20201401 Ver 1_06_USFWS Correspondence_20201113

U.S. FISH AND WILDLIFE CORRESPONDENCE

BURNS �MEDONNELL
April 13, 2020
Emily Wells
U.S. Fish & Wildlife Service
Raleigh Ecological Services Field Office
551 Pylon Drive, Suite F
Raleigh, North Carolina 27606-1487
Submitted via Email at emil. [e-mail]
Re: Piedmont Natural Gas, Line 472 DOT Replacement Project
Protected Species Habitat Assessment
U.S. Army Corps of Engineers Project No. SAW-2020-00375
Dear Ms. Wells:
Burns & McDonnell Consultants, Inc. was retained by Piedmont Natural Gas Company, Inc.
(PNG) to provide environmental permitting support for the proposed Line 472 DOT Relocation
Project (Project) located in Johnston County, North Carolina (NC). The Project, which will result
in impacts on waters of the U.S., will require a Nationwide Permit No. 12 from the U.S. Army
Corps of Engineers (USACE), Wilmington District. The following information is being provided
to the U.S. Fish and Wildlife Service (USFWS) for review and concurrence under the
requirements of Section 7 of the Endangered Species Act (ESA). A Project Location map is
provided in Appendix A.
INTRODUCTION
PNG plans to install approximately 7,980 linear feet of 8" high-pressure steel distribution
pipeline in Johnston County, NC. The Project will begin about 0.7 miles east of interchange 312
on NC Route 42, proceeding 2,280 feet south before turning southwest for nearly a mile where it
will terminate at NC Route 1010, across from West View Elementary School. The pipeline will
cross underneath an existing Duke Energy transmission power line and it will cross various
landuse types consisting primarily of mixed hardwood pine forest and agricultural fields. The
habitat assessment was conducted along the proposed pipeline route using a 300 to 400-foot-
wide survey corridor (Study Area). The Study Area is approximately 55 acres total, which is
significantly larger than the approximately 20 acres that will be temporarily impacted during
construction.
HABITAT ASSESSMENT
In April and July of 2019, Burns & McDonnell biologists completed a pedestrian survey of the
Project Study Area to evaluate the potential for federally protected species habitat to occur
within the Project footprint. The Project Study Area includes the proposed Project footprint
(where direct construction impacts will occur) as well as a buffer area to allow for minor shifts in
the route or workspaces. As noted above, the Study Area was much wider (300 — 400 feet) than
what the actual pipeline construction corridor will be (75 — 125 feet).
3650 Mansell Road \ Suite 300 \ Alpharetta, GA 30022
burnsmcd.com

BURNS �MEDONNELL
Ms. Emily Wells
U.S. Fish & Wildlife Service
April 13, 2020
Page 2
In addition to the pedestrian field survey, an Information for Planning and Consultation (IPaC)
report was pulled for the Project. The IPaC listed the red -cockaded woodpecker (Picoides
borealis) and two freshwater clam species (dwarf wedgemussel [Alasmidonta heterodon] and the
yellow lance [Elliptio lanceolata]) as potentially occurring in the Project footprint. Further, the
report lists Atlantic pigtoe (Fusconaia masoni), Carolina madtom (Noturus furiosus), and the
Neuse River waterdog (Necturus lewisi) as "Proposed for Listing" (Table 1). Proposed critical
habitat for these species were also documented on the IPaC. Additionally, a desktop review was
performed using aerial imagery, USFWS National Wetlands Inventory (NWI) data, U.S.
Department of Agriculture Natural Resources Conservation Service (MRCS) 2017 Web Soil
Survey for Johnston County, NC, and United States Geological Survey (USGS) National
Hydrography Dataset (NHD) data.
Table 1: Protected Species with Potential to Occur in the Project Study Area
Federal
Species Name
Status
Preferred Habitat
Impact
Birds
Suitable habitat consists of
Red -cockaded Woodpecker
open, mature pine
Habitat not present in Survey
(Picoides borealis)
Endangered
woodlands. Rarely are groups
Area - Not Likely to Adversely
found in mixed hardwood
Affect
pine forests.
Amphibians
Neuse River Waterdog
Proposed
Prefers medium streams to
Project will avoid Swift Creek
(Necturus lewisi) 1
Threatened
large rivers. May occur in
— Not Likely to Adversely
Swift Creek.
Affect
Fishes
Carolina Madtom
Proposed
Project will avoid Swift Creek
(Noturus furiosus) 1
Endangered
May occur in Swift Creek.
— Not Likely to Adversely
Affect
Mussels
Atlantic Pigtoe
Proposed
Swift Creek is proposed
Project will avoid Swift Creek
(Fusconaia masoni) Z
Threatened
critical habitat.
— Not Likely to AdverselyAffect
Dwarf Wedgemussel
Project will avoid Swift Creek
(Alasmidonta heterodon)
Endangered
Could occur in Swift Creek
— Not Likely to Adversely
Affect
Yellow Lance
Threatened
Swift Creek is proposed
Project will avoid Swift Creek

BURNS �MEDONNELL
Ms. Emily Wells
U.S. Fish & Wildlife Service
April 13, 2020
Page 3
Federal
Species Name
Status
Preferred Habitat
Impact
(Elliptio lanceolata) 2
critical habitat.
— Not Likely to Adversely
Affect
1/ Proposed critical habitat exists; however, the Project is outside proposed critical habitat.
Z/ Proposed critical habitat is present in the Project Study Area.
ANALYSIS BY SPECIES
This habitat assessment includes species under the jurisdiction of the USFWS and protected by
the ESA (16 U.S.C. 1531 et seq.). The USFWS IPaC was used to identify federally protected
species with potential to occur in the Project Study Area (https:Hecos.fws.gov/ipac/). The red -
cockaded woodpecker (federally endangered), dwarf wedgemussel (federally endangered) and
the yellow lance (federally threatened) were identified by IPaC as species protected by the ESA.
No designated critical habitat for these federally protected species is located within the Project
footprint. However, due to the Project's proximity to Swift Creek, proposed critical habitats were
identified near the project for the Neuse River waterdog, Carolina madtom, Atlantic pigtoe, and
dwarf wedgemussel.
Additionally, the bald eagle (Haliaeetus leucocephalus), which is federally protected by the Bald
and Golden Eagle Protection Act (BGEPA) (16 U.S.C. 668), was evaluated. If impacts to
migratory bird species are anticipated, it is recommended that construction be restricted during
NC's migratory bird nesting season (April 15 — September 15). No nests were observed during
the April and July 2019 environmental field surveys.
Red -Cockaded Woodpecker
The federally endangered red -cockaded woodpecker prefers open pine forest habitat containing
longleaf or southern pines. The red -cockaded woodpecker (RCW) excavates cavities exclusively
in living mature pine trees. Suitable habitat requires pine trees with decayed heartwood and little
to no mid -story growth. The Study Area intersects two distinct areas of hardwood pine forest.
The area in the western portion of the Study Area appears to be a tree plantation. The central and
eastern portions of the Study Area intersect a palustrine forested swamp. The thick tree density in
this area contains few open areas that would provide adequate RCW habitat. Based on a lack of
suitable habitat along the Study Area, the Project is not anticipated to result in adverse effects on
the RCW or suitable RCW habitat.
Aquatic Species
As listed in Table 1, the federally protected aquatic species that inhabit creeks and river areas
with well -oxygenated, slow to moderate flowing water all have potential to occur in Swift Creek.

BURNS �MEDONNELL
Ms. Emily Wells
U.S. Fish & Wildlife Service
April 13, 2020
Page 4
The Project has been routed to avoid impacts on Swift Creek. However, the proposed route does
intersect an unnamed intermittent tributary that feeds into Swift Creek approximately 3,000 feet
downstream from the pipeline crossing. Given the relatively small drainage area of the stream it
is likely to be dry for portions of the year. As with all stream or wetland crossings, PNG will
implement industry approved best management practices during construction to prevent sediment
from traveling downstream from the construction crossing. PNG will attempt to perform this
stream crossing during dryer summer months when flow is limited or possibly absent.
Swift Creek is proposed critical habitat for numerous aquatic species, as noted in Table 1. At its
nearest point, the Project's construction corridor is approximately 80 feet west of Swift Creek
(maps are available in Appendix A). Based on this assessment, the Project is not anticipated to
result in adverse effects on protected aquatic species.
Bald Eagle
The BGEPA prohibits take of bald eagles. Bald eagles are year-round residents in Johnston
County, NC. The Survey Corridor does not intersect any major reservoirs or rivers that could be
used by nesting eagles. If active bald eagle nests are observed, PNG will work with the USFWS
to prevent disturbance and stay within federal and state regulatory compliance. Based on a lack
of suitable habitat along the Study Area, the Project is not anticipated to have adverse effects on
bald eagles.
CONCLUSIONS
Based on the results of the habitat assessment, Burns & McDonnell has concluded that the
proposed Project is not likely to adversely affect federally listed species. If you have any
questions regarding the proposed Project or the contents of this habitat assessment report, you
may contact me at 770-510-4511 or by e-mail at [e-mail] at your convenience.
Sincerely,
Sara Kent
Senior Environmental Specialist
Attachments:
Appendix A - Figures
Appendix B - IPaC Report
cc: Tina Woodward, PNG

APPENDIX A - FIGURES

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Source: Esri; USGS; Burns & McDonnell Engineering, Inc.
Issued: 4/9/2020

APPENDIX B - IPAC REPORT

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:
Consultation Code: 04EN2000-2020-SLI-1021
Event Code: 04EN2000-2020-E-02324
Project Name: Line 472
April 09, 2020
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

04/09/2020 Event Code: 04EN2000-2020-E-02324
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/CurrentBirdlssues/Hazards/towers/towers.htm; http://
www.towerkill.com; and http://www.fws.gov/migratory birds/CurrentBirdlssues/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].

04/09/2020 Event Code: 04EN2000-2020-E-02324
Attachment(s):
• Official Species List

04/09/2020 Event Code: 04EN2000-2020-E-02324
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]

04/09/2020 Event Code: 04EN2000-2020-E-02324
Project Summary
Consultation Code: 04EN2000-2020-SLI-1021
Event Code: 04EN2000-2020-E-02324
Project Name: Line 472
Project Type: OIL OR GAS
Project Description: Relocation of an existing natural gas transmission line.
Project Location:
Approximate location of the project can be viewed in Google Maps: https:
www.google.com/maps/place/35.60435985603371N78.55131405879379W
Counties: Johnston, NC

04/09/2020 Event Code: 04EN2000-2020-E-02324 3
Endangered Species Act Species
There is a total of 6 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.
Birds
NAME
Red -cockaded Woodpecker Picoides borealis
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/7614
Amphibians
NAME
Neuse River Waterdog Necturus lewisi
There is proposed critical habitat for this species. Your location is outside the critical habitat.
Species profile: https:Hecos.fws.gov/ecp/species/6772
Fishes
NAME
STATUS
Endangered
STATUS
Proposed
Threatened
STATUS
Carolina Madtom Noturus furiosus Proposed
There is proposed critical habitat for this species. Your location is outside the critical habitat. Endangered
Species profile: https:Hecos.fws.gov/ecp/species/528

04/09/2020 Event Code: 04EN2000-2020-E-02324
0
Clams
NAME STATUS
Atlantic Pigtoe Fusconaia masoni Proposed
There is proposed critical habitat for this species. Your location overlaps the critical habitat. Threatened
Species profile: https:Hecos.fws.gov/ecp/species/5164
Dwarf Wedgemussel Alasmidonta heterodon Endangered
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/784
Yellow Lance Elliptio lanceolata Threatened
There is proposed critical habitat for this species. Your location overlaps the critical habitat.
Species profile: https:Hecos.fws.gov/ecp/species/4511
Critical habitats
There are 2 critical habitats wholly or partially within your project area under this office's
jurisdiction.
AIAKAG
Atlantic Pigtoe Fusconaia masoni
https:Hecos.fws.gov/ecp/species/5164#crithab
Yellow Lance Elliptio lanceolata
https:Hecos.fws.gov/ecp/species/4511#crithab
STATUS
Proposed
Proposed

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
551-F Pylon Drive
Raleigh, North Carolina 27606
May 7, 2020
Sara Kent
Burns & McDonnell
3650 Mansell Road, Suite 300
Alpharetta, GA 30022
Re: PNG Line 472 — Johnston County
Dear Mrs. Kent:
This letter is to inform you that the Service has established an on-line project planning and
consultation process which assists developers and consultants in determining whether a
federally -listed species or designated critical habitat may be affected by a proposed project. For
future projects, please visit the Raleigh Field Office'sproject planning website at
https://www.fws.gov/raleigh/pp.html. If you are only searching for a list of species that may be
present in the project's Action Area, then you may use the Service's Information, Planning, and
Consultation System (IPaC) website to determine if any listed, proposed, or candidate species
may be present in the Action Area and generate a species list. The IPaC website may be viewed
at https://ecos.fws.gov/ipac/. The IPaC web site contains a complete and frequently updated list
of all endangered and threatened species protected by the provisions of the Endangered Species
Act of 1973, as amended (16 U.S.C. 1531 et seq.)(Act), a list of federal species of concern' that
are known to occur in each county in North Carolina, and other resources.
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
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.
'The term "federal species of concern" refers to those species which the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their designation
does not necessarily imply that the species will eventually be proposed for listing as a federally endangered or
threatened species. However, we recommend that all practicable measures be taken to avoid or minimize adverse
impacts to federal species of concern.

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. Ourcomments 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,
4V m-OL-0-foir
Pete Benjamin
Field Supervisor

BURNS �MEDONNELL
July 17, 2020
Pete Benjamin
U.S. Fish & Wildlife Service
Raleigh Ecological Services Field Office
Post Office Box 33726
Raleigh, NC 27636-3726
Submitted via Email at pete benjaminkfws.gov
Subject: Request for Concurrence — USFWS Consultation Code: 04EN2000-2020-SLI-1452
PIEDMONT NATURAL GAS
LINE 472 DOT RELOCATION PROJECT, JOHNSTON COUNTY, NC
Dear Mr. Benjamin
Burns & McDonnell Consultants, Inc. (Burns & McDonnell) was retained by Piedmont Natural
Gas Company (PNG), a subsidiary of Duke Energy, to provide environmental permitting support
for the proposed Line 472 DOT Relocation Project (Project) located in Johnston County, North
Carolina (NC). A request for concurrence letter for the Project was provided to U.S. Fish and
Wildlife on April 16, 2020, and concurrence was received on May 7, 2020 (Appendix A). Since
receiving concurrence, the southern portion of the Project was rerouted during landowner
negotiations. The new route is along the eastern property boundary and parallels an unnamed
tributary to Swift Creek as show in the Project Location map in Appendix B.
PNG proposes to install approximately 7,980 linear feet of 8-inch high-pressure steel distribution
pipeline in Johnston County, NC. The eastern terminus of the Project is approximately 0.7 miles
east of interchange 312 on NC Route 42, proceeding 2,280 feet south before turning southwest
for almost 1-mile where it will terminate at NC Route 1010, across from West View Elementary
School. The proposed pipeline crosses underneath an existing Duke Energy transmission power
line and it will cross a variety land use types consisting primarily of mixed hardwood pine forest
and agricultural fields. The habitat assessment was conducted along the proposed pipeline route
using a 300 to 400-foot-wide survey corridor (Survey Area). The Survey Area figures are
provided in Appendix B.
The purpose of the Project will be to meet the growing demand of Piedmont's customer base
through the replacement. The target date for construction to begin is November 2020.
This letter represents PNG's informal consultation with the U.S. Fish and Wildlife (USFWS)
Section 7(c) of the Endangered Species Act (ESA) of 1973, The Migratory Bird Treaty Act
(MBTA) of 1918, as amended (16 U.S.C. 703 et seq.), and the Bald and Golden Eagle Protection
Act (BGEPA) of 1940, as amended (16t U.S.C. 688-688d). PNG is providing the following
information below for the USFWS review.
3650 Mansell Road \ Suite 300 \ Alpharetta, GA 30022
burnsmcd.com

BURNS �MEDONNELL
Mr. Pete Benjamin
U.S. Fish & Wildlife Service
July 9, 2020
Page 2
METHODS
This letter was prepared in response to USFWS Information for Planning and Consultation
(IPaC) result letter (Appendix C) sent to PNG on July 7, 2020 regarding special status species
that may occur within the Survey Area (Consultation Code: 04EN2000-2020-SLI-1452, Event
Code: 04EN2000-2020-E-03312. In response to USFWS's initial feedback, PNG assessed
whether the proposed project had potential to affect ESA species (i.e., ESA listed, proposed and
candidate species), bald eagles (Haliaeetus leucocephalus), golden eagles (Aquila chrysaetos),
and migratory birds (including raptor species), and associated habitat within the Survey area.
Protected Species Desktop Review
Correspondence from the USFWS, provided in Appendix A, states the Project area is not within
proposed or designated critical habitat and that five ESA species, not including migratory birds
have the potential to occur in the Project area.
• Red -cockaded Woodpecker (Picoides borealis) - Endangered
• Neuse River Water Dog (Necturus lewisi) — Proposed Threatened
• Carolina madtom (Noturus furiosus) — Proposed Endangered
• Atlantic Pigtoe (Fusconaia masoni) — Proposed Threatened
• Dwarf Wedgemussel (Alasmidonta heterodon) — Endangered
• Yellow Lance (Elliptio lanceolata) — Threatened
The IPaC listed the red -cockaded woodpecker (Picoides borealis) and two freshwater clam
species (dwarf wedgemussel [Alasmidonta heterodon] and the yellow lance [Elliptio lanceolate])
as potentially occurring in the Project area. The report also lists Atlantic pigtoe (Fusconaia
masoni), Carolina madtom (Noturus furiosus), and the Neuse River waterdog (Necturus lewisi)
as "Proposed for Listing" (Table 1). Proposed critical habitat for these species were also
documented on the IPaC. Additionally, a desktop review was performed using aerial imagery,
USFWS National Wetlands Inventory (NWI) data, U.S. Department of Agriculture Natural
Resources Conservation Service (NRCS) 2017 Web Soil Survey for Johnston County, NC, and
United States Geological Survey (USGS) National Hydrography Dataset (NHD) data.
Protected Species Findings for the Proposed Survey Area
In April and July 2019 and May 2020, Burns & McDonnell biologists completed a pedestrian
survey of the Project Survey Area to evaluate the potential for federally protected species habitat
to occur within the Project area.

BURNS NME-DONNELL
Mr. Pete Benjamin
U.S. Fish & Wildlife Service
July 9, 2020
Page 3
Table 1: Protected Species with Potential to Occur in the Project Area
Federal
Species Name
Status
Preferred Habitat
Impact
Birds
Suitable habitat consists of
Red -cockaded Woodpecker
open, mature pine
Habitat not present in Survey
(Picoides borealis)
Endangered
woodlands. Rarely are groups
Area - Not Likely to Adversely
found in mixed hardwood
Affect
pine forests.
Amphibians
Neuse River Waterdog
Proposed
Prefers medium streams to
Project will avoid Swift Creek
(Necturus lewisi)'
Threatened
large rivers. May occur in
— Not Likely to Adversely
Swift Creek.
Affect
Fishes
Carolina Madtom
Proposed
Project will avoid Swift Creek
(Noturus furiosus)'
Endangered
May occur in Swift Creek.
— Not Likely to Adversely
Affect
Mussels
Atlantic Pigtoel
Proposed
Swift Creek is proposed
Project will avoid Swift Creek
(Fusconaia masoni)
Threatened
critical habitat.
— Not Likely to Adversely
Affect
Dwarf Wedgemussel
Project will avoid Swift Creek
(Alasmidonta heterodon)
Endangered
Could occur in Swift Creek
— Not Likely to Adversely
Affect
Yellow Lance'
Swift Creek is proposed
Project will avoid Swift Creek
(Elliptio lanceolate)
Threatened
critical habitat.
— Not Likely to Adversely
Affect
1/ Proposed critical habitat exists; however, the Project is outside proposed critical habitat.
ANALYSIS BY SPECIES
This habitat assessment includes species under the jurisdiction of the USFWS and protected by
the ESA (16 U.S.C. 1531 et seq.). The USFWS IPaC was used to identify federally protected
species within potential to occur in the Project area (https:Hecos.fws.gov/ipac/). The red -
cockaded woodpecker (federally endangered), dwarf wedgemussel (federally endangered) and
the yellow lance (federally threatened) were identified by IPaC as species protected by the ESA.

BURNS �MEDONNELL
Mr. Pete Benjamin
U.S. Fish & Wildlife Service
July 9, 2020
Page 4
No designated critical habitat for these federally protected species is located within the Project
area. However, due to the Project's proximity to Swift Creek, proposed critical habitats were
identified near the project for the Neuse River waterdog, Carolina madtom, Atlantic pigtoe, and
dwarf wedgemussel.
Additionally, the bald eagle (Haliaeetus leucocephalus), which is federally protected by the Bald
and Golden Eagle Protection Act (BGEPA) (16 U.S.C. 668), was evaluated. If impacts to
migratory bird species are anticipated, it is recommended that construction be restricted during
NC's migratory bird nesting season (April 15 — September 15). No nests were observed during
the April and July 2019 or May 2020 environmental field surveys.
Red -Cockaded Woodpecker
The federally endangered red -cockaded woodpecker prefers open pine forest habitat containing
longleaf or southern pines. The red -cockaded woodpecker (RCW) excavates cavities exclusively
in living mature pines trees. Suitable habitat requires pine trees with decayed heartwood and
little to no mid -story growth. The Study Area intersects two distinct areas of hardwood pine
forest. The area in the western portion of the Study Area appears to be a tree plantation. The
central and eastern portions of the Study Area intersect a palustrine forested swamp. The thick
tree density in this area contains few open areas that would provide adequate RCW habitat.
Based on a lack of suitable habitat along the Study Area, the Project is not anticipated to result in
adverse effects on the RCW or suitable RCW habitat.
Aquatic Species
As listed in Table 1, the federally protected aquatic species that inhabit creeks and river areas
with well -oxygenated, slow to moderate flowing water all have potential to occur in Swift Creek.
The Project has been routed to avoid impacts on Swift Creek. However, the proposed route does
intersect an unnamed intermittent tributary that feeds into Swift Creek approximately 3,000 feet
downstream from the pipeline crossing. Given the relatively small drainage area of the stream it
is likely to be dry for portions of the year. As with all stream or wetland crossings, PNG will
implement industry approved best management practices during construction to prevent sediment
from traveling downstream from the construction crossing. PNG will attempt to perform this
stream crossing during dryer summer months when flow is limited or possibly absent.
Additionally, PNG will implement industry approved best management practices along the re-
routed portion of the pipeline that parallels
Swift Creek is proposed critical habitat for numerous aquatic species, as noted in Table 1. At it's
nearest point, the Project's construction corridor is approximately 80 feet west of Swift Creek
(maps are available in Appendix B). Based on this assessment, the Project is not anticipated to
result in adverse effects on protected aquatic species.

BURNS �MEDONNELL
Mr. Pete Benjamin
U.S. Fish & Wildlife Service
July 9, 2020
Page 5
Bald Eagle
The BGEPA prohibits take of bald eagles. Bald eagles are year-round residents in Johnston
County, NC. The Survey Area does not intersect any major reservoirs or rivers that could be used
by nesting eagles. If active bald eagle nests are observed, PNG will work with the USFWS to
prevent disturbance and stay within federal and state regulatory compliance. Due on a lack of
suitable habitat within the Survey Area, adverse effects on bald eagles are not anticipated.
CONCLUSIONS
Based on the information provided, PNG believes the proposed Project is not likely to adversely
affect ESA federally listed species, their habitat, or proposed designated critical habitat. PNG
requests any comments or concurrence on these findings within 30 days. If you have any
questions or feedback regarding this Project, please contact Jesse Brown at 770-510-4526 or by
e-mail [e-mail].
Respectfully,
Jesse A Brown
Senior Environmental Scientist
Burns and McDonnell Consultants, Inc.
Appendix: A. USFWS Project Concurrence Correspondence
B. Project Location on Topographic Map and Survey Area on Aerial Photography
C. USFWS IPaC Letter
cc: Tom Morris, PNG
Tina Woodward, PNG
Anthony McMullen, Burns & McDonnell

APPENDIX A - USFWS PROJECT CONCURRENCE CORRESPONDENCE

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
551-F Pylon Drive
Raleigh, North Carolina 27606
May 7, 2020
Sara Kent
Burns & McDonnell
3650 Mansell Road, Suite 300
Alpharetta, GA 30022
Re: PNG Line 472 — Johnston County
Dear Mrs. Kent:
This letter is to inform you that the Service has established an on-line project planning and
consultation process which assists developers and consultants in determining whether a
federally -listed species or designated critical habitat may be affected by a proposed project. For
future projects, please visit the Raleigh Field Office'sproject planning website at
https://www.fws.gov/raleigh/pp.html. If you are only searching for a list of species that may be
present in the project's Action Area, then you may use the Service's Information, Planning, and
Consultation System (IPaC) website to determine if any listed, proposed, or candidate species
may be present in the Action Area and generate a species list. The IPaC website may be viewed
at https://ecos.fws.gov/ipac/. The IPaC web site contains a complete and frequently updated list
of all endangered and threatened species protected by the provisions of the Endangered Species
Act of 1973, as amended (16 U.S.C. 1531 et seq.)(Act), a list of federal species of concern' that
are known to occur in each county in North Carolina, and other resources.
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
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.
'The term "federal species of concern" refers to those species which the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their designation
does not necessarily imply that the species will eventually be proposed for listing as a federally endangered or
threatened species. However, we recommend that all practicable measures be taken to avoid or minimize adverse
impacts to federal species of concern.

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. Ourcomments 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,
4V m-OL-0-foir
Pete Benjamin
Field Supervisor

APPENDIX B - FIGURES

W 70
PIP
I40
. iriingl� 4i5N N-f
turner .' ...... .i 00-5
3
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NC 42
7fa $ 3fp
NC 50 r _140
NC 42
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Svurhrll; P:eusant
SYnbds
H '
NC Q
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II
HDD Centerline Figure A-1
NORTH General Location Map
Pipeline Centerline %BURNS Line 472 Replacement Project
p N&M_DONNELL•" Duke Energy / Piedmont
Study Area 0 2,000 4,000 Natural Gas
Feet Johnston County, North Carolina
Source: Esri, Duke Energy / Piedmont Natural Gas, Burns & McDonnell Issued: 6/26/2020

9
i
owl,
1110
0
Sarn',le Plot (ASP)
lJ Sample Plot (SP)
Delineated Wetland
Depl ne Delineated Stream
Figure A-4
HDD Centerline
Type (��d Type (S
Type
Wetland Delineation Map
Pipeline Centerline
PUB Intermittent
Line 472 Replacement Project
Study Area
PEM - Perennial
%BURNS
�RWDONNELL
Duke Energy / Piedmont
50ft Riparian Zone
PSS
Natural Gas
Zone 1
PFO
0 125
250
Johnston County, North Carolina
Zone 2
0016iiiiii
Feet
Page 1 of 4
Source: Esri, Duke
Energy / Piedmont Natural Gas, Burns & McDonnell
Issued: 6/26/2020

9
W-03
� LT
Kr:
SP PKM 09
SP-PKM-08
SP PKM-04
SP PKM-03
W-01
S-01 -
W-08
Sample Plot (SP) Delineated Wetland Delineated Stream Figure A-4
HDD Centerline Type (W) Type (S) Wetland Delineation Map
Pipeline Centerline PUB Intermittent Line 472 Replacement Project
PEM ORTH Perennial N`�♦ BURNS
oStudy Area PSS \RWDONNELL" Duke Energy / Piedmont
50ft Riparian Zone Natural Gas
Zone 1 PFO 0 125 250 Johnston County, North Carolina
Zone 2 001iiiiiiiiii Feet Page 2 of 4
Source: Esri, Duke Energy / Piedmont Natural Gas, Burns & McDonnell Issued: 6/26/2020

0
0
0
r
a
E
M0
0
a
m
ir
t
i'
s�
•.� SP PKM-02
SP-PKM-01
W-06 A.
f •T
;r 5
F`
< 4: .
�w `D Sample Plot (SP) Delineated Wetland Delineated Stream Figure A-4
\1\1 HDD Centerline Type (W) Type (S)
PUB Intermittent Wetland Delineation Map
Pipeline Centerline Line 472 Replacement Project
J
Study Area PEM Perennial voR7H %BURNS
oDuke Energy /Piedmont
Pss �M5DOMNEIwL`"
50ft Riparian Zone Natural Gas
_ Zone 1 PFO 0 125 250 Johnston County, North Carolina
Zone 2 0016iiiiii Feet Page 4 of 4
Source: Esri, Duke Energy / Piedmont Natural Gas, Burns & McDonnell Issued: 6/26/2020

APPENDIX C - USFWS IPAC LETTER

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:
Consultation Code: 04EN2000-2020-SLI-1452
Event Code: 04EN2000-2020-E-03312
Project Name: Line 472 Replacement Project
July 06, 2020
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

07/06/2020 Event Code: 04EN2000-2020-E-03312
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/CurrentBirdlssues/Hazards/towers/towers.htm; http://
www.towerkill.com; and http://www.fws.gov/migratory birds/CurrentBirdlssues/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].

07/06/2020 Event Code: 04EN2000-2020-E-03312
Attachment(s):
• Official Species List

07/06/2020 Event Code: 04EN2000-2020-E-03312
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]

07/06/2020 Event Code: 04EN2000-2020-E-03312
Project Summary
Consultation Code: 04EN2000-2020-SLI-1452
Event Code: 04EN2000-2020-E-03312
Project Name: Line 472 Replacement Project
Project Type: OIL OR GAS
Project Description: natural gas distribution pipeline replacement
Project Location:
Approximate location of the project can be viewed in Google Maps: https://
www.google.com/maps/place/35.60545114776376N78.5509454268774W
Counties: Johnston, NC

07/06/2020 Event Code: 04EN2000-2020-E-03312 3
Endangered Species Act Species
There is a total of 6 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.
Birds
NAME
Red -cockaded Woodpecker Picoides borealis
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/7614
Amphibians
NAME
Neuse River Waterdog Necturus lewisi
There is proposed critical habitat for this species. Your location is outside the critical habitat.
Species profile: https:Hecos.fws.gov/ecp/species/6772
Fishes
NAME
STATUS
Endangered
STATUS
Proposed
Threatened
STATUS
Carolina Madtom Noturus furiosus Proposed
There is proposed critical habitat for this species. Your location is outside the critical habitat. Endangered
Species profile: https:Hecos.fws.gov/ecp/species/528

07/06/2020 Event Code: 04EN2000-2020-E-03312
4
Clams
NAME STATUS
Atlantic Pigtoe Fusconaia masoni Proposed
There is proposed critical habitat for this species. Your location is outside the critical habitat. Threatened
Species profile: https:Hecos.fws.gov/ecp/species/5164
Dwarf Wedgemussel Alasmidonta heterodon Endangered
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/784
Yellow Lance Elliptio lanceolata Threatened
There is proposed critical habitat for this species. Your location is outside the critical habitat.
Species profile: https:Hecos.fws.gov/ecp/species/4511
Critical habitats
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S
JURISDICTION.

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
551-F Pylon Drive
Raleigh, North Carolina 27606
July 29, 2020
Jesse Brown
Burns & McDonnell
3650 Mansell Road, Suite 300
Alpharetta, GA 30022
Re: PNG Line 472 Route Modification— Johnston County
Dear Mr. Brown:
This letter is to inform you that the Service has established an on-line project planning and
consultation process which assists developers and consultants in determining whether a
federally -listed species or designated critical habitat may be affected by aproposed project. For
future projects, please visit the Raleigh Field Office'sproject planning website at
https://www.fws.gov/raleigh/pp.html. If you are only searching for a list of species that may be
present in the project's Action Area, then you may use the Service's Information, Planning, and
Consultation System (IPaC) website to determine if any listed, proposed, or candidate species
may be present in the Action Area and generate a species list. The IPaC website may be viewed
at https://ecos.fws.gov/ipac/. The IPaC web site contains a complete and frequently updated list
of all endangered and threatened species protected by the provisions of the Endangered Species
Act of 1973, as amended (16 U.S.C. 1531 et seq.)(Act), a list of federal species of concern' that
are known to occur in each county in North Carolina, and other resources.
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
'The term "federal species of concern" refers to those species which the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their designation
does not necessarily imply that the species will eventually be proposed for listing as a federally endangered or
threatened species. However, we recommend that all practicable measures be taken to avoid or minimize adverse
impacts to federal species of concern.

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.
With regard to the above -referenced project, we offer the following remarks. Ourcomments 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.
Si ely,
Pete Benjamin
Field Supervisor