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HomeMy WebLinkAbout20191756 Ver 3_H - PETS Report_20200605CAROLINA WETLAND SERVICES, INC. 550 E. Westinghouse Blvd. Charlotte, NC 28273 704-527-1177 (office) 704-527-1133 (fax) June 5, 2020 Mr. Rob Stout Stantec 2127 Ayrsley Town Blvd, Suite 300 Charlotte, NC 28273 Subject: Protected Species Habitat Assessment Report Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements Mecklenburg County, North Carolina CWS Project No. 2019-0234 Dear Mr. Stout, Stantec has contracted Carolina Wetland Services, Inc. (CWS) to provide a protected species habitat assessment for the Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements project. The Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements project limits consist of an approximately 60-foot wide, 8,200-foot long corridor that begins northeast of the University City Boulevard and East W.T. Harris Boulevard intersection, and extends northward along Toby Creek to just southwest of the North Tryon Street and the East Mallard Creek Church Road intersection. Just south of the North Tryon Street and East Mallard Creek Church Road intersection there is an additional trunk that branches off of the main corridor that will be used for a water reuse line. This trunk is approximately 40-feet wide and 10,400-feet long, and extends northeast along Mallard Creek to North Tryon Street in Charlotte, North Carolina (Figure 1). Methods In -office Desktop Review To determine which protected species are listed as occurring or potentially occurring within the project vicinity and prior to conducting the on -site field investigation, CWS consulted the United States Fish and Wildlife Service (USFWS) Endangered and Threatened Species and Species of Concern by County for North Carolina online database for Mecklenburg County'. In addition, CWS performed a data review using the North Carolina Natural Heritage Program (NCNHP) Data Explorer2 on June 5, 2020 to determine if any record occurrences of federally -listed, candidate endangered, threatened species, or critical habitat are located within the project limits. United States Fish and Wildlife Service, Raleigh Field Office. Accessed August 8, 2019. Endangered and Threatened Species and Species of Concern by County for North Carolina. https://www.fws.gov/raleigh/species/cntylist/mecklenburg.htmi 2 North Carolina Natural Heritage Data Explorer. Accessed August 8, 2019. https://ncnhde.natureserve.org/. NORTH CAROLINA - SOUTH CAROLINA WWW.CWS-INC.NET Page 1 of 8 Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements June 5, 2020 Protected Species Assessment Report CWS Project No. 2019-0234 Typical habitat requirements for listed species was discerned from multiple USFWS3 and NCNHP4 online resources including, but not limited to, specific USFWS species profiles, recovery plans, NCNHP's Guide to Federally Listed Endangered and Threatened Species of North Carolina, and List of the Rare Plant Species of North Carolina. United States Department of Agriculture - Natural Resources Conservation Service (USDA-NRCS) Web Soil Survey of Mecklenburg County5 and aerial imagery were also reviewed for potential habitat communities of listed species within the project vicinity (Figures 2 and 3). Field Survey CWS scientists Megan Shelton, WPIT6, Project Scientist, Kerry Wright, Project Scientist, Arnie Hoy, Staff Scientist III, and Ian Dunning, Staff Scientist I conducted a pedestrian habitat assessment of the project area on August 20, October 22 and 23, 2019, March 12, 2020, and April 17, 2020. Potential habitats for potentially occurring federally -protected species that were identified during the desktop review were assessed in the field for the quality of physical and/or biological features essential to the conservation of the applicable species. Additionally, during the pedestrian habitat assessment, areas were reviewed for applicable federally protected species. However, formal surveys were not conducted for the occurence of protected species. Identification references for natural communities include the National Land Cover Database (2011)7. Results Based on the NCNHP data explorer review, there are two occurrences of Schweinitz's sunflower within a one -mile radius of the project limits (Attachment A). The USFWS lists seven federally protected species for Mecklenburg County (Table 1). An official species list has not been obtained from the USFWS Asheville Field Office. 3 U.S. Fish and Wildlife Service. 2006. Optimal Survey Windows for North Carolina's Federally Threatened and Endangered Plant Species. http://www.fws.gov/noes/es/plant_Survey.htmi. Accessed August 8, 2019. 4 Buchanan, M.F. and J.T. Finnegan. 2010. Natural Heritage Program List of the Rare Plant Species of North Carolina. NC Natural Heritage Program, Raleigh, NC. Accessed from https://www.fws.gov/raleigh/species/cntylisttnc_counties.html 5 United States Department of Agriculture, 2017. Web Soil Survey of Mecklenburg County, North Carolina. Accessed 8/8/19. Source: https://websoilsurvey.nres.usda.gov/app/HomePage.htm 6 Wetland Professional in Training, The Society of Wetland Scientist Professional Certification Program MLRC. National Land Cover Database, 2011. https://www.mric.gov/nlcdll_leg.php Page 2 of 8 Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements June 5, 2020 Protected Species Assessment Report CWS Project No. 2019-0234 Table 1. Unofficial List of Federally -Protected Species Potentially Occurring within the Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements, Mecklenburg County, NC. Major Group Scientific Name Common Name Federal Status* Record Status Plant Helianthus Schweinitz's E Current schweinitzii sunflower Plant Echinacea Smooth coneflower E Current laevigata Plant Rhus michauxii Michaux's sumac E Current Animal Lasmigona Carolina heelsplitter E Current decorata Animal Bombus afints Rusty -patched E Historic bumble bee Animal Myotis Northern -long-eared T Current septentrionalis bat Animal Haliaeetus Bald eagle BGPA Current leucocephalus * E - Endangered, T - Threatened, BGPA - Bald and Golden Eagle Protection Act Three terrestrial community types were identified within the project area during the field survey. These community types consist of deciduous, herbaceous and low intensity development (Figure 3). Of the identified on -site community types, the forested and herbaceous areas are considered potential habitat for federally threatened or endangered species that could potentially occur within the project limits. A brief description of each species habitat requirements and determination of effect findings are listed below by species. Schweinitz's sunflower (Helianthus schweinitzii) Habitat Description: Schweinitz's sunflower is a perennial herb with yellow rays and yellow centers. They can reach heights of five feet. Populations are limited to the piedmont of North and South Carolina. It has been listed as an Endangered species under the ESA since 1991.8 The typical habitat for this plant includes roadsides, old pastures, transmission line right-of-ways, open areas, either natural or human -maintained habitats, or edges of upland woods. Major characteristics of soils associated with suitable Schweinitz's sunflower habitat include thin soils, soils on upland interstream flats or gentle slopes, soils that are clay like in both composition and texture (and often with substantial rock fragments), soils that have a high shrinkage swell capacity, and those which vary over the course of the year from very wet to very dry. Biological Analysis: A NCNHP data record review revealed that there are two occurrences within one mile of the project limits. The herbaceous areas throughout the project limits consist of the Monocan loam soil series, which is not conducive to Schweinitz's sunflower habitat. In addition, these areas are heavily maintained through the practices of mowing and s United States Fish and Wildlife Services. 1991. Endangered and Threatened Wildlife and Plants; Helianthus schweinitzii (Schweinitz's sunflower) Determined to be Endangered. hftp://ecos.fws.gov/docs/f`ederal_register/frl852.pdf. Page 3 of 8 Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements June 5, 2020 Protected Species Assessment Report CWS Project No. 2019-0234 pesticide application, which is not supportive of Schweinitz's sunflower (Photographs 3 and 5). The on -site forested areas do not provide adequate sunlight and do not contain the proper soil series to support Schweinitz's sunflower (Photographs 1, 9 and 10). On October 22, 2019, CWS visited a nearby reference population, and noted that all plant parts of the Schweinitz's sunflower were identifiable and the plant was approximately five feet tall (Photograph 13). No individuals of Schweinitz's sunflower were observed in the study area during the field review. As the survey was conducted during the optimal survey window of late August to October and mature vegetation was present, Schweinitz's sunflower would have been seen if present. Therefore, because no individuals of Schweinitz's sunflower were observed during the optimal survey window, CWS concludes that this project will have no effect on the Schweinitz's sunflower. Smooth coneflower (Echinacea laevigata) Habitat Description: Smooth coneflower is a tall, perennial herbaceous plant found in areas with abundant sunlight where competition in the herbaceous layer is minimal. It has been federally listed as Endangered under the ESA since 1992.9 Typical habitat for this plant includes meadows, open woodlands, the ecotonal regions between meadows and woodlands, cedar barrens, dry limestone bluffs, clear cuts, and roadside and utility rights -of -way. In North Carolina, the species normally grows in magnesium- and calcium- rich soils associated with gabbro and diabase parent material, and typically occurs in Iredell, Misenheimer, and Picture soil series. It grows best where there is abundant sunlight, little competition in the herbaceous layer, and periodic disturbances (e.g., regular fire regime, well-timed mowing, careful clearing) that prevents encroachment of shade -producing woody shrubs and trees. On sites where woody succession is held in check, it is characterized by a number of species with prairie affinities. Biological Analysis: A NCNHP data record review revealed that there are no current occurrences for this species within the project limits, or within a one -mile radius of the project (Attachment A). The majority of the project limits are forested, which does not provide the abundant sunlight the smooth coneflower requires. In addition, Iredell, Misenheimer, and Picture soil series commonly associated with the smooth coneflower are not found within the project limits.10 Due to the lack of habitat and known occurrences, CWS concludes that this project will have no effect on smooth coneflower. Michaux's sumac (Rhus michauxii) Habitat Description: Michaux's sumac is a rhizomatous shrub. It is densely hairy with compound leaves exhibiting evenly -serrated leaflets. Flowers are small, greenish to white, in terminal clusters. Fruits are red drupes produced from August to October. It has been listed as an Endangered species under the Endangered Species Act (ESA) since 1989.11 It is y United States Fish and Wildlife Services. 1992. Endangered and Threatened Wildlife and Plants; Echinacea laevigata (Smooth Coneflower) Determined to be Endangered. http://ecos.fws.gov/docs/federal_ register/fr2140.pdf. 10 United States Department of Agriculture, 2018. Web Soil Survey of Mecklenburg County, North Carolina. Accessed 8/8/19 Source: https://websoilsurvey.nres.usda.gov/app/HomePage.htm 11 United States Fish and Wildlife Services. 1989. Endangered and Threatened Wildlife and Plants; Determination of Endangered Page 4 of 8 Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements June 5, 2020 Protected Species Assessment Report CWS Project No. 2019-0234 found on the coastal plains of Virginia to Florida, with most populations occurring in North Carolina. It prefers sandy or rocky open woods with basic soils, as well as, highway right-of-ways, roadsides, or edges of artificially -maintained clearings. Biological Analysis: A NCNHP data record review revealed that there are no current occurrences for this species within the project limits, or within a one -mile radius of the project (Attachment A). Disturbed open areas conducive to early -succession species are not present in the project area. The Monacan loam soil series that covers the majority of the site is too acidic to provide suitable habitat for Michaux's sumac. Additionally, there are no current records of this species within Mecklenburg County12. Due to the lack of habitat and known occurrences, CWS concludes that this project will have no effect on Michaux's sumac. Carolina heelsplitter (Lasmigona decorata) Habitat Description: The Carolina heelsplitter was historically known from several locations within the Catawba and Pee Dee River systems in North Carolina and the Pee Dee and Savannah River systems, and possibly the Saluda River system in South Carolina. In North Carolina, the species is now known only from a handful of streams in the Pee Dee and Catawba River systems. The species exists in very low abundances, usually within 6 feet of shorelines, throughout its known range. The general habitat requirements for the Carolina heelsplitter are shaded areas in large rivers to small streams, often burrowed into clay banks between the root systems of trees, or in runs along steep banks with moderate current. Recently, the Carolina heelsplitter has been found in sections of streams containing bedrock with perpendicular crevices filled with sand and gravel, and with wide riparian buffers." Biological Analysis: There are ten perennial streams on -site, including Mallard Creek and Toby Creek. This portion of Mallard Creek has been severely impaired by stormwater runoff from the surrounding university14. The runoff has resulted in high nutrient levels and high turbidity, which is not supportive of the Carolina heelsplitter. Toby Creek is severely incised and highly turbid, and contains large amounts of silt throughout the stream, which is not conducive to Carolina heelsplitter habitat. In addition, the other perennial streams that drain into Toby and Mallard Creek are heavily embedded with silt and trash, which is not suitable habitat for Carolina heelsplitter. All of the on -site perennial streams are connected to downstream waters via large culverts, which is also not conducive for Carolina heelsplitter (Photographs 2, 4, 6, 7, 8, and 11). Additionally, the NCNHP data record review revealed that there are no current occurrences for this species within the Status for Rhus michauxii (Michawes sumac). http://ecos.fws.gov/docs/federal_ register/fr1601.pdf. 12 USFWS Michaux's Sumac Recovery Plan; https://ecos.fws.gov/docs/recovery_plan/930430.pdf 13 NCDOT TE Animal Habitat Descriptions. 2015. https://con nect. ncdot.gov/resources/Environmental/Compliance%20G u ides%20and%20 Procedu resfTE%20Ani mal %20 Habitat% 20Descri ptions%20Mar_6_2015. pdf 14hftps://files. nc.gov/ncdegNVater%20Quality/Planning/BPU/BPU/Yadkin/Yadkin%20Plans/2010%20PIan/6_03040105%20Rocky%2 OR-2010.pdf Page 5 of 8 Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements June 5, 2020 Protected Species Assessment Report CWS Project No. 2019-0234 project limits, or within a one -mile radius of the project (Attachment A). Therefore, CWS concludes that this project will have no effect the Carolina heelsplitter. Rusty Patched Bumble Bee (Bombus affinis) The Rusty patched bumble bee was listed as Endangered under the ESA in January 2016.15 Rusty patched bumble bees once occupied grasslands and tallgrass prairies of the Upper Midwest and Northeast, but most grasslands and prairies have been lost, degraded, or fragmented by conversion to other uses. According to USFWS guidance, "the rusty patched bumble bee population has declined by approximately 90% or more. There are currently records of Bombus affinis in isolated places within 13 states and 1 providence since 2000. In these areas, surveys should only be completed by qualified biologists under the guidance of the federal recovery/scientific permit under section 10(a)(1)(B) of the ESA. These surveyors must also meet all applicable state permitting and reporting requirements. The presence of Bombus affinis has been broken down into three zones. A high potential zone provides a reasonable basis for describing where the species is likely to be present and where federal agencies and others should consult with Fish and Wildlife Services to evaluate the potential effects of their actions. A low potential zone buffers a high potential zone and are much less likely to support existing populations. Scientists are hopeful that some of these low potential areas may contain the bee, and they recommend that surveyors obtain a scientific recovery permit. The third zone is the unoccupied zone. Scientists believe that the likelihood of finding the species in these areas is so low that they do not recommend scientific recovery permits, unless a Bombus affinis may have accidentally been collected.16 According to USFWS' Rusty Patched Bumble Bee Interactive Map, Mecklenburg County is located within an unoccupied zone. Therefore, the proposed project will have no effect on the Rusty -patched bumble bee. Northern long-eared bat (Myotis septentrionalis) The northern long-eared bat (NLEB) is one of the species of bats most impacted by the white -nose syndrome disease. Summer habitat (roosting habitat) of the NLEB includes forests and woodlots containing live trees and/or dead snags greater than three inches diameter at breast height with cavities or crevices. Winter habitat (hibernacula) of the NLEB includes caves, mines, rocky areas, or structures that mimic similar conditions such as culverts greater than 48-inch in diameter." The NLEB was listed as Threatened (T) on April 2, 2015. The forested areas within the property are potential habitats for the NLEB. A Standard Local Operating Procedure for Endangered Species Act Compliance (SLOPES) was established for NLEB between the USFWS Asheville and Raleigh Ecological Offices and the United States Army Corps of Engineers (USACE), Wilmington District, on January 31, 2017.18 This SLOPES defines how the USACE will make determinations of effect to the NLEB on projects in which the USACE is the lead federal agency. Alternative Local Procedure 2 (ALP 2) applies for the Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements project as the action 15 United States Fish and Wildlife Services. https://www.fws.gov/midwestlendangered/insects/rpbb/pdf/Survey_Protocols_RPBB_12April2019. pdf 18 United States Fish and Wildlife Services. https://www.fws.gov/midwestlendangered/insects/rpbb/index.html 17 United States Fish and Wildlife Service. 2016.4(d) Rule for the Northern Long -Eared Bat; Final rule. hftps://www.gpo.gov/fdsys/pkg/FR-2016-01-14/pdf/2016-00617.pdf 18 USACE http://saw-reg.usace.army.mil/NLEB/1-30-17-signed_NLEB-SLOPES&apps.pdf Page 6 of 8 Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements June 5, 2020 Protected Species Assessment Report CWS Project No. 2019-0234 area is within range of the NLEB,19 the action area is located outside of a red 12-digit HUC as defined by the Asheville Ecological Services Field Office,20 and consultation by the USACE is required on other listed species or critical habitat. The final 4(d) rule exempts incidental take of NLEB associated with activities that occur greater than 0.25 miles from a known hibernaculum site and greater than 150 feet from a known, occupied maternity roost from June 1-July 31. In accordance with ALP 2 and the final 4(d) rule (effective as of February 16, 2016), any incidental take that may result from associated activities is exempt under the 4(d) rule. Therefore, this project is exempt under the 4(d) rule. Bald eagle (Haliaeetus leucocephalus) The Bald and Golden Eagle Protection Act,21 enacted in 1940, prohibits anyone without a permit issued, from "taking" bald eagles, including their parts, nests, or eggs. Habitat for the bald eagle includes cliffs and forested areas typically within 1.0 mile of estuaries, large lakes, reservoirs, rivers, seacoast, and as they become more abundant, stands of undisturbed forest. A desktop-GIS assessment of the project study area, as well as, the area within a 1 mile radius of the project limits, was performed on August 8, 2019 using 2019 color aerials. No water bodies large enough or sufficiently open to be considered potential feeding sources were identified. Since there was no foraging habitat within the review area, a survey of the project study area and the area within the project limits was not conducted. Additionally, a review of the NCNHP database on August 8, 2019 revealed no known occurrences of this species within 1.0 mile of the project study area. Due to the lack of habitat and known occurrences, CWS concludes that this project will have no effect on this species. Summary Based on the literature search and the results of the on -site assessment for suitable habitat of federally -protected endangered, and threatened species, suitable habitat was not observed within the project limits for smooth coneflower, Michaux's sumac, bald eagle, or Carolina heelsplitter. Marginal habitat was observed for Schweinitz's sunflower. The project area is not located within the currently occupied range of the rusty -patched bumble bee. CWS has concluded that activities within the project area will not directly or indirectly jeopardize the continued existence of Schweinitz's sunflower, smooth coneflower, Michaux's sumac, bald eagle, rusty -patched bumble bee, and Carolina heelsplitter. Additionally, based on the project area location, no tree removal activities will occur within a 150-foot radius of a known, occupied NLEB maternity roost from June 1-July 31 and no trees will be removed within 0.25 miles of a known hibernaculum at any time of year. Therefore, any incidental take on NLEB that may result from associated activities is exempt under the 4(d) rule and notifications will follow the SLOPES agreement22. Biological determinations requirements for federally protected species are summarized in Table 2. 19 The U.S. Fish and Wildlife Service (USFWS) 2016. https://www.fws.gov/midwest/endangered/mammals/nieb/pdf/WNSZone.pdf 20 The U.S. Fish and Wildlife Service (USFWS) 2016. Northern Long -Eared Bat. 21 https://www.fws.gov/midwest/MidwestBird/eaglepermits/bagepa.html 22 http://www.fws.gov/asheville/htmis/project_review/NLEB_in_WNC.htmi Page 7 of 8 Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements June 5, 2020 Protected Species Assessment Report CWS Project No. 2019-0234 Table 2. Biological Determination Requirements Summary Table for Federally Protected Species Federal Effect on Listed Biological Scientific Name Common Name Status* Species Determination Required Helianthus schweinitzii Schweinitz's sunflower E No Effect No Echinacea laevigata Smooth coneflower E No Effect No Rhus michauxii Michaux's sumac E No Effect No Lasmigona decorata Carolina heelsplitter E No Effect No Bombus affinis Rusty -patched bumble bee E No Effect No Myotis septentrionalis Northern -long-eared bat T Exempt Yes** Haliaeetus Bald eagle BGPA No Effect No leucocephalus * E - Endangered, T - Threatened, BGPA - Bald and Golden Eagle Protection Act ** - Required in accoradnce with SLOPES, ALP 2 agreement. A biological assessment was not conducted for this project. All biological determinations of effect represent the best professional opinion of CWS and are not official determinations of effect. It is the responsibility of the lead federal agency to render an official determination of effect. Should the lead federal agency agree with CWS's initial findings of no effect, then no USFWS consultation is required to comply with Section 7 of the Endangered Species Act. Should the lead federal agency's determination of effect differ from the findings of CWS, formal or informal consultation with USFWS may be required. Thank you for the opportunity to provide these services on this important project. Please do not hesitate to contact Megan Bollero at 757-576-6433 or megan@cws-inc.net should you have any questions or comments regarding this report. Sincerely, (firc?,_ B,&,,, Megan Bollero, WPIT Project Scientist Aliisa Harjuniemi, PWS Senior Project Manager Attachments: Figure 1: USGS Topographic Map Figure 2: USDA-NRCS Web Soil Map of Mecklenburg County Figure 3: Aerial Map Attachment A: NCNHP Data Review Report Attachment B: Representative Photographs (1-12) Page 8 of 8 2a � c - [] yc P " 4 f Elem. y 5 - - .. V $,per 1- CRr�kUS f 17 2 -Y r' c fl 9adr COinsital AQXI _ 44 ga r•{ iJV i'Ji RS+TV Rf? C.1rolInaN f 13 t� MARL J s 4-1 U at � P Legend Toby Creek Outfall Improvements (13 ac.) Mallard Creek Reuse Line Extension (12 ac.) "' 2,000 1,000 0 2,000 Feet REFERENCE: USGS 7.5 MINUTE TOPOGRAPHIC QUADRANGLE(S): HARRISBURG, NC (2017). - SCALE: 1 inch = 2,000 feet DATE: 6/5/2020 USGS Topographic Map FIGURE NO. 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Secretary ■�-ion NATURAL AND CULTURAL RESOURCES a Walter Clark, Director, Land and Water Stewardship NCNHDE-12161 June 5, 2020 Megan Bollero Carolina Wetland Services 550 East Westinghouse Blvd Charlotte, INC 28273 RE: Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements Dear Megan Bollero: 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: httgs://www.fws.gov/offices/Di rectory/ListOffices.cfm?statecode=37. Please note that natural heritage element data are maintained for the purposes of conservation planning, project review, and scientific research, and are not intended for use as the primary criteria for regulatory decisions. Information provided by the NCNHP database may not be published without prior written notification to the NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of NCNHP data may not be redistributed without permission. Also please note that the INC Natural Heritage Program may follow this letter with additional correspondence if a Dedicated Nature Preserve, Registered Heritage Area, Clean Water Management Trust Fund easement, or an occurrence of a Federally -listed species is documented near the project area. If you have questions regarding the information provided in this letter or need additional assistance, please contact Rodney A. Butler at rod ney.butler(a)ncdcr.aov or 919-707-8603. Sincerely, INC Natural Heritage Program DEPARIMEN 1 GF NATURAL AND CULTURAL RESOURCES 121 W JONES STREET. RALEIGH. NC 27603 • 1651 MAIL SERVICE CENTER. RALEIGH. 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View of unsuitable habitat for Schweinitz's sunflower, Smooth coneflower, and Michuax's sumac, Photograph 2. View of unsuitable habitat for Carolina heelsplitter (Toby Creek), facing south (8.20.19). Photopage 1 of 6 Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements Attachment A: Photopage June 5, 2020 CWS Project No. 2019-0234 Photograph 3. View of unsuitable habitat for Schweinitz's sunflower, facing south. Photograph 4. View of unsuitable habitat for Carolina heelsplitter, facing west. Photopage 2 of 6 Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements June 5, 2020 Attachment A: Photopage CWS Project No. 2019-0234 Photograph 5. View of unsuitable habitat for Schweinitz's sunflower, facing north. Photograph 6. View of unsuitable habitat for Carolina heelsplitter, facing west. Photopage 3 of 6 •. y } -`\.- � i _ �4.:t. .'1 �` .M ::fir .�r ��i 'k� ♦i�y� •• sue•- M _ � � ' 611 >n AW AM 10. 'k . � .. 'r�.. � }' 1 � _ i � - tip-• :. 1 �r 0 - �+�-�� ,T_�- •t2 ��. '- ���: � -: i�_.;�--ram+' .r� ��� � -Yt�� ���-_- � -� '� '.}� 'tl 1l �Uf. �b _.. . _ =�. � •fir":'-�.: ~��,. � '��1�� • I.I • F.I... •.�i'.` 1<1`'' i s 7Lf 1 ' j / !. +-` 41 e ��'—• is �.'_� 4j .� �`:• .v -iE_ k �: , pppp ` }�=+Y�'Iy.= rye :. : iyy r.yl., } tv � VT IMA 444. ,.r. ' �-i � � •. -; � Fix `�,,. � _ 1, �.ti ,,�- , ,ram.• � �,:�;� �; �a�! ,'f-�.,�►. Mallard Creek Reuse Line Extension and Toby Creek Outfall Improvements June 5, 2020 Attachment A: Photopage CWS Project No. 2019-0234 Photograph 11. View of unsuitable habitat for Carolina heelsplitter, facing northwest. Photograph 12. View of Schweinitz's sunflower at nearby reference population. Photopage 6 of 6