20190626 Ver 1_PCN Form Submission_20190509

DWR
IDIOM— M WM­ It--
Pre -Construction Notification (PCN) Form
September 29,2018 Ver 3
21nitial Review
Has this project met the requirements for acceptance in to the review process?*
r Yes
r No
Is this project a public transportation project?*
C Yes r No
Change only if needed.
BIMS # Assigned
20190626
Is a payment required for this project? *
r No payment required
r Fee received
r Fee needed - send electronic notification
Reviewing Office*
Wilmington Regional Office - [phone]
Information for Initial Review
Ia. Name of project:
Willard Solar. LLC
Ia. Who is the Primary Contact? *
Kim Williams - Land Management Group
1b. Primary Contact Ernail:*
[e-mail]
Date Submitted
5/9/2019
Nearest Body of Water
Rockfish Creek
Basin
Cape Fear
Water Classification
QSW
Site Coordinates
Latitude:
34.7020
FA. Processina Information
County (or Counties) where the project is located:
Pander
Is this project a public transportation project?
r Yes r No
Longitude:
-77.9694
Ia. Type(s) of approval sought from the Corps:
* Section 404 Permit (wetlands, streams and waters, Clean Water Act)
* Section 10 Permit (navigable waters, tidal waters, Rivers and Harbors Act)
1 b. What type(s) of permit(s) do you wish to seek authorization?
P Nationwide Permit (NWP)
F- Regional General Permit (RGP)
F Standard (P)
Version#*
1
What amout is owed?*
* $240.00
* $570.00
Select Project Reviewer*
Robb Mairs:eads\rlmairs2
1 c. Primary Contact Phone:*
[phone]

1c. Has the NWP or GP number been ve rifle d by the Corps?
r Yes r No
Nationwide Permit (NWP) Number:
NWP Numbers (for multiple NWPS):
1d. Type(s) of approval sought from the DWR:
W 401 Water Quality Certification - Regular
F Non -404 Jurisdictional General Permit
F Individual Permit
14 - Linear transportation
le. Is this notification solelyfor the record because written approval is not required?
For the record only for DWR 401 Certification:
For the record only for Corps Permit:
r- 401 Water Quality Certification - Express
r- Riparian Buffer Authorization
1f. Is this an after -the -fact permit application?*
r Yes r No
1g. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts?
r Yes IT No
1g. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts?
r Yes r No
Acceptance Letter Attachment
1h. Isthe project located in anyof NC's twenty coastal counties?
IT Yes r No
li. Is the project located within a NC DCM Area ofEnvironmental Concern (AEC)?
r Yes r No
1j. Is the project located in a designated trout watershed?
C Yes r No
FB. Applicant Information
Id. Who is applying forthe permit?
r- Owner V Applicant (other than owner)
le. Is there an Agent/Consultant for this project?
r Yes r No
2. Owner Information
2a. Name(s) on recorded deed:
Kennedy Brothers Property, LLC
2b. Deed book and page no.:
2c. Responsible party:
Margaret R. Kennedy
2d. Address
Street Address
455 Church Street
Address Une 2
aty
Willard
Fbstal / Zip Cide
28478
2e. Te le phone Number:
[phone]
2g. Email Address:*
noemailaddress@,O(Xcom
3. Applicant Information (if different from owner)
r Unknown
State / Frovince / R�gicn
NC
0�untry
USA
2f. Fax Number
r Yes r No
r Yes r No

3a. Name:
Mike Stanton
3b. Business Name:
Willard Solar, LLC
3c. Address
Street Address
3402 Pico Boulevard
Address Line 2
City
Santa Monica
Flostal / Zip Code
90405
3d. Telephone Number:
[phone]
3f. Email Address:*
[e-mail]
C. Project Information and Prior Project History
1. Project Information
1b. Subdivision name:
(if appropriate)
VA
1 c. Ne are st mu n icipal ity / town:
Willard
F2. Project Identification
2a. Property Identification Number:
3314-07-3758-0000
2c. Project Address
Street Address
555 Church Street
Address Une 2
City
Willard
Flostal / Zip Code
28478
3. Surface Waters
3a. Name of the nearest body of water to proposed project:*
Rockfish Creek
3b. Water Resources Classification of nearest receiving water:*
C;SW
3c. What river basin(s) is your project located in?*
Cape Fear
3d. Please provide the 12-cligit HILIC in which the project is located.
030300070506
4. Project Description and History
State / Ravinoe / Fbgion
CA
Country
USA
3e. Fax Number:
2b. Property size:
32.7
State / Rovince / Pbgion
NC
Country
USA
4a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this application:*
Most of the site is agricultural fields. Some forested areas e)dst along the northern project boundary and in the southern section of the tract. One depressional wetland in the central
part of the tract support black gum (Nyssa sylvatiGa), red maple (Acer rubrum), and loblolly pine (Pinus taeda) in the canopy and some red maple in the shrub layer. Another vetland
area is located in the northeastern corner and supports a dense assemblage of mostly red maple and loblolly pine. Some forested uplands are located along the southern project
boundary and betveen the fields and the wetlands. These areas contain a mix of loblolly pine and sweetgurn (Liquidambar styraciflua) trees. Several ditches cross through the northern,
central, and southern parts of the tract. The sections of ditches that traverse through fields are mowed and those located within or adjacent to forested areas have vegetated banks.
The ditches and wetlands on site appear to flow northeast into an unnamed tributary of Rockfish Creek. A transmission line is located along the eastern site boundary. Adjacent land
use consists of undeveloped and forested land, agricultural fields, and residences.
4b. Have Corps permits or DWR certifications been obtained for this project (including all prior phases) in the past?*
r Yes r No r Unknown
4d.Attach an 8 1/2X11 excerptfromthe most recentversion ofthe USGS topographic map indicating the location ofthe projectsite. (forDWR)
Willard topo.pdf 863.22KB

4e. Attach an 8 1/2 X1 I excerpt from the most recent version of the published County NRCS Soil Survey map depicting the project site. (for DWR)
Willard Soils.pdf 861.18KB
4f. List the total estimated acreage of all existing wetlands on the property:
0.2
4g. List the total estimated linear feet of all existing streams on the property:
684
4h. Explain the purpose of the proposed project**
The applicant plans to develop a solar facility within the site. One small impact to a jurisdictional channel is needed to install a road and utilities in order to access uplands within the site.
4i. Describe the overall project in detail, including indirect impacts and the type of equipment to be used:*
The applicant plans to develop a solar facility within the site. The solar facility will consist of fixed tilt photovoltaic panel tables supported on driven steel piles. The system will be
connected to the eAsting Duke Energy Progress utility electric grid on the east side of Church Road, south of the proposed project access driveway. The construction process entails
steel post installation Wth light clearing and grading if needed. Once the steel posts are installed, brackets and modules will be installed.The proposed channel crossing will be 32 feet
wide (24' gravel road and 4' side slopes). A 12" culvert will be installed. Conductors and cables will also be directionally bored under the ditch.
4j. Please upload project drawings for the proposed project.
20190424-WILLRD-EX-201-RPW DITCH XJNG.pdf
5. Jurisdictional Determinations
5a. Have the wetlands or streams been delineated on the property or proposed impact areas?
r Yes r No
Comments:
5b. Ifthe Corps made ajurisdictional determination, whattype of determination was made?*
r Preliminary r Approved r NotVerified r Unknown r N/A
Corps AID Number:
Action ID# SAW -2015-01822
5c. If Sa is yes, who delineated the jurisdictional areas?
Name (if known): Paull'arley
Agency/Consultant Company: Land Management Group
Other:
3.68MB
r Unknown
5d. List the dates of the Corp jurisdiction determination or State determination if a determination was made by the Corps or DWR
Emily Greer with the USACE issued the PJD on 5/3/17. Robb Mairs of the NC DWR issued a stream determination on 4/4/19.
5dl. Jurisdictional determination upload
Willard DWR Stream Detemn 04-04-19.pdf 1.52MB
Willard-USACE Lett (Prelim)_5-3-17.pdf 689.76KB
6. Future Project Plans
6a. Is this a phased project?*
r Yes r No
Are anyother NWP(s), regional general permit(s), or individual permits(s) used, or intended to be used, to authorize any part ofthe proposed project or related activity?
No
D. Proposed Impacts Inventory
1. Impacts Summary
la. Where are the impacts associated with your project? (check all that apply):
r- Wetlands r- Streams -tributaries
W Open Waters F Pond Construction
4. Open Water Impacts
r- Buffers
14al. Impact Reaso 14b. Impact type 14c. Name of wate rb 14d. Activity type :114e. Wate rbody type
Road and Utility
Crossing
N/A
Ditch
_t=]
4g. Total temporary open water Impacts:
0.00
4g. Total open water impacts:
4g. Total permanent open water impacts:
0.01

0.01
4h. Comments:
Impact is actually 0.002 acre (96 so, but table will only allow entering to one -hundredths.
E. Impact Justification and Mitigation
1. Avoidance and Minimization
Ia. Specifically describe measures taken to avoid or minimize the proposed impacts in designing the project:
The applicant has avoided all wetlands and streams Wthin the site, but needs to impact a small amount of jurisdictional ditch (non -stream) in order to
access uplands within the site. Note that they are unable to utilize the existing crossing of this ditch because of its close proAmity to the property
boundary. Placing a road at this location would create a sharp turning radius, Mich would be difficult for large vehicles to safely maneuver around.
Conductors and cables will be directionally bored under the ditch to avoid additional impacts to the channel.
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques:
Applicant will implement a sedimentation and erosion control plan that has been approved by the Land Quality Section (PENDE-2019-020).
Conductors and cables will be directionally bored under the ditch to avoid additional impacts to the channel.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for impacts to Waters of the U.S. or Waters of the State?
r Yes r No
2b. Ifthis project DOES NOTrequire Compensatory Mitigation, explain why:
Impacts have been minimized to 0.002 acre of open water aurisdictional channel). No impacts to wetlands or streams are proposed.
F. Stormwater Management and Diffuse Flow Plan (required by DWR)
1. Diffuse Flow Plan
Ia. Does the project include or is it adjacent to protected riparian buffers identified within one of the NC Riparian Buffer Protection Rules?
r Yes r No
If no, explain why:
Site is located within Cape Fear River Basin.
2. Stormwater Management Plan
2a. Is this a NCDOT project subject to compliance with NCDOT's Individual NPIDES permit NCS000250?
r Yes r No
2b. Does this project meetthe requirements for low density projects as defined in 15ANCAC 02H .1003(2)?
r Yes r No
Comments:
Applicant hasobtained a low density stormwater permitfrorn DEMLR(SW8 190406).
G. Supplementary Information
1. Environmental Documentation
Ia. Doesthe project involve an expenditure of public (federal/state/local) funds orthe use of public (federal/state) land?*
r Yes r No
2. Violations (DWR Requirement)
2a. Is the site in violation ofDWRWater Quality Certification Rules (15ANCAC 2H .0500), Isolated Wetland Rules (115ANCAC 2H .1300), or DWRSurface Water orWetland Standards or
Riparian Buffer Rules (115ANCAC 2B.0200)?*
r Yes r No
3. Cumulative Impacts (DWR Requirement)
3a. Will this project result in additional development, which could impact nearby downstream water quality?*
r Yes r No
3b. If you answered "no," provide a short narrative description.
No access or utilities will be provided to adjacent tracts. No additional wetland or stream impacts are anticipated for the project.
4. Sewage Disposal (DWR Requirement)
4a. Is sewage disposal required by DWR for this project? *

r' Yes (-- No r' N/A
5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or habitat?
r Yes r No
5b. Have you checked with the USFWSconcerning Endangered Species Act ini
r Yes r No
5c. If yes, indicate the USFWS Field Office you have contacted.
Raleigh
5d. Is another Federal agency invoi
r Yes r No
5e. Is this a DOT project located within Division's 1-8?
r Yes r No
5f. Will you cut anytrees in orderto conductthe work in waters ofthe U.S.?
r Yes r No
5g. Does this project involve bridge maintenance or removal?
r Yes r No
5h. Does this project involve the construction/installation of a wind turi
r Yes r No
r Unknown
5i. Doesthis project involve (1) blasting, ari otherpercussive activities that will be conducted byrnachines, such asjackhammers, mechanized pile drivers, etc.?
r Yes (- No
Ifyes, please provide details to include type ofpercussive activity, purpose, duration, and specific location ofthis activityon the property.
Willard— Percussive.pdf 62.94KB
5j. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat?
ILMG performed a habitat assessment for federally -protected species and determined that forested areas within the site could provide appropriate
summer and wintering roosting habitat for the northern long-eared bat. Because no roost trees have been identified by the USFWS in Fender County,
any associated take from the proposed project as a result of clearing trees would be exempt per the Programmatic Biological Opinion for the Ni
The site does not appear to contain suitable habitat to support any other threatened or endangered species known to occur in Fender County. The
USFWS issued a letter dated March 29, 2019 in which they stated that the project is not likely to adversely affect any federally -listed species and that
the requirements of Section 7(a)(2) of the Endangered Species Act have been satisfied for the project.
Consultation Documentation Upload
Willard—USFW Resp Lett 03-29-19.pdf 333.83KB
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as an Essential Fish Hai
r Yes G No
6b. What data sources did you use to determine whether your site would impact an Essential Fish
Ni Ei Mapper was reviewed.
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal governments have designated as having historic or cultural preservation status?*
r Yes r No
7b. What data sources did you use to determine whetheryour site would impact historic or archeological resources?*
ILMG reviewed the HPOWEB GIS Service to determine if any cultural resources and/or historic properties have been recorded within or near the site.
This reviewfound no cultural resources or historic properties identified within or adjacent to the project area. Additionally, Si reviewed the project
via a State Clearinghouse Review request and had no comment on the project as proposed.
7c. Historic or Prehistoric Information Upload
CH 16-0267 -- sch form.pdf 95.29KB
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEIVIA-designated 1 00 -year floodplain?
r Yes r No
8c. Whatsource(s) did you use to make the floodplain detemninatiori
The FEMA National Flood Insurance Program map was reviewed.
Miscellaneous
Comments

Miscellaneous attachments not previously requested.
Willard Aerial.pdf
Willard Vicinity.pdf
FSIgnature
[7 By checking the box and signing below, I certify that:
2.44MB
1.08MB
• I have given true, accurate, and complete information on this form;
• I agree that submission of this PCN form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act");
• I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act");
• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written signature; AND
• I intend to electronically sign and submit the PCN form.
Full Name:
Kimberlee C Williams
Signature
C,A�,-Wvw,�4, rw-O�Zwv,
Date
5/9/2019

AGENT AUTHORIZATION FORM

TO WHOM IT MAY CONCERN:

I/we, the undersigned, hereby authorize Land Management Group to act as our agent in the
preparation and representation of information related to the Section 404/401 permit application
for Willard Solar, LLC; Pender County, NC project. All questions in regards to this project
should be directed to Land Management Group.

Sincerely,

________________________________________
Applicant

________________________________________
Print Name

________________________________________
Date
DocuSign Envelope ID: 6FF0E584-08B4-4CF7-8966-F869FB161CD5
Authorized
Person
3/22/2019
Mike Stanton
Esri, HERE, Garmin, © OpenStreetMap contributors
Willard Solar, LLCPender County, NC
Map Date: 03-05-19LMG19.070 3805 Wrightsville AvenueWilmington, NC 28403(910) 452-0001
Figure 3
2016 Aerial Photograph
0 300 600150Feet¯Boundaries are approximate and not meant to be absolute.Map Source: 2016 NC One Map
Fo
Wo
GoA
GoA
GoA
NoB
GoA
GoA
GoA
Willard Solar, LLCPender County, NC
Map Date: 03-28-19LMG19.070 3805 Wrightsville AvenueWilmington, NC 28403(910) 452-0001
Figure 4Pender County NRCS Soil Map
0 400 800200Feet¯Bo undaries are ap proximate and not mea nt to b e a bsolute.Ma p Sou rce : NRCS Soil Survey
Esri, HERE, Garmin, © OpenStreetMap contributors, Copyright:© 2013National Geographic Society, i-cubed
Willard Solar, LLCPender County, NC
Map Date: 03-05-19LMG19.070 3805 Wrightsville AvenueWilmington, NC 28403(910) 452-0001
Figure 2Topographic Map
0 1,000 2,000500Feet¯Bo undaries are ap proximate and not mea nt to b e a bsolute.Ma p Sou rce : Walla ce East N C, 198 1 Topograp hic Qua drangle
Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NR Can,Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand),NGCC, © OpenStreetMap contributors, and the GIS User Community
Willard Solar, LLCPender County, NC
Map Date: 03-05-19LMG19.070 3805 Wrightsville AvenueWilmington, NC 28403(910) 452-0001
Figure 1Vicinity Map
0 1 20.5 Miles¯Bo undaries are ap proximate and not mea nt to b e a bsolute.Ma p Sou rce : ArcG IS World Street Map
WILLARD SOLAR, LLC
Pender County, NC

The project involves the construction of a solar facility. A pile driver will be used to install the
steel posts, which may be considered a percussive activity. This work will be conducted in a
timely manner and will take place in accordance with construction times authorized in the
construction permit.

April 4, 2019

Ms. Kim Williams
c/o Land Management Group
3805 Wrightsville Ave.
Wilmington, N.C. 28403

Subject: Stream Determination # Pender 2019-001
Proposed Willard Solar Site, Pender County
Tributary to Rockfish Creek

Dear Kim:

On March 28, 2019, at your request and in attendance with Mr. Paul Farley with Land Management Group, Robb Mairs,
NC Division of Water Resource (NCDWR) staff, conducted an on-site determination of the existing stream at the
proposed Willard Solar Site location. The enclosed signed drawing dated on April 4, 2019 depicts the E/I point and
whether a feature has been determined to be a stream or not. This drawing has been signed and is valid for 5 years.

This on-site determination shall expire five (5) years from the date of this letter. Landowners or other affected
parties that dispute a determination made by DWR or a delegated Local Authority may request a determination
by the Director. An appeal request must be made within sixty (60) calendar days of the date of this letter or
from the date the affected party (including downstream and/or adjacent owners) is notified of this letter. A
request for determination by the Director shall be referred to the Director in writing c/o Karen Higgins, DWR
401 & Buffer Permitting Unit, 1617 Mail Center, Raleigh, NC 27699-1617. This determination is final and binding
unless you ask for a hearing within 60 days.

The owner/future owners should notify the Division (including any other local, state and federal agencies) of this
determination concerning any future correspondence regarding the subject property. This project may require a
Section 404/401 Water Quality Certification for the proposed activity. Any inquiries should be directed to Robb Mairs
of DWR at 910.796.7303 and Emily Greer of the U.S. Army Corps of Engineers at 910.251.4567.

Please contact Robb Mairs at 910.796.7303 or [e-mail] if you have any questions or concerns.

Sincerely,

Robb Mairs
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDWQ

Enclosure: Supporting Map
Cc: Emily Greer, US Army Corps of Engineers, Wilmington Field Office - EC
Karen Higgins, 401 Wetlands and Buffers Unit- LF
N
3ounaanes are approximate and not meant to be absolute.
Oap Source: 2016 GIS World Imaoery
Willard Solar, LLC
Pender County, NC
Map Date: 03-28-19
LMG19.070
LMG
LAND MANAGEMENT GROUP
a DAVEA company
3805 Wrightsville Avenue
Wilmington, NC 28403
[phone]
0 150 300 600
Feet
Wetland
Delineation Map

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
March 29, 2019
Kimberlee Williams
Land Management Group
3805 Wrightsville Ave., Suite 15
Wilmington, NC 28403
Re: Willard Solar Farm (Update Area) — Pender County, NC
Dear Mrs. Williams:
This letter is in response to your request for information on your proposed solar project, listed
above. Our comments are submitted pursuant to, and in accordance with, provisions of the
Endangered Species Act (the Act).
Based on the information provided and other information available, it appears that the proposed
action is not likely to adversely affect any federally -listed endangered or threatened species, their
formally designated critical habitat, or species currently proposed for listing under the Act at
these sites. We believe that the requirements of section 7(a)(2) of the Act have been satisfied for
your project. Please remember that obligations under section 7 consultation 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 determined that may be affected by the identified action.
However, the Service is concerned about the potential impacts the proposed action might have
on aquatic species. Aquatic resources are highly susceptible to sedimentation. Therefore, we
recommend that all practicable measures be taken to avoid adverse impacts to aquatic species,
including implementing directional boring methods and stringent sediment and erosion control
measures. An erosion and sedimentation control plan should be submitted to and approved by
the North Carolina Division of Land Resources, Land Quality Section prior to construction.
Erosion and sedimentation controls should be installed and maintained between the construction
site and any nearby down -gradient surface waters. We recommend maintaining natural,
vegetated buffers on all streams and creeks adjacent to the project site.
The Service recommends that solar facilities be sited in areas that are previously disturbed, or
sites that do not impact mature forest, wetlands,'or streams. The'North Carolina Wildlife
Resources Commission has developed a Guidance Memorandum (a copy can be found on our
website at (http://www.fws.gov/raleigh) to address and mitigate secondary and cumulative

impacts to aquatic and terrestrial wildlife resources and water quality. We recommend that you
consider this document in the development of your projects and in completing an initiation
package for consultation (if necessary).
In addition, we encourage the use of natural vegetation management practices (such as sheep
grazing) and the planting or seeding of native pollinator plant species where possible on the site,
and other efforts to improve habitat for various species (such as bird houses and bat boxes).
Please note our specific recommendations, below.
Invasive Exotic Species — the Service is concerned with the introduction and spread of invasive
exotic species in association with the proposed project. Without active management, including
the revegetation of disturbed areas with native species, the project area will likely be a source for
the movement of invasive exotic plant species. Exotic species are a major contributor to species
depletion and extinction, second only to habitat loss. Exotics are a factor contributing to the
endangered or threatened status of more than 40 percent of the animals and plants on the Federal
List of Endangered and Threatened Wildlife and Plants.' It is estimated that at least 4,000 exotic
plant species and 2.300 exotic animal species are now established in the United States, costing
more than $130 billion a year to control2. Additionally, the U.S. Government has many
programs and laws in place to combat invasive species (see www.invasivespecies.gov) and thus
cannot spend money to counter these efforts. Specifically, Section 2(a)(3) of Executive Order
13112 Invasive Species (February 3, 1999) directs federal agencies to "not authorize, fund, or
carry out actions that it believes are likely to cause or promote the introduction or spread of
invasive species in the United States or elsewhere." Despite their short-term erosion control
benefits, many exotic species used in soil stabilization seed mixes are persistent once they are
established, thereby preventing the reestablishment of native vegetation. Many of these exotics
plants3 are also aggressive invaders of nearby natural areas, where they are capable of displacing
already established native species. Therefore, we strongly recommend that only native plant
species be used in association with all aspects of this project.
Pollinator Recommendations — Although solar energy production is a fast-growing
Renewable energy source that can lessen overall impacts to natural resources when compared to
conventional energy sources (coal, oil, gas, etc.), we believe solar farms can adversely affect
valuable natural resources if they are not properly planned and constructed. Impacts to natural
resources from the construction, operation, and maintenance of solar farms include: the removal
of forests and riparian buffers; creation of monotypic habitat; introduction of invasive species;
use of herbicides; creation of large, clear open spaces; and barriers created from fencing.
Recent evidence indicates that pollinators, especially native bees and monarch butterflies, are in
serious decline, Habitat losses and diminished native food sources have decreased the
populations and diversity of pollinators throughout the country. For these reasons, we
recommend that solar facilities be sited in areas that are previously disturbed (fallow fields,
closed industrial sites, etc.) or sites that do not impact mature forests, streams, or wetlands. To
offset the overall impacts of solar facilities and/or to increase the habitat and species diversity
within the solar facility area, we further recommend the following measures be implemented into
project design:
2

Sow native seed mixes with plant species that are beneficial to pollinators throughout the
site. Taller growing pollinator plant species should be planted around the periphery of the
site and anywhere on the site where snowing can be restricted during the summer months.
Taller plants, left un -mowed during the summer, would provide benefits to pollinators,
habitat to ground nesting/feeding birds, and cover for small mammals. Low
growing/groundcover native species should be planted under the solar panels and
between the rows of solar panels. This would provide benefits to pollinators while also
minimizing the amount of maintenance such as mowing and herbicide treatment. Using a
seed mix that includes milk weed species (milk weed is an important host plant for
monarch butterflies) is especially beneficial. The following website provides a
comprehensive list of native plant species that benefit pollinators:
https://mail.google. com/mail/u/0/4advancedsearch/subj ect=pollinator&subset=all&has=a
nita&within=l d&sizeoperator=s_sl&sizeunit=s_smb/14f0366dba7d3bda?projector=l .
Additional information regarding plant species, seed mixes, and pollinator habitat
requirements can be provided upon request.
2. Create openings in fencing to allow passage for small mammals and turtles.
3. If possible, the solar field should be designed with open areas spread throughout the
project site and planted and maintained with taller/pollinator friendly plant species. This
practice would benefit pollinators, create diversity throughout the site, and provide much
needed shelter islands to aid in the movement of small mammals and birds.
4. Mitigate for the loss of forested habitat. Though the loss of forested habitat cannot be
fully mitigated when cleared for solar facilities, we believe measures should be
implemented into the design plans to offset the impacts of the project to the greatest
extent practicable. We recommend the construction and placement of bat and bird boxes
throughout the site along with perch poles that are large enough to be used by raptors.
Provide nesting sites for pollinator species. Different pollinators have different needs for
nesting sites. Therefore, we recommend designing the solar facility to maintain a diverse
array of habitats to accommodate varied pollinators from hummingbirds to butterflies to
bees. Hummingbirds typically nest in trees or shrubs while many butterflies lay eggs on
specific host plants. Most bees nest in the ground and in wood or dry plant stems. For
additional information and actions that can be taken to benefit pollinators please visit the
following website:
http://www.fws.gov/pollinators/pollinatorpages/yourhelp.html
The Service has established an on-line project planning and consultation process which assists
developers and consultants in determining whether a federally -listed species or designated
critical habitat may be affected by a proposed project. For future projects, please visit the
Raleigh Field Office's project planning website at https:/Iwww.lws.i?ov/raleidi/prp_ht . If you
are only searching for a list of species that may be present in the project's Action Area, then you
may use the Service's Information, Planning, and Consultation System (IPaQ website to
determine if any listed, proposed, or candidate species may be present in the Action Area and
generate a species list. The IPaC website may be viewed at https!//ecos.fws.gov/iiac/. The

IPaC web site contains a complete and frequently updated list of all endangered and threatened
species protected by the provisions of the Endangered Species Act of 1973, as amended (16
U.S.C. 1531 et seq.)(Act), a list of federal species of concern that are known to occur in each
county in North Carolina, and other resources.
If you have any questions or comments, please contact Kathy Matthews of this office at (919)
856-4520 ext. 27.
Sincerely,
. et Benjamin
Field Supervisor
1 Wilcove, D. S., D. Rothstein, J. Dubow, A. Phillips, and E. Losos. 1998. Quantifying threats to imperiled species
in the United States. BioScience 48:607615.
2 Pimentel, D., L. Lach, R. Zuniga, and D. Morrison. 2000. Environmental and economic costs of nonindigenous
species in the United States. BioScience 50:5365.
3 The term "federal species of concern" refers to those species which the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their designation does
not necessarily imply that the species will eventually be proposed for listing as a federally endangered or threatened
species. However, we recommend that all practicable measures be taken to avoid or minimize adverse impacts to
federal species of concern.
11

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NORTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
I G 1 00 N0
MS RENEE GLEDIILL-EARLEY
CLEARINGHOUSE COORDINATOR
DEPT OF CULTURAL RESOURCES
INTERGOVERNMENTAL REVIEW
H11. ENERGY RELATED
FACILITIES/ACTIVITIES
STATE HISTORIC PRESERVATION OFFICE
MSC 4617 - ARCHIVES EUILDING
RALEIGH NC
REVIEW DISTRIBUTION
CA'RE FEAP. COG
DEFT OF AGRICULTURE
DEPT OF CULTUPAL RESOURCES
DEPT OF ENVIR. QUALITY - COASTAL MG
DEPT OF ENVIRONMENTAL QUALITY
DEPT OF TRANSPORTATION
DPS - DIV OF EMERGENCY MANAGEMENT
PROJECT INFORMATIOR
APPLICANT: N.C. Department of Commerce
TYPE: State Environmental Policy Act
Environmental Review
r^: n ,I 1
r `�7�
12016 Li
STATE NUMBER: 16-E-4600-0229
DATE RECEIVED' 02/08/2016
AGENCY RESPflHSE: 03/04/2016
REVIEW CLOSED: 03/09/2016
n
co (6- ".-
DESC= Application of Willard Solar, LLC for a Certificate to construct a 5 -MW Solar
Photovoltaic Facility in. Pender Co. Docket #SP -7474 Sub 1. - View document at
http://sta-wl.ncuc.net/Ncuc/portal/ncuc/page.//Dockets/portal.aspx, Type SP -7474
Sub 1 in the Docket Number search line.
Located along Church Street, approximately 3 .8 miles north from the intersection
of Pelham Road and Mary Slocum Road SW, Willard, NC
The attached project has neer. submitted to the N. C. State Clearinghouse for
intergovernmental review, Please review and submit your response by the above
indicated date to 1301 Mail Service Center, Raleigh NC 27699-1301.
If additional review time is needed, please contact this office at (919)80'"-2425.
AS A RESULT OF THIS REVIEW THE FOLLOWING IS SUBMITTED: NO COMMENT E C010M'TS ATTACHED
SIGNED BY: 9'�LA Lo '
(;q
]DATE : :3 - q -L W
FEB 1 2 M6