20171559 Ver 3_USFWS Comments_20211206

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
December 6, 2021
Mr. Andrew Williams
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
RE: Comments on the Greensboro -Randolph Megasite Public Notice, November 19, 2021, SAW-2015-
01268, Randolph County, North Carolina
Dear Mr. Williams:
The U.S. Fish and Wildlife Service (Service) provides these comments in response to the Public Notice
for the Greensboro -Randolph Megasite. This letter is submitted in accordance with the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d) and the Endangered Species Act of
1973 (ESA), as amended (16 U.S.C. 1531 et. seq.), to be used in your review relative to the protection of
fish and wildlife resources.
The proposed Greensboro -Randolph Megasite and associated US 421 transportation improvements
encompass approximately 1,858 acres of land including approximately 23.7 acres of wetlands, 76,133
linear feet of named and unnamed tributaries flowing primarily into Sandy Creek and the Deep River, 34
acres of open water ponds, and the 53 acre Dodson's Lake. Proposed impacts associated with the 1000
acre development and transportation component include 41,876 linear feet of stream impact (732 linear
feet of temporary and 41,144 linear feet of permanent), 10.095 acres of wetland impact (0.45 acres of
temporary and 9.645 acres of permanent) and 22.04 acres of open water impacts.
For this public notice, two boxes were checked regarding the Corps' Endangered Species initial
determinations. The first box states "The Corps determines that the proposed project may affect federally
listed endangered or threatened species or their formally designated critical habitat. This determination
only applies to the Northern Long-eared Bat (Myotis septentrionalis). The Corps reviewed this project in
accordance with (IAW) the NLEB Standard Local Operating Procedures for Endangered Species
(SLOPES) between the USACE, Wilmington District, and the Asheville and Raleigh USFWS Offices,
and determined that the action area for this proj ect is located outside of the highlighted areas/red 12-digit
HUCs and activities in the action area do not require prohibited incidental take; as such, this project meets
the criteria for the 4(d) rule and any associated take is exempted/excepted. " The Service concurs with this
determination for NLEB.
There have been previous discussions and coordination with consultants regarding portions of this project
from 2017-2021, which include surveys for Schweinitz's Sunflower (Helianthusschweinitzii), Cape Fear
Shiner (Notropis mekistocholas) and the Atlantic Pigtoe (Fusconaia mason). Surveys were conducted in
2017 within the proposed US 421 improvement project area and portions of the adjacent Sandy Creek for
Cape Fear Shiner and Schweinitz's Sunflower, with results finding no individuals of either species, nor
was suitable habitat present for the Cape Fear Shiner in Sandy Creek adjacent to this site. The Service
concurred with a Self Certification letter in 2018 forthese two species within the transportation
improvement project area only, and would still find this determination to be applicable for that area of the
project.

In the fall of 2021 additional surveys were conducted on the larger portion of the project area that is not
associated with the transportation component for Atlantic Pigtoe, Cape Fear Shiner, Schweinitz's
Sunflower and the Bald Eagle. The findings of these surveys did not indicate that the species was present
due to lack of suitable habitat for the Cape Fear Shiner and Atlantic Pigtoe, and that no species were
observed during surveys for the Schweinitz's Sunflower or the Bald Eagle.
The second box states that the Corps is initiating consultation under Section 7 of the ESA for this
project's impacts. The Service appreciates the opportunity to provide comments concerning this large-
scale commercial development within the Cape Fear River Basin, which is habitat formany imperiled
aquatic species, including the federally endangered Cape Fear Shiner, Atlantic Pigtoe, and habitat for
numerous state protected mussel species. We would concur that the onsite habitat would not be suitable
for the Cape Fear Shiner or Atlantic Pigtoe, and our data does not indicate occupied reaches immediately
downstream of the project area in Sandy Creek. However, land use change on a scale this large has the
potential to result in downstream impacts from sedimentation to suitable habitat and pollutants within
Sandy Creek, and eventually within with Deep River. Close coordination should occur with the North
Carolina Wildlife Resources Commission to discuss impacts to the imperiled mussel species under their
purview including the Carolina Creekshell (Villosa vaughaniana), Eastern Creekshell (Villosa delumbis),
and the Notched rainbow (Villosa constricta) immediately downstream in Sandy Creek.
Bald eagles are commonly found near large bodies of water such as lakes, ponds and rivers. The
proximity of this project area to the multiple ponds and Dodsons Lake may allow for suitable nest trees to
be present or within 600 feet of the project area. We would request that an additional review be
conducted prior to large tree removal and land disturbance in suitable areas of the project area to ensure
no new nests have been constructed. To determine if bald eagles (Haliaeetus leucocephalus) are within
the action area, we recommend the Corps or applicant complete our online project review process
(available at: http://www.fws.gov/southeast/es✓baldeagle/).
We would request that the applicant use innovative stormwater designs and other Best Management
Practices (BMP's) above what is legally required within their development to reduce sedimentation runoff
during all phases of this large scale, natural landscape altering project. Additionally, the Service has
supported the expansion of riparian buffer widths on all intermittent and perennial streams as one
appropriate measure to treat sediment running off the landscape prior to it entering onsite streams on other
large scale projects in the Cape Fear River Basin. We encourage the applicant to plant and retain riparian
buffer widths on any remaining streams to 100ft on intermittent streams, and 200ft on perennial streams
within the project area to further minimize potential water quality impacts.
We encourage the Greensboro -Randolph Megasite partners and NCDOT to work with Town, County,
State and Federal staff to address potential secondary and cumulative impacts of this new development,
specifically how stormwater controls will handle the potential for excessive off -site sedimentation, and
we continue to offer our assistance. If you have any questions please contact John Ellis at 919-856-4520
or [e-mail].
Sincerely,
dot Pete Benjamin
Field Supervisor

eC: Gabriela Garrison, NCWRC
Sue Homewood, NCDEQ

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
P.O. Box 33726
Raleigh, NC 27636-3726
Date: 9/30/2021
Self -Certification Letter
Project Name Greensboro Randolph Megasite
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:
❑✓
o
o
"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

x
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-0072
Event Code: 04EN2000-2021-E-04804
Project Name: Greensboro Randolph Megasite
September 30, 2021
Subject: Updated 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 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

09/30/2021
Event Code: 04EN2000-2021-E-04804 2
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/migratorybirds/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].

09/30/2021
Event Code: 04EN2000-2021-E-04804 3
Attachment(s):
• Official Species List

09/30/2021
Event Code: 04EN2000-2021-E-04804 1
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]

09/30/2021
Event Code: 04EN2000-2021-E-04804 2
Project Summary
Consultation Code:
Event Code:
Project Name:
Project Type:
Project Description:
04EN2000-2020-SLI-0072
Some(04EN2000-2021-E-04804)
Greensboro Randolph Megasite
The Greensboro Randolph Megasite is located south of Greensboro in
Randolph County near the Town of Liberty. This site has been identified
as a possible site for an advanced manufacturing and assembly plant.
Highway 421 runs adjacent to the site which provides good access to
major interstates and an existing railroad parallels the northern boundary
of the site. This combined with a large employment base in the greater
Greensboro area makes the GRMS very attractive to potential advanced
manufacturers.
General Purpose and Need
The purpose of the proposed project is generation of jobs and labor
income to improve unemployment, increase median income, and decrease
the poverty rate in Randolph County and the region. In addition, an
advanced manufacturing plant could generate state and local revenue.
Proposed Action
The proposed action includes development of facilities and infrastructure
necessary to create a megasite to attract and support an advanced
manufacturing operation.
Project Location:
Approximate location of the project can be viewed in Google Maps: https://
www.google.com/maps/@35.888659475155066,-79.62663251578857,14z
Counties: Randolph County, North Carolina

09/30/2021
Event Code: 04EN2000-2021-E-04804 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
Fisheriesl, 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.
Fishes
NAME
Cape Fear Shiner Notropis mekistocholas
There is final critical habitat for this species. The location of the critical habitat is not available.
Species profile: https://ecos.fws.gov/ecp/species/6063
Clams
NAME
Atlantic Pigtoe Fusconaia masoni
There is proposed critical habitat for this species. The location of the critical habitat is not
available.
Species profile: https://ecos.fws.gov/ecp/species/5164
Insects
NAME
Monarch Butterfly Danaus plexippus
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/9743
STATUS
Endangered
STATUS
Proposed
Threatened
STATUS
Candidate

09/30/2021
Event Code: 04EN2000-2021-E-04804 4
Flowering Plants
NAME
Schweinitz's Sunflower Helianthus schweinitzii
No critical habitat has been designated for this species.
Species profile: https://ecos.fws.gov/ecp/species/3849
STATUS
Endangered
Critical habitats
THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S
JURISDICTION.

■ ■...
—BM'. NC DEPARTMENT OF
■ EI= NATURAL AN❑ CULTURAL RESOURCES
■.■■■
September 30, 2021
Jessica Tisdale
HDR
555 Fayetteville Street
Raleigh, NC 27601
RE: Greensboro Randolph Megasite
Dear Jessica Tisdale:
Roy Cooper, Governor
D. Reid Wilson, Secretary
Walter Clark
Director, Division of Land and Water Stewardship
NCNHDE-15880
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
A query of the NCNHP database indicates that there are records for rare species, important natural
communities, natural areas, and/or conservation/managed areas within the proposed project
boundary. These results are presented in the attached `Documented Occurrences' tables and map.
The attached `Potential Occurrences' table summarizes rare species and natural communities that
have been documented within a one -mile radius of the property boundary. The proximity of these
records suggests that these natural heritage elements may potentially be present in the project area
if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one -mile
radius of the project area, if any, are also included in this report.
If a Federally -listed species is documented within the project area or indicated within a one -mile
radius of the project area, the NCNHP recommends contacting the US Fish and Wildlife Service
(USFWS) for guidance. Contact information for USFWS offices in North Carolina is found here:
https://www.fws.gov/offices/Directory/ListOffices.cfm?statecode=37.
Please note that natural heritage element data are maintained for the purposes of conservation
planning, project review, and scientific research, and are not intended for use as the primary criteria
for regulatory decisions. Information provided by the NCNHP database may not be published
without prior written notification to the NCNHP, and the NCNHP must be credited as an information
source in these publications. Maps of NCNHP data may not be redistributed without permission.
Also please note that the NC Natural Heritage Program may follow this letter with additional
correspondence if a Dedicated Nature Preserve, Registered Heritage Area, Land and Water Fund
easement, or an occurrence of a Federally -listed species is documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance,
please contact Rodney A. Butler at rodnev.butlerncdcr.aov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPARTMENT OF NATURAL AND CULTURAL RESOVRCES
Q 121 W. JONES STREET. RALEIGH. NC 27603 • 16S1 MAIL SERVICE CENTER. RALEIGH. NC 27699
OFC 'M9.707.9120 • FAX [phone]

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Intersecting the Project Area
Greensboro Randolph Megasite
September 30, 2021
NCNHDE-15880
No Element Occurrences are Documented within the Project Area
There are no documented element occurrences (of medium to very high accuracy) that intersect with the project area. Please note, however, that although the
NCNHP database does not show records for rare species within the project area, it does not necessarily mean that they are not present; it may simply mean that
the area has not been surveyed. The use of Natural Heritage Program data should not be substituted for actual field surveys if needed, particularly if the project
area contains suitable habitat for rare species. If rare species are found, the NCNHP would appreciate receiving this information so that we may update our
database.
No Natural Areas are Documented within the Project Area
Managed Areas Documented Within Project Area*
Managed A=71=111 Owner Owner Type
Randolph County Open Space Randolph County Local Government
Randolph County Open Space Randolph County Local Government
NOTE: If the proposed project intersects with a conservation/managed area, please contact the landowner directly for additional information. If the project intersects with a Dedicated Nature Preserve
(DNP), Registered Natural Heritage Area (RHA), or Federally -listed species, NCNHP staff may provide additional correspondence regarding the project.
Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.ora/help. Data query generated on September 30, 2021; source: NCNHP, Q2 July 2021. Please
resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 2 of 4

Taxonomic
Group
Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mile Radius of the Project Area
Greensboro Randolph Megasite
September 30, 2021
NCNHDE-15880
Element Occurrences Documented Within a One -mile Radius of the Project Area
Laster
EO ID Scientific Named Common Name
- A
servation
Date
Element Accuracy Federal State Global State
Occurrence
Rank
Status tatus Rank Rank
Vascular Plant 38672 Helianthus schweinitzii Schweinitz's Sunflower 2018-09-27
No Natural Areas are Documented Within a One -mile Radius of the Project Area
Managed Areas Documented Within a One -mile Radius of the Project Area
Managed Area Name
Piedmont Land Conservancy Easement
Farm and Ranch Lands Protection Program
Easement
Randolph County Open Space
Randolph County Open Space
NC Division of Mitigation Services Easement
Owner
Piedmont Land Conservancy
US Department of Agriculture, Natural
Resources Conservation Service
Randolph County
Randolph County
NC DEQ, Division of Mitigation Services
E 2-High Endangered Endangered G3 S3
Owner Type
Private
Federal
Local Government
Local Government
State
Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.org/help. Data query generated on September 30, 2021; source: NCNHP, Q2 July 2021. Please
resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 3 of 4

s
September 30, 2021
▪ Project Boundary
▪ Buffered Project Boundary
Managed Area (MAREA)
NCNHDE-15880: Greensboro Randolph Megasite
1:40,407
0 0.35 0.7
I � i
1.4 mi
0 0.5 1
2 km
Sources' Esri, HERE, Garmin,, Intermap, increment P Corp_, GEBCO, USGS,
FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esn Japan,
METI, Esri China (Hong Kong), (c) OpenStreetMap contributors, and the GIS
User Community
Page 4 of 4

Species Conclusions Table
Project Name: Greensboro Randolph Megasite
Date: 9/30/2021
Species / Resource Name
Conclusion
ESA Section 7 / Eagle Act Determination
Notes / Documentation
Cape Fear Shiner (Notropis
mekistocholas)
No suitable habitat present
No effect
Field visit confirmations of habitat — 2015-
2021. Species survey was conducted in the
Study Area and in Sandy Creek by qualified
biologist on September 26, 2017. Species
was not found. Low flow conditions in
streams prevent suitability. Please see
attached survey report for more details.
Atlantic Pigtoe (Fusconaia
masoni)
No suitable habitat present
No effect
Field visit confirmations of habitat — 2015-
2021. No survey conducted. Low flow
conditions in streams prevent suitability.
Please see attached Cape Fear Shiner
survey report for more details
Schweinitz's Sunflower
(Helianthus schweinitzii)
Suitable habitat present,
species not present
No effect
Field visit confirmations of habitat — 2015-
2021. Field survey during optimal flower
season conducted Sept 27th and 28th with
no species found. Confirms prior Sep 18th
and 19th, 2017 and Oct 8th and 9th, 2019
surveys.
Critical Habitat
No critical habitat present
No effect
Critical habitat for Cape Fear Shiner is
located in Randolph County, but not within
one mile of the Study Area.
Bald Eagle (Haliaeetus
Ieucocephalus)
Unlikely to disturb nesting
bald eagles
No Eagle Act Permit Required
Suitable foraging habitat exists for the bald
eagle at Dodsons Lake. No impacts to the
lake are expected and no eagle nests have
been documented.
Acknowledgement: I agree that the above information about my proposed project is true. I used all of the provided resources to make an
informed decision about impacts in the immediate and surrounding areas.
Signature /Title
Date
9/30/2021

hdrinc.com
MEMORANDUM
DATE: Thursday, September 30, 2021
PROJECT:
TO:
Greensboro Randolph Megasite
Project File
FROM: Vickie Miller - HDR
SUBJECT: Schweinitz's Sunflower Survey for the Greensboro Randolph
Megasite
This memo serves to document the field review for the federally protected Schweinitz's
sunflower (Helianthus schweinitzii) for the Greensboro Randolph Megasite (GRMS)
(Figure 1). The GRMS is located south of Greensboro in Randolph County near the Town
of Liberty and has been identified as a possible site for an advanced manufacturing and
assembly plant.
Field surveys for the presence of Schweinitz's sunflowers within suitable habitat were
conducted on September 18, 19, 20; October 11, 12, and 20, 2017; conducted again on
October 8 and 9, 2019, and most recently on September 27 and 28, 2021 during the
United States Fish and Wildlife Service optimal survey window. Prior to conducting the
onsite assessment, a review of North Carolina Natural Heritage Program data, last
updated in September 2021, indicated one known record of Schweinitz's sunflower within
one mile of the study area. Recent aerial photographs were evaluated to identify areas of
likely habitat within the study areas.
The field crews visited the known population to ensure the plants vegetative state prior to
beginning the surveys. Suitable habitat for the species was determined to be areas with
open woods and other sunny or semi -sunny habitats which were typically created by
disturbance such as mowing, clearing, or grazing. Because the species is intolerant to
shade and grows best in areas with disturbance, railroad, roadsides, power lines, and
utility rights -of -way; areas where forest canopies were opened up; areas adjacent to
agricultural fields; along pastured areas; areas adjacent to yards; and in and along edges
of other artificially maintained clearings undergoing natural succession were all reviewed
during the survey.
555 Fayetteville Street, Suites 900 & 210, Raleigh, NC 27601-3034
[phone]

Survey Results: The field teams spent 2 days reviewing the study area. Suitable habitat
for the species occurs throughout the study area; however, no occurrences of Schweinitz's
sunflower were found. Based upon these findings, it was determined the project would
have no effect on Schweinitz's sunflower.
Biological Conclusion: No Effect
Field Investigators
Investigators/Years of Experience: Vickie Miller — 20+ years
Sara Easterly — 20+ years
Ryan Dugger — 7 years
Jackson Garvey — 5 years
If you have any questions please contact Vickie Miller at 919-232-6637 or
[e-mail].
hdrinc.com 555 Fayetteville Street, Suites 900 & 210, Raleigh, NC 27601-3034
[phone]
2

Legend
Megasite Boundary
County Boundary
0 Feet 1,500
SCHWEINITZ'S SUNFLOWER SURVEY
FY2
FIGURE 1

Cape Fear Shiner Survey Report
For
Greensboro Randolph Megasite
Randolph County, North Carolina
Prepared For:
555 Fayetteville St., Suite 900
Raleigh, NC 27601
Contact Person:
Vickie Miller
Senior Environmental Planner
HDR
[e-mail]
November 7, 2017

Prepared by:
RkK
900 Ridgefield Drive, Suite 350
Raleigh, NC 27609
Contact Person:
Neil Medlin
Senior Project Scientist
[e-mail]
919-878-9560

Table of Contents
1.0 Introduction 1
2.0 Waters Affected 1
2.1 NPDES Dischargers 1
2.2 303(d) Classification 1
3.0 Target Federally Protected Species Description 1
3.1 Cape Fear Shiner (Notropis mekistocholas) 1
3.1.1 Characteristics 2
3.1.2 Distribution and Habitat Requirements 2
3.2 Survey Efforts 2
3.3 Stream Conditions at Time of Survey: Sandy Creek at US 421 3
3.4 Assessment Location (AL) Conditions at Time of Observation 4
3.5 Methodology 4
3.6 Results 4
4.0 Discussion/Conclusions 5
5.0 References 6
Appendix A. Figures:
Figure 1: Project Vicinity & Survey Location
Figure 2: NCNHP Element Occurrences
Figure 3: NPDES Dischargers and 303(d) Listed Streams

1.0 Introduction
This evaluation was conducted as part of the environmental studies currently underway for the
potential development of a tract of land located in northeast Randolph County typically referred
to as the Greensboro Randolph Megasite (Appendix A, Figure 1). This portion of Randolph
County is located in the Cape Fear River Basin. The Cape Fear Shiner (Notropis mekistolas) is
listed for Randolph County by the U.S. Fish and Wildlife Service (USFWS) as Endangered
under the Endangered Species Act (ESA).
A review of the NC Natural Heritage Program (NCNHP) records, last accessed on October 12,
2017, indicates there are no element occurrences (EOs) for the Cape Fear Shiner within a 5-mile
buffer of the site (Figure 2). The closest EO for the Cape Fear Shiner (EO ID 218) is in the Deep
River, approximately 19 stream miles downstream from the site. The only observation date
listed for EO 218 is August 2, 2007 and the EO is considered to be current.
2.0 Waters Affected
The Greensboro Randolph Megasite and the potential interchange projects that are associated
with the site's future development are located within the Sandy Creek watershed in the Cape
Fear River Basin (HUC# 03030003). From the southernmost Megasite property boundary a UT
and then Sandy Creek flows approximately 13.5 stream miles to its confluence with the Deep
River. Two dams are located between the Megasite and the Deep River. An old mill dam is
located immediately above SR 2453 (Kidds Millpond Road) on Sandy Creek approximately
seven stream miles below the property boundary. The Ramseur Lake Dam is also located on
Sandy Creek less than one stream mile above its confluence with the Deep River.
2.1 NPDES Dischargers
There is one NPDES permitted discharger located within the 5-mile buffer of the Megasite.
However, it does not discharge into the Sandy Creek watershed and therefore has no effect on
Sandy Creek at any of the assessment locations or the survey location.
2.2 303(d) Classification
Sandy Creek is not on the North Carolina Department of Environmental Quality (NCDEQ) -
Division of Water Resources 2014 303(d) list of impaired streams or the 2016 draft list.
3.0 Target Federally Protected Species Description
3.1 Cape Fear Shiner (Notropis mekistocholns)
3.1.1 Characteristics
The Cape Fear Shiner was first described as a new species in 1971. It is a small (approximately
2 inches long), yellowish minnow with a black band along the sides of its body. The shiner's
fins are yellow and somewhat pointed. It has a black upper lip, and the lower lip bears a thin
Cape Fear Shiner Survey, HDR1, Randolph County
November 2017
Page 1

black bar along its margin. The Cape Fear Shiner is known to consume plant and animal
material. However, unlike most other minnows in the genus Notropis spp., the Cape Fear
Shiner's digestive tract is modified primarily for a plant diet by having an elongated, convoluted
intestine.
3.1.2 Distribution and Habitat Requirements
The Cape Fear Shiner is endemic to the upper Cape Fear River Basin in the Central Piedmont of
North Carolina. The species is known from tributaries and mainstreams of the Cape Fear, Deep,
Haw and Rocky Rivers in Chatham, Harnett, Lee, Moore and Randolph counties.
This shiner is generally associated with gravel, cobble, and boulder substrates, and has been
observed in slow pools, riffles, and slow runs. These areas occasionally support water willow
(Justicia americana), which may be used as cover or protection from predators {e.g. flathead
catfish (Pylodictis olivaris), bass (Micropterus spp.) and crappie (Pomoxis spp.)}. The Cape
Fear Shiner can be found swimming in schools of other minnow species but is never the most
abundant species.
3.2 Survey/Assessment Efforts
A fish survey was conducted in association with this project by RK&K employees Neil Medlin
(NC Wildlife Resources Commission Permit #17-ES00030 and #17-SFC00091), Hal Bain and
Tris Ford on September 26, 2017.
3.3 Stream Conditions at Time of Survey: Sandy Creek at US 421
This survey location was selected as a general representative for the upper Sandy Creek
watershed, including the Unnamed Tributaries (UTs) to Sandy Creek that drain the Megasite
parcel. In addition, this location is the closest to known Cape Fear Shiner records and therefore
should have a greater potential to have the species present than the upstream assessment
locations on Sandy Creek and all the UTs above the survey location. Sandy Creek in the survey
reach was estimated to have a channel width that varied between 30 and 35 feet. The actual wet
width of the stream within the channel varied greatly. The stream segment underneath the
southbound US 421 bridge had water in the entire channel. The pattern below the road was quite
different with stream segments approximately three feet wide flowing between pools or slightly
deeper runs that occupied at least half of the stream channel. Numerous large sand bars were
exposed in the areas between the runs and pools.
The banks were approximately five feet high with some areas exhibiting erosion and/or
undercutting. The maximum depth was three feet with an average depth of one foot. The
substrate was dominated by sand with clay as greatly subdominant. Gravel and silt were also
present in the survey reach. Beaver activity in the form of gnawed sticks was observed at the
survey location. A narrow to moderately wide forested buffer is present along the survey
location with a mix of active crop and pasture land use outside of the buffer. However, Sandy
Creek had no wooded stream buffer for the portion of the stream located on the north side of US
Cape Fear Shiner Survey, HDR1, Randolph County
November 2017
Page 2

421. This unbuffered stream reach is located roughly 325 feet above the upper end of the survey
reach.
3.5 Assessment Location (AL) Conditions at Time of Observation
Two assessment locations (locations where stream habitat was assessed but no fish surveys were
conducted) were on Sandy Creek. The other four were on UTs to Sandy Creek (Figure 1).
These UTs have been assigned stream numbers as part of other environmental studies currently
being conducted on the Greensboro Randolph Megasite. These stream numbers, as of the date of
this report, are included in the assessment location descriptions below.
AL-7 Sandy Creek at SR 2406 (Hollow Hill Road)
This was the most upstream location assessed on Sandy Creek. The stream channel at this road
crossing averaged roughly 13 feet wide but the width varied greatly. The substrate was very
rocky and dominated by bedrock and boulder with cobble, gravel, and sand also present. The
only flowing water observed was a trickle between small rocky pools and runs.
AL-6 Sandy Creek at SR 2442 (Ramseur -Julian Road)
This site is located approximately 1.5 stream miles below the SR 2406 crossing. The stream
channel was estimated to average 20 feet wide with a wet width that varied from six feet to the
full channel width in some runs. Sand was the dominant substrate type at this location with
gravel as the subdominant type. Cobble and sparse boulder were also present.
AL-5 UT at SR 2408 (Browns Meadow Road)
Stream 40 was approximately eight to ten feet wide at the road crossing but narrowed to less than
two feet wide and only one inch deep roughly 125 feet downstream of the road. Water flow was
barely visible in this narrow, shallow reach. From the constriction, the stream continued another
150 feet before becoming part of the upper end of Dodsons Lake. Heavy sediment deposition
was noted in the floodplain below the road crossing, possibly the results of the heavy rainfall and
high flows resulting from Hurricane Matthew. Above Browns Meadow Road, the UT had a
channel width of approximately 10 feet. A small beaver dam was observed 150 feet above the
road with very little flowing water moving around one end of it. The substrate throughout the
reach assessed was dominated by sand with gravel as subdominant.
AL-4 UT at Cow Pasture
Stream 21 at this location was completely dry at the time of observation. The channel was
approximately six feet wide with a sand and gravel substrate along with a very small amount of
cobble.
AL-3 UT at SR 2407 (Starmount Road) below Dodsons Lake
This section of stream 18 comes out of Dodsons Lake and was wooded above the road crossing.
The stream was estimated to be six feet wide with minimal flow observed only in very shallow
(' one inch deep) areas of this stream reach. Some areas of bank erosion were observed in bends
suggesting periods of high flows. Below the road crossing, the stream narrowed and flowed
through a completely clear-cut area until its confluence with Sandy Creek.
Cape Fear Shiner Survey, HDR1, Randolph County
November 2017
Page 3

AL-2 UT at SR 2407 (Starmount Road)
Stream 21 at this road crossing was incised and had a stream bed that varied between 16 and 22
feet wide. The banks were as much as six feet high with areas of erosion. Little water was
present within the stream bed and very minimal flow was observed between isolated small pools.
This stream was completely dry upstream at the Cow Pasture assessment location (AL-4).
3.5 Methodology
A freshwater fish survey was conducted from approximately 450 yards downstream of the
southbound bridge of US 421 to approximately 50 yards upstream of the bridge (but still just
downstream of the northbound bridge) for a total distance of approximately 500 yards. The
survey reach was selected to include the deep run between the US 421 bridges. The survey was
conducted using a Smith -Root model LR-24 backpack electrofishing unit, dip nets, and a seine.
The electrofishing unit was set to provide an output consistent with the nonlethal levels
established by Holliman et. al., 2003. The stream was sampled with one biologist operating the
electrofishing unit while the other biologists collected the stunned fish with dip nets. All stunned
fish were collected and temporarily placed in five (5) gallon buckets. In addition to the backpack
electrofishing efforts, active seine hauls were made in areas of habitat appropriate for this
collection technique. All fish were identified and released onsite.
3.6 Results
Fourteen freshwater fish species were identified during the survey with a total of 340 individuals
observed (Table 1). The number of individuals of Eastern Mosquitofish (Gambusia holbrooki)
included in the total was a conservative estimate as many more individuals were observed than
were collected. This species is common and is often the only species of fish found in extremely
low dissolved oxygen, stagnant bodies of water such as ditches. No Cape Fear Shiners were
collected or observed during the survey. A total of 923 shocking seconds were utilized during
this survey along with six seine hauls.
Table 1. Freshwater Fish Suecies in Sand v Creek.
Common Name
Scientific Name
No. Individuals
Redbreast Sunfish
Lepomis auritus
41
Bluegill
Lepomis macrochirus
27
Green Sunfish
Lepomis cyanellus
1
Bluehead Chub
Nocomis leptochephalus
6
Creek Chub
Semotilus atromaculatus
11
Margined Madtom
Noturus insignis
2
Flat Bullhead
Ameiurus platycephalus
4
Redfin Pickerel
Esox americanus
4
Highfin Shiner
Notropis altipinnis
1
Golden Shiner
Notemigonus crysoleucas
1
Pirate Perch
Aphredoderus sayanus
1
Creek Chub Sucker
Erimyzon oblongus
1
Eastern Mosquitofish
Gambusia holbrooki
>200*
Cape Fear Shiner Survey, HDR1, Randolph County
November 2017
Page 4

Common Name
Scientific Name
No. Individuals
Tessellated Darter
Etheostoma olmstedi
42
s
�
Total Number of Individuals
340**
Total Number of Species
14
Electrofishing Seconds
923
*This conservative estimate was derived from over 100 individuals being collected and several
times that number being observed.
**The total number of individuals includes an estimated number of Eastern Mosquitofish.
4.0 Discussion/Conclusions
The site assessment results indicate that the small streams in the study area were experiencing
low flow conditions at the time of observation. One assessment location, AL-4, was completely
dry and all the other locations had very low water levels. While these stream conditions may not
be common throughout the year, streams experiencing these conditions tend to support a more
limited aquatic fauna than streams not subjected to such low flow conditions. Although a total of
14 species of fish were collected at the survey location in Sandy Creek, five of the species were
represented by only a single individual. In terms of the number of individuals collected and/or
observed, the Eastern Mosquitofish was by far the dominant species at the survey location. As
previously pointed out, this species is very tolerant of extremely low dissolved oxygen (DO)
levels and its dominance within the survey reach of Sandy Creek suggests the stream has
experienced low DO levels for at least a moderate amount of time.
In addition to the portion of Sandy Creek surveyed for this project, NCDOT has previously
conducted fish surveys at two locations further downstream in Sandy Creek. Sandy Creek at SR
2453 (Kidds Mill Road) was surveyed on April 19, 2016 and Sandy Creek at SR 2481 (Low
Bridge Road) was surveyed on April 19, 2012. No Cape Fear Shiners were collected or observed
during either of these surveys. The results of all three surveys indicate Cape Fear Shiners are not
present in Sandy Creek.
Based the distance to known Cape Fear Shiner records, the current and previous Sandy Creek
fish survey results, and the presence of two dams isolating Sandy Creek from possible
colonization from known downstream populations, impacts to the species will not occur due to
the development of the Greensboro Randolph Megasite.
Biological Conclusion for Cape Fear Shiner: No Effect
Cape Fear Shiner Survey, HDR1, Randolph County
November 2017
Page 5

5.0 References.
Holliman,F.M., J.B. Reynolds, and T.J. Kwak. 2003. A predictive risk model for electroshock -
induced mortality of the endangered Cape Fear shiner. North American Journal of
Fisheries Management 23: 90-912.
LeGrand, Jr., H.E., J.T. Finnegan, S.E. McRae, S.P. Hall. 2010. Natural Heritage Program List of
the Rare Animal Species of North Carolina. N.C. Natural Heritage Program, Raleigh,
NC.
North Carolina Depailiuent of Environmental Quality - Division of Water Resources.2014. 2014
North Carolina 303(d) and Draft 2016 Lists.
http://portal.ncdenr.org/web/wq/ps/mtu/assessment
North Carolina Depaitiuent of Environmental Quality. NPDES Wastewater Treatment Facility
Permits. Accessed July 21, 2017. http://data-
ncdenr.opendata.arcgis.com/datasets/a86af4f7549343419b4c8177cedb3e4b_0
North Carolina Natural Heritage Program (NCNHP). 2017. nheo-2017-04. Natural Heritage
Element Occurrence polygon shapefile. April 12, 2017.
North Carolina Wildlife Resources Commission. Cape Fear Shiner (Notropis mekistocholas).
http://www.ncwildlife.org/Learning/Species/Fish/Cape-Fear-Shiner.
North Carolina Wildlife Resources Commission. Unpublished Aquatics Database.
Pottern, G.B. 2009. 2007 Status update of the Cape Fear Shiner (Notropis mekistocholas).
Report to the North Carolina Resources Commission. 27 pp.
U.S. Fish and Wildlife Service. 2010. Cape Fear Shiner (Notropis mekistocholas) Fact Sheet.
USFWS, Raleigh, NC. https://www.fws.gov/raleigh/species/es_cape_ fear_shiner.hmtl.
U.S. Fish and Wildlife Service. 1988. Cape Fear Shiner Recovery Plan. USFWS, Atlanta, GA.
58 pp.
Cape Fear Shiner Survey, HDR1, Randolph County
November 2017
Page 6

Appendix A
Figures

Legend
Survey Location
Assessment Locations
`NG OneMapfN'gC
B2a�d
;G ograplyiic Info?
Prepared By:
RfelC
Prepared For:
GREENSBORO
RANDOLPH
Freshwater Fish Survey
SURVEY LOCATION ON
SANDY CREEK AT US421
RANDOLPH COUNTY
Date:
Scale
Job No.
November 2017
0 1,000 2,000 Feet
Drawn by: GSM
Checked by
Figure
1
KNM

Legend
Survey Location
Assessment Locations
Cape Fear Shinner
Prepared By:
RfelC
Prepared For:
GREENSBORO
RANDOLPH
NC NHP
Element Occurrence
SURVEY LOCATION ON
SANDY CREEK AT US421
RANDOLPH COUNTY
Guilford County
'Y�
RadoIphCounty
Date:
November 2017
Scale
0
1 Miles
Job No
Drawn by:
Checked by:
Figure
GSM
KNM

1
9
MIN
I
Legend
O NPDES Sites
Assessment Locations
Survey Location
5-Mile Buffer
303(d) Listed Streams
11-r
421
64
62 G#
040ei
Guilford County)
Randolph County
4
B i)dom Creek
i
5 rd'
fnt leas�afnt Creek
OneM
421
Liberty
NV
Prepared By:
RfelC
Prepared For:
GREENSBORO
RANDOLPH
NPDES Dischargers and
303(d) Listed Streams
SURVEY LOCATION ON
SANDY CREEK AT US421
RANDOLPH COUNTY
Date:
November 2017
Scale
0
1 Miles
Job No
Drawn by: GSM
Checked by: KNM
Figure

From: Neil Medlin
To: Miller, Vickie M. (Raleigh)
Cc: Kristina Miller; Henderson. Jonathan
Subject: Cape Fear Shiner Evaluation
Date: Thursday, September 28, 2017 1:48:19 PM
Attachments: image001.pnq
image002.pnq
image003.pnq
image004.pnq
image005.pnq
Vickie,
A fish survey in Sandy Creek at US 421 and stream/habitat assessments at several additional
locations on and in the vicinity of the project site were completed by RK&K staff on September 26,
2017. No Cape Fear Shiners were observed during the survey in Sandy Creek. I have also reviewed
existing information for the species for the northeast portion of Randolph County. Provided that
appropriate sediment and erosion control measures are utilized during construction, development
of the project site will not affect the Cape Fear Shiner.
A draft survey report (summarizing the information collected in the field and all other information
reviewed) will be provided to you as soon as practical. The recommended Biological Conclusion (No
Effect as outlined in the above paragraph) for the Cape Fear Shiner will be included in the report. In
the interim, until you receive the draft report, if you have any specific questions, please let me
know.
NEIL MEDLIN
Senior Project Scientist
RJt 3C
900 Ridgefield Drive, Suite 350
Raleigh, NC 27609
919.878.9560 P 1 919.965.7900 C
www.rkk.com
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