the payment will be approved by the permit issuing agencies as mitigation for project
impacts. It is the responsibility of the applicant to contact these agencies to determine if payment to the
Bank will be approved. It is also the responsibility of the applicant to determine the appropriate credit ratios
that will be required for the corresponding wetland and/or stream impacts You must also comply with all
other state, federal or local government permits, regulations or authorizations associated with the proposed
activity
This acceptance is valid for six (6) months from the date of this letter and is not transferable. If we have not
received payment for the accepted credits of the issued 404 Permit/401 Certification/LAMA permit
within this time frame, this acceptance will expire. Predicated on the total payment due to the Bank, as
set forth herein, a ten (10) percent non-refundable deposit is due at the time of acceptance by the Bank It is
the applicant's responsibility to send copies of their permits to the Bank Once the Bank receives a copy of
the permit(s), an invoice will be issued based on the information identified below. Payment must be made
prior to conducting the authorized work It is the applicant's responsibility to ensure that the credit types and
amounts identified below are consistent with the compensatory mitigation requirements of the permit(s)
issued. The Bank and/or its agents are not responsible for determining the applicant's mitigation
requirements.
Based on the information supplied by the applicant, the impacts that may require compensatory mitigation
are summarized in the following table:
Note that the impact and credit totals above were provided by the applicant It is the applicant's
responsibility to provide accurate information (including the requested mitigation credits). The Bank and/or
its agents are not responsible for determining the required credit amounts The Bank's decision to accept
credits is based upon the information provided by the applicant. The Bank is not liable for any credit
shortage should the applicant's required mitigation credits exceed the amount specified in the above table
Based upon the type and amounts of credits requested above, the following payment must be provided to
the Bank prior to issuance of credits.
CU Location
Stream (ft.)
Wetlands ac.)
Non-ri anan
Ri anan
Impact
03040203
286
Credits
2.90
Note that the impact and credit totals above were provided by the applicant It is the applicant's
responsibility to provide accurate information (including the requested mitigation credits). The Bank and/or
its agents are not responsible for determining the required credit amounts The Bank's decision to accept
credits is based upon the information provided by the applicant. The Bank is not liable for any credit
shortage should the applicant's required mitigation credits exceed the amount specified in the above table
Based upon the type and amounts of credits requested above, the following payment must be provided to
the Bank prior to issuance of credits.

Credit Type Unit Per Unit Credit Fee
Sub -Total
Stream 0 $29600
$000
Nonriparian Wetland 2.9 $26,41800
$76,61220
Riparian Wetland 0 $40,256.00
$0.00
Total Payment Due
Non-refundable Deposit
Balance Due Upon Invoice
$76,612.20
$7,661.22
$68,950.98
Upon receipt of full payment, the Bank will take responsibility for providing the compensatory mitigation. If
the regulatory agencies require mitigation credits greater than indicated above, and should the applicant
want the Bank to provide such credits, it is the applicant's responsibility to submit an additional credit
request form to the Bank.
If you have any questions or need additional information, please contact Paula Buis at 910-579-7300 or
pbuis@ladane com.
Sincerely,
aa.
Paula Buis
Stone Farm Mitigation Bank, LLC
cc: NCDWQ-Raleigh
USACE
NCDWQ-Local
Agent

EXHIBIT C
Land Owner Information

Line 33 3" line replacement landowners for individual permit.
Robeson County PIN
Owner
Deed
Mailing Address
Book/Page
947055554300
William Mast
787/303
1910 Ross Mill Rd
Henderson, NC 27536
Jeremy and Eden
1274 Lombardy Village
947053424000"
Locklear
1126/777
Rd., Shannon,
NC 28386
947052835500*
Teresa Collins et al.
710/345
PO BOX 387
Shannon, NC 28386
947072435400
Mark Locklear
1116/874
10142 Rennert Rd
Shannon, NC 28386
Jasper and John
261 Ireland Dr.
947072508400
Gray
1193/206
Lumber Bridge, NC
28357
*indicates jurisdictional impact on property