20180364 Ver 1_Cover Letter_20180314

hdrinc.com
440 S. Church Street, Suite 900, Charlotte, NC 28202
T 704.338.6700 F 704.338.6760

March 12, 2018

Mr. David L. Shaeffer
U.S. Army Corps of Engineers
Charlotte Regulatory Office
8430 University Executive Park Drive
Charlotte, NC 28269

Mr. Alan Johnson
N.C. Division of Water Resources
401 & Buffer Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

Subject: Duke Energy Carolinas
Lookout Shoals Embankment Seismic Stability Improvements Project
Section 404 Nationwide Permit 3 (Maintenance)/
Section 401 General Water Quality Certification No. 4085

Mr. Shaeffer & Mr. Johnson,
HDR, on behalf of Duke Energy Carolinas, LLC (Duke Energy), is submitting the attached joint
agency Clean Water Act (CWA) Section 404 Nationwide Permit (NWP)/Section 401 Water
Quality Certification (WQC) Pre-Construction Notification (PCN) for the proposed Lookout
Shoals Embankment Seismic Stability Improvements (ESSI) Project in Catawba County, North
Carolina. A pre-application meeting was held on March 29, 2017 to discuss the proposed project
and associated environmental impacts, and to develop a collaborative permitting strategy.
Meeting participants included representatives from HDR, Duke Energy, the U.S. Army Corps of
Engineers (USACE), and the North Carolina Department of Environmental Quality (NCDEQ)
Division of Water Resources (NCDWR). During the meeting, it was determined that unavoidable
impacts to jurisdictional waters of the U.S. may be authorized under a USACE Nationwide
Permit 3 (Maintenance) and a NCDWR Water Quality Certification (WQC) No. 4085.
Background
The Lookout Shoals Development, which was constructed in 1914-1915, is located on the
Catawba River in Catawba County, approximately 2.5 miles west of Sharon, North Carolina
(Figure 1 and Figure 2). The development consists of a powerhouse structure, concrete gravity
spillway structure, and an earthen embankment dam with two concrete gravity overflow
sections. The existing earthen embankment dam is approximately 89 feet high, 1,200 feet long,
and has upstream and downstream slopes ranging between 2.5- and 3.0-feet horizontal to 1.0-
foot vertical (H:V).
The existing earthen embankment dam section of the Lookout Shoals Development was
determined to be susceptible to liquefaction during a seismic event and is the subject of
remediation for the ESSI Project. The Lookout Shoals embankment dam was constructed using
the semi-hydraulic fill method. This method consists of hauling in and dumping soil from rail cars
or trucks to form containment berms; dumped material is then sprayed with water jets to create
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 2
a soil-water slurry between the berms. W ater percolates through the material, leaving finer-
grained soil between the berms and forming a low-permeability zone within the embankment
(i.e., core). Coarser grained material generally remains deposited near the face of the dam.
Construction by the semi-hydraulic fill method results in an earthen structure that retains a loose
soil matrix and is characterized by a low-density and a low-penetration resistance. Loose soils
that comprise the dam become saturated from normal reservoir water levels and, if subjected to
strong ground motions from a seismic activity, can be susceptible to liquefaction. Liquefaction is
caused by cyclic shaking (i.e. earthquake ground motions) or other rapid loading that increases
the pore pressure between soil particles and results in a significant loss of strength in the soil.
The loss of strength in soils may cause slopes to fail under their own weight immediately after
the earthquake (or other ground motion) and compromise the ability of the dam to retain water
(i.e. dam failure).
Studies from the Lookout Shoals embankment dam submitted to the Federal Energy Regulatory
Commission (FERC) in 2007 and 2014 analyzed the liquefaction potential of the embankment
dam materials and determined that the existing embankment does not meet the FERC-
prescribed minimum safety factor for slope stability under post-seismic conditions.
Improvements to the downstream slope of the existing earthen embankment are required to
meet the minimum safety factor requirement for the post-seismic load case.
Alternative Analyses
Alternative 1 – Stability Berm (Preferred Alternative)
The stability berm remediation alternative, which is the preferred alternative, includes improving
the downstream slope of the existing earthen embankment through excavation and placement
of compacted fill for berm construction.
Ground motions used to design the proposed berm were specified by the FERC. The FERC
required that ground motions from the 2011 central Virginia earthquake, with a moment
magnitude (M) of 5.8 and an unscaled peak ground acceleration (PGA) of 0.26 g, be scaled
down to represent a local earthquake and used in analyses. The representative local
earthquake was given designated as a 5.4 M event with a PGA of 0.16 g. Iterative analyses
were performed to determine the dimensions of a stability berm that would accommodate the
FERC-required ground motions.
Analyses determined that an earthen berm approximately 140 feet wide at a crest elevation of
865 feet above mean sea level (ft msl) with a 2.5:1.0 (H:V) slope placed downstream of the
existing dam would meet the FERC’s minimum post-seismic condition safety factor
requirements. In the event of deformation resulting from liquefaction and failure of the existing
embankment dam slope, the berm geometry would retain sufficient undisturbed embankment
crest width and freeboard to serve as a water-retaining structure, thereby greatly reducing the
risk of total loss. It is anticipated that approximately 340,000 cubic yards of embankment fill
material may be required for construction of the stability berm. Berm construction would
effectively extend the toe of the existing dam approximately 150 feet downstream and would tie
into the existing hillsides (abutments) on either side of the existing dam.
Duke Energy – Lookout Shoals ESSI Section 404/401
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Berm construction support activities will require the development of temporary access roads,
excavated soil spoil areas, material stockpile areas, a borrow area, a construction laydown area,
erosion and sediment control basins, and a permanent transmission line relocation right-of-way.
Alternative 2 – Roller-Compacted Concrete Alternative
The concept of a roller-compacted concrete (RCC) gravity retaining wall at the downstream
slope of the existing Lookout Shoals earthen embankment dam was explored as a possible
alternative for the ESSI Project. The RCC alternative was investigated as a reduced cost option
compared to an earthen stability berm owing to the large quantity of embankment fill material
necessary for construction of a compacted fill berm. If an on-site borrow source could not be
identified, the purchase and transportation of off-site borrow soil to build the stability berm could
potentially exceed the cost of purchasing concrete materials for an RCC gravity retaining wall.
The maximum width cross-section of the dam was used for qualitative comparison of material
quantities between the compacted fill berm alternative and the RCC retaining wall alternative.
The cross-sections were developed using existing ground surface elevations, estimated top of
competent rock elevations, typical foundation excavation requirements, and an assumed RCC
gravity retaining wall geometry. The comparison showed that the RCC retaining wall alternative
was likely to require less soil material than would be required to construct a compacted soil
berm; however, the reduced soil material quantity was not significant enough to offset the
quantity and cost of concrete that would be necessary to construct a n RCC gravity retaining
wall. The assessment of material costs was based on an estimate that the unit price for in-place
concrete in RCC retaining wall construction would be at least five times the unit price of in-place
compacted soil fill berm (i.e. every cubic yard of concrete placed would need to save more than
five cubic yards of compacted soil fill to be cost effective). The assessment concluded that
construction of an RCC retaining wall alternative would not result in a lower construction cost s
than the compacted fill berm alternative and the RCC retaining wall alternative was not further
developed.
Alternative 3 – No Build Alternative
The post-seismic stability anal ysis results indicated that improvements, however constructed,
are required to satisfy FERC-prescribed factors of safety for the Lookout Shoals embankment
dam. If a No Build alternative was to be considered, Duke Energy would be in violation of the
mandated safety improvements required by FERC; therefore, a No Build alternative is not a
viable option.
Delineated Wetlands and Jurisdictional Waters of the United States
In December 2013, HDR biologists surveyed the 120-acre Duke Energy-owned property
(Propert y or Study Area) for wetlands and jurisdictional waters of the U.S. regulated under
Section 404 of the CWA. This field investigation was conducted according to the methodologies
and guidance described in the USACE 1987 Wetland Delineation Manual, USACE Post-
Rapanos guidance, the 2012 USACE Eastern Mountains and Piedmont Regional Supplement
(Version 2.0), and the North Carolina Division of Water Quality (NCDWR) Methodology for
Identification of Intermittent and Perennial Streams and Their Origins (Version 4.11) (NCDWQ
2010). Jurisdictional waters of the U.S. were delineated (flagged in the field) using a Trimble®
GeoXH GPS unit capable of sub-meter accuracy. GPS points were post-processed utilizing
Trimble® GPS Pathfinder Office software.
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 4
Field reconnaissance activities identified five jurisdictional streams and five jurisdictional
wetlands within the Property (Figure 3). A summary of jurisdictional waters of the U.S. is
provided in Table 1. Stream identification forms and wetland determination data forms for on-
site waters are included in Appendix B. An Approved Jurisdictional Determination (Action ID:
2014 - 00699) was issued by the USACE on May 21, 2014, and expires on May 21, 2019 (see
attached).
Table 1. Summary of USACE Verified Jurisdictional Waters of the U.S. within the Property
Site Number or Name Latitude Longitude Cowardin
Classification
Estimated Amount of
Aquatic Resource in
Review Area
Streams
Stream 1
(Tributary to Catawba River) 35.754496 -81.095146 R3UB1 2,815 linear feet
Stream 1a
(Tributary to Catawba River) 35.753559 -81.091833 R3UB1 80 linear feet
Stream 2
(Tributary to Catawba River) 35.754973 -81.097685 R4UB1 730 linear feet
Stream 3
(Tributary to Catawba River 35.755134 -81.094979 R4UB1 55 linear feet
Stream 4
(Tributary to Catawba River) 35.751753 -81.095067 R4UB1 150 linear feet
Stream 5
(Tributary to Catawba River) 35.752651 -81.093029 R3UB1 2,015 linear feet
TOTAL 5,845 linear feet
Wetlands
Wetland 1 (Forested) 35.755472 -81.100139 PFO1A 0.07 acre
Wetland 2 (Forested) 35.755345 -81.100299 PFO1A 0.01 acre
Wetland 3 (Forested) 35.755083 -81.098652 PFO1A 0.55 acre
Wetland 4
(Shrub/scrub & open water) 35.754262 -81.093556 PSS1C/
PUBHh 5.03 acres
Wetland 5 (Forested) 35.752438 -81.092851 PFO1A 0.19 acre
TOTAL 5.85 acres
Resource in

Duke Energy – Lookout Shoals ESSI Section 404/401
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Unavoidable Impacts to Jurisdictional Waters Area
Pre-project site planning was conducted to delineate and field-verify jurisdictional waters of the
U.S within the Property. These features were used to select a viable alternative to the existing
earthen embankment dam and site the associated project construction facilities to avoid and
minimize impacts to aquatic resources. Table 2 provides a summary of impacts to verified
jurisdictional waters. Refer to the attached Site Impact Drawing for additional details.
Table 2. Summary of Impacts to Waters of the United States
Impact
Number

Type of
Impact Type of Wetland
Type of jurisdiction
USACE (404,10) or
NCDWR (401, other)

Area of Impact
(Acres)
WETLAND IMPACTS
W1
(Permanent)
Fill
(Stability Berm) Scrub-Shrub USACE and NCDWR 0.6
W2
(Temporary)
Excavation/Fill
(Cofferdam and
Sediment Basin)
Scrub-Shrub USACE and NCDWR 1.0
TOTAL 1.6
STREAM IMPACTS
Impact
Number
Type of
Impact Stream Name Perennial or
Intermittent?
Average
Stream
Width
(Feet)
Impact Length
(Linear Feet)
S1
(Permanent)
Fill
(Culvert & Rip
Rap Apron)
Tributary to the
Catawba River Perennial 5 83
S2
(Temporary)
De-Watering
(Pump Around)
Tributary to the
Catawba River Perennial 5 200
S3
(Permanent)
Fill
(Access Road)
Tributary to the
Catawba River Intermittent 2 55
TOTAL 338

Wetland Impacts
The proposed permanent and temporary wetland impacts are described below.
 Permanent Impacts:
o The construction of the proposed stability berm will result in approximately 0.6
acres of unavoidable impacts to USACE verified scrub-shrub wetlands.
o A mitigation request will be submitted to the NCDEQ’s Department of Mitigation
Services (DMS) In-Lieu Fee program for unavoidable impacts at a 2:1 ratio.
Fees for wetland credits are calculated in quarter-acre increments. A 1.25-credit
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 6
for impacts to riparian wetlands will be requested to accommodate the
mitigation ratio. Current fees located in the higher fee Hydrologic Unit
(03050101) are $71,772 per acre credit. An approval letter NCDEQ’s DMS will
is attached.

 Temporary Impacts:
o The excavation and fill activities for the proposed temporary coffer dam and
sediment basin below the berm stability structure will result in approximately 1.0
acre of temporary impacts.
o Excavated wetland soils will be stockpiled in uplands and used during post-
construction restoration activities.
o Wetland restoration activities will consist of replacing stockpiled wetland soils,
re-grading impacted areas to original pre-construction contours, and re-seeding
disturbed areas with a native wetland seed mix. The restoration area will remain
undisturbed to allow the wetland system to reforest naturally.
o The impacted wetland area will be photo-documented prior to any land
disturbance activities.
o The restoration site will be monitored for two (2) years after construction during
the growing season. Monitoring will consist of establishing several photo
monitoring stations and documenting the percent vegetative cover.
o Success criteria will be defined by 60 percent vegetative cover following the first
full growing season and 80 percent vegetative cover following the second
growing season. Greater than 50 percent of the dominant species must be
hydrophytic plants (Wetland Indicator Status of FAC or wetter).
Stream Impacts
The proposed permanent and temporary stream impacts are described below.
 Permanent Impacts:
o The existing deteriorated 40-foot long, 36-inch corrugated metal pipe will be
replaced with an approximate 90-foot long, 36-inch reinforced concrete pipe
(RCP) low flow culvert and a 48-inch RCP high flow culvert to accommodate the
proposed access road. A 30-foot long rip rap apron will be placed downstream
of the proposed culverts to dissipate energy from high flows. These activities
will result in approximately 83 linear feet of unavoidable impacts to a perennial
tributary to the Catawba River.
 The replacement culverts will be located entirely within the footprint of
the existing deteriorated structure to avoid and minimize impacts.
 Culverts were sized to accommodate the hydraulic capacity of the
channel and surrounding watershed and to promote passage of fish
and other aquatic organisms.
 The culvert inverts will be installed at an elevation below the existing
stream at slopes that allow for aquatic passage and movement of
aquatic life.
 The culverts will be staggered in elevation to create a low flow culvert
and “floodplain” culverts.
 Excavated stream bed material (i.e., cobbles/gravels) will be stockpiled
and placed in the culverts to mimic natural instream conditions.
Duke Energy – Lookout Shoals ESSI Section 404/401
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Page 7
 Rip rap outlet protection below the proposed culverts will be keyed in to
prevent washout and installed at an elevation to maintain aquatic
passage and promote surface water flow during low flow conditions.
 A pump-around will be employed when installing the culverts to work in
the dry. Water will be pumped through a sediment filter bag before
returning to the stream.
 Disturbed stream banks will be sloped back, seeded with native
vegetation (including live stakes), and matted with biodegradable
erosion control material.
o Construction of the proposed access road near the base of the dam will result in
approximately 55 linear feet of unavoidable impacts to an intermittent tributary
to the Catawba River.
o The USACE Final 2017 Regional Condition for Nationwide Permits Section 3.2
indicates that compensatory mitigation for stream losses less than 150 linear
feet that require a PCN may be required by the District Engineer on a case-by-
case basis to ensure that the proposed activities result in minimal adverse
effects on the aquatic environment. The ESSI Project was designed to avoid
and minimize stream losses to the greatest extent practicable. No mitigation
payments are proposed for unavoidable impacts unless required by the District
Engineer.

 Temporary Impacts:
o Approximately 200 linear feet of temporary impacts will be associated with the
de-watering for the pump-around, impervious dikes, and sediment removal
device for the culvert and headwall installation.
Sediment released during ground disturbance and project construction has the potential to result
in adverse impacts to adjacent surface waters and aquatic organisms. Avoidance and
minimization measures will include implementing a minimum 30-foot riparian buffer on existing
surface waters, including wetlands, to reduce the potential for sedimentation and protect water
quality and aquatic habitat. In addition, Duke Energy has developed an Erosion and Sediment
Control (E&SC) Plan, which was submitted and approved by the NCDEQ Land Quality Section
(CATAW -2018-013). The E&SC plan will be implemented during construction to prevent
sedimentation impacts to water resources. Best Management Practices (BMP) will include, but
will not be limited to, installing protective silt fencing, restricting the use of wet concrete within
surface waters, and implementing and maintaining an on-site spill prevention plan for heavy
equipment. The work area will be inspected daily for signs of erosion or degradation and BMP
device failure. Following construction, all disturbed areas will be restored and re -graded to pre-
construction grades and re-vegetated with native trees, shrubs, and herbs (see attached
Restoration Plan Drawings).
North Carolina Department of Environmental Quality Surface Water
Classifications and Buffers
The Catawba River from Lookout Shoals Dam to Lyle Creek is designated as Class Water
Supply IV-Highly Developed (WS-IV) and Critical Area waters by the NCDEQ. Class WS-IV
waters are defined in the Environmental Management Commission Rule (15A NCAC 02B .0101)
as “waters used as sources of water supply for drinking, culinary, or food processing purposes…
Duke Energy – Lookout Shoals ESSI Section 404/401
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Page 8
WS-IV waters are generally in moderately to highly developed watersheds or Protected Areas”
(NCDWR 2017a). Critical Area (CA) is defined as land within one-half mile upstream and
draining to a river intake or within one-half mile and draining to a normal pool elevation of water
supply reservoirs” (NCDWR 2017b). Class CA waters are the “land adjacent to a water supply
intake where risk associated with pollution is greater than from remaining portions of the
watershed”. Buffer requirements implemented by the NCDEQ for WS-IV and CA waters include
a 30-foot buffer for low density developments and a 100-foot buffer for high density
developments (NCDWR 2011) for this reach of the Catawba River and associated unnamed
tributaries. The NCDEQ buffer applies if the Project will require an E&SC Plan (i.e., if the
disturbance area is greater than one acre). Based on the preliminary site plan and estimated
area of disturbance, an E&SC Plan will be required and on-site jurisdictional streams are subject
to low density development (30-foot) buffer requirements.
The Catawba River mainstem is subject to additional state buffer requirements (Rule 15A NCAC
02B .0243 [General Assembly of North Carolina 2014]). A 50-foot riparian buffer comprising two
zones (a 30-foot-wide undisturbed forested zone and a 20-foot-wide stable, vegetated zone)
applies to the Catawba River mainstem beginning at the top of bank, extending landward (i.e.,
away from water). However, Item (6) of 15A NCAC 02B .0243 states that overhead electric
utility lines are exempt or allowable, dependent upon angle of crossing (i.e., perpendicular)
and/or length of disturbance (i.e., less or greater than 150 linear feet). Based on preliminary site
plans, the disturbance area does not enter the 50-foot riparian buffer of the Catawba River
within the Property; therefore, no impacts are anticipated.
Agency Correspondence
Cultural Resources
A Phase 1 Cultural Resources Assessment of the Property was conducted in May and July of
2016. This survey included controlled surface inspection and subsurface surveys of the Area of
Potential Effect (APE) for cultural material through excavation of 180 shovel test pits spaced at
30-meter (98.4-feet) intervals in areas with at least a moderate probability for isolated activity.
These sites are defined as areas with less than 15 percent slope and not saturated or obviously
previously disturbed. Where culture material was identified, 77 additional shovel test pits were
excavated at 10-meter (32.8-foot) intervals to delineate site boundaries and assess site integrity.
Five archaeological resources were recorded and are summarized in Table 3.
Table 3. Archaeological Resources Discovered within the Property
State
Site No.1
Project
Site No. Description
Subsurface
Material
(Y/N)
Percent
Destroyed
(%)
Preliminary NRHP2
Eligibility
Recommendation
31CT267** LS-001
Concrete and stone
masonry historical
foundation remains
situated in a floodplain
near the Catawba River
and possibly associated
with commercial rock
crushing activities
Y 70 Potentially Eligible
Duke Energy – Lookout Shoals ESSI Section 404/401
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State
Site No.1
Project
Site No. Description
Subsurface
Material
(Y/N)
Percent
Destroyed
(%)
Preliminary NRHP2
Eligibility
Recommendation
31CT268** LS-002
Isolated, surface-level
historical flask wine
bottle located next to a
dirt road, on the surface
of and post-dating a ca.
1951 borrow area
N
(isolated
bottle
drop)
Ineligible
31CT269** LS-003
Isolated, surface-level
push pile of historical
glass artifacts located
next to a dirt road, on the
surface of and post-
dating a ca. 1951 borrow
area
N 80 Ineligible
31CT270&
270**
LS-004 &
LS-005
Multicomponent site
including a limited-
activity, aboriginal lithic
scatter component and a
possible historical
domestic
storage/habitation
component, located on
the crest of a hill
Y 30 Potentially Eligible
31CT272** LS-006
Isolated, buried historical
bottle glass located in a
frequently inundated
floodplain near LS-005
Y (secondary
context) Ineligible
1 Per OSA coding, two asterisks (**) to the right of an archaeological site number indicate a historical
period site. Numbers such as 31CT270&270** indicate a site having both a pre-contact and a historical
period component. 2 National Register of Historic Places

The Phase 1 Assessment identified that one of the five archaeological resources within the
Property may be eligible for listing on the National Register. Correspondence with the N.C. State
Historic Preservation Office (NCSHPO) recommended additional archaeological investigations
for site 31CT270&270**, which will be impacted by ground disturbance activities, to determine
whether the historic component of the site is eligible for the NRHP.
A Phase II Cultural Resources Assessment was conducted in September 2017 to determine the
eligibility of 31CT270&270**; the assessment indicated that the historic component of the site
will not generate significant or substantial information to address pertinent research questions
regarding the historic occupations in the region. Therefore, the site 31CT270&270** was
recommended as not eligible for the NRHP. NCSHPO concurred with the recommendation that
no adverse impacts to significant archeological resources will be initiated by the proposed
project and that no further archaeological investigations are required. A copy of the response
from the NCSHPO dated February 22, 2018 is attached.

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Federally Protected Species
An updated species list (https://www.fws.gov/raleigh/species/cntylist/catawba.html) for Catawba
County was obtained from the United States Fish and Wildlife Service (USFWS) website (last
updated on April 28, 2017). A summary of federally protected species in Catawba County is
provided in Table 4.
Table 4. Federally Protected Species for Catawba County, North Carolina
Species Federal
Designation1
Record
Status2
Potential Habitat
Present Biological Determination
Vertebrates
Bald eagle
(Haliaeetus leucocephalus) BGPA Current Yes May affect, but not likely to
adversely affect
Northern long-eared bat
(Myotis septentrionalis) T Probable/
Potential Yes May affect, but not likely to
adversely affect
Vascular Plants
Schweinitz’s sunflower
(Helianthus schweinitzii) E Current Yes No effect
Dwarf-flowered heartleaf
(Hexastylis naniflora) T Current Yes No effect
1 BGPA =Bald and Golden Eagle Protection Act.
T (Threatened): a taxon likely to become endangered within the foreseeable future throughout all or a significant portion of its range;
E (Endangered): a taxon in danger of extinction throughout all or a significant portion of its range.
2 Current: The species has been observed in the county within the last 50 years; Probable/Potential: The species is considered likely to
occur in this county based on the proximity of known records (in adjacent counties), the presence of potentially suitable habitat, or
both.

During reconnaissance activities in December 2013, individuals belonging to the genus
Hexastylis were noted on hillside slopes and adjacent stream side areas throughout the
Property. Dwarf-flowered heartleaf (Hexastylis naniflora) is a federally protected species and is
listed as “Threatened” under the Endangered Species Act. Populations of dwarf -flowered
heartleaf have also been documented near the Property, therefore, HDR recommended that a
survey be conducted during the optimal survey window (flowering season, March to early May)
to identify the Hexastylis species within the Property. A known, existing off-site population was
visited as a reference to the current condition of the species (i.e., flowering) within the Property
prior to the field survey. The field survey visit was conducted on April 22, 2014. Representative
flowers were examined throughout the property. Calyx tube openings were measured and
flowers were longitudinally sectioned to observe the position of the ovary. Data collected during
the field investigation determined that orifice openings were greater than seven millimeters and
indicated that the superior ovary positions were not characteristic of the dwarf-flowered
heartleaf. Therefore, no individuals representative of the Hexastylis naniflora species were
identified within the Property and no impacts are anticipated.
HDR also conducted a field survey for the Schweinitz’s sunflower (Helianthus schweinitzii) and
potential habitat for this species within the Property. The Schweinitz’s sunflower prefers
disturbed habitat with poor clay-rich soils, such as along roadsides and within utility rights -of-
way, with adequate sun and limited competitive vegetation. Concurrent with the field
investigation, a known, existing off-site population of Schweinitz’s sunflower was visited as a
reference to the current condition of this species. The field survey indicated that the maintained
right-of-way within the Property includes combination of areas with dense, woody sapling
vegetation and herbaceous growth, maintained lawn (grass) areas, and areas that had been
recently mowed. Neither the dense vegetative growth area nor the maintained lawn area is
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 11
suitable habitat for the Schweinitz’s sunflower. HDR concluded that suitable habitat for the
Schweinitz’s sunflower is present in several areas of the Property. These areas are maintained
for moderate herbaceous growth and are underlain by loamy-clay soils. Based on the site visit to
the off-site known population, aboveground plant parts were identifiable and flowers were
present and in bloom at the time of survey. No individuals of Schweinitz’s sunflower were
observed within the identified suitable habitat within the Property; therefore, no impacts to this
species are anticipated.
Lookout Shoals Lake and the Catawba River provide suitable foraging habitat for the bald eagle
(Haliaeetus leucocephalus). Mature trees located along forested shorelines and riparian areas
provide suitable roosting and/or nesting habitat. No bald eagle nests are k nown to occur within
the Property and no nests or individual species were observed during the site visits.
Forested areas within the Property may provide potential roosting habitat for the Northern long-
eared bat (Myotis septentrionalis) (NLEB). Northern long-eared bats have two distinct seasonal
habitats– winter habitats include caves and mines, and summer habitats consist of roosting
singly or in colonies underneath bark, in cavities, or crevices of both live and dead trees. Mature
trees (greater than 12 inches in diameter) that exhibit exfoliating bark (i.e., hickories and oaks)
and dead tree snags were observed within the forested portions of the Property and may serve
as potential roosting habitat. According to the USFWS, the Property is not located within a
watershed with known NLEB maternity trees or hibernation sites. It is assumed that no clearing
restrictions or mitigation measures will be required; therefore, potential incidental take of this
species associated with ESSI Project activities is exempt under the final Section 4(d) rule of the
Endangered Species Act.
Correspondence (October 6, 2017) was sent to the USFWS requesting comments on any
potential issues that may emerge with respect to endangered species, migratory birds, or other
resources associated with the proposed construction activities. A copy of the response and
recommendations from the USFWS received on November 14, 2017 is attached.
HDR kindly requests that you review the attached information, provide verification of
jurisdictional waters of U.S., and provide authorization to construct the proposed ESSI Project
under the CWA Section 404/401 Nationwide Permit. Should you have any questions regarding
this projector require additional information, please do not hesitate to contact me at (704) 973-
6878 or [e-mail].
Sincerely,

Eric Mularski, PWS
Senior Environmental Scientist

Attachments: Agent Authorization Form
Pre-Construction Notification Form
Figure 1. Project Location
Figure 2. USGS Quadrangle
Figure 3. USACE Verified Waters of the United States
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 12
USACE Approved Jurisdictional Determination (Action ID: 2014-00699)
NC DMS In-Lieu-Fee Acceptance Letter
NCDEQ Land Quality Section – Erosion and Sediment Control Approval
(CATAW -2018-013)
NCSHPO Correspondence Letter
USFWS Correspondence Letter
Lookout Shoals ESSI Site Impact Figure
Lookout Shoals ESSI Project Site Drawings

cc. Jon Wise, PMP – Duke Energy
John Eddy, PE – Duke Energy
Clint Forsha, PE, PMP – HDR

Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 13

Photograph #1 – W etland 1 – facing east (December 2013)

Photograph #2 – Wetland 2 – facing east (December 2013)
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 14

Photograph #3 – Stream 1 (perennial tributary), facing downstream (December 2013)

Photograph #4 – Wetland 3 and Mesic Mixed Hardwood Forest (hillslope), facing southeast
(December 2013)
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 15

Photograph #5 – Stream 2 (intermittent tributary), facing downstream (December 2013)

Photograph #6 – Stream 1 (perennial tributary), facing upstream (December 2013)
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 16

Photograph #7 – Stream 3 (intermittent tributary), facing upstream (December 2013)

Photograph #8 – Wetland 4, facing east (December 2013)
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 17

Photograph #9 – Open water/emergent wetland, facing northwest (December 2013)

Photograph #10 – Stream 4 (intermittent tributary), facing downstream (December 2013)
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 18

Photograph #11 – Stream 5 (perennial tributary), facing upstream (December 2013)

Photograph #12 – Wetland 5, facing west (December 2013)
Duke Energy – Lookout Shoals ESSI Section 404/401
March 12, 2018
Page 19

Photograph #13 – Stream 1a (perennial tributary), facing downstream (December 2013)

Photograph #14 – Stream 1 (perennial tributary), facing downstream (December 2013)