20201142 Ver 1_9_Fig_7_USFW_NCSHPO_03.26.20 (2)_20200904

P I L 0 T ENVI RON M E N T A L. I N C
February 13, 2020
Revised March 26, 2020
Mr. Matthew McGovern
Sugar Solar, LLC
880 Apollo Street, Suite 333
El Segundo, California 90245
Reference: Limited NEPA Assessment
Sugar Solar
Approximate 752-Acre Tract
Country Club Road
Yadkinville, Yadkin County, North Carolina
Pilot Project 3680.2
Dear Mr. McGovern:
Pilot Environmental, Inc. (Pilot) is pleased to submit this report of the Limited National
Environmental Policy Act (NEPA) Assessment forthe approximate 752-acre tract located east and
west of Country Club Road in Yadkinville, Yadkin County, North Carolina. The site is depicted on
the attached U.S. Geological Survey (USGS) Topographic Map (Drawing 1) and Aerial Photograph
Map (Drawing 2).
Background
Congress passed the Endangered Species Act (ESA or "Act") in 1973. The purpose of the ESA is to
protect and recover imperiled species and the ecosystems upon which they depend. It is
administered by the U.S. Fish and Wildlife Service (USFWS) and the Commerce Department's
National Marine Fisheries Service (NMFS). The USFWS has primary responsibility for terrestrial
and freshwater organisms, while the responsibilities of the Commerce Departments NMFS are
mainly marine wildlife. Under the ESA, federally protected species may be listed as either
endangered or threatened. "Endangered" means a species is in danger of extinction throughout
all or a significant portion of its range. "Threatened" means a species is likely to become
endangered within the foreseeable future. All species of plants and animals, except pest insects,
are eligible for listing as endangered or threatened. For the purposes of the ESA, Congress
defined species to include subspecies, varieties, and, for vertebrates, distinct population
segments.
The N.C. State Historic Preservation Office (NCSHPO) was created by the United States
government in 1966 under Section 106 of the National Historic Preservation Act (NHPA). The
purposes of the SHPO include surveying and recognizing historic properties, reviewing
nominations for properties to be included in the National Register of Historic Places, reviewing
undertakings for the impact on the properties, as well as supporting federal organizations, state
and local governments, and the private sector.
PO Box 128, Kernersville, NC 27285
www.pilotenviro.com

Limited NEPA Assessment
Pilot Project 3680.2
March 26, 2020
Scope of Services
Pilot was contracted to perform a Limited NEPA Assessment for the approximate 752-acre tract
located east and west of Country Club Road in Yadkinville, Yadkin County, North Carolina. The
site consists of portions or the entirety of sixteen parcels identified by the Yadkin County
Geographical Information System (GIS) as Parcel Identification Numbers (PINS) 5818153663,
581800328577, 581800140879, 581800049419, 581800048150,581800038619, 580800926184,
5818114449, 581800218450, 5808916149, 581700283931, 581700174078, 581700381065,
581700372302, 581700362604, and 581700367810. The site is being evaluated for proposed
development with a solar farm. The purpose of the Limited NEPA Assessment is to identify the
potential for impact to federally listed threatened and endangered species and historic/cultural
resources. The scope of services included a field reconnaissance, a review of available literature,
and a submittal of relevant site information to solicit comments from the USFWS and the
NCSHPO. Pilot was provided with a Google Earth digital file of the site boundary.
Pilot was also contracted to perform a Phase I Environmental Site Assessment and a Wetland
Delineation on the site. Details of these investigations are included in separate reports.
Site Reconnaissance
Pilot personnel conducted the site visits on July 27-28, 2018, December 26-28, 2018 and January
9, 2019, and October 24, 2019. The site contains agricultural fields, recently timbered land, and
wooded land. Several agricultural buildings and residences are located on the eastern and
western portions of the site. Overhead powerlines and the associated utility easement cross the
central portion of the site.
The agricultural fields were fallow or planted with tobacco and soybeans during our most recent
site visit. The majority of the agricultural fields abut the wooded land with little to no transition
zone. The limited areas with transition zones are dominated by sumac, pokeweed, broomsedge,
goldenrod, blackberry, and greenbrier. The fallow fields and recently timbered land were
vegetated with scrub shrub vegetation and mixed grasses including various hardwood saplings,
sumac, pokeweed, blackberry, greenbrier, ryegrass, goldenrod, broomsedge, pigweed,
johnsongrass, coffeeweed, cocklebur, wingstem, and other mixed grasses/forbs.
The majority of the wooded land consists of mature mixed hardwoods with scattered pines and
cedars ranging from approximately 25 to more than 50 years old. The canopy is moderately dense
to closed and dominated by various oak and hickory species, American beech, sweetgum, red
maple, American sycamore, river birch, green ash, and black cherry. The midstory ranges from
moderately open to moderately dense and contains similar tree species as those observed in the
canopy as well as American holly, Chinese privet, eastern red cedar, American hornbeam, and
flowering dogwood. The understory ranges from open to moderately dense and is dominated by
Christmas fern, Japanese stiltgrass, greenbrier, Japanese honeysuckle, trumpet creeper,
multiflora rose, and muscadine.
iA

Limited NEPA Assessment
Pilot Project 3680.2
March 26, 2020
Portions of the wooded land on the northern and southern portions of the site are planted pine
stands estimated to be approximately 10 to 20 years old. The canopies and midstories are
moderately dense to densely vegetated with planted pines as well as scattered hardwood
species. The understories range from moderately open to dense and are dominated by Japanese
honeysuckle, running cedar, wingstem, trumpet creeper, Chinese privet, muscadine, greenbrier,
Christmas fern, Southern Lady fern, broomsedge, lespedeza, dogfennel, goldenrod, and
blackberry.
Pilot conducted a stream/wetland delineation on the site. The delineation has been field verified
by the United States Army Corps of Engineers (USACE). Streams are located throughout the site.
The streams range from approximately 3 to 20 feet wide. The majority of the streams have well-
defined, sinuous channels with silt, sand, and cobble substrate, moderate baseflow, and aquatic
fauna. Several narrower, first- and second -order streams have less defined channels with
primarily silt substrate and contained little to no baseflow at the time of our site visit. Three
ponds are located on the central portion of the site. The ponds are less than one acre in size and
are hydrologically connected to downgradient waters. Wetlands are located adjacent to and
upgradient of the pond on the eastern portion of the site and the streams in several areas. The
wetlands include saturated headwater, fringe, and floodplain wetlands typical of the piedmont
of North Carolina. Drawing 3 shows the locations of delineated features.
Federally Listed Threatened and Endangered Species
Database Review
The project location was entered into the USFWS Information for Planning and Conservation
(IPaC) online mapping system to obtain a resource list of threatened and endangered species and
designated or proposed critical habitat that may be affected by the project. The IPaC Resources
Trust Report is included as an attachment. Additionally, Pilot reviewed the USFWS Endangered
Species Database to identify federally protected species in Yadkin County, North Carolina. The
following federally protected species was identified:
Common Name IScientific name Federal Status lRecord Status
Northern Long-eared Bat Myotis septentrionalis JT Probable/Potential
T — Threatened
3

Limited NEPA Assessment
Pilot Project 3680.2
March 26, 2020
Species/Habitat Description
Northern Long-eared Bat (Myotis septentrionalis)
Description: The northern long-eared bat (NLEB) is a medium-sized bat about 3 to 3.7 inches in
length but with a wingspan of 9 to 10 inches. As its name suggests, this bat is distinguished by its
long ears, particularly as compared to other bats in its genus, Myotis, which are actually bats
noted for their small ears (Myotis means mouse -eared). The northern long-eared bat is found
across much of the eastern and north central United States and all Canadian provinces from the
Atlantic coast west to the southern Northwest Territories and eastern British Columbia. The
species' range includes 39 states. White -nose syndrome, a fungal disease known to affect bats,
is currently the predominant threat to this bat, especially throughout the Northeast where the
species has declined by up to 99 percent from pre -white -nose syndrome levels at many
hibernation sites. Although the disease has not yet spread throughout the northern long-eared
bat's entire range (white -nose syndrome is currently found in at least 22 of 39 states where the
northern long-eared bat occurs), it continues to spread. Experts expect that where it spreads, it
will have the same impact as seen in the Northeast.
Habitat: During summer, northern long-eared bats roost singly or in colonies underneath bark, in
cavities, or in crevices of both live and dead trees. Males and non -reproductive females may also
roost in cooler places, like caves and mines. This bat seems opportunistic in selecting roosts, using
tree species based on suitability to retain bark or provide cavities or crevices. It has also been
found, rarely, roosting in structures like barns and sheds. Northern long-eared bats spend winter
hibernating in caves and mines, called hibernacula. They typically use large caves or mines with
large passages and entrances; constant temperatures; and high humidity with no air currents.
Specific areas where they hibernate have very high humidity, so much so that droplets of water
are often seen on their fur. Within hibernacula, surveyors find them in small crevices or cracks,
often with only the nose and ears visible.
Conclusion: Hibernacula was not observed on the site. The site contains areas of wooded land
that could afford suitable summer roosting habitat. Similar habitat was observed on surrounding
properties. Based on a review of the June _1_2016_NLEB_HUC12 NLEB shapefiles obtained from
the Asheville Ecological Services Field Office website, the 12-digit HUC with the nearest
confirmed hibernation and/or maternity sites is located more than 61 miles from the site. Based
on the distance from known roost trees and the availability of similar suitable habitat on nearby
properties, we have made the determination that the proposed project is not likely to adversely
affect the NLEB.
C!

Limited NEPA Assessment
Pilot Project 3680.2
March 26, 2020
USFWS Correspondence
Pilot submitted letters to the USFWS to solicit comments pertaining to the proposed project. The
USFWS responded to our requests in letters dated March 8, 2019 and November 20, 2019. The
letter responses indicate that the USFWS concurs with our "may affect — is not likely to adversely
affect" determination for the NLEB. The USFWS recommends a tree cutting moratorium of June
1-July 31 within areas of NLEB habitat to avoid accidental take of the species. The letters further
indicate that the USFWS concurs with our "no effect" determination for all other federally listed
species that are known to occur in Yadkin County. According to the letters, the USFWS believes
that the requirements under section 7 of the Act are fulfilled for the proposed project. Copies of
the letters are included as attachments.
Historic/Archaeological Resources
Literature Review
Pilot reviewed the NCSHPO GIS website to obtain information regarding the potential occurrence
of historic resources on the site and nearby properties. The NCSHPO GIS map (Drawing 4) did not
identify listed properties or properties eligible for listing on or adjacent to the site. A "surveyed
only, gone" resource is identified on the southwestern portion of the site. Two "surveyed only'
resources are identified on adjacent properties east of the site. Several "study List- individual
entry" resources are identified approximately 750 feet and farther east and south of the site.
Other historic properties are not identified within one-half mile of the site.
SHPO Correspondence
The NCSHPO responded to North Carolina State Clearinghouse Department of Administration
Intergovernmental Review request for an approximate 596-acre portion of the site in a letter
dated April 25, 2019. The response indicates that the NCSHPO has no comment on the project
as proposed. A copy of the response is included as an attachment.
An amended application was submitted to the State Clearinghouse to include the additional land
for the site. The NCSHPO response to the amended request, dated March 23, 2020, indicates that
the NCSHPO has no comment on the project as proposed. A copy of the response is included as
an attachment.

Limited NEPA Assessment
Pilot Project 3680.2
March 26, 2020
Conclusions and Opinions
This Limited NEPA Assessment has revealed that it is not likely for the proposed development of
the site with a solar farm to impact federally listed threatened/endangered species and/or
documented historic/cultural resources. The USFWS recommends a tree cutting moratorium of
June 1-July 31 within areas of NLEB habitat to avoid accidental take of the species. If additional
information concerning federally listed threatened/endangered species, historic/cultural
resources, agency involvement, or proposed site development becomes available that makes a
material difference in our findings and conclusions, Pilot reserves the right to revise the
conclusions and opinions found within this report. Additional assessment is not recommended
at this time.
Closing
We appreciate the opportunity to provide our services to you. Please contact us at (336) 310-
4527 if you have questions or require additional information.
Sincerely,
�,eueK `n7
Seren M. Homer
Project Manager
David S. Brame, PWS
Senior Project Manager
Attachments: Drawing 1— USGS Topographic Map
Drawing 2—Aerial Photograph Map
Drawing 3 — Wetland Map
Drawing 4 — NCSHPO GIS Map
IPaC Report, dated March 25, 2020
USFWS Response Letter, dated March 8, 2019
USFWS Response Email, dated November 20, 2019
NCSHPO Response Letter, dated April 25, 2019
NCSHPO Response Letter, dated March 23, 2020
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Site Boundary
Drawing 1 USGS Topographic Map
Sugar Solar
USGS Topographic Map
Yadkinville, NC Quadrangle Approximate 752-Acre Tract
Scale: 1" = 2,000' Yadkinville, Yadkin County, NC
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2018 Aerial Imagery
Approximate 752-Acre Tract
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Scale: 1" = 1,500' PILO
PILOT ENVIRONMENTAL,INC Pilot Project 3680.2

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Drawing 3 Wetland Map
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PILOT EN VIRONMENTAL,INC Pilot Project3680.2

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Ecological Services Field Office
160 Zillicoa Street
Asheville, NC 28801-1082
Phone: [phone] Fax: [phone]
http://www.fws.gov/nc-es/es/couMfr.html
In Reply Refer To:
Consultation Code: 04EN1000-2020-SLI-0090
Event Code: 04EN1000-2020-E-01158
Project Name: Sugar Solar
March 25, 2020
Subject: Updated 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 attached species list 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. Although not required by
section 7, many agencies request species lists to start the informal consultation process and begin
their fulfillment of the requirements under section 7(c) of the Endangered Species Act (Act) of
1973, as amended (16 U.S.C. 1531 et seq.).
This list, along with other helpful resources, is also available on the U.S. Fish and Wildlife
Service (Service) Asheville Field Office's (AFO) website: https://www.fws.gov/raleigh/species/
cntylist/nc counties.html. The AFO website list includes "species of concern" species that could
potentially be placed on the federal list of threatened and endangered species in the future. Also
available are:
Design and Construction Recommendations
https://www.fws.gov/asheville/htmis/project review/Recommendations.html
Optimal Survey Times for Federally Listed Plants
https://www.fws.gov/nc-es/plant/plant survey.html
Northern long-eared bat Guidance
https://www.fws.gov/asheville/htmis/project review/NLEB in WNC.html
Predictive Habitat Model for Aquatic Species
https://www.fws.gov/asheville/htmls/Maxent/Maxent.html

03/25/2020 Event Code: 04EN1000-2020-E-01158
New information based on updated surveys, changes in the abundance and distribution of
species, changed habitat conditions, or other factors could require modifications of these lists.
Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the Act,
the accuracy of the species lists 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 or the AFO website (the AFO website dates each
county list with the day of the most recent update/change) 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 or by going to the AFO website.
The purpose of the Act is to provide a means whereby threatened and endangered species and the
ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2) of the
Act and its implementing regulations (50 CFR 402 et seq.), Federal agencies are required to
utilize their authorities to carry out programs for the conservation of threatened and endangered
species and to determine whether projects may affect threatened and endangered species and/or
designated critical habitat.
A Biological Assessment is required for construction projects (or other undertakings having
similar physical impacts) that are major Federal actions significantly affecting the quality of the
human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2)
(c)). For projects other than major construction activities, the Service suggests that a Biological
Evaluation similar to a Biological Assessment be prepared to determine whether the project may
affect listed or proposed species and/or designated or proposed critical habitat. Recommended
contents of a Biological Assessment are described at 50 CFR 402.12 and on our office's website
at https://www.fws.gov/asheville/htmis/project review/assessment guidance.html.
If a Federal agency (or their non-federal representative) determines, based on the Biological
Assessment or Biological Evaluation, that listed species and/or designated critical habitat may be
affected by the proposed project, the agency is required to consult with the Service pursuant to
50 CFR 402. In addition, the Service recommends that candidate species, proposed species, and
proposed critical habitat be addressed within the consultation. More information on the
regulations and procedures for section 7 consultation, including the role of permit or license
applicants, can be found in the "Endangered Species Consultation Handbook" at: http://
www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF.
Though the bald eagle is no longer protected under the Endangered Species Act, 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 additional consultation (see
https://www.fws.gov/southeast/our-services/permits/eagles/). Wind energy projects should follow
the wind energy guidelines (http://www.fws.gov/windenergy/) for minimizing impacts to
migratory birds (including bald and golden eagles) 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/CurrentBirdlssues/Hazards/towers/towers.htm;

03/25/2020 Event Code: 04EN1000-2020-E-01158
3
http://www.towerkill.com; and http://www.fws.gov/migratoI3Lbirds/CurrentBirdlssues/Hazards/
towers/comtow.html.
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.
Attachment(s):
• Official Species List
• Migratory Birds
• Wetlands

03/25/2020 Event Code: 04EN1000-2020-E-01158
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:
Asheville Ecological Services Field Office
160 Zillicoa Street
Asheville, NC 28801-1082
[phone]

03/25/2020 Event Code: 04EN1000-2020-E-01158 2
Project Summary
Consultation Code: 04EN1000-2020-SLI-0090
Event Code: 04EN1000-2020-E-01158
Project Name: Sugar Solar
Project Type: POWER GENERATION
Project Description: The site is an approximate 752-acre tract located along Country Club
Road in Yadkin County that is proposed for development with a solar
facility.
Project Location:
Approximate location of the project can be viewed in Google Maps: https:
www.google.com/maps/place/36.16042593249979N80.65486843418451W
Counties: Yadkin, NC

03/25/2020 Event Code: 04EN1000-2020-E-01158 3
Endangered Species Act Species
There is a total of 1 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
Fisheriesi, 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.
Mammals
NAM L STATUS
Northern Long-eared Bat Myotis septentrionalis Threatened
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/9045
Critical habitats
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECTAREA UNDER THIS OFFICE'S
JURISDICTION.

03/25/2020
Event Code: 04EN1000-2020-E-01158
Migratory Birds
Certain birds are protected under the Migratory Bird Treaty Act! and the Bald and Golden Eagle
Protection Actz.
Any person or organization who plans or conducts activities that may result in impacts to
migratory birds, eagles, and their habitats should follow appropriate regulations and consider
implementing appropriate conservation measures, as described below.
1. The Migratory Birds Treaty Act of 1918.
2. The Bald and Golden Eagle Protection Act of 1940.
3. 50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)
The birds listed below are birds of particular concern either because they occur on the USFWS
Birds of Conservation Concern (BCC) list or warrant special attention in your project location.
To learn more about the levels of concern for birds on your list and how this list is generated, see
the FAQ below. This is not a list of every bird you may find in this location, nor a guarantee that
every bird on this list will be found in your project area. To see exact locations of where birders
and the general public have sighted birds in and around your project area, visit the E-bird data
mapping tool (Tip: enter your location, desired date range and a species on your list). For
projects that occur off the Atlantic Coast, additional maps and models detailing the relative
occurrence and abundance of bird species on your list are available. Links to additional
information about Atlantic Coast birds, and other important information about your migratory
bird list, including how to properly interpret and use your migratory bird report, can be found
below.
For guidance on when to schedule activities or implement avoidance and minimization measures
to reduce impacts to migratory birds on your list, click on the PROBABILITY OF PRESENCE
SUMMARY at the top of your list to see when these birds are most likely to be present and
breeding in your project area.
NAME BREEDING SEASON
Prothonotary Warbler Protonotaria citrea Breeds Apr 1 to Jul 31
This is a Bird of Conservation Concern (BCC) throughout its range in the
continental USA and Alaska.
Wood Thrush Hylocichla mustelina Breeds May 10 to Aug
This is a Bird of Conservation Concern (BCC) throughout its range in the 31
continental USA and Alaska.

03/25/2020 Event Code: 04EN1000-2020-E-01158
Probability Of Presence Summary
The graphs below provide our best understanding of when birds of concern are most likely to be
present in your project area. This information can be used to tailor and schedule your project
activities to avoid or minimize impacts to birds. Please make sure you read and understand the
FAQ "Proper Interpretation and Use of Your Migratory Bird Report" before using or attempting
to interpret this report.
Probability of Presence ( ')
Each green bar represents the bird's relative probability of presence in the 10km grid cell(s) your
project overlaps during a particular week of the year. (A year is represented as 12 4-week
months.) A taller bar indicates a higher probability of species presence. The survey effort (see
below) can be used to establish a level of confidence in the presence score. One can have higher
confidence in the presence score if the corresponding survey effort is also high.
How is the probability of presence score calculated? The calculation is done in three steps:
The probability of presence for each week is calculated as the number of survey events in
the week where the species was detected divided by the total number of survey events for
that week. For example, if in week 12 there were 20 survey events and the Spotted Towhee
was found in 5 of them, the probability of presence of the Spotted Towhee in week 12 is
0.25.
2. To properly present the pattern of presence across the year, the relative probability of
presence is calculated. This is the probability of presence divided by the maximum
probability of presence across all weeks. For example, imagine the probability of presence
in week 20 for the Spotted Towhee is 0.05, and that the probability of presence at week 12
(0.25) is the maximum of any week of the year. The relative probability of presence on
week 12 is 0.25/0.25 = 1; at week 20 it is 0.05/0.25 = 0.2.
3. The relative probability of presence calculated in the previous step undergoes a statistical
conversion so that all possible values fall between 0 and 10, inclusive. This is the
probability of presence score.
Breeding Season( )
Yellow bars denote a very liberal estimate of the time -frame inside which the bird breeds across
its entire range. If there are no yellow bars shown for a bird, it does not breed in your project
area.
Survey Effort (1)
Vertical black lines superimposed on probability of presence bars indicate the number of surveys
performed for that species in the 10km grid cell(s) your project area overlaps. The number of
surveys is expressed as a range, for example, 33 to 64 surveys.
No Data (—)
A week is marked as having no data if there were no survey events for that week.
Survey Timeframe

03/25/2020 Event Code: 04EN1000-2020-E-01158 3
Surveys from only the last 10 years are used in order to ensure delivery of currently relevant
information. The exception to this is areas off the Atlantic coast, where bird returns are based on
all years of available data, since data in these areas is currently much more sparse.
■ probability of presence breeding season I survey effort — no data
SPECIES JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Prothonotary
Warbler — — --- ---- --� —+ — — — -- ---
BCC Rangewide (COI)
B od Thr s (CON) ---- — — — — — — — — ----11-1 Al 11111111 — — — — . — -- . .
Additional information can be found using the following links:
Birds of Conservation Concern http://www.fws.gov/birds/management/managed-species/
birds-of-conservation-concern.DhD
• Measures for avoiding and minimizing impacts to birds http://www.fws.gov/birds/
management/project-assessment-tools-and-guidance/
conservation-measures.php
• Nationwide conservation measures for birds http://www.fws.gov/migratoDLbirds/pdf/
irds/pdf/
management/nationwidestandardconservationmeasures. pdf
Migratory Birds FAQ
Tell me more about conservation measures I can implement to avoid or minimize impacts
to migratory birds.
Nationwide Conservation Measures describes measures that can help avoid and minimize
impacts to all birds at any location year round. Implementation of these measures is particularly
important when birds are most likely to occur in the project area. When birds may be breeding in
the area, identifying the locations of any active nests and avoiding their destruction is a very
helpful impact minimization measure. To see when birds are most likely to occur and be breeding
in your project area, view the Probability of Presence Summary. Additional measures and/or
permits may be advisable depending on the type of activity you are conducting and the type of
infrastructure or bird species present on your project site.
What does IPaC use to generate the migratory birds potentially occurring in my specified
location?
The Migratory Bird Resource List is comprised of USFWS Birds of Conservation Concern
BCC and other species that may warrant special attention in your project location.

03/25/2020 Event Code: 04EN1000-2020-E-01158 4
The migratory bird list generated for your project is derived from data provided by the Avian
Knowledge Network (AKN). The AKN data is based on a growing collection of survey, banding,
and citizen science datasets and is queried and filtered to return a list of those birds reported as
occurring in the 10km grid cell(s) which your project intersects, and that have been identified as
warranting special attention because they are a BCC species in that area, an eagle (Eagle Act
requirements may apply), or a species that has a particular vulnerability to offshore activities or
development.
Again, the Migratory Bird Resource list includes only a subset of birds that may occur in your
project area. It is not representative of all birds that may occur in your project area. To get a list
of all birds potentially present in your project area, please visit the AKN Phenology Tool.
What does IPaC use to generate the probability of presence graphs for the migratory birds
potentially occurring in my specified location?
The probability of presence graphs associated with your migratory bird list are based on data
provided by the Avian Knowledge Network (AKN). This data is derived from a growing
collection of survey, banding, and citizen science datasets .
Probability of presence data is continuously being updated as new and better information
becomes available. To learn more about how the probability of presence graphs are produced and
how to interpret them, go the Probability of Presence Summary and then click on the "Tell me
about these graphs" link.
How do I know if a bird is breeding, wintering, migrating or present year-round in my
project area?
To see what part of a particular bird's range your project area falls within (i.e. breeding,
wintering, migrating or year-round), you may refer to the following resources: The Cornell Lab
of Ornithology All About Birds Bird Guide, or (if you are unsuccessful in locating the bird of
interest there), the Cornell Lab of Ornithology Neotropical Birds guide. If a bird on your
migratory bird species list has a breeding season associated with it, if that bird does occur in your
project area, there may be nests present at some point within the timeframe specified. If "Breeds
elsewhere" is indicated, then the bird likely does not breed in your project area.
What are the levels of concern for migratory birds?
Migratory birds delivered through IPaC fall into the following distinct categories of concern:
1. "BCC Rangewide" birds are Birds of Conservation Concern (BCC) that are of concern
throughout their range anywhere within the USA (including Hawaii, the Pacific Islands,
Puerto Rico, and the Virgin Islands);
2. "BCC - BCR" birds are BCCs that are of concern only in particular Bird Conservation
Regions (BCRs) in the continental USA; and
3. "Non -BCC - Vulnerable" birds are not BCC species in your project area, but appear on
your list either because of the Eagle Act requirements (for eagles) or (for non -eagles)
potential susceptibilities in offshore areas from certain types of development or activities
(e.g. offshore energy development or longline fishing).

03/25/2020 Event Code: 04EN1000-2020-E-01158 5
Although it is important to try to avoid and minimize impacts to all birds, efforts should be made,
in particular, to avoid and minimize impacts to the birds on this list, especially eagles and BCC
species of rangewide concern. For more information on conservation measures you can
implement to help avoid and minimize migratory bird impacts and requirements for eagles,
please see the FAQs for these topics.
Details about birds that are potentially affected by offshore projects
For additional details about the relative occurrence and abundance of both individual bird species
and groups of bird species within your project area off the Atlantic Coast, please visit the
Northeast Ocean Data Portal. The Portal also offers data and information about other taxa besides
birds that may be helpful to you in your project review. Alternately, you may download the bird
model results files underlying the portal maps through the NOAA NCCOS Integrative Statistical
Modeling and Predictive Mapping of Marine Bird Distributions and Abundance on the Atlantic
Outer Continental Shelf project webpage.
Bird tracking data can also provide additional details about occurrence and habitat use
throughout the year, including migration. Models relying on survey data may not include this
information. For additional information on marine bird tracking data, see the Diving Bird Study
and the nanotag studies or contact Caleb Spiegel or Pam Lorin.
What if I have eagles on my list?
If your project has the potential to disturb or kill eagles, you may need to obtain a permit to avoid
violating the Eagle Act should such impacts occur.
Proper Interpretation and Use of Your Migratory Bird Report
The migratory bird list generated is not a list of all birds in your project area, only a subset of
birds of priority concern. To learn more about how your list is generated, and see options for
identifying what other birds may be in your project area, please see the FAQ "What does IPaC
use to generate the migratory birds potentially occurring in my specified location". Please be
aware this report provides the "probability of presence" of birds within the 10 km grid cell(s) that
overlap your project; not your exact project footprint. On the graphs provided, please also look
carefully at the survey effort (indicated by the black vertical bar) and for the existence of the "no
data" indicator (a red horizontal bar). A high survey effort is the key component. If the survey
effort is high, then the probability of presence score can be viewed as more dependable. In
contrast, a low survey effort bar or no data bar means a lack of data and, therefore, a lack of
certainty about presence of the species. This list is not perfect; it is simply a starting point for
identifying what birds of concern have the potential to be in your project area, when they might
be there, and if they might be breeding (which means nests might be present). The list helps you
know what to look for to confirm presence, and helps guide you in knowing when to implement
conservation measures to avoid or minimize potential impacts from your project activities,
should presence be confirmed. To learn more about conservation measures, visit the FAQ "Tell
me about conservation measures I can implement to avoid or minimize impacts to migratory
birds" at the bottom of your migratory bird trust resources page.

03/25/2020 Event Code: 04EN1000-2020-E-01158
Wetlands
Impacts to NWI wetlands and other aquatic habitats may be subject to regulation under Section
404 of the Clean Water Act, or other State/Federal statutes.
For more information please contact the Regulatory Program of the local U.S. Army Corps of
Engineers District.
Please note that the NWI data being shown may be out of date. We are currently working to
update our NWI data set. We recommend you verify these results with a site visit to determine
the actual extent of wetlands on site.
FRESHWATER POND
• Palustrine
RIVERINE
• Riverine

"cHr Or rtiF � ee ELDUFE
United States Department of the Interior
g
g ' FISH AND WILDLIFE SERVICE
• �9RCH 3 �aa Asheville Field Office •�`'
160 Zillicoa Street Suite #B
Asheville, North Carolina 28801
March 8, 2019
Ms. Catherine Carston
Pilot Environmental, Inc.
PO Box 128
Kernersville, North Carolina 27285
Dear Ms. Carston:
Subject: Listed Species Assessment, for Proposed 596-Acre Solar Array Site (Sugar Solar), adjacent
to Country Club Road, in Yadkinville, Yadkin County, North Carolina (Pilot Project No.
3680.1)
On January 30, 2019, we received (via e-mail) your letter requesting our comments on the subject
project. We originally provided comments on the 218-acre portion of the subject project on
September 11, 2018. Your current letter indicates that the project now includes an additional 377-
acres of adjacent property as part of the subject project. We have reviewed the information that you
presented and the following comments are provided in accordance with the provisions of the
National Environmental Policy Act (42 U.S.C.§ 4321 et seq.); the Fish and Wildlife Coordination
Act, as amended (16 U.S.C. 661-667e); the Migratory Bird Treaty Act, as amended (16 U.S.C. 703);
and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act).
Project Description
According to the information presented, your client is proposing to construct a solar array on a 596-
acre site. A majority of the site consists of forested land and agricultural fields. Agricultural
buildings and structures occur in several areas across the site. A majority of the wooded areas
consist of mature mixed hardwood forests. A section of North Deep Creek flows north to south
across the project site and several un-named tributaries occur on the site. The site also contains two
small farm ponds and about 1.5-acre of wetlands.
Federally Listed Endangered and Threatened Species
Though the project site contains suitable summer maternity roosting habitat for northern long-eared
bat (Myotis septentrionalis), we concur with your conclusion that no known hibernacula occurs
within'/4-mile of the site and no known summer roost trees occur within 150-feet of the site. The
nearest known record for this species is about 60-miles from the project site. According to the new
4(d) rule implemented for the listing of northern long-eared bat, a cutting moratorium of June 1-July
31 is recommended within areas of habitat for this species. Because: 1) the project site is over 60-
miles away from the nearest known occurrence; 2) there is a large amount of suitable habitat in close
proximity to the site and in the surrounding area; and 3) there is a minimal amount of tree clearing

Ms. Carston — Pilot Environmental, Inc. 2
that would occur with the project, we concur with your "may affect — not likely to adversely affect"
determination for this project. We recommend the cutting moratorium of June 1-July 31 be
implemented into the plans if possible. Though a "not likely to adversely affect" determination
would not be dependent on this action, the cutting moratorium is a measure that can be implemented
to further reduce the probability of "take" of this species. We also concur with your "no effect"
determination for all other federally listed species that are known to occur in Yadkin County.
Therefore, we believe the requirements under section 7 of the Act are fulfilled. However, obligations
under section 7 of the Act must be reconsidered if. (1) new information reveals impacts of this
identified action that may affect listed species or critical habitat in a manner not previously
considered, (2) this action is subsequently modified in a manner that was not considered in this
review, or (3) a new species is listed or critical habitat is determined that may be affected by the
identified action.
Wildlife Resources
Because of the large amount of aquatic resources on the site, we strongly recommend that a
minimum of 50-feet of existing forested riparian buffers on both sides of the stream be preserved.
Avoiding impacts to these areas, and retaining adequate riparian buffers on the site will help to
mitigate potential adverse impacts that the project could have on the water quality and stream
channel stability. Riparian buffers would also allow movement corridors, cover, and nesting sites for
wildlife. For more details on the protection of riparian buffers and other recommendations for
protecting wildlife and aquatic resources on the project site, we refer you to the comments included
in our original September 11, 2018 letter. Though those comments were based on the smaller
acreage, the comments and recommendations remain the same for the entire 596-acre proposal.
We appreciate the opportunity to provide comments on this project. Please contact Mr. Bryan
Tompkins of our staff at 828/258-3939, Ext. 240, if you have any questions. In any future
correspondence concerning this project, please reference our Log Number 4-2-18-393.
Sincerely,
- - original signed - -
Janet Mizzi
Field Supervisor

Seren Homer
From: Tompkins, Bryan <[e-mail]>
Sent: Wednesday, November 20, 2019 2:21 PM
To: Seren Homer
Subject: Re: [EXTERNAL] Request for Review and Comment- Sugar Solar (Yadkin County)
Good afternoon Seren.
The USFWS has reviewed the information that you provided in your November 12, 2019
email. Your letter indicates that the proposed Sugar Solar Project (originally proposed as a 596-
acre project) has been expanded. The new project site now includes an additional 156-acres
that is adjacent to the original acreage bringing the total acreage of the project site to 752-
acres. The newly proposed acreage consists primarily of forested areas and actively cultivated
agricultural fields interspersed throughout the site. A utility easement and associated overhead
transmission lines cross the site through the agricultural fields. Several un-named streams
occur within the boundaries of the newly proposed 156-acre site. We reviewed the originally
proposed 595-acre site and provided comments to you, including section 7 concurrence, on
March 8, 2019 (USFWS Project No. 4-2-18-393). We have reviewed the newly proposed
acreage and species assessment information included with your letter. Our current review of
the proposed additional acreage is not changed from our original letter/comments. We concur
with the listed species determinations as included in your proposal and our comments remain
the same as included in our March 8, 2019 letter. Therefore, we believe the requirements under
section 7 of the Endangered Species Act (Act) are fulfilled. However, obligations under section
7 of the Act must be reconsidered if: (1) new information reveals impacts of this identified action
that may affect listed species or critical habitat in a manner not previously considered, (2) this
action is subsequently modified in a manner that was not considered in this review, or (3) a new
species is listed or critical habitat is determined that may be affected by the identified action. We
ask that you refer to our March 8, 2019 letter for additional comments and recommendations for
measures to benefit pollinators and minimize the impacts of the project.
We appreciate the opportunity to review the project proposal.
If you have any questions or if I can be of assistance in any way, please do not hesitate to
contact me.
Bryan Tompkins
US Fish and Wildlife Service
160 Zillicoa Street
Asheville, North Carolina 28801
828/258-3939 ext.42240 (office)
828/450-7586 (cell)
NOTE: This email correspondence and any attachments to and from this sender is subject to the Freedom of
Information Act (FOIA) and may be disclosed to third parties.

NORTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
INTERGOVERNMENTAL REVIZ1
COUNTY: YADKIN H11:ENERGY RELATED STATE NUMBER: 19-E-4600-0211
FACILITIES/ACTIVITIES DATE RECEIVED: 03/21/2019
AGENCY RESPONSE: 04/17/2019
REVIEW CLOSED: 04/22/2019
MS RENEE GLFDHJLL-EARLEY Received: 03/26/24 9
CLEARINGHOUSE COORDINATOR State Historic Preservation Office
DEPT OF NATURAL & CULTURAL RESOURCE
STATE HISTORIC PRESERVATION OFFICE
MSC 4617 - ARCHIVES BUILDING
RALEIGH NC
REVIEW DISTRIBUTION
DEPT OF AGRICULTURE
DEPT 01' ENVERONMENTAL QUALITY
DEPT OF NATURAL & CULTURAL. RESOURCE
DEPT OF TRANSPORTATION
DNCR - NATURAL HERITAGE PROGRAM
BPS - DIV OF EMERGENCY MANAGEMENT
PIEDMONT TRIAD REGIONAL COUNCIL
,,7ECT IN TION
CH 18-1258
Due -- 4/3/19
p. N DC, L{ISI1`I
PRO FOFtNf21
APPLICANT: North Carolina Department of Commerce Due -41glC1
TYPE: State Environmental Policy Act
Environmental Review
S- O(C&�
t
DESC: Amended Application of Sugar Solar, LLC for Certificate to construct a 60 Mai
Solar :acility in Yadkin Co. Docket OSP-11728, Sub 0. - View document at
http://starwl.ncuc.net/NCUC/por.tal/ncu.c/page/Dockets/porta1.aspx, Type SP-11728
Sub 0 i.n the Docket Number search ?ire.
,ocated at the intersection- of Country Club Read and Steelman Road, approximately
.3 miles south of Grace's Drive, Yadkinville, NC
Amended due to the additional ,acreage that has been added to the original site
plan.
CROSS-REFERENCE NUMBER: I8-E-4600-0304
T}ke attached project has been submitted to the N. C. State Clearinghouse for
intergovernmental review. Please review and submit your response by the above
indicated date to 1301 Mai: Service Center, Raleigh NC 21699-1301.
'f additional review time is needed, pleas: contact this office at 0 19)807-2425,
AS A RES=;'.,T CIF T=ilS REVIEW THE FOLLOWING IS SUBMITTED: 9 NO COMMENT ❑ COMMENTS ATTACHED
STGNED RY: DATE: g1z71��
0
i.�
LL
LL
O

COUNTY: YADKIN
NORTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
INTERGOVERNMENTAL REVIEW
H11:ENERGY RELATED
FACILITIES/ACTIVITIES
MS RENEE GLEDHILL-EARLEY
CLEARINGHOUSE COORDINATOR
DEPT OF NATURAL & CULTURAL RESOURCE
STATE HISTORIC PRESERVATION OFFICE
MSC 4617 - ARCHIVES BUILDING
RALEIGH NC
REVIEW DISTRIBUTION
CH 18-1258
STATE NUMBER: 20-E-4600-0183
DATE RECEIVED: 02/20/2020
AGENCY RESPONSE: 03/18/2020
REVIEW CLOSED: 03/23/2020
Historic Preservation Office
Received: 02/28/2020
DEPT OF AGRICULTURE
DEPT OF ENVIRONMENTAL QUALITY
DEPT OF NATURAL & CULTURAL RESOURCE
DEPT OF TRANSPORTATION
DNCR - NATURAL HERITAGE PROGRAM
DPS - DIV OF EMERGENCY MANAGEMENT
PIEDMONT TRIAD REGIONAL COUNCIL
PROJECT INFORMATION
APPLICANT: North Carolina Department of Commerce
TYPE: State Environmental Policy Act
Environmental Review
Due: O /09/2020
A-- 9 311,9 1 20 l�
Due: 03I , IO nLD
S_0 W
DESC: Amended Application of Sugar Solar, LLC for Certificate to construct a 60 MW
Solar Facility in Yadkin Co. Docket 4SP-11728, Sub 0. - View document at
http://starwl.ncuc.net�4 CUC/portal/ncuc/page/Dockets/portal.aspx, Type SP-11728
Sub 0 in the Docket Number search line.
Located at the intersection of Country Club Road and Steelman Road, approximately
.3 miles south of Grace's Drive, Yadkinville, NC
Amended due to the additional land that has been added to the facility.
CROSS-REFERENCE NUMBER: 18-E-4600-0304 19-E-4600-0211
The attached project has been submitted to the N. C. State Clearinghouse for
intergovernmental review. Please review and submit your response by the above
indicated date to 1301 Mail Service Center, Raleigh NC 27699-1301.
If additional review time is needed, please contact this office at [phone].
AS A RESULT OF THIS REVIEW THE FOLLOWING IS SUBMITTED: ® NO COMMENT COMMENTS ATTACHED
SIGNED BY: — C d OL` .
DATE: 03/23/2020
MAR 0 2 2020