20200456 Ver 1_401 Application_20200402

Staff Review
Does this application have all the attachments needed to accept it into the review process?
r Yes r No
ID#*
20200456
Version* 1
Is this project a public transportation project?* r Yes
r No
Reviewer List:* Stephanie Goss: eads\szgoss
Select Reviewing Office:* Raleigh Regional Office - [phone]
Submittal Type:*
401 Application
Does this project require a request for payment to be sent?*
r
Yes
r
No
How much is r $240.00
owed?* r $570.00

Project Submittal Form
Please note: fields marked with a red asterisk below are required. You will not be able to submit the form until all
mandatory questions are answered.
Project Type: r
New Project
r
New Project w Existing ID
r
Pre -Application Submittal
r
More Information Response
r
Other Agency Comments
r
For the Record Only (Courtesy Copy)
r
Stream or Buffer Appeal
New Project - Please check the new project type if you are trying to submit a new project that needs an official approval
decision.
Pre -Application Submittal - Please check the pre -application submittal if you just want feedback on your submittal and
do not have the expectation that your submittal will be considered a complete application requiring a formal decision.
More Information Response - Please check this type if you are responding to a request for information from staff and
you have and ID# and version for this response.
Other Agency Comments - Please check this if you are submitting comments on an existing project.
Project Contact Information
Name: Brad Luckey
VUio is submitting the inforrration?
Email Address: [e-mail]
Project Information
Project Name: Grissom Solar Farm
Is this a public transportation project?
r Yes
r No
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
r Yes r No r Unknown
County (ies)
Halifax
Please upload all files that need to be submited.
aick the upload button or drag and drop files here to attach document
Grissom_PCN 04-02-20.pdf 8.84MB
Only pdf or Iv17 files are accepted.
Describe the attachments:
Request for 401 WQC, Grissom Solar Farm, Halifax County. NC
Sign and Submit
V Bychecking the boxand signing box below, I certifythat:

• I have given true, accurate, and complete information on this form;
• I agree that submission of this form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the
"Uniform Electronic Transactions Act")
• I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes
(the "Uniform Electronic Transactions Act');
• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written
signature; AND
• I intend to electronically sign and submit the online form."
Signature:
rr1
Submittal Date: Is filled in &Ao ratically.

Preliminary ORM Data Entry Fields for New Actions
ACTION ID #: SAW- 2019-00780
Prepare file folder ❑
1. Project Name [PCN Form A2a]: Grissom Solar Farm
Begin Date (Date Received):
Assign Action ID Number in ORM ❑
2. Work Type: Private ❑Institutional ❑Government ❑Commercial
3. Project Description / Purpose [PCN Form 133d and 133e]:
Attached.
4. Property Owner / Applicant [PCN Form A3 or A41: Attached
5. Agent / Consultant [PNC Form A5 — or ORM Consultant ID Number]:
Attached
6. Related Action ID Number(s) [PCN Form 135b]:
7. Project Location — Coordinates, Street Address, and/or Location Description [PCN Form B lb]:
Attached
8. Project Location —Tax Parcel ID [PCN Form Bla]: Attached
9. Project Location — County [PCN Form A2b]: Halifax
10. Project Location — Nearest Municipality or Town [PCN Form A2c]: Brinkleyville
11. Project Information — Nearest Waterbody [PCN Form 132a]: Rocky Swamp
12. Watershed / 8-Digit Hydrologic Unit Code [PCN Form 132c]: 03020102
Authorization: Section 10 ❑ Section 404 ❑✓
Regulatory Action Type:
❑ Standard Permit
✓❑ Nationwide Permit #
❑ Regional General Permit #
❑ Jurisdictional Determination Request
Section 10 and 404 ❑
❑Pre -Application Request
❑ Unauthorized Activity
❑ Compliance
❑ No Permit Required
Revised 20150602

Office Use Only:
Corps action ID no.
DWQ project no.
Form Version 1.3 Dec 10 2008
Pre -Construction Notification PCN Form
A. Applicant Information
1.
Processing
1 a.
Type(s) of approval sought from the
Corps:
®Section 404 Permit El Section 10 Permit
1 b.
Specify Nationwide Permit (NWP) number: NWP 14 or General Permit (GP) number:
1c.
Has the NWP or GP number been verified by the Corps?
❑ Yes
® No
1d.
Type(s) of approval sought from the DWQ (check all that apply):
N 401 Water Quality Certification — Regular ❑ Non-404 Jurisdictional General Permit
❑ 401 Water Quality Certification — Express ❑ Riparian Buffer Authorization
1 e.
Is this notification solely for the record
because written approval is not required?
For the record only for DWQ 401
Certification:
❑ Yes ® No
For the record only for Corps Permit:
❑ Yes N No
1f.
Is payment into a mitigation bank or in -lieu fee program proposed for mitigation
of impacts? If so, attach the acceptance letter from mitigation bank or in -lieu
fee program.
❑ Yes
® No
1g.
Is the project located in any of NC's twenty coastal counties. If yes, answer 1 h
below.
❑ Yes
® No
1 h.
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
❑ Yes
® No
2.
Project Information
2a.
Name of project:
Grissom Solar Farm
2b.
County:
Halifax
2c.
Nearest municipality / town:
Brinkleyville
2d.
Subdivision name:
2e.
NCDOT only, T.I.P. or state
project no:
3.
Owner Information
3a.
Name(s) on Recorded Deed:
Robert N. Whitaker / Christopher W. Barnwell
3b.
Deed Book and Page No.
81-E/430, 1354/146, 12 &105 / 1809/336
3c.
Responsible Party (for LLC if
applicable):
N/A
3d.
Street address:
3281 Loop Road / PO Box 557
3e.
City, state, zip:
Enfield, NC 27823 / Halifax, NC 27839
3f.
Telephone no.:
3g.
Fax no.:
3h.
Email address:
Page 1 of 11
PCN Form — Version 1.3 December 10, 2008 Version

4.
Applicant Information (if different from owner)
4a.
Applicant is:
❑ Agent ® Other, specify: Developer
4b.
Name:
Ms. Jess Ingram
4c.
Business name
(if applicable):
Grissom Solar, LLC
4d.
Street address:
3402 Pico Boulevard, Suite 300
4e.
City, state, zip:
Santa Monica, CA 90405
4f.
Telephone no.:
919-900-0367
4g.
Fax no.:
4h.
Email address:
[e-mail]
5.
Agent/Consultant Information (if applicable)
5a.
Name:
Bradley S. Luckey
5b.
Business name
(if applicable):
Pilot Environmental Inc.
5c.
Street address:
PO Box 128
5d.
City, state, zip:
Kernersville, NC 27285
5e.
Telephone no.:
336.708.4997
5f.
Fax no.:
5g.
Email address:
[e-mail]
Page 2 of 11
PCN Form — Version 1.3 December 10, 2008 Version

B. Project Information and Prior Project History
1. Property Identification
1a. Property identification no. (tax PIN or parcel ID):
0101698 / 0100711
1 b. Site coordinates (in decimal degrees):
Latitude: 36.23972 Longitude: - 77.83875
(DD.DDDDDD) (-DD.DDDDDD)
1c. Property size:
103 acres
2. Surface Waters
2a. Name of nearest body of water (stream, river, etc.) to
Rocky Swamp
proposed project:
2b. Water Quality Classification of nearest receiving water:
WS-IV, NSW
2c. River basin:
Tar -Pamlico
3. Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
The site contains undeveloped wooded land and agricultural fields. Structures are not located on the site. The site is
located in a residential/rural area of Halifax County, North Carolina.
3b. List the total estimated acreage of all existing wetlands on the property:
—3.98 ac
3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property:
Open Water Pond = —1.5 ac. Perennial Streams =—1,475'
3d. Explain the purpose of the proposed project:
The purpose of the proposed project is to provide road access and electrical interconnection during development and
long term maintenance of the site as a solar farm.
3e. Describe the overall project in detail, including the type of equipment to be used:
The overall project consists of development of the site with a proposed solar farm. In order to provide safe access and
interconnection of the site, improvements and a culvert replacement at an existing crossing are necessary. To facilitate
development of the site and access road improvements, clearing the site is necessary. Graders, haulers, excavators and
other heavy equipment will be used during site construction.
4. Jurisdictional Determinations
4a. Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /
® Yes ❑ No ❑ Unknown
project (including all prior phases) in the past?
Comments:
4b. If the Corps made the jurisdictional determination, what type
®Preliminary El Final
of determination was made?
4c. If yes, who delineated the jurisdictional areas?
Agency/Consultant Company: Pilot Environmental, Inc.
Name (if known): Michael Brame/David Brame
Other:
4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation.
SAW-2019-00780 dated 3.6.20
5. Project History
5a. Have permits or certifications been requested or obtained for
❑ Yes ❑ No ® Unknown
this project (including all prior phases) in the past?
5b. If yes, explain in detail according to "help file" instructions.
Page 3 of 11
PCN Form — Version 1.3 December 10, 2008 Version

6. Future Project Plans
6a. Is this a phased project? ❑ Yes ® No
6b. If yes, explain.
Page 4 of 11
PCN Form — Version 1.3 December 10, 2008 Version

C. Proposed Impacts Inventory
1. Impacts Summary
1a. Which sections were completed below for your project (check all that apply):
❑ Wetlands ® Streams - tributaries ❑ Buffers
® Open Waters ❑ Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a.
2b.
2c.
2d.
2e.
2f.
Wetland impact
Type of jurisdiction
number—
Type of impact
Type of wetland
Forested
(Corps - 404, 10
Area of impact
Permanent (P) or
(if known)
DWQ — non-404, other)
(acres)
Temporary T
W1 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W2 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W3 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W4 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W5 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W6 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
2g. Total wetland impacts
2h. Comments: Wetland impacts are not proposed.
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a.
3b.
3c.
3d.
3e.
3f.
3g.
Stream impact
Type of impact
Stream name
Perennial
Type of jurisdiction
Average
Impact
number -
(PER) or
(Corps - 404, 10
stream
length
Permanent (P) or
intermittent
DWQ — non-404,
width
(linear
Temporary (T)
(INT)?
other)
(feet)
feet)
S1 ®P ®T
Culvert Fill/De-
watering
Unnamed
® PER
❑INT
® Corps
❑ DWQ
12
13/20
S2 ❑ P ❑ T
❑ PER
❑ Corps
❑ INT
❑ DWQ
S3 ❑ P ❑ T
❑ PER
❑ Corps
❑ INT
❑ DWQ
S4 ❑ P ❑ T
❑ PER
❑ Corps
❑ INT
❑ DWQ
S5 ❑ P ❑ T
❑ PER
❑ Corps
❑ INT
❑ DWQ
S6 ❑ P ❑ T
❑ PER
❑ Corps
❑ INT
❑ DWQ
3h. Total stream and tributary impacts
13/20
3i. Comments: The proposed culvert replacement will permanently impact 13 linear feet of stream channel with
culvert/sideslope fill and temporarily impact 20 linear feet of stream channel with de -watering measures. Following culvert
installation, temporary fills will be removed and the stream channel bed and banks will be restored to pre -construction grade
and live -staked or planted with native vegetation.
Page 5 of 11
PCN Form — Version 1.3 December 10, 2008 Version

4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U.S. then individually list all open water impacts below.
4a.
4b.
4c.
4d.
4e.
Open water
Name of waterbody
impact number —
(if applicable)
Type of impact
Waterbody type
Area of impact (acres)
Permanent (P) or
Temporary T
01 ❑ P ®T
Unnamed
De -Watering
Pond
0.001 (60SF)
02 ❑P❑T
03 ❑P❑T
04 ❑P❑T
4f. Total open water impacts
0.001 (60SF)
4g. Comments: The proposed culvert replacement will temporarily impact 0.001 ac of open water pond with de -watering
measures. Following completion of the culvert replacement, areas of temporary impact will be restored to pre -construction
grade.
5. Pond or Lake Construction
If pond or lake construction proposed, then complete the chart below.
5a.
5b.
5c.
5d.
5e.
Wetland Impacts (acres)
Stream Impacts (feet)
Upland
Pond ID
Proposed use or purpose
(acres)
number
of pond
Flooded
Filled
Excavated
Flooded
Filled
Excavated
Flooded
P1
P2
5f. Total
5g. Comments: Construction of ponds/lakes are not proposed.
5h. Is a dam high hazard permit required?
❑ Yes ®No If yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
Page 6 of 11
PCN Form — Version 1.3 December 10, 2008 Version

6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If any impacts require mitigation, then you MUST fill out Section D of this form.
6a.
❑ Neuse ® Tar -Pamlico ❑ Other:
Project is in which protected basin?
❑ Catawba ❑ Randleman
6b.
6c.
6d.
6e.
6f.
6g.
Buffer impact
number—
Reason
Buffer
Zone 1 impact
Zone 2 impact
Permanent (P) or
for
Stream name
mitigation
(square feet)
(square feet)
Temporary T
impact
re uired?
B1 ❑P❑T
El Yes
❑ No
B2 ❑P❑T
El Yes
❑ No
B3 ❑P❑T
El Yes
❑ No
6h. Total buffer impacts
6i. Comments: The access road improvements will disturb less than 40 linear feet of riparian buffer and is exempt. Buffer
impacts requiring authorization are not proposed.
D. Impact Justification and Mitigation
1. Avoidance and Minimization
1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
Due to the development and use of the site as a solar farm, an existing road must be improved to provide access to the site
during construction and long term maintenance of the site as a solar farm. Alternate access options from Medoc Mountain
Road would impact more WoUS. Therefore, applicant selected improving an existing stream/buffer crossing instead of
installation of a new crossing. The road width has been designed to the minimal width necessary to safely accommodate
heavy equipment, tractor trailers, emergency personnel and other vehicles for the construction, operation and maintenance of
the proposed project.
The solar array and necessary infrastructure (overhead/underground voltage lines, inverters, etc.) have been designed to
avoid impacts to jurisdictional streams, wetlands and ponds.
Approximately 3.98 acres of wetlands, 1.5 acres of open water pond and 1,442 linear feet of stream channel are being
avoided.
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
The impact limits will be staked in the field. The normal elevation of the pond will be lowered to allow culvert replacement to
occur in the dry. A sandbag coffer dam and temporary rock checks will be installed around the culvert footprint. Appropriate
bank protection will be provided in the channel during construction and all excess excavated material will be immediately
removed from the crossing area. Upon completion of the culvert replacement, the temporary sand bag coffer dam and
temporary rock check will be removed and flow will be diverted through the culvert. Following construction, disturbed banks
will be restored to similar pre -construction conditions, matted and seeded/live staked.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for
❑ Yes ® No
impacts to Waters of the U.S. or Waters of the State?
2b. If yes, mitigation is required by (check all that apply):
❑ DWQ ❑ Corps
❑ Mitigation bank
2c. If yes, which mitigation option will be used for this
El Payment to in -lieu fee program
project?
❑ Permittee Responsible Mitigation
Page 7 of 11
PCN Form — Version 1.3 December 10, 2008 Version

3.
Complete if Using a Mitigation Bank
3a.
Name of Mitigation Bank:
3b.
Credits Purchased (attach receipt and letter)
Type
Quantity
3c. Comments:
4.
Complete if Making a Payment to In -lieu Fee Program
4a. Approval letter from in -lieu fee program is attached.
❑ Yes
4b.
Stream mitigation requested:
linear feet
4c.
If using stream mitigation, stream temperature:
❑ warm ❑ cool ❑cold
4d.
Buffer mitigation requested (DWQ only):
square feet
4e.
Riparian wetland mitigation requested:
acres
4f.
Non -riparian wetland mitigation requested:
acres
4g.
Coastal (tidal) wetland mitigation requested:
acres
4h.
Comments:
5.
Complete if Using a Permittee Responsible Mitigation Plan
5a.
If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
6.
Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWQ
6a. Will the project result in an impact within a protected riparian buffer that requires
buffer mitigation?
❑ Yes ® No
6b.
If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.
Zone
6c.
Reason for impact
6d.
Total impact
(square feet)
Multiplier
6e.
Required mitigation
(square feet)
Zone 1
3 (2 for Catawba)
Zone 2
1.5
6f. Total buffer mitigation required:
6g.
If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in -lieu fee fund).
6h.
Comments:
Page 8 of 11
PCN Form — Version 1.3 December 10, 2008 Version

E.
Stormwater Management and Diffuse Flow Plan (required by DWQ)
1.
Diffuse Flow Plan
1 a.
Does the project include or is it adjacent to protected riparian buffers identified
® Yes ❑ No
within one of the NC Riparian Buffer Protection Rules?
1 b.
If yes, then is a diffuse flow plan included? If no, explain why.
❑ Yes ❑ No
Comments: Concentrated flow is not being discharged into the buffers.
2.
Stormwater Management Plan
2a.
What is the overall percent imperviousness of this project?
<10 %
2b.
Does this project require a Stormwater Management Plan?
❑ Yes ® No
2c.
If this project DOES NOT require a Stormwater Management Plan, explain why: Based on the % impervious, a
stormwater management plan is not requried.
2d.
If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan:
® Certified Local Government
2e.
Who will be responsible for the review of the Stormwater Management Plan?
❑ DWQ Stormwater Program
❑ DWQ 401 Unit
3.
Certified Local Government Stormwater Review
3a.
In which local government's jurisdiction is this project?
❑ Phase II
® NSW
3b.
Which of the following locally -implemented stormwater management programs
❑ USMP
apply (check all that apply):
® Water Supply Watershed
❑ Other:
3c.
Has the approved Stormwater Management Plan with proof of approval been
❑ Yes ® No
attached?
4.
DWQ Stormwater Program Review
❑ Coastal counties
❑ HQW
4a.
Which of the following state -implemented stormwater management programs apply
❑ ORW
(check all that apply):
❑ Session Law 2006-246
❑ Other:
4b.
Has the approved Stormwater Management Plan with proof of approval been
attached?
❑ Yes ® No
5.
DWQ 401 Unit Stormwater Review
5a.
Does the Stormwater Management Plan meet the appropriate requirements?
❑ Yes ❑ No
5b.
Have all of the 401 Unit submittal requirements been met?
❑ Yes ❑ No
Page 9 of 11
PCN Form — Version 1.3 December 10, 2008 Version

F.
Supplementary Information
1.
Environmental Documentation (DWQ Requirement)
1 a.
Does the project involve an expenditure of public (federal/state/local) funds or the
❑ Yes
® No
use of public (federal/state) land?
1 b.
If you answered "yes" to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State
❑ Yes
® No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1c.
If you answered "yes" to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
❑ Yes
® No
letter.)
Comments: We are not aware of a NEPA or SEPA being requried.
2.
Violations (DWQ Requirement)
2a.
Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards,
❑ Yes
® No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b.
Is this an after -the -fact permit application?
❑ Yes
® No
2c.
If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s):
3.
Cumulative Impacts (DWQ Requirement)
3a.
Will this project (based on past and reasonably anticipated future impacts) result in
❑ Yes
® No
additional development, which could impact nearby downstream water quality?
3b.
If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
We are not aware of additional development that will impact nearby downstream water quality.
4.
Sewage Disposal (DWQ Requirement)
4a.
Clearly detail the ultimate treatment methods and disposition (non -discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
Wastewater will not be generated by the proposed project.
Page 10 of 11
PCN Form — Version 1.3 December 10, 2008 Version

5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or
❑ Yes ® No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act
® Yes ❑ No
impacts?
® Raleigh
5c. If yes, indicate the USFWS Field Office you have contacted.
❑ Asheville
5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
USFWS reviewed the project and issued comments dated 7/11/19 (attached).
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat?
❑ Yes ® No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
Based on our knowledge of the site, the site is not located in or near an area designated as essential fish habitat. Best
management practices and the use of temporary sediment and erosion control devices will prevent sediment from entering
down -gradient waterbodies which may contain fish.
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation
❑ Yes ® No
status (e.g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
The applicant completed and submitted a cultural resources assessment in December, 2019. According to a December
21, 2019 letter from the NCSHPO (attached), significant cultural resources will not be adversely affected by the proposed
project.
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA-designated 100-year floodplain?
❑ Yes ® No
8b. If yes, explain how project meets FEMA requirements:
8c. What source(s) did you use to make the floodplain determination? FEMA FIRM 372039400J (Drawing 4)
% Digitally signed by Bradley S. Luckey
/ DN: cn=Bradley S. Luckey, o=Pilot
bra Enviromental,Inc.,ou,
a
Bradley S. Luckey
email=[e-mail],c=US
4.2.19
Date: 2020.04.02 13:56:52 -04'00'
Applicant/Agent's Printed Name
Date
Applicant/Agent's Signature
(Agent's signature is valid only if an authorization letter from the applicant
isprovided.)
Page 11 of 11
PCN Form — Version 1.3 December 10, 2008 Version

DocuSign Envelope ID: 34E8E852-7CF5-4B9B-9E6C-926745445563
AGENT AUTHORIZATION
This form authorizes PEI to act as our agent in stream/wetland matters including U.S. Army Corps
of Engineers and North Carolina Division of Water Resources field verification and permitting.
Property Address
Applicant Information:
Name:
Address:
Telephone Number:
Fax Number:
E-mail Address
1987 Medoc Mountain Road
Enfield, NC 27823
Grissom Solar, LLC
3402 Pico Blvd., Suite 300
Santa Monica, CA 90405
919-900-0367
[e-mail]
DocuSigned by:
C9307QE56A8QD4Q2
ISS U7l raAA 3/15/2020
Signature:__Date:

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U.S. ARMY CORPS OF ENGINEERS
WILMINGTON DISTRICT
Action Id. SAW-2019-00780 County: HALIFAX U.S.G.S. Quad: RINGWOOD
NOTIFICATION OF JURISDICTIONAL DETERNIINATION
Property Owner/Applicant: Mr. Robert Whitaker
Address: 3281 Loop Road
Enfield, North Carolina 27823
Authorized Agent: Pilot Environmental, Inc.
Mr. Michael Brame
Address: Post Office Box 128
Kernersville, North Carolina 27285
Size (acres) —103 Nearest Town Brinkleyville
Nearest Waterway Rocky Swamp River Basin Tar River
USGS HUC 03020102 Coordinates Latitude: 36.239721
Longitude:-77.838747
Location description: The project area is identified as an approximate 103 acre tract of land, located on Halifax
County, North Carolina Parcel 0101698. This parcel is southwest of the intersection of Medoc Mountain Road and NC
HWY 4, near Brinkleyville, Halifax County, North Carolina.
Indicate Which of the Following Apply:
A. Preliminary Determination
X There are waters, including wetlands, on the above described project area, that may be subject to Section 404 of the
Clean Water Act (CWA)(33 USC § 1344) and/or Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403). The
waters, including wetlands, have been delineated, and the delineation has been verified by the Corps to be sufficiently
accurate and reliable. Therefore this preliminary jurisdiction determination may be used in the permit evaluation process,
including determining compensatory mitigation. For purposes of computation of impacts, compensatory mitigation
requirements, and other resource protection measures, a permit decision made on the basis of a preliminary JD will treat all
waters and wetlands that would be affected in any way by the permitted activity on the site as if they are jurisdictional
waters of the U.S. This preliminary determination is not an appealable action under the Regulatory Program
Administrative Appeal Process (Reference 33 CFR Part 331). However, you may request an approved JD, which is an
appealable action, by contacting the Corps district for further instruction.
_ There are wetlands on the above described property, that may be subject to Section 404 of the Clean Water Act
(CWA)(33 USC § 1344) and/or Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403). However, since the
waters, including wetlands, have not been properly delineated, this preliminary jurisdiction determination may not be
used in the permit evaluation process. Without a verified wetland delineation, this preliminary determination is merely an
effective presumption of CWA/RHA jurisdiction overall of the waters, including wetlands, at the project area, which is
not sufficiently accurate and reliable to support an enforceable permit decision. We recommend that you have the
waters of the U.S. on your property delineated. As the Corps may not be able to accomplish this wetland delineation in a
timely manner, you may wish to obtain a consultant to conduct a delineation that can be verified by the Corps.
B. Approved Determination
_ There are Navigable Waters of the United States within the above described property subject to the permit requirements of
Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403) and Section 404 of the Clean Water Act (CWA)(33 USC
§ 1344). Unless there is a change in law or our published regulations, this determination may be relied upon for a period
not to exceed five years from the date of this notification.
Page 1 of 2

SAW-2019-00780 Grissom Solar
_ There are waters of the U.S., including wetlands, on the above described project area subject to the permit requirements
of Section 404 of the Clean Water Act (CWA) (33 USC § 1344). Unless there is a change in the law or our published
regulations, this determination may be relied upon for a period not to exceed five years from the date of this notification.
_ We recommend you have the waters of the U.S. on your property delineated. As the Corps may not be able to
accomplish this wetland delineation in a timely manner, you may wish to obtain a consultant to conduct a delineation that
can be verified by the Corps.
_ The waters of the U.S., including wetlands, on your project area have been delineated and the delineation has been
verified by the Corps. We strongly suggest you have this delineation surveyed. Upon completion, this survey should be
reviewed and verified by the Corps. Once verified, this survey will provide an accurate depiction of all areas subject to
CWA jurisdiction on your property which, provided there is no change in the law or our published regulations, may be
relied upon for a period not to exceed five years.
_ The waters of the U.S., including wetlands, have been delineated and surveyed and are accurately depicted on the plat
signed by the Corps Regulatory Official identified below on . Unless there is a change in the law or our
published regulations, this determination may be relied upon for a period not to exceed five years from the date of this
notification.
_ There are no waters of the U.S., to include wetlands, present on the above described project area which are subject to the
permit requirements of Section 404 of the Clean Water Act (33 USC 1344). Unless there is a change in the law or our
published regulations, this determination may be relied upon for a period not to exceed five years from the date of this
notification.
_ The property is located in one of the 20 Coastal Counties subject to regulation under the Coastal Area Management Act
(CAMA). You should contact the Division of Coastal Management in Morehead City, NC, at [phone] to
determine their requirements.
Placement of dredged or fill material within waters of the US, including wetlands, without a Department of the Army permit
may constitute a violation of Section 301 of the Clean Water Act (33 USC § 1311). Placement of dredged or fill material,
construction or placement of structures, or work within navigable waters of the United States without a Department of the
Army permit may constitute a violation of Sections 9 and/or 10 of the Rivers and Harbors Act (33 USC § 401 and/or 403). If
you have any questions regarding this determination and/or the Corps regulatory program, please contact Ms. Samantha
Dailey at 919-554-4884, ext. 22 or by email at Samantha.J.Daileynusace.army.mil.
C. Basis For Determination: N/A. An Approved JD has not been completed.
D. Remarks: Refer to the enclosed Preliminary JD Form and Drawing 5-Wetland Map dated
07/01/19 for a detailed evaluation of the aquatic resources on -site.
E. Attention USDA Program Participants
This delineation/determination has been conducted to identify the limits of Corps' Clean Water Act jurisdiction for the
particular site identified in this request. The delineation/determination may not be valid for the wetland conservation
provisions of the Food Security Act of 1985. If you or your tenant are USDA Program participants, or anticipate participation
in USDA programs, you should request a certified wetland determination from the local office of the Natural Resources
Conservation Service, prior to starting work.
F. Appeals Information for Approved Jurisdiction Determinations (as indicated in Section B. above)
If you object to this determination, you may request an administrative appeal under Corps regulations at 33 CFR Part 331.
Enclosed you will find a Notification of Appeal Process (NAP) fact sheet and Request for Appeal (RFA) form. If you request
to appeal this determination you must submit a completed RFA form to the following address:
US Army Corps of Engineers
South Atlantic Division
Attn: Jason Steele, Review Officer
60 Forsyth Street SW, Room 10M15
Atlanta, Georgia 30303-8801

SAW-2019-00780 Grissom Solar
In order for an RFA to be accepted by the Corps, the Corps must determine that it is complete, that it meets the criteria for
appeal under 33 CFR part 331.5, and that it has been received by the Division Office within 60 days of the date of the NAP.
Should you decide to submit an RFA form, it must be received at the above address by
It is not necessary to submit an RFA form to the Division Office if you do not object to the determination in this
correspondence. DAI LEY.SAMANTHA. g ysignedy
Di stall b
DAI LEY.SAMANTHA.J.1387567948
Corps Regulatory Official:
Date: March 6, 2020
J.1387567948
Expiration Date: N/A
Date: 2020.03.06 07:38:10-05'00'
The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete our Customer Satisfaction Survey, located online at
hllp://corpsmilpu.usace.army.mil/cm_apex/Pp=136:4:0.

SAW-2019-00780 Grissom Solar
PWMNGTIFICATION OF ADNHNISTRATIVE APPEAL OPTIONS AND PROCESS AND
REQUEST FOR APPEAL
Applicant: Mr. Robert Whitaker File Number: SAW-2019-00780
Date: March 6 2020
Attached
is:
See Section below
INITIAL PROFFERED PERMIT Standard Permit or Letter ofpermission)
A
PROFFERED PERMIT Standard Permit or Letter ofpermission)
B
PERMIT DENIAL
C
APPROVED JURISDICTIONAL DETERMINATION
D
PRELIMINARY JURISDICTIONAL DETERMINATION
E
SECTION I - The following identifies your rights and options regarding an administrative appeal of the above decision.
Additional information may be found at http://www.usace.anny.mil/Missions/CivilWorks/RegulatoryProgramandPermits.aspx or
Corps regulations at 33 CFR Part 331.
A: INITIAL PROFFERED PERMIT: You may accept or object to the permit.
• ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final
authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your signature
on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all rights to appeal the
permit, including its terms and conditions, and approved jurisdictional determinations associated with the permit.
• OBJECT: If you object to the permit (Standard or LOP) because of certain terms and conditions therein, you may request that the
permit be modified accordingly. You must complete Section II of this form and return the form to the district engineer. Your
objections must be received by the district engineer within 60 days of the date of this notice, or you will forfeit your right to appeal
the permit in the future. Upon receipt of your letter, the district engineer will evaluate your objections and may: (a) modify the
permit to address all of your concerns, (b) modify the permit to address some of your objections, or (c) not modify the permit
having determined that the permit should be issued as previously written. After evaluating your objections, the district engineer
will send you a proffered permit for your reconsideration, as indicated in Section B below.
B: PROFFERED PERMIT: You may accept or appeal the permit
• ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final
authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your signature
on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all rights to appeal the
permit, including its terms and conditions, and approved jurisdictional determinations associated with the permit.
• APPEAL: If you choose to decline the proffered permit (Standard or LOP) because of certain terms and conditions therein, you
may appeal the declined permit under the Corps of Engineers Administrative Appeal Process by completing Section II of this form
and sending the form to the division engineer. This form must be received by the division engineer within 60 days of the date of
this notice.
C: PERMIT DENIAL: You may appeal the denial of a permit under the Corps of Engineers Administrative
Appeal Process by completing Section II of this form and sending the form to the division engineer. This form
must be received by the division engineer within 60 days of the date of this notice.
D: APPROVED JURISDICTIONAL DETERMINATION: You may accept or appeal the approved JD or
provide new information.
• ACCEPT: You do not need to notify the Corps to accept an approved JD. Failure to notify the Corps within 60 days of the date of
this notice means that you accept the approved JD in its entirety, and waive all rights to appeal the approved JD.
• APPEAL: If you disagree with the approved JD, you may appeal the approved JD under the Corps of Engineers Administrative
Appeal Process by completing Section II of this form and sending the form to the division engineer. This form must be received by
the division engineer within 60 days of the date of this notice.

SAW-2019-00780 Grissom Solar
E: PRELIMINARY JURISDICTIONAL DETERMINATION: You do not need to respond to the Corps
regarding the preliminary JD. The Preliminary JD is not appealable. If you wish, you may request an approved
JD (which may be appealed), by contacting the Corps district for further instruction. Also you may provide new
information for further consideration by the Corps to reevaluate the JD.
SECTION II - REQUEST FOR APPEAL or OBJECTIONS TO AN INITIAL PROFFERED PERMIT IN
REASONS FOR APPEAL OR OBJECTIONS: (Describe your reasons for appealing the decision or your
objections to an initial proffered permit in clear concise statements. You may attach additional information to
this form to clarify where your reasons or objections are addressed in the administrative record.)
ADDITIONAL INFORMATION: The appeal is limited to a review of the administrative record, the Corps
memorandum for the record of the appeal conference or meeting, and any supplemental information that the
review officer has determined is needed to clarify the administrative record. Neither the appellant nor the Corps
may add new information or analyses to the record. However, you may provide additional information to clarify
the location of information that is already in the administrative record.
POINT OF CONTACT FOR QUESTIONS OR INFORMATION:
If you have questions regarding this decision and/or
If you only have questions regarding the appeal process you may also
the appeal process you may contact:
contact:
District Engineer, Wilmington Regulatory Division
Mr. Jason Steele, Administrative Appeal Review Officer
Raleigh Regulatory Field Office
CESAD-PDO
Attn: Samantha Dailey
U.S. Army Corps of Engineers, South Atlantic Division
3331 Heritage Trade Drive, Suite 105
60 Forsyth Street, Room 1OM15
Wake Forest, North Carolina 27587
Atlanta, Georgia 30303-8801
Phone: [phone]
RIGHT OF ENTRY: Your signature below grants the right of entry to Corps of Engineers personnel, and any government
consultants, to conduct investigations of the project site during the course of the appeal process. You will be provided a 15 day
notice of any site investigation, and will have the opportuni to participate in all site investi ations.
Date:
Telephone number:
Signature of appellant or agent.
For appeals on Initial Proffered Permits send this form to:
District Engineer, Wilmington Regulatory Division, Attn: #PM_FULLNAME#, 69 Darlington Avenue, Wilmington,
North Carolina 28403
For Permit denials, Proffered Permits and approved Jurisdictional Determinations send this form to:
Division Engineer, Commander, U.S. Army Engineer Division, South Atlantic, Attn: Mr. Jason Steele,
Administrative Appeal Officer, CESAD-PDO, 60 Forsyth Street, Room 1OM15, Atlanta, Georgia 30303-8801
Phone: [phone]

APPENDIX 2
PRELIMINARY JURISDICTIONAL DETERMINATION FORM
BACKGROUND INFORMATION
A. REPORT COMPLETION DATE FOR PRELIMINARY JURISDICTIONAL DETERMINATION (JD):
March 5, 2020
B. NAME AND ADDRESS OF PERSON REQUESTING PRELIDHNARY JD:
Property Owner/Applicant:
Address:
Authorized Agent:
Address:
Mr. Robert Whitaker
3281 Loon Road
Enfield, North Carolina 27823
Pilot Environmental, Inc.
Mr. Michael Brame
Post Office Box 128
Kernersville, North Carolina 27285
C. DISTRICT OFFICE, FILE NAME, AND NUMBER: Wilmington, Grissom Solar, Mr. Robert Whitaker, Halifax
County, SAW-2019-00870
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION:
(USE THE ATTACHED TABLE TO DOCUMENT MULTIPLE WATERBODIES AT DIFFERENT SITES)
State: NC County/parish/borough: Halifax County City: Brinkleyville
Center coordinates of site (lat/long in degree decimal format): Lat. 36.239721°N, Long.-77.838747' W.
Universal Transverse Mercator:
Name of nearest water body: Rocky Swamp (Tar River 03020102)
E. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLIES):
❑ Office (Desk) Determination. Date:
® Field Determination. Date(s): June 25, 2019
TABLE OF AQUATIC RESOURCES IN REVIEW AREA WHICH "MAY BE" SUBJECT TO REGULATORY
JURISDICTION
Estimated Amount
Geographic authority
of Aquatic
Type of aquatic
to which the aquatic
Site Number
Latitude
Latitude
Resources in
resource (i.e.
resource "may be"
(ON)
(°W)
Review Area
wetland vs.
subject (i.e. Section 404
Linear
non -wetland)
or Section 10/404)
Feet
Acres
PA
36.241412
-77.837818
1.5
Non -Wetland
Section 404
WA
36.241754
-77.838674
2.78
Wetland
Section 404
WB
36.236325
-77.839709
1.2
Wetland
Section 404
SA
36.241160
-77.837250
40
Non -Wetland
Section 404
SB
36.236332
-77.836988
1435
Non -Wetland
Section 404
1. The Corps of Engineers believes that there may be jurisdictional aquatic resources in the review area, and the requestor of this
PJD is hereby advised of his or her option to request and obtain an approved JD (AJD) for that review area based on an informed
decision after having discussed the various types of JDs and their characteristics and circumstances when they may be
appropriate.
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 AJD for the activity, the permit applicant is hereby made

aware that: (1) the permit applicant has elected to seek a permit authorization based on a PJD, which does not make an official
determination of jurisdictional aquatic resources; (2) the applicant has the option to request an AJD before accepting the terms
and conditions of the permit authorization, and that basing a permit authorization on an AJD could possibly result in less
compensatory mitigation being required or different special conditions; (3) 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) 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) undertaking any activity in reliance upon the subject
permit authorization without requesting an AJD constitutes the applicant's acceptance of the use of the PJD; (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 PJD constitutes agreement that all aquatic resources in the review area affected in any way by
that activity will be treated as jurisdictional, and waives 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 AJD or a PJD, the JD will be processed as soon as practicable. Further, an AJD, 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. If, during an administrative appeal, it becomes appropriate to make an official determination whether geographic
jurisdiction exists over aquatic resources in the review area, or to provide an official delineation of jurisdictional aquatic
resources in the review area, the Corps will provide an AJD to accomplish that result, as soon as is practicable. This PJD finds
that there "may be " waters of the U.S. and/or that there "may be " navigable waters of the U.S. on the subject review area, and
identifies all aquatic features in the review area that could be affected by the proposed activity, based on the following
information:
SUPPORTING DATA. Data reviewed for preliminary JD (check all that apply): Checked items should be included in
subject file. Appropriately reference sources below where indicated for all checked items:
® Maps, plans, plots or plat submitted by or on behalf of the PJD requestor. Pilot Environmental, Inc. submitted a
Jurisdictional Determination Request on May 7, 2019, with revisions received on July 1, 2019.
® Data sheets prepared/submitted by or on behalf of the PJD requestor.
® 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: 1:241c, NC -Ringwood
® USDA Natural Resources Conservation Service Soil Survey. Citation: Web Soil Survey: June 2019.
® National wetlands inventory map(s). Cite name: SAW Regulatory Viewer — June 2019.
❑ State/Local wetland inventory map(s):
❑ FEMA/FIRM maps:
❑ 100-year Floodplain Elevation is: (National Geodetic 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):
IMPORTANT NOTE: The information recorded on this form has not necessarily been verified by the Corns and should
not be relied upon for later jurisdictional determinations.
DAI LEY.SAMAN Digitally signed by
DAILEY.SAMANTHA.J.1387
THA11387567 567948
Date: 2020.03.06 07:39:13
948 -05'00
Signature and date of
Regulatory Project Manager
(REQUIRED)
Signature and date of
person requesting preliminary JD
(REQUIRED, unless obtaining the signature is
Impracticable)
i Districts may establish timeframes for requestor to return signed PJD forms. If the requestor does not respond within the
established time frame, the district may presume concurrence and no additional follow up is necessary prior to finalizing an
action.

DP-2 \
0 .
— .0 — , f
LEGEND "' —
Site Boundary
Wetland
Pond
Perennial Stream se
1,435 LF'
— — — — 50 Ft Tar Pam Buffer
■ Culvert
SA 1-5 Flag Number THE LOCATIONS OF FEATURES SHOWN ON THIS MAP WERE FIELD VERIFIED BY MS. SAMANTHA
DAILEY WITH THE USACE ON JUNE 25, 2019. THIS EXHIBIT INCLUDES GPS LOCATIONS OF
DP-1 0 Data Point DELINEATED FEATURES. DELINEATED BY MTB/DSB 05-01-19.
Drawing 5 Wetland Map
Aerial Imagery from ESRI Grissom Solar
and Pilot GPS Data - - Approximate 100-Acre Tract
Scale: 1" = 400' PIL01 Brinkleyville, Halifax County, NC
Date:07/01/19 PILOT ENVIRONMENTAL,INC Pilot Project4708

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
July 11, 2019
Michael Brame
Pilot Environmental Inc.
PO Box 128
Kernersville, NC 27285
Re: Grissom Solar Update— Halifax County, NC
Dear Mr. Brame:
This letter is in response to your request for information on your proposed solar project, listed
above. Our comments are submitted pursuant to, and in accordance with, provisions of the
Endangered Species Act (the Act).
Based on the information provided and other information available, it appears that the proposed
action is not likely to adversely affect any federally -listed endangered or threatened species, their
formally designated critical habitat, or species currently proposed for listing under the Act at
these sites. We believe that the requirements of section 7(a)(2) of the Act have been satisfied for
your project. Please remember that obligations under section 7 consultation must be
reconsidered if. (1) new information reveals impacts of this identified action that may affect
listed species or critical habitat in a manner not previously considered; (2) this action is
subsequently modified in a manner that was not considered in this review; or, (3) a new species
is listed or critical habitat determined that may be affected by the identified action.
However, the Service is concerned about the potential impacts the proposed action might have
on aquatic species. Aquatic resources are highly susceptible to sedimentation. Therefore, we
recommend that all practicable measures be taken to avoid adverse impacts to aquatic species,
including implementing directional boring methods and stringent sediment and erosion control
measures. An erosion and sedimentation control plan should be submitted to and approved by
the North Carolina Division of Land Resources, Land Quality Section prior to construction.
Erosion and sedimentation controls should be installed and maintained between the construction
site and any nearby down -gradient surface waters. We recommend maintaining natural,
vegetated buffers on all streams and creeks adjacent to the project site.
The Service recommends that solar facilities be sited in areas that are previously disturbed, or
sites that do not impact mature forest, wetlands, or streams. The North Carolina Wildlife
Resources Commission has developed a Guidance Memorandum (a copy can be found on our
website at (http://www.fws.gov/raleigh) to address and mitigate secondary and cumulative

impacts to aquatic and terrestrial wildlife resources and water quality. We recommend that you
consider this document in the development of your projects and in completing an initiation
package for consultation (if necessary).
In addition, we encourage the use of natural vegetation management practices (such as sheep
grazing) and the planting or seeding of native pollinator plant species where possible on the site,
and other efforts to improve habitat for various species (such as bird houses and bat boxes).
Please note our specific recommendations, below.
Invasive Exotic Species — the Service is concerned with the introduction and spread of invasive
exotic species in association with the proposed project. Without active management, including
the revegetation of disturbed areas with native species, the project area will likely be a source for
the movement of invasive exotic plant species. Exotic species are a major contributor to species
depletion and extinction, second only to habitat loss. Exotics are a factor contributing to the
endangered or threatened status of more than 40 percent of the animals and plants on the Federal
List of Endangered and Threatened Wildlife and Plants.' It is estimated that at least 4,000 exotic
plant species and 2,300 exotic animal species are now established in the United States, costing
more than $130 billion a year to controlZ. Additionally, the U.S. Government has many
programs and laws in place to combat invasive species (see www.invasivespecies.gov) and thus
cannot spend money to counter these efforts. Specifically, Section 2(a)(3) of Executive Order
13112 Invasive Species (February 3, 1999) directs federal agencies to "not authorize, fund, or
carry out actions that it believes are likely to cause or promote the introduction or spread of
invasive species in the United States or elsewhere." Despite their short-term erosion control
benefits, many exotic species used in soil stabilization seed mixes are persistent once they are
established, thereby preventing the reestablishment of native vegetation. Many of these exotics
plants3 are also aggressive invaders of nearby natural areas, where they are capable of displacing
already established native species. Therefore, we strongly recommend that only native plant
species be used in association with all aspects of this project.
Pollinator Recommendations — Although solar energy production is a fast-growing
Renewable energy source that can lessen overall impacts to natural resources when compared to
conventional energy sources (coal, oil, gas, etc.), we believe solar farms can adversely affect
valuable natural resources if they are not properly planned and constructed. Impacts to natural
resources from the construction, operation, and maintenance of solar farms include: the removal
of forests and riparian buffers; creation of monotypic habitat; introduction of invasive species;
use of herbicides; creation of large, clear open spaces; and barriers created from fencing.
Recent evidence indicates that pollinators, especially native bees and monarch butterflies, are in
serious decline. Habitat losses and diminished native food sources have decreased the
populations and diversity of pollinators throughout the country. For these reasons, we
recommend that solar facilities be sited in areas that are previously disturbed (fallow fields,
closed industrial sites, etc.) or sites that do not impact mature forests, streams, or wetlands. To
offset the overall impacts of solar facilities and/or to increase the habitat and species diversity
within the solar facility area, we further recommend the following measures be implemented into
project design:
2

Sow native seed mixes with plant species that are beneficial to pollinators throughout the
site. Taller growing pollinator plant species should be planted around the periphery of the
site and anywhere on the site where mowing can be restricted during the summer months.
Taller plants, left un-mowed during the summer, would provide benefits to pollinators,
habitat to ground nesting/feeding birds, and cover for small mammals. Low
growing/groundcover native species should be planted under the solar panels and
between the rows of solar panels. This would provide benefits to pollinators while also
minimizing the amount of maintenance such as mowing and herbicide treatment. Using a
seed mix that includes milk weed species (milk weed is an important host plant for
monarch butterflies) is especially beneficial. The following website provides a
comprehensive list of native plant species that benefit pollinators:
https://mail.google.com/mail/u/0/#advancedsearch/subject=pollinator&subset=all&has=a
nita&within=l d&sizeoperator=s_sl&sizeunit=s_smb/ 14f0366dba7d3bda?projector=l .
Additional information regarding plant species, seed mixes, and pollinator habitat
requirements can be provided upon request.
2. Create openings in fencing to allow passage for small mammals and turtles.
3. If possible, the solar field should be designed with open areas spread throughout the
project site and planted and maintained with taller/pollinator friendly plant species. This
practice would benefit pollinators, create diversity throughout the site, and provide much
needed shelter islands to aid in the movement of small mammals and birds.
4. Mitigate for the loss of forested habitat. Though the loss of forested habitat cannot be
fully mitigated when cleared for solar facilities, we believe measures should be
implemented into the design plans to offset the impacts of the project to the greatest
extent practicable. We recommend the construction and placement of bat and bird boxes
throughout the site along with perch poles that are large enough to be used by raptors.
Provide nesting sites for pollinator species. Different pollinators have different needs for
nesting sites. Therefore, we recommend designing the solar facility to maintain a diverse
array of habitats to accommodate varied pollinators from hummingbirds to butterflies to
bees. Hummingbirds typically nest in trees or shrubs while many butterflies lay eggs on
specific host plants. Most bees nest in the ground and in wood or dry plant stems. For
additional information and actions that can be taken to benefit pollinators please visit the
following website:
http://www.fws.gov/pollinators/pollinatorpages/yourhelp.html
The Service has established an on-line project planning and consultation process which assists
developers and consultants in determining whether a federally -listed species or designated
critical habitat may be affected by a proposed project. For future projects, please visit the
Raleigh Field Office's project planning website at https•//www.fws„gov/raleigh/pp.html. If you
are only searching for a list of species that may be present in the project's Action Area, then you
may use the Service's Information, Planning, and Consultation System (IPaC) website to
determine if any listed, proposed, or candidate species may be present in the Action Area and
generate a species list. The IPaC website may be viewed at https://ecos.fws.gov/ipac/. The

IPaC web site contains a complete and frequently updated list of all endangered and threatened
species protected by the provisions of the Endangered Species Act of 1973, as amended (16
U.S.C. 1531 et seq.)(Act), a list of federal species of concern3 that are known to occur in each
county in North Carolina, and other resources.
If you have any questions or comments, please contact Kathy Matthews of this office at (919)
856-4520 ext. 27.
Sincerely,
2Pete Benjatriii
Field Supervisor
I Wilcove, D. S., D. Rothstein, J. Dubow, A. Phillips, and E. Losos. 1998. Quantifying threats to imperiled species
in the United States. BioScience 48:607615.
2 Pimentel, D., L. Lach, R. Zuniga, and D. Morrison. 2000. Environmental and economic costs of nonindigenous
species in the United States. BioScience 50:5365.
3 The term "federal species of concern" refers to those species which the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their designation does
not necessarily imply that the species will eventually be proposed for listing as a federally endangered or threatened
species. However, we recommend that all practicable measures be taken to avoid or minimize adverse impacts to
federal species of concern.
4

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
December 19, 2019
Dawn Reid
Office of Archives and History
Deputy Secretary Kevin Cherry
dawnreid&archcon. org
Archaeological Consultants of the Carolinas, Inc.
121 East First Street
Clayton, NC 27520
Re: Archaeological Survey of the Grissom Solar, LLC Tract, Halifax County, ER 19-2786
Dear Ms. Reid:
Thank you for your November 21, 2019, letter transmitting the archaeological report and site forms for the
project listed above. We have reviewed the information provided and offer the following comments.
Four archaeological sites (31HX541 — 31HX544) were identified and recorded as a result of the survey. Based
on their limited artifact assemblages and lack significant historical associations none of these sites are
considered eligible for listing in the National Register of Historic Places. Based on the information provided,
this office concurs with this recommendation.
In the report you state that all artifacts will be either transferred to OSA for curation or returned to the
property owner (page 8). Please provide a revised report that specifies the final plan for the disposition of
artifacts collected and analyzed as a result of the survey.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.review&ncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
n
amona M. Bartos
eputy State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

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Scale: 1„-2,000, PILOT ENVIRONMENTAL,INC Pilot Project4708

Site Boundary
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Not to Scale PILOT ENVIR0NMENTAL,INC Pilot Project4708

Drawing 3
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Grissom Solar
Approximate 100-Acre Tract
Brinkleyville, Halifax County, NC
Pilot Project 4708

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LEGEND
.Site Boundary
01%Annual Chance Flood Hazard
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from FEMA Web Map Service , ,�
Scale: 1" - 2 000' o Brinkleyville, Halifax County, NC
• P I LOT E N V I R 0 N M E N T A L, I N C
Pilot Project 4708

LEGEND
Site Boundary
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Drawing 5
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Scale: 1" = 400'
Date: 07/01/19
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THE LOCATIONS OF FEATURES SHOWN ON THIS MAP WERE FIELD VERIFIED BY MS. SAMANTHA
DAILEY WITH THE USACE ON JUNE 25, 2019. THIS EXHIBIT INCLUDES GPS LOCATIONS OF
DELINEATED FEATURES. DELINEATED BY MTB/DSB 05-01-19.
`v' Wetland Map
Grissom Solar
- Approximate 100-Acre Tract
PLOT Brinkleyville, Halifax County, NC
PILOT ENVIR0NMENTAL,INC Pilot Project4708