20201281 Ver 1_PCN Attachments_20211118

rx
a
° z
0
FM
a� z J o
Q o U U Q
p d
a�a a~ LL o U
N
of
z w w U O
�O �LL z Oo U u>
O� ��z u>> m w wa 2
FO Nm LLii QLU Of
�� d
0o pw w v~ a �
UU - U LL d0 m (7 O
a� ma 0LL U �w
F (n W F O zz a (O (V Q LL
F� C) C) �� w< U� QU U
z� a U� �� // \ Q QO o
J aUm0 Fa 'n
co �- J \ (% \ wrn w
Of�
aQ w0 �'�� ��i �LL a O
o >
0 LiJ
"! J
IJ(r/iYq ,ll�%��`
`
\` \\`\\
\=ems i\ 1
�16
Jk(rr:
mil== _��� �N�/(,�/JA/�(�_�.�`'
,\\\
..o \\� (/ J
o� \\0\\
a
(+11 `1�\�i\111rr/h\ II III�L�4I�%%k(1 r � moo ° C
1 / l �/ / \\\\ F F m LL F F
o 1 11\I111\\I f i{��O/(Jil(✓%j/(
O o
z
M
�t�H3128
a

m
ma
pw
wco
0 LL
ap
0 z
a
a n
W
J
Q
U
N
U_
2
CL
Q
CD
0
z
o0
w U
0 0
Q
¢a
Z�
w�
zw
J as
aofo
a N
/
Z
ON
z
C.
U U\
fl�
za<w
oQo
\ \ o
wma
�o

2 6
e e
O
/ \ e
»
�
@ e
>
5
\
< �| �\m
a §
-a \ \
\ , . , . f / �� e
K - o=
//°
§ | \ o
/ \
\ / Of
o §
| / ~
}\v0
%7\\ | 2
- g �
Ld
ƒ �
| � �
/ \
\ �
a // B
E /
/ @\
3 }"
\ | cn
/ ) 4 /—
\ f
0 \
a_ / ~
_ f
/ _ \
k co
—$
_
\
I--_ a *|777}
co + �|■,§§:
■
|�■$§|§
A|-E
|
f
E;|1�§§ ■
,_�
|��|�§*

U.S. ARMY CORPS OF ENGINEERS
WILMINGTON DISTRICT
Action Id. SAW-2020-00737 County: Gaston U.S.G.S. Quad: NC- Belmont
NOTIFICATION OF JURISDICTIONAL DETERMINATION
Requestor:
Atlantic Residential Fund VI
Matt Brunsen
Address:
2600 Longstone Lane, Suite 201
Marriotsville, MD 21104-1529
Telephone Number:
410-442-7770
E-mail:
mattb(&chesapeakecap.com
Size (acres) 34.69 Nearest Town Cramerton
Nearest Waterway South Fork Catawba River River Basin Santee
USGS HUC 03050102 Coordinates Latitude: 35.222630
Longitude:-81.072994
Location description: The review area is located on the north side of Hamrick Road; approximately 0.7 miles east of the
intersection of Hamrick Road and Cramer Mountain Road. PIN: 3584028468. Reference review area description shown in
Jurisdictional Determination Request package entitled "Figure 1, Location Mad' and Dated 02/12/2020.
Indicate Which of the Following Apply:
A. Preliminary Determination
® There appear to be waters, including wetlands on the above described project area/property, that may be subject to Section 404
of the Clean Water Act (CWA)(33 USC § 1344) and/or Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403). The
waters, including wetlands have been delineated, and the delineation has been verified by the Corps to be sufficiently accurate
and reliable. The approximate boundaries of these waters are shown on the enclosed delineation map dated 2/21/2020. Therefore
this preliminary jurisdiction determination may be used in the permit evaluation process, including determining compensatory
mitigation. For purposes of computation of impacts, compensatory mitigation requirements, and other resource protection
measures, a permit decision made on the basis of a preliminary JD will treat all waters and wetlands that would be affected in any
way by the permitted activity on the site as if they are jurisdictional waters of the U.S. This preliminary determination is not an
appealable action under the Regulatory Program Administrative Appeal Process (Reference 33 CFR Part 331). However, you may
request an approved JD, which is an appealable action, by contacting the Corps district for further instruction.
❑ There appear to be waters, including wetlands on the above described project area/property, that may be subject to Section 404
of the Clean Water Act (CWA)(33 USC § 1344) and/or Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403).
However, since the waters, including wetlands have not been properly delineated, this preliminary jurisdiction determination
may not be used in the permit evaluation process. Without a verified wetland delineation, this preliminary determination is
merely an effective presumption of CWA/RHA jurisdiction over all of the waters, including wetlands at the project area, which
is not sufficiently accurate and reliable to support an enforceable permit decision. We recommend that you have the waters,
including wetlands on your project area/property delineated. As the Corps may not be able to accomplish this wetland
delineation in a timely manner, you may wish to obtain a consultant to conduct a delineation that can be verified by the Corps.
B. Approved Determination
❑ There are Navigable Waters of the United States within the above described project area/property subject to the permit
requirements of Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403) and Section 404 of the Clean Water Act
(CWA)(33 USC § 1344). Unless there is a change in law or our published regulations, this determination may be relied upon for
a period not to exceed five years from the date of this notification.
❑ There are waters, including wetlandson the above described project area/property subject to the permit requirements of Section
404 of the Clean Water Act (CWA) (33 USC § 1344). Unless there is a change in the law or our published regulations, this
determination may be relied upon for a period not to exceed five years from the date of this notification.
❑ We recommend you have the waters, including wetlands on your project area/property delineated. As the Corps may not be
able to accomplish this wetland delineation in a timely manner, you may wish to obtain a consultant to conduct a delineation that
can be verified by the Corps.
❑ The waters, including wetlands on your project area/property have been delineated and the delineation has been verified by
the Corps. The approximate boundaries of these waters are shown on the enclosed delineation map dated DATE. We strongly

SAW-2020-00737
suggest you have this delineation surveyed. Upon completion, this survey should be reviewed and verified by the Corps. Once
verified, this survey will provide an accurate depiction of all areas subject to CWA jurisdiction on your property which, provided
there is no change in the law or our published regulations, may be relied upon for a period not to exceed five years.
❑ The waters, including wetlands have been delineated and surveyed and are accurately depicted on the plat signed by the
Corps Regulatory Official identified below onDATE. Unless there is a change in the law or our published regulations, this
determination may be relied upon for a period not to exceed five years from the date of this notification.
❑ There are no waters of the U.S., to include wetlands, present on the above described project area/property which are subject to the
permit requirements of Section 404 of the Clean Water Act (33 USC 1344). Unless there is a change in the law or our published
regulations, this determination may be relied upon for a period not to exceed five years from the date of this notification.
❑ The property is located in one of the 20 Coastal Counties subject to regulation under the Coastal Area Management Act (CAMA).
You should contact the Division of Coastal Management in Morehead City, NC, at [phone] to determine their
requirements.
Placement of dredged or fill material within waters of the US, including wetlands, without a Department of the Army permit may
constitute a violation of Section 301 of the Clean Water Act (33 USC § 1311). Placement of dredged or fill material, construction or
placement of structures, or work within navigable waters of the United States without a Department of the Army permit may
constitute a violation of Sections 9 and/or 10 of the Rivers and Harbors Act (33 USC § 401 and/or 403). If you have any questions
regarding this determination and/or the Corps regulatory program, please contact Bryan Roden -Reynolds at 704-510-1440 or
brvan.roden-rynolds( )usace.army.mil.
C. Basis For Determination: Basis For Determination: See the preliminary jurisdictional determination
form dated 6/17/2020.
D. Remarks: None.
E. Attention USDA Program Participants
This delineation/determmation has been conducted to identify the limits of Corps' Clean Water Act jurisdiction for the particular site
identified in this request. The delineation/determination may not be valid for the wetland conservation provisions of the Food Security
Act of 1985. If you or your tenant are USDA Program participants, or anticipate participation in USDA programs, you should request
a certified wetland determination from the local office of the Natural Resources Conservation Service, prior to starting work.
F. Appeals Information (This information applies only to approved jurisdictional determinations as indicated in B.
above)
This correspondence constitutes an approved jurisdictional determination for the above described site. If you object to this
determination, you may request an administrative appeal under Corps regulations at 33 CFR Part 331. Enclosed you will find a
Notification of Appeal Process (NAP) fact sheet and request for appeal (RFA) form. If you request to appeal this determination you
must submit a completed RFA form to the following address:
US Army Corps of Engineers
South Atlantic Division
Attn: Phillip Shannin, Review Officer
60 Forsyth Street SW, Room 10M15
Atlanta, Georgia 30303-8801
In order for an RFA to be accepted by the Corps, the Corps must determine that it is complete, that it meets the criteria for appeal
under 33 CFR part 331.5, and that it has been received by the Division Office within 60 days of the date of the NAP. Should you
decide to submit an RFA form, it must be received at the above address by Not applicable.
**It is not necessary to submit an RFA form to the Division Office if you do not object to the determination in this correspondence.**
RODEN
Corps Regulatory Official: REYNOLDS.BRYAN.KENNETH.1263385574
Digitally signed by RODEN REYNOLDS.BRYAN.KENNETH.1263385574
Date: 2020.06.17 1031:12-04'00'
Date of JD: 6/17/2020 Expiration Date of JD: Not applicable

SAW-2020-00737
The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete the Customer Satisfaction Survey located at
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
Copy furnished:
Agent: Headwater Environmental
Nick Creidler
Address: 1844 Sir Tyler Drive
Wilmington, NC 28405
Telephone Number: 910-777-8386
E-mail: nick(&headwaterenvironmental.com

NOTIFICATION OF ADMINISTRATIVE APPEAL OPTIONS AND PROCESS AND
REQUEST FOR APPEAL
Applicant: Atlantic Residential Fund VI, Matt Brunsen I File Number: SAW-2020-00737
Date: 07/31/2020
Attached is:
See Section below
INITIAL PROFFERED PERMIT (Standard Permit or Letter of permission)
A
PROFFERED PERMIT (Standard Permit or Letter of permission)
B
PERMIT DENIAL
C
APPROVED JURISDICTIONAL DETERMINATION
D
❑X
PRELIMINARY JURISDICTIONAL DETERMINATION
E
SECTION I - The following identifies your rights and options regarding an administrative appeal of the above decision.
Additional information may be found at or http://www.usace.army.miUMissions/CivilWorks/ReaulatoryProgramandPenuits.asi)
OZI& Corps regulations at 33 CFR Part 331.
A: INITIAL PROFFERED PERMIT: You may accept or object to the permit.
• ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final
authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your
signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all
rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the
permit.
• OBJECT: If you object to the permit (Standard or LOP) because of certain terms and conditions therein, you may request
that the permit be modified accordingly. You must complete Section II of this form and return the form to the district
engineer. Your objections must be received by the district engineer within 60 days of the date of this notice, or you will
forfeit your right to appeal the permit in the future. Upon receipt of your letter, the district engineer will evaluate your
objections and may: (a) modify the permit to address all of your concerns, (b) modify the permit to address some of your
objections, or (c) not modify the permit having determined that the permit should be issued as previously written. After
evaluating your objections, the district engineer will send you a proffered permit for your reconsideration, as indicated in
Section B below.
B: PROFFERED PERMIT: You may accept or appeal the permit
• ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final
authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your
signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all
rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the
permit.
• APPEAL: If you choose to decline the proffered permit (Standard or LOP) because of certain terms and conditions therein,
you may appeal the declined permit under the Corps of Engineers Administrative Appeal Process by completing Section II of
this form and sending the form to the division engineer. This form must be received by the division engineer within 60 days
of the date of this notice.
C: PERMIT DENIAL: You may appeal the denial of a permit under the Corps of Engineers Administrative Appeal Process by
completing Section II of this form and sending the form to the division engineer. This form must be received by the division
engineer within 60 days of the date of this notice.
D: APPROVED JURISDICTIONAL DETERMINATION: You may accept or appeal the approved JD or provide new
information.
• ACCEPT: You do not need to notify the Corps to accept an approved JD. Failure to notify the Corps within 60 days of the
date of this notice, means that you accept the approved JD in its entirety, and waive all rights to appeal the approved JD.
• APPEAL: If you disagree with the approved JD, you may appeal the approved JD under the Corps of Engineers
Administrative Appeal Process by completing Section II of this form and sending the form to the district engineer. This form
must be received by the division engineer within 60 days of the date of this notice.

E: PRELIMINARY JURISDICTIONAL DETERMINATION: You do not need to respond to the Corps regarding the
preliminary JD. The Preliminary JD is not appealable. If you wish, you may request an approved JD (which may be appealed),
by contacting the Corps district for further instruction. Also you may provide new information for further consideration by the
Corps to reevaluate the JD.
SECTION II - REQUEST FOR APPEAL or OBJECTIONS TO AN INITIAL PROFFERED PERMIT
REASONS FOR APPEAL OR OBJECTIONS: (Describe your reasons for appealing the decision or your objections to an initial
proffered permit in clear concise statements. You may attach additional information to this form to clarify where your reasons or
objections are addressed in the administrative record.)
ADDITIONAL INFORMATION: The appeal is limited to a review of the administrative record, the Corps memorandum for the
record of the appeal conference or meeting, and any supplemental information that the review officer has determined is needed to
clarify the administrative record. Neither the appellant nor the Corps may add new information or analyses to the record.
However, you may provide additional information to clarify the location of information that is already in the administrative
record.
POINT OF CONTACT FOR QUESTIONS OR INFORMATION:
If you have questions regarding this decision and/or the
If you only have questions regarding the appeal process you may
appeal process you may contact:
also contact:
District Engineer, Wilmington Regulatory Division
Mr. Phillip Shannin, Administrative Appeal Review Officer
Attn: Bryan Roden -Reynolds
CESAD-PDO
Charlotte Regulatory Office
U.S. Army Corps of Engineers, South Atlantic Division
U.S Army Corps of Engineers
60 Forsyth Street, Room 1 OM15
8430 University Executive Park Drive, Suite 615
Atlanta, Georgia 30303-8801
Charlotte, North Carolina 28262
Phone: [phone]
RIGHT OF ENTRY: Your signature below grants the right of entry to Corps of Engineers personnel, and any government
consultants, to conduct investigations of the project site during the course of the appeal process. You will be provided a 15 day
notice of any site investigation, and will have the opportum to participate in all site investi ations.
Date:
Telephone number:
Signature of appellant or agent.
For appeals on Initial Proffered Permits send this form to:
District Engineer, Wilmington Regulatory Division, Attn: Bryan Roden -Reynolds, 69 Darlington Avenue, Wilmington, North
Carolina 28403
For Permit denials, Proffered Permits and Approved Jurisdictional Determinations send this form to:
Division Engineer, Commander, U.S. Army Engineer Division, South Atlantic, Attn: Mr. Phillip Shannin, Administrative
Appeal Officer, CESAD-PDO, 60 Forsyth Street, Room 1OM15, Atlanta, Georgia 30303-8801
Phone: [phone]

PRELIMINARY JURISDICTIONAL DETERMINATION (PJD) FORM
BACKGROUND INFORMATION
A. REPORT COMPLETION DATE FOR PJD: 07/31/2020
B. NAME AND ADDRESS OF PERSON REQUESTING PJD: Atlantic Residential Fund VI, Matt Brunsen,
2600 Longstone Lane, Suite 201, Marriotsville, MD 21104-1529
C. DISTRICT OFFICE, FILE NAME, AND NUMBER: Wilmington District, Hamrick Road, SAW-2020-
00737
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION: The review area is located on the
north side of Hamrick Road; approximately 0.7 miles east of the intersection of Hamrick Road and Cramer
Mountain Road. PIN: 3584028468. Reference review area description shown in Jurisdictional Determination
Request package entitled "Figure 1, Location Map" and Dated 02/12/2020.
(USE THE TABLE BELOW TO DOCUMENT MULTIPLE AQUATIC RESOURCES
AND/OR AQUATIC RESOURCES AT DIFFERENT SITES)
State: NC County: Gaston City: Cramerton
Center coordinates of site (lat/long in degree decimal format): Latitude: 35.222630 Longitude:-81.072994
Universal Transverse Mercator:
Name of nearest waterbody: South Fork Catawba
River
E. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY):
® Office (Desk) Determination. Date: 06/02/2020
❑Field Determination. Date(s):
TABLE OF AQUATIC RESOURCES INREVIEW AREA WHICH "MAY BE" SUBJECT TO
REGULATORY JURISDICTION
Feature
Latitude
Longitude
Estimated
Type of aquatic
Geographic authority to
(decimal
(decimal
amount of
resources (i.e.,
which the aquatic
degrees)
degrees)
aquatic
wetland vs. non-
resource "may be"
resources in
wetland waters)
subject (i.e., Section 404
review area
or Section 10/404)
(acreage and
linear feet, if
applicable
Wetland A
35.22184700
-81.07198800
0.45 acre
Wetland
404
Wetland A2
35.22201000
-81.07293000
0.14 acre
Wetland
404
Wetland B
35.22336100
-81.07187600
0.96 acre
Wetland
404
Wetland C
35.22494500
-81.07284600
0.3 acre
Wetland
404
Stream
35.22198100
-81.07256900
100 linear feet
Non -wetland
404
Stream B
35.22215100
-81.07550400
180 linear feet
Non -wetland
404
Stream C
1770 linear
Non -wetland
404
35.22401000
-81.07445500
feet
1. The Corps of Engineers believes that there may be jurisdictional aquatic resources in the
review area, and the requestor of this PJD is hereby advised of his or her option to request
and obtain an approved JD (AJD) for that review area based on an informed decision after
having discussed the various types of JDs and their characteristics and circumstances when
they may be appropriate.
2. In any circumstance where a permit applicant obtains an individual permit, or a Nationwide
General Permit (NWP) or other general permit verification requiring "pre- construction
notification" (PCN), or requests verification for a non -reporting NWP or other general
permit, and the permit applicant has not requested an AID for the activity, the permit

applicant is hereby made aware that: (1) the permit applicant has elected to seek a permit
authorization based on a PJD, which does not make an official determination of
jurisdictional aquatic resources; (2) the applicant has the option to request an AJD before
accepting the terms and conditions of the permit authorization, and that basing a permit
authorization on an AJD could possibly result in less compensatory mitigation being
required or different special conditions; (3) the applicant has the right to request an
individual permit rather than accepting the terms and conditions of the NWP or other
general permit authorization; (4) the applicant can accept a permit authorization and
thereby agree to comply with all the terms and conditions of that permit, including
whatever mitigation requirements the Corps has determined to be necessary; (5)
undertaking any activity in reliance upon the subject permit authorization without
requesting an AJD constitutes the applicant's acceptance of the use of the PJD; (6)
accepting a permit authorization (e.g., signing a proffered individual permit) or undertaking
any activity in reliance on any form of Corps permit authorization based on a PJD
constitutes agreement that all aquatic resources in the review area affected in any way by
that activity will be treated as jurisdictional, and waives any challenge to such jurisdiction
in any administrative or judicial compliance or enforcement action, or in any administrative
appeal or in any Federal court; and (7) whether the applicant elects to use either an AID or
a PJD, the JD will be processed as soon as practicable. Further, an AJD, a proffered
individual permit (and all terms and conditions contained therein), or individual permit
denial can be administratively appealed pursuant to 33 C.F.R. Part 331. If, during an
administrative appeal, it becomes appropriate to make an official determination whether
geographic jurisdiction exists over aquatic resources in the review area, or to provide an
official delineation of jurisdictional aquatic resources in the review area, the Corps will
provide an AJD to accomplish that result, as soon as is practicable. This PJD finds that
there "may be" waters of the U.S. and/or that there "may be" navigable waters of the U.S.
on the subject review area, and identifies all aquatic features in the review area that could
be affected by the proposed activity, based on the following information:

SUPPORTING DATA. Data reviewed for PJD (check all that apply) Checked items are included in the administrative
record and are appropriately cited:
® Maps, plans, plots or plat submitted by or on behalf of the PJD requestor:
Map: Figures 1-7
® Data sheets prepared/submitted by or on behalf of the PJD requestor. Datasheets:
® Office concurs with data sheets/delineation report.
❑ Office does not concur with data sheets/delineation report. Rationale:
❑ Data sheets prepared by the Corps:
❑Corps navigable waters' study:
❑ U.S. Geological Survey Hydrologic Atlas:
❑USGS NHD data:
❑ USGS 8 and 12 digit HUC maps:
❑ U.S. Geological Survey map(s). Cite scale & quad name:
®Natural Resources Conservation Service Soil Survey. Citation: Figure 2, Printed Soil Mat) (Soil Survey of
Gaston County Dated 1989) and Figure 3, Web Soil Survey Mat) (Web Soil Survey of Gaston County)
® National wetlands inventory map(s). Cite name: Figure 5, National Wetlands Inventory Mai) (USFWS NWI
Ma er
❑ State/local wetland inventory map(s):
®FEMA/FIRMmaps: Figure 4, FEMA Mai) (National Flood Hazard Laver)
❑ 100-year Floodplain Elevation is: (National Geodetic Vertical Datum of 1929)
® Photographs: ® Aerial (Name & Date): Figure 1, Location Mat) (Dated 02/12/2020) and Figure 7, Wetland
Delineation Mat) (Dated 02/21/2020)
or ® Other (Name & Date): Photographs 1-10 Dated 02/19/2020
❑ Previous determination(s). File no. and date of response letter:
® Other information (please specify): Figure 6, LiDARMai) (Dated 02/12/2020)
IMPORTANT NOTE: The information recorded on this form has not necessarily been verified by the Corps
and should not be relied upon for later iurisdictional determinations.
RODEN
REYNOLDS.BRYAN.KE
N N ETH.1263385574
Digitally signed by RODEN
REYNOLDS.BRYAN.KENNETH.126
3385574
Date: 2020.06.17 10:30:49-04'00'
Signature and date of Regulatory
staff member completing PJD
6/ 17/2020
Signature and date of person requesting PJD
(REQUIRED, unless obtaining the signature is
impracticable)1
1 Districts may establish timeframes for requester to return signed PJD forms. If the requester does not respond within the established
time frame, the district may presume concurrence and no additional follow up is necessary prior to fmalizing an action.

This is not a survey. All locations depicted on this figure are approximate. This Wetland Delineation was completed by
Headwater Environmental, Inc. (Headwater) on February 19, 2020. The wetland and stream locations were recorded with the
Trimble Geo7x GPS device. Headwater recommends coordinating with the U.S. Army Corps of Engineers and North Carolina
Division of Water Resources
8
0��5
4e
IN 01)-40
4� a
y �i,
NamCick Rd
Feet
0 150 300 600
Headwater
ENVIRONMENTAL INC.
DP-3
DP-1
A2
c
ICM,
SOURCE
Site Reconnaissance
February 19, 2020
Date: 2/21/2020 NC One Map
Latest Orthoimagery
Prepared by: NJC " 1 inch = 300 feet
Site: 34.69 acres
Wetlands: between 1.5-2 acres
Wetland A
Legend
Site boundary
Wetland
- - - - Ephemeral stream
- - - Intermittent stream
Perennial stream
• Data point
FIGURE 7
WETLAND DELINEATION MAP
Cramerton Site
Hamrick Road
Cramerton, Gaston County
North Carolina
Headwater Project # 202002

ROY COOPER
Governor
ELIZABETH S. BISER
secretary
NORTH CAROLINA
Environmental Quality
November 5, 2021
Nicholas Parker
Amicus Partners, PLLC
30 Union Street South, Suite B
Concord, NC 28025
Project: Villages at Cramerton Mills
Expiration of Acceptance: 5/5/2022
County: Gaston
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to
accept payment for compensatory mitigation for impacts associated with the above referenced project as
indicated in the table below. Please note that this decision does not assure that participation in the DMS in -
lieu fee mitigation program will be approved by the permit issuing agencies as mitigation for project impacts.
It is the responsibility of the applicant to contact permitting agencies to determine if payment to the DMS will
be approved. You must also comply with all other state, federal or local government permits, regulations or
authorizations associated with the proposed activity including G.S. § 143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the issued 404 Permit1401 Certification within this time frame, this acceptance will
expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS receives a copy
of the permit(s) an invoice will be issued based on the required mitigation in that permit and payment must
be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid by an applicant is
calculated based upon the Fee Schedule and policies listed on the DMS website.
Based on the information supplied by you in your request to use the DMS, the impacts for which you are
requesting compensatory mitigation credit are summarized in the following table. The amount of mitigation
required and assigned to DMS for this impact is determined by permitting agencies and may exceed the
impact amounts shown below.
River Basin
Impact Location
8-di it HUC
Impact Type
Impact Quantity
Catawba
03050102
Warm Stream
24
Catawba
03050102
Non -Riparian Wetland*
0.14
*Non -riparian wetland credit is not available in this service area. In accordance with the directive
from the February S, 20111RT meeting, non -riparian wetland impacts located in the mountain and
piedmont areas of North Carolina can be accepted as requested, but mitigated utilizing riparian
wetland mitigation credits. Upon receipt of payment, DMS will take responsibility for providing the
compensatory mitigation. The mitigation will be performed in accordance with the In -Lieu Fee Program
instrument dated July 28, 2010. Thank you for your interest in the DMS in -lieu fee mitigation program. If you
have any questions or need additional information, please contact [e-mail].
Sincerely,
Ate t_&�
FOR James. B Stanfill
Asset Management Supervisor
cc: Nick Creidler, agent
D Q§ North Carolina Department of Environmental Quality I Division of Mitigation Services
217 West Jones Street 1 1652 Mail Service Center I Raleigh, North Carolina 27699-1652
o mM�wa919.707,8976

Headwater
ENVIRONMENTAL INC.
910.777.3908 • 1 121 Military Cutoff Dr, Suite C #306, Wilmington, NC 28405
SUBMITTED VIA EMAIL: [e-mail]
November 16, 2021
U.S. Fish and Wildlife Service
P.O. Box 33726
Raleigh, North Carolina 27636
Reference: 9-Step Biological Assessment
Villages at Cramerton Mills
Cramerton, Gaston County, North Carolina
Headwater Project #202002C
www.headwaterenvironmental.com
To whom it may concern,
On behalf of Amicus Partners, PLLC (residential developer) and MCP SFR Cramerton LP (the property
owner), Headwater Environmental, Inc. (Headwater) is providing your office a courtesy copy of our 9-Step
Biological Assessment.
The site is located on the north side of Hamrick Road, approximately 3,100 feet east of its intersection with
Cramer Mountain Road in Cramerton, Gaston County, North Carolina. According to Gaston County GIS,
the site is 31.59 acres, identified as PIN 3584028468, and it is owned by MCP SFR Cramerton LP.
A proposed residential subdivision will be generally located on the central and western portions of the site.
Based on our assessment of the on -site conditions, Headwater did not identify areas of potential habitat for
the federally listed threatened and endangered species. It is our opinion that suitable habitat for the listed
species is not present on the site and the project is not likely to result in a take of a federally -listed threatened
or endangered species.
Additionally, Headwater has determined that the requirements of Section 7 of the Endangered Species Act;
and the Bald and Golden Eagles Protection Act (the Eagle Act) have been satisfied. The project is also in
compliance with Programmatic Biological Opinion on the 4(d) Rule for the NLEB.
We appreciate the opportunity to provide a copy of our review. Please contact us at [phone] if you
have questions or require additional information.
Sincerely,
Headwater Environmental, Inc.
C. Paul Pascarosa
President
Nick Creidler
Environmental Consultant
Attachments: 9-Step Outline and Process
Figures 1 and 2
Photographs
IPAC Species List Letter, dated July 21, 2021
North Carolina Natural Heritage Database Review, November 16, 2021
Species Conclusion Table, November 16, 2021
USFWS Self -Certification Letter, November 16, 2021

Villages at Cramerton Mills
9-Step Process
Cramerton, Gaston County, North Carolina
Headwater Project #202002C
Step 1: Action Area
To determine the action area, mark the project footprint on a topographic map. Identify the range
of impacts such as; ground disturbance, changes in water quality and quantity, air quality, lighting
effects, and noise disturbance.
The site is located on the north side of Hamrick Road, approximately 3,100 feet east of its
intersection with Cramer Mountain Road in Cramerton, Gaston County, North Carolina. According
to Gaston County GIS, the site is 31.59 acres, identified as PIN 3584028468, and it is owned by
MCP SFR Cramerton LP.
The proposed use of the site is for a residential subdivision. The project footprint will be generally
limited to the central and western portions of the site.
Step 2: Species List
Use the USFWS Information, Planning, and Consultation (IPaC) system to determine if any listed,
proposed, or candidate species may be present in the action area.
Headwater utilized the IPaC system to obtain a copy of the federally listed threatened and
endangered species for Gaston County. A copy of the official species list is enclosed with this
report. Additionally, a query of the USFWS threatened and endangered species by county was
completed. Based on our assessment of the on -site conditions, habitat for the northern long-eared
bat is present throughout the site. According to the USFWS, the NLEB is not known to be present
within Gaston County.
Step 3. State Coordination
Determine whether a documented occurrence of any listed, proposed, or candidate species is
within the action area by contacting the NHP.
On November 16, 2021, Headwater performed a query of the NHP database. Headwater's query
of the NHP database indicated there are no records for rare species, important natural
communities, natural areas, and/or conservation/managed areas within the project boundary.
Step 4: Suitable Habitat
Determine whether listed/proposed/candidate species may occur based on the habitat present
within the action area for each species on the species conclusion table. Review the species
information provided in IPaC, and the information provided by NHP, to determine whether the
action area contains suitable habitat for each species.
The site can be classified into three (2) habitat areas:
1. Forested Uplands
2. PFO Wetlands and Stream Corridor
Forested Uplands
The site is wooded. The upland wooded areas consist of mature trees with a dense understory.
PFO Wetlands and Stream Corridor
Forested wetlands on site consist of mature mixed hardwood and pine tree species with a dense
understory. Stream A is located within a wooded area with a dense understory along its corridor.
Streams B and C are located in a mature mixed hardwood wooded area. An active floodplain is

located along the South Fork Catawba River with mature hardwood trees along the stream
corridor. Soils throughout these areas consist of clay loams.
The USFWS lists four (4) species as threatened, endangered, or as proposed threatened or
endangered for Gaston County, North Carolina:
COMMON NAME
SCIENTIFIC NAME
TAXONOMIC
GROUP
FEDERAL
STATUS
Northern long-eared bat
Myotis septentrionalis
Mammal
T
Bog turtle
Clemmys muhlenbergii
Reptile
T
Dwarf -flowered heartleaf
Heastylis nanilfora
Flowering plant
T
Schweinitz's sunflower
Helianthus schweinitzii
Flowering plant
E
E: Endangered, T: Threatened, P: Proposed threatened/endangered
Northern long-eared bat (Myotis Septentrionalis)
The northern long-eared bat is a medium-sized bat averaging three and half inches in length but
with a wingspan of nine to ten inches. It is distinguished by its long ears. During summer, northern
long-eared bats roost singly or in colonies underneath bark, in cavities, or in crevices of both live
and dead trees. It has also been found, rarely, roosting in structures like barns and sheds.
Northern long-eared bats spend winter hibernating in large caves and mines with large passages.
Specific areas where they hibernate have very high humidity, so much so that droplets of water
are often seen on their fur.
Northern long-eared bats emerge at dusk to fly through the understory of forested hillsides and
ridges feeding on moths, flies, leafhoppers, caddisflies, and beetles, which they catch while in
flight using echolocation. This bat also feeds by gleaning motionless insects from vegetation and
water surfaces.
Bog turtle (Clemmys muhlenbergii)
The bog turtle is the smallest turtle in North America, rarely exceeding three or four inches in
length and weighing only about four ounces. Its orange to yellow patch on either side of the neck
easily distinguishes it from other turtles. Bog turtles live in the mud, grass and sphagnum moss
of bogs, swamps, and marshy meadows. These wetlands are usually fed by cool springs flowing
slowly over the land, creating the wet, muddy soil needed by the turtles. This species is considered
"threatened due to similarity of appearance" based on the habitat degradation of the northern
population of bog turtle. Riparian wetlands with areas of sphagnum moss, assorted grasses, and
sedges (i.e. bogs) were not observed within the stream corridors at the site.
Dwarf -flowered heartleaf (Hexastylis naniflora)
Dwarf -flowered heartleaf is a low -growing evergreen perennial plant. It has dark green, leathery,
heart -shaped leaves that are one to three inches in diameter, supported by long thin leaf stems
connecting it to underground rhizomes. The jug -shaped flowers are usually beige to dark brown
or purple and appear from mid -March to early June. Dwarf -flowered heartleaf grows in acidic soils
along bluffs and adjacent slopes, in boggy areas next to streams and creek heads, and along the
slopes of nearby hillsides and ravines. The forest canopy where this species is found includes
oak -hickory -pine community type. It is endemic to the lower mountains and foothills of North and
South Carolina.
Schweinitz's sunflower (Helianthus schweinitzh)
This plant is a perennial herb that produces solitary stem, five to six feet tall, and bears yellow
flower heads in late summer and early autumn. It occurs within clearings in upland oak -pine -
hickory woods and piedmont longleaf pine forests in moist to mostly dry sandy loams. This species
requires full to partial sun of an open habitat. This habitat is historically associated with areas that
K

experience wildfires and grazing by herds of bison and elk. Now, most occurrences are confined
to roadsides and powerline clearings.
HABITAT REVIEW
Mature trees are present throughout the site. Potential habitat for the northern long-eared bat is
present throughout the site.
Bog, swamp, or marshy wetland areas are not present on site. Therefore, habitat for the bog turtle
is not present.
A mature oak -hickory -pine community located along adjacent slopes to bogs, streams, or ravines
is not present on site.
Open, sunny, frequently disturbed habitat required by the Schweinitz's sunflower is not present
on site.
According to NHP, there are no biological occurrences mapped within the site boundary. Based
on our assessment of the on -site conditions, the mature wooded areas throughout the site
represents potential habitat for the northern long-eared bat. According to the USFWS, the
northern long-eared bat is not known to be present in Gaston County. Headwater determined that
potential habitat for the remaining listed species is not present on site.
Step 5: Critical Habitat
There is no critical habitat present within the action area.
Step 6: Eagle Protection
The bald eagle (Haliaeetus leucocephalus) is protected by the Bald and Golden Eagles Protection
Act (the Eagle Act). The Eagle Act protects the bald from take and disturbance.
An adult bald eagle has a white head, white tail, and large yellow bill; the remaining plumage is
dark brown. Immature individuals are generally dark brown with light splotching. Bald eagles are
a large bird of prey with a five to seven -foot wingspan. Breeding and roosting habitat is generally
located near large bodies of water; such as, coastal areas, bays, rivers, lakes, etc. The bald eagle
constructs large nests in tall mature trees or cliffs. Tree species vary greatly and include pines
and hardwoods. The same nest may be used year after year. Winter roost sites vary in their
proximity to food sources. Bald eagles are an adaptable species, and their habitat can be found
throughout the United States.
Neither a bald eagle specimen, nor bald eagle roosts were observed at the site. The South Fork
Catawba River, located along the northeastern site boundary, is potential foraging habitat. The
proposed residential development will not encroach within the floodplain along the river.
Therefore, impacts to migratory birds and their habitat, including bald and golden eagles, are not
anticipated with this project.
Step 7: Northern long-eared bat (NLEB)
The USFWS: Raleigh Field Office requires this species be taken into consideration due to
relatively recent rise of "white nose syndrome" in this bat population.
The northern long-eared bat (Myotis septentrionalis) is 3 to 3.7 inches long with a wingspan of
nine to 10 inches. They are dark brown, with a pale underside. As its name suggests, this bat
distinguishes itself by its long ears. In winter, the northern long-eared bats spend winter in caves
and mines. In summer, the northern long-eared bat roosts underneath bark and cavities of trees.
This bat has also been found roosting in barns and sheds. Northern long-eared bats emerge at

dusk to feed. They primarily fly through the understory of forested areas feeding on moths, flies,
leafhoppers, caddisflies, and beetles, which they catch while in flight using echolocation or by
gleaning motionless insects from vegetation.
Wooded land is located throughout the site. However, according to USFWS records, the NLEB is
not known to be present in Gaston County.
Step 8: Determinations
Refer to Species Conclusion table on the following page.
Step 9: Project Review Package
A courtesy copy of our Biological Assessment will be provided to the USFWS. Additional
correspondence with the USFWS is not warranted at this time.
M

SOURCE
Headwater Site Reconnaissance
AO ENVIRONMENTAL INC. February 19, 2020
Date: 11/16/2021 NC One Map
Latest Orthoimagery
Prepared by: NJC // 1 inch = 300 feet
FIGURE 2
HABITAT MAP
Cramerton Site
Hamrick Road
Cramerton, Gaston County
North Carolina
Headwater Project # 202002C

�P-11-

SITE PHOTOS
Headwater Project #202002
Photographs taken on February 19, 2020
Photograph 5. Stream A on the central portion of the site.
Photograph 6. South Fork Catawba River along the northeastern boundary.

SITE PHOTOS
Headwater Project #202002
Photographs taken on February 19, 2020
Photograph 7. Stream B on the northern portion of the site, headcut where it turns perennial.
Photograph 8. Stream C located along the northwestern site boundary.

SITE PHOTOS
Headwater Project #202002
Photographs taken on February 19, 2020
Photograph 9. Stream B on the northern portion of the site. Headcut where stream turns perennial.
Photograph 10. Stream C located along the northwestern site boundary.

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.p,ov/nc-es/es/coupiyfr.html
In Reply Refer To:
Consultation Code: 04EN1000-2021-SLI-0744
Event Code: 04EN1000-2021-E-01781
Project Name: Villages at Cramerton Mills
July 21, 2021
Subject: List of threatened and endangered species that may occur in your proposed project
location 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
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.

07/21/2021 Event Code: 04EN1000-2021-E-01781
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/windenerg_y/) 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;
http://www.towerkill.com; andhttp://www.fws.gov/migratoDbirds/CurrentBirdlssues/Hazards/
towers/comtow.html.

07/21/2021 Event Code: 04EN1000-2021-E-01781 3
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

07/21/2021 Event Code: 04EN1000-2021-E-01781
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]

07/21/2021 Event Code: 04EN1000-2021-E-01781 2
Project Summary
Consultation Code: 04EN1000-2021-SLI-0744
Event Code:
04EN1000-2021-E-01781
Project Name:
Villages at Cramerton Mills
Project Type:
** OTHER **
Project Description:
The site is located on the north side of Hamrick Road, approximately
3,100 feet east of its intersection with Cramer Mountain Road in
Cramerton, Gaston County, North Carolina. According to Gaston County
GIS, the site is 31.59 acres, identified as PIN 3584028468, and it is owned
by MCP SFR Cramerton LP.
The proposed use of the site is for a residential subdivision. The project
footprint will be generally limited to the central and western portions of
the site.
Project Location:
Approximate location of the project can be viewed in Google Maps: https:
www. google.com/maps/(a)35.22277235,-81!07300019697232,14z
Counties: Gaston County, North Carolina

07/21/2021 Event Code: 04EN1000-2021-E-01781 3
Endangered Species Act Species
There is a total of 4 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.
1. 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
NAME 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
Reptiles
NAME
STATUS
Bog Turtle Clemmys muhlenbergii
Similarity of
Population: U.S.A. (GA, NC, SC, TN, VA)
Appearance
No critical habitat has been designated for this species.
(Threatened)
Species profile: https:Hecos.fws.gov/ecp/species/6962
Flowering Plants
NAME
STATUS
Dwarf -flowered Heartleaf Hexastylis nani flora
Threatened
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/2458
Schweinitz's Sunflower Helianthus schweinitzii
Endangered
No critical habitat has been designated for this species.
Species profile: https:Hecos.fws.gov/ecp/species/3849

07/21/2021 Event Code: 04EN1000-2021-E-01781
Critical habitats
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S
JURISDICTION.

07/21/2021 Event Code: 04EN1000-2021-E-01781
Migratory Birds
Certain birds are protected under the Migratory Bird Treaty Act! and the Bald and Golden Eagle
Protection Act2.
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 Treat. 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.
BREEDING
NAME SEASON
Bald Eagle Haliaeetus leucocephalus Breeds Sep 1 to
This is not a Bird of Conservation Concern (BCC) in this area, but warrants attention Jul 31
because of the Eagle Act or for potential susceptibilities in offshore areas from certain types
of development or activities.
https:Hecos.fws.gov/ecp/species/1626
Kentucky Warbler Oporornis formosus Breeds Apr 20
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA to Aug 20
and Alaska.

07/21/2021 Event Code: 04EN1000-2021-E-01781 2
NAME
BREEDING
SEASON
Prairie Warbler Dendroica discolor
Breeds May 1
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
to Jul 31
and Alaska.
Prothonotary Warbler Protonotaria citrea
Breeds Apr 1 to
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
Jul 31
and Alaska.
Red-headed Woodpecker Melanerpes erythrocephalus
Breeds May 10
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
to Sep 10
and Alaska.
Rusty Blackbird Euphagus carolinus
Breeds
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
elsewhere
and Alaska.
Wood Thrush Hylocichla mustelina
Breeds May 10
This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA
to Aug 31
and Alaska.
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

07/21/2021 Event Code: 04EN1000-2021-E-01781 3
(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
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
Bald Eagle I�11 IIII IIII IIII IIII IIII IIII ---- IIII IIII IIII II�1
Non -BCC
Vulnerable
WarblerKentucky BCC Rangewide---- — — — -
-++—
(CON)
Prairie Warbler IIII IIII IIII ---- ---- ---- ---- —
BCC Rangewide ++—
(CON)
Warbler nt — — — — — — — — — — — — — — — — —++
BCC Rangewide
(CON)
Red-headed +—'—'—+— —+ — ---+ — ----- 111 Jill Jill Jill 111 ---
1—�
Woodpecker +
BCC Rangewide
(CON)

07/21/2021 Event Code: 04EN1000-2021-E-01781 4
Rusty Blackbird +—+— —+-- ---+ — — — — — — — — — — — — — — — — — — — — — — — — — — — — —+'
BCC Rangewide
(CON)
Wood Thrush
BCC Rangewide ---- — — — -
-++—
(CON)
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.php
• 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/migrator3Lbirds/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 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
(BCQ and other species that may warrant special attention in your project location.
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.

07/21/2021 Event Code: 04EN1000-2021-E-01781 5
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).
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

07/21/2021 Event Code: 04EN1000-2021-E-01781 6
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 Loring.
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.

Roy Cooper, Governor
9" 0 INC DEPARTMENT OF
""i ■
WMk.M 1 NATURAL AND CULTURAL RESOURCES
■-000
November 16, 2021
Nick Creidler
Headwater Environmental, Inc
1121 Military Cutoff Road, Suite C #306
Wilmington, NC 28405
RE: Villages at Cramerton Mills
Dear Nick Creidler:
13. Reid Wilson, Secretary
Misty Buchanan
Deputy Director, Natural Heritage Program
NCNHDE-16353
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
Based on the project area mapped with your request, a query of the NCNHP database indicates that
there are no records for rare species, important natural communities, natural areas, and/or
conservation/managed areas within the proposed project boundary. Please note that although there
may be no documentation of natural heritage elements within the project boundary, it does not
imply or confirm their absence; the area may not have been surveyed. The results of this query
should not be substituted for field surveys where suitable habitat exists. In the event that rare
species are found within the project area, please contact the NCNHP so that we may update our
records.
The attached `Potential Occurrences' table summarizes rare species and natural communities that
have been documented within a one -mile radius of the property boundary. The proximity of these
records suggests that these natural heritage elements may potentially be present in the project area
if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one -mile
radius of the project area, if any, are also included in this report.
If a Federally -listed species is found within the project area or is indicated within a one -mile radius of
the project area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS) for
guidance. Contact information for USFWS offices in North Carolina is found here:
httr)s://www.fws.gov/offices/Directory/ListOffices.cfm?statecode=37.
Please note that natural heritage element data are maintained for the purposes of conservation
planning, project review, and scientific research, and are not intended for use as the primary criteria
for regulatory decisions. Information provided by the NCNHP database may not be published
without prior written notification to the NCNHP, and the NCNHP must be credited as an information
source in these publications. Maps of NCNHP data may not be redistributed without permission.
The NC Natural Heritage Program may follow this letter with additional correspondence if a
Dedicated Nature Preserve, Registered Heritage Area, Land and Water Fund easement, or Federally -
listed species are documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance,
please contact Rodney A. Butler at rod ney.butler�ncdcr.gov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPARTMENT OF NATURAL AND CULTURAL RESOURCES
121 1N. JON S STREET, RALEIGI I_ NC 27603 - 16Sl MAOL SERVICE CENTER. PAL EIGH. rkc 276�0
OFC 919.707.9120 • FAK 919.707.9421

/
CO
®
CO
/
\
/
3
\
o
CO 0
\
?
®
©
©
/
CO
±
ƒ
e_
u
/
CO %
/
CO
( /
CO
% %
\
\
s/
CO
Jo2±
/
0}
»\
0
/
co
\\
\
\/
!_
2
/
Z \
»
t t t t
G:
e
e e e e
\
E
E
E
/ / /
\§
^ 2
=
u
CO/
g
\ \ \ \
` \
&\
CO\
\
x
x
x
» s
e o 0 0 0
§
0
0 3 e 3 3
?
\
} a a % / a a
{ y
:
&:
/
e
9
0 v
4 0 0 2 0 0
e e
e
\(®
6\
\
2
E
2/
o
e
3
\
_
4
/
°
j ®
% \
�/\/
\
\\
CO
CO
+6(-0
E— 2
=
g
/
3
3
i
G
\
\
\
\
\
)a
E
E
/
e
,
\
e
OaZ
4
$©-
\
\
6
2
/ g
\%
/
% \ /
t
0-
\
k
e
% /
- (
/ZZ
m
e\
±
/
-
4
/
»
®
\ \ 0 \
2
\
\
<
\
-
% % z ,.9.9
3
\
/
e
/ / \ \ \
\ \
ƒ
m
Z
\
\
E
\
0
0
\ ?
®
\ \ y / /
\ z
e
z
m
=
e»
/
r e 3 3
: 0
}
\
\
\
\ >
/ / / \ \ \ 0
/ J
±
®
\
0
\
\
4 0 0 % e : :
\
e
E
%
\
=
a
2 2
§
O e e e Z O O
§
COCOCOCO\
2
\
g
_
j:
\
\
\ \
=
3
2
7
/»
\
000
(CO
»
§
\
(
E
\ E
�
2
a)\
3
2
e
o
c o
0
3
}
/
\/
E
\
CC)O
O
e
�_
?}
/
©
\ /
E
m
t
\ E
g
§
.k
e
z®
a) 2
®
E
/
.g \ y
z
./
\
s
\ \ \ \ e e
\
CmCC)
\ / /
0
%
\
\
\ \ \ \ \ \
\
®
0
\ \
/
m
/
)
\
m o o \ i
u
&
_
»
2
»
_
o
E = _ / % z z
00 0%
\ \
/
/
/
\
9
/
o
m O O
2 -
\
2 / /
\ \
\
o E E 0
\ y
©
©
\
4
4 \ \ \
2 \
s
(
/
\ §
\
/ _ \
\
\
/
/
\
\ / \
//
Ex
z
a
E 2 E
_
=
3
z%
////
4 e\ 0
§
\
\ \ 0
\
\
\
/ /
/
/ / / o \ : :
-
oe3
44ze
>
>
Z74
2:2:
uzGG
\/
§
\
c

w—
\
IN, % le,� �
�
�
►
E
0
�
m
E
�
U
m
�
Q
�
m
�
M
LO
CY)
C.0
W
❑
2
Z
U
z
K
/ / \
) / \
IN0 \ 7 #
m m 3 z
f
} ❑ ❑ 13 13
z
\
s
\
c

T
G
N
O
N
N
E
N
0
z
N
i0
0
(n 0
N
c0 .�
fn
U O
N
C .L
E
LL m
co (D
m m
N
to N �
N
U
0 0
CO
Q
0
O
Q C
z
O
c
vi
T
) O
O
N
O
o
0 0 N -a -0
N
O
L-0L p p U
O L N
C
O c0
N
O N
N
w O
�0+;
cl
o
O—L �
L }
Y
t c N
O c.3
0
-0c0
0 t r
c
c
c0�
N
a)
r�
2
0)m
J (n
�
mt� N
0 z
U
C
N(n
0 0
j
�'�
0 (0
p 0Cl
(0
O
N N
c Q
�
N
O .�
r X C
o C
> p
U (0 U
QY r- a)
U
O
i N -O
t
0- C O
c
to O N
c�
Y
N
0
1
N
a)
a)
d
Q
N Q
m
E m
o m
Y N
2
Q
0)� N
N 7�= c) (0
C
(0 Q
O
"O CO�' Q N
7
N C a)li
C(
N N N C
in
a)
(0 N
N 0 .u)
QJ
(0 ~ - E N m
d
E
O
� O O
N
O
O
o-r-
E ao
C
m>-22
O
O
Z
U
CO H
Q to in
0 to
Z� to "O H
L.L O
v
Q
>
QGl
N
B C
E2
c4 O
W_
N
N
'�
U
U
U
w
O
U
w
c E
N
N
N
Z
N
O i
(0
O
Z
O
Z
O
Z
V E
O
Z
O
Y
N
cn
Q
Z
O
z
cn
LU
N
C
C
C
f
in
N
N
N
N
N
N
N
N
N
U)
c
Q
O
y
Q
Q
Q
Q
� N
v
46
C
C
C
C
N
p
m
C
O
to
N
to
N
to
N
to
N
N
T O
U
N
N
N
N
Y_ N
v
—
co
co
co
O
U
Z
O
Z
O
�
m
E
_
R
Z
m
�
O
N
�
N
V
N
,N
N
O
cm
U'a)
u'
me
N
E.Z
:E -0
y
w
m
Z
m
o=
co
cn
°n
E
in=
U
N
O
N
N
N
O
z
U
C
(0
C
N
C
O
.5
C
LLJ
L
N
(0
(0
N
r-�
C
N
cn
N
d
m

14ro�ry�'2 nERI& vnaJ"
o United States Department of the Interior
9
FISH AND WILDLIFE SERVICE,, �A�H 3 dad
Raleigh Field Office
P.O. Box 33726
Raleigh, NC 27636-3726
Date:
November 16, 2021
Self -Certification Letter
Project Name Villages at Cramerton Mills
Dear Applicant:
Thank you for using the U.S. Fish and Wildlife Service (Service) Raleigh Ecological
Services online project review process. By printing this letter in conjunction with your
project review package, you are certifying that you have completed the online project
review process for the project named above in accordance with all instructions
provided, using the best available information to reach your conclusions. This letter,
and the enclosed project review package, completes the review of your project in
accordance with the Endangered Species Act of 1973 (16 U.S.C. 1531-1544, 87 Stat.
884), as amended (ESA), and the Bald and Golden Eagle Protection Act (16 U.S.C.
668-668c, 54 Stat. 250), as amended (Eagle Act). This letter also provides
information for your project review under the National Environmental Policy Act of
1969 (P.L. 91-190, 42 U.S.C. 4321-4347, 83 Stat. 852), as amended. A copy of this
letter and the project review package must be submitted to this office for this
certification to be valid. This letter and the project review package will be maintained
in our records.
The species conclusions table in the enclosed project review package summarizes
your ESA and Eagle Act conclusions. Based on your analysis, mark all the
determinations that apply:
❑"no effect" determinations for proposed/listed species and/or
✓ proposed/designated critical habitat; and/or
❑✓ "may affect, not likely to adversely affect" determinations for proposed/listed
species and/or proposed/designated critical habitat; and/or
❑ "may affect, likely to adversely affect" determination for the Northern long-
eared bat (Myotis septentrionalis) and relying on the findings of the January 5,
2016, Programmatic Biological Opinion for the Final 4(d) Rule on the
Northern long-eared bat;
❑ "no Eagle Act permit required" determinations for eagles.

Applicant Page 2
We certify that use of the online project review process in strict accordance with the
instructions provided as documented in the enclosed project review package results in
reaching the appropriate determinations. Therefore, we concur with the "no effect" or
"not likely to adversely affect" determinations for proposed and listed species and
proposed and designated critical habitat; the "may affect" determination for Northern
long-eared bat; and/or the "no Eagle Act permit required" determinations for eagles.
Additional coordination with this office is not needed. Candidate species are not
legally protected pursuant to the ESA. However, the Service encourages consideration
of these species by avoiding adverse impacts to them. Please contact this office for
additional coordination if your project action area contains candidate species.
Should project plans change or if additional information on the distribution of
proposed or listed species, proposed or designated critical habitat, or bald eagles
becomes available, this determination may be reconsidered. This certification letter is
valid for 1 year. Information about the online project review process including
instructions, species information, and other information regarding project reviews
within North Carolina is available at our website http://www.fws.gov/raleigh/pp.html.
If you have any questions, you can write to us at [e-mail] or please contact
Leigh Mann of this office at 919-856-4520, ext. 10.
Sincerely,
/s/Pete Benjamin
Pete Benjamin
Field Supervisor
Raleigh Ecological Services
Enclosures - project review package