20100899 Ver 3_Individual_20170203

Individual Permit Application for U.S. Army Corps of
Engineers Section 404 Permit
and
North Carolina 401 Water Quality Certification
January 27, 2017
Applicant:
Clearwater Paper Corporation
`5 CLEARWATER
0
PAPER
Clearwater Paper Corporation
Attn: Mr. Brian Hoagland
601 W. Riverside Ave.
Spokane, WA 99201
Project Location:
Washburn Switch Road
Shelby, NC 28150
Prepared by:
ClearWater Environmental Consultants, Inc.
32 Clayton Street
Asheville, North Carolina 28801
828-698-9800

Preliminary ORM Data Entry Fields for New Actions
SAW - 201 - BEGIN DATE [Received Date]:
Prepare file folder ❑ Assign Action ID Number in ORM ❑
1. Project Name [PCN Form A2a): Clearwater Paper
2. Work Type: Private ❑ Institutional ❑ Government ❑ Commercial W1
3. Project Description / Purpose [PCN Form B3d and Be]:
Construction of a manufacturing facility.
4. Property Owner / Applicant [PCN Form A3 or A41: Clearwater Paper Corporation
5. Agent / Consultant [PCN Form AS — or ORM Consultant ID Number]: Clearwater Environmental Consultants
6. Related Action ID Number(s) [PCN Form B5b]: 2010-00061 and 2011-02398
7. Project Location - Coordinates, Street Address, and/or Location Description [PCN Form Blb]:
35.318254, -81.600612
8. Project Location -Tax Parcel ID [PCN Form Bla]: 2528-60-3865 and 2528-31-7203
9. Project Location—County [PCN Form A2b]: Cleveland
10. Project Location — Nearest Municipality or Town [PCN Form A2cj: Shelby
11. Project Information — Nearest Waterbody [PCN Form B2a]: Brushy Creek
12. Watershed / 8 -Digit Hydrologic Unit Code [PCN Form 82c]: Upper Broad 03050105
Authorization: Section 10 ❑ Section 404
Regulatory Action Type:
✓ Standard Permit
Nationwide Permit #
❑ Regional General Permit #
❑ Jurisdictional Determination Request
Section 10 & 404 11
11 Pre -Application Request
Unauthorized Activity
❑ Compliance
❑ No Permit Required
Revised 20150602

U.S. ARMY CORPS OF ENGINEERS
OMB APPROVAL NO. 0710-0003
APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT
EXPIRES: 28 FEBRUARY 2013
33 CFR 325. The proponent agency is CECW-CO-R.
Public reporting for this collection of information is estimated to average 11 hours per response, Including the time for reviewing Instructions, searching
existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of Information. Send comments regarding
this burden estimate or any other aspect of the collection of Information, Including suggestions for reducing this burden, to Department of Defense,
Washington Headquarters, Executive Services and Communications Directorate, Information Management Division and to the Office of Management and
Budget, Paperwork Reduction Project (0710-0003). Respondents should be aware that notwithstanding any other provision of law, no person shall be
subject to any penalty for falling to comply with a collection of information If It does not display a currently valid OMB control number. Please DO NOT
RETURN your form to either of those addresses. Completed applications must be submitted to the District Engineer having jurisdiction over the location of
the proposed activity.
PRIVACY ACT STATEMENT
Authorities: Rivers and Harbors Act, Section 10, 33 USC 403; Clean Water Act, Section 404, 33 USC 1344; Marine Protection, Research, and Sanctuaries
Act, Section 103, 33 USC 1413; Regulatory Programs of the Corps of Engineers; Final Rule 33 CFR 320-332. Principal Purpose: Information provided on
this forth will be used In evaluating the application for a permit. Routine Uses: This Information may be shared with the Department of Justice and other
federal, state, and local government agencies, and the public and may be made available as part of a public notice as required by Federal law. Submission
of requested Information is voluntary, however, If information is not provided the permit application cannot be evaluated nor can a permit be Issued. One set
of original drawings or good reproducible copies which show the location and character of the proposed activity must be attached to this application (see
sample drawings and/or Instructions) and be submitted to the District Engineer having jurisdiction over the location of the proposed activity. An application
that is not completed In full will be returned.
(ITEMS 1 THRU 4 TO BE FILLED BY THE CORPS)
1. APPLICATION NO.
2. FIELD OFFICE CODE
3. DATE RECEIVED
14, DATE APPLICATION COMPLETE
(ITEM_ S BELOW TO BE FILLED BYAPPLICAN7)
5. APPLICANTS NAME
8. AUTHORIZED AGENTS NAME AND TITLE (agent is nofrequlred)
First- Middle -Jeff Last - Richardson
First - R Middle -Clement Last -Riddle
Company - Cleveland County Government - County Manager
Company - ClearWater Enviromenlal
E-mail Address -
E-mail [e-mail]
3. APPLICANTS ADDRESS:
9. AGENTS ADDRESS:
Address- PO Box 1210 311 East Marion Street
Address- 32 Clayton Street
City - Shelby State - NC Zip - 28151 Country-
City - Asheville State - NC Zip - 28881 Country -
7. APPLICANTS PHONE NOs. w/AREA CODE
10. AGENTS PHONE NOs. w/AREA CODE
a. Residence b. Business c. Fax
a. Residence b. Business c. Fax
' STATEMENT OF AUTHORIZATION
11. 1 hereby authorize, M to art j i ha11 lf a my agent in the processing of this application and to furnish, upon request,
supplemental information in support of this rmfl, ,plication
IGNA UR • , FAPP.LICANT AT
NAME, LOCATION, AND DESCRIPTION OF PROJECT OR ACTIVITY
12. PROJECT NAME OR TITLE (see instructions)
Clearwater paper
13. NAME OF WATERBODY, IF KNOWN (if applicable)
14. PROJECT STREET ADDRESS (if applicable)
UT Brushy Creek
Address
City - Shelby State NC Zip- 28150
15. LOCATIONOF PROJECT
Latitude: •N 35.31751 Longitude: -W -81.60472
16. OTHER LOCATION DESCRIPTIONS, IF KNOWN (see instructions)
,tate Tax Parcel ID 32624;32196;40797;32623 Municipality Cleveland County
Section - Township - Range -
ENG FORM 4345, OCT 2012 PREVIOUS EDITIONS ARE OBSOLETE. Page 1 of 3

17. DIRECTIONS TO THE SITE
The Clearwater Paper project site is located in Shelby, Cleveland County, North Carolina. To access the site from Asheville, take 1-26 East
to Exit 67 (US Highway 74 to Columbus/Rutherfordion/NC Highway 108). Continue onto US Highway 74 and travel approximately 37
miles. Tum left on to Washburn Switch Road. The proposed Clearwater Paper facility is on the right on the east side of the railroad tracks
(and across from the existing Clearwater Paper facility).
18. Nature of Activity (Description of project, include all features)
See "Proposed Project Development", Section 5.0 of the permit application.
19. Project Purpose (Describe the reason or purpose of the project, see instructions)
See 'Project Purpose", Section 4.0 of the permit application.
USE BLOCKS 20-231F DREDGED ANDIOR FILL MATERIAL IS TO BE DISCHARGED
20. Reason(s) for Discharge
See "Proposed Project Development", Section 5.0 of the permit application.
21. Type(s) of Material Being Discharged and the Amount of Each Type in Cubic Yards:
Type Type Type
Amount in Cubic Yards Amount in Cubic Yards Amount in Cubic Yards
culverts and approximately 140 cubic yards
22. Surface Area In Acres of Wetlands or Other Waters Filled (see instructions)
Acres 0.03 permanent fill - 0.032 temporary fill
or
Linear Feet 1578 permanent till - 214 temporary fill
23. Description of Avoidance, Minimization, and Compensation (see instructions)
See "Discussion of Alternatives", Section 6.0 of the permit application.
ENG FORM 4345, OCT 2012 Paye o. o

24. Is Any Portion of the Work Already Complete? []Yes ©No IF YES, DESCRIBE THE COMPLETED WORK
25. Addresses of Adjoining Property Owners, Lessees, Etc., Whose Property Adjoins the Waterbody fn more van mm ee enteree pore, pease ev:oh o a, Iomenei ice)
a. Address- See "Adjoining Property Owners" list in permit application.
City - State - Zip -
b. Address -
city - State - 7Jp -
c. Address-
city - State - Zip -
d.Address-
city - State - 7JP -
e. Address -
city - State - zip -
26. Ust of Other Certificates or Approvals/Denials received from other Federal, State, or Local Agencies for Work Described In This Application.
AGENCY TYPE APPROVAL• IDENTIFICATION DATE APPLIED DATE APPROVED DATE DENIED
NUMBER
USACE Jurisdictional Determi 2011-02398 12.21.2011
Would Include but is not restricted to zoning, building, and flood plain permits
27, A" ' _ n is hereby made for permit or permits to authorize the work described in this application. I certify that this information In this application is
c .plate d accurate. urther edify that I possess the authority to undertake the workdescribed Zhereinoracting as the duly authorized agent of the
ppllcant
A l
Ask�GN TU E OF APPLICHNT DTE SIGNATURE OF AGENT ATE
The Application must be signed by the person who desires to undertake the proposed activity (applicant) or it may be signed by a duly
authorized agent if the statement in block 11 has been filled out and signed.
18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or agency of the United States
knowingly and willfully falsifies, conceals, or covers up any trick, scheme, or disguises a material fact or makes any false, fictitious or
fraudulent statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious or
fraudulent statements or entry, shall be fined not more than $10,000 or imprisoned not more than five years or both.
ENG FORM 4345, OCT 2012 Page 3 of 3

James Webb
James Webb
310 Borders Road
1630 Farmville Road
Shelby, NC 28152
Shelby, NC 28150
Tampa Warehouse, LLC Peggy Bullard
20940 Bethelwood Lane 115 Jordan Drive
Cornelius, NC 23031 Shelby, NC 28150
Jimmy Preston Hawkins Eskridge Grove Baptist Church
2304 W. Randolph Road 634 Washburn Switch Road
Shelby, NC 28150 Shelby, NC 28151
Kyle Aldinger Cleveland County
1507 Chatfield Road PO Box 1210
Shelby, NC 28150 Shelby, NC 28151
Michael Douglas Gengler NC Department of Transportation
15 Heritage Lane 1546 Mail Service Center
Shelby, NC 28150 Raleigh, NC 27611

&earW - er
Department of the Army
Wilmington District, Corps of Engineers
Attn: Scott McLendon, Chief Regulatory Division
PO Box 1890
Wilmington, NC 28402-1890
-and-
NCDWR, Webscape Unit
Attn: Karen Higgins
512 North Salisbury Street
Raleigh, North Carolina 27604
1, the current landowner/managing partner of the property identified below, hereby
authorize ClearWater Environmental Consultants, Inc. (CEC) to act on my behalf as my
agent during the processing of permits to impact Wetlands and Water of the US that are
regulated by the Clean Water Act and the Rivers and Harbors Act.
CEC is authorized to provide supplemental information needed for permit processing at
the request of the USACE or DWR.
Property Owner of Record: Cleveland
Property Owner Address:
Phone Number:
Property Location:
Owner/Managing partner f
Date:
PO Box 1210, Shelby NC 28151
704-484-4800
32 Clayton Street
Asheville, NC 28801
Phone: [phone]
www.cwenv.com

CLe axV/ Vater
Department of the Army
Wilmington District, Corps of Engineers
Attn: Scott McLendon, Chief Regulatory Division
PO Box 1890
Wilmington, NC 28402-1890
-and-
NC DWR, Webscape Unit
Ann: Karen Higgins
512 North Salisbury Street
Raleigh, North Carolina 27604
I, the current landowner/managing partner of the property identified below, hereby
authorize C1earWater Environmental Consultants, Inc. (CEC) to act on my behalf as my
agent during the processing of permits to impact Wetlands and Water of the US that are
regulated by the Clean Water Act and the Rivers and Harbors Act.
CEC is authorized to provide supplemental information needed for permit processing at
the request of the USACE or DWR.
Property Owner of Record: Clearwater Paper
Property Owner Address: 601 W Riverside Ave Suite 1100
Spokane WA 99201
Phone Number: 509-344-5972
Property Location: 662 Washburn Switch Rd. Shelby, NC 28150
Owner/Managing partner Signature: — AFL` Brian Hoaglund 1/23/17
Date: January 23, 2017
32 Clayton Street
.Asheville, NC 28801
Phone: [phone]
www.cwenv.com

TABLE OF CONTENTS
1.0
INTRODUCTION TO PROJECT.....................................................................................1
1.1
Project Location...................................................................................................................1
1.2
Jurisdictional Waters............................................................................................................1
2.0
BACKGROUND/PRIOR PROJECT HISTORY.............................................................2
3.0
EXISTING SITE CONDITIONS........................................................................................2
3.1
Natural Communities...........................................................................................................2
3.2
Streams and Wetlands..........................................................................................................3
3.3
Fish and Wildlife Use of the Project Site.............................................................................3
3.4
Threatened and Endangered Species...................................................................................3
3.5
Cultural Resources...............................................................................................................5
3.6
Floodplain............................................................................................................................6
3.7
Soils..................................................................................................................................6
4.0
PROJECT PURPOSE.........................................................................................................7
5.0
PROPOSED PROJECT DEVELOPMENT......................................................................7
6.0
DISCUSSION OF ALTERNATIVES..............................................................................10
6.1
Alternatives - Site Selection..............................................................................................11
6.2
Alternatives - As-Proposed...............................................................................................12
6.3
Alternatives - Use of Existing Facilities (Off-Site)...........................................................13
6.4
Alternatives - Use of Existing Facility (West of Washburn -Switch Road) ......................13
6.5
Alternatives - Use of Existing Facility (West of Washburn -Switch Road) and a
Portion
of the Proposed Facility (East of Washburn -Switch Road)..............................................14
6.6
Alternatives - No Action/No Build...................................................................................14
6.7
Avoidance and Minimization.............................................................................................14
6.8
Alternatives Conclusion.....................................................................................................14
7.0
CONCEPTUAL MITIGATION PLAN...........................................................................15
7.1
NC Division of Mitigation Services (DMS)......................................................................15
8.0
US ENVIRONMENTAL PROTECTION AGENCY 404(b)(1) GUIDELINES ..........16
8.1
Factual Determination........................................................................................................16
8.2
Potential Impacts on Physical and Chemical Characteristics of the Aquatic
Ecosystem................................................................................................................................16
8.3
Potential Impacts to Biological Characteristics of the Ecosystem.....................................18
8.4
Potential Impacts on Special Aquatic Sites.......................................................................20
8.5
Potential Effects on Human Use Characteristics...............................................................21
8.6
Summary ............................................................................................................................22
9.0
PUBLIC INTEREST CONSIDERATIONS....................................................................23
9.1
Conservation......................................................................................................................23
9.2
Economics..........................................................................................................................23
9.3
Aesthetics...........................................................................................................................23
9.4
General Environmental Concerns......................................................................................24
9.5
Wetlands............................................................................................................................24
9.6
Historic Properties.............................................................................................................24
9.7
Fish and Wildlife Values...................................................................................................24
9.8
Flood Hazards....................................................................................................................25
9.9
Floodplain Values..............................................................................................................25

9.10
Land Use............................................................................................................................25
9.11
Navigation..........................................................................................................................25
9.12
Shore Erosion and Accretion.............................................................................................26
9.13
Recreation..........................................................................................................................26
9.14
Water Supply and Conservation........................................................................................26
9.15
Water Quality (Stormwater Management).........................................................................26
9.16
Energy Needs.....................................................................................................................26
9.17
Safety................................................................................................................................26
9.18
Food and Fiber Production.................................................................................................26
9.19
Mineral Needs....................................................................................................................26
9.20
Considerations of Property Ownership..............................................................................27
9.21
Needs and Welfare of the Public.......................................................................................27
10.0
SECONDARY AND CUMULATIVE EFFECTS...........................................................28
11.0
SUMMARY........................................................................................................................28
ii

LIST OF FIGURES
Figure 1
Site Vicinity Map
Figure 2
USGS Topographic Map
Figure 3
Hexastylis naniflora Relocation Map
Figure 4
FEMA 100 -YR Floodplain Map
Figure 5
USDA Soils Map
Figure 6
Site Plan
Figure 7
Utilities Overview Map
Figure 8
Sewer line — Stream and wetland Impact Map
Figure 8a
Typical cross section — sewer line crossing
Figure 9
Force Main — No impact map
Figure 10
Gas and Water Line — No impact map
LIST OF APPENDICES
Attachment A Jurisdictional Determination (dated January 23, 2017) and
jurisdictional delineation maps of utility (Sewer, water, gas)
ROWS.
Attachment B 2012 Authorized Impacts (SAW Action ID -2010-00061)
Attachment C NC Stream Assessment Method Forms
Attachment D Threatened and Endangered Species Information
Attachment E Cultural Resources Information
Attachment F NC Division of Mitigation Services Acceptance Letter (dated
December 16, 2017)
iii

1.0 INTRODUCTION TO PROJECT
The applicant, Clearwater Paper Corporation, proposes to expand existing operations in
Shelby, Cleveland County, North Carolina. The proposed project site is on the east side
of Washburn -Switch Road across from the existing Clearwater Paper manufacturing
facility. Clearwater Paper makes and converts tissue paper into usable products for the
home and commercial markets.
1.1 Project Location
The Clearwater Paper project site is located in Shelby, Cleveland County, North
Carolina. To access the site from Asheville, take I-26 East to Exit 67 (US
Highway 74 to Columbus/Rutherfordton/NC Highway 108). Continue onto US
Highway 74 and travel approximately 37 miles. Tum left on to Washburn Switch
Road. The proposed Clearwater Paper facility is on the right on the east side of
the railroad tracks (and across from the existing Clearwater Paper facility). In
general, the site is bordered to the north by an unnamed tributary to Bushy Creek,
to the east by Brushy Creek, to the west by the railroad tracks, and to the south by
a transmission line. A site vicinity map (Figure 1) and USGS topographic map
(Figure 2) are attached for review.
1.2 Jurisdictional Waters
Stream channels on site include unnamed tributaries to Brushy Creek. There are
several wetlands located on site. These wetlands are associated with adjacent
stream channels. The project site is part of a larger site that was delineated in
June -August of 2011. A Notification of Jurisdictional Determination was issued
for the site on December 21, 2011. The site was re -verified on January 23, 2017
(Attachment A).
The tributaries on site flow to Brushy Creek which is a tributary to the First Broad
River. The First Broad River is a tributary to the Broad River which is a
navigable -in -fact water in South Carolina. Tributaries on site are classified by the
NC Division of Water Resources (DWR) as class "C" waters.
The table below summarizes the amounts of jurisdictional waters on site.
Tnhle 1 On-site Totals
Feature
Amount
I Unit
Stream
7,147
1 linear feet
Wetlands
14.61
1 acres
O en Water
0
acres
The utility right-of-way (ROW) corridors (gas, water, and sewer) were delineated
in January 2017. Attachment A provides delineation maps for the proposed utility
ROW corridors.

An "Existing Site Conditions" section (Section 3.0) has been included in this
application for review and further describes the jurisdictional waters on site.
2.0 BACKGROUND/PRIOR PROJECT HISTORY
A permit application for the facility on the west side of Washburn -Switch Road was
submitted on March 5, 2010, and a Nationwide Permit 39 was issued March 18, 2010
(SAW -2010-00061). The NC Division of Water Resources did not provide written
concurrence for the project; however, a Stormwater Management Plan (SMP) approval
was issued on May 17, 2011. The SMP was modified on September 20, 2011. The
existing Clearwater Paper facility was constructed in late 2010 and early 2011. A permit
modification for the addition of a secondary access road and minor after -the -fact impacts
was submitted on April 17, 2012. The permit modification was issued on June 1, 2012
(SAW -2010-00061). Not all impacts associated with the modification were complete.
To date, the following impacts have occurred at the existing facility for a total of 104
linear feet of stream impact and 0.09 acre of wetland impact (Attachment B — Figures 3A
and 3B):
'r.1%1- O
Impact # (Figure 3A and 313
Impact Amount
Purpose
3
15 LF
Railroad Crossin
4
0.09 AC
Railroad Crossing
9
89 LF
Entrance Road
An Individual Permit for a facility expansion (at the existing facility on the west side of
Washburn -Switch Road) was submitted on November 3, 2014. A Department of the
Army Permit was issued by the Corps on June 25, 2015 (Action ID SAW -2010-00061),
and a Water Quality Certification was issued on May 15, 2015 (DWR# 10-0899 v2).
Impacts associated with the Individual Permit have not been completed.
3.0 EXISTING SITE CONDITIONS
The proposed project site is mostly undeveloped. One warehouse, currently leased by
Clearwater Paper is adjacent to Washbum-Switch Road. Approximately 50 acres of the
site is fallow field and another approximately 100 acres has been clear cut. Wooded
areas are limited to corridors surrounding streams and wetlands.
3.1 Natural Communities
Natural communities on site include mixed age loblolly pine forest, riparian
forest, mixed pine -hardwood forest, and fallow field. The loblolly pine forest
represents the largest habitat type on site and is dominated by loblolly pine stands
of different age classes. This habitat type has been greatly disturbed by clear -
cutting at the site. Riparian forests are adjacent to streams and wetlands on site.
This habitat type is generally disturbed and contains numerous invasive species.
Many stream banks are highly eroded with limited vegetation on the banks.
2

Mixed pine -hardwood forest is up -gradient from the riparian forest. This habitat
type includes younger stands of trees and is dominated by loblolly pine. The old
field is present on the eastern side of the site and is surrounded by wooded areas.
It appears that this field is mowed at least annually by hunters that utilize the land.
Habitats associated within the utility ROW corridors included the shoulders of
existing DOT roads, residential lawns, herbaceous wetlands, and existing
maintained sewer line ROWS. These habitats are routinely managed through the
use of mechanized mowing and/or bush hogging equipment.
3.2 Streams and Wetlands
Streams on site include the unnamed tributaries to Brushy Creek. There are
approximately 7,147 linear feet of stream channel within the project boundary. In
general, the unnamed tributaries flow west to east and eventually into the Broad
River via the First Broad River. The Broad River is a navigable -in -fact water in
South Carolina. Stream channels on site are high to low quality. Channels are
generally impacted by historic agricultural use; although, recovery from impact is
evident in some channel reaches. NC Stream Assessment Method ratings for
stream reaches proposed for impact are included for review (Attachment Q.
There are approximately 4.61 acres of wetland within the project boundary.
Portions of two large wetlands are present on site. Evidence of beaver activity is
present in the largest wetland located near the southeast property corner. This
wetland includes a forested area to the west and ponded areas to the east. The
largest wetland on the northern property boundary is forested. These two
wetlands have been avoided. The small wetlands proposed for impact, totaling
0.03 acre, are adjacent to their associated stream channel and are of high quality.
3.3 Fish and Wildlife Use of the Project Site
Wildlife species inhabiting the site include those typically found in rural settings.
Site-specific studies and inventories documenting species utilization of the project
area have not been conducted.
3.4 Threatened and Endangered Species
A protected species survey was conducted at the site on July 25 and August 1, 3,
and 4, 2011 by CEC to determine the occurrence of or potential for existence of
federally listed threatened and endangered animal and plant species, specifically
Hexastylis noniflora, on the project site. The survey was conducted for Cleveland
County. During the site survey, CEC searched all wooded areas and stream sides
for Hexastylis species. Multiple Hexastylis nanii lora plants and populations were
present. A "Threatened and Endangered Species Assessment' documenting
findings of the survey was finalized on November 3, 2011 (Attachment D).
A second protected species survey was conducted at the site on March 27 and
April 2, 2015 to further determine the extents of Hexastylis nanii lora populations
on site. This survey was also conducted for Cleveland County. Approximately
3

196 Hexastylis nanii lora plants were observed during this survey. Approximately
70 of the observed plants occurred along the northeast boundary. The other plants
occurred in three locations along the unnamed tributaries to Busby Creek near the
center of the property (Figure 3). An official report of findings was never
finalized for this survey.
In April of 2015, after the survey was complete, ClearWater Environmental
Consultants, Inc. (CEC) recommended that Cleveland County relocate the plants
in the center of the site to an area that was unlikely to be disturbed by future
development. In September of 2015, after coordination with the US Fish and
Wildlife Service (FWS), approximately 126 Hexastylis naniflora plants were
relocated to the southeastern comer of the subject property (Figure 3). Relocated
plants were planted adjacent to an existing population of Hexastylis nanii lora. A
brief report was submitted to the FWS after completion of the relocation
(Attachment D).
In April of 2016, CEC visited the relocation area to observe general site
conditions, and evaluate the success and vigor of the relocated plants. Mortality
of two plants was noted. A brief report was submitted to the FWS after
completion of the site visit (Attachment D).
A site plan was finalize for the project in December of 2016. Approximately two
Hexastylis nanii lora plants were found to be located within the proposed road
corridor. On December 13, 2016, these two plants were relocated to the west, out
of the proposed road corridor and within the existing population of 70+ plants that
would remain unimpacted by the proposed project (Figure 3). During the
December 13, 2016 site visit, the locations of populations A, B, and C (which
were relocated in 2015) were also evaluated for presents of plants that regenerated
during the past year. Approximately 10 plants were found at Site A and
approximately 13 plants were found at Site B. By letter dated December 15, 2016
(Attachment D), the FWS has concurred with a determination that the proposed
project may affect, but is not likely to adversely affect Hexastylis nanii lora.
A protected species survey was conducted on January 16, 17, and 25, 2017 by
CEC to determine the occurrence of or the potential for the existence of federally
listed threatened and endangered animal and plant species, specifically Hexastylis
nanii lora. This survey was conducted on the proposed Sewer Line Upgrades,
New Parallel Gravity Sewer Line, Force Main Sewer Line Upgrades, and New
Water Main Extension and Gas Line portions of the project. No Hexastylis plants
were observed during the survey. It is the opinion of CEC that installation of the
utilities is not likely to adversely affect Hexastylis na i lora.
CEC has conducted a file review of up-to-date (October of 2016) records
maintained by the FWS and North Carolina Natural Heritage Program (NHP).
The desktop literature review involved a review of the FWS list of protected
species in Cleveland County and the NHP Element Occurrence Data on which
a]

NHP identifies current and historic occurrences of listed species for a specific
locale. The FWS lists 2 species as occurring in Cleveland County. The NHP
database identifies 11 element occurrences (EO) within a 2 -mile radius of the
project site; 8 EOs, comprised of 1 species, hold Federal status and are subject to
Section 7 consultation. The species identified by the FWS and NHP are listed
below.
Table 3.
Common Name Scientific Name Status
Northern Lon -eared Bat M otis se tentrionalis Threatened
Dwarf -flowered heartleaf I Hexastylis nanii lora Threatened
*Hexastylis naniflora has been discussed above.
CEC consulted the FWS's "Northern Long -Eared Bat Consultation Areas" map for
Cleveland County. The proposed project site is not in a Hydrologic Unit Code
(HUC) identified as having known occurrences of hibernation of maternity sites. It
is the opinion of CEC that any incidental take associated with proposed activities
would be exempt under the 4(d) rule. By letter dated December 15, 2016
(Attachment D), the FWS has concurred with this determination. Approximately
65 acres of tree clearing would occur at the site.
It is the opinion of CEC that the requirements under Section 7 of the Endangered
Species Act have been fulfilled for this project. The FWS will be notified via
Public Notice about the project and will be given the opportunity to comment on
the project and its potential effects on threatened and endangered species.
3.5 Cultural Resources
On October 28, 2011, TRC completed a background study and limited field
reconnaissance for a large tract adjacent to Washbum-Switch Road which
included the proposed project area (Attachment E). The goal of the work was to
assess the potential for significant cultural resources on and adjacent to the
property. The literature search identified no previously recorded archeological
sites on the tract. It is TRC's opinion that archaeological sites are likely present
on the site; however, given the soil characteristics and the results of nearby
surveys, any prehistoric sites that are present are unlikely to be eligible for the
National Register of Historic Places (NRHP).
The only documented historic structure near the property is the Coleman Blanton
Farm, which is situated approximately 1,600 feet northeast of the property. Given
its distance from the property, it is very unlikely that this structure complex would
be affected by development of the property.
USGS maps dating to 1950 and 1983 indicate that a historic period cemetery is
located on the tract. Documentary research and field reconnaissance was not able
to confirm the location or identity of the cemetery, but it was thought to be the
19`h century Major McCombs Cemetery.
5

The October 28, 2011 letter concluded that the site research and field
reconnaissance suggests that the property is unlikely to contain any archaeological
sites that would constrain development. It was recommended that additional
efforts to identify and locate the cemetery be conducted at the site prior to any
ground disturbing activities.
In January of 2015, additional background research and fieldwork were
completed at the site in order to confirm the location and identity of the cemetery
suspected to be located at the site (Attachment E). It was discovered at the
beginning of fieldwork, through the discovery of displaced grave markers, that the
Major McCombs Cemetery was present on the property. Subsequent fieldwork
identified six apparent graves at the cemetery site. Additional background
research confirmed the McCombs family association and provided additional
information on the interred individuals. TRC recommended preserving the
cemetery in place or relocation of the cemetery in accordance with State statues.
Cleveland County opted to relocate the cemetery. TRC completed the excavation
and removal of all graves associated with the Major McCombs Cemetery in
March of 2015 (Attachment E). All material removed from the graves and the
associated tombstone fragments where transferred to Cleveland County for
temporary storage prior to reburial. With guidance from living family members,
remains where buried at Double Springs Church in Shelby (Attachment E). By
letter dated September 30, 2016, the Office of State Archaeology expressed
satisfaction with the outcome of the relocation.
3.6 Floodplain
Designated floodplains are present along Bushy Creek and extend into the project
boundary (FEMA Map Panel 3710252800J, effective February 20, 2008, Figure
4). All site development would take place outside of the designated 100 -year
floodplain.
3.7 Soils
The project site is located within the Piedmont physiographic region of North
Carolina and more specifically the Southern Outer Piedmont Ecoregions. One
soil association is present on site: the Pacolet-Bethlehem. The Pacolet-Bethlehem
association is classified as gently sloping to moderately steep, moderately deep to
very deep, well drained soils. This association is found on piedmont uplands.
Soil series present on site include: Appling, Cecil, Chewacla, Helena -Worsham
complex, Pacolet-Bethlehem complex, Pacolet-Saw complex, Toccoa, and Urban
Land (Figure 5)
I

4.0 PROJECT PURPOSE
The basic project purpose of the proposed expansion is to snake and convert tissue paper
into usable products for the home and commercial markets. More specifically, the
overall project purpose is to expand tissue paper making and converting capacity to meet
market demands.
5.0 PROPOSED PROJECT DEVELOPMENT
The proposed project includes the construction of approximately 2.5 million square feet
of manufacturing and warehouse space (Figure 6). Additional manufacturing space
would house a tissue machine which converts raw material to "parent rolls" of tissue;
converting equipment which converts rolls into consumer products such as toilet paper,
paper towels, facial tissue, and napkins; a parent roll storage warehouse; and a bale
storage warehouse. The project also includes warehouse space for finished goods.
The project would include stream and wetland impacts associated with the construction
of the new facility. Permanent impacts associated with the proposed project are
identified in the table below.
Table 4. Stream Impacts
Impact
Stream (LF)
Purpose
1
200
Proposed Entrance Road
2
910
Facility and Rail
3
468
Facility
Totals
1578 LF
8 stream crossings
4 wetland crossings
Table 5. Wetland Impacts
Impacts I Wetland AC Purpose
4 0.03 Facility
Totals 0.03 AC
Utilities — Utility upgrades (Figure 7) are needed to support the facility and this
includes upgrades to the sewer line, and installation of new gas and water lines to the
site. Utility service to the site would be as follows:
Tahle. 6 Utility Lines - Temporary Wetland and Stream Impacts
Impact
Distance
Stream (LF)
Impact
Gas
+/-16,900 If
3 stream crossings
Directionally bored — no impact
Water
+/- 25,421 if
3 stream crossings
Directionally bored — no impact
Sewer Gravity Line
(new & upgrade)
+/-18,616
8 stream crossings
4 wetland crossings
Trench excavation — 214 LF
Trench excavation — 0.032 acres
Sewer Force Main
+/- 8936 if
1 stream crossing
Directionally bored — no impact
Totals
1 214 IL and 0.032 acres
7

• Sewer — sewer infrastructure would include a combination of existing lines,
upgrades of existing lines, and installation of new parallel lines.
There will be a new parallel 24 inch sewer line that is constructed inside an
existing right-of-way. This line extends from the Crest Lift Station (located on
Crest Road) and extend in a northerly direction for +/- 16,275 If. At a location
just north of the new bypass the new sewer line will connect to an existing 8 inch
sewer line that will be upgraded to a 15 inch sewer line and extend for +/- 2,341
If and connects to the new manufacturing facility. These sewer lines will cross
eight streams and four herbaceous wetlands. Temporary impacts to streams total
2141f and to wetlands total 0.032 acres (Figure 8). Stream bed and banks will be
restored to their original condition (Figure 8a). Wetlands will be regraded to
original elevation and contours with 6-12 inches of topsoil from the trench area
and seeded with a wetland seed mix.
There will be a new parallel 16 inch sewer force main line constructed in an
existing right-of-way that extends for +/-8,936 If from College Avenue in a
southeastern direction towards the existing City of Shelby waste water plant. The
force main has one stream crossing which will be directionally bored under the
First Broad River, no stream impact (Figure 9). Attachment A provides
delineation maps for the proposed sewer improvements.
• Water — A new water line will be installed from the existing water treatment plant
to the site. The proposed routing proceeds from the water treatment facility to
West Grover Street, north along Polkville Road, west along Chatfield Road, west
along Farmville Road, and crosses under the railroad tracks to Washburn Switch
Road. The proposed water main alignment provides accessible space for boring
pits, minimizes conflicts with private parcels, and minimizes road crossings and
driveway repairs. The proposed main will lay in parallel to the existing 16 -inch
water line on the north side of West Grover Street. Upon reaching the Polkville
Road intersection, the line will turn north, staying on the eastern side of the road
because it has less driveways and will make use of the existing 30 -inch casing
under the Shelby bypass. The line will cross Polkville Road to stay on the south
side of Chatfield Road. This side is preferable because it allows the line to turn
onto the south side of Farmville Road without an additional bore. As proposed,
there would be three stream crossings that would be horizontally directionally
drilled, no stream impact (Figure 10). The proposed route includes 25,421 linear
feet of open trench, 268 linear feet of jack and bore, and 706 linear feet of
horizontal directional drill. Attachment A provides delineation maps for the
proposed water line.
• Natural gas — Natural gas will be brought to the site with a new 6" steel line that
will extend 16,900 feet from an existing line on Polkville Road. The gas line is
proposed to be installed within the DOT ROW and be located on the south side of
Chatfield Road and then tum left and stay with in DOT ROW on the south side of
Fannville Road. The line will cross Washburn Switch road and run south to the
M

railroad where it connects to an existing gas line. As proposed, there would be 3
stream crossings that would be horizontally directionally drilled, no stream impact
(Figure 10). Attachment A provides delineation maps for the proposed gas line.
Electric — overhead utility line extended from the existing substation, using
existing corridors off site, proposed on-site route indicated on site plan.

6.0 DISCUSSION OF ALTERNATIVES
This discussion of alternatives is submitted by the applicant to assist the Wilmington
District, Corps in evaluating the application for authorization to discharge dredged or fill
material into waters of the United States, including wetlands, under Section 404 of the
Clean Water Act, 33 U.S.C. § 1344 at the proposed project site.
An analysis of the Section 404(b)(1) Guidelines (Guidelines) requirements for
consideration of alternatives as required by 40 C.F.R. 230.10(a) is set forth below.
The Guidelines' alternatives requirements provide that "no discharge of dredged or fill
material shall be permitted if there is a practicable alternative to the proposed discharge
which would have less adverse impact on the aquatic ecosystem, so long as the
alternative does not have other significant adverse environmental consequences." [See
40 C.F.R. 230.10(a) (emphasis added).] The record must contain "sufficient information
to demonstrate that the proposed discharge complies with the requirements of Section
230.10(a) of the Guidelines. The amount of information needed to make such a
determination and the level of scrutiny required by the Guidelines is commensurate with
the severity of the environmental impact (as determined by the functions of the aquatic
resource and the nature of the proposed activity) and the scope/cost of the project." [See
Corps/EPA Memorandum to the Field "Appropriate Level of Analysis Required for
Evaluating Compliance with Section 404(b)(1) Guidelines Alternatives Requirements," p.
2, dated August 23, 1994, hereinafter the "Memorandum."] As noted in the
Memorandum on pages 3-4, the 404(b)(1) Guidelines "only prohibits discharges when a
practicable alternative exists which would have less adverse impact on the aquatic
ecosystem." [See Memorandum.] "If an alleged alternative is unreasonably expensive to
the applicant, the alternative is not practicable." [See Guidelines Preamble, "Economic
Factors," 45 Federal Register 85343 (December 24, 1980).]
Practicable alternatives for the project are those alternatives that are "available and capable
of being done after taking into consideration costs, existing technology, and logistics in
light of overall project purposes." [See 40 C.F.R. 230.10(a)(2).] Clarification is provided
in the Preamble to the Guidelines on how cost is to be considered in the determination of
practicability. An alternative site is considered "available" if it is presently owned by the
applicant or "could reasonably be obtained, utilized, expanded or managed in order to
fulfill the basic purpose of the proposed activity." 40 C.F.R. § 230.10(a)(2).
The intent is to consider those alternatives, which are reasonable in terms of the overall
scope and cost of the proposed project. The term economic [for which the term "costs"
was substituted in the final rule] might be construed to include consideration of the
applicant's financial standing, or investment, or market share, a cumbersome inquiry
which is not necessarily material to the objectives of the Guidelines.
10

The Environmental Protection Agency (EPA) 404(b)(1) Guidelines state that, "we have
chosen instead to impose an explicit, but rebuttable presumption that alternatives to
discharges in special aquatic sites are less damaging to the aquatic ecosystem, and are
environmentally preferable." Of course, the general requirements that impacts to the
aquatic system not be acceptable also applies. This presumption "...contains sufficient
flexibility to reflect circumstances of unusual cases" (249 Fed. Reg., 85339, December
24, 1980). It is clear from these stipulations that a preferable alternative may allow
filling in certain wetland areas and subsequent mitigation and/or management of other
areas.
6.1 Alternatives — Site Selection
Clearwater Paper Corporation was willing to considered sites other than the proposed
project site for development of the manufacturing facility. A set of criteria was
developed to aid in the search for a site and ultimate selection of a site. Some factors that
were considered for property selection include: property size, property availability, access
to rail and interstates, access to utilities, access to an existing labor force, and proximity
to existing operations and the target market. Each criterion is discussed in further detail
below:
Property Size - Tissue manufacturing utilizes specialized equipment that must be
a specific size. For example, machinery must be large enough to create "parent
rolls" of tissue which are 205 inches wide (approximately 17 feet) and 90-120
inches in diameter (7.5-10 feet). Equipment size and storage capacity generally
dictates building size required for manufacturing. At a minimum, storage is
required for approximately 30 days' worth of finished goods inventory and 20-30
days' worth of raw materials.
Property Availabilitv — An alternative site is considered "available" if it is
presently owned by the applicant or "could reasonably be obtained, utilized,
expanded or managed in order to fulfill the basic purpose of the proposed
activity". In order to meet the stated project purpose, the additional
manufacturing and warehouse space would ideally be constructed adjacent to or
in close proximity to the existing facility.
Access to Rail — A suitable project site would require access to existing rail. Rail
is needed to transport raw pulp material directly to the facility. Rail is the most
efficient way for the facility to receive raw materials.
Access to Interstate — A suitable project site would require access to interstates.
Interstate roads are needed to distribute finished goods to market.
Access to Utilities — Any expansion, regardless of location, would require access
to electricity, natural gas, water, and sewer service.
Access to an Existing Labor Force — One goal of manufacturing is to keep
production costs low so that costs for final products remain desirable for

consumers. This allows customers to purchase necessary goods at a reasonable
price while manufacturers make a reasonable profit. One way to minimize the
cost of consumer goods is to minimize the size of the labor force. Expanding
locally is desirable because the labor force is already present.
Proximity to Target Market — Clearwater Paper's Shelby facility provides finished
paper goods distribution for the southeast. Additional storage and manufacturing
capability needs to be located in the market needing supply (in this case, the
southeast).
Cost Efficiency — Manufacturing cost must remain low to supply competitively
priced goods to the market.
6.2 Alternatives — As -Proposed
The proposed project includes development of a paper manufacturing, converting,
and storage facility. The proposed facility would expand on Clearwater Paper's
existing manufacturing and converting capacity at the existing facility (on the east
side of Washburn -Switch Road). The proposed facility allows Clearwater Paper
to expand in two phases (under one roof) with the first phase being completely
operational in 24-30 months. The second phase would be completed after the first
phase was operational. Phase 1 of expansion includes approximately 1,300,000
square feet expansion divided into pulp bale storage, finished products warehouse,
converting, parent roll storage, basement areas. Phase 2 would be a duplicate of
Phase 1. The building is the minimum size necessary to house the required
manufacturing equipment, raw material, and finished good warehousing for both
expansion phases.
Clearwater Paper would likely hire additional shift workers; however, other staff
members, such as management, would be able to expand their scope of work to
include the new facility. Constructing a new facility, at a distance location, would
require an entire new labor force. Although, the labor force requirements are
loosely correlated to environmental impacts at the site, consideration of the labor
force is of importance to Clearwater Paper and their continued operation.
In order to meet the stated project purpose, the additional manufacturing and
warehouse space should be constructed in close proximity to the existing facility.
This prevents duplication of management infrastructure already existing at the
site. Clearwater Paper would likely hire additional shift workers; however, other
staff members, such as management, would be able to expand their scope of work
to include the new facility. Constructing a new facility, at a distance location,
would require an entirely new labor force. Although, the labor force requirements
are loosely correlated to environmental impacts at the site, consideration of the
labor force is of importance to Clearwater Paper and their continued operation.
Close proximity ensures that the additional manufacturing capacity remains at the
center of Clearwater Paper's southeastern market. Electricity, water, sewer, and
natural gas are in close proximity to the site, and a commitment to fund and
12

construct the necessary utility infrastructure upgrades has been secured from the
City of Shelby and Cleveland County. A railroad spur for delivering pulp to the
facility would be extended onto the site from an adjacent CSX main line. Rail is
the most efficient way for the facility to receive raw materials and the expansion
is planned so that the rail can be extended to bring wood pulp directly to the new
facility.
The proposed expansion site is of the size required to house manufacturing
equipment; is available; has access to rail, utilities, and an existing labor force;
and is located in the target market area. The project as proposed is the least
damaging practical alternative and meets the project purpose and needed.
6.3 Alternatives — Use of Existing Facilities (Off -Site)
Generally, additional manufacturing could be done at another existing location
(out-of-state). However, this is not economically feasible or cost efficient. The
closest tissue converting facility is in Elwood, IL approximately 728 miles from
Shelby, NC. And, the closest papermaking facility is in Neenah, WI
approximately 908 miles from Shelby, NC. In either instance, material would
need to be shipped to another facility to complete the manufacturing process and
then shipped back to Shelby for distribution to the southeast. Manufacturing and
distribution facilities should be located relatively close to the market they supply
(southeast) in order to decrease shipping cost to the consumer. Logistically, it is
not feasible or cost efficient to ship materials and products multiple times.
Because Clearwater Paper already manufactures in Shelby and serve the southeast
region, a local expansion is the most rational and feasible option to increase
product production.
6.4 Alternatives — Use of Existing Facility (West of Washburn -Switch Road)
An expansion was originally proposed at the existing facility west of Washburn -
Switch Road. Impacts at this location included 1,882 linear feet of stream
impacts and 0.04 acres of wetland impact. The originally proposed expansion has
not been constructed.. Due to an increase in market demand, a larger expansion is
needed than was originally proposed. The size of the expansion is dictated by the
equipment necessary to manufacture and convert tissue paper; and store the
quantity of raw materials and finished goods at the site. Additional
manufacturing capabilities are needed. Additionally, current paper production is
exceeding storage capacity at the existing site. This exceedance is expected to
increase as production continues to increase. Clearwater Paper has been required
to lease nearby warehouse space to store finished goods. This situation is
undesirable due to double -handling of the products, additional shipping costs, and
the inability to maintain finished goods on site. The new facility would double
manufacturing capacity in the region to meet current market demands and provide
storage space for on-site warehousing of finished goods. The ability to leverage
interactions with existing operations at the existing facility will keep the overall
cost of delivering finished goods competitive, positioning the facility for long
13

term operation and future growth. The savings can then be passed on to the
consumer.
6.5 Alternatives — Use of Existing Facility (West of Washburn -Switch Road) and
a Portion of the Proposed Facility (East of Washburn -Switch Road)
Consideration was given to housing a new paper machine within a new expansion
at the existing facility (west of Washburn -Switch Road), and housing the
converting machines and warehouses at an expansion on the proposed site (east of
Washburn -Switch Road). The paper machine creates parent rolls of tissue which
are then converted to product. Ideally, paper is rolled and converted in the same
facility. Separating the two processes would require limiting the size of the parent
rolls so that they would fit onto a truck; then, trucking the rolls to the converting
facility. This method would decrease manufacturing efficiency and increase costs
due to additional hauling. This would in tum increase cost to the consumer.
6.6 Alternatives — No Action/No Build
An expansion, that meets the applicant's stated project purpose and need, is not
feasible on the proposed property without regulated impacts. Even if a smaller
building could be constructed, stream impacts would be required to cross stream
channels that bisect the property. A smaller building would eliminate vital
manufacturing equipment and the complete tissue manufacturing process could
not be completed in the expansion. The overall project purpose is to expand
tissue paper making and converting capacity to meet market demands. With a
reduced manufacturing ability, market demands would likely not be met.
Clearwater Paper would lose competitive advantage in the market and likely lose
business to other tissue manufacturers that could meet the demand.
If the Corps opted not to issue the permit for the project as proposed, an
expansion would not be built. Manufacturing at the existing facility would
continue, as is, regardless of market demand. In this case, the project purpose and
need would not be met. And as stated above, Clearwater Paper would lose
competitive advantage in the market and likely lose business to other tissue
manufacturers that could meet the demand.
6.7 Avoidance and Minimization
The project as proposed avoids approximately 5,569 linear feet (78%) of stream
and 4.58 acres (99%) of wetlands. Previously proposed impacts to wetlands
associate with stonnwater controls have been eliminated. Additionally, the site
plan makes use of nearby infrastructure which minimizes impacts and land
disturbance on site.
6.8 Alternatives Conclusion
This discussion of avoidance and minimization, together with the documents
submitted by the applicant in support of the 404 Permit, show that the project is in
compliance with the Guidelines. As this analysis clearly demonstrates, the
proposed expansion is designed to avoid and minimize impacts to the site to the
maximum extent practicable while maintaining a rational project design.
14

7.0 CONCEPTUAL MITIGATION PLAN
Upon completion and implementation of practical avoidance and minimization efforts, a
total of 1,578 linear feet of new stream impacts associated with the development of the
proposed project site are unavoidable. Impacts associated with the previous permit
include 104 linear feet of stream impact. Unavoidable stream impacts will be mitigated
for at a compensatory mitigation ratio of 1:1. The following conceptual mitigation plan
is provided in support of this permit application.
7.1 NC Division of Mitisation Services (DMS)
By letter dated December 16, 2016, DMS has indicated they are willing to accept
payment for impacts associated with redevelopment at Clearwater Paper site. The
acceptance letter is enclosed for review (Attachment F). The table below
summarizes the basic mitigation requirements along with the proposed stream
mitigation.
Impact
Total New Impact
Compensatory Mitigation
Ratio (x: ])
Basic Mitigation
Requirement
Previous Impact
104 LF(perennial)
1
104 LF
Impact #1
200 LF(perennial)
1
200 LF
Impact #2
910 LF(perennial)
2
1,820 LF
Impact #3
405 LF(perennial)
2
810 LF
Impact #3
63 LF (intermittent)
1
63 LF
Total Perennial Impact
1,619 LF
Total Intermittent Impact
63 LF
Grand Total Impacts
1,682 LF
Total Mitigation Re uired
2,997 LF
The applicant is not proposing wetland mitigation at this time due to the minimal
amount of wetland impacts.
15

8.0 US ENVIRONMENTAL PROTECTION AGENCY 404(b)(1) GUIDELINES
EPA interim regulations providing guidance for specification of deposit on sites for
dredge and fill material were published on September 17, 1993, in 40 C.F.R. 230 per
Section 404(b)l. Sub -Parts A through I pertain to dredge and fill permits, and apply to
project sites similar to this project.
Sub -Part D presents a summary of compliance criteria for the 404(b)1 guidelines. This
section references and defines practicable alternatives and indicates that a dredge and fill
permit shall not be issued if practicable alternatives exist. Alternatives reviewed, detailed
in Section 6.0, were assessed for compliance with 404(b)1 guidelines.
Additional EPA guidance is presented related to general regulatory criteria, wildlife
value, and human health guidelines. The discharge of dredge and fill material is
considered permittable under these guidelines if the discharge activity: does not
contribute to violation of state water quality standards; does not violate toxic effluent
standards; does not jeopardize the continued existence of species listed as threatened and
endangered pursuant to the federal Endangered Species Act of 1973 and subsequent
amendments; does not cause degradation to any marine sanctuaries; does not contribute
to significant degradation of "waters of the United States;" does not adversely affect
human health as it pertains to water supply; does not adversely impact wildlife, the food
chain, and special aquatic sites; does not contribute to the discharge of pollutants that
may affect the food web; does not have negative effects on the productivity of the aquatic
ecosystem, or their physical values; and does not have adverse impacts on recreation,
aesthetic, or economic values. Additionally, the applicant is required to minimize
potential adverse impacts on the aquatic ecosystem.
8.1 Factual Determination
The Corps is required to determine both potential short-term and long-term effects
of a proposed discharge of dredge and fill material on the physical, chemical, and
biological components of an aquatic environment.
8.2 Potential Impacts on Physical and Chemical Characteristics of the Aquatic
Ecosystem
Sub -Part C of the 40 C.F.R. 230 guidelines lists six physical and chemical
characteristics that must be assessed during the permit review, and the effects of
which must be determined to be minimal on the aquatic ecosystem.
8.2.1 Substrate
Fill material in the form of culverts would be placed in a jurisdictional
stream on site. Any discharge would consist of suitable fill material and
would not include any trash, debris, car bodies, asphalt, etc. The fill
material would also be free of toxic pollutants in toxic amounts. Proper
sediment and erosion control measures would be installed prior to and
during construction to ensure that the bottom elevation of remaining
streams and wetlands on the property would not change.
16

8.2.2 Suspended Particulate/Turbidity (Sediment and Erosion Control)
During construction activities on the site, there may be a minimal increase
in suspended particulates that may lead to increased turbidity downstream.
However, the increase would be minimal and temporary due to the
installation and maintenance of proper sediment and erosion control
measures during construction and shortly thereafter.
8.2.3 Water Quality
The proposed discharge of dredge and fill material should not cause
increased chemical contamination levels within the aquatic ecosystem.
Specifically, changes in clarity, color, odor, and taste of water in addition
to possible chemical contamination shall be minimized or reduced. Al]
discharges of dredge and fill material would be controlled with a sediment
and erosion control plan.
It is anticipated that all of the fill material needed at the site would be
taken from on-site areas. The fill material used on site would be clear and
free of chemical contamination. Should additional fill material be
required, suitable, off-site, clean fill material would be purchased and
transported to the project.
The applicant is concurrently applying for a NC Division of Water
Resources, Water Quality Certification.
8.2.4 Current Patterns in Water Circulation
The proposed discharged dredge and fill material should not adversely
modify current water circulation patterns by obstructing flow, changing
direction or velocity of water, or changing velocity or flow of circulation.
Culverts would be buried to a depth that is equal to 20% of their diameter;
culverts that are larger than 48 inches would be buried to a depth of 12
inches, unless topographic constraints indicate culvert slopes greater than
5% or bedrock is present at the culvert location.
8.2.5 Normal Water Fluctuations
The discharge of fill material associated with this project is not anticipated
to have any significant effect on the downstream hydrologic regimes.
8.2.6 Salinity
Because this project is located inland and away from tidally influenced
waters and wetlands, no modification to the salinity of on-site or adjacent
waters is expected.
17

8.3 Potential Impacts to Biological Characteristics of the Ecosystem
Sub -Part D of the 40 C.F.R. 230 guidelines specifies three areas of concern in
which disposal of dredge and fill material can affect the biological components of
the ecosystem. These components are threaten and endangered species; fish,
crustaceans, mollusks, other aquatic organisms in the food web; and wildlife.
8.3.1 Threatened or Endangered Species
A protected species survey was conducted at the site on July 25 and
August 1, 3, and 4, 2011 by CEC to determine the occurrence of or
potential for existence of federally listed threatened and endangered
animal and plant species, specifically Hexastylis nanii lora, on the project
site. The survey was conducted for Cleveland County. During the site
survey, CEC searched all wooded areas and stream sides for Hexastylis
species. Multiple Hexastylis naniflora plants and populations were
present. A "Threatened and Endangered Species Assessment"
documenting findings of the survey was finalized on November 3, 2011
(Attachment D).
A second protected species survey was conducted at the site on March 27
and April 2, 2015 to further determine the extents of Hexastylis nanii lora
populations on site. This survey was also conducted for Cleveland
County. Approximately 196 Hexastylis nanii lora plants were observed
during this survey. Approximately 70 of the observed plants occurred
along the northeast boundary. The other plants occurred in three locations
along the unnamed tributaries to Bushy Creek near the center of the
property (Figure 3). An official report of findings was never finalized for
this survey.
In April of 2015, after the survey was complete, C1earWater
Environmental Consultants, Inc. (CEC) recommended that Cleveland
County relocate the plants in the center of the site to an area that was
unlikely to be disturbed by future development. In September of 2015,
after coordination with the US Fish and Wildlife Service (FWS),
approximately 126 Hexastylis nanii lora plants were relocated to the
southeastern corner of the subject property (Figure 3). Relocated plants
were planted adjacent to an existing population of Hexastylis nanii lora. A
brief report was submitted to the FWS after completion of the relocation
(Attachment D).
In April of 2016, CEC visited the relocation area to observe general site
conditions, and evaluate the success and vigor of the relocated plants.
Mortality of two plants was noted. A brief report was submitted to the
FWS after completion of the site visit (Attachment D).
W

A site plan was finalize for the project in December of 2016.
Approximately two Hexastylis nanijlora plants were found to be located
within the proposed road corridor. On December 13, 2016, these two
plants were relocated to the west, out of the proposed road corridor and
within the existing population of 70+ plants that would remain unimpacted
by the proposed project (Figure 3). During the December 13, 2016 site
visit, the locations of populations A, B, and C (which were relocated in
2015) were also evaluated for presents of plants that regenerated during
the past year. Approximately 10 plants were found at Site A and
approximately 13 plants were found at Site B. By letter dated December
15, 2016 (Attachment D), the FWS has concurred with a determination
that the proposed project may affect, but is not likely to adversely affect
Hexastylis nanii lora.
A protected species survey was conducted on January 16, 17, and 25, 2017
by CEC to determine the occurrence of or the potential for the existence of
federally listed threatened and endangered animal and plant species,
specifically Hexastylis nanii lora. This survey was conducted on the
proposed Sewer Line Upgrades, New Parallel Gravity Sewer Line, Force
Main Sewer Line Upgrades, and New Water Main Extension and Gas Line
portions of the project. No Hexastylis plants were observed during the
survey. It is the opinion of CEC that installation of the utilities is not
likely to adversely affect Hexastylis nani�lora.
CEC has conducted a file review of up-to-date (October of 2016) records
maintained by the FWS and North Carolina Natural Heritage Program
(NHP). The desktop literature review involved a review of the FWS list of
protected species in Cleveland County and the NHP Element Occurrence
Data on which NHP identifies current and historic occurrences of listed
species for a specific locale. The FWS lists 2 species as occurring in
Cleveland County. The NHP database identifies 11 element occurrences
(EO) within a 2 -mile radius of the project site; 8 EOs, comprised of 1
species, hold Federal status and are subject to Section 7 consultation. The
species identified by the FWS and NHP are listed below.
Common Name I Scientific Name I Status
Northern Long-eared Bat M otis se tentrionalis I Threatened
Dwarf -flowered heartleaf Hexas lis naniflora Threatened
*Hexastylis naniflora has been discussed above.
CEC consulted the FWS's "Northern Long -Eared Bat Consultation Areas"
map for Cleveland County. The proposed project site is not in a Hydrologic
Unit Code (HUC) identified as having known occurrences of hibernation of
maternity sites. It is the opinion of CEC that any incidental take associated
with proposed activities would be exempt under the 4(d) rule. By letter
dated December 15, 2016 (Attachment D), the FWS has concurred with
19

this determination. Approximately 65 acres of tree clearing would occur at
the site.
It is the opinion of CEC that the requirements under Section 7 of the
Endangered Species Act have been fulfilled for this project. The FWS will
be notified via Public Notice about the project and will be given the
opportunity to comment on the project and its potential effects on threatened
and endangered species.
8.3.2 Fishes Crustaceans Mollusks and other Aquatic Organisms in the Food
Web
Discharges of dredge and fill material can alter the food web by impacting
animals, such as invertebrates, that make up the basis of a food chain. The
release of contaminants or an increase in turbidity has the potential to
negatively affect certain aspects of the food web. Such releases may also
potentially increase the levels of exotic species.
Culverts on site would be partially buried in the streambed to allow natural
stream substrate to accumulate in the bottom of the culvert and to allow
uninhibited aquatic life passage.
Impacts to primary food chain production within the waters of the US and
wetlands on the project site is expected to be minimal.
8.3.3 Other Wildlife
The discharge of dredge and fill material has the potential to negatively
affect breeding and nesting areas, escape cover, travel corridors, and
preferred food sources for resident and migrant wildlife species.
The project as proposed would not affect breeding and nesting areas,
escape cover, travel corridors, or food sources for resident and migrant
wildlife species.
8.4 Potential Impacts on Special Aquatic Sites
Sub -Part E of the 40 C.F.R. 230 guidelines addresses considerations for potential
impacts on special aquatic sites, which include: sanctuaries and refuges,
wetlands, mud flats, vegetated shallows, coral reefs, and riffle -pool complexes.
8.4.1 Sanctuaries and Refuges
The discharge of dredge and fill material has the potential to negatively
affect adjacent sanctuaries and wildlife refuges by impacting water
quality, decreasing wildlife habitat, increasing human access, and creating
the need for frequent maintenance activity, resulting in the establishment
of undesirable plant and animal species, which can change the balance of
habitat type. There are no designated sanctuaries of refuges located within
20

the project vicinity; therefore, impacts to sanctuaries or refuges would not
occur as a result of development at the proposed project site.
8.4.2 Wetlands
The discharge of dredge and fill material has the potential to adversely
affect wetlands including wetland substrate, hydrology, and vegetation.
Discharges can lead to a loss of wetland values, such as wildlife habitat,
flood storage, and groundwater recharge. Approximately 0.03 acre of
wetlands would be impacted as a result of development at the proposed
project site.
8.4.3 Mud Flats
Discharge of dredge and fill material has the potential to negatively affect
mud flats that exist along inland lakes, ponds, and riverine systems. There
are no mud flat communities within the project boundary; therefore, loss
of these ecosystems would not occur as a result of development at the
proposed project site.
8.4.4 Vegetated Shallows
Discharge of dredge and fill material has the potential to negatively affect
vegetated shallows. Vegetated shallows are permanently inundated areas
that contain rooted aquatic vegetation. This type of habitat generally
exists within estuarine and marine environments; and some freshwater
lakes and rivers. No vegetated shallow habitats exist within the project
boundary; therefore, no impacts to this ecosystem would occur as a result
of development at the proposed project site.
8.4.5 Coral Reefs
Discharge of dredge and fill material has the potential to negatively affect
coral reefs. Coral reefs typically exist within marine ecosystems. Coral
reefs do not exist within the project boundary; therefore, no impacts to this
ecosystem would occur as a result of development at the proposed project
site.
8.4.6 Riffle -Pool Complexes
Discharge of dredge and fill material into or upstream of riffle -pool
complexes has the potential to negatively affect water quality and wildlife
value. The streams on site are of poor quality and do not exhibit natural
morphology. Although riffle -pool complexes may be impacted by the
proposed project, all impacts to stream channels would be mitigated.
8.5 Potential Effects on Human Use Characteristics
Sub -Part F of the 40 C.F.R. 230 guidelines address potential effects on human use
of wetlands and waterways. Factors including water supply, recreational and
commercial fisheries, water -related recreation, aesthetics, and parks and similar
preserves are considered within this portion of the guidelines.
21

8.5.1 Municipal and Private Water Supoly
The public water supply would not increase or decrease due to activities at
the proposed project site. Potable water would be supplied by the City of
Shelby.
8.5.2 Recreational and Commercial Fisheries
Discharge of dredge and fill material has the potential to negatively affect
recreational and commercial fisheries. Streams on site are not a part of
any recreational or commercial fishery. Activities taking place at the
proposed project site would not adversely impact recreational or
commercial fisheries.
8.5.3 Water -Related Recreation
Activities taking place at the proposed project site would not increase or
decrease waterborne recreation in the project boundary or vicinity.
8.5.4 Aesthetics
Aesthetically, the proposed development would be no different from any
other industrial development in surrounding areas. The project is not
expected to diminish the aesthetic value of the area or cause disharmony
from an aerial or neighboring view.
8.5.5 Parks, National and Historical Monuments, National Beach Shores
Wilderness Areas, Research Sites, and Similar Preserves
No parks, national or historical monuments, national beach shores,
wilderness areas, research sites, or similar preserves would be affected by
the proposed development at the site.
8.6 Summary
Based on the EPA guidelines identified within 40 C.F.R. 230, and enumerated
herein, a number of potential environmental impacts have been presented and
subsequently addressed. The proposed permanent impact to 1,578 linear feet of
unnamed tributaries to Brushy Creek and 0.03 acre of wetland will not cause any
off site adverse impacts. Mitigation offered through payment in to the DMS
would compensate for any on-site impacts.
22

9.0 PUBLIC INTEREST CONSIDERATIONS
When reviewing this application, the Corps is required to consider the project in terms of
the public interest. In considering the public interest, the Corps must evaluate the
probable impacts of the project and evaluate the "benefits which reasonably may be
expected to occur from the proposal against reasonably foreseeable detriments". In
balancing these interests, the Corps must consider the public and private need for the
proposed project, the practicability of using reasonable alternative locations, and the
extent and permanence of the beneficial and/or detrimental impacts of the project. The
Corps also considers the following public interest factors:
conservation, economics, aesthetics, general environmental concerns,
wetlands, historic and cultural resources, fish and wildlife values, flood
hazards, floodplain values, land use, navigation, shore erosion and
accretion, recreation, water supply and water quality, energy needs, safety,
food and fiber production, mineral needs, and considerations of the
property ownership.
Pursuant to 33 C.F.R. 323.6, a determination that the project is not contrary to the public
interest must be achieved before permit issuance. Public interest considerations are listed
in 33 C.F.R. 320.4 (a)(1) and are discussed below.
Furthermore, the Corps regulations state that a permit will be granted unless the district
engineer determines that it would be contrary to the public interest.
The applicant has extensively evaluated these factors through the planning process and
believes that the proposed project is clearly not contrary to the public interest.
9.1 Conservation
The applicant is not proposing preservation as a component of the project;
however, those projects completed by the DMS in association with this
project would be preserved in perpetuity.
9.2 Economics
The project would provide an overall benefit to the local economy of
Cleveland County. During and upon completion of construction, the site
would provide job opportunities associated with operation and
maintenance of the facility. The appropriate economic evaluations have
been completed and the project as proposed is economically viable.
9.3 Aesthetics
Aesthetically, the proposed development would be no different from any
other industrial development in surrounding areas. The project is not
expected to diminish the aesthetic value of the area or cause disharmony
from an aerial or neighboring view.
23

9.4 General Environmental Concerns
Other than stream impacts, proposed development activities at the
development site would have no significant identifiable impacts upon other
environmental components.
9.5 Wetlands
The discharge of dredge and fill material has the potential to adversely
affect wetlands including wetland substrate, hydrology, and vegetation.
Discharges can lead to a loss of wetland values, such as wildlife habitat,
flood storage, and groundwater recharge. Approximately 0.03 acre of
wetlands would be permanently impacted as a result of the expansion at
the proposed project site.
9.6 Historic Properties
On October 28, 2011, TRC completed a background study and limited
field reconnaissance for a large tract adjacent to Washburn Switch Road
which included the proposed project area (Attachment E). The goal of the
work was to assess the potential for significant cultural resources on and
adjacent to the property. The literature search identified no previously
recorded archeological sites on the tract. It is TRC's opinion that
archaeological sites are likely present on the site; however, given the soil
characteristics and the results of nearby surveys, any prehistoric sites that
are present are unlikely to be eligible for the National Register of Historic
Places (NRHP).
The only documented historic structure near the property is the Coleman
Blanton Farm, which is situated approximately 1,600 feet northeast of the
property. Given its distance from the property, it is very unlikely that this
structure complex would be affected by development of the property.
The October 28, 2011 letter concluded that the site research and field
reconnaissance suggests that the property is unlikely to contain any
archaeological sites that would constrain development.
9.7 Fish and Wildlife Values
Riparian and wetland areas provide habitat for many types of wildlife
because of their diverse and productive plant communities, complex
structure, and close proximity to surface water. Wildlife may be
permanent residents of riparian and wetland areas or occasional visitor that
use the areas for food, water, or temporary shelter.
Food availability varies with the type of vegetation in riparian and wetland
areas, but includes fruit, seed, foliage, twigs, buds, insects, and other
invertebrates. Trees and shrub produce a variety of foods that are eaten by
many animals and may be especially important sources of nutrition during
24

the winter months. Grasses and herbaceous vegetation provide seeds and
forage both within riparian and wetland areas and along the forest border.
The stream environment provides moving water for many animals to
drink, feed, swim, and reproduce. Water is also available on moist
vegetation and in wetlands that are often associated with riparian areas.
These areas, both permanent and temporary, are especially important for
amphibians and macro -invertebrates.
Riparian and wetland areas provide a sheltered environment for many
species of animals to feed, rest, and reproduce. Animals use these areas to
seek shelter from extreme weather and to escape predators and human
activity. Riparian and wetland areas may also provide important travel
corridors for some species, and are frequently used as stop -over points for
migratory birds.
Riparian areas are narrow and overgrown with exotic species.
Overgrowth has created a dense understory that does not represent unique
or high quality wildlife habitat.
9.8 Flood Hazards
It is likely that some tributaries on the property will flood occasionally due
to natural fluctuations in weather patterns that increase precipitation. The
activities proposed to take place within the project boundary are not
expected to increase or decrease the natural rate of flooding at the site or
downstream.
9.9 Floodplain Values
Designated floodplains are present along Bushy Creek and extend into the
project boundary (FEMA Map Panel 37102528007, effective February 20,
2008, Figure 4). All site development would take place outside of the
designated 100 -year floodplain.
9.10 Land Use
The proposed project would be in compliance with local zoning
regulations and ordinances. The project is consistent with surrounding
land use and development.
9.11 Navigation
Streams on site are tributaries to Brushy Creek which is a tributary to the
First Broad River. The First Broad River is a tributary to the Broad River
which is a navigable -in -fact water in South Carolina. Activities proposed
at the development site are not likely to affect navigation.
25

9.12 Shore Erosion and Accretion
The proposed project should have minimal effects on erosion and runoff.
An erosion control plan would be implemented as part of the construction
plan for the project. During the construction process, best management
practices (BMPs) would be followed. These BMPs would include the
construction of swales, erosion and sediment control structures, turbidity
barriers, and other measures that would prevent sediment transport off the
project site and into adjacent waters. Activities proposed at the
development site are not likely to cause significant erosion or accretion.
9.13 Recreation
Proposed activities would not increase or decrease waterborne recreation
on site or in the project vicinity.
9.14 Water Supply and Conservation
The public water supply would not increase or decrease due to proposed
activities at the development site.
9.15 Water Quality (Stormwater Management)
No short term or long term adverse water quality impacts are anticipated.
BMPs would be incorporated during construction.
The applicant would be concurrently applying for a NC Division of Water
Resources, Water Quality Certification.
9.16 Energy Needs
Activities taking place at the development site, during construction and at
full build out, are not expected to significantly increase energy demands
beyond the capacity of the local facility. Energy would not be produced as
a result of the proposed activities at the development site.
9.17 Safety
The proposed project would be designed with the maximum possible
considerations for public safety. The proposed activities at the development
site will not increase or decrease public safety.
9.18 Food and Fiber Production
The proposed activities at the development site would not increase or
decrease food and fiber production.
9.19 Mineral Needs
The project fulfills no current mineral needs. No mining activities are
proposed as part of the proposed activities at the development site.
26

9 20 Considerations of Property Ownership
Cleveland County currently owns the property proposed for development
and has the inherent right to develop the land in a reasonable and
responsible manner, which includes adhering to all Federal, State, and
local regulations.
Cleveland County Government
Attn: Mr. Jeff Richardson, County Manager
P.O. Box 1210
311 East Marion Street
Shelby, NC 28151
9.21 Needs and Welfare of the Public
The proposed project would positively address the needs and welfare of the
public by providing additional commercial/retail goods to citizens across the
country. Additional jobs would be created during construction and
operations of the facility in Cleveland County, North Carolina.
27

10.0 SECONDARY AND CUMULATIVE EFFECTS
The proposed project site is located within the Broad River Subbasin 03-08-04.
Approximately 63 percent of this subbasin is forested and the total land mass includes
approximately 426 square miles (272,640 acres). The project area is comprised of
approximately 241 acres (0.37 square miles). All of the land mass included within the
project site accounts for less than 0.09 percent of the land mass of the basin. These
percentages alone, limit significant cumulative effects on the watershed. Past activities
within the subbasin include logging; agricultural, commercial and residential development;
and road building. Agricultural and residential development and road building in the
vicinity remains active. Continued and future development of the watershed is independent
of activities proposed at the project site. Impacts within the project boundary include the
development of a manufacturing facility. Stream impacts are necessary for the construction
at the site. Activities associated with the proposed project should not result in a significant
impairment of the water resources on site or interfere with the productivity and water
quality of the existing aquatic ecosystem.
11.0 SUMMARY
The expansion at the proposed project site includes 1,578 linear feet of stream impact and
0.03 acres of wetland impact. Alternatives have been discussed and the project as
proposed is the least damaging practical alternative which meets the project purpose.
Potential impacts to the physical and chemical characteristics of the ecosystem, biological
characteristic of the ecosystem, impacts on special aquatic sites, and potential effects on
human use characteristics would be minimal. The project is not contrary to the public
interest and would aid in the continued growth of Cleveland County.

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Pmviousl3 Pertness] Impacts
104 if and 009¢
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Attachment A
Jurisdictional Determination for project site
(dated January 23, 2017)
and
Jurisdiction Determination Request for Utility (sewer, water, gas) Corridors

U.S. ARMY CORPS OF ENGINEERS
WILMINGTON DISTRICT
Action Id. SAW -2011-02398 County: Cleveland U.S.G.S. Quad: NC -Shelby
NOTIFICATION OF JURISDICTIONAL DETERMINATION
Property Owner:
Cleveland County Government
Kristin Reese
Address:
311 East Marion St., PO Box 1210
Shelby, NC, 28151
Telephone Number:
704-300-9818
E-mail:
kristinQccedp.com
Size (acres) 350 Nearest Town Sbelby
Nearest Waterway Brushy Creek River Basin Santee
USGS HUC 03050105 Coordinates Latitude: 35.320277
Longitude: -81.598591
Location description: 35.320277,-81.598591. Site is on the HEM near the intersection of Washburn Switch Road and Farmville
Road.
Indicate Which of the Following Apply:
A. Preliminary Determination
❑ There appear to be waters on the above described project area/property, that may be subject to Section 404 of the Clean Water
Act (CWA)(33 USC § 1344) and/or Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403). The waters 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 appear to be waters on the above described project area/property, that may be subject to Section 404 of the Clean Water
Act (CWA)(33 USC § 1344) and/or Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403). However, since the waters
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 CW A/RHA
jurisdiction over all of the waters at the project area, which is not sufficiently accurate and reliable to support an enforceable
permit decision. We recommend that you have the waters on your project area/property delineated. As the Corps may not be able
to accomplish this wetland delineation in a timely manner, you may wish to obtain a consultant to conduct a delineation that can
be verified by the Corps.
B. Approved Determination
❑ There are Navigable Waters of the United States within the above described project area/property subject to the permit
requirements of Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403) and Section 404 of the Clean Water Act
(CWA)(33 USC § 1344). Unless there is a change in law or our published regulations, this determination may be relied upon for
a period not to exceed five years from the date of this notification.
® There are waters on the above described project area/property subject to the permit requirements of Section 404 of the Clean
Water Act (CWA) (33 USC § 1344). Unless there is a change in the law or our published regulations, this determination may be
relied upon for a period not to exceed five years from the date of this notification.
❑ We recommend you have the waters on your project area/property delineated. As the Corps may not be able to accomplish
this wetland delineation in a timely manner, you may wish to obtain a consultant to conduct a delineation that can be verified by
the Corps.

Z The waters on your project area/property have been delineated and the delineation has been verified by the Corps. The
approximate boundaries of these waters are shown on the enclosed delineation map dated 4/28/2016.. If you wish to have the
delineation surveyed, the Corps can review and verify the survey upon completion. Once verified, this survey will provide an
accurate depiction of all areas subject to CWA and/or RHA 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 have been delineated and surveyed and are accurately depicted on the plat signed by the Corps Regulatory Official
identified below on SURVEY SIGNED DATE. Unless there is a change in the law or our published regulations, this
determination may be relied upon for a period not to exceed five years from the date of this notification.
❑ There are no waters of the U.S., to include wetlands, present on the above described project area/property which are subject to the
permit requirements of Section 404 of the Clean Water Act (33 USC 1344). Unless there is a change in the law or our published
regulations, this determination may be relied upon for a period not to exceed five years from the date of this notification.
❑ The property is located in one of the 20 Coastal Counties subject to regulation under the Coastal Area Management Act (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 fi II 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 Shaeffer at 704-510-1437 or
David.L.Shaeffera,usace.a rmy.mil.
C. Basis For Determination: Basis For Determination: See the approved iurisdictional determination
form dated 1/23/2017.
D. Remarks: None.
E. Attention USDA Program Participants
This delineation/determination has been conducted to identify the limits of Corps' Clean Water Act jurisdiction for the particular site
identified in this request. The delineation/determination may not be valid for the wetland conservation provisions of the Food Security
Act of 1985. If you or your tenant are USDA Program participants, or anticipate participation in USDA programs, you should request
a certified wetland determination from the local office of the Natural Resources Conservation Service, prior to starting work.
F. Appeals Information (This information applies only to approved jurisdictional determinations as indicated in B.
above)
This correspondence constitutes an approved jurisdictional determination for the above described site. If you object to this
determination, you may request an administrative appeal under Corps regulations at 33 CFR Part 331. Enclosed you will find a
Notification of Appeal Process (NAP) fact sheet and request for appeal (RFA) form. If you request to appeal this determination you
must submit a completed RFA form to the following address:
US Army Corps of Engineers
South Atlantic Division
Atm: Jason Steele, Review Officer
60 Forsyth Street SW, Room I OM 15
Atlanta, Georgia 30303-8801
In order for an RFA to be accepted by the Corps, the Corps must determine that it is complete, that it meets the criteria for appeal
under 33 CFR part 33 1.5, 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 03/24/2017
**It is not necessary to submit a�\n/\ PFA form to the Division Office if you do not object to the determination in this correspondence.**
d--+ ////1111 OIVIOIIY,4nN bY5x/.E{ifP➢/.Vlfll GHIIW]]O5,]
xN:n115.x11S4onmmm4w=CoO.ou.iFl.ou.YSA
mcSXPEfiE0.tI�V103f14x.IMN50$]I
Corps Regulatory Official: MIc:�V.41.]]L:I*S4LEM
Date of 1D: 1/23/2017 Expiration Date of 1D: 1/23/2022

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
htip://corpSnlapu usace armv.mil/cm apex/f?p=136:4:0.
Copy furnished:
Agent: Clear Water Environmental
Clement Riddle
Address: 32 Clayton St.
Asheville, NC, 28801
Telephone Number: 828-698-9800
E-mail: clementna cwenv.com

Jurisdictional Determination
• New Water Main Extension & Gas ]Line
• Approximate Sewer gine Upgrades
• New Parallel Gravity Sewer Line
• Force Main Sewer Upgrades

ATTACHMENTA
PRELIMINARY JURISDICTIONAL DETERMINATION FORM
BACKGROUND INFORMATION
A. REPORT COMPLETION DATE FOR PRELIMINARY JURISDICTIONAL
DETERMINATION (JD): January 30,2017
B. NAME AND ADDRESS OF PERSON REQUESTING PRELIMINARY JD:
Cleveland County Government, Attn: Jeff Richardson
P.O. Boz 1210, Shelby, NC 28151
C. DISTRICT OFFICE, FILE NAME, AND NUMBER:
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION:
Project is Located off Famville Rd, Chatfield Rd, Polkville Rd, W. Grove Street, W. Dixon Blvd, Crest Rd, 8 River Rd in Shelby, NC.
(USE THE ATTACHED TABLE TO DOCUMENT MULTIPLE WATERBODIES AT DIFFERENT
SITES)
State: NC County/parish/borough: Cleeland
City: Shelby
Center coordinates of site (lat/long in degree decimal format):
Lat. 35.324179 ON; Long, -81.582537 W.
Universal Transverse Mercator:
Name of nearest waterbody: First Broad River
Identify (estimate) amount of waters in the review area:
Non -wetland waters:
677 linearfeet: 3-50 width (ft) and/or acres.
Cowardin Class: c
Stream Flow: Perennial & Intermittent
Wetlands: 0.032 acres.
Cowardin Class: c
Name of any water bodies on the site that have been identified as Section 10
waters:
Tidal:
Non -Tidal:

E. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT
APPLY):
❑ Office (Desk) Determination. Date:
❑✓ Field Determination. Date(s): January 16,17, and 24, 2017
SUPPORTING DATA. Data reviewed for preliminary JD
(check all that apply - checked items should be included in case file and,
where checked and requested, appropriately reference sources below):
❑✓ Maps, plans, plots or plat submitted by or on behalf of the
applicant/consultant:
❑✓ Data sheets prepared/submitted by or on behalf of the
applicant/consultant.
Office concurs with data sheets/delineation report.
❑ Office does not concur with data sheets/delineation report.
❑ Data sheets prepared by the Corps:
❑ Corps navigable waters' study:
❑ U.S. Geological Survey Hydrologic Atlas:
❑ USGS NHD data
❑ USGS 8 and 12 digit HUC maps
❑✓ U.S. Geological Survey map(s). Cite scale & quad name:
❑ USDA Natural Resources Conservation Service Soil Survey.
❑ National wetlands inventory map(s). Cite name:
❑ State/Local wetland inventory map(s
❑ FEMA/FIRM maps:
❑ 100 -year Floodplain Elevation is:
(National Geodectic Vertical Datum of 1929)
❑✓ Photographs: ❑ Aerial (Name & Date): NcccIA(2015) or
❑ Other (Name & Date):
❑ Previous determination(s). File no. and date of response letter:
❑ Other information (please specify
2

1. The Corps of Engineers believes that there may be jurisdictional waters of the
United States on the subject site, and the permit applicant or other affected party
who requested this preliminary JD is hereby advised of his or her option to
request and obtain an approved jurisdictional determination (JD) for that site.
Nevertheless, the permit applicant or other person who requested this
preliminary JD has declined to exercise the option to obtain an approved JD in
this instance and at this time.
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
approved JD for the activity, the permit applicant is hereby made aware of the
following: (1) the permit applicant has elected to seek a permit authorization
based on a preliminary JD, which does not make an official determination of
jurisdictional waters; (2) that the applicant has the option to request an approved
JD before accepting the terms and conditions of the permit authorization, and
that basing a permit authorization on an approved JD could possibly result in less
compensatory mitigation being required or different special conditions; (3) that
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)
that 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) that undertaking
any activity in reliance upon the subject permit authorization without requesting
an approved JD constitutes the applicant's acceptance of the use of the
preliminary JD, but that either form of JD will be processed as soon as is
practicable; (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 preliminary JD constitutes agreement that all
wetlands and other water bodies on the site affected in any way by that activity
are jurisdictional waters of the United States, and precludes 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 approved JD or a preliminary JD, that JD
will be processed as soon as is practicable. Further, an approved JD, 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,
and that in any administrative appeal, jurisdictional issues can be raised (see 33
C.F.R. 331.5(a)(2)). If, during that administrative appeal, it becomes necessary
to make an official determination whether CWA jurisdiction exists over a site, or
to provide an official delineation of jurisdictional waters on the site, the Corps will
provide an approved JD to accomplish that result, as soon as is practicable.

This preliminary JD finds that there "may be" waters of the United States on the
subject project site, and identifies all aquatic features on the site that could be
affected by the proposed activity, based on the following information:
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.
Signature and date of
Regulatory Project Manager
(REQUIRED)
0ll. PLV-- I LiTDl1�
Signature and date of
person requesting preliminary JD
(REQUIRED, unless obtaining
the signature is impracticable)

Potential ly3urisdictional Water
Site Number
Latitude
Longitude
owardin Clas
Estimated Amount
of Aquatic Resource
in Review Area
Class of Aquatic Resource
Sl UT Beaverdam Creek)
35.314724
-81.610021
C
44 LF
Non -Section 10 - Non -wetland
S2 UT Beaverdam Creek)
35.311191
-81.612060
C
70 LF
Non -Section 10 - Non -wetland
S3 UT Beaverdam Creek)
35.304981
-81.612770
C
56 LF
Non -Section 10 - Non -wetland
S4 (UT Beaverdam Creek)
35.301558
-81.611714
C
12 LF
Non -Section 10 - Nan -wetland
SS UT Beaverdam Creek
35.292939
-81.608017
C
41 LF
Non -Section 10 - Non -wetland
S6 UT Beaverdam Creek
35.293143
-81.607712
C
145 LF
Non -Section 10 - Non -wetland
S7 UT Beaverdam Creek
35.283892
-81.608834
C
46 LF
Non -Section 10 - Non -wetland
SS UT Beaverdam Creek)
35.280316
-81.611785
C
43 LF
Non -Section 10 - Non -wetland
S9 UT Beaverdam Creek)
35.275812
-81.615467
C
58 LF
Non -Section 10 - Non -wetland
S10 UT Beaverdam Creek
35.274361
-81.616499
C
40 LF
Non -Section 10 - Non -wetland
Sl l (Fist Broad River)
35.245266
-81.571806
C
22 LF
Non -Section 10 - Non -wetland
S12 Little Creek)
35.327742
-81.593829
C
32 LF
Non -Section 10 - Nan -wetland
S13 Brush Creek
35.320450
-81.576112
C
31 LF
Non -Section 10 -Non -wetland
S14 UT Bnushy Creek
35.321454
-81.570026
C
5 LF
Non -Section 10 - Non -wetland
S15 First Broad River
35.302765
1 -81.565934
C
32 LF
Non -Section 10 - Non -wetland
W 1 UT Beaverdam Creek)
35.309516
-81.612361
C
0.001 AC
Non -Section 10 - Wetland
W2 (UT Beaverdam Creek
35.290975
-81.608839
C
0.02 AC
Non -Section 10 -Wetland
W3 (UT Beaverdam Creek)
35.288681
-81.608152
C
0.001 AC
Non -Section 10 - Wetland
W4 (UT Beaverdam Creek)
-81.616352
C
0.01 AC
Non -Section 10 - Wetland

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Drawn by: KAY 1.23.17; Tied# 890 det co"\cov�'�
Cleveland CounCLearWaterty, Site Vicinty
North Carolina 32 Clayton Street
Asheville. North Carolina 28801 Figure 1

Utility Overview
�,f New Water Main
i Extension & Gas Line Y. !
� l
Approximate Sewer I
Line Upgrades \ ! I •1 .. ��
1 vel
r
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r 1
it ,-r.., 1 .•� � _. �/ - i
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Legend
EDApproximate Sewer Line Upgrades e
New Parallel Gravity Sewer Line
Force Main Sewer Upgrades
Q 1 _O 2,000 4,000 8,000
® New Water Main Extension 8 Gas Line , _ '.'� ' Feel
Ura Eby: KAY 1,23.13p-
�1 y _
CLea— AAAker USGS Topographic Map
Cleveland County, 7 Shelby & Blacksburg North Quad!
North Carolina 32 Clayton street
Asheville, North Carolina 28801 figure 2

Approximate Sewer Line Upgrades & New Parrallel Gravity Sewer Line
iY P02
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Cleveland County, CLearWater USDA Soils Map
North Carolina 32 Clayton Street
Asheville, North Carolina 28801 Figure 4, Sheet I
Apo j+d2 Ur
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_
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Drawn by., KAY 1.24.17; Pmjecl# 800
c.e3`\�,
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Cleveland County, CLearWater USDA Soils Map
North Carolina 32 Clayton Street
Asheville, North Carolina 28801 Figure 4, Sheet I

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WETLAND DETERMINATION DATA FORM — Eastern Mountains ano rteamont Kegion
Project/Site: CY16 CfZAra-r•1
F CAS
rnor1-6 City/County: �-j
EyELA rJ r1 Sampling Dale: t I}11-7-
Applicant/Owner:
-� Surface Water (All
_ True Aquatic Plants (B14)
Stale: KI C SamplingPoint: W 7_
Investigator(s): ILa•)T /
_ Hydrogen Sulfide Odor (Cl)
Section, Township, Range:
Landform (hillslope, terrace, etc.):
DFP¢cnT r„ ­r
Local relief (concave,
convex, none): Cnn! c nJG Slope (%): � I �-
Subregion (LRR or MLRA): Lk B P Lac
'i S. 290959
Long: - R I G 1)A5 3 o Datum: 01, R3
Soil Map Unit Name:? hT PA
r it SAur,Nl rr0v
r„a u, Is ve zs i. sroPCS.
M -o. EcooED NWI classification:
Are climatic I hydrologic conditions on the site typical for
this time of year? Yes :f
No (If no, explain in Remarks.)
Are Vegetation _, Soil _
or Hydrology
significantly disturbed?
Are "Normal Circumstances” present? Yes Y No
Are Vegetation _, Soil _,
or Hydrology _
nalurally 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 X No Is the Sampled Area
Hydric Soil Present? Yes X No within a Wetland? Yes _� No
Wetland Hydrology Present? Yes X No
Remarks:
WC1eAN1) Z. WE1ce 0 f)0 AT NJ aFF-511E Io S,aCA
HYDROLOGY
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two required)
Primary Indicators (minimum of one is repuired� check all that apply)
_ Surface Soil Cracks (136)
-� Surface Water (All
_ True Aquatic Plants (B14)
_ Sparsely Vegetated Concave Surface (68)
_ High Water Table (A2)
_ Hydrogen Sulfide Odor (Cl)
_ Drainage Patterns (B10)
X Saturation (A3)
X Oxidized Rhizospheres on Living Roots (0)
_ Moss Trim Lines (B16)
_ Water Marks (B1)
_ Presence of Reduced Iron (C4)
_ Dry -Season Water Table (C2)
_ Sediment Deposits (62)
_ Recent Iron Reduction in Tilled Soils (C6)
_ Crayfish Burrows (C8)
_ Drift Deposits (133)
_ Thin Muck Surface (0)
_ Saturation Visible on Aerial Imagery (C9)
_ Algal Mat or Crust (B4)
_ Other (Explain in Remarks)
_ Stunted or Stressed Plants (D1)
_ Iron Deposits (135)
_ Geomorphic Position (132)
_ Inundation Visible on Aerial Imagery (B7)
_ Shallow Aquitard (D3)
X Water -Stained Leaves (139)
_ Microlopographic Relief (D4)
_ Aquatic Fauna (B13)
_ FAC-Neulral Test (D5)
Field Observations:
Surface Water Present? Yes �_ No_
Depth (inches): n - I
Water Table Present? Yes _ No _
X Depth (inches):
Saturation Present? Yes K No_
Depth (inches): \
Wetland Hydrology Present? Yes X No
(includes capillary fringe)
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:
Remarks:
US Army Corps o1 Engineers Eastern Mountains and Piedmont - Version 2.0

VLL3L f AI IUM tvive Jiraial - uDu nuouurnu lid, mo yr P gnu. 'r y' ......
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0
Absolute Dominant Indicator
Dominance Test worksheet:
Tree Stratum (Plot size: 3n
1 % Cover Species Status
Number of Dominant Species
1
That Are OBL, FACW, or FAQ (A)
2.
Total Number of Dominant
Species Across All Strata: Z (B)
3,
4.
Percent of Dominant Species
That Are OBL. FACW, or FAC: 5 0 (- (AIB)
5.
6.
= Total Cover
Prevalence Index worksheet:
Total % Cover of Multiply by:
50% of total cover: 20% of total cover:
DEL species n x 1 = O
Sapling Stratum (Plot size:
I S 1
FACW species ) r7 x 2 = 3v
1.
FAC species 5 x 3 = 17
2.
FACU species 0 x 4 = 0
3.
UPL species O X5= fl
4.
Column Totals: 2 O (A) 9'S (B)
5.
Prevalence Index = BIA = 2 2 5
6
= Total Cover
Hydrophytic Vegetation Indicators:
50% of 10181 cover: 20% of total cover:
_ 1 - Rapid Test for Hydrophytic Vegetation
Shrub StratumPlot size:
1 Stratum(
Is- )
_ 2 - Dominance Test is X50%
Y 3 - Prevalence Index is 53.0'
_ 4 - Morphological Adaptations' (Provide supporting
data in Remarks or on a separate sheet)
2
3.
_ Problematic Hydrophytic Vegetation' (Explain)
4.
5.
'Indicators of hydric soil and wetland hydrology must
6.
be present, unless disturbed or problematic.
Definitions of Five Vegetation Strata:
= Total Cover
Herb Stratum (Plot size:
1. (A2EY Sill
5o% of total cover: 20% of total cover:
S ) `I
Z 5
Tree - Woody plants, excluding woody vines.
approximately 20 if (6 m) or more in height and 3 in.
(7.6 cm) or larger in diameter at breast height (DBH).
Sapling - Woody plants, excluding woody vines,
approximately 20 If (6 m) or more in height and less
than 3 in. (7.6 cm) DBH.
2. n . u a rf Sv 5 15 Y AC v.7
3. Lo n cM '4APdmi n S tJ TA(
4. Vi vn CO
5
Shrub - Woody plants, excluding woody vines,
approximately 3 to 20 It 0 to 6 m) in height.
5
7.
6
Herb -All herbaceous (non -woody) plants, including
herbaceous vines, regardless of size, and woody
plants, except woody vines, less than approximately 3
9.
ft (1 m) in height.
10.
Woody vine -All woody vines, regardless of height.
11.
�t� = Total Cover
50%of total cover: Z 3. 5 20%of total cover: 0i 9
Woody Vine Stratum (Plot size: 1
1.
2.
3.
4.
5.
Hydrophytic
= Total Cover
50% of total cover: 20%of total cover:
Vegetation
Present? YesNo
_
Remarks: (Include photo numbers here pr on a separate sheet.)
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

SOIL
00111pully ry .. � .-
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)
Depth Matrix
Redox Features
(inches) Color (moist)
Calor (moist) % Type Loc`
Texture Remarks
0-17 lolrz ph 95
to -1R PIL
LOAM
'Type: C=Concentration. D=De lotion, RM=Reduced
Matrix, MS=Masked Sand Grains.
'Location: PL=Pore Lining, M=Matrix.
Hydric Soil Indicators:
Indicators for Problematic Hydric Soils':
_ Hislosol (Al)
_ Dark Surface (S7)
_ 2 cm Muck (A10) (MLRA 147)
_ Hislic Epipedon (A2)
_ Polyvalue Below Surface (SB) (MLRA 147, 148)
_ Coast Prairie Redox (Al 6)
Black Hislic (A3)
_ Thin Dark Surface (59) (MLRA 147, 148)
(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)
_ Very Shallow Dark Surface (TF1 2)
_
_ Depleted Below Dark Surface (Al l)
_ Depleted Dark Surface (F7)
_ Other (Explain in Remarks)
_ Thick Dark Surface (At 2)
_ Redox Depressions (178)
_ Sandy Mucky Mineral (Si) (LRR N,
_ Iran -Manganese Masses (1712) (LRR N,
MLRA 147, 148)
MLRA 136)
_ Sandy Gleyed Matrix (S4)
_ Umbric Surface (F13) (MLRA 136, 122)
'Indicators of hydrophylic vegetation and
_ Sandy Redox (S5)
_ Piedmont Floodplain Soils (F19) (MLRA 148) wetland hydrology must be present.
_ Stripped Matrix (S6)
_ Red Parent Material (1721) (MLRA 127, 147)
unless disturbed or problematic.
Restrictive Layer (if observed):
Type: )?We
Depth (inches): )Z
Hydric Soil Present? Yes_ No
Remarks:
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

WETLAND DETERMINATION DATA FORM - Eastern Mountains and Piedmont Region
Project/Site: 6°101,(7nt7 v SCu E? L-joE CASEinefJ City/County: C.LI:VELA�D Sampling Dale: I Il Il"
ApplicanUOwner. (o- A - (I rFW(A i A ta A M o -to 7 'l. 5 Lo PEi OrarG SJONAt`I t:«�or0 State: N (_ Sampling Point: VJ
Investigamr(s): VA -4 Rt Y Section, Township, Range:
Landform (hillslope, terrace, etc J:i�Po (OCUULA-iTnu Local relief (concave, convex, none): (n Of AU F Slope I%):
Subregion(LRR or MLRA): I_ER P Lal: -5. 7f & 15 Long: -At • 60HIG7 Datum: NAD?,
Soil Map Unit Name:
NWI classification:
Are climatic / hydrologic conditions on the site typical for this time of year? Yes Y No _ (If no, explain in Remarks.)
Are Vegetation Soil _, or Hydrology significantly disturbed? Are 'Normal Circumstances- present? Yes 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 is the Sampled Area
Hydric Soil Present? Yes i No within a Wetland? Yes,[_ No
Welland Hydrology Present? Yes No
Remarks:
WEI LAND 3, 1-7 NEAR VVCE LaNU cep'IiN �I E: O�'F -`,TrF is S j11EAt+1
HYDROLOGY
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two reauiredl
Primary Indicators (minimum of one Is required, check all that apply)
_ Surface Soil Cracks (86)
Surface Water (AI)
_ True Aquatic Plants (B14)
_ Sparsely Vegetated Concave Surface (BB)
_
_ High Water Table (A2)
_ Hydrogen Sulfide Odor (Cl)
_ Drainage Patterns (BID)
-� Saturation (A3)
_ Oxidized Rhizospheres on Living Roots (C3)
_ Moss Trim Lines (Bl6)
_ Water Marks (B7)
_ Presence of Reduced Iron (C4)
_ Dry -Season Water Table (C2)
_ Sediment Deposits (B2)
_ Recent Iron Reduction in Tilled Soils (C6)
_ Crayfish Burrows (C6)
_ Drift Deposits (63)
_ Thin Muck Surface (0)
_ Saturation Visible on Aerial Imagery (C9)
_ Algal Mat or Crust (84)
_ Other (Explain in Remarks)
_ Stunted or Stressed Plants (D1)
_ Iron Deposits (B5)
X Geomorphic Position (D2)
_ Inundation Visible on Aerial Imagery (137)
_ Shallow Aquitard (D3)
_ Waler-Stained Leaves (B9)
_ Microtopographic Relief (D4)
_ Aquatic Fauna (B13)
Y 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
X No_ Depth (inches): I
Wetland
Hydrology Present? Yes _X No
(includes capillary rrin e
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous Inspections), if available:
Remarks:
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

VEGETATION (Five Strata) — Use scientific names of plants. Sampling Point: W3
Tree Stratum (Plot size: So )
1
Absolute Dominant Indicator
°5 Cover Species? Status
Dominance Test worksheet:
Number of Dominant Species
That Are OBL. FACW, or FAC: 3 (A)
2.
Total Number of Dominant
Species Across All Strata: 3 (B)
3,
4'
Percent or Dominant Species
That Are DBL, FACW, or FAC: 1 0 O '1. (A/B)
5.
6.
= Total Cover
Prevalence Index worksheet:
Total % Cover of: Multiply by:
50% of total cover:
Sapling Stratum (Plot size: 15 1
20% of total cover:
OBL species S x 1 = S
FACW species ) x 2 = 3fr
1
FAC species 2 x 3 =
•
2.
FACU species 0 x 4 = U
3.
UPL species D X5=
Column Totals: Z (o (A) A01 (B)
4.
S.
6:
Prevalence Index = BIA = I • $ 8
= Total Cover
Hydrophytic Vegetation Indicators:
50% of total cover:
Shrub Stratum (Plot size: 15 )
1. Srt�tx IJ26tzn
20% of total cover:
�_ `/ ORL
_ 1 - Rapid Test for Hydrophytic Vegetation
2 - Dominance Test is >50%
3- Prevalence Index is 53.0'
_ 4- Morphological Adaptations' (Provide supporting
data in Remarks or on a separate sheet)
_ Problematic Hydrophytic Vegetation' (Explain)
2. 13 E a r� a eo- z Y T A c r
3•
4.
5•
6.
'Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.
7 = Total Cover
Definitions of Five Vegetation Strata:
5o% of total cover:
3. 5 20% of total cover: 1 y
Tree - Woody plants, excluding woody vines,
Herb Stratum (Plot size: 5 )
1. i - • J t eF =US U t
_ `/ fn,j
approximately 20 it (6 m) or more In height and 3 in.
(7.6 cm) or larger in diameter at breast height (DBH).
2. L co -r cee n 7A? �-r n
FA -"`7
Sapling - Woody plants, excluding woody vines,
approximately 20 ft (6 m) or more in height and less
Than 3 in. (7.6 cm) DBH.
3. A LE v 2l1 iio r WN _ -I FAI
4.
5
Shrub - Woody plants, excluding woody vines,
approximately 3 to 20 it (1 to 6 m) in height.
Herb - All herbaceous (non -woody) plants, including
herbaceous vines, regardless of size, and woody
plants, except woody vines, less than approximately 3
6
7.
0
9•
it (I m)in height.
10.
Woody vine -All woody vines, regardless of height.
11.
101 = Total Cover
50% of total cover:
q.5 20% of total cover:
Woody Vine Stratum (Plot size: 30 )
1.
2.
3.
4.
S.
Hydrophylic
50% or total cover.
= Total Cover
20% of total rover.
Vegetation
Present? Yes X_ No
Remarks: (Include photo numbers here or on a separate sheet.)
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

son
Profile
to
the indicator or
Sampling Point: W 3
Depth Matrix Redox Features
(inches) Color (moist) % Color (mois0 % Tvoe Loc Texture Remarks
0- 10 7. S I G /7 q_L_ '11-Z ''Jk II STIT LUAM
_ Histasol(Al)
_ Hislic Epipedon (A2)
_ Black Hislic (A3)
_ Hydrogen Sulfide (A4)
Stratified Layers (A5)
_ 2 cm Muck (A10) (LRR N)
_ Depleted Below Dark Surface (All)
_ Thick Dark Surface (Al2)
_ Sandy Mucky Mineral (Si) (LRR N,
MLRA 147,148)
_ Sandy Gleyed Matrix (S4)
_ Sandy Redox (55)
Stripped Matrix (56)
Type: QntK
Depth (inches): to
Dark Surface (S7)
_ Polyvalue Below Surface (SB) (MLRA 147, 148)
_ Thin Dark Surface (S9) (MLRA 147, 148)
Loamy Gleyed Matrix (F2)
Depleted Matrix (F3)
_
Redox Dark Surface (F6)
_ Depleted Dark Surface (F7)
_ Redox Depressions (FB)
_ Iron -Manganese Masses (1`12) (LRR N,
MLRA 136)
_ Umbric Surface (F13) (MLRA 136, 122)
_ Piedmont Floodplain Soils (F19) (MLRA 148)
Red Parent Material (F21) (MLRA 127, 147)
Indicators for Problematic Hydric So
_ 2 cm Muck (A70) (MLRA 147)
_ Coast Prairie Redox (A16)
(MLRA 147, 148)
_ Piedmont Floodplain Sails (F19)
(MLRA 136, 147)
_ Very Shallow Dark Surface (TF12)
_ Other (Explain in Remarks)
'Indicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problemalic.
Hydric Soil Present? yes _Y No
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

WETLAND DETERMINATION DATA FORM — Eastern Mountains and Piedmont Region
Project/Site:�90u&mak-rl �FWF¢. LvOC EA1[rnC0T City/County: /I.IVELAN1i COUM11 Sampling Dale:
Applicant/Owner: stale: OL Sampling Point I I Pl-
Invesligator(s): KAYO137y Section, Township, Range:
Landform (hillslope, terrace, etc.):l-ni , e of EyirsiTi . 17 i Local relief (concave, convex, none): FLAB Slope (%): �..
Subregion (LRR or MLRA): L k Iz P Lal: 35 Z5 10 3 a Long: —81 606 (6-11 Datum: NAS R�
Soil Map Unit Name: A —z'r S(a?ES O(eANSVIIJAuVl FLo lFi) NWI classification:
Are climatic I hydrologic conditions on the site typical lar this time of year? Yes Y_ No (If no, explain in Remarks.)
Are Vegetation _, soil _, or Hydrology _ significantly disturbed? Are "Normal Circumstances' present? Yes Y 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 '(
Hydric Soil Present? Yes _ No X
Wetland Hydrology Present? Yes No
TJI�LA NO
A-1 12 -ro ?% 0O 'S .
HYDROLOGY
Is the Sampled Area
within a Wetland? Yes No
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two required)
Primary Indicators (minimum of one is required, check all that apply)
_, Surface Soil Cracks (B6)
Surface Water (Al)
_ True Aquatic Plants (B14)
_ Sparsely Vegetated Concave Surface (BB)
_
High Water Table (A2)
_ Hydrogen Sulfide Odor (Cl)
_ Drainage Patterns (B10)
_
Saturation (A3)
_ Oxidized Rhizospheres on Living Roots (C3)
_ Moss Trim Lines (B16)
_
Water Marks (Bl)
_ Presence of Reduced Iron (C4)
_ Dry -Season Water Table (C2)
_
Sediment Deposits (B2)
_ Recent Iron Reduction in Tilled Soils (C6)
_ Crayfish Burrows (CB)
_
_ Drift Deposits (83)
_ Thin Muck Surface (C7)
_ Saturation Visible on Aerial Imagery (C9)
_ Algal Mat or Crust (B4)
_ Other (Explain in Remarks)
_ Stunted or Stressed Plants (Dl)
_ Iron Deposits (BS)
_ Geomorphic Position (02)
Inundation Visible on Aerial Imagery (57)
_ Shallow Aquilard (D3)
_
Water -Stained Leaves (B9)
_ Microtopographic Relief (D4)
_
_ Aquatic Fauna (B13)
_ FAC-Neulral Test (DS)
Field observations:
Surface Water Present? Yes _ No-,<
Depth (inches):
Water Table Present? Yes _ No
X Depth (inches):
Ji
Saturation Present? Yes _ No
X Depth (inches):
Wetland
Hydrology Present? Yes _ No
[includes capillary fringe)
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:
Remarks:
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

VFr:FTAT1nN (Five Strata) - Use scientific names of plants.
Sampling Point: Of L- 3
Tree Stratum (Plot size: 'o ) %Cover Species? Status Number of Dominant Species
t That Are OBL. FACW, or FAC: ) (A)
2. Total Number of Dominant
3 Species Across All Strata: .� (B)
4. Percent of Dominant Species
s That Are DBL, FACW, or FAC: 33 ' (A/B)
= Total Cover Hydropnytrc vegetation mnrcdtu,-:
50% of total cover: 20% of total cover: _ 1 - Rapid Test for Hydrophytic Vegetation
X
Shrub Stratum (Plot size: 1.5- ) V — 2 - Dominance Test is 50% ,
1. LSG ui-f ¢ u rg S wcNz r- _� / FAa tJ — 3 - Prevalence Index is s3.0
2 _ 4 . Morphological Adaptations' (Provide supporting
data In Remarks or on a separate sheet)
3• Problematic Hydrophytic Vegetation' (Explain)
11:3 = Total Cover
50% of total cover: 20% 20% of total cover:_
Herb Stratum (Plot size: S )
1. f -r r'LCFen rap rr-cn 1° —L FCL
2. TB-rgce, Sri to Y
3. LUG 0,11 R.vM SU nt FNSP 1 0 T-AG%I
4. So -iDA(-a SP Z o
7
Z,q - Total Cover
50% of total cover: IZ 20% of total cover: q
Woody Vine Stratum (Plot size: 30 )
'Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.
Tree - Woody plants, excluding woody vines,
approximately 201t (6 m) or more in height and 3 in.
(7.6 cm) or larger in diameter at breast height (DBH).
Sapling - Woody plants, excluding woody vines,
approximately 20 It (6 m) or more in height and less
than 3 in. (7.6 cm) DBH.
Shrub - Woody plants, excluding woody vines,
approximately 3 to 20 ft 0 to 6 m) in height.
Herb- All herbaceous (non -woody) plants, including
herbaceous vines, regardless of size, and woody
plants, except woody vines, less than approximately 3
It (1 m) in height.
Woody vine - All woody vines, regardless of height.
Hydrophytic
Total Cover I vegetation
Present?
509. of total cover: 20% of total cover:
is here or on a separate sheet)
Yes _ No X
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0
- Total Cover
a
Total %Cover of:
Multiply by:
50% of total cover:
20% of 10181 cover:
OBL species n
x 1 = 0
Sapling Stratum (Plot size: I S I
FACW species n
x 2 = CD
1.
FAC species 10
x 3 = so
2.
FACU species 11-
x 4 = (p �j
3.
UPL species O
x 5 = n
4.
Column Totals: 7-+
(A) G P, (B)
5.
,.
Prevalence Index = BIA
= 3 • G 3
= Total Cover Hydropnytrc vegetation mnrcdtu,-:
50% of total cover: 20% of total cover: _ 1 - Rapid Test for Hydrophytic Vegetation
X
Shrub Stratum (Plot size: 1.5- ) V — 2 - Dominance Test is 50% ,
1. LSG ui-f ¢ u rg S wcNz r- _� / FAa tJ — 3 - Prevalence Index is s3.0
2 _ 4 . Morphological Adaptations' (Provide supporting
data In Remarks or on a separate sheet)
3• Problematic Hydrophytic Vegetation' (Explain)
11:3 = Total Cover
50% of total cover: 20% 20% of total cover:_
Herb Stratum (Plot size: S )
1. f -r r'LCFen rap rr-cn 1° —L FCL
2. TB-rgce, Sri to Y
3. LUG 0,11 R.vM SU nt FNSP 1 0 T-AG%I
4. So -iDA(-a SP Z o
7
Z,q - Total Cover
50% of total cover: IZ 20% of total cover: q
Woody Vine Stratum (Plot size: 30 )
'Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.
Tree - Woody plants, excluding woody vines,
approximately 201t (6 m) or more in height and 3 in.
(7.6 cm) or larger in diameter at breast height (DBH).
Sapling - Woody plants, excluding woody vines,
approximately 20 It (6 m) or more in height and less
than 3 in. (7.6 cm) DBH.
Shrub - Woody plants, excluding woody vines,
approximately 3 to 20 ft 0 to 6 m) in height.
Herb- All herbaceous (non -woody) plants, including
herbaceous vines, regardless of size, and woody
plants, except woody vines, less than approximately 3
It (1 m) in height.
Woody vine - All woody vines, regardless of height.
Hydrophytic
Total Cover I vegetation
Present?
509. of total cover: 20% of total cover:
is here or on a separate sheet)
Yes _ No X
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

SOIL
depth needed to document the indicator or
Sampling Point: QFL 3
Depth Matrix Redox Features
(inches) Color (moist) % Color (moist) % Tvoe Lac Texture Remarks
I -L Io -IK A/9 015 Iu'IV 4/r, _ .A LOAM w LeSn i" of
('2Of' EL cc,-rinl Js
&eE L F1 LL 1 n.I Oen Ac
Hydric Soil Indicators:
Indicators for Problematic Hydric Soils':
Hislosol (Al)
_ Dark Surface (S7)
_ 2 cm Muck (A10) (MLRA 147)
_
_ Hislic Epipedon (A2)
_ Polyvalue Below Surface (SB) (MLRA 147, 148)
_ Coast Prairie Redox (A16)
Black Hislic (A3)
_ Thin Dark Surface (59) (MLRA 147, 148)
(MLRA 147, 148)
_
_ Hydrogen Sulfate (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)
_ Very Shallow Dark Surface (TF12)
_
_ Depleted Below Dark Surface (All)
_ Depleted Dark Surface (F7)
_ Other (Explain In Remarks)
_ Thick Dark Surface (At 2)
_ Redox Depressions (F8)
_ Sandy Mucky Mineral (S1) (LRR N,
_ Iron -Manganese Masses (F12) (LRR N,
MLRA 147,148)
MLRA 136)
_ Sandy Gleyed Matrix (S4)
_ Umbric Surface (F13) (MLRA 136, 122)
'Indicators of hydrophylic vegetation and
_ Sandy Redox (S5)
_ Piedmont Floodplain Soils (1779) (MLRA 148)
wetland hydrology must be present,
_ Stripped Matrix (S6)
Red Parent Material (1721) (MLRA 127, 147)
unless disturbed or problematic.
Type:
Depth (inches):
Hydric Soil Present? Yes _ No
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

WETLAND DETERMINATION DATA FORM — Eastern Mountains and Piedmont Region
ProjecUSile: '6c1 AA 1-Z 'I S6wr-o_ 17rJF CACFMPNICitylCounty: /rfVCCANI Crnirs'rl Sampling Date: -1 111
Applicant/Owner: State: NC Sampling Point: VJ/t
Investigator(s): ILAy 51 y Section, Township, Range:
Landform (hillslope, terrace, etc.): 7f Pt'ESS io.J Local relief (concave, convex, none): !o iJ CK � e Slope (°o): �) �1•
Subregion (LRR or MLRA): 1 12 R P Lal: 3G . 2-49 9 Sn Long: R I G r (c 'i ': e. Datum: Wp V) cA ?
Soil Map Unit Name: CIA /Ijt7i iA LCA LOAM -2-/• 5 P{t Ortnts= rnu-r FL -,a NWl classification:
Are climatic 1 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 disturbed7 Are "Normal Circumstances- present? Yes y 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 1( No Is the Sampled Area
Hydric Soil Present? Yes X No within a Wetland? Yes i' No
Welland Hydrology Present? Yes X No
Remarks:
VW CTLAO0 A. WET'A O 7RATJ1 0Fs-STYE
HVDROLOGY
Welland Hydrology Indicators:
Secondary Indicators (minimum of two required)
Primary Indicators (minimum of one is required, check all that aooly)
_ Surface Soil Cracks (B6)
Surface Water (A1)
_ True Aquatic Plants (B74)
_ Sparsely Vegetated Concave Surface (138)
_
_ High Water Table (A2)
_ Hydrogen Sulfide Odor (C7)
_ Drainage Patterns (BIC)
.0 Saturation (A3)
_ Oxidized Rhizospheres on Living Roots (C3)
_ Moss Trim Lines (B16)
Water Marks (Bt)
_ Presence of Reduced Iron (C4)
_ Dry -Season Water Table (C2)
_
Sediment Deposits (132)
_Recent Iron Reduction in Tilled Soils (C5)
_ Crayfish Burrows (CB)
_
_ Drift Deposits (B3)
_ Thin Muck Surface (0)
_ Saturation Visible on Aerial Imagery (C9)
_ Algal Mat or Crust (B4)
_ Other (Explain in Remarks)
_ Stunted or Stressed Plants (D7)
_ Iron Deposits (B5)
_ Geomorphic Position (D2)
Inundation Visible on Aerial Imagery (B7)
_ Shallow Aquilard (D3)
_
X Water -Stained Leaves (B9)
_ Microtopographic Relief (04)
_ Aquatic Fauna (B13)
_ FAC -Neutral Test (D5)
Field Observations:
Surface Water Present? Yes _
No X Depth (inches):
Water Table Present? Yes
No V Depth (inches):
Saturation Present? Yes X
No_ Depth (inches): i
Wetland
Hydrology Present? Yes �� No
(includes capillary fringe)
Describe Recorded Data (stream gauge,
monitoring well, aerial photos, previous inspections), i( available:
Remarks:
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

VEGETATION (Five Strata) - Use scientific names of plants.
Sampling Point:__
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0
Absolute Dominant Indicator
Dominance Test worksheet:
Tree Stratum (Plot size: 30 )
1
% Cover Species? Status
Number of Dominant Species
That Are (DEL, FACW, or FAQ ) (A)
2.
Total Number of Dominant
Species Across All Strata: Z (e)
3.
4.
Percent of Dominant Species
That Are DBL, FACW, or FAC: SO , 1. (A/B)
5.
6.
= Total Cover
Prevalence Index worksheet:
Total % Cover of: Multiply by:
50% of total cover:
20% of total cover:
DEL species n x 1 = n
Sapling Stratum (Plot size: 1 j;- )
FACW species 1-5- x 2 = 3o
1-
FAC species 5 x 3= I S
2.
FACU species 2 x 4 = 'Yu
3.
UPL species J x 5 = c7
4.
Column Totals: ZZ (A) 5-S (B)
5.
Prevalence Index = BIA
6
= Total Cover
Hydrophylic Vegetation Indicators:
50% of total cover:
Shrub Stratum (Plot size: 1 S )
1
2
20% of total cover:
_ 1 - Rapid Test for Hydrophytic Vegetation
_ 2 - Dominance Test is a50%
3 . Prevalence Index is 53.0'
_ 4 - Morphological Adaptations' (Provide supporting
data in Remarks or on a separate sheet)
3•
_ Problematic Hydrophytic Vegetation' (Explain)
4.
5'
'Indicators of hydric soil and wedand hydrology must
6.
be present, unless disturbed or problematic.
= Total Cover
Definitions of Five Vegetation Strata:
50% of total cover:
Herb Stratum (Plot size: S )
I. CPZEx 'SP.
20% of total cover:
t S Y
Tree - Woody plants, excluding woody vines.
approximately 20 it (6 m) or more in height and 3 in.
(7.6 cm) or larger in diameter at breast height (DBH).
2. l u"c u i E f Fv su 3
115 FAL
Sapling - Woody plants, excluding woody vines,
approximately 20 it (6 m) or more in height and less
than 3 in. (7.6 cm) DBH.
3. L ,J- c.E¢A 7N,POJ ILA S r.J FA c
4. QZ N
S. 7- 1h C,poz-T. s1—Zf TJ—m �JA
2 tJ FAtO
Shrub- Woody plants, excluding woody vines,
approximately 3 to 20 it (1 to 6 m) in height.
6
7.
Herb - All herbaceous (non -woody) plants, including
herbaceous vines, regardless of size, and woody
plants, except woody vines, less than approximately 3
B
9,
ft (1 m) in height.
10.
Woody vine -Ail woody vines, regardless of height.
11.
3°I = Total cover
50% of total cover: I 1 . S 20% Of total cover: ti
Woody Vine Stratum (Plot size: 30 )
1,
2.
3.
4.
S.
Hydrophylic
50% of total cover:
= Total Cover
20% of total cover:
Vegetation
Present? yes /� No
Remarks: (Include photo numbers here or on a separate sheet.)
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

soil
or
Depth Matrix Redox Features
(inches) Calor (moist) % Color (1110150 Tvoe Loc
C\- W 1.VV )/Z qO-1.S`1R 4/4IO C IA
.lno RM=Reduced Matrix. MS=Masked Sand Grains.
Soil Indicators:
_ Histosol (A1)
_ Histic Epipedon (A2)
Black Histic (A3)
_ Hydrogen Sulfide (A4)
_ Stratified Layers (A5)
_ 2 cm Muck (A10) (LRR N)
Depleted Below Dark Surface (All)
_ Thick Dark Surface (Al2)
_ Sandy Mucky Mineral (Sl) (LRR N,
MLRA 147,148)
_ Sandy Gleyed Matrix (S4)
_ Sandy Redox (S5)
Stripped Matrix (S6)
Type: Kuce /LaMPA c'1TnN
Depth (inches): 16
Sampling Point: W 'I
absence
Texture Remarks
SPiJOY LQAM
_ Dark Surface (S7)
_ Polyvalue Below Surface (S8) (MLRA 147, 148)
_ Thin Dark Surface (S9) (MLRA 147, 148)
_ Loamy Gleyed Matrix (172)
_ Depleted Matrix (F3)
_ Redox Dark Surface (F6)
Depleted Dark Surface (F7)
_ Redox Depressions (FB)
_ Iron -Manganese Masses (F12) (LRR N,
MLRA 136)
_ Umbric Surface (F73) (MLRA 136, 122)
_ Piedmont Floodplain Soils (F19) (MLRA 148)
Red Parent Material (F21) (MLRA 127, 147)
Indicators for Problematic Hydric So
_ 2 cm Muck (Al0) (MLRA 147)
_ Coast Prairie Redox (Al 6)
(MLRA 147, 148)
Piedmont Floodplain Soils (1`19)
(MLRA 136,147)
_ Very Shallow Dark Surface (TF12)
_ Other (Explain in Remarks)
'Indicators of hydrophylic vegetation and
wetland hydrology must be present,
unless disturbed or problematic.
Hydric Soil Present? Yes No
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

WETLAND DETERMINATION DATA FORM - Eastern Mountains and Piedmont Region
Project/Site: Y,1r1 �?A,r Y SCwEL' I-sr-ic EA1EMr City/County: CLEVELA,Jf) cc.,.u,,l Sampling Date: 13- t�
Applicant/Owner: State: r-1 c Sampling Point: t) p L 4
Investigator(s): 14A%l %I Section, Township, Range:
Landform (hillslope, terrace, etc.): Enc C a FrnSn.lo 9tw Local relief (concave, convex, none): FLAT Slope (%):
Subregion (LRR or MLRA): L Q R P Lat: 5. 2-4 S o9 x Long: — A 1 (a I to Z9 to Datum: rel A D 9 3
Soil Map Unit Name: C A -!tc )t, LLA t.AIAn•7'r• `+cc�CS, V` OEDNWI classification:
Are climatic I hydrologic conditions an the site typical for this time of year? Yes Y No (If no, explain in Remarks.)
Are Vegetation _. Soil or Hydrology _ significantly disturbed? Are 'Normal Circumstances' present? Yes ,,.r No
Are Vegetation _, Soil _ or Hydrology naturally problematic? (It needed, explain any answers in Remarks.)
SUMMARY OF FINDINGS — Attach site map showing sampling point locations, transects, important features, etc.
Hydrophylic Vegetation Present? Yes — Nom_ I Is the Sampled Area
Hydric Soil Present? Yes No v within a Wetland? Yes No k
Welland Hvdroloov Present? Yes No -*l'
UPLAND PA"11Z -T,, '-
HYDROLOGY
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two reauiredl
Primary Indicators (minimum of one is required, check all that apply)
_ Surface Soil Cracks (B6)
_ Surface Water (Al)
_ True Aquatic Plants (014)
_ Sparsely Vegetated Concave Surface (BB)
_ High Water Table (A2)
_ Hydrogen Sulfide Odor (Cl)
_ Drainage Patterns (B10)
_ Saturation (A3)
_ Oxidized Rhlzospheres on Living Roots (C3)
_ Moss Trim Lines (116)
_ Water Marks (Bl)
_ Presence of Reduced Iron (C4)
_ Dry -Season Water Table (C2)
_ Sediment Deposits (B2)
_ Recent Iron Reduction In Tilled Soils (C6)
_ Crayfish Burrows (Coil
_ Drift Deposits (B3)
_ Thin Muck Surface (C7)
_ Saturation Visible on Aerial Imagery (C9)
_ Algal Mat or Crust (B4)
_ Other (Explain in Remarks)
_ Stunted or Stressed Plants (Dl)
_ Iron Deposits (85)
_ Geomorphic Position (D2)
_ Inundation Visible on Aerial Imagery (B7)
_ Shallow Aquimrd (D3)
_ Water -Stained Leaves (B9)
_ Microtopographic Relief Oil)
_ Aquatic Fauna (B13)
_ FAC -Neutral Test (05)
Field Observations:
Surface Water Presem? Yes— No
y Depth (inches):
Water Table Present? Yes _ No
X Depth (inches):
Saturation Present? Yes _ No
i Depth (inches):
Wetland
Hydrology Present? Yes _ No
(includes ca ilia frin e
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:
Remarks:
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

t/Fr1FTATICIN (Five Stratal - Use scientific names of plants.
Sampling Point: V I' L. 4
Tree Stratum (Plot size: 3 D ) % Cover Species? Status Number of Dominant Species
1 That Are OBL, FACW. or FAC: [\ (A)
2. Total Number of Dominant
3 Species Across All Strata: 3 (B)
4. Percent of Dominant Species
s That Are OBL, FACW, or FAC: O I. (AIB)
= Total Cover Hydropnytm vegetation mu.ca....;
50% of total cover: 20% of total cover: _ 1 - Rapid Test for Hydrophytic Vegetation
2 - Dominance Test is >50%
Shrub Stratum (Plot size: 15' ) — '
7. L7l tG,¢ur.n S7 ,mac. -ASF to y —fncJ—3'Prevalenre Index 1553.0
_ 4 - Morphological Adaptations' (Provide supporting
2. data in Remarks or on a separate sheet)
3• — Problematic Hydrophylic Vegetation' (Explain)
10 = Total Cover
so% of total cover:
= Total Cover
Total %Cover of:
Multiply by:
OBL species D
x 1 = d
50% of total cover: 20% of total cover:
Sapling Stratum (Plot size: 1 S I
2. LurJTCECA —%n?a NicA
FACW species 7_
x 2 =�_
1.
z-
FAC species to
x3= 3 0
2.
j FAC
FACU species
UPL species
Column Totals: 2G
x 4 = �J G
X5= 0
(A) CIO (B)
3.
4.
5.
VA -V
Prevalence Index = BIA = 9 (e
= Total Cover Hydropnytm vegetation mu.ca....;
50% of total cover: 20% of total cover: _ 1 - Rapid Test for Hydrophytic Vegetation
2 - Dominance Test is >50%
Shrub Stratum (Plot size: 15' ) — '
7. L7l tG,¢ur.n S7 ,mac. -ASF to y —fncJ—3'Prevalenre Index 1553.0
_ 4 - Morphological Adaptations' (Provide supporting
2. data in Remarks or on a separate sheet)
3• — Problematic Hydrophylic Vegetation' (Explain)
10 = Total Cover
so% of total cover:
S 20% of total cover: Z
Herb Stratum (Plot size: �, )
1.1E<TJrA S?-
2. LurJTCECA —%n?a NicA
A
3. TQ VQ'm% CFF usui
z-
FACW
4.?VAq— L,AccA
2
j FAC
5.5 ,rte &d G'>
Z
N
Z
VA -V
6. IAQA-XACJN 1OFP-c r rA c
rj
'Indicators of hydric sol and wel and hydrology must
be present, unless disturbed or problematic.
Tree - Woody plants, excluding woody vines,
approximately 20 it (6 m) or more in height and 3 in.
(7.6 cm) or larger in diameter at breast height (DBH).
Sapling - Woody plants, excluding woody vines,
approximately 20 it (6 m) or more in height and less
than 3 in. (7.6 cm) DBH.
Shrub - Woody plants, excluding woody vines,
approximately 3 to 20 it (1 to 6 m) in height.
Herb - All herbaceous (non -woody) plants, including
herbaceous vines, regardless of size, and woody
plants, except woody vines, less than approximately 3
It (1 m) in height.
10. Woody vine - All woody vines, regardless of height.
11.
<i = Total Cover
50% of Iotas cover: 2`1 20% of total cover: 9 . (e
Woody Vine Stratum (Plot size: 6 )
H
ege a i
—
=Total Cover Vegetatonn
Present? Yes No
50% of total cover: 20% of total cover:
rs here or on a separate sheet.)
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

cnu
Sampling Point: uJI _L9
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)
Depth Matrix
(inches) Color (moist) %
Redox Features
Color (moist) % Type Loc Texture
Remarks
0 16 �.SyR 9/!0 loo
S nJoy LrAM
'Type: C=Concentration, D=De letion, RM=Reduced Matrix, MS=Masked Sand Grains. 'Location:
PL=Pore Lining. M=Matrix.
Indicators for Problematic Hydric Soils':
Hydric Soil Indicators:
Histosol (Al)
_ Dark Surface (S7) _
2 cm Muck (A70) (MLRA 147)
_
Histic Epipedon (A2)
_ Polyvalue Below Surface (S8) (MLRA 147, 148) _
Coast Prairie Redox (A16)
_
Black Histic (A3)
_ Thin Dark Surface (S9) (MLRA 147, 148)
(MLRA 147, 148)
_
Hydrogen Sulfide (A4)
_ Loamy Gleyed Matrix (F2) _
Piedmont Floodplain Soils (F79)
_
Stratified Layers (A5)
_ Depleted Matrix (F3)
(MLRA 136, 147)
_
2 cm Muck (A10) (LRR N)
_ Redox Dark Surface (F6) _
Very Shallow Dark Surface (TF12)
_
_ Depleted Below Dark Surface (A11)
_ Depleted Dark Surface (F7) _
Other (Explain in Remarks)
Thick Dark Surface (Al2)
_ Redox Depressions (FB)
_
_ Sandy Mucky Mineral (S7) (LRR N,
_ Iron -Manganese Masses (F12) (LRR N,
MLRA 147, 148)
Sandy Gleyed Matrix (S4)
MLRA 136)
_ Umbrlc Surface (F13) (MLRA 136, 122)
'Indicators of hydrophytic vegetation and
_
Sandy Redox (S5)
_ Piedmont Floodplain Soils (F19) (MLRA 148)
wetland hydrology must be present,
_
_ Stripped Matrix(f (S6)
_ Red Parent Material (F21) (MLRA 127, 147)
unless disturbed or problematic.
Restrictive Layer observed):
Type: Q4•¢ h MoRLTTON
Y
Hydric
Soil Present? Yes_ No_:L_
Depth (inches): It)
Remarks:
US Army Corps of Engineers
Eastern Mountains and Piedmont - Version 2.0

Potentially Jurisdictional Water ' `•
Wetland (AQ Stream(LF)
W1 0.001 Sl 44,E
W2 0.02 S2 70
W3 0.001 S3 56 I 1 I f
W4 0.01 S4 121 /
S5 41 1 ��
S6 145
S7 46
S8 43
S9 58 —
S10 40
S11 22 �1{
S12 32
S13 31
S14 5—
Sis 32
'Foul 0.032 Total 677 ' -
Stream
Contours
Force Main Sewer Upgrades Easement (20 FT ROW)
)raven by: KAY 1.25:17; CEC Project# 893 _
Cleveland County,
North Carolina
Force MaOM Sewer Upgrades
ft ('_ - •a
CLearWaker
32 Clayton Street
Asheville, North Carolina 28801
Jurisdictional wetlands and waters identified on this map have been located within sub -meter accuracy
utilizing a Trimble mapping grade Global Positioning System (GPS) and the subsequent differential
correction of that data. GPS points may demonstrate uncorrectable errors due to topography, vegetative
cover, and/or multipath signal error.
Note: The illustrated wetland and stream locations are approximate. These areas have been flagged In the
field; however, they have not been surveyed. Although Clearwater Environmental Consultants, Inc. (CEC) Is
confident in our assessment, the US Army Corps of Engineers (Corps) is the only agency that can make
final decisions regarding jurisdictional wetland and waters of the US delineations. Therefore, all preliminary
determinations are subject to change until written verification is obtained. CEC strongly recommends that
written verification be obtained from the Corps prior to dosing on the property, beginning any site work, or
making any legal reliance on this determination.
This map was prepared by CEC using the best Information available to CEC at the time of production. This
map is for informational purposes only and should not be used to determine precise boundaries, roadways,
property boundary lines, nor legal descriptions. This map shall not be construed to be an official survey of
any data depicted.
Source Data: Tape Is from Cleveland County. Aerial Imagery NCCGIA (2015). Force Main Sewer Upgrades
Easement is from City of Shelby.
0 250 500 1,000
F Feet
N
N
1T
Stream & Wetland Delineation Map
Delineated January 25, 2017
Figure 7

New �Alater Main Edi-tensbn &,, Gas Une
Sheet 1
Cleveland County,
North Carolina
0 1,000 2,000 4,000
till
Feet
N
ij
till
ii
Sheet 3
Sheet 4
CLearater Stream & Wetland Delineation Map
32 Clayton Street Delineated January 16, 2017
Asheville, North Carolina 28801 Figure 8
Jurisdictional wetlands and waters identified on this map have been located within sub -meter
accuracy utilizing a Trimble mapping grade Global Positioning System (GPS) and the
subsequent differential correction of that data. GPS points may demonstrate uncorrectable
enors due to topography, vegetative cover, and/or multipalh signal error.
1�J
NOW The illustrated wetland and stream locations are approximate. These areas have been _
flagged in the field; however, they have not been surveyed. Although Clearwater
Environmental Consultants, Inc. (CEC) is confident in our assessment, the US Any Corps of --
Engineers (Corps) is the only agency that can make final decisions regarding jurisdictional
wegand and waters of the US delineations. Therefore, all preliminary delemninations are .
subject to change until written verification is obtained. CEC strongly recommends that written
S beet
verification be obtained from the Corps prior to closing on the property, beginning any site
- -��
work, or making any legal reliance on this determination.
This map was prepared by CEC using the best information available to CEC at the time of
production. This map is for informational purposes only and should not be used to determine
precise boundaries, roadways, property boundary lines, nor legal descriptions. This map
shall not be construed to be an official survey of any data depicted.
Source Data: Topa is from Cleveland County, NCCGIAAerial Imagery (2015). New Water
Main Extension 8 Gas Line Easement is from City of Shelby.
0 1,000 2,000 4,000
till
Feet
N
ij
till
ii
Sheet 3
Sheet 4
CLearater Stream & Wetland Delineation Map
32 Clayton Street Delineated January 16, 2017
Asheville, North Carolina 28801 Figure 8

New Water NAah Exftensbn 8, Gas done
.: , , t � , , , , iso • �—� I ! /I
Jwithin sub -meter accuracy
urisdictional
naTrimblwetlands waters identified
Trimble mapping grade Global on this Positioning a
PositioningSystem (GPS) anddthe subsequent differential
9locate
correction of that data. GPS points may demonstrate uncorrectable errors due to topography, vegetative 1
cover, and/or mullipath signal error.
I
stream locations area approximate. These areas have been flagged in the -
Note: The illustrated wetland str pp 99
field; however, they have not been surveyed. Although Clearwater Environmental Consultants, Inc. (CEC) is
confident in our assessment, the US Army Corps of Engineers (Corps) is the only agency that can make
final decisions regarding jurisdictional wetland and waters of the US delineations. Therefore, all preliminary
determinations are subject to change until written verification is obtained. CEC strongly recommends that
written verification be obtained from the Corps prior to closing on the property, beginning any site work, or
making any legal reliance on this determination.
This map was prepared by CEC using the best information available to CEC at the time of production. This
map Is for informational purposes only and should not be used to determine precise boundaries, roadways
property boundary lines, nor legal descriptions. This map shall not he construed to be an official survey of
any data depicted
SourceData Topa is from Cleveland County. Aerial Imagery NCGGIA (2015). New Water Main Extension 8
Gas Line Easement are from the City of Shelby.
A
J
Potcntially Jurisdielior INVater - �►.. _ �;,. - F\ _. r y _
Wetland (AC) Stream (LF)
-
Wl 0.001 Sl 44
W2 0.02 S2 70
W3 0.001 S3 56
W4 0.01 S4 12
S5 41
S6 145
S7 46
S8 43
/-
S9 58 � -
S10 40
sl1 22-
S12 32
S13 31
S14 5
S15 32
Total 0.032 Tota) 677
Legend
Stream
Contours
y�New Water Main Extension & Gas Line Easement (30 FT ROW)
r\atl 1 y\ 3!17; CEq Prol-g-c-T-890 -'V;+� r.
Cleveland County,
North Carolina
,\ , --------------
I - —
CLearWaLer
32 Clayton Street
Asheville, North Carolina 28801
v - N
0 250 500 1,000 _
Stream & Wetland
Delineation Map
Delineated January 16, 2017
Figure 8, Sheet 1

New Water jMaa n Extensibn 8v. Gas Une
Potentially Juris dicti
Wetland (AQ Stre;
W I 0.001 S 1
W3 0.001
W4 0.01
S3
S4
S5
S6
S7
SS
S9
Sir
Sit
S12
S13
41k,41k,
Water
44
70
56
12
41
145
46
43
40
22
32
31
5
32
'Coral 0.032 I 1 mal 677
Legend
h
Jurisdictional wetlands and waters identified on this map have been located within sub -meter accuracy
�l I utilizing a Trimble mapping grade Global Positioning System (GPS) and the subsequent differential _
correction of that data. GPS points may demonstrate uncorrectable errors due to topography, vegetative
cover, and/or multipath signal error.
Y
r Note: The illustrated wetland and stream locations are approximate. These areas have been gagged in the J
field Id' h th h t b n surved Althou h ClearWaler Environmental Consultants Inc (CEC) is
1
/
A owever, ey he no eeye . g 1 .
confident in our assessment, the US Army Corps of Engineers (Corps) is the only agency that can make
/ finaldecisions regarding jurisdictional wetland and waters of the US delineations. Therefore, all preliminary -
determinations are subject to change until written verification is obtained. CEC strongly recommends that
written verification be obtained from the Corps prior to closing on the property, beginning any site work, or
making any legal reliance on this determination.
1l`I This map was prepared by CEC using the best information available to CEC at the time of production. This
n n and should not be used to determine precise boundaries roadways,
map is for informational purposes only p y ,
property boundary lines, nor legal descriptions. This map shall not be construed to be an official survey of
any data depicted.
Source Data: Topo is from Cleveland County. Aerial Imagery NCGGIA (2015). New Water Main Extension &
Gas line Easement are from the City of Shelby.
� ( I
` \ — / 0 250 500 1,000
Feet
N
Stream
Contours
New Water Main Extension & Gas Line Easement (30 FT ROW)
Cleveland County, CLearWaEer Stream & Wetland
Delineation Map
North CarolinaDelineated January 16, 2017
32 Clayton Street �'
Asheville, North Carolina 28801 Figure 8, Sheet 2

i ))l
0 78
LO
0 Q
04
� �\\ • �,\\��\��� �- 1. _ �/� �����`�� --_-
00
00
ai
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\,
LL
R EVE
Vd~ in
�
y
�/ \\\�� •-tet//� �� ,/ ��\\�\ *\`;� � `�\\` oy v o Fc ¢ c � c � u v � u C7 U �.
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A N_ V
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C7 rI y 7 O �O N �O M 00 O N N N r n O a c v a Eo v y o- € o S 9 U C
Ctl V l� Vl d' 7 7 V'f 7 N M M M r 5U' U' E c o c E 3 c ._a_ 1p Q v O O
c a v ov C CO
oo3c �vc'3yNem anc >' �E N �l
ms`m "mo-nN t ao� o� x �+ Cd
5
o a o U m
COIL �T�>Cy O.� OIC T R W
r- 00 ON ."-r .N. M.. �-+ .�. a n- m 5 w - `o .N o 2 C g O O
\\ '.\�'.. U ♦+ V] V] V] V] V] V] (� @ E > Ig c Uma U v 0 € > E 2 �1`. U
!n o v N v
.� •L as v O
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U c u U m
N m~ 7i3 '9Log vv L'nov yN
M o -
a v
7a O O O n10E�(7 yam;, 7-I
O O O n�Ido m�omdvnm m° om O i.
mc o�
no"cmw �c /�/���
\ !/`--•_ / F i:�oo =S AUac a's ml -O2
c ..r q o m 3 o m
ova
Z
�.�,C a 2 c . 12
3 N N N C W W 3 y> 3 r 6 n C N ❑
v

New Water Ma'M Exdensbn & Gas done
Jurisdictional wetlands and waters identified on this map have been located within sub -meter accuracy
utilizing a Trimble mapping grade Global Positioning System (GPS) and the subsequent differenfial
correction of that data. GPS points may demonstrate uncorrectable errors due to topography, vegetative
cover, and/or multipath signal error.
11 t
— —�/Note: The Illustrated wetland and stream locations are approximate. These areas have been flagged in the
I ` i ` • `�� II`II - _ moi/ \\�`�� field; however, they have not been surveyed. Although Clearwater Environmental Consultants, Inc. (CEC) is
confident in our assessment, the US Army Corps of Engineers (Corps) is the only agency that can make
final decisions regarding jurisdictional wetland and waters of the US delineations. Therefore, all preliminary
determinations are subject to change unfit written verification is obtained. CEC strongly recommends that
written verification be obtained from the Corps prior to closing on the property, beginning any site work, or
making any legal reliance on this determination. /
This map was prepared by CEC using the best information available to CEC at the time of production. This
map is for Informational purposes only and should not be used to determine precise boundaries, roadways,
propa bounds lines, nor legal descriptions. This map shall not be construed to be an official survey of
any data at boundary a tlepictetl.
1 Source Data: Too is from Cleveland County. Aerial Imagery NCGGIA (2815). New Water Water Main
\ 1 1 I i� Extension & Gas Line Easement are from the City of Shelby.
0 250 500 1,000
Feet
-
PolenliallyJunsncchonal AVldcr�-
Wetland AC Stream r
W 1 0.001 SI 41
W2 0.02 S2 70
W3 0.001S3 56
W4 0.01 S4 12 �.*•� 1 �., \ _ - _ _—_ _ . iii..-
SS 41 i
S6 145 -,�
1L \II - ��-
S7 46
SS 43
58
sio 40
S13 31
S14 5
(f l
S15 32
1,
Erol.1O032 Total 677
Legend
Stream\�
Contours
New Water Main Extension & Gas Line Easement (30 FT ROW)
Drawn byKAY 123. 7; Projec 890
Cleveland County, JI -el
tY_ak�� Stream &Wetland
, Delineation Map
North Carolina _ Delineated Janus 16 2017
32 Clayton Street January
Asheville, North Carolina 28801 Figure 8, Sheet 4

Attachment B
2012 Authorized Impacts (SAW Action ID 2010-00061
(dated March 18, 2010)

"
Impact #1
53 LF
0�earwater Paper Expansion (+/- 100 AC)
Impact t#2(
0.01 AC f
Proiecl Summary
Total Project Area
Jurisdictional Waters of the US
Streams
Wetlands
Open Water
Jurisdictional Impacts
Streams
Wetlands
Open Water
Avoidance/Minimization
Streams
Wetlands
Open Water
Cumulative Impacts
Streams
Wetlands
Open Water
Mitigation
Streams (EEP)
+/- 100 acres
i{ -- Proposed Warehouse
Impact#5 rr
125 LF L
Proposed Expansion
Impact #7 Impact #8
0.01 AC
0.02
(two wetlands)
w
/ \Ext t5 ni gTa`clt / - \ LYlmpact#9
(Permitted and
Constructed)
5,639 linear feetf
' '
J+l - sF" ��� ',- it�,� `
0.05 acres
0 acres
_
Legend
1,8821inear feet
0.04 acres
0 acres
Existing Culvert Proposed Culvert Around Expansion
3,757 linear feet
0.01 acres
Stream Proposed Expansion
0 acres
r _
11
- Wetland Proposed Contours
1,986 linear feet
0.13 acres
•;
,
I I Existing Building Clearwater Paper Property
�J
'
0 acres
Existing Road and Parking e o Cleveland County Property
1,986 linear feet
— Existing Rail Spur
�iect# 6jfi
leering
I 1 I I I I
1 i. f I 1
-"
— �, � � -- �,,, �
� � I t �, �
Cleveland County,
North Carolina
CLe rV//Vater
224 South Grove Street, Suite F
Hendersonville, North Carolina 28792
�r
0 250 500 1,000
Feet
Site Plan
Burton Engineering
Figure 3A

0 500 1,000 2,000
Feet
Clearwater Paper Expansion (+/- 100 AC
�/�l
atb
i Proposed
SW Eesin
L � e86 rl
- — 15U -
_C
-� e d
Vuen _
Impel tlR S �
1 ✓' - - ._ __ 0.01 Ac
1
Inch = 100 fee
0 50100 200
® Feet
k",,
Cleveland County,
North Carolina
o99nc
.lPemmeaem
I I
Proposed WarehoLse
\ `
V � A
- _ Imp aNS
jam.
1125U
224 South Grove Street, Suite F
Hendersonville, North Carolina 28792
0 50100 200
- Feet
ImIxa NO -M nPll=100
as
1.1antes.ae0menm essosetetl--
xiNeape
pinpolied EMP,attsion" -- -
losses"
002
ea.ellenh) — \i
• �' -moi' `r �
Y
Pm M Sarananew
Tend! Protect A.
q-INLeri
lttmdiaianal Waters of Ne US
Stv=m=
5,6391inearfeat
We^ends
U05acrc
Op Water
a..
Jurisdiaionellmpaas
SlreLns
19821inearfea
We .&
004.oes
Op Water
Oacres
Cumulative Impacts
sie.
1,986 It.. feel
Wetlands
0.13 acres
Open Water
0..
A,cmdart.H nimrsatlan
Streams
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CEC Project# 616
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Attachment C
NC Stream Assessment Forms

7771 npv _ �, ��,°rr-��r l•� �-p,q,., }, oti

NC SAM FIELD ASSESSMENT RESULTS
user manual version L. i
I USACE AID* NCDWR M I
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic
quadrangle, and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property,
identify and number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for
detailed descriptions and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were
performed. See the NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION
1. Project name (if any): Washburn Switch Tract 2. Date of evaluation: 12-13-16
3. Applicant/owner name: Clearwater Paper 4. Assessor name/organization: R. Reid, K. Yankura
5. County: Cleveland 6. Nearest named water body
7. River basin: Broad on USGS 7.5 -minute quad: Brushy Creek
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.319772, -81.596983
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): #1 10. Length of assessment reach evaluated (feet): 50
11. Channel depth from bed (in riffle, if present) to lop of bank (feel): 1-3 ❑Unable to assess channel dep
12. Channel width at lop of bank (feet): 5 13. Is assessment reach a swamp steam? ❑Yes []No
14. Feature type: ❑Perennial flow ®Intermittent Flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) N Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic EIA \1 V J NB�
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip NSize 1 (< 0.1 mi') ❑Size 2 (0.1 to < 0.5 mi') ❑Size 3 (0.5 to < 5 mi') []Size 4 (2 5 mi')
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? NYes []No If Yes, check all that apply to the assessment area.
❑Section 10 water []Classified Trout Waters ❑Water Supply Watershed (❑I ❑II ❑III ❑IV ❑V)
[]Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule In effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
[]Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in 'Notes/Sketch" section or attached? []Yes NNo
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
❑B No flow, water in pools only.
NC No water in assessment reach.
2. Evidence of Flow Restriction -assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
NB Not
3. Feature Pattern - assessment reach metric
NA A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
❑B Not A
4. Feature Longitudinal Profile - assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming,
over widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of
these disturbances).
NB Not A
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
❑B 10 to 25% of channel unstable
NC > 25% of channel unstable

6. Streamside Area Interaction – streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
❑A ❑A Little or no evidence of conditions that adversely affect reference interaction
EB EB Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area,
leaky or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C Extensive evidence of conditions that adversely affect reference interaction (little to no Floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision,
disruption of flood flows through streamside area] or loo much floodplain/intertidal zone access [examples:
impoundments, intensive mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a
man-made feature on an interstream divide
7. Water Quality Stressors – assessment reachlinterticial zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
❑1 Other: (explain in "Notes/Sketch" section)
EJ Little to no stressors
8. Recent Weather – watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a
drought.
EA Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
❑C No drought conditions
9. Large or Dangerous Stream – assessment reach metric
❑Yes ENo Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types–assessment reach metric
10a. ❑Yes ENo Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
t Ob.
Check all that occur (occurs If > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A
Multiple aquatic macrophyles and aquatic mosses❑F
5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) F E
❑G Submerged aquatic vegetation
EB
Multiple sticks and/or leaf packs and/or emergent g 9
❑H Low -tide refugia (pools)
[]C
vegetation t
Multiple snags and logs (including lap trees) v
❑I Sand bottom
❑J 5% vertical bank along the marsh
❑D
5% undercut banks and/or root mals and/or roots "
❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E
Little or no habitat
•»»""'«""""•'••"'•"'•*'*"REMAINING
QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS**"---*—*"*-**
11. Bedform and
Substrate –assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a.
[]Yes
ENo Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b.
Bedform evaluated. Check the appropriate box(es).
EA
Riffle -run section (evaluate 11 c)
❑B
Pool -glide section (evaluate 11 d)
❑C
Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c.
In riffle
sections, check all that occur below the normal wetted perimeter of the assessment reach – whether or not submerged.
Check at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) _
absent,
Rare (R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative
percentages should not exceed 100% for each assessment reach.
NP
R C A P
E
❑ ❑ ❑ ❑ Bedrock/saprolite
E
❑ ❑ ❑ ❑ Boulder (256 – 4096 mm)
E
❑ ❑ ❑ ❑ Cobble (64 – 256 mm)
❑
❑ E ❑ ❑ Gravel (2 – 64 mm)
❑
❑ E ❑ ❑ Sand (.062 – 2 mm)
❑
❑ E ❑ ❑ Silt/clay (< 0.062 mm)
❑
❑ E ❑ ❑ Detritus
E
❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d.
❑Yes
[]No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12. Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes []No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ []Beetles
❑ ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/sh(mp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
® ❑Megaloptera (alderfly, fishfly, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Otherfish
❑ ❑Salamanders/tadpoles
❑ []Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland
runoff.
LB RB
❑A ❑A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑S Moderate alteration to water storage capacity over a majority of the streamside area
❑C ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil
compaction, livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water t 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
❑C ❑C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
ON ON
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
❑E Stream bed or bank soil reduced (dig through deposited sediment if present)
OF None of the above
17. Baseflow Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (Z 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
OF None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width— streamside area metric (skip for Tidal Marsh Streams)
Consider "vegetated buffer' and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
RA RA RA ❑A ? 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B RB From 50 to < 100 feel wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RS) for Metric 19 ("Vegetated" Buffer Width).
LB RB
RA RA Mature forest
❑B ❑B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but
is within 30 feet of stream (< 30 feet),, or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on dither bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded' Buffer Width).
LB RS
RA RA Medium to high stem density
❑B ❑B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
RA RA The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feel of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
RB RB Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. []Yes RNo Was conductivity measurement recorded?
If No, select one of the following reasons. ❑No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E z 230
Notes/Sketch:

Draft NC SAM Stream Rating Sheet
Accompanies User Manual Version 2.1
Stream Site Name Washburn Switch Tract
Stream Category Pbl
Date of Assessment 12-13-16
Assessor Name/Organization R. Reid, K. Yankura
Notes of Field Assessment Form (Y/N) NO
Presence of regulatory considerations (Y/N) NO
Additional stream information/supplementary measurements included (Y/N) NO
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) NO
USACE/
NCDWR
Function Class Rating Summary
All Streams
Intermittent
(1) Hydrology
LOW
LOW
(2) Baseflow
HIGH
HIGH
(2) Flood Flow
LOW
LOW
(3) Streamside Area Attenuation
MEDIUM
MEDIUM
(4) Floodplain Access
MEDIUM
MEDIUM
(4) Wooded Riparian Buffer
HIGH
HIGH
(4) Microtopography
NA
NA
(3) Stream Stability
LOW
LOW
(4) Channel Stability
LOW
LOW
(4) Sediment Transport
MEDIUM
MEDIUM
(4) Stream Geomorphology
MEDIUM
MEDIUM
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
HIGH
HIGH
(2) Baseflow
HIGH
HIGH
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Indicators of Stressors
NO
NO
(2) Aquatic Life Tolerance
MEDIUM
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
MEDIUM
HIGH
(2) In -stream Habitat
LOW
MEDIUM
(3) Baseflow
HIGH
HIGH
(3) Substrate
MEDIUM
MEDIUM
(3) Stream Stability
LOW
LOW
(3) In -stream Habitat
LOW
HIGH
(2) Stream -side Habitat
HIGH
HIGH
(3) Stream -side Habitat
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
MEDIUM
HIGH

NC SAM FIELD ASSESSMENT RESULTS
user manuar velo,vu z. r
USACE AID #: NL UVw( H:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic
quadrangle, and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property,
identify and number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for
detailed descriptions and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were
performed. See the NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECTISITE INFORMATION:
1. Project name (if any): Washburn Switch Tract 2. Date of evaluation: 12-13-16
3. Applicantlowner name: Clearwater Paper 4. Assessor name/organization: R. Reid, K. Yankura
5. County: Cleveland 6. Nearest named water body
7. River basin: Broad on USGS 7.5 -minute quad: Brushy Creek
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.320195, -81.596427
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): #2 10. Length of assessment reach evaluated (feet): 100
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 1-2 ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 2-4 13. Is assessment eawamp steam? ❑Yes []No
14. Feature type: ®Perennial flow ❑Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A\ �� ®B\\
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip
®Size 1 (< 0.1 mi') ❑Size 2 (0.1 to < 0.5 mi') ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (a 5 mi')
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ONO If Yes, check all that apply to the assessment area.
❑Section 10 water
❑Classified Trout Waters ❑Water Supply Watershed (❑I oil []III [:]IV ❑V)
❑Essential Fish Habitat
❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
[]Publicly owned property
❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters .
❑Anadromous fish
❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of
a federal and/or state listed protected species within the assessment area.
List species:
[]Designated Critical Habitat (list species)
19. Are additional stream information/supplemr
1. Channel Water- assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
®A Water throughout assessment reach.
❑B No flow, water in pools only.
❑C No water in assessment reach.
or
2. Evidence of Flow Restriction -assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern - assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not A
4. Feature Longitudinal Profile - assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming,
over widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of
these disturbances).
®B Not A
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
®B 10 to 25% of channel unstable
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
NA NA Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area,
leaky or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision,
disruption of flood flows through streamside area] or too much floodplain/intertidal zone access [examples:
impoundments, intensive mosquito ditching]) or Floodplain/intertidal zone unnaturally absent or assessment reach isa
man-made feature on an interstream divide
7. Water Quality Stressors — assessment reachlintertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
❑I Other: (explain in "Notes/Sketch" section)
Ed Little to no stressors
8. Recent Weather—watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a
drought.
NA Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
❑C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
[-]Yes ENo is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. [-]Yes NNo Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
1 Ob. Check all that occur (occurs 'rf > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses _ ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) E ❑G Submerged aquatic vegetation
NB Multiple sticks and/or leaf packs and/or emergent m ❑H Low -tide refugia (pools)
vegetation t ❑I Sand bottom
EC Multiple snags and logs (including lap trees) t ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots u ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS"****'"""'*"*'**'*
11. Bedform and Substrate — assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ENo Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
NA Riffle -run section (evaluate 11 c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged.
Check at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) _
absent, Rare (R) = present but < 10%, Common (C) _ > 1040%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative
percentages should not exceed 100% for each assessment reach.
NP R C A P
E ❑ ❑ ❑ ❑ Bedrock/saprolite
N ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
N ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ N ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ N ❑ ❑ Sand (.062 — 2 mm)
❑ ❑ N ❑ ❑ Silt/clay (< 0.062 mm)
❑ ❑ N ❑ ❑ Detritus
N ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12. Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes [:]No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water []Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ []Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ NCaddisfly larvae (T)
❑ []Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
N ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Olherfish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
N ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland
runoff.
LB RB
❑A ❑A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
❑C ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil
compaction, livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water z 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
❑C ❑C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y NY Are wetlands present in the streamside area?
ON ❑N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
NA Streams and/or springs Qurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
ND Evidence of bank seepage or sweating (iron in water indicates seepage)
NE Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Baseflow Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (2 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
OF None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
NA Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams)
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 5010 < 100 feet wide
❑C ❑C ❑C ❑c From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ('Vegetated" Buffer Width).
LB RB
®A ®A Mature forest
❑B ❑B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but
is within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressorsoccurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
®A ®A Medium to high stem density
❑B ❑B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
EIA ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity— assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. []No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E 2 230

Draft NC SAM Stream Rating Sheet
Accompanies User Manual Version 2.1
Stream Site Name Washburn Switch Tract Date of Assessment 12-13-16
Stream Category Pbl Assessor Name/Organization R. Reid, K. Yankura
Notes of Field Assessment Form (YIN) NO
Presence of regulatory considerations (YIN) NO
Additional stream information/supplementary measurements included (YIN) NO
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Perennial
USACE/ NCDWR
I Streams Intermittent
(1) Hydrology
HIGH
(2) Baseflow
HIGH
(2) Flood Flow
HIGH
(3) Streamside Area Attenuation
HIGH
(4) Floodplain Access
HIGH
(4) Wooded Riparian Buffer
HIGH
(4) Microtopography
NA
(3) Stream Stability
MEDIUM
(4) Channel Stability
MEDIUM
(4) Sediment Transport
MEDIUM
(4) Stream Geomorphology
HIGH
(2) Stream/Intertidal Zone Interaction
NA
(2) Longitudinal Tidal Flow
NA
(2) Tidal Marsh Stream Stability
NA
(3) Tidal Marsh Channel Stability
NA
(3) Tidal Marsh Stream Geomorphology
NA
(1) Water Quality
HIGH
(2) Baseflow
HIGH
(2) Streamside Area Vegetation
HIGH
(3) Upland Pollutant Filtration
HIGH
(3) Thermoregulation
HIGH
(2) Indicators of Stressors
NO
(2) Aquatic Life Tolerance
HIGH
(2) Intertidal Zone Filtration
NA
(1) Habitat
HIGH
(2) In -stream Habitat
MEDIUM
(3) Baseflow
HIGH
(3) Substrate
MEDIUM
(3) Stream Stability
MEDIUM
(3) In -stream Habitat
MEDIUM
(2) Stream -side Habitat
HIGH
(3) Stream -side Habitat
HIGH
(3) Thermoregulation
HIGH
(2) Tidal Marsh In -stream Habitat
NA
(3) Flow Restriction
NA
(3) Tidal Marsh Stream Stability
NA
(4) Tidal Marsh Channel Stability
NA
(4) Tidal Marsh Stream Geomorphology
NA
(3) Tidal Marsh In -stream Habitat
NA
(2) Intertidal Zone
NA
Overall
HIGH

NC SAM FIELD ASSESSMENT RESULTS
user manual versruu . 1
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic
quadrangle, and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property,
identify and number all reaches on the attached map, and include a separate for for each reach. See the NC SAM User Manual for
detailed descriptions and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were
performed. See the NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECTISITE INFORMATION:
1. Project name (if any): Washburn Switch Tract 2. Dale of evaluation: 12-13-16
3. Applicant/owner name: Clearwater Paper 4. Assessor name/organization: R. Reid, K. Yankura
5. County: Cleveland 6. Nearest named water body
7. River basin: Broad on USGS 7.5 -minute quad: Brushy Creek
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.319863, -81.604065
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): #4 10. Length of assessment reach evaluated (feet): 100
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 3-6 ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 6-8 13. Is assessment reacwamp steam? []Yes ❑No
14. Feature type: ®Perennial flow ❑Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) N Piedmont (P) ❑ Inner Coastal Plain (I) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic OA \1 ®B�
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip []Size 1 (< 0.1 mi') ®Size 2 (0.1 to < 0.5 miz) ❑Size 3 (0.5 to < 5 mit) []Size 4 (a 5 mi')
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters []Water Supply Watershed (❑I ❑f [-]III []IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish 0303(d) List ❑CANIA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ❑Yes NNo
1. Channel Water- assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
NA Water throughout assessment reach.
❑B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
NB Not A
3. Feature Pattern - assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
NB Not A
4. Feature Longitudinal Profile -assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming,
over widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of
these disturbances).
NB Not A
S. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
NB 10 to 25% of channel unstable -
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
❑A ❑A Little or no evidence of conditions that adversely affect reference interaction
®B ®B Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area,
leaky or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with Floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision,
disruption of flood flows through streamside area] or too much floodplain/intertidal zone access [examples:
impoundments, intensive mosquito ditching]) or floodplainlintertidal zone unnaturally absent or assessment reach is a
man-made feature on an interstream divide
7. Water Quality Stressors — assessment reachlinterticial zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
01 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a
drought.
RA Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
❑C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses J_ [IF 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) F E ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent 6 N ❑H Low -tide refugia (pools)
vegetation ❑I Sand bottom
❑C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
®D 5% undercut banks and/or root mats and/or roots 02 ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*****"******"'"'***'***"****'**REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****'""*"*'*'*'***
11. Bedform and Substrate— assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Sedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11 c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged.
Check at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) _
absent, Rare (R) = present but < 10%, Common (C) _ > 1040%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative
percentages should not exceed 100% for each assessment reach.
NP R C A P
to ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
❑ ® ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ® ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ❑ ® ❑ ❑ SilVclay (< 0.062 mm)
❑ ❑ ® ❑ ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12. Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the user Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water ❑Other:
12b. ®Yes ONO Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ []Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ®Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ []Crustacean (isopodlamphipod/crayfish/shrimp)
® ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ®Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, flshfly, dobsonfly larvae)
❑ ❑Midgeslmosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland
runoff.
LB RB
❑A ❑A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
❑C ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil
compaction, livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water 2 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
❑C ❑C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
NO Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Baseflow Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (�! 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
®F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on' condition.
NA Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees) .
❑C Stream shading is gone or largely absent

19. Buffer Width - streamside area metric (skip for Tidal Marsh Streams)
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
NA NA NA NA >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D El ❑D n From 10 to < 30 feet wide
❑E❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure -streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
NA NA Mature forest
❑B ❑B Non-mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors - streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but
is within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs odelther bank, check fibre and skip to Metric 22: X
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density - streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
NA NA Medium to high stem density
❑B ❑B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer - streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
NA NA The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition - streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
NB NB Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
EIC []C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity - assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes NNo Was conductivity measurement recorded?
If No, select one of the following reasons. [-]No Water []Other:
251b, Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >- 230
Notes/Sketch:

Draft NC SAM Stream Rating Sheet
Accompanies User Manual Version 2.1
Stream Site Name Washburn Switch Tract
Stream Category Pb2
Date of Assessment 12-13-16
Assessor Name/Organization R. Reid, K. Yankura
Notes of Field Assessment Form (Y/N) NO
Presence of regulatory considerations (Y/N) NO
Additional stream information/supplementary measurements included (Y/N) NO
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Perennial
Function Class Rating Summary
USACE/ NCDWR
All Streams Intermittent
(1) Hydrology
MEDIUM
(2) Baseflow
HIGH
(2) Flood Flow
MEDIUM
(3) Streamside Area Attenuation
MEDIUM
(4) Floodplain Access
MEDIUM
(4) Wooded Riparian Buffer
HIGH
(4) Microtopography
NA
(3) Stream Stability
MEDIUM
(4) Channel Stability
MEDIUM
(4) Sediment Transport
LOW
(4) Stream Geomorphology
HIGH
(2) Stream/Intertidal Zone Interaction
NA
(2) Longitudinal Tidal Flow
NA
(2) Tidal Marsh Stream Stability
NA
(3) Tidal Marsh Channel Stability
NA
(3) Tidal Marsh Stream Geomorphology
NA
(1) Water Quality
HIGH
(2) Baseflow
HIGH
(2) Streamside Area Vegetation
HIGH
(3) Upland Pollutant Filtration
HIGH
(3) Thermoregulation
HIGH
(2) Indicators of Stressors
NO
(2) Aquatic Life Tolerance
HIGH
(2) Intertidal Zone Filtration
NA
(1) Habitat
LOW
(2) In -stream Habitat
LOW
(3) Baseflow
HIGH
(3) Substrate
LOW
(3) Stream Stability
MEDIUM
(3) In -stream Habitat
MEDIUM
(2) Stream -side Habitat
HIGH
(3) Stream -side Habitat
HIGH
(3) Thermoregulation
HIGH
(2) Tidal Marsh In -stream Habitat
NA
(3) Flow Restriction
NA
(3) Tidal Marsh Stream Stability
NA
(4) Tidal Marsh Channel Stability
NA�
(4) Tidal Marsh Stream Geomorphology
NA
(3) Tidal Marsh In -stream Habitat
NA
(2) Intertidal Zone
NA
Overall
MEDIUM

NC SAM FIELD ASSESSMENT RESULTS
user manual verslv,, ..
USAGE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic
quadrangle, and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property,
identify and number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for
detailed descriptions and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were
performed. See the NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECTISITE INFORMATION:
1. Project name (if any): Washburn Switch Tract 2. Date of evaluation: 12-13-16
3. Applicant/owner name: Clearwater Paper 4. Assessor name/organization: R. Reid, K. Yankura
5. County: Cleveland 6. Nearest named water body
7. River basin: Broad on USGS 7.5 -minute quad: Brushy Creek
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.321714, -81.604260
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): #5 10. Length of assessment reach evaluated (feet): 100
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 4 ❑Unable to assess channel depth.
12. Channel width at top of bank (feel): 8 13. Is assessment reach a swamp steam? []Yes ❑No
14. Feature type: ®Perennial flow ❑Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
"i
16. Estimated geomorphic ❑A� ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ❑Size 1 (< 0.1 mi') ®Size 2 (0.1 to < 0.5 mi') []Size 3 (0.5 to < 5 mi) []Size 4 (? 5 mi')
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ❑Water Supply Watershed (❑I ❑f ❑III ❑IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
1. Channel Water — assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
®A Water throughout assessment reach.
❑B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction — assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not A
3. Feature Pattern — assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not A
4. Feature Longitudinal Profile — assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming,
over widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of
these disturbances).
®B NotA
5. Signs of Active Instability — assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
❑B 10 to 25% of channel unstable
®C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
❑A ❑A Little or no evidence of conditions that adversely affect reference interaction
NB NB Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area,
leaky or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision,
disruption of flood flows through streamside area] or too much floodplainlintertidal zone access [examples:
impoundments, intensive mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a
man-made feature on an inlerstream divide
7. Water Quality Stressors — assessment reachlintertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑e Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch'
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
Of Other: (explain in "Notes/Sketch" section)
NJ Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought. or higher is considered a
drought.
NA Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑e Drought conditions and rainfall exceeding 1 inch within the last 48 hours
❑C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes NNo Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types —assessment reach metric
10a. ❑Yes NNo Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
1 Ob. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats)F E ❑G Submerged aquatic vegetation
NB Multiple sticks and/or leaf packs and/or emergent 8.% OH Low -tide refugia (pools)
vegetation t ❑I Sand bottom
❑C Multiple snags and logs (including lap trees) I ❑J 5% vertical bank along the marsh
ND 5% undercut banks and/or root mats and/or roots 0 ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
****"*""'"'***"***"**'**"*REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS*'**"'*""*—'—'*'--.
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes NNo Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11b. Bedform evaluated. Check the appropriate box(es).
NA Riffle -run section (evaluate 11 c)
❑S Pool -glide section (evaluate 11d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged.
Check at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) _
absent, Rare (R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative
percentages should not exceed 100% for each assessment reach.
NP R C A P
N ❑ ❑ ❑ ❑ Bedrock/saprolite
N ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
❑ N ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ N ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ N ❑ Sand (.062 — 2 mm)
❑ ❑ N ❑ ❑ Silt/clay (< 0.062 mm)
❑ ❑ N ❑ ❑ Detritus
N ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12. Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ®Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ®Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishfiy, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
® ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
® ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland
runoff.
LB RB
❑A ❑A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
❑C ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil
compaction, livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond waters 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
❑C ❑C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
ON ON
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
FIC Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
ND Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
OF None of the above
17. Baseflow Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (z 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
OF None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams)
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
NA NA ❑A NA z 100 feet wide or extends to the edge of the watershed
❑S ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C NC ❑C From 30 to < 50 feel wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure - streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A NA Mature forest
NB ❑e Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but
is within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressorsoccurson either bahk, check here and "skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
NA NA Medium to high stem density
❑B ❑B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer —streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
NA NA The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A NA Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
NB ❑B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes NNo Was conductivity measurement recorded?
If No, select one of the following reasons. ❑No Water []Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E z 230

Draft NC SAM Stream Rating Sheet
Accompanies User Manual Version 2.1
Stream Site Name Washburn Switch Tract
Stream Category Pb2
Date of Assessment 12-13-16
Assessor Name/Organization R. Reid, K. Yankura
Notes of Field Assessment Form (Y/N) NO
Presence of regulatory considerations (Y/N) NO
Additional stream information/supplementary measurements included (Y/N) NO
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Perennial
USACEI NCDWR
Function Class Rating Summary
An oxreams unvouIuou•
(1) Hydrology
LOW
(2) Baseflow
HIGH
(2) Flood Flow
LOW
(3) Streamside Area Attenuation
MEDIUM
(4) Floodplain Access
MEDIUM
(4) Wooded Riparian Buffer
HIGH
(4) Microtopography
NA
(3) Stream Stability
LOW
(4) Channel Stability
LOW
(4) Sediment Transport
LOW
(4) Stream Geomorphology
HIGH
(2) Stream/Intertidal Zone Interaction
NA
(2) Longitudinal Tidal Flow
NA
(2) Tidal Marsh Stream Stability
NA
(3) Tidal Marsh Channel Stability
NA
(3) Tidal Marsh Stream Geomorphology
NA
(1) Water Quality
HIGH
(2) Baseflow
HIGH
(2) Streamside Area Vegetation
HIGH
(3) Upland Pollutant Filtration
HIGH
(3) Thermoregulation
HIGH
(2)Indicators of Stressors
NO
(2) Aquatic Life Tolerance
HIGH
(2) Intertidal Zone Filtration
NA
(1) Habitat
LOW
(2) In -stream Habitat
LOW
(3) Baseflow
HIGH
(3) Substrate
LOW
(3) Stream Stability
LOW
(3) In -stream Habitat
MEDIUM
(2) Stream -side Habitat
HIGH
(3) Stream -side Habitat
HIGH
(3) Thermoregulation
HIGH
(2) Tidal Marsh In -stream Habitat
NA _
(3) Flow Restriction
NA
(3) Tidal Marsh Stream Stability
NA
(4) Tidal Marsh Channel Stability
NA
(4) Tidal Marsh Stream Geomorphology
NA
(3) Tidal Marsh In -stream Habitat
NA
(2) Intertidal Zone
NA
Overall
LOW

Attachment D
Threatened and Endangered Species Reports
and
USFWS Correspondence

Threatened and Endangered Species
Assessment for Washburn Switch Road Business Park
Cleveland County, North Carolina
November 3, 2011
Prepared for:
Cleveland County Government
Mr. David Dear
Post Office Box 1210
Shelby, North Carolina 28151
Prepared By:
Clearwater Environmental Consultants, Inc.
224 South Grove Street
Hendersonville, North Carolina 28792
[phone]

1.0 INTRODUCTION
The following report includes methods used and results for a threatened and endangered
species survey and habitat assessment for the approximately 485 -acre project site known as
the Washburn Switch Business Park. The threatened and endangered species survey was
conducted to determine the occurrence of or the potential for existence of federally listed
threatened and endangered animal and plant species on the proposed site. Completion of
this survey was directed by and complies with three current state and federal regulations: the
Federal Endangered Species Act of 1973 (16 USC 1531-1543), the North Carolina
Endangered Species Act (N.C.G.S. Sect. 113 article 25), and the North Carolina Plant
Protection and Conservation Act of 1979 (N.C.G.S. Sect. 19b 106: 202.12-22).
The project site is located east of Washburn Switch Road and a portion of the western site
is bound by an existing CSX railroad track in Cleveland County, North Carolina (Figure
1 and 2). The site also contains an existing Duke Energy transmission right-of-way
(ROW) and is border to the south by the Future Highway 74 Shelby bypass. Latitude
and longitude for the site are 35.31834N and -81.59703W. Site elevations range from
760 feet to 870 feet above mean sea level (MSL).
2.0 METHODOLOGY
CEC has conducted a file review of records maintained by the U.S. Fish and Wildlife
Service (FWS) (July 20, 2011) and North Carolina Natural Heritage Program (June 21,
2011) (NHP). The desktop literature survey involved a review of the FWS list of
protected species in Cleveland County and the Shelby USGS Topo Quad on which NHP
identifies current and historic occurrences of listed species for that locale. There are six
current and/or historic records of occurrences of federally listed threatened species within
the Shelby Quad. A query of the NHP database yielded the following list of threatened
and endangered species within a 2 -mile radius of the project site:
Scientific Name
Common Name
Federal Status
Hexastylis nanii lora
Dwarf -flowered heartleaf
threatened
Hexastylis naniflora is the only federally listed threatened or endangered species listed in
Cleveland County by the FWS and it is also the only threatened or endangered species
within the Shelby Quad. Database search results are included for review (Attachment A).
On November 1, 2011, Ms. Rebekah Newton of Clear -Water Environmental Consultants,
Inc. (CEC) received an email from Mr. Bryan Tompkins of the US Fish and Wildlife
Service (FWS) regarding the proposed project site. Mr. Tompkins indicated that the FWS
has occurrence data for dwarf -flowered heartleaf (Hexastylis naniora) in close proximity to
and within the boundaries of the project site. Additional information obtained from the
NHP identifies occurrence data at the southeastern comer of the property with one
occurrence identifying 157 plant `clumps" in a 0.4 acre area. Additional populations have
also been identified in a 2 -mile radius of the project site (Figure 3).
2

A protected species survey was conducted on July 25 and August 1, 3 and 4, 2011 by CEC
to determine the occurrence of or the potential for existence of federally listed threatened
and endangered animal and plant species, specifically Hexastylis nanii lora, on the proposed
site. During the site survey, CEC searched wooded areas and stream sides for any
Hexastylis species present. Several Hexastyilis plants were observed during this survey
(Figure 3).
3.0 HABITAT CLASSIFICATION
The protected species audit consisted of a pedestrian survey. During field surveys, nine
general habitats were identified and compared with recognized habitats for hexstylis
potentially occurring on the site. Potential flora and fauna were identified to the taxonomic
unit level necessary to determine if the observed specimen was a protected species. Plants
were identified to the lowest taxonomic level readily discernible in the field during the time
of survey.
The following is a description of each of the four habitat types identified on the referenced
site (Figure 3). A soils description is also provided.
3.1 Mixed Age Loblolly Plantations
This is the largest habitat type on site and is dominated by loblolly pine stands of
different age classes The overstory is dominate by loblolly (Pinus taeda) with a
few scattered black cherry's (Prunus serotina) and yellow poplars (Liriodendron
tulipifera). Species observed in the understory include water oak (Quercus
nigra), black walnut (Juglans nigra), yellow poplar, red maple (Acer rubrum),
winged sumac (Rhus coppillinum), black gum (Nyssa sylvatica), willow oak
(Quercus phellos), hickory (Carya sp.), American holly (Ilex opaca), and
dogwood (Cornus ,/lorida). The herb layer is sparse an and species observed
include poison ivy (Toxicodendron radicans), Japanese honeysuckle (Lonicera
japonica), greenbrier (Smilax rotundifolia), blackberry, and ebony spleenwort
(Asplenium platyneuron). These habits are in silvicultural use and have
experienced logging activities and ground disturbance and are generally not
suitable for habitat for hexastyilis nanii lora.
3.2 Piparian/floodplain Forest
The site, in general, is disturbed and contains numerous invasive species. Stream
banks are highly eroded with limited vegetation on the banks. Species observed
in the riparian areas include yellow poplar, river birch (Betula nigra), box elder
(Acer negundo), red maple and sweetgum (Liquidambar styracii lua). Understory
species include smaller individuals of yellow poplar, red maple, Chinese privet
(Ligustrum sinense), and flowering dogwood. Herbaceous species observed
include Virginia creeper (Parthenocissus quinquefolia), microstegium (Eulalia

viminea) Christmas fern (Polystichum acrostichoides) and multiflora rose (Rosa
multiflora). This area does provide some suitable habitat within the riparian
areas.
3.3 Disturbed Upland Mixed Pine -Hardwood Forest
This habitat type is drier than the riparian area. It includes a younger stand of
trees and is dominated by loblolly pine. Species observed in the overstory include
loblolly pine, sweetgum, yellow poplar, hickory, water oak (Quercus nigra),
black cherry and Virginia pine (Pinus virginiana). Species observed in the
herbaceous layer include spotted wintergreen (Chimaphila maculata), Virginia
creeper, Japanese honeysuckle, spleenwort, blackberry (Rubus sp.) and greenbriar
(Smilax sp.). This area does provide some suitable habitat within the riparian
areas.
3.4 Wetland
There are two large wetland areas on the site. Both of these areas are heavily
influenced and manipulated by the presence of beavers. Tree species observed in
the wetland areas include red maple, green ash (Fraxinus pennsylvanica)
mulberry (Morus sp.), black willow (Salix nigra), willow oak, silky dogwood
(Cornus ammomum), yellow poplar, and box elder. Shrub species observed
include tag alder (Alnus serndata) and elderberry (Sambucus canadensis).
Species observed in the herbaceous layer include impatiens (Impatiens
campensis), false nettle (boehmeria cylindrical), sedge (Carex lurida),
microstegium (Eulalia viminea), grassleaf rush (Juncus marginatus), soft rush
(Juncus effusus), seedbox (Ludwigia alternifolia), wool grass (Scirpus cyperinus),
arrow leaf tearthumb (Polygonum sagittatum), Virginia creeper, moss fem
(Selaginella pallescens), jack-in-the-pulpit (Arisaema triphyllum ), netted chain
fem (Woodwardia aereolaia), and microstegium (Eulalia viminea). There are
smaller wetland areas is adjacent to the unnamed tributary streams with some of
the species listed above. This habitat is not suitable for the listed protected
species.
3.5 Duke Energy Right -of Way
This habitat is seasonally cut and maintained through mechanical means such as
mowing and bush hogging. Some of the right-of-way crosses wetlands and
pastures, these habitats are discussed further below. Some early successional tree
saplings and shrubs exist but this site is dominated by herbs and grasses. Trees
such as red maple, blackjack oak, scarlet oak, southern red oak, white oak,
chestnut oak, eastern red cedar, black locust (Robinina pseudacacia), and tree -of -
heaven (Ailanthus allissima) are on the right-of-way edge as the forest edge takes
over. Herbs and grasses dominate this habitat and species observed include
goldenrods, whorled coreopsis, hoary mountain mint (Pycnanthemum incanum),
butterfly weed (Asclepias tuberosa), ironweed, Queen Anne's lace (Daucus
4

carota), alternate leaf wing stem (Verbesina alternifolia), and crownbeard
(Verbesina occidentale). Other less common plants included butterfly pea
(Clitoria mariana), fleabane (Erigeron philadelphicus), evening primrose
(Oenothera biennis), sunflowers (Helianthus spp.), Indian plantain (Cocalia
muhlenbergii), and round leaf eupatorium (Eupatorium rotundifolium). This
habitat is not suitable for the listed protected species.
3.6 Pasture
This habitat is maintained by mechanical means such mowing or through the
presence of domesticated animals such as cows. A variety of perennial grasses
such as Festuca spp. (fescue), and Panicum spp. (panic grass) are common. The
area is covered in various grasses with a few large shade oak (Quercus sp.) trees.
This habitat is not suitable for the listed protected species.
3.7 Old Field
This habitat type exists in the center portion of the site. The open old -field
habitats are surrounded by wooded areas. Vegetation observed within this habitat
type includes goldenrod (Solidago altissima), loblolly saplings, sumac (Rhus sp.),
broomsedge (Andropogon virginicus), Russian olive (Elaeagnus angustifolia),
multiple flowering rose, poison ivy (Toxicodendron radicans), blackberry (Rubus
sp.) (Panicum sp.)fescue grass (Festuca sp.), dog fennel (Eupatorium
capillifolium), hickory saplings (carya sp.), Aster (aster sp.), Johnson grass
(Sorghum halepense), lespedeza (Lespedeza sp.), queens anne's lace (Daucus
carota) and other grasses. This habitat is not suitable for the listed protected
species.
3.8 Streams
These freshwater habitats include the streambeds and banks of Brushy Creek
Creek, and its unnamed tributaries. Brushy Creek flows through the site, while other
unnamed tributaries have their origins in seeps and springs on site. Permanently
rooted aquatic plants are practically non-existent in swift streams such as those on
site. Most streams are incised and are bordered by riparian forests dominated by
tulip poplar, red maple, sweetgum, buckeye (Aesculus), and river birch. In addition
to saplings of the above trees, species commonly observed in the shrub layers along
streams include great rhododendron, mountain laurel, and spicebush. The
streamside herbaceous layer includes microstegium, and Christmas fem. This
habitat is not suitable for the listed protected species.
3.9 Soils
The Washburn Switch Site is located within the Piedmont physiographic region of
North Carolina and more specifically the Southern Outer Piedmont Ecoregion.
One soil association is present on site; the Cecil-Pacolet association. The Cecil -
5

Pacolet association is classified as gently sloping and strongly sloping, very deep,
well drained soils that have a loamy surface layer and a clayey subsoil. This
association is found on uplands. Soil series present on site include: Appling
(ApB), Cecil (CaB2), Chewacla (Cha), Helena -Worsham complex (HeB), Pacolet
(PaC2), and Pacolet-Bethlehem complex (PbB2 and PbC2) (Figure 4).
4.0 LISTED SPECIES AND ACKNOWLEDGED HABITATS
The following is a brief description of each listed species included in the survey, its
recognized habitat, and comments regarding survey results for that species:
4.1 Dwarf -flowered Heartleaf
Dwarf -flowered heartleaf is federally listed as
threatened in North Carolina. Dwarf -flowered
heartleaf habitat includes acidic sandy loam
soils along bluffs and nearby slopes, hillsides
and ravines, in boggy areas adjacent to
creekheads and streams. Soil type is the most
important habitat requirement (Pacolet,
Madison, or Musella types). The plant needs
sunlight in early spring for maximum
flowering and seed production. Flowering and
fruiting occurs from mid-March to early June.
The dwarf -flowered heartleaf has the smallest flowers of any North American
Hexastylis; most are less that 0.4 inch long with narrow sepal tubes (never more
than .28 inch wide). The jug -shaped flowers range from beige to dark brown,
sometimes greenish or purplish. The evergreen leaves are leathery, dark green,
and heart -shaped.
Stream side and wooded areas with Pacolet soils are present on the site. Wooded
and stream side areas are highly disturbed by previous land use (agricultural fields
and silviculture).
5.0 CONCLUSION
During completion of threatened and endangered species assessments for the project site,
CEC staff observed numerous H. Nanii lora plants. We recommend preliminary site
planning to see if these locations will be avoided. Based on conceptual site plans it is
possible that additional surveys for Hexastylis be conducted in the suitable habitat areas
that may be disturbed.
Because of the transitory nature of some of the listed threatened and endangered species
and the particular flower/fruiting periods of some plants, it is possible that endangered
species populations and locations may change over time. Therefore, any potential
0

findings at a later date should be fully investigated and coordinated with appropriate
agencies to prevent potential adverse impacts.
6.0 References
US Department of Agriculture PLANTS Database.
http•//ulants.usda.goy/j ava/nameSearch
United States Fish and Wildlife Service Division of Endangered Species. Species
accounts at http•//www.fxvs.gov/nc-es/es/countyfr.htrnl
NC Natural Heritage Program, Virtual Workroom.
htto•//www nenho ore/Pages/heritaaedata htm]

Washburn Switch Business Park
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Washburn Switch Business Park
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Washburn Switch Business Park

Attachment A
FWS and NHP Occurrence Data

Endangered Species, 'Threatened Species,li edel-al Species of
Concern, and Candidate Species,
Cleveland County, North Carolina
�rr'"one
-W-
Updated:
Updated: 09-22-2010
Common Name Scientific name Federal Record Status
Status
Vertebrate:
Invertebrate:
Vascular Plant:
Dwarf -flowered heartleaf
Hexastylis naniora
T
Current
Gray's saxifrage
Saxifiaga caroliniana
FSC
Current
Sweet pinesap
Monotropsisodorata
FSC
Current
Torrey's Mountain -mint
Pycnanthemum torrei
FSC
Historic
Nonvas calar Plant:
Lichen:
Definitions of Federal Status Codes:
E = endangered. A taxon "m danger of extinction throughout all or a significant portion of its range."
T = threatened. A taxon "&ely to become endangered within the foreseeable future tbrougbout all or a significant
portion of its range."
C = candidate. A taxon under consideration for official listing for which there is sufficient information to support
listing. (Formerly "Cl"candidate species.)
BGPA =Bald and Golden Eagle Protection Act. See below.
FSC = federal species of concern. A species under consideration for listing, for which there is insufficient
information to support listing at this time. These species may or may not be listed in the f Lure, and many of these
species were formerly recognized as "C2" candidate species.
T(S/A) = threatened due to similarity of appearance. A taxon that is threatened due to similarity of appearance
with another listed species and is listed for its protection. Taxa listed as T(S/A) are not biologically endangered
or threatened and are not subject to Section 7 consultation. See below.

EXP = experimental population. A taxon listed as experimental (either essential or nonessential). Experimental,
nonessential populations of endangered species (e.g., red wall) arc treated as threatened species on public land,
for consultation purposes, and as species proposed for listing on private land.
P = proposed. Taxa proposed for official listing as endangered or threatened will be noted as 'PE" or 'PT",
respectively.
Bald and Golden Eagle Protection Act (BGPA):
In the July 9, 2007 Federal Register( 7237346-37372), the bald eagle was declared recovered, and removed
(de-listed) from the Federal List of Threatened and Endangered wildlife. Tilos delfsting took effect August
8,2007. After delisting, the Bald and Golden Eagle Protection Act (Eagle Act) (16 U.S.C. 668-668d) becomes
the primary law protecting bald eagles. The Eagle Act prolub its take of bald and golden eagles and provides a
statutory definition of"take" that includes "disturb". The USFWS has developed National Bald Eagle
Management Guidelines to provide guidance to land managers, landowners, and others as to how to avoid
disturbing bald eagles. For mor information, visit hMJ/www.RvS.90-v/nhigr�torvbu-dsPoaldeagle hhn
Threatened due to siml argy of -kppgarance(T(S/A)):
In the November 4, 1997 Federal Register (55822-55825), the northern population of the bog turtle (from New
York south to Maryland) was listed as T (threatened), and the southern population (from Virginia south to
Georgia) was listed as T(S/A) (threatened due to similarity of appearance). The T(S/A) designation bans the
collection and interstate and international commercial trade of bog turtles from the southern population. The
T(S/A) designation has no effect on land management activities by private landowners in North Carolina, part of
the southern population of the species. In addition to its official status as T(S/A), the U.S. Fish and Wildlife
Service considers the southern population of the bog turtle as a Federal species of concern due to habitat loss.
Definitions or Record Status:
Current - the species has been observed in the county within the last 50 years.
Historic - the species was last observed in the county more than 50 years ago.
Obscure - the date and/or location of observation is uncertain.
IncidentaUmigrant - the species was observed outside of its normal range or habitat.
Probable/potential - the species is considered likely to occur in this county based on the proximity of known
records (in adjacent counties), the presence ofpotentially suitable habitat, or both.

stale Global Habitat Comments
Rank Rank
Rich deciduous forests,
53 63
bluffs, and ravines
Element Ocanence(s)
53 G3
6121/2011
Rich deciduous forests,
53 63
bluffs, and ravines
Rich deciduous forests,
53 G3
6 record(s)
found
within 2 Miles Of the selected point
93 63
bluffs, and ravines
Rich deciduous forests,
53 G3
bluffs, and ravines
Stare
Federal
scientific
EO
Common Name
Dale Obsasterved
Observed
nark
Ra nH
Accuracy
Ac
protection
Protection
Name
Nb
Status
stilus
Hexas lis
ty
36
Dwarf-
flowered
1997-06-
[D
Medium
T
T
nanlflora
Heartleaf
04
Hexastylls
106
Dwarf-
nowered26
2000-10-
E
Medium
T
T
nanlflora
Heartleaf
HexastyllsDwarf
109
flowered
2006-04-
D
MI h
9
T
T
nanillora
Heartleaf
06
Hexastylis
190
Dwarf w
floered
F
Medium
T
T
nanlflora
Heartleaf
2700-10-
Heis
191
Dwarf-
flowered
2000-30-
D
Medium
T
T
naniflor
lflora
Heartleaf
27
Hex192
Dwarf-
flowered
2000-10-
a
Medium
T
T
na nIflora flora
Heartleaf
�7
stale Global Habitat Comments
Rank Rank
nhpweb.enr.state.nc.us/.../eo—py_eo_select.phtml?sh... 1/1
Rich deciduous forests,
53 63
bluffs, and ravines
Rich deciduous forests,
53 G3
bluffs, and ravines
Rich deciduous forests,
53 63
bluffs, and ravines
Rich deciduous forests,
53 G3
bluffs, and ravines
Ruch deciduous forests,
93 63
bluffs, and ravines
Rich deciduous forests,
53 G3
bluffs, and ravines
nhpweb.enr.state.nc.us/.../eo—py_eo_select.phtml?sh... 1/1

Dwarf -flowered heartleaf relocation
C1earWater Environmental Consultants, Inc. (CEC) conducted a relocation of the dwarf -flowered
heartleaf on the 350 acre business park site in Cleveland County on September 15-16, 2015.
CEC transplanted +/- 126 individuals of dwarf -flowered heartleaf from three sites (A -C) and
relocated them on the southeastern corner of the property adjacent to an existing population of
dwarf -flowered heartleaf (Figure 1).
Individual plants were transplanted over the course of two days and relocated to the southeast
comer of the property. Each plant was watered and marked with pin flags for future monitoring
purposes (See Photos Below). CEC proposes to monitor the planted populations annually for the
spring and fall of 2016 an submit a letter report to the United States Fish and Wildlife Service.
Photo 1. Dwarf -flowered heartleaf after removal.

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Dwarf -flowered heartleaf relocation
ClearWater Environmental Consultants, Inc. (CEC) conducted a relocation of the dwarf -flowered
heartleaf on the 350 acre business park site in Cleveland County on September 15-16, 2015. CEC
transplanted +/- 126 individuals of dwarf -flowered heartleaf from three sites (A -C) and relocated them on
the southeastern comer of the property adjacent to an existing population of dwarf -flowered heartleaf
(Figure 1).
Individual plants were transplanted over the course of two days and relocated to the southeast comer of
the property. Each plant was watered and marked with a pin flag for future monitoring purposes. CEC
proposed to monitor the planted populations annually for the spring and fall of 2016 and submit findings
to the United States Fish and Wildlife Service.
CEC revisited the transplant location on April 28, 2016 to observe general site conditions and to evaluate
the success rate of the relocated dwarf -flowered heartleaf individuals. During this time, it was noted that
the site had remained undisturbed, and that the plants and their corresponding pin flag markers were
unaffected by human or animal interference. Of the +/- 126 dwarf -flower heartleaf individuals that were
transplanted to the relocation site, two had failed to thrive. Therefore, the relocated dwarf -flower heartleaf
population experienced a 98% success rate.
Photo 2. Successful dwarf -flowered heartleaf transplant.

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Once
160 Zillicoa Street
Asheville, North Carolina 28801
December 15, 2016
Rebekah N. Reid
ClearWater Environmental
32 Clayton Street
Asheville, North Carolina 28801
Dear Ms. Reid:
Subject: Washburn Switch Business Park Project; Cleveland County, North Carolina
Log No. 4-2-17-082
The U.S. Fish and Wildlife Service (Service) reviewed the site plans for the project referenced
above which were provided by email on August 23, 2016, and we attended a pre -application site
visit on September 21, 2016. The Service submits the following comments in accordance with
the provisions of the Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661 667e); the
National Environmental Policy Act (42 U.S.C. §4321 et seq.); and section 7 of the Endangered
Species Act of 1973, as amended (16 U.S.C. 1531 1543) (Act).
Proiect Description
According to the information provided, you are seeking required permits to construct a
commercial development and appurtenant structures (e.g. parking, road access, rail access, etc.)
on approximately 350 acres of land west of Shelby, North Carolina. Preliminary project
information indicate that approximately 8,000 linear feet of jurisdictional stream and 6.148 acres
of wetlands occur within the project boundary.
Federally Listed Endangered and Threatened Species
According to Service records, suitable summer roosting habitat may be present in the project
area for the federally threatened northern long-eared bat. However, the final 4(d) rule (effective
as of February 16, 2016), exempts incidental take of northern long-eared bat associated with
activities that occur greater than 0.25 miles from a known hibernation site, and greater than 150
feet from a known, occupied maternity roost during the pup season (June 1 — July 31). Based on
the information provided, the project (which may require tree clearing) would occur at a location
where any incidental take that may result from associated activities is exempt under the 4(d) rule.
ClearWater staff observed the federally threatened dwarf -flowered heartleaf (Hexastylis
nanii lora) during a site evaluation. You relocated approximately 126 individual plants occurring
within the project boundary to a location outside of the proposed impact area. Service staff
observed the plant relocation site on September 21, 2016 and found that recent maintenance
activities (vegetative clearing) on an adjacent overhead powerline easement are likely disturbing
a small proportion of this population. ClearWater staff and the Service have agreed to transplant
15-30 plants from the relocation site to a nearby location that is further away from the utility

easement in early 2017. During a site visit on December 13, 2016, ClearWater staff observed
that dwarf -flowered heartleaf sites A and B have regenerated about 23 individuals from
rootstock. These plants will also be relocated in early 2017.
With regards to the proposed project's effect on dwarf -flowered heartleaf, the Service believes
that the impact avoidance, minimization, and mitigation measures have effectively reduced the
probability of take to a level that is insignificant and discountable. Therefore, the Service would
concur with a determination that the proposed project may affect, but is not likely to adversely
affect this species.
According to Service records, no other federally protected species occur within the proposed
project's impact area. Therefore, we consider the requirements under the Act to be complete and
require no further action at this time. Please be aware that obligations under section 7 of the Act
must be reconsidered if: (1) new information reveals impacts of this identified action that may
affect listed species or critical habitat in a manner not previously considered, (2) this action is
subsequently modified in a manner that was not considered in this review, or (3) a new species is
listed or critical habitat is determined that may be affected by the identified action.
The Service appreciates the opportunity to review this project. Please supply this office a copy
of the final permit application once it is complete. Please contact Mr. Byron Hamstead of our
staff at 828/258-3939, Ext. 225, if you have any questions. In any future correspondence
concerning this project, please reference our Log Number 4-2-17-082.
Sincerely,
- - original signed - -
Janet A. Mizzi
Field Supervisor
e.c. David Schaeffer, USACE
Alan Johnson, NCDEQ
Sue Homewood, NCDEQ

Attachment E
Cultural Resource Reports and SHPO Correspondence

50101 Governor's Drive
Suite 250
Chapel Hill, NC 27517
919.530.8446 PHONE
919.530.8525 FAx
www.TRCsoIudons.Com
October 28, 2011
Ms. Rebekah Newton
Clearwater Environmental
224 South Grove Street, Suite F
Hendersonville, NC 28792
Re: Letter Report, Cultural Resources Background Research and Limited Field Reconnaissance for the
Proposed Washburn Switch Business Park, Cleveland County, North Carolina
Dear Ms. Newton:
TRC has completed a cultural resources background study and limited field reconnaissance for the
proposed Washburn Switch Business Park in Cleveland County, North Carolina (Figure 1). The
background study was conducted on October 20-21, 2011 by Erin Grantham and Paul Webb, and the
field reconnaissance was conducted on October 25, 2011 by Belinda Cox.
The irregularly shaped parcel is situated north and east of Washburn Switch Road (SR 1313), which
parallels the path of the CSX rail line through the area. The tract is largely wooded in planted pines, but
also includes open pasture and two drainages. Most of the upland soils on the tract are classified as
moderately eroded Cecil sandy loam and Pacolet-Bethlehem complex soils (USDA NRCS 2011). A 1983
USGS quadrangle shows a dirt road running west -east across the center of the tract and leading to a single
outbuilding (or vacant building); a cemetery is mapped on a ridgetop located just north of the road and
approximately 2,400 feet (ca. 730 m) east of Washburn Switch Road. Two other homes and an
outbuilding are shown along the northern edge of the property, south of SR 1342.
The goals of the present work were to assess the potential for significant cultural resources on and
adjacent to the property so that this information could be considered for planning purposes. The study was
also intended to gather information on the potential cemetery shown on the USGS map, determine its
location and approximate extent, and present options for either additional investigations (if necessary) or
its preservation or treatment.
BACKGROUND RESEARCH RESULTS
Archaeological Sites. A review of the files and records at the Office of State Archaeology (OSA) in
Raleigh showed that the southern edge of the property was included within a 1999-2000 survey for the
Proposed US 74 Shelby Bypass (Smith and Sanborn 2001), and that an area immediately east of the
property was included in a 2001 survey conducted prior to construction of a Wal-Mart complex (Gresham
2001). In addition, in 2010 TRC conducted a literature review and reconnaissance of a 145 -acre tract west
of and across Washburn Switch Road from the property (Olson 2010). There are no known sites on the
property, however, and no indications that the remainder of the property has been surveyed.

Six sites have been recorded within one-half mile of the property. These six sites (31CL44, 31CL51,
31CL56, 31CL57, 31CL59, and 31CL60), are situated southeast and southwest of the property, and
include the Eskridge Grove Church Cemetery (31CL51), a 19'h century house site (31CL44), a
multicomponent prehistoric lithic scatter/19 h century site (31CL59), two multicomponent prehistoric
lithic scatters/20' century sites (31CL56 and 31CL59), and a 20'h century site (31CL57). All have been
determined not eligible for the National Register of Historic Places (NRNP).
Historic Structures. Review of the State Historic Preservation Office (SHPO) online database (HPOWEB
2011) identified two previously surveyed structures within one-half mile of the property. These are the
Coleman Blanton Farm (CL0012), which is situated approximately 1,600 feet (ca. 500 m) northeast of the
property, and an unidentified house (CL0506) that was within the Wal-Mart tract and is presumably no
longer extant. The Coleman Blanton Farm is also known as Brushy Creek Dairy Farm and was one of the
first large commercial dairies in Cleveland County; the 73-acre faun includes a vernacular Queen Anne
style farmhouse as well as a support structures that were constructed between 1909 and 1950 (Eades and
Pezzoni 2003; Mattson and Alexander 1996). This complex has been placed on the NRHP study list and
is considered eligible for the NRHP.
Cemeteries. Current (1983) and former (1950) USGS maps (see Figures 1 and Figure 5 [below]) depict a
cemetery near the center of the tract. Although data on Cleveland County cemeteries are available on-line
(NCGENWEB 2011; TTP 2011) and in published reports (e.g., McEntire 1986), none of the examined
sources include a comprehensive map of Cleveland County cemeteries or provide detailed locational data
for all recorded cemeteries. Based on the available information, however, it is possible that this cemetery
represents the Major McCombs Graveyard, which was recorded by WPA surveyors in 1939 (McEntire
1986; httl2i//www.ncpenweb.us/cigyeland/cemeteries/Major McCombs Graveyard.txt). At that time, the
graveyard contained five marked 19 "-century interments of McCombs family members and was
described as "about 400 yards east of Shelby-New House Road on a hill dotted with pines and oaks and
being relatively small in dimension; also about 300 yards east of the old Bate Blanton place or residence."
That location fits relatively well with the mapped location, and is also compatible with the Blanton and
McCombs notations found on the 1886 map (see Figure 2, below); in addition, there are no indications
that the McCombs graveyard is presently known at another location. Genealogical data available on-line
(hup7Hgenforum genealogv.com/mccombs/messages/904.htm1) also indicate that McCombs lived west of
Brushey Creek in the general project area.
Historic Man Review. The project tract is situated in south-central Cleveland County, at the western edge
of the larger Shelby community. Cleveland County was formed in 1842 from Lincoln County, which had
in tum been formed in 1779 from Tryon County. The Euro -American settlement of the Cleveland County
area began in the latter 1700s, intensifying after the Revolutionary War. By 1840 Lincoln County had a
population of over 25,000, and in 1850 Cleveland County had a population of over 10,000. The new
county was primarily agricultural, consisting of numerous small farms (Novick 1997).
A series of historic maps dating from the 19'h to the mid-20'h century were examined to identify potential
historic structure locations on or adjacent to the project area. Most of the 19'" century maps to not show
any detail of the project area, although the town of Shelby is noted on maps as early as 1843 (Morse and
Breese 1843). The earliest detailed map of the area dates to 1886 (Figure 2; Kyzer 1886), and is a fairly
schematic map showing farm locations in Cleveland County. That map depicts several farms in the
general project area west of Brushy Creek, including those occupied by A. Blanton, C.L.(?) Blanton, S.
Poston, and Miss McCombs, but it is not possible to determine which, if any, were situated on the project
tract. A 1918 soils map (Figure 3; Vanetta and McDowell 1918) provides additional detail, and depicts a
dirt road running through the tract from west to east; a segment of that road still survives as the entrance
road into the property. A single structure is shown along the north side of that road and was probably
about where the roar presently reenters the tract behind an existing industrial facility that fronts on

Washburn Switch Road. The map does not depict a cemetery on the tract, but appears not to depict
cemeteries in general. A subsequent highway map (Figure 4; NCSHPWC 1938) appears not to depict the
dirt road, but shows several houses along an east -west road located farther to the north (now SR 1342).
The earliest available USGS map showing the tract is a 1:62,5000 -scale map dating to 1950 (Figure 5;
USGS 1950); that map shows the east -west road, as well as five apparent residences and two outbuildings
within the tract. The USGS map also depicts a cemetery on the north side of the road, at the same location
shown on the 1983 1:24,000 quadrangle (see Figure 1).
Field Reconnaissance. The field reconnaissance was conducted at and adjacent to the mapped cemetery
location, beginning in a clearing on the north side of an unnamed, dirt roadway located off Farmville
Road to the east of Washburn Switch Road. Based on the growth of immature pine and oak trees, as well
as the waist -high grasses and scrub, it appears that the location had been cleared in the recent past (Figure
6). Portions of the cleared area revealed disturbed surface sediments with widely scattered recent historic
trash (e.g., beverage cans, a 5 -gallon plastic bucket, etc). No evidence of a cemetery was visible in the
cleared area, and the inspection was subsequently expanded to the wooded area surrounding the clearing
to the north, east, and west. The area along the edges of the clearing to the north and northeast were not
fully inspected due to the large piles of tree debris and sediment in those areas (Figures 7). It is evident
that this debris has been piled and/or otherwise manipulated by machinery, and some of the debris may
have been pushed from the clearing. The area surrounding the debris was inspected and no visible historic
remains were encountered. The debris extends to the north, down a moderate slope toward a creek, into an
area overgrown with blackberries, greenbriars, patches of sumac, and some young alders.
Based on the map evidence and general patterns of cemetery location in the North Carolina Piedmont
(Clauser 1994), it is most likely that the cemetery (if it in fact was present) was located on the level
ground, probably a short distance off of the main roadway. This area has been impacted by clearing, and
if any grave markers were once present, they have been removed or obscured. The clearing is unlikely to
have extended deep enough to have impacted any interments, however, and it is likely that the lower
portions of the grave shafts and the interments remain intact.
SUMMARY AND CONCLUSIONS
The literature search has identified no previously recorded archaeological sites on the tract. Based on the
historic map review and the results of nearby surveys (e.g., Gresham 2001; Smith and Sanborn 2001;
Olson 2010), the tract almost certainly contains a variety of archaeological sites, however; these are likely
to include low to moderate density prehistoric sites as well as 19th to mid -20'i, century sites. A
determination regarding any requirement for additional survey will ultimately be based on project specific
permitting requirements, but given the soil characteristics and the results of nearby surveys, any
prehistoric sites that are present are unlikely to be eligible for the NRNP. Historic period farmstead sites
on the property are also unlikely to be NRNP eligible, unless they represent short term 19'h century
occupations retaining considerable integrity.
The only documented historic structure near the property is the Coleman Blanton Farm (CLOW 2), which
is situated approximately 1,600 feet (ca. 500 m) northeast of the property. Given its distance from the
property, it is very unlikely that this structure complex would be affected by development of the property.
USGS maps dating to 1950 and 1983 indicate that a historic period cemetery is located on the tract.
Documentary research has not been able to confirm the identity of this cemetery, but it may represent the
19" century Major McCombs graveyard, which was recorded in this general area by a 1939 WPA survey.
The mapped cemetery location was examined, but no gravemarkers or other indications of a cemetery
were noted.

Any cemetery that might be present is unlikely to be eligible for the NRHP, and thus would not be
covered under Section 106 of the National Historic Preservation Act (NHPA) or its implementing
regulations (36 CFR 800). Like other cemeteries, however, it would be protected by North Carolina
General Statutes (G.S.) 14-148 (Defacing or desecrating grave sites) and 14-149 (Desecrating, plowing
over or covering up graves; desecrating human remains); other statutes contained in Chapter 65, Article
12 (Abandoned and Neglected Cemeteries) specify who can visit cemeteries on private lands and the
conditions under which cemeteries can be moved. Finally, Chapter 70, Article 3 (the Unmarked Human
Burial and Human Skeletal Remains Protection Act) outlines the procedures to be followed in the event of
discovery of unmarked human remains. The relevant portions of these statutes are provided in Appendix
A, and their full texts are available at http://www.ncleg.net/gascripts/Statutes/Statutes.asp.
Given the uncertainty regarding the cemetery's presence and the extent of recent modification to the area,
additional efforts to document and define the cemetery are recommended prior to any ground disturbing
activities at the mapped location. Such efforts should begin with additional documentary and possibly oral
history research to attempt to confirm the cemetery's presence and determine the age and identities of
those interred. Associated fieldwork should include systematic attempts to identify any remaining grave
markers and locate grave shafts. A variety of techniques could be used in this effort, including systematic
probing, Ground Penetrating Radar (GPR) survey, and/or limited topsoil stripping. In particular, topsoil
stripping using a trackhoe or backhoe with a smooth blade would probably be an effective technique to
locate grave shafts beneath disturbed or plowed soil.
If the cemetery is determined to be present, there are two principal options for its treatment. First, the
cemetery could be demarcated and preserved in place. Under this option the cemetery would remain
undisturbed, and family members would be allowed to access it as outlined in G.S. 65-101 and 65-102. Or
second, the graves could be moved to another location as outlined in G.S. 65-106. Such removal would
require notification of the next-of-kin (if this could be determined), as well as approval by the relevant
local or county governing body.
In conclusion, the research and field reconnaissance suggest that the property is unlikely to contain any
archaeological sites that would constrain its development potential. Two 20 century maps depict a
cemetery on the site, however, and it was not possible to confirm or disprove the cemetery's existence
during an initial field visit. Any cemetery that might be present is protected by North Carolina state
statutes, and additional efforts to identify and locate the cemetery are recommended prior to any further
ground disturbances in the area. If such a cemetery is present, it could either be preserved in place or
moved in accordance with state statutes.
We hope this information is useful to you. Please do not hesitate to contact me at [phone] or
[e-mail] if you would like additional information or have any questions or comments
about this report.
Sincerely,
(]�,j a W..G
Paul A. Webb
Program Manager, Chapel Hill/Asheville

REFERENCES CITED
Clauser, John. W. Jr.
1994 The Southern Folk Cemetery in Piedmont North Carolina In Cemeteries, North Carolina Historic
Preservation Office Newsletter, Fall 1994, pp. 2-7.
Eades, Brian R., and J. Daniel Pezzoni
2003 Architectural Perspectives of Cleveland County, North Carolina. Cleveland County Historic
Preservation Taskforce, Shelby, North Carolina.
Gresham, Thomas H.
2001 Archaeological Survey of the Shelby Loan Tract, Cleveland County, North Carolina. Southeastern
Archaeological Services, Athens, Georgia. On file, Office of State Archaeology, Raleigh.
14POWEB
2011 North Carolina State Historic Preservation Office GIS Web Service. htly,Hlzis.ncdcr.gov/hpoweb/,
accessed October 25, 2011.
Kyzer, Paul B.
1886 Complete Map of Cleveland County, North Carolina. On file, North Carolina State Archives, Raleigh.
McEntire, Russell Hicks
1986 WPA Cemetery Records for 1939, Cleveland County, North Carolina. Privately Published,
Weaverville, North Carolina.
Mattson, Richard L., and Frances P. Alexander
1996 Phase 11 Intensive Architectural Survey, U.S. 74, Shelby Bypass, Cleveland County. Mattson,
Alexander, and Associates, Inc. Submitted to North Carolina Department of Transportation, Raleigh.
Morse, Sidney E., and Samuel Breese
1843 North Carolina. On file, North Carolina Stale Archives, Raleigh.
NCGENWEB
2011 Cleveland County Cemeteries. http://www.ncgenweb.us/cleveland/Clevelandlndex.htmi, accessed
October 20, 2011.
North Carolina State Highway and Public Works Commission (NCSHPWC)
1938 Cleveland County, North Carolina. North Carolina Department of Natural Resources and Community
Development, Raleigh
Novick, Lee
1997 Archaeological and Historical Background Report for US 74 Shelby Bypass (R-2707) Study Area,
Cleveland County, North Carolina. North Carolina Department of Transportation, Raleigh.
Olson, Heather
2010 Cultural Resources Background Study and Reconnaissance of a 145 -acre Tract, Cleveland County,
North Carolina. TRC Environmental Corporation, Chapel Hill.
Smith, Caleb, and Erica Sanborn
2001 Intensive Archaeological Survey of the Proposed US 74 (Shelby) Bypass, Cleveland County, North
Carolina. New South Associates, Stone Mountain, Georgia. On file, Office of State Archaeology, Raleigh.
Tombstone Transcription Project (TTP)
2011 Rutherford County, North Carolina htip,//www.usgwtombsiones.org/northcarolinaI cleveland.html)
accessed October 20, 2011.
USDA National Resources Conservation Service (MRCS)
2011 Web Soil Survey. http-//websoilsurvey.nrcs.usda.gov/al)p/HomePage.htm, accessed October 25, 2011.
United States Geological Survey (USGS)
1950 Shelby, North Carolina. 1:62,500 scale.
1983 Shelby, North Carolina. 1:24,000 scale.
Vanetta, E.S., and F.N. McDowell
1918 Soil Survey of Cleveland County, North Carolina. U.S. Department of Agriculture, Washington, D.C.

APPENDIX A. SELECTED NORTH CAROLINA GENERAL STATUTES RELATING TO CEMETERIES
§ 14-148. Defacing or desecrating grave sites.
(a) It is unlawful to willfully:
(1) Throw, place or put any refuse, garbage or trash in or on any cemetery.
(2) Take away, disturb, vandalize, destroy or change the location of any stone, brick, iron or other
material or fence enclosing a cemetery without authorization of law or consent of the
surviving spouse or next of kin of the deceased.
(3) Take away, disturb, vandalize, destroy, or tamper with any shrubbery, flowers, plants or other
articles planted or placed within any cemetery to designate where human remains are interred
or to preserve and perpetuate the memory and name of any person, without authorization of
law or the consent of the surviving spouse or next of kin.
(b) The provisions of this section shall not apply to:
(1) Ordinary maintenance and care of a cemetery by the owner, caretaker, or other person acting to
facilitate cemetery operations by keeping the cemetery free from accumulated debris or other
signs of neglect.
(2) Conduct that is punishable under G.S. 14-149.
(3) A professional archaeologist as defined in G.S. 70-28(4) acting pursuant to the provisions of
Article 3 of Chapter 70 of the General Statutes.
(c) Violation of this section is a Class 1 felony if the damage caused by the violation is one thousand dollars
($1,000) or more. Any other violation of this section is a Class 1 misdemeanor. In passing sentence, the court shall
consider the appropriateness of restitution or reparation as a condition of probation under G.S. 15A -1343(b)(9) as an
alternative to actual imposition of a fine, jail term, or both. (1840, c. 6; R.C., c. 34, s. 102; Code, s. 1088; Rev., s.
3680; C.S., s. 4320; 1969, c. 987; 1981, c. 752, s. 1; c. 853, s. 4; 1993, c. 539, s. 87; 1994, Ex. Sess., c. 24, s. 14(c);
2007-122, s. 1.)
§ 14-149. Desecrating, plowing over or covering up graves; desecrating human remains.
(a) It is a Class I felony, without authorization of law or the consent of the surviving spouse or next of kin
of the deceased, to knowingly and willfully:
(1) Open, disturb, destroy, remove, vandalize or desecrate any casket or other repository of any
human remains, by any means including plowing under, tearing up, covering over or
otherwise obliterating or removing any grave or any portion thereof.
(2) Take away, disturb, vandalize, destroy, tamper with, or deface any tombstone, headstone,
monument, grave marker, grave ornamentation, or grave artifacts erected or placed within any
cemetery to designate the place where human remains are interred or to preserve and
perpetuate the memory and the name of any person. This subdivision shall not apply to the
ordinary maintenance and care of a cemetery.
(3) Repealed by Session Laws 2007-122, s. 2, effective December 1, 2007, and applicable to
offenses committed on or after that date.
(al) It is a. Class H felony, without authorization of law or the consent of the surviving spouse or next of kin
of the deceased, to knowingly and willfully disturb, destroy, remove, vandalize, or desecrate any human remains that.
have been interred in a cemetery.
(b) The provisions of this section shall not apply to a professional archaeologist as defined in G.S. 70-28(4)
acting pursuant to the provisions of Article 3 of Chapter 70 of the General Statutes. (1889, c. 130; Rev., s. 3681;
1919, c. 218; C.S., s. 4321; 1981, c. 752, s. 2; c. 853, s. 5; 2007-122, s. 2.)

Chapter 65.
Cemeteries.
Article 12.
Abandoned and Neglected Cemeteries.
Part 1. General.
§ 65-85. Definitions.
As used in this Article, the following terms mean:
(1) Abandoned. — Ceased from maintenance or use by the person with legal right to the real
property with the intent of not again maintaining the real property in the foreseeable future.
(2)
Cemetery. — A tract of land used for burial of multiple graves.
(3)
Department. — The Department of Cultural Resources.
(4)
Grave. — A place of burial for a single decedent.
(5)
Neglected. — Left unattended or uncared for through carelessness or intention and lacking a
(6)
caretaker.
Public cemetery. — A cemetery for which there is no qualification to purchase, own, or come
into possession of a grave in that cemetery. (2007-118, s. 1.)
Part 3. Access to and Maintenance of Abandoned or Neglected Cemeteries.
§ 65-101. Entering public or private property to maintain or visit with consent
Any of the following persons, with the consent of the public or private landowner, may enter the property of
another to discover, restore, maintain, or visit a grave or abandoned public cemetery:
(1) A descendant of the person whose remains are reasonably believed to be interred in the grave
or abandoned public cemetery.
(2) A descendant's designee.
(3) Any other person who has a special personal interest in the grave or abandoned public
cemetery. (1987, c. 686, s. 1; 1991, c. 36, s. 1; 2007-118, s. 1.)
§ 65-102. Entering public or private property to maintain or visit without consent.
(a) If the consent of the landowner cannot be obtained, any person listed in G.S. 65-101(1), (2), or (3) may
commence a special proceeding by petitioning the clerk of superior court of the county in which the petitioner has
reasonable grounds to believe the grave or abandoned public cemetery is located for an order allowing the petitioner
to enter the property to discover, restore, maintain, or visit the grave or abandoned public cemetery. The petition
shall be verified. The special proceeding shall be in accordance with the provisions of Articles 27A and 33 of
Chapter 1 of the General Statutes. The clerk shall issue an order allowing the petitioner to enter the property if the
clerk finds all of the following:
(1) There are reasonable grounds to believe that the grave or abandoned public cemetery is located
on the property or it is reasonably necessary to enter or cross the landowner's property to
reach the grave or abandoned public cemetery.
(2) The petitioner, or the petitioner's designee, is a descendant of the deceased, or the petitioner
has a legitimate historical, genealogical, or governmental interest in the grave or abandoned
public cemetery.
(3) The entry on the property would not unreasonably interfere with the enjoyment of the property
by the landowner.
(b) The clerk's order may state one or more of the following:
(1) Specify the dates and the daylight hours that the petitioner may enter and remain on the
property.
(2) Grant the petitioner the right to enter the landowners property periodically, as specified in the
order, after the time needed for initial restoration of the grave or abandoned public cemetery.
(3) Specify a reasonable route from which the petitioner may not deviate in all entries and exits
from the property. (1987, c. 686, s. l; 1991, c. 36, s. 1; 1999-216, s. 12; 2007-118, s. 1.)

Part 4. Removal of Graves.
§ 65-106. Removal of graves; who may disinter, move, and reinter; notice; certificate filed; reinterment
expenses; due care required.
(a) The State of North Carolina and any of its agencies, public institutions, or political subdivisions, the
United States of America or any agency thereof, any church, electric power or lighting company, or any person,
firm, or corporation may effect the disinterment, removal, and reinterment of graves as follows:
(1) By the State of North Carolina or any of its agencies, public institutions, or political
subdivisions, the United States of America or any agency thereof, when it shall determine and
certify to the board of county commissioners in the county from which the bodies are to be
disinterred that such removal is reasonably necessary to perform its governmental functions
and the duties delegated to it by law.
(2) By any church authority in order to erect a new church, parish house, parsonage, or any other
facility owned and operated exclusively by such church; in order to expand or enlarge an
existing church facility; or better to care for and maintain graves not located in a regular
cemetery for which such church has assumed responsibility of care and custody.
(3) By an electric power or lighting company when it owns land on which graves are located, and
the land is to be used as a reservoir.
(4) By any person, firm, or corporation who owns land on which an abandoned cemetery is located
after first securing the consent of the governing body of the municipality or county in which
the abandoned cemetery is located.
(b) The party effecting the disinterment, removal, and reinterment of a grave containing a decedent's
remains under the provisions of this Part shall, before disinterment, give 30 days' written notice of such intention to
the next of kin of the decedent, if known or subject to being ascertained by reasonable search and inquiry, and shall
cause notice of such disinterment, removal, and reinterment to be published at least once per week for four
successive weeks in a newspaper of general circulation in the county where such grave is located, and the first
publication shall be not less than 30 days before disinterment. Any remains disinterred and removed hereunder shall
be reinterred in a suitable cemetery.
(c) The party removing or causing the removal of all such graves shall, within 30 days after completion of
the removal and reinterment, file with the register of deeds of the county from which the graves were removed and
with the register of deeds of the county in which reinterment is made, a written certificate of the removal facts. Such
certificate shall contain the full name, if known or reasonably ascertainable, of each decedent whose grave is moved,
a precise description of the site from which such grave was removed, a precise description of the site and specific
location where the decedent's remains have been reinterred, the full and correct name of the party effecting the
removal, and a brief description of the statutory basis or bases upon which such removal or reinterment was
effected. If the full name of any decedent cannot reasonably be ascertained, the removing party shall set forth all
additional reasonably ascertainable facts about the decedent including birth date, death date, and family name.
The fee for recording instruments in general, as provided in G.S. 161-10(a)(1), for registering a certificate of
removal facts shall be paid to the register of deeds of each county in which such certificate is filed for registration.
(d) All expenses of disinterment, removal, and acquisition of the new burial site and reinterment shall be
borne by the party effecting such disinterment, removal, and reinterment, including the actual reasonable expense of
one of the next of kin incurred in attending the same, not to exceed the sum of two hundred dollars ($200.00).
(e) The Office of Vital Records of North Carolina shall promulgate regulations affecting the registration
and indexing of the written certificate of the removal facts, including the form of that certificate.
(f) The party effecting the disinterment, removal, and reinterment of a decedent's remains under the
provisions of this Part shall ensure that the site in which reinterment is accomplished shall be of such suitable
dimensions to accommodate the remains of that decedent only and that such site shall be reasonably accessible to all
relatives of that decedent, provided that the remains may be reinterred in a common grave where written consent is
obtained from the next of kin. If under the authority of this Part, disinterment, removal, and reinterment are effected
by the State of North Carolina or any of its agencies, public institutions, or political subdivisions, the United States
of America or any agency thereof, any electric power or lighting company, then such disinterment, removal, and
reinterment shall be performed by a funeral director duly licensed as a "funeral director" or a "funeral service
licensee" under the provisions of Article 13A of Chapter 90 of the General Statutes.
(g) All disinterment, removal, and reinterment under the provisions of this Part shall be made under the
supervision and direction of the county board of commissioners or other appropriate official, including the local
health director, appointed by such board for the county where the disinterment, removal, and reinterment take place.
3

If reinterment is effected in a county different from the county of disinterment with the consent of the next of kin of
the deceased whose remains are disinterred, then the disinterment and removal shall be made under the supervision
and direction of the county board of commissioners or other appropriate official, including the local health director,
appointed by such board for the county of the disinterment, and the reinterment shall be made under the supervision
and direction of the county board of commissioners or other appropriate official, including the local health director,
appointed by such board for the county of reinterment.
Due care shall be taken to do said work in a proper and decent manner, and, if necessary, to famish suitable
coffins or boxes for reinterring such remains. Due care shall also be taken to remove, protect, and replace all
tombstones or other markers, so as to leave such tombstones or other markers in as good condition as that prior to
disinterment. Provided that in cases where the remains are to be moved to a perpetual care cemetery or other
cemetery where upright tombstones are not permitted, a suitable replacement marker shall be provided.
(h) Nothing contained in this Part shall be construed to grant or confer the power or authority of eminent
domain, or to impair the right of the next of kin of a decedent to remove or cause the removal, at his or their
expense, of the remains or grave of such decedent. (1919, c. 245; C.S., ss. 5030, 5030(a); Ex. Sess. 1920, c. 46;
1927, c. 23, s. 1; c. 175, s. 1; 1937, c. 3; 1947, cc. 168, 576; 1961, c. 457; 1963, c. 915, s. 1; 1965, c. 71; 1971, c.
797, s. 1; 1977, c. 311, s. 1; 2001-390, s. 3; 2007-118, s. 1.)
Chapter 70.
Indian Antiquities, Archaeological Resources and Unmarked Human Skeletal Remains Protection.
Article 3.
Unmarked Human Burial and Human Skeletal Remains Protection Act.
§ 70-26. Short title.
This Article shall be known as "The Unmarked Human Burial and Human Skeletal Remains Protection Act."
(1981, c. 853, s. 2.)
§ 70-27. Findings and purpose.
(a) The General Assembly finds that:
(1) Unmarked human burials and human skeletal remains are subject to vandalism and inadvertent
destruction at an ever-increasing rate;
(2) Existing State laws do not provide adequate protection to prevent damage to and destruction of
these remains;
(3) There is a great deal of scientific information to be gained from the proper excavation, study
and analysis of human skeletal remains recovered from such burials; and
(4) There has been no procedure for descendants or other interested individuals to make known
their concerns regarding disposition of these remains.
(b) The purpose of this Article is (i) to provide adequate protection from vandalism for unmarked human
burials and human skeletal remains, (ii) to provide adequate protection for unmarked human burials and human
skeletal remains not within the jurisdiction of the medical examiner pursuant to G.S. 130A-383 that are encountered
during archaeological excavation, construction, or other ground disturbing activities, found anywhere within the
State except on federal land, and (iii) to provide for adequate skeletal analysis of remains removed or excavated
from unmarked human burials if the analysis would result in valuable scientific information. (1981, c. 853, s. 2;
2007-484, s. I I (a).)
§ 70-28. Definitions.
As used in this Article:
(1) "State Archaeologist" means the head of the Office of State Archaeology section of the Office
of Archives and History, Department of Cultural Resources.
(2) "Executive Director" means the. Executive Director of the North Carolina Commission of
Indian Affairs.
(3) "Human skeletal remains" or "remains" means any part of the body of a deceased human being
in any stage of decomposition.
(4) "Professional archaeologist" means a person having (i) a postgraduate degree in archaeology,
anthropology, history, or another related field with a specialization in archaeology, (ii) a
minimum of one year's experience in conducting basic archaeological field research,
including the excavation and removal of human skeletal remains, and (iii) designed and

executed an archaeological study and presented the written results and interpretations of such
study.
(5) "Skeletal analyst" means any person having (i) a postgraduate degree in a field involving the
study of the human skeleton such as skeletal biology, forensic osteology or other relevant
aspects of physical anthropology or medicine, (ii) a minimum of one year's experience in
conducting laboratory reconstruction and analysis of skeletal remains, including the
differentiation of the physical characteristics denoting cultural or biological affinity, and (iii)
designed and executed a skeletal analysis, and presented the written results and interpretations
of such analysis.
(6) "Unmarked human burial" means any interment of human skeletal remains for which there
exists no grave marker or any other historical documentation providing information as to the
identity of the deceased. (1981, c. 853, s.2; 2002-159, s. 35(a); 2007484, s. ]0(a).)
§ 70-29. Discovery of remains and notification of authorities.
(a) Any person knowing or having reasonable grounds to believe that unmarked human burials or human
skeletal remains are being disturbed, destroyed, defaced, mutilated, removed, or exposed, shall notify immediately
the medical examiner of the county in which the remains are encountered.
(b) If the unmarked human burials or human skeletal remains are encountered as a result of construction or
agricultural activities, disturbance of the remains shall cease immediately and shall not resume without authorization
from either the county medical examiner or the State Archaeologist, under the provisions of G.S. 70-30(c) or
70-30(d).
(c) (1) If the unmarked human burials or human skeletal remains are encountered by a professional
archaeologist, as a result of survey or test excavations, the remains may be excavated and
other activities may resume after notification, by telephone or registered letter, is provided to
the State Archaeologist. The treatment, analysis and disposition of the remains shall come
under the provisions of G.S. 70-34 and 70-35.
(2) If a professional archaeologist directing long-term (research designed to continue for one or
more field seasons of four or more weeks' duration) systematic archaeological research
sponsored by any accredited college or university in North Carolina, as a part of his research,
recovers Native American skeletal remains, he may be exempted from the provisions of G.S.
70-30, 70-31, 70-32, 70-33, 70-34 and 70-35(c) of this Article so long as he:
a. Notifies the Executive Director within five working days of the initial discovery of
Native American skeletal remains;
b. Reports to the Executive Director, at agreed upon intervals, the status of the project;
C. Curates the skeletal remains prior to ultimate disposition; and
d. Conducts no destructive skeletal analysis without the express permission of the
Executive Director.
Upon completion of the project fieldwork, the professional archaeologist, in consultation with
the skeletal analyst and the Executive Director, shall determine the schedule for the
completion of the skeletal analysis. In the event of a disagreement, the time for completion of
the skeletal analysis shall not exceed four years. The Executive Director shall have authority
concerning the ultimate disposition of the Native American skeletal remains after analysis is
completed in accordance with G.S. 70-35(a) and 70-36(b) and (c).
(d) The State Archaeologist shall notify the Chief, Medical Examiner Section, Division of Health Services,
Department of Health and Human Services, of any reported human skeletal remains discovered by a professional
archaeologist. (1981, c. 853, s. 2; 1997-443, s. I IA.118(a); 2007-484, s. 10(b).)
§ 70-30. Jurisdiction over remains.
(a) Subsequent to notification of the discovery of an unmarked human burial or human skeletal remains, the
medical examiner of the county in which the remains were encountered shall determine as soon as possible whether
the remains are subject to the provisions of G.S. 130A-383.
(b) If the county medical examiner determines that the remains are subject to the provisions of G.S.
130A-383, the county medical examiner will immediately proceed with the investigation.
(c) if the county medical examiner determines that the remains are not subject to the provisions of G.S.
130A-383, the county medical examiner shall so notify the Chief Medical Examiner. The Chief Medical Examiner
m

shall notify the State Archaeologist of the discovery of the human skeletal remains and the findings of the county
medical examiner. The State Archaeologist shall immediately take charge of the remains.
(d) Subsequent to taking charge of the human skeletal remains, the State Archaeologist shall have 48 hours
to make arrangements with the landowner for the protection or removal of the unmarked human burial or human
skeletal remains. The State Archaeologist shall have no authority over the remains at the end of the 48-hour period
and may not prohibit the resumption of the construction or agricultural activities without the permission of the
landowner. (1981, c. 853, s. 2; 2007-484, ss. 10(c), 1 I(b).)
§ 70-31. Archaeological investigation of human skeletal remains.
(a) If an agreement is reached with the landowner for the excavation of the human skeletal remains, the
State Archaeologist shall either designate a member of his staff or authorize another professional archaeologist to
excavate or supervise the excavation.
(b) The professional archaeologist excavating human skeletal remains shall report to the State
Archaeologist, either in writing or by telephone, his opinion on the cultural and biological characteristics of the
remains. This report shall be transmitted as soon as possible after the commencement of excavation, but no later
than two full business days after the removal of a burial.
(c) The State Archaeologist, in consultation with the professional archaeologist excavating the remains,
shall determine where the remains shall be held subsequent to excavation, pending other arrangements according to
G.S. 70-32 or 70-33.
(d) The Department of Cultural Resources may obtain administrative inspection warrants pursuant to the
provisions of Chapter 15, Article 4A of the General Statutes to enforce the provisions of this Article, provided that
prior to the requesting of the administrative warrant, the Department shall contact the affected landowners and
request their consent for access to their land for the purpose of gathering such information. If consent is not granted,
the Department shall give reasonable notice of the time, place and before whom the administrative warrant will be
requested so that the owner or owners may have an opportunity to be heard. (1981, c. 853, s. 2; 2007-484, s. ]0(d).)
§ 70-32. Consultation with the Native American Community.
(a) If the professional archaeologist determines that the human skeletal remains are Native American, the
State Archaeologist shall immediately notify the Executive Director of the North Carolina Commission of Indian
Affairs. The Executive Director shall notify and consult with the Eastern Band of Cherokee or other appropriate
tribal group or community.
(b) Within four weeks of the notification, the Executive Director shall communicate in writing to the State
Archaeologist, the concerns of the Commission of Indian Affairs and an appropriate tribal group or community with
regard to the treatment and ultimate disposition of the Native American skeletal remains.
(c) Within 90 days of receipt of the concerns of the Commission of Indian Affairs, the State Archaeologist
and the Executive Director, with the approval of the principal tribal official of an appropriate tribe, shall prepare a
written agreement concerning the treatment and ultimate disposition of the Native American skeletal remains. The
written agreement shall include the following:
(1) Designation of a qualified skeletal analyst to work on the skeletal remains;
(2) The type of analysis and the specific period of time to be provided for analysis of the skeletal
remains;
(3) The timetable for written progress reports and the final report concerning the skeletal analysis
to be provided to the Slate Archaeologist and the Executive Director by the skeletal analyst;
and
(4) A plan for the ultimate disposition of the Native American remains subsequent to the
completion of adequate skeletal analysis.
If no agreement is reached within 90 days, the Archaeological Advisory Committee shall determine the terms of
the agreement. (1981, c. 853, s. 2; 2007-484, s. 10(e).)
§ 70-33, Consultation with other individuals.
(a) If the professional archaeologist determines that the human skeletal remains are other than Native
American, the State Archaeologist shall publish notice that excavation of the remains has occurred, at least once per
week for four successive weeks in a newspaper of general circulation in the county where the burials or skeletal
remains were situated, in an effort to determine the identity or next of kin or both of the. deceased.

(b) If the next of kin are located, within 90 days the State Archaeologist in consultation with the next of kin
shall prepare a written agreement concerning the treatment and ultimate disposition of the skeletal remains. The
written agreement shall include:
(1) Designation of a qualified skeletal analyst to work on the skeletal remains;
(2) The type of analysis and the specific period of time to be provided for analysis of the skeletal
remains;
(3) The timetable for written progress reports and the final report concerning the skeletal analysis
to be provided to the State Archaeologist and the next of kin by the skeletal analyst; and
(4) A plan for the ultimate disposition of the skeletal remains subsequent to the completion of
adequate skeletal analysis.
If no agreement is reached, the remains shall be handled according to the wishes of the next of kin. (1981, c.
853, s. 2; 2007-484, s. I0(f).)
§ 70-34. Skeletal analysis.
(a) Skeletal analysis conducted under the provisions of this Article shall only be accomplished by persons
having those qualifications expressed in G.S. 70-28(5).
(b) Prior to the execution of the written agreements outlined in G.S. 70-32(c) and 70-33(b), the State
Archaeologist shall consult with both the professional archaeologist and the skeletal analyst investigating the
remains.
(c) The professional archaeologist and the skeletal analyst shall submit a proposal to the State
Archaeologist within the 90 -day period set forth in G.S. 70-32(c) and 70-33(b), including:
(1) Methodology and techniques to be utilized;
(2) Research objectives;
(3) Proposed time schedule for completion of the analysis; and
(4) Proposed time intervals for written progress reports and the final report to be submitted.
(d) If the terms of the written agreement are not substantially met, the Executive Director or the next of kin,
after consultation with the State Archaeologist, may take possession of the skeletal remains. In such case, the State
Archaeologist may ensure that appropriate skeletal analysis is conducted by another qualified skeletal analyst prior
to ultimate disposition of the skeletal remains. (1981, c. 853, s. 2; 2007-484, s. I0(g).)
§ 70-35. Disposition of human skeletal remains.
(a) If the skeletal remains are Native American, the Executive Director, after consultation with an
appropriate tribal group or community, shall determine the ultimate disposition of the remains after the analysis.
(b) If the skeletal remains are other than Native American and the next of kin have been identified, the next
of kin shall have authority concerning the ultimate disposition of the remains after the analysis.
(c) If the State Archaeologist has received no information or communication concerning the identity or next
of kin of the deceased, the skeletal remains shall be transferred to the State Archaeologist and permanently curated
according to standard museum procedures after adequate skeletal analysis. (1981, c. 853, s. 2; 2007-484, s. ]0(h).)
§ 70-36. Financial responsibility.
(a) The provisions of this Article shall not require that the owner of the land on which the unmarked human
burials or human skeletal remains are found, bear the cost of excavation, removal, analysis or disposition.
(b) If a determination is made by the Executive Director, in consultation with an appropriate tribal group or
community, that Native American skeletal remains shall be reintered following the completion of skeletal analysis,
an appropriate tribal group or community may provide a suitable burial location. If it elects not to do so, it shall be
the responsibility of the North Carolina Commission of Indian Affairs to provide a suitable burial location.
(c) The expense of transportation of Native American remains to the reburial location shall be borne by the
party conducting the excavation and removal of the skeletal remains. The reburial ceremony may be provided by an
appropriate tribal group or community. If it elects not to do so, the reburial ceremony shall be the responsibility of
the Commission of Indian Affairs. (1981, c. 853, s. 2.)
§ 70-37. Prohibited acts.
(a) No person, unless acting under the provisions of G.S. 130-198 through G.S. 130-201, shall:
(1) Knowingly acquire any human skeletal remains removed from unmarked burials in North
Carolina after October 1, 1981, except in accordance with the provisions of this Article;
12

(2) Knowingly exhibit or sell any human skeletal remains acquired from unmarked burials in
North Carolina; or
(3) Knowingly retain human skeletal remains acquired from unmarked burials in North Carolina
after October 1, 1981, for scientific analysis beyond a period of time provided for such
analysis pursuant to theprovisions of G.S. 70-32, 70-33 and 70-34, with the exception of
those skeletal remains curated under the provisions of G.S. 70-35.
(b) Other provisions of criminal law concerning vandalism of unmarked human burials or human skeletal
remains may be found in G.S. 14-149. (1981, C. 853, s. 2.)
§ 70-40. Penalties.
(a) Violation of the provisions of G.S. 70-29 is a Class 1 misdemeanor.
(b) Violation of the provisions of G.S. 70-37(a) is a Class H felony. (1981, c. 853, s. 2; 1993, c. 539, s. 543;
1994, Ex. Sess., c. 24, s. 14(c).)
13

Figure 1. Proposed Washburn Switch Business Park location in Cleveland County, North Carolina.
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50101 Governor's Drive
Suite 250
Chapel Hill, NC 27517
919.530.8446 PHONE
919.530.8525 FAX
www.TRCsolutions.com
January 30, 2015
Ms. Kristin Fletcher
Cleveland County Economic Development Partners
1800 East Marion Street
Shelby, North Carolina 28152
Re: Letter Report, Additional Cemetery Investigations at the Proposed Washburn Switch Business Park,
Cleveland County, NC
Dear Ms. Fletcher:
TRC Environmental Corporation (TRC) has completed additional background research and field
investigations concerning the cemetery at the proposed Washburn Switch Business Park in Cleveland
County, North Carolina. This research was conducted as a follow-up to initial research completed in 2011
(Webb 2011), which had suggested that the cemetery shown on USGS topographic maps (USGS 1950,
1983) might represent a 10 century cemetery associated with the McCombs family.
The present work included additional background research and fieldwork, which were conducted
concurrently. It was confirmed at the beginning of the fieldwork (through the discovery of displaced
grave markers) that the McCombs Cemetery was present on the property. The subsequent fieldwork
identified six apparent graves at the cemetery site, and the background research confirmed the McCombs
family association and provided additional information on the interred individuals.
PREVIOUS RESEARCH
Initial indications that a cemetery might be present on the proposed development tract were provided by
USGS topographic maps (USGS 1950, 1983), which show a cemetery situated in the approximate center
of the tract, north of an east -west trending dirt road (Figure 1). Based on its location, the cemetery was
believed to possibly represent the Major McCombs Graveyard, which was recorded by WPA workers as
part of the Historical Records Survey of North Carolina in 1938 (http://digital.ncdcr.gov/cdm/compound
object/collection/pl50l2coill/id/36296/ree/19; McEntire 1986; Propst and Hartshorn 2008). As
transcribed by Propst and Hartshorn (2008), the survey data read:
MAJOR MCCOMBS GRAVEYARD
Located in No. 7 Township, Cleveland County, NC this cemetery is about six miles northwest of
Shelby, NC; about 400 yards east of Shelby -New House Road on a hill dotted with pines and oaks
and being relatively small in dimension; also about 300 yards east of the old Bate Blanton place or
residence.
Owner of cemetery: Bate Blanton

Approximate number of marked graves: [Omitted; should read 51
Before 1914: 5
After 1914: None
Unmarked graves: None
General condition of cemetery: Neglected.
Date of survey: Nov. 9, 1938
Workers: B. E. Weathers and A. G. Melton
Inscriptions:
McCombs, Major
(Bom in Va., 1738. See U.S. Census 1850 Cleveland Co.)
McCombs, Mary Ann, wife of Major McCombs (B. 1783 in N.C. See U.S.C.)
McCombs, Nancy [sic] Fronia, daughter of Major and Mary Ann. McCombs (Bom 1827 in N.C.
See U.S. Census 1850, Cleveland County.)
McCombs, Hulda Ann, daughter of Major and Mary Ann McCombs (Bom 1820 in N.C. See U.S.
Census, Cleveland County.)
McCombs, Andrew, son of Major and Mary Ann McCombs
(The above names occur on marble slabs with absolutely no dates given. The data in parenthesis
taken from U.S. Census of Cleveland County. Worker, Anson G. Melton.) (Collis Jones said that it
was generally known that Molly McCombs, wife of Major McCombs, was a witch.)
The location described fits well with the mapped cemetery location, and is also compatible with a
"McCombs" notation shown on an 1886 Cleveland County map (Kyzer 1886); in addition, there are no
indications from other records that the McCombs graveyard is presently known at another location. Aerial
photographs demonstrated that the cemetery area was in pasture (or cultivation) as recently as the 1940s,
but that most of the area was then (in 2011) in planted pines.
An initial field inspection conducted in 2011 identified the likely cemetery location as in or adjacent to a
clearing within the pines north of the dirt road, but failed to identify any obvious indications of a
cemetery at that location (Webb 2011).
BACKGROUND RESEARCH
The present work began with additional background research, which included deed research to
supplement post -1970 chain -of -title information provided by Cleveland County as well as on-line
genealogical research. That research was successful in associating the McCombs family with the
property, and also provided additional information on the family members buried there. The following
paragraphs summarize the results of that research.
According to on-line genealogical data, Major McCombs ("Major" was his name, not a rank) was born in
Virginia about 1783 and had presumably married Mary Ann Hogue by about 1802, when the first of their
children was born. 11 is not evident when Major and Mary Ann McCombs moved to what is now
Cleveland County, but census records indicate he lived in the area by 1800. He reportedly bought land on
Brushy Creek in what was then Rutherford County (presumably including the present tract) from his
brother Sheldrake McCombs in 1829, and appears as a Rutherford County resident on the 1800-1840
Federal censuses; Major and Mary Ann McCombs are listed as residing in Cleveland County on the 1850
and 1860 censuses.

Major and Mary Ann McCombs had at least eight children, as listed below. (The following data have
been compiled from family genealogical information and census records available on www ancestry.com,
and supplemented by cemetery data from the WPA records and www.findagrave.com. The emphasis in
the research was in determining if there were any indications of additional individuals who might have
been buried in the Major McCombs Graveyard beyond those specified above. Birth dates for several of
these children are given differently in different sources, and all dates may vary slightly from those given
here.)
1. Cynthia (1802-1875). Cynthia McCombs married Bill Smith, and is buried at Beaver Dam Baptist Church,
Shelby, North Carolina.
2. Elizabeth "Betsey" (1806-1860). Elizabeth McCombs married Martin Elliott.
3. Milton A. (1808-1881). Milton A. McCombs married Rachel (last name unknown), and died in Arkansas.
4. Huldah Ann (1814-1868). According to family records, Huldah Ann McCombs may have married Burgess
McEntire. She is buried in the Major McCombs Graveyard.
5. Sarah "Sallie" (1815-1880). Sarah McCombs married Street Harrill (and lived next door to the property in
1880). She is recorded as buried in the "Street Harrill Old Cemetery" in WPA records, but
www.findagrave.com indicates that she is buried at Double Springs Baptist Church, Shelby.
6. Mary Ann (1816-1906). Mary Ann married Jonathan N. Gardner, who died in 1849; she is buried at Zion
Baptist Church, Shelby.
7. Andrew M. (1820-1900+). (Born Nov. 1815 per 1900 census). Andrew apparently married Sarah E.
Starner in 1858. She may have died in 1859 or 1860, as he was apparently living alone and away from his
parents in 1860. He is listed as a widower in the 1900 census, and died between 1900 and 1910. He is
buried in the Major McCombs Graveyard.
8. Nancy Sephronia (1827-1910+). (Bom May 1819 per 1900 census). Nancy McCombs never married. She
died between 1910 and 1920, and is buried in the Major McCombs Graveyard.
Major McCombs appears in the 1850 Federal census as a 67 -year old farmer, living with his wife Mary
A., daughter Nancy S., and son Andrew, and possessing real estate valued at $1200. That year he reported
owning 12 slaves aged from less than one year to 22. In 1860 the Major McCombs household consisted of
three members: Major, Mary A., and Nancy S.; Andy McCombs appears living separately in Cleveland
County. Major McCombs did not report owning slaves in 1860, although Andy McCombs reported
owning 13 slaves aged from less than one year to 30.
The first examined deed tying the McCombs family to the land is dated June 12'", 1866, and records the
transfer of a tract containing "one hundred acres more or less" from Major McCombs to Andrew
McCombs as trustee for Major McCombs's daughter Nancy Sophrona McCombs (see Table 1 for a listing
of all deed references). By that time Mary Ann McCombs was apparently deceased. Major McCombs was
also near death in 1866, as his will (dated May 1840) was probated in Cleveland County in February
1867. The will provides a variety of bequests to Andrew, Mary Ann, and his son Milton as guardian for
his daughter Cynthia Smith (whose husband was presumably deceased). The will also directs his
executors (Mary Ann, Milton, and Andrew) to provide him a "decent burial suitable to the wishes of my
relatives and friends," but gives no instructions concerning the location.
The 1870 census records two McCombs families living on or adjacent to the tract. Andrew McCombs is
listed as a farmer, living with his sister Nancy. The second McCombs family is headed by Tilda, who is
35 and described as black, and six presumed family members aged from six to 13. The oldest two, Caleb
and Alice, are listed as black; the youngest four, Bennie, Love (?), Cicero, and Martha, are listed as
mixed -race. (Matilda McCombs died in January 1889, and according to WPA records is buried in the
Shelby City Cemetery).
In 1880 Andrew and Nancy McCombs continue to reside together, adjacent to what appear to be two
African-American McCombs households. There are no 1890 census records available.

The next transfer of the property occurred on February 10, 1894, when A.M. and N.S. McCombs deeded
the land to Cicero A. McCombs. (Cicero McCombs was as an eight-year-old living on the property in
1870, but was apparently living in York County, South Carolina in 1880 with his wife Martha). Key
portions of the deed read:
This deed made this the 10' day of February 1894, between A.M. McCombs and N.S.
McCombs of the first part and Cicero A. McCombs of the second part, all of the County
of Cleveland and State of North Carolina- Witnesseth that the said parties of the first part
for and in consideration of the sum of five dollars in hand paid by the said party of the
second part, the receipt whereof is hereby acknowledged and in consideration of the care
and support of the parties of the first part by the party of the second part, by furnishing to
the parties of the first part suitable and necessary board, clothing, shelter, medical
attention, nursing etc. during life and at the death of each a suitable and decent burial, and
in further consideration that the said parry of the second part shall put at the grave of the
said parties of the first part and of Major McCombs, and wife Mary McCombs, Huldah
McCombs and Mary Ann Gardner in case the latter is buried in the family burial of the
McCombs [sic] suitable stones to mark the grave or burial place of each, have given,
granted, bargained, sold, conveyed and confirmed, and by these presents do give, grant,
bargain, sell, convey and confirm unto the said party of the second part his heirs and
assigns forever all the following described piece or parcel of land, lying and being in No.
7 Township Cleveland County State of North Carolina known and designated as follows
The 1900 census lists Cicero McCombs as head of a family including his wife Martha and eight children;
other residents in the household include a servant (Frank Blanton) and two boarders, Andrew and Nancy
McCombs. Andrew McCombs apparently died sometime between 1900 and 1910; the 1910 census shows
Nancy S. McCombs as the only boarder in the Cicero McCombs household.
Nancy McCombs apparently died sometime between 1910 and 1917, as on March 15, 1917 Cicero and
Martha McCombs sold the property to F.B. (Forest Bate) Blanton and his wife E.V. Blanton. A plat
drawn in 1936 and based on that survey shows a residence on the property, but does not depict a
cemetery. In 1942 F. Bate and Erie Blanton transferred the property to C. Robert and Elizabeth Blanton,
who owned it until 1970. The land remained in the extended Blanton family until 1984, when it was sold
to Wyatt W. and Brenda H. Dellinger. With the exception of the reference in the 1894 deed, there are no
references to a cemetery in any of the deeds.
After selling the land, Cicero and Martha McCombs moved to Palmyra, New Jersey, where they appear in
the 1920 and 1930 censuses.
FIELDWORK
Fieldwork was conducted at the property on January 12 and 19-22, 2015, by Michael Nelson, John
Kesler, and Paul Webb. The initial visit was conducted on January 12 by Nelson and Webb, and was
intended to determine current conditions and discuss details of the proposed field methods; it was
followed by more intensive investigations by Nelson and Kesler from January 19-22.

Initial Reconnaissance
The initial reconnaissance focused on an area north of the dirt road and west of a former clearing, which
constituted the highest part of the east -west trending ridge and also the site of a single tree visible on a
1937 aerial photograph (Figure 2). Based on this data, the cemetery was considered likely to be situated
within a 50 -foot north -south by 100 foot east -west area centered on UTM coordinates E445357
N3908524 (NAD 83). That area (along with the rest of the ridge) was found to have been recently
timbered and was littered with debris; it was also crossed by a recent scraped area exposing the subsoil
(Figure 3).
Initial inspection of the area encountered a small fragment of cut stone resembling a footstone (grave
marker), supporting the assumption that this was the likely cemetery location. A walkover survey was
then conducted over the remainder of the landform, but no additional indications of graves were
observed.
The surveyors then conducted a brief reconnaissance along the dirt road to the east and west to
determine if any other potential cemetery areas were present. Approximately 630 feet (ft) to the east of
the presumed cemetery location, a cut marble headstone base was observed in a small push pile
(apparently dating to the time when the pines were planted) on the north side of the access road (Figure
4). After further investigation, two other headstones were found buried in the push pile, including a
complete (but broken) marble headstone (Figure 5). After it was uncovered, that headstone (Figure 6)
proved to be engraved "NANCY FRONIA—Daughter of—MAJOR & MARY ANN MCCOMBS.
Subsequent inspection also revealed a third partial marker fragment engraved "MAJOR." The push pile
was not systematically explored, however, and it is likely that additional markers or fragments are
present.
Subsequent inspection along the base of the landform also revealed a fourth and smaller headstone base
(Figure 7), which was found approximately 330 ft north of the first push pile. The base was found
partially buried on the surface, not in an obvious push pile, but surrounded by other stones and historic
debris, including cinderblock fragments and unidentified metal fragments.
Delineation Fieldwork
The cemetery delineation methods were developed based on the historical date concerning the
cemetery, as well as knowledge of typical 19" to early 201h century rural cemeteries. The historical
record confirmed that the graves of at least five adults were present, which could be assumed to
measure at least 5-6 ft in length. The graves were assumed to be oriented east -west, as is typical of
Christian burials (Clauser 1994). Finally, it was assumed that the earthen fill within each pit would be
mottled and softer and less compact than the surrounding subsoil, and thus would be identifiable
through probing and/or mechanized topsoil stripping.
The fieldwork began with the establishment of multiple transects running north -south across the narrow
east -west trending ridge, beginning at the dirt road and extending north -south to the beginning of the
slope. The transects measured roughly 43 to 69 ft long and were spaced 4 ft apart. Probing (using a 3/8
inch diameter metal probe) was then conducted at two -foot intervals along the transects to search for
less compact soil that might represent grave shafts. A total of 22 transects were probed across the
landform, but only 11 locations with possible softer soil were identified. Closer interval probing was
conducted around the areas of soft loose dirt, but no rectangular anomalies that might represent graves
were identified.

Following the probing, mechanized stripping was conducted using a backhoe and operator (Gary Head)
provided by Cleveland County. The backhoe was equipped with a 38 -inch -wide smooth blade attached
to a three foot bucket. Trenches were opened up at 3-4 ft intervals along a north -south direction,
approximately following the original probing transects. A total of 16 trenches were opened to up to I I
inches below the ground surface to search for evidence of grave shafts, but no obvious shafts were
identified (Figure 8). Seven more footstone fragments were recovered during the trenching, however,
providing additional confirmation that the cemetery was situated at this location. Three footstone
fragments had engraved letters, one with M.A.M. (Mary Ann McCombs) and two that refit with
H.A.M. (Hulda Ann McCombs); two other stones had a horizontal line engraved across the short
section, while three stones had no discernible markings. In total, four of the stones refit to represent two
separate footstones. These footstone fragments were all found in disturbed contexts at the surface or
just below the surface, and most were located within 9 ft of one other.
Given the high density of footstone fragments within a relatively concentrated area in the area between
Trenches 4 to 8, it was decided to continue the mechanized stripping in this general area by removing
the strips of soil between the trenches. After two and half days of mechanized stripping, a small area of
heavily mottled slightly less compact soil was identified along the west side of a large pine stump. This
stain was smaller than anticipated, however, and measures only about 4.25 ft long and 2 ft wide (Figure
9). The apparent pit (subsequently identified as Grave 6) was rectangular in shape and oriented east -
west, however, and is believed to likely represent the grave of a child.
After continued stripping in the area, a total of six apparent grave were uncovered (Figure 10). Just
about 3 ft east of the small apparent grave, a row of five rectangular very faint and heavily mottled soil
stains oriented east -west were uncovered. Those stains were numbered Graves 1-5, starting with the
northernmost stain, while the single smaller graveshaft to the west was designated Grave 6. While most
of the stains contained very mottled faint fill with obvious edges, the edges of the southernmost stain
(Grave 5) were difficult to identify and could only be approximately defined by the probing.
Grave 1 is the northernmost stain and is located approximately 43 ft from the north edge of the dirt
road. It is the best defined stain and measures almost 8 ft long and just over 3 ft wide (Figure 11).
Grave 2 is located approximately 2.5 ft south of Grave I and is also relatively well defined. It measures
7.5 ft long by almost 3 ft wide (Figure 12). Grave 3 is located about 2 ft south of Grave 2. It is very
faint and not very well defined, but based on probing and the visible fill, it is approximately 8 ft long
by roughly 3.25 ft wide. Grave 3 is the largest of the six identified graveshafts (Figure 13).
At 3 to 4.5 ft, the distance between Graves 3 and 4 is the widest gap between identified graves. Grave 4
has well defined edges and three identifiable comers, but the southwest corner could not be defined due
to a large stump disturbance. The smaller pit (Grave 6) is located approximately 32 inches west of
Grave 4. Grave 5 is the southernmost grave identified and is located approximately 26.5 ft north of the
edge of the access road. It is poorly defined with no clear edges discernible from the fill, however
based on the probing, a roughly 6 ft long by 2.75 to 3.5 ft wide grave was identified (Figure 14).
An area ranging from 15 to 30 ft around the identified grave was stripped and examined to search for
additional potential graves, but none was found. Consequently, it is believed that these six graves are
the only graves located at the Major McCombs Graveyard.

Summary
In summary, six apparent graves were identified at the Major McCombs Graveyard. Although surface
indications of a cemetery at the location were scant, with just a single small footstone fragment visible,
subsequent mechanized stripping identified seven more cut stone footstone fragments (including some
with initials of McCombs family members), as well as six apparent graveshafts. The five largest graves
are situated in a row and almost certainly represent the five McCombs family members known to be
buried here; the identity of individual in the sixth apparent grave is unknown, but it likely that of a
child related to the McCombs family.
The reconnaissance confirmed that the McCombs Graveyard was situated on the property, but that the
headstones had been removed from their original location, probably in connection with preparation of
the ground for tree planting. Fragments of at least three different headstones were identified in
disturbed contexts situated along the eastern edge of the former pine plantation and from 590 to 690 ft
northeast and east of the cemetery, where they were deposited during former land clearing activities. At
least two of those stones are definitely those of McCombs family members, and it is likely that all five
of the historically referenced markers are situated in that general area.
SUMMARY AND RECOMMENDATION
The investigations were successful in confirming the location of the McCombs family cemetery at the
proposed Washburn Switch Business Park in Cleveland County. A total of six apparent graves are
present, five of which represent the historically described graves of Major, Mary Ann, Huldah Ann,
Andrew, and Nancy S. McCombs. These interments appear to date from about 1860 to about 1917. The
headstones that were apparently placed to mark these graves in 1894 or later, and which were recorded in
1938, were removed during past land clearing activities and have been deposited in at least two locations
to the east and northeast. The identity of the sixth interment is unknown, but it likely represents the grave
of a McCombs family member. Based on the historical descriptions, that grave was apparently unmarked
and not readily discernable in 1938.
As previously noted, the Major McCombs Graveyard is protected by North Carolina General Statutes
(G.S) 14-148, Defacing or desecrating grave sites, and 14-149, Desecrating, plowing over or covering
up graves; desecrating human remains. In the event that the cemetery cannot be preserved in place, we
recommend that the graves be removed in accordance with G.S. 65-106, Removal ofgraves, or G.S. 70
Article 3, the Unmarked Human Burial and Human Skeletal Remains Protection Act.
We appreciate the opportunity to work with you on this project and look forward to continuing to work
with you in determining the appropriate treatment of the cemetery and grave markers. Please do not
hesitate to contact me at [phone] or [e-mail] if you would like additional
information or have any questions or comments about this report.
Sincerely,
Paul A. Webb Michael Nelson
Cultural Resource Program Leader Archaeologist, Asheville

REFERENCES CITED
Kyzer, Paul B.
1886 Complete Map of Cleveland County, North Carolina. On file, North Carolina State Archives, Raleigh.
McEntire, Russell
1986 WPA Cemetery Records for 1939, Cleveland County, North Carolina. Privately Published,
Weaverville, North Carolina.
Propst, Ann K., and Derick S. Hartshorn
2008 Cleveland County WPA Cemeteries CD. Privately published. http://www.hartshom.us/CWPA.htm.
United States Geological Survey (USGS)
1950 Shelby, North Carolina. 1:62,500 scale.
1983 Shelby, North Carolina. 1:24,000 scale.
Webb, Paul A.
2011 Letter Report, Cultural Resources Background Research and Limited Field Reconnaissance for the
Proposed Washburn Switch Business Park, Cleveland County, North Carolina. TRC Environmental
Corporation, Chapel Hill. Submitted to Clearwater Environmental Consultants, Hendersonville.

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50101 Governor's Drive
Suite 250
Chapel Hill, NC 27517
919.530.8446 PHONE
919.530.8525 Fax
www.TRCsolutictis.com
March 23, 2015
Mr. Kristin Fletcher
Cleveland County Economic Development Partners
1800 East Marion Street
Shelby, North Carolina 28152
Re: Letter Report, McCombs Graveyard (31CL128) Removal at the Proposed Washburn Switch
Business Park, Cleveland County, NC
Dear Ms. Fletcher:
TRC Environmental Corporation (TRC) has completed the excavation and removal of all graves associated
with the McCombs Graveyard (archaeological site 31CL128) at the proposed Washburn Switch Business
Park in Cleveland County, North Carolina. The graves were removed in accordance with North Carolina
General Statute (G.S.) 70 Article 3, the Unmarked Human Burial and Human Skeletal Remains
Protection Act. The fieldwork for this project was conducted on March 2-6, 2015. TRC Bioarchaeologist
Sean Norris, M.A., RPA directed the work, and TRC Archaeologist Michael Nelson and Archaeological
Technician Laurie Griesmer completed the excavation team. All material removed from the graves and
the associated tombstone fragments have been transferred to Cleveland County for temporary storage
prior to reburial.
The McCombs Graveyard is located on the east side of Washburn Switch Road approximate 4.0 miles
northwest of the town of Shelby (Figure 1). It is situated on a recently clear cut ridgetop. An examination
of USGS topographic maps (USGS 1950, 1983) first indicated that a cemetery was once present within on
the tract, and background research suggested that the cemetery was the Major McCombs Graveyard
(Webb 2011). Major McCombs ("Major" was his name, not a rank) was born in Virginia in 1783. By
1802 he had moved to what is now Cleveland County and married Mary Ann Hogue. Major and Mary
Ann McCombs had at least eight children. The records indicate that three of the children, Huldah Ann
(1814-1868), Andrew M. (1820-1900+) and Nancy Sephronia (1827-1910+), are interred in the Major
McCombs Graveyard. The cemetery was recorded by WPA workers as part of the Historical Records
Survey of North Carolina in 1938. The WPA workers documented five marked graves and no unmarked
graves (http://digital.ncdcr.gov/cdm/compoundobject/collection/pl5012co111/id/36296/rec/19);
(http://www.ncgenweb.us/cleveland/cemeteries/Major—McCombs_Graveyard.txt; McEntire 1986; Propst
and Hartshorn 2008).
PREVIOUS INVESTIGATIONS
An initial field inspection conducted in 2011 identified the likely cemetery location as being in a stand of
planted pines adjacent to the north side of the dirt road that provided access to the Washburn Switch
Business Park property. That investigation failed to identify any obvious indications of a cemetery at that
location (Webb 2011). In January 2015 additional reconnaissance investigations and subsequent cemetery

delineation took place (Webb and Nelson 2015). The initial reconnaissance focused on ridge where USGS
topographic maps, a 1937 aerial photograph (Figure 2) and the 2011 investigation suggested the presence
of a cemetery. An initial reconnaissance found a marble footstone fragment at that location, and
pedestrian survey along a dirt road that runs east -west along the ridgeline identified a cut marble
headstone base and two headstones in a push pile, including a complete (but broken) marble headstone
inscribed NANCY FRONIA—Daughter of—MAJOR & MARY ANN MCCOMBS" (Figure 3).
Additional fieldwork was then conducted to identify the actual cemetery location. Systematic probing
and mechanized trenching and stripping were utilized to search for evidence of grave shafts. Seven
footstone fragments were recovered during the trenching, and six rectangular shaped features believed
to be graves were identified (Figure 4). The topsoil was removed from the area surrounding the features
to determine if any undocumented graves were present, but no additional soil anomalies were
encountered. Consequently, it was believed that these six apparent grave features represented the only
burials at the Major McCombs Graveyard (Webb and Nelson 2015).
The features were marked, their GPS locations were recorded and they were covered with protective
plastic sheeting and reburied. After consultation with the North Carolina Office of State Archaeology it
was determined that excavation of the grave -like features should take place. It was recommended that if
human graves were identified during excavation, then those graves should be removed in accordance with
North Carolina G.S. 70 Article 3.
Prior to the fieldwork, TRC attempted to contact seven family members identified through research on
www.ancestrV.com. Three family members responded expressing varying degrees of support for the
proposed removal, while a fourth did not respond in detail. Three other individuals contacted did not
respond. Detailed information on the contacts was provided in an email to Cleveland County and the
State Archaeologist on February 24, 2015; no additional family contacts have been made to date.
CEMETERY EXCAVATION
On March 3, 2015, TRC archaeologists, with the aid of a backhoe and operator provided by Cleveland
County, removed the layer of backfill that was placed over the graves after their January 2015
discovery. Once the protective plastic sheeting was encountered backhoe operations were temporarily
halted until the plastic was removed and the six features were relocated. The backhoe was then used to
slowly remove the overburden from atop each grave. Periodic soil probing of the features directed the
backhoe until the grave fill was removed to within six inches or less of each potential burial. Due to the
differential burial procedures the overburden above each grave ranged from approximate three feet
(below ground surface) for Grave 1 to nearly six feet of soil for Grave 5. The remaining grave fill was
removed by hand, and standard archaeological methods and tools were used to carefully expose and
identify artifacts and remains in each burial. Once the graves were identified the area surrounding the
burials was stripped of topsoil to determine if any previously unidentified features were present. No
additional graves were located.
The presence of human graves at the site was confirmed in the early afternoon of March 3. The State
Archaeologist was notified via phone and email, and was kept informed of the subsequent progress.
A thorough description of each burial was recorded in the field using a standardized burial data form.
These forms include fields for recording information on the burial type, deposition/orientation, burial
dimensions, grave type, grave dimensions, preservation, evidence of disturbance, fill characteristics,
associations, sex, and general comments.

Grave 1
Coffin Type: Rectangular
Orientation: Head to the west
Shaft Dimensions: 90 x 38 inches
Burial Dimensions: 76 x 22 inches
Presumed Individual: Andrew McCombs (1820-1900+)
Grave 1 is the northernmost feature in the cemetery. It was first identified as a rectangular shaped feature
measuring 90 inches east—west by 38 inches north—south. Mechanical stripping and hand excavation
revealed a burial depression at the base of the grave shaft. The burial depression, based on the location of
artifacts, is believed to conform to the size of the coffin. The burial depression was roughly rectangular in
shape and measured 76 inches east—west by 22 inches north—south (Figure 5).
Excavation of the burial depression identified coffin hardware, coffin decorations and clothing related
artifacts. No skeletal fragments were present. Six swing bail handles (three to a side) were recovered. The
handles were connected to two lugs, or plates, that were in turn connected to the coffin. The lugs of each
handle bore an oak leaf and acom motif (Figure 6). The handles themselves are decorated with a floral
tendril pattern along the centerline. Four thumbscrews with associated escutcheon plates were also
present. The screws are iron with a flat white metal or alloy head. Two large thumbscrews have a flat
head with a sunburst or blossom motif (Figure 7). The two smaller thumbscrews exhibit a fanning leaf-
like, almost fleur de lis design. Twenty two (likely wire) nails were also recovered.
In addition to the decorative handles and thumbscrews, two other pieces of coffin decoration were
recovered. Near the center of the coffin was a white metal, "banner style" plaque reading "At Rest"
(Figure 8). An oval shaped, plate glass view window was present on the coffin. Personal artifacts
recovered from the burial include four large, metal (formerly cloth covered) buttons with shank
attachments, one medium size, white porcelain, four hole, Prosser molded button and one small, white
porcelain, four hole, Prosser molded button.
During the late nineteenth and early twentieth century the United States experienced a `Beautification of
Death" movement (Bell 1990: 54). This popular movement sought to use rituals and materials to idealize
death and memorialize the dead. During this time mass produced coffin hardware and decorations became
widely available. The swing bail handles from Burial 1 were popular from the 1850s to the 1910s,
thumbscrews and escutcheons were widely used after 1870 and mass produced plaques came into fashion
after 1878 (Bybee 2002, Glover 2009). Viewing windows were popular from the 1850s to the mid -1920s
(Bell 1990, Bybee 2002).
The coffin hardware and the personal items can be used to date the burial and in tum, support an
assumption about who was buried in this grave. Based on the presence of the thumbscrews and the
plaque, it seems likely that this grave postdates the 1870s, suggesting that it is the grave of either Andrew
McCombs or Nancy McCombs. The presence of four large metal, cloth covered buttons, although not
definitive, are at least suggestive of a man's coat, while the white Prosser buttons, manufactured between
1840 to the mid-1960s (Sprague 2002), are consistent with a dress shirt. Based on this information, it is
considered probable that Grave 1 is that of Andrew McCombs (1820-1900+); additional support for this
interpretation is provided by the presence of small, cloth covered buttons (which might more likely be
associated with women's clothing) in Burial 3 (the other post -1870s adult grave).

Grave 2
Coffin Type: Hexagonal
Orientation: Head to the west
Shaft Dimensions: 90 x 33 inches
Burial Dimensions: 73 x 22 inches
Presumed Individual: Hulda McCombs (McEntire) (1814-1868)
Grave 2 is approximately 30 inches south of Grave 1. During the initial backhoe stripping the feature was
identified as rectangular shaped and measuring 90 inches east—west by 33 inches north—south. At the base
of the rectangular grave shaft a hexagonal grave was burial depression was identified (Figure 9). The
hexagonal burial measures 73 inches in length, 22 inches wide at the widest point and 13 inches wide at
the feet.
Thirty-one cut nails were recovered from this burial. No coffin handles, thumbscrews or other coffin
adomment was present. No skeletal fragments were recovered from this burial. The only personal items
within the grave were four white, porcelain buttons (Figure 10). The buttons are of the four hole, sew
through type with a hobnail rim.
Hexagon or toe -pincher, unadorned coffins were widely used from the sixteenth to the nineteenth century
(Pye 2010). Beginning in the late nineteenth century rectangular, decorated caskets became the norm,
although the hexagonal shape was still widely used into the twentieth century. While there may be
personal reasons for the simplicity of this burial, the lack of ornamentation and the hexagonal shape of the
coffin strongly suggests this is one of the earlier burials at the cemetery. The small decorated buttons
suggest a female was buried in this grave. Given that Nancy Sephronia McCombs is believed to be buried
in Grave 3 and Mary Ann McCombs in Grave 4 (see below), it is likely that Grave 2 is that of Hulda
McCombs (McEntire) (1814-1868).
Grave 3
Coffin Type: Rectangular
Orientation: Head to the west
Shaft Dimensions: 96 x 40 inches
Burial Dimensions: 84 x 28 inches
Presumed Individual: Nancy Sephronia McCombs (1827-1910+)
Grave 3 contains a number of decorative elements. Similar to that of Grave 1, the coffin featured an oval,
glass viewing plate (Figure 11). Rather than swing bail handles, Grave 3 utilized six short -bar handles.
This style of handle is characterized by two arms that are attached to the lugs. A wood or iron bar is
attached between the two arms. The bar is usually covered in plush fabric. The lugs on the short bar
handles have an acorn and oak leaf motif (Figure 12). Four large and four small thumbscrews and
associated escutcheons were recovered from this grave. The thumbscrews exhibit the same decorative
patterns as those of Grave 1. Also similar to Grave 1 was the presence of a plaque, although the plaque
from Grave 3 is heavily corroded. It is rectangular in shape. The word "At" the capital letter "R" can be
discerned indicating that the plaque was a mass produced decoration that read "At Rest" rather than a
personalized marker (Figure 13).
Additional artifacts recovered from the grave include 83 (likely wire) nail/nail fragments, a fragment of
wire that appears to have been part of the casket lining and five small metal, cloth covered buttons. The
buttons were found in the midsection of the grave and were aligned in two parallel rows suggesting a
double breasted garment. In addition to the artifacts small fragments of bone were collected from this
grave. The bone fragments had adhered to the wood on the underside of the coffin plaque. Bone

preservation was very poor throughout the rest of the grave, but an outline of the skeletal remains in the
form of small bone flakes and a darker organic outline was observed. As with the other burials, the soil
from the base of the grave was collected to ensure that every potential fragment of human remains was
recovered.
When first identified the rectangular shaped grave was the largest at the site. It is in a line with Graves 1
and 2, approximated 24 inches south of Grave 2. It measured 96 inches east—west by 45 inches north—
south. The rectangular shaped coffin outline at the base of the grave shaft measured 84 inches east—west
by 28 inches north—south. The rectangular shape of the coffin suggests a later date to the burial, as does
the decorative hardware and viewing plate. The small cloth covered buttons suggest a garment worn by a
female. Based on this information, is believed that Grave 3 is that of Nancy Sephronia McCombs (1827-
1910+).
Grave 4
Coffrt Type: Hexagonal
Orientation: Head to the west
Shaft Dimensions: 81 x 31 inches
Burial Dimensions: 74 x 28 inches
Presumed Individual: Mary Ann McCombs (1783-1860+)
Grave 4 was identified approximately 50 inches south of Grave 3, and was partly obscured by a large tree
stump near the western edge of this grave. At the time of the discovery the grave measured 81 inches
east—west by 31 inches north—south. Being the second deepest grave at the site, approximately five feet of
topsoil was removed before a burial depression and coffin wood was encountered. Similar to Burial 2, a
hexagonal shaped coffin depression was dug into the base of a rectangular grave shaft. This hexagonal
sub -shaft measured 74 inches in length, 28 inches wide at its widest point, and 14 inches across at the
feet.
No skeletal remains were encountered within this grave. Coffin wood, two nail fragments and a coffin
tack were the only artifacts recovered. Grave 6, an infant burial, is immediately west of this grave. Grave
5 is directly south. The size of the grave, the lack of adomment and hexagonal coffin shape support the
notion that this is one of the earlier adult burials in the cemetery. Graves 1, 2 and 3 are believed to be
those of the McCombs adult children (Andrew, Huldah, and Nancy), leaving this grave to be the burial of
either Major or Mary Ann McCombs.
The graves in the McCombs graveyard cemetery are aligned with the heads facing west and the feet
facing east, as is typical of nineteenth to twentieth century Christian burials. Judeo-Christian tradition
states that being buried with one's head to the west will allow the person to rise facing the messiah/savior
as he arrives with dawning sun in the east on judgment day. In this tradition, when a married couple is
buried together the husband is typically buried south of the wife, so that when they rise the wife will be
on his left, in the same position as which they faced the minister/priest/alter on their wedding day. Based
on the assumption that the McCombs family followed this tradition, and based on the nature of the
buttons in adjacent Grave 5, it is likely that this is the grave of Mary Ann McCombs (1783-1860+).

Grave 5
Coffin Type: Hexagonal
Orientation: Head to the west
Shaft Dimensions: unknown
Burial Dimensions: 80 x 24 inches
Presumed Individual: Major McCombs (1783—c. 1867)
Grave 5 is the southernmost grave in the cemetery. At the plowzone level the grave feature is disturbed by
the same large tree stump that partially obscures Grave 4, and the disturbance was such that it was
initially uncertain whether the softer soil observed during probing was due to root activity or an actual
grave. It was not until approximately five feet of soil was removed that the grave became well defined
(Figure 15). This is the deepest grave at the site, with its base approximately six feet below ground
surface. At the base of the excavation a rectangular shaped coffin outline was present. The coffin
measures 80 inches in length and 24 inches in width.
One tooth root fragment was the only skeletal element recovered from this burial. Coffin hardware
consisted of 38 nail fragments and six white metal coffin tacks. Personal items recovered consisted of two
vulcanized rubber, two -hole buttons, three small four hole, white Prosser buttons and one larger four hole,
white Prosser button (Figure 16). The two vulcanized, hard rubber buttons have a manufacture's mark
reading "N.R Co Goodyear s P=T" on the back. These buttons are attributed to the Novelty Rubber
Company out of New York which utilized Nelson Goodyear's patent (P=T) to manufacture vulcanized
rubber goods from 1853 to 1886 (<http://www.vintagebuttons.net/rubber.html).
It is believed that this is the grave of Major McCombs. The rubber buttons suggest a men's coat, and the
date of the button's manufacture is consistent with Major McCombs' death c. 1867. The lack of coffin
adornment also is suggestive of a relatively early burial, and the large size of the coffin, over six and a
half feet in length, is also suggestive of a male. And, as described above, it is common in Christian
tradition for the husband to be buried on south of the wife when graves are oriented with the heads
oriented to the west.
Grave 6
Coffin Type: Hexagonal
Orientation: Head to the east
Shaft Dimensions: 32 x 24 inches
Burial Dimensions: 31 x 13 inches
Individual: Unknown infant
Grave 6 represents an infant or small child. It was not documented during the 1938 WPA survey of the
cemetery, and was apparently unmarked at that time; it is also not referenced in the 1894 deed referring to
the cemetery (Webb and Nelson 2015). The grave is directly adjacent to Grave 4, presumably that of
Mary Ann McCombs, but cannot be firmly associated with any specific family member.
Upon initial discovery the grave appeared as a rectangular feature measuring 32 inches in length by 24
inches in width. At the base of the rectangular grave shaft a hexagonal sub -shaft was excavated in order to
inter a hexagonal shaped coffin. The sub-shaft/burial depression measures 31 inches in length, 13 inches
at its widest and 10 inches at its most narrow point (Figure 17). Five nail fragments were collected from
this grave. No skeletal elements were present.

SUMMARY AND RECOMMENDATION
Six graves were excavated at the McCombs Graveyard located at the proposed Washburn Switch
Business Park in Cleveland County in accordance with North Carolina G.S. 70 Article 3, the Unmarked
Human Burial and Human Skeletal Remains Protection Act. Five of the graves represent the historically
described graves of Major, Mary Ann, Huldah Ann, Andrew, and Nancy S. McCombs. A sixth,
apparently unmarked grave of an infant was also encountered. These interments appear to date from about
1860 to the 1910s, as is suggested by the historical record (Webb and Nelson 2015).
Five headstones were recorded as being present in 1938, but were removed from the cemetery during
prior land clearing activities. Portions of at least three headstones were found deposited in two locations
to the east and northeast of the cemetery, and have been collected. A systematic pedestrian survey, soil
probing in push piles and shovel skimming did not recover any additional headstones.
At the end of the excavation all grave items and soil from the base of each burial was delivered to
Cleveland County for temporary storage until a suitable location for reburial is identified.
We appreciate the opportunity to work with you on this project, and look forward to continuing to work
with you in determining and appropriate treatment of the cemetery and grave markers. Please do not
hesitate to contact Paul Webb at [phone] or pwebb0_tresolutions.com, or Sean Norris at (803)
933-9991 or snorris2tresolutions.com, if you would like additional information or have any questions or
comments about this report.
Sincerely,
( '„ c' t U -
Paul A. Webb
Cultural Resource Program Leader
Sean Norris
Biorchaeologist, Columbia

REFERENCES CITED
Bell, Edward L.
1990 The Historical Archaeology of Mortuary Behavior: Coffin Hardware from Uxbridge, Massachusetts.
Historical Archaeology 24(3):54-78.
Bybee, Alexandra D.
2002 Bioanihropological Investigations of the Reynolds Cemetery (46Ka349) in Kanawha County, West
Virginia. Cultural Resource Analysts, Inc., Hurricane, West Virginia. Prepared for Dr. Robert F. Maslowski,
Huntington District Corp of Engineers, Huntington, West Virginia.
Glover, Amy Suzanne
2009 Coffin It Up: The Influence of Social Status and Ethnicity in an Historic -Era Los Angeles Cemetery.
Society for California Archaeology Proceedings 22:1-7.
Hacker -Norton, D., and M. Trinkley
1984 Remember Man Thou Art Dust: Coffin Hardware of the Early Twentieth Century. Chicora Foundation
Research Series 2. Columbia, South Carolina.
McEntire, Russell
1986 WPA Cemetery Records for 1939, Cleveland County, North Carolina. Privately Published, Weaverville,
North Carolina.
Propst, Ann K., and Derick S. Hartshorn
2008 Cleveland County WPA Cemeteries CD. Privately published. http://Www.hartshom,us/CWPA.htm.
Pye, Jeremy W.
2010 Typology and Analysis of Mortuary Artifacts Recoveredfrom the Excavations in the 20" Century, New
Home Cemetery, Fort Bend County, Texas. University of Florida, Department of Anthropology,
Gainesville, Florida. Report prepared for Geo -Marine, Inc., Plano, Texas.
Sprague, R.
2002 China or Prosser Button Identification and Dating. Historical Archaeology 36(2):111-127.
United States Geological Survey (USGS)
1950 Shelby, North Carolina. 1:62,500 scale.
1983 Shelby, North Carolina. 1:24,000 scale.
Webb, Paul A.
2011 Letter Report, Cultural Resources Background Research and Limited Field Reconnaissance for the
Proposed Washburn Switch Business Park, Cleveland County, North Carolina. TRC Environmental
Corporation, Chapel Hill. Submitted to Clearwater Environmental Consultants, Hendersonville.
Webb, Paul A., and Michael Nelson
2015 Letter Report, Additional Cemetery Investigations at the Proposed Washburn Switch Business Park,
Cleveland County, North Carolina. TRC Environmental Corporation, Chapel Hill. Submitted to Cleveland
County Economic Development Partners, Shelby.

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Figure 8. Plaque recovered from Grave 1.
14

Figure 10. Buttons recovered from Grave 2.
Figure 11. Grave 3 exposed, facing west.
15

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a
Office of State Archaeology
Stephen R. Claggetl State Archaeologist
Governor Pat McCrory Division A Historical Reres
Office of Archives and History
Susan Matte Secretary
o
September 30, 2016
Ms. Kristin H. Reese, Executive Director
Cleveland County Economic Development Partnership
1800 East Marion Street
Shelby, NC 28152
Re: Archaeological Site 31CL128, McCombs Cemetery Relocation, Washburn Switch Business
Park, Cleveland County, ER15-0968
Ms. Reese, thank you for the information that you provided our office regarding the reburial of
human remains from Archaeological Site 31 CL128, (McCombs Cemetery). We are pleased that
this project has been successfully completed and ae satisfied with the resulting outcome. If you
have any comments or questions, please feel free to contact me.
Sincerely
John J. Mintz
Deputy State Archaeologist- Land
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R.dnph NC 21601
19delgh INC 27601

Attachment F
NC DMS Acceptance Letter
(dated December 16, 2016)

I:
Mitigation Services
ENVIRONMENTAL QUALITY
Brian Hoagiund
Clearwater Paper Corporation
601 W. Riverside Ave. Suite 1000
Spokane, WA 99201
Project: Clearwater Paper
PAT MCCRORY
DONALD R VAN DER VAART
December 16, 2016
Expiration of Acceptance: June 16, 2017
County: Cleveland
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to accept
payment for compensatory mitigation for impacts associated with the above referenced project as indicated in the
table below. Please note that this decision does not assure that participation in the DMS in -lieu fee mitigation
program will be approved by the permit issuing agencies as mitigation for project impacts. It is the responsibility
of the applicant to contact permitting agencies to determine if payment to the DMS will be approved. You must
also comply with all other state, federal or local government permits, regulations or authorizations associated with
the proposed activity Including G.S. § 143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the issued 404 Permit/401 CertificationiCAMA permit within this time frame, this
acceptance will expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS
receives a copy of the permit(s) an Invoice will be issued based on the required mitigation in that permit and
payment must be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid by an
applicant is calculated based upon the Fee Schedule and policies listed at http://portal.ncdenr.org/web/eep.
Based on the information supplied by you in your request to use the DMS, the impacts that may require
compensatory mitigation are summarized in the following table. The amount of mitigation required and assigned
to DMS for this Impact is determined by permitting agencies and may exceed the impact amounts shown below.
River CU Location
Basin (8 -digit HUC)
I Stream (feet)
Wetlands (acres)
Buffer I
(Sq. Ft.)
Buffer II
(Sq. Ft.)
Cold
I Cool
Warm I Ri arian I
Non-Ri adan
Coastal Marsh
Broad 03050105 1
0
1 0
L -1,682T
0.12
1 0
0
0
0
Upon receipt of payment, DMS will take responsibility for providing the compensatory mitigation. The mitigation
will be performed in accordance with the In -Lieu Fee Program instrument dated July 28, 2010 and 15A NCAC
02B .0295 as applicable. Thank you for your interest in the DMS in -lieu fee mitigation program. If you have any
questions or need additional information, please contact Kelly Williams at [phone].
cc: Rebekah Reid, agent
Sincerely,
Jam s. Stanfill
Asset anagement Supervisor
SQ¢ afNorth Camli.. Fmironmenlal Quality l Mitigation Screiccs
1652 Mail Scrvkce Cemer I Ralcigh, NC 27699-1652 1 217 W. routs SmSuile 31300
919 707 8976 T