20171527 Ver 2_Endangered Species_Critical Habitat_20200407

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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Ecological Services Field Office
Post Office Box 33726
Raleigh, NC 27636-3726
Phone: [phone] Fax: [phone]
In Reply Refer To: February 21, 2020
Consultation Code: 04EN2000-2020-SLI-0707
Event Code: 04EN2000-2020-E-01576
Project Name: Person County MegaSite
Subject: List of threatened and endangered species that may occur in your proposed project
location, and/or may be affected by your proposed project
To Whom It May Concern:
The species list generated pursuant to the information you provided identifies threatened,
endangered, proposed and candidate species, as well as proposed and final designated critical
habitat, that may occur within the boundary of your proposed project and/or may be affected by
your proposed project. The species list fulfills the requirements of the U.S. Fish and Wildlife
Service (Service) under section 7(c) of the Endangered Species Act (Act) of 1973, as amended
(16 U.S.C. 1531 et seq.).
New information based on updated surveys, changes in the abundance and distribution of
species, changed habitat conditions, or other factors could change this list. Please feel free to
contact us if you need more current information or assistance regarding the potential impacts to
federally proposed, listed, and candidate species and federally designated and proposed critical
habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the
Act, the accuracy of this species list should be verified after 90 days. This verification can be
completed formally or informally as desired. The Service recommends that verification be
completed by visiting the ECOS-IPaC website at regular intervals during project planning and
implementation for updates to species lists and information. An updated list may be requested
through the ECOS-IPaC system by completing the same process used to receive the enclosed list.
Section 7 of the Act requires that all federal agencies (or their designated non-federal
representative), in consultation with the Service, insure that any action federally authorized,
funded, or carried out by such agencies is not likely to jeopardize the continued existence of any
federally -listed endangered or threatened species. A biological assessment or evaluation may be
prepared to fulfill that requirement and in determining whether additional consultation with the
Service is necessary. In addition to the federally -protected species list, information on the
species' life histories and habitats and information on completing a biological assessment or

02/21/2020 Event Code: 04EN2000-2020-E-01576
evaluation and can be found on our web page at http://www.fws.gov/raleigh. Please check the
web site often for updated information or changes
If your project contains suitable habitat for any of the federally -listed species known to be
present within the county where your project occurs, the proposed action has the potential to
adversely affect those species. As such, we recommend that surveys be conducted to determine
the species' presence or absence within the project area. The use of North Carolina Natural
Heritage program data should not be substituted for actual field surveys.
If you determine that the proposed action may affect (i.e., likely to adversely affect or not likely
to adversely affect) a federally -protected species, you should notify this office with your
determination, the results of your surveys, survey methodologies, and an analysis of the effects
of the action on listed species, including consideration of direct, indirect, and cumulative effects,
before conducting any activities that might affect the species. If you determine that the proposed
action will have no effect (i.e., no beneficial or adverse, direct or indirect effect) on federally
listed species, then you are not required to contact our office for concurrence (unless an
Environmental Impact Statement is prepared). However, you should maintain a complete record
of the assessment, including steps leading to your determination of effect, the qualified personnel
conducting the assessment, habitat conditions, site photographs, and any other related articles.
Please be aware that bald and golden eagles are protected under the Bald and Golden Eagle
Protection Act (16 U.S.C. 668 et seq.), and projects affecting these species may require
development of an eagle conservation plan (http://www.fws.gov/windenergy/
eagle_guidance.html). Additionally, wind energy projects should follow the wind energy
guidelines (http://www.fws.gov/windenergy/) for minimizing impacts to migratory birds and
bats.
Guidance for minimizing impacts to migratory birds for projects including communications
towers (e.g., cellular, digital television, radio, and emergency broadcast) can be found at: http://
www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/towers.htm; http://
www.towerkill.com; and http://www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/
comtow.html.
Not all Threatened and Endangered Species that occur in North Carolina are subject to section 7
consultation with the U.S Fish and Wildlife Service. Atlantic and shortnose sturgeon, sea
turtles,when in the water, and certain marine mammals are under purview of the National Marine
Fisheries Service. If your project occurs in marine, estuarine, or coastal river systems you should
also contact the National Marine Fisheries Service, http://www.nmfs.noaa.gov/
We appreciate your concern for threatened and endangered species. The Service encourages
Federal agencies to include conservation of threatened and endangered species into their project
planning to further the purposes of the Act. Please include the Consultation Tracking Number in
the header of this letter with any request for consultation or correspondence about your project
that you submit to our office. If you have any questions or comments, please contact John Ellis
of this office at [e-mail].

02/21/2020 Event Code: 04EN2000-2020-E-01576
Attachment(s):
• Official Species List

02/21/2020 Event Code: 04EN2000-2020-E-01576
Official Species List
This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the
requirement for Federal agencies to "request of the Secretary of the Interior information whether
any species which is listed or proposed to be listed may be present in the area of a proposed
action".
This species list is provided by:
Raleigh Ecological Services Field Office
Post Office Box 33726
Raleigh, NC 27636-3726
[phone]

02/21/2020 Event Code: 04EN2000-2020-E-01576
Project Summary
Consultation Code: 04EN2000-2020-SLI-0707
Event Code: 04EN2000-2020-E-01576
Project Name: Person County MegaSite
Project Type: DEVELOPMENT
Project Description: Person County MegaSite, approximately 1,350 acres
Project Location:
Approximate location of the project can be viewed in Google Maps: https:
www.google.com/maps/place/36.48054254417718N78.98205437391178W
Counties: Person, NC
2

02/21/2020 Event Code: 04EN2000-2020-E-01576 3
Endangered Species Act Species
There is a total of 0 threatened, endangered, or candidate species on this species list.
Species on this list should be considered in an effects analysis for your project and could include
species that exist in another geographic area. For example, certain fish may appear on the species
list because a project could affect downstream species.
IPaC does not display listed species or critical habitats under the sole jurisdiction of NOAA
Fisheries1, as USFWS does not have the authority to speak on behalf of NOAA and the
Department of Commerce.
See the "Critical habitats" section below for those critical habitats that lie wholly or partially
within your project area under this office's jurisdiction. Please contact the designated FWS office
if you have questions.
NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an
office of the National Oceanic and Atmospheric Administration within the Department of
Commerce.
Critical habitats
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S
JURISDICTION.

NCNHDE-11443
February 21, 2020
Morgan Gilbert
Timmons Group
5410 Trinity Road
Raleigh, NC 27606
RE: Person County MegaSite; 39329.001
Dear Morgan Gilbert:
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
A query of the NCNHP database indicates that there are records for rare species, important natural
communities, natural areas, and/or conservation/managed areas within the proposed project
boundary. These results are presented in the attached ‘Documented Occurrences’ tables and map.
The attached ‘Potential Occurrences’ table summarizes rare species and natural communities that
have been documented within a one-mile radius of the property boundary. The proximity of these
records suggests that these natural heritage elements may potentially be present in the project area
if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one-mile
radius of the project area, if any, are also included in this report.
If a Federally-listed species is documented within the project area or indicated within a one-mile
radius of the project area, the NCNHP recommends contacting the US Fish and Wildlife Service
(USFWS) for guidance. Contact information for USFWS offices in North Carolina is found here:
https://www.fws.gov/offices/Directory/ListOffices.cfm?statecode=37.
Please note that natural heritage element data are maintained for the purposes of conservation
planning, project review, and scientific research, and are not intended for use as the primary criteria
for regulatory decisions. Information provided by the NCNHP database may not be published
without prior written notification to the NCNHP, and the NCNHP must be credited as an information
source in these publications. Maps of NCNHP data may not be redistributed without permission.
Also please note that the NC Natural Heritage Program may follow this letter with additional
correspondence if a Dedicated Nature Preserve, Registered Heritage Area, Clean Water
Management Trust Fund easement, or an occurrence of a Federally-listed species is documented
near the project area.
If you have questions regarding the information provided in this letter or need additional assistance,
please contact Rodney A. Butler at [e-mail] or 919-707-8603.
Sincerely,
NC Natural Heritage Program
Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Intersecting the Project Area
Person County MegaSite
Project No. 39329.001
February 21, 2020
NCNHDE-11443
Element Occurrences Documented Within Project Area
Taxonomic
Group
EO ID Scientific Name Common Name Last
Observation
Date
Element
Occurrence
Rank
Accuracy Federal
Status
State
Status
Global
Rank
State
Rank
Amphibian 21719 Hyla versicolor Gray Treefrog 2005-07-13 E 3-Medium ---Special
Concern
G5 S2S3
Freshwater
Bivalve
29502 Villosa constricta Notched Rainbow 2006-02-24 E 3-Medium ---Threatened G3 S3
Natural
Community
25502 Basic Mesic Forest
(Piedmont Subtype)
---2008 C 2-High ------G3G4 S3S4
Vascular Plant 24127 Acmispon helleri Carolina Birdfoot-
trefoil
2006-09-11 D?2-High ---Special
Concern
Vulnerable
G5T3 S3
Natural Areas Documented Within Project Area
Site Name Representational Rating Collective Rating
Marlowe Creek Slopes R3 (High)C4 (Moderate)
Storys Creek/Marlowe Creek Swamp R5 (General)C5 (General)
No Managed Areas Documented within the Project Area
Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.org/content/help. Data query generated on February 21, 2020; source: NCNHP, Q1 Jan 2020.
Please resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 2 of 5
Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One-mile Radius of the Project Area
Person County MegaSite
Project No. 39329.001
February 21, 2020
NCNHDE-11443
Element Occurrences Documented Within a One-mile Radius of the Project Area
Taxonomic
Group
EO ID Scientific Name Common Name Last
Observation
Date
Element
Occurrence
Rank
Accuracy Federal
Status
State
Status
Global
Rank
State
Rank
Amphibian 21719 Hyla versicolor Gray Treefrog 2005-07-13 E 3-Medium ---Special
Concern
G5 S2S3
Freshwater
Bivalve
29502 Villosa constricta Notched Rainbow 2006-02-24 E 3-Medium ---Threatened G3 S3
Natural
Community
25502 Basic Mesic Forest
(Piedmont Subtype)
---2008 C 2-High ------G3G4 S3S4
Natural
Community
25504 Piedmont Acidic Glade ---2006-09-11 C 2-High ------G2 S2
Natural
Community
25507 Piedmont Monadnock
Forest (Typic Subtype)
---2010 A 2-High ------G3G4 S3
Vascular Plant 24047 Acmispon helleri Carolina Birdfoot-
trefoil
2006-08-09 B 3-Medium ---Special
Concern
Vulnerable
G5T3 S3
Vascular Plant 24127 Acmispon helleri Carolina Birdfoot-
trefoil
2006-09-11 D?2-High ---Special
Concern
Vulnerable
G5T3 S3
Vascular Plant 24142 Acmispon helleri Carolina Birdfoot-
trefoil
2006-08-22 D 2-High ---Special
Concern
Vulnerable
G5T3 S3
Vascular Plant 27371 Ranunculus micranthus Rock Buttercup 1973-04-23 H 3-Medium ---Significantly
Rare
Peripheral
G5 S1
Natural Areas Documented Within a One-mile Radius of the Project Area
Site Name Representational Rating Collective Rating
Marlowe Creek Slopes R3 (High)C4 (Moderate)
Storys Creek/Marlowe Creek Swamp R5 (General)C5 (General)
Hagers Mountain R4 (Moderate)C5 (General)
Page 3 of 5
Managed Areas Documented Within a One-mile Radius of the Project Area
Managed Area Name Owner Owner Type
Person County Open Space Person County Local Government
Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.org/content/help. Data query generated on February 21, 2020; source: NCNHP, Q1 Jan 2020.
Please resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 4 of 5
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Page 5 of 5
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box33726
Raf eigh, North Carolina 27 63 6-37 26
February 21^,20L9
Ross Sullivan
U.S, Army Corps of Engineers, Wilmington District
Raleigh Regulatory Field Office
333L Heritage Trade Drive, Suite L05
Wake Forest, NC 27587
Re: Person County Mega Park / SAW-2016-025421 Person County
Dear Mr. Sullivan:
The U.S. Fish and Wildlife Service (Service) has reviewed the project advertised in the above
referenced Public Notice. The project, as advertised in the Public Notice, is expected to have
minimal adverse impacts to fish and wildlife resources. Therefore, we have no objection to the
activity as described in the permit application.
ln accordance with the Endangered Species Act of 1973, as amended, (ESA) and based on the
information provided, and other available information, it appears the action is not likely to adversely
affect federally listed species or their critical habitat as defined by the ESA. We believe that the
requirements of section 7 (aX2) of the ESA have been satisfied for this project. Please remember
that obligations under the ESA must be reconsidered if : (1) new information identifies impacts of this
action that may affect listed species or critical habitat in a manner not previously considered; (2) this
action is 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.
For your convenience a list of all federally protected endangered and threatened species in North
Carolina is now available on our website at <http://www.fws.gov /raleiglv. Our web page contains a
complete and updated list of federally protected species, and a list of federal species of concern
known to occur in each county in North Carolina.
The Service appreciates the opportunity to review and provide comments on the proposed action.
Should you have any questions regarding the project, please contact John Ellis at [phone],
extension 26.
NMFS, Beaufort, NC
EPA, AtIanta, GA
WRC, Raleigh
tr/
cc:

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
MEMORANDUM

TO: Lyn Hardison, Environmental Assistance Coordinator
NCDEQ Division of Environmental Assistance and Customer Services

FROM: Ross Sullivan
Raleigh Regulatory Field Office
US Army Corps of Engineers

DATE: February 22, 2019

SUBJECT: Public Notice for Person County Mega Park, Corps Action ID Number: SAW-2016-
02542.

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina Environmental Policy Act (G.S.
113A-1 through 113A-10; 1 NCAC 25) and North Carolina General Statutes (G.S. 113-131 et seq.).

Person County proposes to construct a semiconductor chip manufacturing plant and associated
infrastructure, including transportation improvements and water and natural gas utility lines. Proposed
work will be completed in two phases. Phase I will include the 318-acre chip manufacturing plant. Phase
2 will include transportation improvements, such road widening, interchange improvements and
additional lanes, as well as gas and water infrastructure projects, specifically a 30-inch waterline serviced
by the City of Roxboro. The project area contains 10,529 linear feet of streams, 1.94 acres of wetlands
and is located in the Roanoke River watershed. Surface waters on the property drain to Storys Creek,
Marlowe Creek and Castle Creek. The proposed project will directly impact 10,529 linear feet of streams
and 1.94 acres of wetlands.

The proposed chip manufacturing plant is in northern Person County, approximately 1.8 miles north of
the City of Roxboro. It is situated on both sides of Country Club Road, south of its intersection with
Edwin Robertson Road. The proposed water utility line will follow Country Club Road to Cavel-Club
Lake and terminate at Kelly Carver Road. The gas utility line will follow Country Club Road to
Community House Road to McGhees Mill Road and terminate at its intersection with Concord Ceffo
Road.
There is a record for the federal species of concern and state-special concern, notched rainbow (Villosa
constricta) in Storys Creek in the project vicinity. The lack of any further records from the site does not
imply or confirm the absence of federal or state-listed species or state Species of Greatest Conservation
Need listed in the 2015 State Wildlife Action Plan (http://www.ncwildlife.org/plan). An on-site survey is
Page 2

February 22, 2019
Person County Mega Park
SAW-2016-02542

the only definitive means to determine if the proposed project would impact rare, threatened or
endangered species.
The NCWRC hesitates to concur with stream impacts and the filling of wetlands due to wildlife habitat
value and the beneficial functions they provide for flood control and water quality protection. Changes in
land use and increases in impervious surfaces may exacerbate channel degradation and sediment impacts
to stream ecosystems due to increased stormwater runoff and elevated flooding. In addition, pollutants
(e.g., sediment, heavy metals, pesticides and fertilizers) washed from roads and developed landscapes can
adversely affect and extirpate species downstream. If the permit is approved, the NCWRC offers the
following recommendations to minimize impacts to aquatic and terrestrial wildlife resources:

1. Maintain or establish a minimum 100-foot undisturbed, native, forested buffer along
perennial streams, and a minimum 50-foot buffer along intermittent streams and wetlands.
Maintaining undisturbed, forested buffers along these areas will minimize impacts to aquatic
and terrestrial wildlife resources. Wide riparian buffers are helpful in maintaining stream
bank stability. In addition, these buffers provide a travel corridor for wildlife species. Lay
down and staging areas should be located outside wetland areas and at least 100 feet from
streak banks.
2. Use bridges for all permanent roadway crossings of streams and associated wetlands to
eliminate the need to fill and culvert, where practicable. If culverts must be used, the culvert
should be designed to allow aquatic life passage. Fords may be appropriate and preferred for
intermittent stream crossings or where crossings will be used only once or twice a year. For
fords, crossings in riffles are preferred with the banks lowered upstream and downstream of
the crossing. Stabilize the stream bottom with geo-textile fabric and rock; concrete should
not be used for bed stabilization.
3. Measures to avoid or minimize impacts to wetlands should be implemented. In addition to
providing wildlife habitat, wetland areas perform important functions of flood control and
water quality protection. Temporarily disturbed wetland areas should be returned to original
soils and contours, reseeded with annual small grains appropriate for the season (e.g. oats,
millet, rye, wheat or rye grass) and allowed to revert to natural wetland vegetation. In all
forested wetlands, clearing should be done by hand.
4. Avoid the removal of large trees at the edges of construction corridors. Disturbed areas
should be re-seeded with seed mixtures that are beneficial to wildlife. Avoid fescue-based
mixtures as fescue is invasive and provides little benefit to wildlife. Native, annual small
grains appropriate for the season are preferred and recommended. Pollinator mixes are
commercially available and provide forage and shelter for numerous species of bees,
butterflies, moths and birds. Where feasible, use woody debris and logs from cleared areas to
establish brush piles adjacent to cleared right-of-ways to improve habitat. Allowing the
corridor areas to re-vegetate into a brush/scrub habitat would maximize benefits to wildlife.
For areas adjacent to residential areas, a native shrub/grass option may also be beneficial.
5. Minimize corridor maintenance and prohibit mowing between April 1 and October 1 to
minimize impacts to nesting wildlife. Create a maintenance schedule that incorporates only a
portion of the area (one third of the area, for example) each year instead of the entire project
area every 3 to 4 years. Pesticides (including insecticides and herbicides) should not be used
for maintenance of ROWs within 100 feet of perennial streams and 50 feet of intermittent
streams, or within floodplains and wetlands associated with these streams.
Page 3

February 22, 2019
Person County Mega Park
SAW-2016-02542

6. Sediment and erosion control measures should be installed prior to any land-disturbing
activity. The use of biodegradable and wildlife-friendly sediment and erosion control devices
is strongly recommended. Silt fencing, fiber rolls and/or other products should have loose-
weave netting that is made of natural fiber materials with movable joints between the vertical
and horizontal twines. Silt fencing and similar products that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife
species. Excessive silt and sediment loads can have detrimental effects on aquatic resources
including destruction of spawning habitat, suffocation of eggs and clogging of gills.

The NCWRC encourages the applicant to consider additional measures to protect aquatic and terrestrial
wildlife species in developing landscapes. The NCWRC’s Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water
Quality (August 2002; http://www.ncwildlife.org/Portals/0/Conserving/documents/2002_
GuidanceMemorandumforSecondaryandCumulativeImpacts.pdf) details measures to minimize secondary
and cumulative impacts to aquatic and terrestrial wildlife resources; in addition, the Green Growth
Toolbox (http://216.27.39.101/greengrowth/) provides information on nature-friendly planning that
discusses how to address growth while concurrently conserving priority terrestrial and aquatic habitat.

Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] or [e-mail].

ec: Karen Higgins, NCDWR

Version 6.15.2017 Page 1

PUBLIC NOTICE

Issue Date: January 23, 2019
Comment Deadline: February 22, 2019
Corps Action ID Number: SAW -2016-02542

The Wilmington District, Corps of Engineers (Corps) received an application from
Person County seeking Department of the Army authorization to discharge
dredged or fill material into waters of the United States, associated with the
construction of a semiconductor chip manufacturing plant on a 318 acre parcel of
land that is situated within a larger tract of land (approximately 1,456 acres)
designated by Person County as the Person County Mega Park. The proposed
project includes off-site transportation and utility improvements. The proposed
project site is located south of Edwin Robertson Road, on both sides of Country
Club Road, north of the City of Roxboro, Person County, North Carolina.

Specific plans and location information are described below. Due to the large
number of permit drawing plans associated with this proposal, they are not
included with this Public Notice. This Public Notice and all attached plans are
also available on the Wilmington District Web Site at:
http://www.saw.usace.army.mil/Missions/RegulatoryPermitProgram.aspx

Applicant: Person County
Mr. David Newell
Post Office Box 1824
Roxboro, North Carolina 27573

AGENT (if applicable): Timmons Group
Ms. Anna Reusche
5410 Trinity Road, Suite 102
Raleigh, North Carolina 27607

Authority

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)
US Army Corps
Of Engineers
Wilmington District

Version 6.15.2017 Page 2

Location

Location Description: The project area is composed of the proposed
semiconductor chip manufacturing plant and the proposed utility and
transportation improvement sites.

The semiconductor chip manufacturing plant site is located in northern Person
County, approximately 1.8 miles north of the City of Roxboro. The site is situated
on both sides of Country Club Road, immediately south of its intersection with
Edwin Robertson Road.

The proposed route for the water utility would begin in the semiconductor chip
manufacturing plant site and follow Country Club Road south to Cavel-Club Lake
Road. At the intersection of Country Club Road and Cavel-Club Lake Road, the
water utility would follow Cavel-Club Lake Road west and terminate at Kelly
Carver Road.

The proposed route for the gas utility would begin at the intersection of Edwin
Robertson Road and Country Club Road, following Country Club Road south to
its intersection with Community House Road. The route would then follow
Community House Road, which turns into McGhees Mill Road, west to its termini
at the intersection of McGhees Mill Road and Concord Ceffo Road.

The proposed transportation improvements would be located along Country Club
Road, Edwin Robertson Road, Shiloh Church Road, and at the Country Club
Road/Chub Lake Road and Shiloh Church Road/US 501 intersections. The
proposed transportation improvements would remove a portion of Country Club
Road within the footprint of the proposed semiconductor chip manufacturing
facility. Traffic from the new northern terminus of Country Club Road would be
rerouted around the semiconductor chip manufacturing plant via new roads
spanning to the east and west around the site, both of which would terminate at
Edwin Robertson Road. Transportation improvements along Edwin Robertson
Road would begin at the semiconductor chip manufacturing plant site and follow
Edwin Robertson Road, which turns to Shiloh Church Road at Woodsdale Road,
east to US 501 (Boston Road). Intersection improvements are proposed to the
Country Club Road/Chub Lake Road and Shiloh Church Road/US 501
intersections.

Project Area (acres): 318 acres
Nearest Town: Roxboro
Nearest Waterways: Marlowe Creek and Story’s Creek
River Basin: Roanoke
Latitude and Longitude: 36.478476 N, -78.990137 W

Version 6.15.2017 Page 3

Existing Site Conditions

The 318 acre project area for the semiconductor chip manufacturing facility and
associated infrastructure is located in the piedmont physiographic region of North
Carolina. The project area has moderate slopes along a ridgeline that bisects the
center of the property. Elevations range from 450 feet above mean sea level
(MSL) along the boundaries to 500 feet MSL in the center of the Project Site.

Current land use in the project area includes both forested and maintained areas.
Forested areas on the site are characterized as pine and mixed hardwood
communities. Maintained areas in the project area include agricultural fields used
for grazing cattle, one single-family home, and an electrical transmission
easement. Land use surrounding the proposed project is predominately
undeveloped forestlands interspersed with agricultural fields and single-family
residential homes.

The project area is located in the Roanoke River watershed (Hydrologic Unit
Code (HUC) 03010104) and includes perennial and intermittent streams and
adjacent wetlands. Surface waters on the property drain to three named water
bodies that occur within the project area, including Story’s Creek, Marlowe
Creek, and Castle Creek; these streams all drain to the Hyco River which drains
to the Roanoke River.

The project area contains approximately 10,529 linear feet (lf) of streams.
Substrate in the streams range from silt/sand to cobble/gravel and Ordinary High
Water Mark (OHWM) indicators included natural lines impressed on the banks,
shelving, matted down vegetation, disturbed leaf litter, sediment deposition,
wrack lines, sediment sorting, and bank scour. All streams in the project area
carry the North Carolina Division of Water Resources (NCDWR) surface water
classification of “C.” The classification C refers to those waters protected for uses
such as secondary recreation, fishing, wildlife, fish consumption, aquatic life
including propagation, survival and maintenance of biological integrity, and
agriculture. Secondary recreation includes wading, boating, and other uses
involving human body contact with water where such activities take place in an
infrequent, unorganized, or incidental manner.

The project area contains approximately 1.94 acres of wetlands. These wetlands
are primarily characterized by the North Carolina Wetland Assessment Method
(NCWAM) as headwater forest wetlands and bottomland hardwood forest.
Vegetation in the headwater forest wetlands consists of a canopy dominated by
black willow (Salix nigra), river birch (Betula nigra), sweetgum (Liquidambar
styraciflua), loblolly pine (Pinus taeda), and red maple (Acer rubrum); a
sapling/shrub layer dominated by the same tree species listed for the canopy
plus Chinese privet (Ligustrum sinense); and a herbaceous and woody vine layer
dominated by soft rush (Juncus effusus) lizard’s tail (Saururus cernuus),
woolgrass (Scirpus cyperinus), common greenbrier (Smilax rotundifolia), wild
Version 6.15.2017 Page 4

grape (Vitis rotundifolia), and poison-ivy (Toxicodendron radicans). Vegetation in
the bottomland hardwood forest consists of a canopy dominated by willow oak
(Quercus phellos), green ash (Fraxinus pennsylvanica), tulip poplar (Liriodendron
tulipifera), and red maple; a sapling/shrub layer dominated by willow oak, green
ash, and Chinese privet; and a herbaceous and woody vine layer dominated by
Japanese stilt-grass (Microstegium vimineum) and poison-ivy.

The entirety of the 1,456-acre Person County Mega Park was delineated to
identify the presence and location of potentially jurisdictional waters of the United
States. The initial field work for the delineation was conducted in June and
August of 2016. The delineation was verified by Eric Alsmeyer of the U.S. Army
Corps of Engineers, Wilmington District (Corps) on July 28, August 4, and August
5, 2016. Additional areas associated with roadway improvements were
delineated in November 2017 and were reviewed by the Corps and the NCDWR
on May 3, 2018.

Applicant’s Stated Purpose

The applicant’s stated purpose is to develop a semiconductor chip manufacturing
plant at the Person County Mega Park, which will serve to bring significant
economic relief to the citizens of Person County. To date, the applicant has not
identified a tenant or user for the proposed site.

Project Description

The overall proposed project includes a semiconductor chip manufacturing plant,
transportation improvements, and the installation of water and natural gas
infrastructure. Implementation of the proposed project would result in direct
impacts to 10,529 lf of streams and 1.94 acres of wetlands. There are no impacts
proposed by either the associated water or gas utility infrastructure projects.

The proposed project would be constructed in two phases. Phase 1 would
consist of the construction of the semiconductor chip manufacturing plant and
would result in permanent impacts to 6,851 lf of stream and 1.56 acres of
wetland. Phase 2 would consist of the associated transportation improvements
and utility infrastructure projects and would result in permanent impacts to an
additional 3,678 lf of stream and 0.38 acre of wetlands.

The proposed semiconductor chip manufacturing plant would involve the
construction of an approximately 318 acre development pad, with plans for the
construction of buildings and parking lots. The proposed transportation
improvements would consist of road widening, interchange improvements, and
additional lanes. The proposed water utility project would be a 30-inch waterline
that would be serviced by the City of Roxboro. The applicant did not provide
much detail concerning the proposed natural gas utility project other than the
Version 6.15.2017 Page 5

proposed route. The applicant stated that no impacts are proposed as a result of
the proposed water or gas utility projects that are associated with the project.

Avoidance and Minimization

The applicant provided the following information in support of efforts to avoid
and/or minimize impacts to the aquatic environment: Several alternatives were
evaluated during the design process in an effort to avoid and minimize impacts to
jurisdictional resources within the site and along the proposed infrastructure
extensions. The applicant has attempted to avoid and minimize impacts to water
resources by designing perpendicular road crossings, where feasible, and
utilizing erosion control Best Management Practices (BMPs) to minimize impacts
associated with offsite sedimentation.

Compensatory Mitigation

The applicant offered the following compensatory mitigation plan to offset
unavoidable functional loss to the aquatic environment: Due to the absence of
private mitigation banks in the area, compensatory mitigation for these
unavoidable impacts would be achieved through payment to the North Carolina
Division of Mitigation Services (NCDMS). A conditional letter of approval was
provided by NCDMS for the necessary credits. Based on the response from
NCDMS, they currently have most of the credits needed in the 03010104 HUC.
However, should that change at the time payment is made, NCDMS may
propose to use adjacent HUCs to fill the mitigation needs of the proposed project
contingent on approval from the regulatory agencies. Because of the rural nature
of the Roanoke watershed and the lack of demand for mitigation within this
watershed, the North Carolina Interagency Review Team has identified
neighboring HUCs within the Roanoke watershed, including 03010103,
03010104 or 03010102, as additional opportunities for mitigation.

The applicant also proposes to explore permittee-responsible mitigation options
as part of the permitting process. The applicant states that payment to the
NCDMS would be an option; however, flexibility to explore other mitigation
opportunities that can better serve the public and environment may be
incorporated into the final mitigation package proposed for the project. The
applicant suggests that alternative mitigation opportunities would allow them to
pursue projects that directly benefit Person County and allow for potential
mitigation to occur in close proximity to the impact site. The applicant states that
they would use a collaborative watershed planning process to incorporate and
solicit input directly from affected stakeholders when developing a mitigation
plan. The applicant indicates that planning efforts would identify and prioritize
aquatic resource restoration, establishment, and enhancement activities, and
preservation of existing aquatic resources that are important for maintaining or
improving ecological functions of the watershed within Person County.

Version 6.15.2017 Page 6

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 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
Version 6.15.2017 Page 7

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 reviewed this project in accordance with (IAW) the
NLEB Standard Local Operating Procedures for Endangered Species
(SLOPES) between the USACE, Wilmington District, and the Asheville
and Raleigh U.S. Fish and Wildlife Service (Service) Offices, and
determined that the action area for this project is located outside of the
highlighted areas/red 12-digit HUCs and activities in the action area do not
require prohibited incidental take; as such, this project meets the criteria
for the 4(d) rule and any associated take is exempted/excepted.

The Corps determines that the proposed project may affect federally listed
endangered or threatened species or their formally designated critical
habitat. Consultation has been completed for this type of activity and the
effects of the proposed activity have been evaluated and/or authorized by
the National Marine Fisheries Service (NMFS) in the South Atlantic
Regional Biological Opinion or its associated documents, including 7(a)(2)
& 7(d) analyses and Critical Habitat assessments. A copy of this public
notice will be sent to the NMFS.

The Corps is not aware of the presence of species listed as threatened or
endangered or their critical habitat formally designated pursuant to the
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.
Version 6.15.2017 Page 8

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 February 15, 2019,
to:

NCDWR Central Office
Attention: Ms. Karen Higgins, 401 and Buffer Permitting Unit
(USPS mailing address): 1617 Mail Service Center, Raleigh, NC 27699-
1617

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.

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).
Version 6.15.2017 Page 9

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 will 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 6.15.2017 Page 10

The Corps of Engineers, Wilmington District will receive written comments
pertinent to the proposed work, as outlined above, until 5pm, February 22, 2019.
Comments should be submitted to Mr. Ross Sullivan,
Raleigh Regulatory Field Office, 3331 Heritage Trade Drive, Suite 105 ,
Wake Forest, North Carolina 27587, at [phone] extension 25 or
[e-mail].

Due to the current lapse in funding for other Federal agencies that may have an
interest in commenting on the proposed action, the District Engineer may extend
the comment period to allow such agencies to comment so that the he can
complete his required Public Interest Review.

In cases where the proposed action May Effect a listed species or a species
proposed for listing pursuant to Section 7 of the Endangered Species Act, and/or
In cases where the proposed action will have an Effect on a property listed, or
eligible to be listed, on the National Register of Historic Places pursuant to
Section 106 of the National Historic Preservation Act, the DE will be unable to
make a final decision on the proposed action until the requirements of the
appropriate statute have been satisfied.

1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] \ Internet: www.ncdenr.gov
An Equal Opportunity \ Affirmative Action Employer – 50% Recycled \ 10% Post Consumer Paper

North Carolina Department of Environment and Natural Resources
Office of Land and Water Stewardship
Pat McCrory Bryan Gossage
Governor Director
John E. Skvarla, III
Secretary
June 6, 2014

Mr. Cory Darnell
ECS Carolinas, LLP
9001 Glenwood Avenue
Raleigh, NC 27617
[e-mail]

RE: Project Trace, Country Club Road and Edwin Robertson Road, Roxboro, Person County, NC
ECS Project No. 06.21626

Dear Mr. Darnell:

Thank you for the opportunity to provide information from the North Carolina Natural Heritage Program
(NCNHP) database for the proposed project referenced above. The NCNHP database shows that the
Marlowe Creek Slopes natural heritage area is located in the eastern portion of the proposed project
area, and there are records for the following rare species in close proximity of the project area:

SCIENTIFIC NAME COMMON NAME ACCURACY STATE STATUS* FEDERAL STATUS*
Acmispon helleri Carolina Birdfoot-trefoil High SC-V FSC
Hyla versicolor Northern Gray Treefrog Medium SR ---
Ranunculus micrantha Rock Buttercup Medium SR-P ---
Villosa constricta Notched Rainbow Medium SC ---
* For status definitions, please see the Help and Definitions document at http://www.ncnhp.org/web/nhp/database-search.

There are two occurrence records for Carolina Birdfoot-trefoil in close proximity: one is located along
the powerline right-of-way on the southern boundary of the project area, just west of the Marlowe
Creek Slopes natural heritage area boundary (and just south of the proposed project boundary), and the
other is located just north of Edwin Robertson Road. Northern Gray Treefrog and Rock Buttercup are
also documented as occurring just north of Edwin Robertson Road and the proposed project area. The
occurrence of Notched Rainbow is Iocated upstream and downstream of Edwin Robertson Road in
Storys Creek.

Attached is a description and map of the Marlowe Creek Slopes natural heritage area from the Inventory
of Significant Natural Areas in Person County, NC (LeGrand 2007), based on field work conducted by
NCNHP in 2006. This portion of the Marlowe Creek Slopes natural heritage area is important for the
Basic Mesic Forest (Piedmont Subtype) natural community that has been mapped along Marlowe Creek,
and also for the rich diversity present on the slopes and the wildflowers present.

Please note that the use of Natural Heritage Program data should not be substituted for actual field
surveys if needed, particularly if the project area contains suitable habitat for rare species or important
Project Trace, Country Club Road and Edwin Robertson Road, Roxboro, Person County, NC
ECS Project No. 06.21626
June 6, 2014
Page 2

natural communities, or known occurrences of rare species or natural communities. If rare species are
found, please contact us so that we may update our records.

Feel free to contact me at 919-707-8629 or [e-mail] if you have questions or need
additional information. Sincerely,
Allison Schwarz Weakley, Conservation Planner
NC Natural Heritage Program
M
( Marlowe Creek Slopes
Person County Natural Areas Inventory - o>
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Scale 1:24,000 NC NHP January 2007 / Q
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87
Person County Natural Areas Inventory
MARLOWE CREEK SLOPES
Site Number: 10 Size: 227 acres
Site Significance: Regional Quadrangle: Roxboro
Ownership: private
SIGNIFICANT FEATURES: This natural area contains perhaps the most extensive series of rich
slopes with wildflowers of any site in the county, with excellent examples of Mesic Mixed
Hardwood Forest natural community. However, it is a very diverse site, containing scarce
communities as well, such as Acidic Piedmont Bluff Glade and Basic Mesic Forest, and it also has
a few examples of Piedmont/Coastal Plain Heath Bluff, as well. Several Watch List plants occur
in the site.
LANDSCAPE RELATIONSHIPS: The natural area abuts Hagers Mountain, just to the east.
Lying downstream by about 0.3 mile (to the north) is the Marlowe Creek Bluff natural area. Farther
downstream, about 0.9 mile to the north, is the southern end of the Storys Creek/Marlowe Creek
Swamp.
SITE DESCRIPTION: Along Marlowe Creek and tributaries on the western side of the creek are
extensive mature hardwood forests. The slopes and bluffs are predominantly covered in Mesic
Mixed Hardwood Forest natural community. These slopes lie mainly on acidic soils, but a few areas
are mapped as Wilkes soil, which is somewhat circumneutral, where Basic Mesic Forest is present.
The former community has American beech (Fagus grandifolia) as a common canopy tree, as is
northern red oak (Quercus rubra). The uncommon maidenhair fern (Adiantum pedatum) is present,
as is a good diversity of spring-flowering herbs, such as foamflower (Tiarella cordifolia), mayapple
(Podophyllum peltatum), and liverleaf (Hepatica americana). In some locales, Christmas fern
(Polystichum acrostichoides) is abundant, and black cohosh (Cimicifuga racemosa) is often
common.
One small area of east-facing slopes contain species such as the Watch List leatherwood (Dirca
palustris), wild hydrangea (Hydrangea arborescens), and goat’s-beard (Aruncus dioicus), which
indicate Basic Mesic Forest. The floodplain of Marlowe Creek is somewhat wide on the western
side, and there is a decent-quality Piedmont Small Stream Forest. Tuliptree (Liriodendron
tulipifera) is very common in the canopy, and sycamore (Platanus occidentalis) is numerous.
Spicebush (Lindera benzoin) is a very common shrub, indicating rich soils. One species of interest
in this floodplain is Pursh’s phacelia (Phacelia purshii), a range extension to the east, as other state
records are from the mountain region. Leatherwood also grows in the floodplain.
The natural area has a narrow ridge that contains an excellent but small example of Dry Oak-
Hickory Forest with considerable herb diversity. White oak (Q. alba) is the dominant tree, but some
post oak (Q. stellata) is present. The locally scarce eastern featherbells (Stenanthium gramineum)
is scattered here. Early lowbush blueberry (Vaccinium pallidum) is a dominant shrub, and maple-
88
leaf viburnum (Viburnum acerifolium) and deerberry (Vaccinium stamineum) are very common also.
Several species of legumes, such as a few species of tick-trefoils (Desmodium spp.), are present in
the herb layer. The Watch List American shinleaf (Pyrola americana) grows on a mesic slope
nearby. A few slopes contain Dry-Mesic Oak-Hickory Forest, with mockernut hickory (Carya
alba), American beech, northern red oak, and red maple (Acer rubrum) among the canopy trees.
Sourwood (Oxydendrum arboreum), flowering dogwood (Cornus florida), and black gum (Nyssa
sylvatica) are understory trees. Some blueberries (Vaccinium spp.) are present in the shrub layer,
but the herb layer is rather poor.
In the southern part of the natural area, Marlowe Creek runs through very rocky terrain, with no
floodplain. These rocky and steep slopes are covered with mountain laurel (Kalmia latifolia), often
in very dense tangles; these are Piedmont/Coastal Plain Heath Bluff natural communities. One
narrow east-west ridge east of the creek has a very dry and glade-like south-facing slope. This is
the poorly-known Acidic Piedmont Bluff Glade. There are scattered rocks, and the ground is rather
hard; some eastern red cedars (Juniperus virginiana) are present. There are few shrubs, and the herb
layer is very diverse, with grasses, and a number of legumes and other forbs. Dittany (Cunila
origanoides) is quite common. Other notable herbs include fire pink (Silene virginica), striped
gentian (Gentiana villosa), little ladies-tresses (Spiranthes tuberosa), and cornel-leaf aster
(Doellingeria infirma).
NOTE: Most of the eastern side of Marlowe Creek was not surveyed because of the lack of access.
Thus, the eastern boundary of the natural area is speculative and based solely on aerial photos.
Several powerlines that cut across upper slopes above Marlowe Creek, to the south of the natural
area, contain rare plants; however, as these powerlines do not bisect the site, they are excluded from
the natural area.
PROTECTION AND MANAGEMENT: Most of the site lies in a single private ownership; this
land is leased to a hunt club for hunting during the fall, winter, and spring. As a result, some
ephemeral spring wildflowers, not seen during the June surveys, are presumably present in the area
and might add to the importance of the natural area. There is no known formal protection of the
natural area. Because of its rather extensive size, it is a high priority for protection, such as with
conservation easements. The area, coupled with the adjacent Hagers Mountain, would be suitable
in acreage for a local park or nature preserve. Little management is needed. Timber harvest, which
occurs to the west of the site, should remain outside the boundary of the natural area, as exotic plants
such as Japanese stilt grass (Microstegium vimineum) rapidly invade rich soil sites such as this. A
few jeep/ATV roads run along ridges toward the creek. It is hoped that no new roads or trails will
be made.
NATURAL COMMUNITIES: Mesic Mixed Hardwood Forest, Basic Mesic Forest (Slope variant),
Dry Oak-Hickory Forest (Piedmont Upland variant), Dry-Mesic Oak-Hickory Forest (Piedmont
Upland variant), Acidic Piedmont Bluff Glade, Piedmont/Coastal Plain Heath Bluff, Piedmont Small
Stream Forest.
89
RARE PLANTS: Watch List – leatherwood (Dirca palustris), American shinleaf (Pyrola
americana).
RARE ANIMALS: None known.
REFERENCES:
LeGrand, H. 2006a. Site report: Marlowe Creek Slopes. N.C. Natural Heritage Program, Office
of Conservation and Community Affairs, DENR, Raleigh.
LeGrand, H. 2006b. Site report: Marlowe Creek Slopes – east of creek. N.C. Natural Heritage
Program, Office of Conservation and Community Affairs, DENR, Raleigh.
€lris
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box33726
Raleigh. North Carol in a 27 636-37?6
July 11,2014
Cory Darnell
ECS Carolinas, LLP
9001 Glenwood Avenue
Raleigh, NC 27617
Re: Project Trace- Person County, NC
Dear Mr. Darnell:
This letter is to inform you that a list of all federally-protected endangered and threatened species
with known occurences in North Carolina is now available on the U.S. Fish and Wildlife
Service's (Service) web page at http://www.fws.gov/raleigh. Therefore, if you have projects that
occur within the Raleigh Field Office's area of responsibility (see attached county list), you no
longer need to contact the Raleigh Field Office for a list of federally-protected species.
Our web page 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), and a list of federal species of concern' that are known to occur in
each county in North Carolina.
Section 7 of the Act requires that all federal agencies (or their designated non-federal
representative), in consultation with the Service, insure that any action federally authorized,
funded, or canied out by such agencies is not likely to jeopardizethe continued existence of any
federally-listed endangered or threatened species. A biological assessment or evaluation may be
prepared to fulfill that requirement and in determining whether additional consultation with the
Service is necessary. In addition to the federally-protected species list, information on the
species' life histories and habitats and information on completing a biological assessment or
evaluation and can be found on our web page at http://www.fws.gov/raleigh. Please check the
web site often for updated information or changes.
I Th.trrr"federal speciesofconcern"referstothosespecieswhichtheServicebelievesmightbeinneedof
concentrated conservation actions. Federal species ofconcern 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.
If your project contains suitable habitat for any of the federally-listed species known to be
present within the county where your project occurs, the proposed action has the potential to
adversely affect those species. As such, we recommend that surveys be conducted to determine
the species' presence or absence within the project area. The use of North Carolina Natural
Heritage program data should not be substituted for actual field surveys.
If you determine that the proposed action may affect (i.e., likely to adversely affect or not likely
to adversely affect) a federally-protected species, you should notify this office with your
determination, the results of your surveys, survey methodologies, and an analysis of the effects
of the action on listed species, including consideration of direct, indirect, and cumulative effects,
before conducting any activities that might affect the species. If you determine that the proposed
action will have no effect (i.e., no beneficial or adverse, direct or indirect effect) on federally
listed species, then you are not required to contact our office for concurrence (unless an
Environmental Impact Statement is prepared). However, you should maintain a complete record
of the assessment, including steps leading to your determination of effect, the qualified personnel
conducting the assessment, habitat conditions, site photographs, and any other related articles.
With regard to the above-referenced project, we offer the following remarks. Our comments are
submitted pursuant to, and in accordance with, provisions of the Endangered Species 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 sectionT(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
Iisted 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. In addition, we recommend maintaining
natural, vegetated buffers on all stleams and creeks adjacent to the project site.
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).
We hope you find our web page useful and informative and that following the process described
above will reduce the time required, and eliminate the need, for general correspondence for
species' lists. If you have any questions or comments, please contact John Ellis of this office at
[phone] ext.26.
Sincerely,
t''-) t .(U- t/-^t'
Pofe Benjamin
Field Supervisor
List of Counties in the Service's Raleigh Field Office Area of Responsibility
Alamance
Beaufort
Bertie
Bladen
Brunswick
Camden
Carteret
Caswell
Chatham
Chowan
Columbus
Craven
Cumberland
Cunituck
Dare
Duplin
Durham
Edgecombe
Franklin
Gates
Granville
Greene
Guilford
Halifax
Hamett
Hertford
Hoke
Hyde
Johnston
Jones
Lee
Lenoir
Martin
Montgomery
Moore
Nash
New Hanover
Northampton
Onslow
Orange
Pamlico
Pasquotank
Pender
Perquimans
Person
Pitt
Randolph
Richmond
Robeson
Rockingham
Sampson
Scotland
Tyrrell
Vance
Wake
Warren
Washington
Wayne
Wilson
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
July 28, 2016
Paul Stephens IV
ECS Carolinas LLP
9001 Glenwood Avenue
Raleigh, NC 27617
Re: Project Trace — Person County, NC
Dear Mr. Stephens:
This letter is to inform you that a list of all federally protected endangered and threatened species
with known occurrences in North Carolina is now available on the U.S. Fish and Wildlife
Service's (Service) web page at http://www.ftvs.-0ov/raleigh. Therefore, if you have projects that
occur within the Raleigh Field Office's area of responsibility (see attached county list), you no
longer need to contact the Raleigh Field Office fora list of federally -protected species.
Our web page 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), and a list of federal species of concerns that are known to occur in
each county in North Carolina.
Section 7 of the Act requires that all federal agencies (or their designated non-federal
representative), in consultation with the Service, insure that any action federally authorized,
funded, or carried out by such agencies is not likely to jeopardize the continued existence of any
federally -listed endangered or threatened species. A biological assessment of evaluation may be
prepared to fulfill that requirement and in determining whether additional consultation with the
Service is necessary. In addition to the federally -protected species list, information on the
species' life histories and habitats and information on completing a biological assessment or
evaluation and can be found on our web page at http://www.fws.gov/raleigh. Please check the
web site often for updated information or changes.
t The tenn "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.

If your project contains suitable habitat for any of the federally -listed species known to be
present within the county where your project occurs, the proposed action has the potential to
adversely affect those species. As such, we recommend that surveys be conducted to determine
the species' presence or absence within the project area. The use of North Carolina Natural
Heritage program data should not be substituted for actual field surveys.
If you determine that the proposed action may affect (i.e., likely to adversely affect or not likely
to adversely affect) a federally -protected species, you should notify this office with your
determination, the results of your surveys, survey methodologies, and an analysis of the effects
of the action on listed species, including consideration of direct, indirect, and cumulative effects,
before conducting any activities that might affect the species. If you determine that the proposed
action will have no effect (i.e., no beneficial or adverse, direct or indirect effect) on federally
listed species, then you are not required to contact our office for concurrence (unless an
Environmental Impact Statement is prepared). However, you should maintain a complete record
of the assessment, including steps leading to your determination of effect, the qualified personnel
conducting the assessment, habitat conditions, site photographs, and any other related articles.
With regard to the above -referenced project, we offer the following remarks. Our comments are
submitted pursuant to, and in accordance with, provisions of the Endangered Species 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. In addition, we recommend maintaining
natural, vegetated buffers on all streams and creeks adjacent to the project site.
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).

We hope you find our web page useful and informative and that following the process described
above will reduce the time required, and eliminate the need, for general correspondence for
species' lists. If you have any questions or comments, please contact John Ellis of this office at
[phone] ext. 26.
Sincerely,
Pete Benjamin
Field Supervisor

North Carolina Department of Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Pat McCrory Office of Archives and History
Secretary Susan Kluttz Deputy Secretary Kevin Cherry
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

June 12, 2014

Cory Darnell
ECS Carolinas, LLP
9001 Glenwood Avenue
Raleigh, NC 27617-7505

Re: Project Trace, Country Club Road and Edwin Robertson Road, Roxboro, 06-21626, Person County,
ER 14-1122

Dear Mr. Darnell:

Thank you for your letter of May 22, 2014. We have reviewed the project referenced above and offer the
following comments.
The project tract consists of a large ridge system located between two second to third order streams. This
system contains relatively long linear ridgetops, ridgetoes, and several likely springheads. The topography is
consistent with other settings within the region that contain a high frequency of archaeological resources,
particularly prehistoric sites. While there are no previously recorded archaeological sites noted within the tract
at present, the area has never been surveyed for archaeological resources. Given the nature of this landscape
and the high probability of prehistoric remains, we recommend a Phase I archaeological survey of the tract. As
a result, we recommend the following conditions for this application:

Prior to initiation of any ground disturbing activities within the project area, the applicant shall arrange
for an archaeological survey of the entire project area (approximately 675.55 acres). The purpose of
this survey will be to locate archaeological sites and make recommendations regarding the eligibility
status of each site in terms of the National Register of Historic Places (NRHP). If a site is determined
to be eligible for the NRHP the applicant shall determine whether the site will be adversely affected by
the project activities; and, if so, develop and implement an appropriate mitigation plan. Two copies of
all resulting archaeological reports, as well as one copy of the North Carolina site forms, should be
forwarded to the Office of State Archaeology through this office for review and comment as soon as
they are available and in advance of any construction or ground disturbance activities.

A list of archaeological consultants who have conducted or expressed an interest in contract work in North
Carolina is available at www.archaeology.ncdcr.gov/ncarch/resource/consultants.htm. The archaeologists
listed, or any other experienced archaeologist, may be contacted to conduct the recommended survey. All
activities associated with the archaeological investigations shall be coordinated with the Office of State
Archaeology prior to beginning any archaeological fieldwork.

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 919-807-6579 or renee.gledhill-
[e-mail]. In all future communication concerning this project, please cite the above referenced
tracking number.
Sincerely,

Ramona M. Bartos