20230761 Ver 1_08_20230517_ltr_FWS_KimleyHorn_HalifaxCoSolarSite_20230525

L.rPS�O-WT of United States Department of the Interior
c FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
' 551-F Pylon Drive
AMR Raleigh,North Carolina 27606
May 17, 2023
Mackenzie Richards, PWS
Kimley-Horn and Associates, Inc.
421 Fayetteville St., Suite 600
Raleigh,North Carolina 27601
Subject: Halifax County Solar Site; Halifax County,NC
Dear Ms. Richards:
This letter is in response to your request for review and concurrence for the Halifax County Solar
Site. The site is being evaluated to determine the feasibility of development with a solar farm.
The 960-acre project area is located along Beaverdam Road and Neville Farm Road, west of
Beaverdam Swamp, within Halifax County,North Carolina. The site is generally described as
agricultural land, undeveloped forested riparian corridors,planted pine of varying stand age that
is utilized for silviculture, internal gravel and dirt access roads that appear to be utilized for
hunting and silviculture operations, and two large easements that transect the site: an overhead
powerline easement and the Atlantic Coast natural gas pipeline easement. No construction plans
or figures of the proposed layout of the solar array are provided. The submittal indicates that two
road crossings will be needed—one in a jurisdictional wetland, and the other across a
jurisdictional ditch. No impacts to streams are anticipated.
The U.S. Fish and Wildlife Service (Service) has reviewed the submittals. Our comments are
provided below pursuant to, and in accordance with, provisions of the Endangered Species Act
of 1973, as amended(ESA).
I. Based on the commitment to avoid stream impacts, the Service concurs with your species
determinations for this project. We believe that the requirements of section 7 (a)(2) of the
ESA have been satisfied for this project. Please remember that obligations under the
ESA must be reconsidered if. (1) new information identifies impacts of this action that
may affect listed species or critical habitat in a manner not previously considered; (2) this
action is modified in a manner that was not considered in this review; or, (3) a new
species is listed or critical habitat determined that may be affected by the identified
action.
2. The tricolored bat(TCB) is proposed for listing as endangered, and may be listed as soon
as September 2023. Please reinitiate consultation if activities that may impact TCB are
not completed before the listing becomes effective. The Service is actively working on a
path forward for projects that may affect TCB. We do not believe that the piedmont or
coastal plain populations of TCB has declined as a result of WNS. The Service may
assume presence in suitable habitat, whether or not recent surveys have been conducted.
Culvert modification or removal will also be a concern for TCB, if the culvert is greater

than 3 feet in diameter. Please consider all proposed activities that may affect TCB
(acreage/number of trees removed, blasting or other intensive noise, lighting, and any
culverts to be modified or removed and their size(s)). As a basic minimization measure,
the Service recommends a commitment to conduct tree clearing activities outside of the
"active season" (April 1 to November 14 in the southeastern plains ecoregion,but those
dates may change as we learn more about the life history of tricolored bat). If and when
the species is listed, there may also be acreage thresholds associated with inactive season
tree removal.
3. The Service recommends that an unfenced wildlife travel corridor be established through
the site. A natural corridor would be along buffered streams and wetlands (e.g., S1, W1,
W6, S5, and S7A or W 10). Crossings could be gated to allow limited access, while
keeping the corridor open for large mammals. Forested buffers (50 feet or greater)
should be preserved along all stream reaches.
4. In addition, we encourage the use of natural vegetation management practices (such as
sheep grazing) and the planting or seeding of native pollinator plant species where
possible on the site, and other efforts to improve habitat for various species (such as bird
houses and bat boxes). The Service has co-authored the North Carolina Technical
Guidance for Native Plantings on Solar Sites, which can be found on the North Carolina
Pollinator Alliance website: http://ncpollinatoralliance.org/wp-
content/uploads/2022/06/NC-Solar-Technical-Guidance-FINAL-May-2022.pdf.
To offset the overall impacts of solar facilities and/or to increase the habitat and species
diversity within the solar facility area, we further recommend the following measures be
implemented into project design:
• Create openings in fencing to allow passage for small mammals and turtles.
• Mitigate for the loss of forested habitat. Though the loss of forested habitat cannot be
fully mitigated when cleared for solar facilities, we believe measures should be
implemented into the design plans to offset the impacts of the project to the greatest
extent practicable. We recommend the construction and placement of bat and bird
boxes throughout the site along with perch poles that are large enough to be used by
raptors.
Thank you for the opportunity to comment on this project. If you have any questions or
comments, please contact Kathy Matthews of this office at(919) 856-4520 ext. 27.
Sincerely,
for Pete Benjamin
Field Supervisor
cc: Maria Dunn,NCWRC
2