20221432 Ver 1_More Info Received_20221011

Staff Review Form
NORTH CAROLINA
Envlronm¢ntcl Qvofiry
Updated September 4, 2020
Staff Review
Does this application have all the attachments needed to accept it into the review process?*
Yes No
ID# *
20221432
Version* 1
Is this project a public transportation project?*
Reviewer List:*
Select Reviewing Office: *
Submittal Type:*
Yes
• No
Andrew Moore:eads\awmoore3
Asheville Regional Office - [phone]
More Info Received
Does this project require a request for payment to be sent?*
Yes
No

Project Submittal Form
Please note: fields marked with a red asterisk * below are required. You will not be able to submit the form until all
mandatory questions are answered.
Project Type: *
For the Record Only (Courtesy Copy)
New Project
Modification/New Project with Existing ID
More Information Response
Other Agency Comments
Pre -Application Submittal
Re-Issuance\Renewal Request
Stream or Buffer Appeal
Pre -Filing Meeting Date Request was submitted on:
9/9/2022
Project Contact Information
Name:
Adam Tripp
Who is submitting the information?
Email Address: [e-mail]
Project Information
Project Name: Lantz Development
Is this a public transportation project?
Yes
No
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
Yes No Unknown
County (ies)
Henderson
Please upload all files that need to be submited.
Click the upload button or drag and drop files here to attach document
LantzDevelopment-PCN Attachments.pdf 19.43MB
Only pdf or kmz files are accepted.
Describe the attachments or
comments:
Attachments include site plan drawings, wetland / stream delineation, JD, mitigation credit letter, USFWS 9-
Step assessment, etc.
Sign and Submit
By checking the box and signing box below, I certify that:
• I, the project proponent, hereby certifies that all information contained herein is true, accurate, and complete to the
best of my knowledge and belief.

• I, the project proponent, hereby requests that the certifying authority review and take action on this CWA 401
certification request within the applicable reasonable period of time.
• I agree that submission of this online form is a "transaction" subject to Chapter 66, Article 40 of the NC General
Statutes (the "Uniform Electronic Transactions Act");
• I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General
Statutes (the "Uniform Electronic Transactions Act");
• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a
written signature; AND
• I intend to electronically sign and submit the online form.
Signature:
Submittal Date: 10/11/22
Is filled in automatically.

40
Headwater
/ ENVIRONMENTAL INC.
September 2, 2022
910.777.3908 • 1 121 Military Cutoff Dr, Suite C #306, Wilmington, INC 28405
www.headwaterenvironmental.com
North Carolina Department of Environmental Quality —Division of Water Resources
And United States Army Corp of Engineers —Wilmington District
Asheville, North Carolina
Reference: Pre -Construction Notification / Permit Application
Lantz Development
Mills River, Henderson County, North Carolina
Headwater Project # A21-202127
To whom it may concern,
On behalf of 280 Holding Group, LLC (commercial developer), Headwater Environmental, Inc. (Headwater)
is providing this document in support of our Pre -Construction Notification (PCN), submitted on September
1, 2022.
The Site is located at 4794 Boylston Highway in Mills River, Henderson County, North Carolina. According
to Henderson County GIS, the site is 12.84 acres, identified as PIN 9631640262, and it is owned by 280
Holding Group, LLC.
A proposed commercial development, including the construction of four buildings and associated parking
will be generally located on the eastern portion of the Site.
In addition to the information provided in the PCN, Headwater is providing certain attachments to support
the application.
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
2_.
Adam Tripp
Senior Geologist
Attachments: Wetland Delineation Report and Jurisdictional Determination
Site Development Plans
Mitigation Bank Credit Reservation Letter and ILF
USFWS 9-Step Biological Assessment and USFWS Submittal Letter
• IPAC Species List Letter, dated August 12, 2022
• North Carolina Natural Heritage Database Review, August 12, 2022
Species Conclusion Table, August 16, 2022
USFWS Self -Certification Letter, August 12, 2022

Wetland Delineation Report and Jurisdictional
Determination

Headwater
/ ENVIRONMENTAL INC.
Mr. Tim Lantz
JJ Park Property Development LLC
283 Holly Haven Court
Mills River, North Carolina 28759
828.774.9655 • 866 Haywood Road, Asheville, NC 2,9,906
Reference: Wetland Delineation
4797 and 4768 Boylston Highway
Mills River, Henderson County, North Carolina
Headwater Project # A21-202127
Dear Mr. Lantz:
www.headwaterenvironmental.com
January 3, 2022
Headwater Environmental, Inc. (Headwater) is pleased to provide the results of our Wetland
Delineation for the above referenced property. Headwater was retained by you to perform a
Wetland Delineation. The purpose of this report is to document and locate the extent of Waters
of the U.S. within the Site boundary.
PROJECT INFORMATION
The Site is located on Boylston Highway, at the intersection of Hilda Lane in Mills River,
Henderson County, North Carolina. According to Henderson County GIS records, the Site is
identified as PIN 9631-64-0262 (12.84 acres; 4794 Boylston Highway) and PIN 9631-64-0566
(3.24 acres), and owned by 280 Holding Group, LLC.
Regulatory Summary
In order to identify wetlands at the Site, Headwater utilized the "Regional Supplement to the Corps
of Engineers Wetland Delineation Manual: Eastern Mountains and Piedmont", issued April 2012.
Identification of wetlands is based on a three -factor approach involving indicators of hydrophytic
vegetation, hydric soil, and wetland hydrology.
Federal authority to regulate activities in wetlands is contained in Section 404 of the Clean Water
Act (33 USC 1344) and Section 10 of the Rivers and Harbors Act (33 USC 403). These Acts
established a program for regulating the discharge of dredged and fill material into the "Waters of
the United States", which includes wetlands and streams. Section 401 of the Clean Water Act
authorizes States and Tribes to administer the water quality certification process to protect
wetlands and other aquatic resources.
On December 7, 2021, the U.S. Army Corps of Engineers (USACE) and the Environmental
Protection Agency (EPA) issued the revised definition of "Waters of the United States". The
issuance of this revised rule rescinds regulations issued under the Navigable Waters Protection
Rule (2020) and The Clean Water Rule (2015). The proposed revised definition has been
published for public comment. Comments must be received before February 7, 2022.
It is Headwaters understanding that the USACE is regulating Waters of the U.S. as per the rules
set forth prior to 2015. The pre-2015 rules are based on the Rapanos v. United States and
Carabell v. United State Supreme Court cases in 2005/2006. The USACE and EPA issued

Wetland Delineation: Boylston Highway Site
Headwater Project A21-202127
January 3, 2022
guidance requiring that a significant nexus determination must be completed to identify the
connectivity of wetlands to traditionally navigable waters. The Wilmington District of the USACE
in conjunction with the EPA, administers the federal wetlands program in this area. In addition,
the North Carolina Department of Environmental Quality (DEQ) administers the wetlands and
stream buffer program for the State of North Carolina as per Section 401 of the Clean Water Act.
METHODOLOGY
Office Review
Headwater reviewed the 7.5-Minute United States Geological Survey (USGS) Topographic
Quadrangle, Skyland, North Carolina dated 1993. The Site is situated between 2,080 and 2,160
feet above MSL (Figure 1). The Site is depicted as developed land. A topographic high point is
depicted on the western portion of the Site. The elevation slopes downgradient to the southeast,
in the direction of Boylston Highway. An unnamed perennial stream is mapped on the central
portion of the site. The stream flow east, towards Mills River.
Headwater reviewed the printed Soil Survey for Henderson County, North Carolina provided by
the Natural Resources Conservation Service (NRCS), dated 1980 (Figure 2). If streams are
depicted as intermittent or perennial on the most recent printed version of the soil map, a stream
determination is recommended. A stream is depicted within the Site boundary.
According to the NRCS Web Soil Survey (WSS), there are four soil series mapped within the Site
boundary (Figure 3). Fannin silt loam (FaC and FaE), well drained, is mapped throughout the
majority of the site. Hatboro loam (Ha), poorly drained, is mapped along the stream corridor. A
small area of Delanco loam (DeB), moderately well drained, is mapped in the northeastern portion
of Site.
According to the FEMA Flood Map Panel 3700963100J Dated October 2, 2008, the Site is located
outside of the flood hazard zone (Figure 4).
According to the United States Fish and Wildlife, National Wetlands Inventory (NWI), a "Riverine"
feature is depicted on the central portion of the Site (Figure 5).
Headwater obtained LiDAR data from North Carolina Emergency Management, Risk
Management (Figure 6). Depressional areas are depicted on the central and eastern portions of
the Site. The western portion of the Site appears to be part of a larger expansive elevated area
that extends further west.
The subject Site drains to an unnamed tributary in the Mills River basin. According to the North
Carolina Department of Environmental Quality (DEQ), the Mills River is identified as a Class
WS-III water (Waters used as sources of water supply for drinking, culinary, or food processing
purposes where a more protective WS-1 or II classification is not feasible. DEQ does not mandate
buffers within this watershed.
Methodology
Following the office review, the Site reconnaissance was completed on August 12, 2021. The field
review involved a general Site inspection, wetland observations, and a wetland boundary
2

Wetland Delineation: Boylston Highway Site
Headwater Project A21-202127
January 3, 2022
delineation. The purpose of the Site reconnaissance was to verify the published data, inspect the
Site for the presence of wetlands, and delineate the wetland/upland boundaries.
During the field review, examination of wetland characteristics was completed. Data Points were
established and enclosed with this report. The Data Points were used to record field data on
vegetation, soils, and hydrology. Information collected at each data point includes the following:
Characterization of Vegetation
Vegetation at each Data Point was characterized as per the appropriate regional
supplement to the USACE Wetland Delineation Manual for the following stratum (layer):
A. Trees: Woody plants, excluding vines, approximately 20 feet or more in height
and three inches or larger in diameter at breast height (DBH).
B. Saplings: Woody plants, excluding vines, 20 feet or more in height and less than
3 inches DBH.
C. Shrubs: Woody plants approximately 3 to 20 feet in height.
D. Herbs: All, non -woody, herbaceous plants less than 3 feet in height.
E. Vines: All woody vines, regardless of length or height.
Soil Characterization
Soil characteristics at each data point were reviewed through the use of a 2-inch diameter
Dutch auger. Soil samples were obtained from ground surface to a depth necessary to
identify hydric soil characteristics. The matrix color of each sample was identified and
recorded using the standard Munsell Soil Color Chart. Other soil characteristics (i.e.:
textures, concretions, structure) of each sample were also examined and recorded.
Particular emphasis was placed on the identification of (or lack of) certain hydric soil
indicators such as low chroma, and/or mottled soils.
Hydrology
Each data point was examined for evidence of surface and subsurface hydrology. Field
indicators (i.e.: water -stained leaves, oxidized root channels, morphological plant
adaptations, etc.) were identified and recorded. Each point was evaluated for primary and
secondary indications of wetlands hydrology.
FINDINGS AND OBSERVATIONS
The weather during the reconnaissance was sunny with temperatures in the 70s (degrees
Fahrenheit). The parcel boundaries were not marked in the field at the time of the Site visit.
However, the parcel boundaries were discernable by landmark features such as fences, tree lines
and roads. Photographs of the Site visit are enclosed with this report.
The Site consists of grassy and wooded land, with evidence of former residential and farming use.
An unnamed perennial stream bisects the Site from west to east. An intermittent stream bisects
the eastern portion of the Site, flowing from south to north and flows to the perennial stream.
Culverted stream crossing are present and documented at both streams. Refer to Figure 7 for a
depiction of the Site findings.
Headwater recorded one data point (DP) on Site. DP-1 was recorded within a depressed area
(possibly a former stormwater pond) on the southeastern portion of Site. Wetland characteristics
were not observed in the depression.
3

Wetland Delineation: Boylston Highway Site
Headwater Project A21-202127
January 3, 2022
Headwater traversed the perimeter boundaries and made several transects across the interior of
the Site. The soils throughout the uplands consist of tan to orange sandy loam, meeting the criteria
for non-hydric soils. Headwater observed two surface water features (streams) on the Site.
Headwater observed no wetlands on the Site. Wetland Determination Data Forms that support
our findings are included as an attachment. Figure 7 depicts the approximate locations of the
jurisdictional features.
REGULATORY VERIFICATION
It is Headwaters' understanding that the proposed use of the Site is for mixed use development.
A Preliminary Jurisdictional Determination (PJD) was provided by the USACE Wilmington District
on November 17, 2021 (attached). The PJD was assigned Action ID SAW-2021-02270.
CONCLUSIONS AND RECOMENDATIONS
• Headwater identified two (2) jurisdictional streams on Site. The jurisdictional streams on Site
are regulated by the USACE.
Henderson County applies a 30-foot stream buffer to perennial and intermittent surface water
features, if the feature is approximately shown on either the most recent version of the soil
survey map prepared by the Natural Resources Conservation Service of the United States
Department of Agriculture or the most recent version of the 1:24,000 scale (7.5 minute)
quadrangle topographic maps prepared by the United States Geological Survey (USGS). As
such, the 30-foot stream buffer should only apply to the perennial stream shown on Figure 7.
• The Henderson County stream buffer requires that "all built -upon area shall be at a minimum
of:
0 30 feet landward of all perennial and intermittent surface waters; or
0 100 feet landward of any perennial surface waters located within a water supply
watershed when using the high -density option.
• Desirable artificial stream bank or shoreline stabilization is permitted. No new development is
allowed in the buffer except for water dependent structures, other structures such as flag
poles, signs and security lights which result in only minimal increases in impervious surface
area and public projects, such as road crossings and greenways where no practical alternative
exists. These activities should minimize built -upon area; direct runoff away from the surface
waters; and maximize the utilization of stormwater best management practices."
LIMITATIONS
Observations, conclusions, and/or recommendations pertaining to the potential jurisdictional
wetland areas within the subject Site are limited to the conditions observed, and/or materials
reviewed at the time this study was undertaken.
This report is provided for the exclusive use of Tim Lantz; their successors and/or assigns and is
not intended to be used or relied upon in connection with other projects or by other unidentified
third parties. The use of this report by an undesignated third party or parties will be at such party's
sole risk and Headwater disclaims liability for such third -party use or reliance.
Headwater appreciates the opportunity to provide our environmental services for this project. If you
have questions or need additional information, please contact us at [phone].
12

Wetland Delineation: Boylston Highway Site
Headwater Project A21-202127
January 3, 2022
Respectfully submitted,
Headwater Environmental, Inc.
Adam Tripp Melanie Kemp
Senior Geologist Environmental Scientist
Enclosure: Figures 1 to 7
Data Point DP-1
Photographs
PJD

Figures

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1,000 2,000 4,000
QSite Boundary Feet
SOURCE FIGURE 1
Headwater 1993 USGS SITE LOCATION MAP
/ ENVIRONMENTAL I NC. 7.5-minute Topographic Quadrangle Timothy Lantz/LFI Holding Group, LLC
Skyland, North Carolina 4794 & 4768 Boylston Hwy
Contour Interval = 10 feet Mills River, INC 28732
Date: 6/21/2021 Reference Scale: 1:24,000 Headwater Project #W21-169
Prepared By: K. Starkes

Tec
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APPROXIMATE r a C
SITE LOCATION
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TeL
F aC FA
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BaB
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Legend
r
0 450 900 1,800
Site Boundary FaE Deb OT09 Feet
r e
SOURCE FIGURE 2
yor Headwater NRCS PRINTED SOIL SURVEY MAP
ENVIRONMENTAL I NC. Printed Soil Map Timothy Lantz/LFI Holding Group, LLC
Henderson County, North Carolina 4794 & 4768 Boylston Hwy
Dated 1980 Mills River, NC 28732
Date: 6/21/2021 Reference Scale: 1:10,000 Headwater Project #W21-169
Prepared By: K. Starkes N

Map Unit
Symbol
Map Unit Name
Acres in
AOI
Percent of AOI
DeB
Delanco (dillard) loam,
0.3
2.00%
2 to 7 percent slopes
FaC
Fannin silt loam, 7 to
3.3
20.60%
15 percent slopes
FaE
Fannin silt loam, 15 to
8.1
50.10%
25 percent slopes
Ha
Hatboro loam
4.4
27.40%
Totals for Area of Interest
16.1
100.00%
5
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i,
CITGO
First Citizens
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e
Legend F
Site Boundary
I--1 'v
Soil Boundary �� 0 80 160 320
Feet
Headwater
SOURCE
FIGURE 3A
WEB SOIL SURVEY MAP
ENVIRONMENTAL INC.
USDA
Web Soil Survey
Timothy Lantz/LFI Holding Group, LLC
ESRI Imagery (2020)
4794 & 4768 Boylston Hwy
Mills River, NC 28732
Date:
6/21/2021
Reference Scale: 1:3,000
Headwater Project #W21-169
Prepared By:
K. Starkes

Q FIRM Panels
Flood Hazard Boundaries J
Limit Lines:
SFHA / Flood Zone Boundary
Flood Hazard Zones
Zone AE �
1% Annual Chance Flood Hazard
Regulatory Floodway
Special Floodway
Area of Undetermined Flood Hazard Zone AE
0.2% Annual Chance Flood Hazard Zone AE
Future Conditions 1% Annual Chance Flood Hazard
Area with Reduced Risk Due to Levee 1
zone AE
Area with Risk Due to Levee A'
APPROXIMATE
SITE LOCATION
Legend
Site Boundary
Zone AE 1�
Headwater SOURCE
/ ENVIRONMENTAL INC. FEMA
Map Panel #3700963100J
Dated 10/02/2008
Date: 6/21/2021 ESRI Imagery (2020)
Reference Scale: 1:15,000
Prepared By: K. Starkes �'^J
'A
.ti
09
101
0 450 900 1,800
Feet
FIGURE 4
FEMA FIRM MAP
Timothy Lantz/LFI Holding Group, LLC
4794 & 4768 Boylston Hwy
Mills River, NC 28732
Headwater Project #W21-169

t
Wetlands
0 Estuarine and Marine Deepwater
❑ Estuarine and Marine wetland
❑ Freshwater Emergent Wetland
Freshwater Forested/Shrub Wetland
❑ Freshwater Pond
E Lake
❑ Oth
e SA-
Riverine S `
I
Legend
0 450 900 1,800
Site Boundary Feet
SOURCE FIGURE 5
Headwater NATIONAL WETLANDS
/ ENVIRONMENTAL INC. USFWS INVENTORY MAP
National Wetlands Inventory
Timothy Lantz/LFI Holding Group, LLC
ESRI Imagery (2020) 4794 & 4768 Boylston Hwy
Date: 6/21/2021 Mills River, NC 28732
Reference Scale: 1:15,000 Headwater Project #W21-169
Prepared By: K. Starkes

Legend
= Site Boundary
Elevation (m) above MSL
.� 2201.33
"J 2076.24
Headwater
Ae ENVIRONMENTAL INC.
Date: 6/21 /2021
Prepared By: K. Starkes
SOURCE
NCEM Risk Management
QL2 LIDAR DEM 05
Reference Scale: 1:2,000
0 50 100 200
Feet
FIGURE 6
LIDAR MAP
Timothy Lantz/LFI Holding Group, LLC
4794 & 4768 Boylston Hwy
Mills River, NC 28732
Headwater Project #W21-169

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Data Point DP-1

U.S. Army Corps of Engineers OMB Control #: 0710-xxxx, Exp: Pending
WETLAND DETERMINATION DATA SHEET — Eastern Mountains and Piedmont Region Requirement Control Symbol EXEMPT:
See ERDC/EL TR-07-24; the proponent agency is CECW-CO-R (Authority: AR 335-15, paragraph 5-2a)
Project/Site: 4794 & 4768 Boylston Hwy City/County: Mills River / Henderson Sampling Date: 8/12/21
Applicant/Owner: Timothy Lantz/LFI Holdings Group, LLC State: NC Sampling Point: DP-1
Investigator(s): Adam Tripp (Headwater Environmetal) Section, Township, Range: Mills River
Landform (hillside, terrace, etc.): Possible stormwater pond Local relief (concave, convex, none): concave Slope (%): 0-1
Subregion (LRR or MLRA): LRR N, MLRA 130B Lat: 35.38514 Long:-82.56911 Datum: Nad83
Soil Map Unit Name: Hatboro Loam NWI classification: Upland
Are climatic / hydrologic conditions on the site typical for this time of year? Yes x No (If no, explain in Remarks.)
Are Vegetation Soil or Hydrology significantly disturbed? Are "Normal Circumstances' present? Yes X No
Are Vegetation Soil or Hydrology naturally problematic? (If needed, explain any answers in Remarks.)
SUMMARY OF FINDINGS — Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Yes No X Is the Sampled Area
Hydric Soil Present? Yes No X within a Wetland? Yes No X
Wetland Hydrology Present? Yes No X
Remarks:
HYDROLOGY
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two required)
Primary Indicators (minimum of one is required: check all that apply)
_ Surface Soil Cracks (136)
—Surface Water (Al) —True
Aquatic Plants (1314)
_ Sparsely Vegetated Concave Surface (138)
_ High Water Table (A2) —Hydrogen
Sulfide Odor (Cl)
_ Drainage Patterns (1310)
—Saturation (A3) —Oxidized
Rhizospheres on Living Roots (C3)
—Moss Trim Lines (B16)
—Water Marks (B1) —Presence
of Reduced Iron (C4)
_ Dry -Season Water Table (C2)
—Sediment Deposits (132) —Recent
Iron Reduction in Tilled Soils (C6)
—Crayfish Burrows (C8)
—Drift Deposits (133) _Thin
Muck Surface (C7)
_ Saturation Visible on Aerial Imagery (C9)
_Algal Mat or Crust (134) _Other
(Explain in Remarks)
_Stunted or Stressed Plants (D1)
—Iron Deposits (135)
_ Geomorphic Position (D2)
_ Inundation Visible on Aerial Imagery (137)
—Shallow Aquitard (D3)
—Water-Stained Leaves (139)
_ Microtopographic Relief (D4)
Aquatic Fauna (1313)
FAC-Neutral Test (D5)
Field Observations:
Surface Water Present? Yes No
x Depth (inches):
Water Table Present? Yes No
x Depth (inches):
Saturation Present? Yes No
x Depth (inches):
Wetland
Hydrology Present? Yes No X
includes capillary fringe)
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:
Remarks:
Area is a depression adjacent to Boylsyon Hwy and may have been used as a stormwater pond, possibly during Hwy construction.
ENG FORM 6116-4-SG, JUL 2018 Eastern Mountains and Piedmont — Version 2.0

VEGETATION (Four Strata) - Use scientific names of plants.
Sampling Point: DP-1
Absolute
Uominant
Indicator
Tree Stratum (Plot size:
40 feet )
% Cover
Species?
Status
Dominance Test worksheet:
1.
Pyrus calleryana
70
Yes
UPL
Number of Dominant Species
2.
Prunus serotina
10
No
FACU
That Are OBL, FACW, or FAC: 2 (A)
3.
Total Number of Dominant
4.
Species Across All Strata: 7 (B)
5.
Percent of Dominant Species
6.
That Are OBL, FACW, or FAC: 28.6% (A/B)
7.
Prevalence Index worksheet:
80
=Total Cover
Total % Cover of: Multiply by:
50% of total cover:
40 20% of total cover:
16
OBL species 0 x 1 = 0
Saplina/Shrub Stratum (Plot size: 40 feet
)
FACW species 50 x 2 = 100
1.
Juglans nigra
70
Yes
FACU
FAC species 10 x 3 = 30
2.
FACU species 130 x 4 = 520
3.
UPL species 90 x 5 = 450
4.
Column Totals: 280 (A) 1100 (B)
5.
Prevalence Index = B/A = 3.93
6.
Hydrophytic Vegetation Indicators:
7.
_ 1 - Rapid Test for Hydrophytic Vegetation
8.
2 - Dominance Test is >50%
9.
3 - Prevalence Index is <_3.01
70
=Total Cover
_
4 - Morphological Adaptations' (Provide supporting
50% of total cover:
35 20%
of total cover:
14
data in Remarks or on a separate sheet)
Herb Stratum (Plot size:
40 feet )
_ Problematic Hydrophytic Vegetation' (Explain)
1.
Solidago gigantea
50
Yes
FACW
Indicators of hydric soil and wetland hydrology must
2.
Glechoma hederacea
50
Yes
FACU
be present, unless disturbed or problematic.
Definitions of Four Vegetation Strata:
3.
4.
Tree - Woody plants, excluding vines, 3 in. (7.6 cm) or
5.
more in diameter at breast height (DBH), regardless of
6
height.
7.
Sapling/Shrub -Woody plants, excluding vines, less
8.
than 3 in. DBH and greater than or equal to 3.28 ft
9
(1 m) tall.
10.
Herb - All herbaceous (non -woody) plants, regardless
11.
of size, and woody plants less than 3.28 ft tall.
100
=Total Cover
Woody Vine - All woody vines greater than 3.28 ft in
50% of total cover:
50 20% of total cover:
20
height.
Woody Vine Stratum (Plot size: 40 feet )
1.
Vitis vinifera
10
Yes
UPL
2.
Rubus frondisentis
10
Yes
UPL
3.
Clematis virginiana
10
Yes
FAC
4.
5.
Hydrophytic
30
=Total Cover
Vegetation
50% of total cover:
15 20% of total cover:
6
Present? Yes No x
Remarks: (Include photo numbers here or on a separate sheet.)
ENG FORM 6116-4-SG, JUL 2018 Eastern Mountains and Piedmont -Version 2.0

SOIL Sampling Point: DP-1
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)
Depth
Matrix
Redox Features
(inches)
Color (moist)
% Color (moist) % Type LOC2
Texture Remarks
0-6
7.5YR 4/4
100
Sandy
6-12
7.5YR 4/4
100
Sandy
12-18
7.5YR 4/4
100
Sandy
Type: C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sand Grains.
2Location: PL=Pore Lining, M=Matrix.
Hydric Soil Indicators:
Indicators for Problematic Hydric Soils3:
_ Histosol (Al)
_ Polyvalue Below Surface (S8) (MLRA 147, 148)
_ 2 cm Muck (A10) (MLRA 147)
Histic Epipedon (A2)
_Thin Dark Surface (S9) (MLRA 147, 148)
_Coast Prairie Redox (A16)
_Black Histic (A3)
_Loamy Mucky Mineral (F1) (MLRA 136)
(MLRA 147, 148)
—Hydrogen Sulfide (A4)
_ Loamy Gleyed Matrix (F2)
—Piedmont Floodplain Soils (F19)
_ Stratified Layers (A5)
_ Depleted Matrix (F3)
(MLRA 136, 147)
_ 2 cm Muck (A10) (LRR N)
_ Redox Dark Surface (F6)
—Red Parent Material (F21)
_ Depleted Below Dark Surface (A11)
_ Depleted Dark Surface (F7)
(outside MLRA 127, 147, 148)
_Thick Dark Surface (Al2)
_ Redox Depressions (F8)
_Very Shallow Dark Surface (F22)
—Sandy Mucky Mineral (S1)
_ Iron -Manganese Masses (F12) (LRR N,
—Other (Explain in Remarks)
Gleyed Matrix (S4)
MLRA 136)
—Sandy
—Sandy Redox (S5)
_ Umbric Surface (F13) (MLRA 122, 136)
3Indicators of hydrophytic vegetation and
—Stripped Matrix (S6)
—Piedmont Floodplain Soils (F19) (MLRA 148)
wetland hydrology must be present,
Dark Surface (S7)
Red Parent Material (F21) (MLRA 127, 147, 148)
unless disturbed or problematic.
Restrictive Layer (if observed):
Type:
Depth (inches):
Hydric Soil Present? Yes No x
Remarks
ENG FORM 6116-4-SG, JUL 2018 Eastern Mountains and Piedmont — Version 2.0

Photographs

Site Photos-4794 & 4768 Boylston Hwy
Headwater Project #W21-169/A21-202127
Photograph 1: View of non -jurisdictional ditch traversing the Site from south to north.
wig
At f
-1-OF
-
_
Photograph 2: View of non -jurisdictional ditch.
Photographs Taken on August 12, 2021 Page 1

Site Photos-4794 & 4768 Boylston Hwy
Headwater Project #W21-169/A21-202127
Photograph 3: Soil from data point DP-1
Photographs Taken on August 12, 2021 Page 2

Preliminary Jurisdictional Determination
(See Additional Attachment)

U.S. ARMY CORPS OF ENGINEERS
WILMINGTON DISTRICT
Action ID: SAW-2021-02270 County: Henderson U.S.G.S. Quad: Skyland
NOTIFICATION OF JURISDICTIONAL DETERMINATION
Property Owner/Applicant: 280 Holding Group, LLC / Attn.: Tim Lantz
Address: 283 Holly Haven Court
Mills River, NC 28759
Telephone Number: 419-438-0698
Email: [e-mail]
Size (acres): 16.08 Nearest Town: Mills River
Nearest Waterway: UTs Mills River Coordinates: 35.38502,-82.56991
River Basin/HUC: Upper French Broad (06010105)
Location description: The site is located on a tract of land (PINS 9631-64-0262 and 9631-64-0566) at 4794 and 4768
Boylston Highway in Mills River, Henderson County, North Carolina.
Indicate Which of the Following Apply:
A. Preliminary Determination
X There are waters on the above described property, that maybe 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 have been delineated,
and the delineation has been verified by the Corps to be sufficiently accurate and reliable. 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 are wetlands on the above described 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 overall 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 of the U. S. on your 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 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 of the U.S., including wetlands, on the above described project area 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 of the U.S. on your 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 of the U.S., including wetlands, on your project area have been delineated and the delineation has been
verified by the Corps. We strongly 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 of the U.S., including wetlands, have been delineated and surveyed and are accurately depicted on the
plat signed by the Corps Regulatory Official identified below on . 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 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
(LAMA). 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 David Brown at
828-271-7980, ext. 4232 or [e-mail].
C. Basis for Determination:
See attached preliminary jurisdictional determination form.
D. Remarks:
The potential waters of the U.S. at this site were verified by the Corps during a site inspection on November 5, 2021, and
are as approximately depicted on the attached Determination Map, Figure 7, submitted by Headwater Environmental,
Inc.
E. Attention USDA Program Participants
The delineation included herein has been conducted to identify the location and extent of the aquatic resource boundaries
and/or the jurisdictional status of aquatic resources for purposes of the Clean Water Act for the particular site identified in
this request. This delineation and/or jurisdictional determination may not be valid for the Wetland Conservation Provisions of
the Food Security Act of 1985, as amended. If you or your tenant are USDA program participants, or anticipate participation
in USDA programs, you should discuss the applicability of a certified wetland determination with the local USDA service
center, prior to starting work.
F. Appeals Information for Approved Jurisdiction Determinations (as indicated in Section B. above)
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: Mr. Philip A. Shannin
Administrative Appeal Review Officer
60 Forsyth Street SW, Floor M9
Atlanta, Georgia 30303-8803
OR
philip. a. shannin�usace. army.mil

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, N/A (preliminary jurisdictional
determination).
It is not necessary to submit an RFA form to the Division Office if you do not object to the determination in this
correspondence.
Corps Regulatory Official:
g �'
David Brown
Issue Date of JD: November 17, 2021
Expiration Date: N/A preliminary jurisdictional determination
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 our Customer Satisfaction Survey, located online at https://regulatory.ops.usace.army.mil/customer-
service-survey/
Copy Furnished (by email):
Headwater Environmental, Inc., Adam Tripp, [e-mail]

RL NOTIFICATION OF ADMINISTRATIVE APPEAL OPTIONS AND PROCESS AND
iv
REQUEST FOR APPEAL
Applicant: 280 Holding Group, LLC / Attn.: Tim Lantz File Number: SAW-2021-02270 Date: November 17, 2021
Attached is:
See Section below
❑ INITIAL PROFFERED PERMIT Standard Permit or Letter olpermissionl
A
❑ PROFFERED PERMIT Standard Permit or Letter ofpermission)
B
❑ PERMIT DENIAL
C
❑ APPROVED JURISDICTIONAL DETERMINATION
D
NJ 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 htti)://www.usace.army.mil/Missions/CivilWorks/Re2ulatoryPro2ramandPennits.asi)x or 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 11 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 11 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 11 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.
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 also
appeal process you may contact:
contact:
District Engineer, Wilmington Regulatory Division,
Mr. Philip Shannin, Administrative Appeal Review Officer
Attn: David Brown
CESAD-PDO
69 Darlington Avenue
U.S. Army Corps of Engineers, South Atlantic Division
Wilmington, North Carolina 28403
60 Forsyth Street, Room 1OM15
Atlanta, Georgia 30303-8801
828-271-7980, ext. 4232
[e-mail].
Phone: [phone]
Email: philip.a.shannin@us ace.army.mil
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 opportunity to participate in all site investigations.
Date:
Telephone number:
Signature of appellant or agent.
For appeals on Initial Proffered Permits send this form to:
District Engineer, Wilmington Regulatory Division, Attn: David Brown, 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 (JD) FORM
U.S. Army Corps of Engineers
I:YTel,T" t111111KI Dim 100[1] Nu /:11 Y 1170
A. REPORT COMPLETION DATE FOR PRELIMINARY JD: November 17, 2021
B. NAME AND ADDRESS OF PERSON REQUESTING PRELIMINARY JD:
280 Holding Group, LLC / Attn.: Tim Lantz
283 Holly Haven Court
Mills River, NC 28759
C. DISTRICT OFFICE, FILE NAME, AND NUMBER:
CESAW-RG-A, SAW-2021-02270, 4794 and 4768 Boylston Highway
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION:
The site is located on a tract of land (PINS 9631-64-0262 and 9631-64-0566) at 4794 and 4768 Boylston Highway in
Mills River, Henderson County, North Carolina.
State: NC County/parish/borough: Henderson City: Mills River
Center coordinates of site (lat/long in degree decimal format): 35.38502,-82.56991
Universal Transverse Mercator: N/A
Name of nearestwaterbody: UTs Mills River
E. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY):
Office (Desk) Determination. Date: November 17, 2021
Field Determination. Date(s): November 17, 2021
Use the table below to document aquatic resources and/or aquatic resources at different sites
TABLE OF AQUATIC RESOURCES INREVIEW AREA WHICH "MAY BE" SUBJECT TO REGULATORY
JURISDICTION
Centered Coordinates
Estimated Amount of
Geographic
(decimal degrees)
Aquatic Resource in
Type of Aquatic
Authority to Which
Site Number
Review Area
Resources
Aquatic Resource
Latitude Longitude
(linear feet or acre)
"May Be" Subject
Perennial Stream
35.38514
-82.56911
1,2401f (0.73 ac)
Non -wetland Waters
Section 404
(UT Mills River)
Intermittent Stream
35.3844
-82.5694
4501f (0.026 ac)
Non -wetland Waters
Section 404
(UT Mills River)
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 AJD 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 AJD 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 preliminary JD (check all that apply) - Checked items should be included in subject file.
Appropriately reference sources below where indicated for all checked items:
Maps, plans, plots or plat submitted by or on behalf of preliminary JD requester: Headwater Environmental, Inc.
Data sheets prepared/submitted by or on behalf of preliminary JD requester. Headwater Environmental, Inc.
® Office concurs with data sheets/delineation report.
❑ Office does not concur with data sheets/delineation report. Rational:
❑ Data sheets prepared by the Corps:
❑ Corps navigable waters' study:
❑ U.S. Geological Survey (USGS) Hydrologic Atlas:
❑ USGS NHD data.
❑ USGS 8 and 12 digit HUC maps.
® USGS map(s). Cite scale & quad name: Skyland
® Natural Resources Conservation Service (MRCS) Soil Survey.
Citation: Henderson County, NC
❑ National wetlands inventory (NWI) map(s). Cite name:
❑ State/Local wetland inventory map(s):
® Federal Emergency Management Agency (FEMA) / Flood Insurance Rate Map (FIRM) maps: Map No. 3700963100J,
effective date Oct. 2, 2008
❑ 100-year Floodplain Elevation is: (National Geodectic Vertical Datum of 1929)
® Photographs: ® Aerial (Name & Date): Google Earth Pro — Apr. 2019, Oct. 2015, Nov. 2013, Oct. 2010, Apr. 2007,
Apr. 2002, Mar. 1998, and Mar. 1994
® Other (Name & Date): SAW Regulatory Viewers — USGS Hydrography Dataset and LIDAR DEM, Hillshade
and Slope
❑ Previous determination(s). File no. and date of response letter:
❑ Applicable/supporting scientific literature:
® Other information (please specify): NOAA AHPS Precipitation Analysis Nov. 9, 2021, last 30 days; NOAA
Climatological Data Oct. and Nov. 2021; and USGS National Water Information System, Mills River Gauge Station
(USGS 03446000) data Oct. 10 — Nov. 11, 2021

The streams on the property are UTs of the Mills River. These streams exhibit physical ordinary high water mark
(OHWM) indicators including, break in slope; developed bed and bank; changes in sediment texture and soil
character; natural line impressed on the bank; shelving; absence of vegetation; leaf litter washed away; sediment
deposition and sorting; water staining; presence of debris; and scour. Aquatic life was observed in the perennial
stream. The perennial stream is depicted as solid blue lines on the USGS 7.5 minute quadrangle map Skyland and the
most current Natural Resource Conservation Service Soil Survey for Henderson County. The UTs of the Mills River
into the Mills River, a traditional navigable water.
IMPORTANT NOTE: The information recorded on this form has not necessarily been verified by the Corps and
should not be relied upon for later jurisdictional determinations.
I <-r �_..
David Brown, November 17, 2021
Signature and date of Regulatory
staff member completing
preliminary JD
In File with submitted JD Request
Headwaters Environmental, Inc.
(signed and dated request preliminary JD per agent
authorization)
Please sign this Preliminary JD Form. Keep a signed copy for your record and return a signed form to the Asheville
Regulatory Field Office by mail or a -mail
USA rmy Corps of Engineers -Wilmington District
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
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 finalizing an action.

SOURCES
Reference Scale: 1:1,500
0
N
❑
N
<13
co
Prepared By:

Site Development Plans

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Mitigation Bank Credit Reservation Letter and
ILF

40
Headwater
/ ENV I R ON MENTAL INC.
September 1, 2022
Kelly Williams
In -Lieu Fee Program Coordinator
Division of Mitigation Services
Department of Environmental Quality
1652 Mail Service Center
Raleigh, NC 27699-1652
910.777.3908 • 30 Westgate Pkwy, #356, Asheville, North Carolina 28806
Reference: Mitigation Credit Percentage Increase Request
Lantz Development
Mills River, Henderson County, North Carolina
Headwater Project # A21-202127
To whom it may concern,
www.headwaterenvironmental.com
On behalf of 280 Holding Group, LLC (commercial developer), Headwater Environmental, Inc. (Headwater)
is providing this request letter associated with obtaining mitigation credits for the proposed Lantz
Development, located at 794 Boylston Highway, Mills River, North Carolina. The development is located in
the French Broad River Basin (06010105 HUC).
All private mitigation banks in the region are empty or all available credits are under contract except for the
Tarkiln Branch Mitigation site. Because Tarklin Branch is a preservation only bank, this bank may provide
only credits for 25% of an impactor's mitigation needs, without DEQ approval to provide a greater
percentage. Tarklin Branch mitigation bank has enough available credits to fulfill 100% of the Lantz
Development's need.
Since no other private mitigation banks are available, we request that all credits or a higher percentage of
mitigation credits than the 25% cap be allowed to be provided to the Lantz Development from the Tarkiln
Branch Mitigation site.
The Mitigation Credit Assurance Letter for Tarklin Branch and the DMS ILF Statement for the Lantz
Development are attached. We appreciate the opportunity to provide this letter for your review. Please
contact us if you have questions or require additional information.
Sincerely,
Headwater Environmental, Inc.
'Z'
Adam Tripp
Senior Geologist
Attachments: DMS ILM Mitigation Request Statement —Lantz Development
Mitigation Credit Assurance Letter: EWS08172022.112.5
CC: Erin Davis, DEQ-DWR

EW
SOLUTIONS
Adam Tripp, P.G.
Senior Geologist
Headwaters Environmental, Inc.
30 Westgate Parkway, 9356
Asheville, NC 28806
Subject: Mitigation Credit Assurance Letter: EWS08172022.112.5
Headwater Project #W21-169
4794 & 4768 Boylston Hwy Mills River, NC 28732
Dear Adam,
August 17, 2022
The purpose of this letter is to notify you that EW Solutions (EWS) will provide up to 25% of
the necessary compensatory stream mitigation for the subject project. The provided credits are
from the Tarkiln Branch Mitigation Site (SAW-2019-02331), a preservation only mitigation
site. It is important to note that if a greater percentage of credit is deemed appropriate by the
DWR Director, EWS has credit available to satisfy up to 100% of the compensatory stream
mitigation for the subj ect prof ect.
Based on the information supplied by you on August 16th, 2022, the impacts are located in CU
06010105 of the French Broad basin in the Blue Ridge Eco-Region, and are as follows:
Impact Type
Total Permitted Impacts
Stream cool thermal regime)
450 linear feet
EWS agrees to provide 112.5 stream (cold) credits from the Tarkiln Branch Mitigation site at
the current state rate of $646.12 per credit; a total of $72,688.50.
Furthermore, if the DWR Director deems it appropriate, EWS also agrees to provide credits
beyond the 25% cap (up to 100% of the request) at the most recent past state rate of $603.87
per credit; the dollar value of additional credit beyond the cap will be calculated based on the
credit unit value of that additional percentage allowed by the DWR Director, if any. More
details are provided in Exhibit A: Letter of Credit Reservation.
If you have any questions or need additional information, please contact David Tuch or Owen
Carson at 828.253.6856.
Sincerely,
David Tuch
Managing Partner
EW Solutions
37 Haywood Street, Suite 100 Asheville NC 28801 828.253.6856 ex. 202

EXHIBIT A: LETTER OF CREDIT RESERVATION
Credit Reservation No. EWS08172022.112.5 Dated August 17, 2022
Provider
Tarkiln Branch Mitigation Site
EW Solutions
37 Haywood Street, Suite 100
Asheville, NC 28801
SAW-2019-02331
Dear Sir or Madam
Account Party
280 Holding Group
Attn: Tim Lantz
283 Holly Haven Court
Mills River, NC 28759
We herebv establish our Credit Reservation No. EWS08172022.112.5
at the request and for the account of
280 Holding Group
Attn: Tim Lantz
283 Holly Haven Court
Mills River, NC 28759
up to the amount of
Permittee Name and Address
112.5
riverine Cold El
Cool Warm
Totaling: $72,688.50
and if a greater percentage of credit is
approved by the DWR Director
up to the amount of
337.5
riverine Cold El Cool Warm
credits @ $646.12/credit
credits @ $603.87/credit*
*This dollar value is yet to be determined and dependent upon official approval of release of credits beyond the 25% cap. In the event of
DWR Director approval, this letter will be updated according to the additional approved amount of credit and its subsequent dollar value.
This letter of Credit is effective as of _August 17, 2022 and shall be valid for 180 days. This letter
of Credit may be renewed following expiration but will be issued at the current rate in effect on the date of
renewal.
Whenever this letter of credit is drawn upon under and in compliance with the terms of this credit, we shall
honor such draft upon presentation to us a Credit Release Letter issued by a representative of the United
States Army Corps of Engineers. Following receipt of payment we shall then issue the signed Credit Release
Letter and record the sale in the official Mitigation Bank Credit Ledger.
David Tuch, Managing Partner, EW Solutions
August 17, 2022
Date

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DMS ILF Mitigation Request Statement of Compliance with §143-214.11 & 143-214.20
(link to G.S. 143-214.11)
Prior to accessing the Division of Mitigation Services (DMS), state law requires applicants to
demonstrate compliance with G.S. § 143-214.11 and 143-214.20. All requests MUST include this form
signed and dated by the permit applicant or an authorized agent.
Compliance Statement:
I have read and understand G.S. § 143-214.11 and 214.20 and have, to the best of my
knowledge, complied with the requirements. I understand that participation in the DMS is
voluntary and subject to approval by permitting agencies.
Please check all that apply:
❑ Applicant is a Federal or State Government Entity or a unit of local government
meeting the requirements set forth in G.S. 143-214.11 and is not required to
purchase credits from a mitigation bank.
❑ There are no listed mitigation banks with the credit type I need located in the
hydrologic unit where this impact will take place (link to QwR fist)
✓❑ Mitigation bank(s) in the hydrologic unit where the impacts will occur have been
contacted and credits are not currently available.
❑ The DWR or the Corps of Engineers did not approve of the use of a mitigation
bank for the required compensatory mitigation for this project.
❑ This is a renewal request and the permit application is under review. Bank
credits were not available at the time the application was submitted.
Enter date permit application was submitted for review:
Note: It is the applicant's responsibility to document any inquiries made to private mitigation
banks regarding credit availability.
AT I have read and understand the DMS refund policies (attached)
initial here
Signature of Applicant or Agent
8/17/22
Date
Adam Tripp
Printed Name
Lantz Development 4794 Boylston hwy mills river nc
Project Name Location
Print Form

Direct questions to Kelly Williams at 919-707-8915 or kelly.williams(aD_ncdenr.gov or to the front desk at 919-707-8976

Refund Policy for Fees Paid to DMS In -Lieu Fee Programs (9/21/2009)
Purpose: The purpose of this policy is to make clear the circumstances and process under which a
permittee can obtain a refund while simultaneously balancing customer service and responsible
business practices. This policy applies to all refund requests made on or after the publication date of
this policy.
Policy Statement: The policy of DMS is to allow for refunds under certain conditions.
1. All refund requests must be made in writing to the DMS In -Lieu Fee Program Coordinator at
kelly.williams(a)-ncdenr.gov.
2. All refund requests are subject to fund availability. DMS does not guarantee fund availability for
any request.
3. The request must either come from the entity that made the payment or from an authorized agent.
Third parties requesting refunds must provide written authorization from the entity that made the
payment specifying the name and address of the authorized refund recipient.
4. Refund requests related to unintended overpayments, typographical errors or incorrect invoices
should be brought the attention of the In -Lieu Fee Program Coordinator as soon as possible. Such
requests are typically approved without delay.
5. Payments made under an incremental payment arrangement are not eligible for refunds.
6. Refund requests made within nine months of payment to DMS will only be considered for requests
associated with projects that have been terminated or modified where the permittee's mitigation
requirements have been reduced. Such requests must be accompanied by written verification from the
permitting agency that the project has been canceled, the permits have been rescinded or have been
modified, or the mitigation requirements have been reduced.
7. Refund requests made more than nine months from the payment date will only be considered for
permits that were terminated or modified to not require any mitigation. Such requests must be
accompanied by written verification from the permitting agency that the project has been canceled, the
permits have been rescinded and/or mitigation is no longer required.
8. Refund requests not meeting the criteria specified above are not eligible for a refund.
9. Refund requests that meet the criteria above will be elevated to DMS Senior Management for
review. The following considerations apply to all refund requests:
a. availability of funds after consideration of all existing project and regulatory obligations
b. the date the payment was made
c. the likelihood DMS can use the mitigation procured using the payment to meet other
mitigation requirements
10. Once a refund has been approved, the refund recipient must provide a completed W-9 form to the
DMS In -Lieu fee Program Coordinator within two weeks in order to process the refund though the
State Controller's Office.
11. All decisions shall be final.

USFWS 9-Step Biological Assessment and
USFWS Submittal Letter
• IPAC SPECIES LIST LETTER, DATED AUGUST 12, 2022
• NORTH CAROLINA NATURAL HERITAGE DATABASE REVIEW,
AUGUST 12, 2022
• SPECIES CONCLUSION TABLE, AUGUST 16, 2022
• USFWS SELF -CERTIFICATION LETTER, AUGUST 12, 2022

40
Headwater
/ ENVIRONMENTAL INC.
910.777.3908 • 1 121 Military Cutoff Dr, Suite C #306, Wilmington, NC 28405
SUBMITTED VIA EMAIL: [e-mail]
September 1, 2022
U.S. Fish and Wildlife Service
160 Zillicoa Street, Suite B
Asheville, North Carolina 28801
Reference: 9-Step Biological Assessment
Lantz Development
Mills River, Henderson County, North Carolina
Headwater Project # A21-202127
To whom it may concern,
www.headwaterenvironmental.com
On behalf of 280 Holding Group, LLC (commercial developer), Headwater Environmental, Inc. (Headwater)
is providing your office a courtesy copy of our 9-Step Biological Assessment.
The site is located at 4794 Boylston Highway in Mills River, Henderson County, North Carolina. According
to Henderson County GIS, the site is 12.84 acres, identified as PIN 9631640262, and it is owned by 280
Holding Group, LLC.
A proposed commercial development will be generally located on the eastern portion 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
Adam Tripp
Senior Geologist
Attachments: 9-Step Outline and Process
Figures 1 and 2
Photographs
IPAC Species List Letter, dated August 12, 2022
North Carolina Natural Heritage Database Review, August 12, 2022
Species Conclusion Table, August 16, 2022
USFWS Self -Certification Letter, August 12, 2022

Lantz Development
9-Step Process
4794 Boylston Highway, Mills River, Henderson County, North Carolina
Headwater Project # A21-202127
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 at 4794 Boylston Highway in Mills River, North Carolina. According to
Henderson County GIS, the site is 12.84 acres, identified as PIN 9631640262, and it is owned by
280 Holdings Group, LLC.
The proposed use of the Site is for a commercial development. The project footprint will be
generally limited to the eastern portions of the Site as shown on Figure 2.
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 Henderson 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 not present in the Action Area, but may be present in other areas of the Site.
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 August 12, 2022, 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 (3) habitat areas:
1. Forested Uplands
2. Pasture and Disturbed Areas
3. Stream Corridor (forested and pasture/disturbed)
Forested Uplands
The western portion of the Site is moderately sloped and wooded. The upland wooded areas
consist of mature trees, including eastern hemlock (Tsuga canadensis), eastern white pine (Pinus
strobus), white oak (Quercus alba), and hickory (Carya) with a dense understory. The forested
upland is outside of the Action Area.
Pasture and Disturbed Area

Most of the Site in the Action Area consists of pasture or recently disturbed land. Where bare
earth is not present, grassy species and other early successional species comprise this habitat.
Stream Corridor
The perennial stream is located within a wooded corridor with a dense understory along its
corridor that includes some invasive species such as Chinese privet (Ligustrum sinense). The
perennial stream is outside of the Action Area. The intermittent stream is located in a grassy, early
successional area with limited mature trees. The intermittent stream is deeply eroded with steep
banks. Refer to Figure 2 for location and depiction of stream features.
Soils throughout these areas consist of clay loams and sandy clay loams.
The USFWS lists four (9) species as threatened, endangered, as candidate for threatened or
endangered, or similarity of appearance, threatened for Henderson County, North Carolina:
COMMON NAME
SCIENTIFIC NAME
TAXONOMIC
GROUP
FEDERAL
STATUS
Northern long-eared bat
Myotis septentrionalis
Mammal
T
Gray Bat
Myotis grisescens
Mammal
E
Bog turtle
Clemmys muhlenbergii
Reptile
SAT
Appalachian Elktoe
Alasmidonta raveneliana
Clam
E
Monarch Butterfly
Danaus plexippus
Insect
C
Bunched Arrowhead
Sagittaria fasciculata
Flowering plant
T
Mountain Sweet Pitcher -Plant
Sarracenia rubra ssp.
Jonesii
Flowering plant
E
Small Whorled Pogonia
/sotria medeoloides
Flowering plant
T
Swamp Pink
Helionias bullata
Flowering plant
T
E: Endangered, T: Threatened, C: Candidate threatened/endangered, SAT: Similarity of Appearance,
Threatened
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.
Gray bat (Myotis grisescens)
The gray bat (sometimes chestnut brown) is a small bat, with a total length of 3 to 4 inches. The
wing membrane connects to the ankle. Mating occurs in September to October. Roost sites are
nearly exclusively restricted to caves throughout the year. Winter roosts are in deep vertical caves
with domed halls. Large summer colonies utilize caves that trap warm air and provide restricted
rooms or domed ceilings. Foraging is generally parallel to streams, over the water at heights of
6 to 9 feet.
K

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.
Appalachian elktoe (Alasmidonta raveneliana)
The Appalachian elktoe is a freshwater mussel with a round anterior and slightly pointed/rounded
posterior, and it is yellowish brown in color. This mussel has been found in gravelly substrate,
often mixed with cobble and boulder, or in cracks in bedrock. Water depths typically have been
shallow, and current velocities have varied from moderate to fast. Reported from shallow,
medium-sized creeks and rivers with cool, clean, well -oxygenated, moderate to fast flowing water.
Most often in riffles, runs, and shallow flowing pools with stable, relatively silt -free, coarse sand
and gravel substrate with cobble, boulders, and/or bedrock.
Monarch Butterfly
Adult monarch butterflies are large and conspicuous, with bright orange wings surrounded by a
black border and covered with black veins. The black border has a double row of white spots,
present on the upper side of the wings. Adult monarchs are sexually dimorphic, with males having
narrower wing venation and scent patches. The bright coloring of a monarch serves as a warning
to predators that eating them can be toxic.
During the breeding season, monarchs lay their eggs on their obligate milkweed host plant
(primarily Asclepias spp.), and larvae emerge after two to five days. Larvae develop through five
larval instars (intervals between molts) over a period of 9 to 18 days, feeding on milkweed and
sequestering toxic chemicals (cardenolides) as a defense against predators. The larva then
pupates into a chrysalis before emerging 6 to 14 days later as an adult butterfly. There are multiple
generations of monarchs produced during the breeding season, with most adult butterflies living
approximately two to five weeks; overwintering adults enter into reproductive diapause
(suspended reproduction) and live six to nine months.
In many regions where monarchs are present, monarchs breed year-round. Individual monarchs
in temperate climates, such as eastern and western North America, undergo long-distance
migration, and live for an extended period of time. In the fall, in both eastern and western North
America, monarchs begin migrating to their respective overwintering sites. This migration can
take monarchs distances of over 3,000 km and last for over two months. In early spring (February -
March), surviving monarchs break diapause and mate at the overwintering sites before
dispersing. The same individuals that undertook the initial southward migration begin flying back
through the breeding grounds and their offspring start the cycle of generational migration over
again.
Bunched arrowhead (Sagittaria fasciculata)
An aquatic perennial herb with erect, emergent leaves, 5 to 14 inches long. Several flowering
stems appear in May and June. The white flowers are arranged in whorls; female flowers on the
lowest whorls, males on the upper ones. The bunched arrowhead is found on very gently sloping
areas with some standing water refreshed by slow continuous seepage of cool clear water.
Appropriate habitat for this species is typically found in a narrow band at the bluff-floodplain
ecotone. The seeps originate at the base of the bluffs and this species is generally found near,
the origin of the seep. The preferred habitat generally does not extend far into the floodplain
because there the seepage tends to spread out and the water stagnates.

Mountain sweet pitcher -plant (Sarracenia rubra jonesii)
The mountain sweet pitcher -plant is carnivorous perennial herb with waxy -green, maroon -veined
leaves that form erect, vase -like "pitchers" with ascending "lids." The pitchers are approximately
18 inches tall and are often partially filled with a broth of decaying insects. This species is found
in mountain bogs with flat to gently sloping topography in valley bottoms that are not subjected to
flooding. The soils of these bogs are acidic, deep, consist of a poorly drained loam/sand/silt, with
measurable amount of organic matter.
Small whorled pogonia (Isatria medeoloides)
The small whorled pogonia is a perennial herb that grows up to 10 inches height when it flowers
and 14 inches when it is fruiting. It has grayish -green, somewhat oblong leaves that are between
one and three and a half inches long. Solitary or occasionally paired greenish -yellow flowers arise
from the center of the leave whorl. It blooms during May and June in the south. Plants that are
large one year are likely to bloom the next year, while plants that are small are more likely to be
vegetative, go dormant, or die. The small whorled pogonia only occasionally reproduces
vegetatively, as indicated by rare occurrences of two or more stems originating from a single root
stock. It is found in habitats consisting of acidic soils with dry to mesic secondary growth,
deciduous or deciduous -coniferous forests with an open herb layer, occasionally with dense ferns,
moderate to light shrub layer, and a relatively open canopy. Soils are typically covered with light
to moderate leaf litter. The small whorled pogonia frequently grows on flats or slope bases near
canopy breaks. The small whorled pogonia grows in a variety of upland, mid -successional,
wooded habitats, usually older hardwood and mixed wood stands of beech, birch, maple, oak,
and white pine.
Swamp pink (Helonias bullata)
A perennial herb with basal, evergreen leaves, up to 12 inches long. Flowering stems, usually 11
to 32 inches tall, have a dense terminal cluster of fragrant, attractive bright pink flowers. Few
plants in each population produce flowers. This species blooms from early April or early May
through mid -June. This species is restricted to forested wetlands that are groundwater influenced
and area perennially saturated, with a low frequency of inundation. The species appears to be
somewhat shade tolerant and to need enough canopy to minimize competition with other more
aggressive species. It is often found at stream sources.
HABITAT REVIEW
Mature trees, including hemlock, white pine, white oak, and hickory, are present on the western
side of the Site, but outside of the Action Area. Tree clearing in this area is not anticipated.
Therefore, the NLEB is not likely to be adversely effected.
Caves are not present on Site. Therefore, habitat for the gray bat is not present.
Bog, swamp, or marshy wetland areas are not present on Site. Therefore, habitat for the bog
turtle, bunched arrowhead, mountain sweet pitcher -plant, and swamp pink are not present.
Neither the intermittent or perennial stream have a gravelly substrate, nor was bedrock present.
While flow rate may be sufficient to support Appalachian elktoe in the perennial stream, it is not
in the intermittent stream. Therefore, Appalachia elktoe habitat is not present.
Milkweed host plants were not observed on -Site. Therefore, monarch butterfly habitat is not
present. Note that the monarch is a candidate species and not yet listed or proposed for listing.
A portion of the forest located on the western portion of the Site has an open herb layer, primarily
on the fringe of the forest on the edge of the perennial stream. Therefore, small whorled pogonia
M

habitat may be present in the northwestern corner of the Site. However, this area is well outside
of the Action Area. Therefore small whorled pogonia is not likely to be adversely effected.
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 on the western portion of
the site represents potential habitat for the northern long-eared bat and a small portion of the
forest in the northwestern corner of the Site may be habitat for the small whorled pogonia.
However, these habitat areas are outside of the Action Area. 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. 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.
Forested areas, which are habitat for the NLEB, were not observed in the project area.
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.

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SOURCE FIGURE 1
Headwater 1993 USGS SITE LOCATION MAP
/ ENVIRONMENTAL I NC. 7.5-minute Topographic Quadrangle Timothy Lantz/LFI Holding Group, LLC
Skyland, North Carolina 4794 & 4768 Boylston Hwy
Contour Interval = 10 feet Mills River, INC 28732
Date: 6/21/2021 Reference Scale: 1:24,000 Headwater Project #W21-169
Prepared By: K. Starkes

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Site Photos-4794 & 4768 Boylston Hwy
Headwater Project #W21-169/A21-202127
Photograph 1: View of non -jurisdictional ditch traversing the Site from south to north.
Photograph 2: View of non -jurisdictional ditch.
Photographs Taken on August 12, 2021 Page 1

Site Photos-4794 & 4768 Boylston Hwy
Headwater Project #W21-169/A21-202127
Photograph 3: Soil from data point DP-1
Photographs Taken on August 12, 2021 Page 2

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Roy Cooper, Governor
■ ■■■
r ■■ ■ INC DEPARTMENT OF
■■,■i NATURAL AND CULTURAL RESOURCES
■ ■■
August 12, 2022
Nick Creidler
Headwater Environmental, Inc
1121 Military Cutoff Road, Suite C #306
Wilmington, NC 28405
RE: Boylston Highway Project; A21-202127
Dear Nick Creidler:
❑. Reid Wilson, Secretary
Misty Buchanan
Deputy Director, Natural Heritage Program
IR \��r.TDTMEi1001i1i1
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
DEPAR7HEN7 OF NATURAL AND CULTURAL RESOURCES
121 W. JONES STREET. RALEIGH. NC 27603 • 1691 MAIL SERVICE CENTER. RALEIGH. NC 27609
OFC 919.707.9120 • FAX [phone]

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�QS�ENT OF pyFyfa8 UK
s"vw"
' o United States Department of the Interior
9 FISH AND WILDLIFE SERVICE F
Raleigh Field Office
P.O. Box 33726
Raleigh, NC 27636-3726
Date:
August 12, 2022
Self -Certification Letter
Project Name Lantz Development
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 Raleighgfws.gov 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