1001 Boulders Parkway P 804.200.6500 Suite 300 F 804.560.1016 Richmond, VA 23225 www.timmons.com July 12, 2019 Mr. Davis Plunkett Holocene Clean Energy 727 W. Hargett St, Ste 201 Raleigh, NC 27603 RE: Reams Solar – Limited NEPA Review Dear Mr. Plunkett, Timmons Group has completed a Limited National Environmental Policy Act (NEPA) Review of the Reams Solar project for a proposed solar electric power generation facility. The project encompasses approximately 63.1 acres and is located in Dinwiddie County, Virginia (see Figure 1: Vicinity Map). The study was developed as a preliminary planning tool to help identify potential constraints to assist in planning the proposed Reams Solar Facility (Site). The study consists of a comprehensive review of publicly available environmental mapping and database resources to identify local, state, and federally regulated resources that have the potential to significantly impact the feasibility of the Site. I. Threatened and Endangered Species Database Search An endangered species review was conducted to gain insight regarding the potential presence of Endangered Species Act (ESA) listed species as well as State listed species onsite or in the vicinity of the Site. The following agencies and associated databases were reviewed for threatened and endangered species: • U.S. Fish and Wildlife Services (USFWS) – Information, Planning and Consultations system (IPaC) • Virginia Department of Game and Inland Fisheries (VDGIF) – Wildlife Environmental Review Map Service (WERMS) • Virginia Department of Game and Inland Fisheries (VDGIF) – Virginia Department of Game and Inland Fisheries (VaFWIS) • Virginia Department of Game and Inland Fisheries (VDGIF) – Northern Long Eared Bat (NLEB) Winter Habitat and Roost Tree Locator • Virginia Department of Game and Inland Fisheries (VDGIF) – Little Brown Bat and Tri-colored Bat Winter Habitat & Roosts Locator • Virginia Department of Conservation and Recreation (VDCR) – Division of Natural Heritage (DNH) database • Center for Conservation Biology (CCB) – VaEagles Nest Locator The comprehensive database search determined there is a potential for two species with federal and/or state protection to occur within the project area (see Attachment 1: Threatened and Endangered Database Searches). Potentially present species and the associated databases are listed below in Table 1. CIVIL ENGINEERING | ENVIRONMENTAL | SURVEYING | GIS | LANDSCAPE ARCHITECTURE | CONSTRUCTION SERVICES Reams Solar – Limited NEPA Review Page 2 Holocene Energy Table 1. Species potentially present at Reams Solar Common Name Scientific Name Status Agency Source Mammal Northern Long-eared bat Myotis septentrionalis Federal Threatened USFWS State Threatened Fishes Roanoke Logperch Percina rex Federal Endangered USFWS State Endangered According to the USFWS IPaC results, the federally and state threatened northern long-eared bat (NLEB) (Myotis septentrionalis) has the potential to occur on the Site as shown in Attachment 1: Threatened and Endangered Database Searches. Based upon a review of available information, in particular the VDGIF NLEB Winter Habitat and Roost Tree Locator, there are no known maternity roosts or hibernacula located within or in close proximity to the Project. Therefore, the Project will not affect any known NLEB occupied areas. Additionally, the Project Proponent may rely upon the findings of the January 5, 2016 Programmatic Biological Opinion for the Final 4(d) Rule on the Northern Long-Eared Bat and Activities Excepted from Take Prohibitions to fulfill the project-specific Section 7 responsibilities as needed. The Project Proponent will not be required to implement voluntary conservation measures, such as Time of Year Restrictions for tree clearing, based on the scope of the project. The Roanoke logperch (Percina rex) is a freshwater species that prefers medium to large-sized streams with riffles, runs, and pools, and sand, gravel, or boulder substrates. Although potential suitable habitat exists downstream of the Site, this species has not been documented by DGIF to be observed within the project boundaries or within the 2-mile buffer around the Site. We do not anticipate project related issues/restrictions due to this species, though further agency coordination may be required if state or federal permits are needed. In stream work, if required, may be limited by the time of year restriction (TOYR) between March 15 – June 30. According to the VDGIF Little Brown Bat and Tri-colored Bat Winter Habitat & Roosts Locator, the little brown bat (Myotis lucifugus lucifugus) and tri-colored bat (Perimyotis subflavus) do not have hibernacula within range of the Site. In addition, no eagle nest or roosts are known to be present in the vicinity of the project area. A project review request was initiated with VDCR-DNH and has not yet been received. A memorandum with the results of that database inquiry will be prepared and forwarded upon receipt. II. Cultural Resources We conducted a Virginia Department of Historic Resources (VDHR) database search for the project area and a one-half mile (0.5mi) buffer surrounding the Site. An exhibit showing the approximate location of the Site with known architectural and archaeological resources from the Virginia Cultural Resource Information Services (VCRIS) database, along with information sheets for each of the resources within the search area are included in Attachment 2: VCRIS Database Search. Five architectural resources and two archaeological resources were identified within the search area. The project boundary intersects with two resources, DHR ID 026-0132 and 026-5004, which are both considered eligible for listing on the National Register of Historic Places (NRHP). One other site, DHR ID 026-0050, has been evaluated as potentially eligible. The remainder of the resources have not been evaluated. See Table 2 below. Reams Solar – Limited NEPA Review Page 3 Holocene Energy Table 2. Cultural Resources Preliminarily Identified within 0.5 mi of Reams Solar DHR ID Name Location Status Architectural Resources 026-0132 Hatcher’s Run Battlefield On site Eligible 026-5004 Boydton Plank Road Battlefield On Site Eligible Burgess’ Mill Hatcher’s Run 026-0050 Reams Station Battlefield (I&II) Adjacent Potentially Eligible 026-5146 Smart House (Historic) Adjacent Not Evaluated 026-5147 House, 24205 Old Vaughan Adjacent Not Evaluated Road Archaeological Resources 44DW0107 Camp, Lithic workshop Adjacent Not Evaluated 44DW0108 Camp, Hamlet Adjacent Not Evaluated Resources 026-0132 and 026-5004 are large resources associated with historic battlefields and whose boundaries extend outside of the project limits. III. Summary and Conclusions We have conducted queries of federal and state databases for the presence of threatened and endangered species, as well as the potential presence of cultural and historical resources. If work is proposed in wetlands or waters of the U.S., then Section 401 and Section 404 Clean Water Act Permits will be required. Submittal of a Section 404 Clean Water Act Permit will provide a federal nexus that will trigger review of threatened and endangered species and cultural resources that could further impose timeline restrictions or reduce the developable footprint of the project. We do not anticipate the project to be impacted by the federal and state threatened and endangered species identified in the vicinity. Five architectural resources and two archaeological resources are identified within the search area. Of those, two of the cultural resources are located on the Site and are both classified as eligible for listing on the NRHP. The remaining resources have not yet been evaluated. Further assessment conducted by a registered historian may be required due to the historic nature of the identified resources. We appreciate the opportunity to present this preliminary analysis for planning purposes. Please note that threatened and endangered database searches must be current (data accessed within six months) to be considered current by reviewing agencies. If you have any questions, please contact me at (804) 200-6577 or [email protected]. Sincerely, Julia Campus Attachments Attachment 1 Threatened and Endangered Database Searches Attachment 2 Cultural Resources Search Attachment 1: Threatened and Endangered Database Searches 6/24/2019 IPaC: Explore Location IPaC U.S. Fish & Wildlife Service IPaC resource list This report is an automatically generated list of species and other resources such as critical habitat (collectively referred to as trust resources) under the U.S. Fish and Wildlife Service's (USFWS) jurisdiction that are known or expected to be on or near the project area referenced below. The list may also include trust resources that occur outside of the project area, but that could potentially be directly or indirectly aected by activities in the project area. However, determining the likelihood and extent of eects a project may have on trust resources typically requires gathering additional site-specic (e.g., vegetation/species surveys) and project-specic (e.g., magnitude and timing of proposed activities) information. Below is a summary of the project information you provided and contact information for the USFWS oce(s) with jurisdiction in the dened project area. Please read the introduction to each section that follows (Endangered Species, Migratory Birds, USFWS Facilities, and NWI Wetlands) for additional information applicable to the trust resources addressed in that section. Location Dinwiddie County, Virginia