ML26009A050

Duke Energy Progress, LLC - H.B. Robinson, Unit 2, Subsequent License Renewal Request for Concurrence with Endangered Species Act Determinations

ML26009A050
Person / Time
Site:	Robinson
Issue date:	01/08/2026
From:	Hall Z Duke Energy Progress
To:	Olds M Office of Nuclear Material Safety and Safeguards, US Dept of Interior, Fish & Wildlife Service, South Carolina Ecological Services
References
Download: ML26009A050 (0)

Text

Biological Assessment for the U.S.

Fish and Wildlife Service Prepared by the U.S. Nuclear Regulatory Commission and Duke Energy Progress, LLC for H.B. Robinson Steam Electric Plant, Unit 2 Subsequent License Renewal Docket No. 50-261 and Operating License No. DPR-23 Darlington County, South Carolina

H.B. Robinson Steam Electric Plant Biological Assessment December 2025 Table of Contents 1.0 Introduction.................................................................................................................. 1 2.0 Description of Proposed Action.................................................................................. 1 3.0 Action Area................................................................................................................... 2 4.0 Federally Listed Species Considered......................................................................... 3 4.1 Tricolored Bat............................................................................................................. 3 4.2 Red-cockaded Woodpecker........................................................................................ 4 4.3 Monarch Butterfly....................................................................................................... 6 4.4 Rough-leaved Loosestrife........................................................................................... 7 4.5 Southern Hognose Snake........................................................................................... 7 4.6 Summary of Potential Species Occurrence in the Action Area.................................... 8 5.0 Proposed Action Effects Analysis.............................................................................. 9 5.1 Tricolored Bat............................................................................................................. 9 5.2 Red-cockaded Woodpecker.......................................................................................10 5.3 Monarch Butterfly......................................................................................................10 5.4 Rough-leaved Loosestrife..........................................................................................11 5.5 Southern Hognose Snake..........................................................................................11 5.6 Cumulative Effects.....................................................................................................12 5.7 Conservation Measures.............................................................................................12 6.0 Determination of Effects.............................................................................................14 7.0 References...................................................................................................................18 7.1 Figure References.....................................................................................................19 i

H.B. Robinson Steam Electric Plant Biological Assessment December 2025 List of Tables Table 1 Potential Occurrences of Federally Listed Species in the Action Area................. 8 Table 2 Effects Determinations for Federally Listed Species..........................................15 List of Figures Figure 1 RNP Site Location..............................................................................................16 Figure 2 RNP ESA Action Area........................................................................................17 Appendices Appendix A: Endangered Species Consultation History Appendix B: Safe Harbor Agreement Annual Reports (2019-2024)

Appendix C: 2024 Monarch Candidate Conservation Agreement with Assurances Annual Compliance Report ii

H.B. Robinson Steam Electric Plant Biological Assessment December 2025 Acronyms AOI area of influence BA biological assessment CCAA Candidate Conservation Agreement with Assurances CFR Code of Federal Regulations CWA Clean Water Act CWIS cooling water intake structure Duke Energy Duke Energy Progress, LLC ESA Endangered Species Act IVM integrated vegetation management NMFS National Marine Fisheries Service NRC United States Nuclear Regulatory Commission RNP H.B. Robinson Steam Electric Plant SCDNR South Carolina Department of Natural Resources SLR subsequent license renewal USFWS United States Fish and Wildlife Service iii

H.B. Robinson Steam Electric Plant Biological Assessment 1

December 2025

1.0 INTRODUCTION

Informal consultation is an optional process that includes all discussions and correspondences between the United States Fish and Wildlife Service (USFWS), the National Marine Fisheries Service (NMFS), and the Federal agency or the designated non-Federal representative, identified to assist the Federal agency in determining whether formal consultation or a conference is required, per Title 50 of the Code of Federal Regulations (CFR) Section 402.13.

The United States Nuclear Regulatory Commission (NRC) is the federal agency licensing operations of domestic nuclear power plants in accordance with the Atomic Energy Act of 1954 and NRC implementing regulations. This licensing includes operations of the H.B. Robinson Steam Electric Plant (RNP) operated by Duke Energy Progress, LLC (Duke Energy). RNP is located in Darlington County, South Carolina, on the southwestern shores of Lake Robinson (see Figure 1).

The NRC is responsible for conducting consultations with the USFWS and NMFS under section 7 of the Endangered Species Act of 1973 (ESA), as amended. ESA regulations allow Federal action agencies to designate a non-Federal representative to conduct informal consultation and to prepare a biological assessment (BA) (50 CFR 402.08).

This document is a BA of potential effects on ESA-listed species, and species proposed for listing, from continued operation of RNP under the subsequent license renewal (SLR) for Unit 2.

Potential effects from plant operations considered here are those associated with species under jurisdiction of the USFWS. This official list of species (Appendix A) comes from the USFWS Information for Planning and Consultation tool and was verified in coordination with the NRC staff. Two federally listed species, and two species proposed for federal listing, were identified as having the potential to be present in the RNP action area (Figure 2) by the USFWS. These include tricolored bat (Perimyotis subflavus; proposed endangered), red-cockaded woodpecker (Dryobates borealis; threatened), monarch butterfly (Danaus plexippus; proposed threatened),

rough-leaved loosestrife (Lysimachia asperulaefolia; endangered) and southern hognose snake (Heterodon simus; proposed threatened). There is no critical habitat for any listed or proposed species within the RNP action area per the USFWS.

In May 2025, the NRC designated Duke Energy as a non-federal representative to prepare a BA for section 7 consultation. This BA serves to inform the informal section 7 consultation between the NRC and USFWS. A copy of the letter designating Duke Energy as the non-federal representative is provided in Appendix A.

2.0 DESCRIPTION

OF PROPOSED ACTION The proposed action is to renew for a second time, and for an additional 20-year period, the operating license for RNP. License renewal preserves the option for Duke Energy to continue operating RNP and provide reliable baseload power for the proposed SLR operating term. For

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December 2025 RNP, the proposed action would extend the operating license from July 31, 2030, to July 31, 2050. (Duke Energy 2025) 3.0 ACTION AREA Action areas are areas affected directly or indirectly by the federal action and not merely the immediate area involved in the action, as described in 50 CFR 402.02. The action area bounds the analyses of federally listed species and critical habitats because only the federally listed species and critical habitats that occur within the action area may be affected by the federal action. For the purpose of assessing potential impacts of the license renewal on federally listed species, the action area is defined below and illustrated in Figure 2.

Terrestrial Region The terrestrial region of the action area consists of 3,905 acres of the RNP site in Darlington and Chesterfield Counties. The majority of the site (29 percent) consists of planted evergreen forest; this is followed by woody wetlands at approximately 12 percent. The remaining 12 terrestrial land use/land cover categories account for approximately 25 percent of the site. The remainder of the RNP site consists of open water and is included in the aquatic action area as defined below. (Duke Energy 2025)

Aquatic Region The aquatic region of the action area encompasses the following areas as influenced by RNP operations:

the impingement area of influence (AOI) as described in the Clean Water Act (CWA),

section 316(b) demonstration report; the RNP discharge canal; and the discharge area into Lake Robinson that receives maximum thermal conditions during normal plant operations, as described in the 1976 CWA, section 316(a) demonstration report.

The face of cooling water intake structure (CWIS) 1 is approximately 30 feet in length.

Impingeable-sized organisms in Lake Robinson in the vicinity of CWIS 1 would be subject to velocities less than 0.5 feet per second, and the impingement AOI does not extend out into the waterbody. The face of CWIS 2 is approximately 40 feet in length. The CWIS 2 AOI extends into Lake Robinson at both the normal operating elevation and low water elevation since the cross-sectional length required to achieve the impingement threshold velocity of 0.5 feet per second is greater than the length of the face of the CWIS. Based on these calculations, a conservative impingement AOI for CWIS 2 is represented as the area defined by an arc extending approximately 19 feet into Lake Robinson from the center of CWIS 2. The total area that is encompassed by the Unit 2 impingement AOI is equal to approximately 575 square feet.

(Duke Energy 2025)

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December 2025 Due to the variability associated with biological, physical, and temporal factors influencing aquatic organism entrainment, an entrainment AOI has not been quantified for RNP (Duke Energy 2025).

The maximum thermal conditions of the discharge area into Lake Robinson occur during July and August under normal plant operation. This area is located in the mid-impoundment area where heated discharge waters form a layer over considerably cooler bottom waters. Because natural temperatures in Lake Robinson can approach 32 degrees Celsius (90 degrees Fahrenheit), anything over this temperature threshold is considered as affected by the RNP thermal discharge and within the boundary of the aquatic action area. Based on this information, as well as isotherm data provided in the 1974 316(a) demonstration report, the discharge area influenced by the summer maximum thermal conditions includes the entire width of Lake Robinson from the discharge canal, upgradient approximately 1.3 miles, and downgradient to the Robinson Impoundment. (CP&L 1974)

Based on the information above, the aquatic action area includes the RNP discharge canal and Lake Robinson from approximately 80.1727094 W, 34.4747600 N at the upgradient extent to the Robinson Impoundment at approximately 80.1477753 W, 34.4023665 N.

4.0 FEDERALLY LISTED SPECIES CONSIDERED The ranges of five federally listed species, or species proposed for listing, overlap with the RNP action area. All five species are under USFWS jurisdiction and are described in the following sections. No critical habitat for any of these species occurs in the RNP action area. A USFWS official species list for the RNP action area is provided in Appendix A.

4.1 Tricolored Bat The tricolored bat is a proposed endangered species under the ESA. This species is a small insectivorous bat that is distinguished by its unique tricolored fur and often appears yellowish to nearly orange. During the winter, tricolored bats are often found in caves and abandoned mines, although in the southern United States, where caves are sparse, tricolored bats are often found roosting in road-associated culverts where they exhibit shorter torpor bouts and forage during warm nights. During the spring, summer, and fall, tricolored bats are found in forested habitats where they roost in trees, primarily among leaves of live or recently dead deciduous hardwood trees, but may also be found in Spanish moss, pine trees, and occasionally human structures.

No critical habitat has been designated for this species. (USFWS 2025a)

Tricolored bats face extinction primarily due to the range-wide impacts of white-nose syndrome, a fungal disease caused by the fungus Pseudogymnoascus destructans which is affecting cave-dwelling bats across the continent. White-nose syndrome has caused estimated declines of more than 90 percent in affected tricolored bat colonies across the majority of the species range. To address the growing threat of white-nose syndrome to the tricolored bat and other bats across North America, the USFWS is leading the White-nose Syndrome National

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December 2025 Response Team, a coordinated effort of more than 150 non-governmental organizations, institutions, Tribes, and state and federal agencies to conduct critical white-nose syndrome research and develop management strategies to minimize impacts of the disease and recover affected bat populations. (USFWS 2025a)

RNPs action area is within the zone 1 year-round active area for the tricolored bat. Further, RNPs building structures and forested areas surrounding the plant could potentially provide suitable roosting and maternity habitat for tricolored bats. However, the species has not been recorded as occurring on the RNP site, and no observations of tricolored bat have been made in the building structures or adjacent forested areas. (Duke Energy 2025) Therefore, tricolored bats may potentially be present within the action area year-round, though the likelihood of occurrence is expected to be uncommon.

4.2 Red-cockaded Woodpecker In November 2024, the red-cockaded woodpecker was downlisted from an endangered species to a threatened species under the ESA (USFWS 2024). Red-cockaded woodpeckers have very large foraging territories requiring vast areas of open pine habitat. Suitable foraging habitat consists of large mature pines, little or no midstory, and abundant herbaceous ground cover including native bunchgrasses (i.e., wiregrass) and forbs. Red-cockaded woodpeckers require 75 to 200 acres of this foraging habitat, depending on the habitat quality. Red-cockaded woodpeckers prefer to forage on mature longleaf pine (Pinus palustris) but will forage on younger trees and other pine species including loblolly pine (Pinus taeda), shortleaf pine (Pinus echinata), pond pine (Pinus serotina), slash pine (Pinus elliottii), and the occasional hardwood tree. High-quality foraging habitat that results in the highest red-cockaded woodpecker productivity is contiguous open stands of mature longleaf pine with an herbaceous ground cover. (SCDNR 2015)

Red-cockaded woodpeckers typically nest in the roost cavity of the breeding male, and it is often the newest among several cavities shared by the family group. These nests are usually found in live pine trees whose heartwood has been weakened by red heart fungus. Nesting sites can be located over 100 feet high and are commonly oriented toward the west or south. The size and shape of nest cavities can change over time and are influenced by the pattern of heart rot within the tree. Typically, the entrance is 2 to 3 inches wide, while the interior can expand to about 3 to 4 inches at its broadest point. Although these cavities dont contain a traditional nest, theyre often lined with wood chips left behind during the excavation process. (CU 2025)

The primary factor leading to the decline of red-cockaded woodpecker is habitat loss. Because the species has specialized habitat requirements, they are extremely vulnerable to land use changes. Current forestry practices do not usually allow pine trees to attain the age necessary for red-cockaded woodpecker habitat. (SCDNR 2015)

Red-cockaded woodpeckers are tracked by groups and clusters. Groups include either a breeding pair with up to seven helpers or a lone male. Clusters include aggregated cavity trees

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December 2025 as well as the surrounding land. In 2000, South Carolina recorded 133 groups on state land, 524 on federal land, and 400 on private land. Altogether, these figures indicated that the state was home to more than 1,000 woodpecker groups, accounting for nearly one-fifth of the total known population at the time. (SCDNR 2015)

Red-cockaded woodpeckers in the Carolina Sandhills are distributed between two population units, Sandhills East and Sandhills West. Most red-cockaded woodpecker groups within Sandhills East occur on the federally managed Fort Bragg Military Installation in Hoke, Harnett, Moore, and Cumberland Counties, North Carolina, while the majority of Sandhills West occurs on Sandhills Game Land in Richmond and Scotland Counties. Both Sandhills East and Sandhills West have increased in estimated population in the last decade. (SEI 2025)

In a 2020 study by USFWS, red-cockaded woodpecker populations were grouped into ecoregions, as defined in the USFWS 2003 Recovery Plan (USFWS 2003), to provide a comparative reference for past, current, and estimated future conditions for representation. RNP occurs in the Mid-Atlantic Coastal Plain ecoregion, which is similar, though broader than the Environmental Protection Agency Level III Middle Atlantic Coastal Plain ecoregion. This ecoregion contains two primary core populations: Coastal North Carolina and Francis Marion National Forest. In addition, the ecoregion contains many important and significant support populations. (USFWS 2020) According to the 2003 Recovery Plan, populations in the Mid-Atlantic Coastal Plain were stable and increasing at the time of the report (USFWS 2003).

Resilience (a populations ability to withstand deterministic and stochastic events of limited intensity and frequency) and redundancy (the ability of a species to withstand catastrophic events) population attributes were characterized as part of the 2020 study.

At the time of the 2020 study, the Mid-Atlantic Coastal Plain contained the most red-cockaded woodpecker populations (24) and had one highly resilient population and one moderately resilient population; the remaining populations were of low or very low resilience categories. Of the 13 ecoregions in the study, those with high and very high resilience were restricted to only four regions: Mid-Atlantic Coastal Plain, East Gulf Coastal Plain, South Atlantic Coastal Plain, and Sandhills. At the time of the 2020 study, the Mid-Atlantic Coastal Plain was one of four ecoregions that had some level of redundancy in terms of relatively resilient populations.

(USFWS 2020)

The 2020 study also provided future redundancy and representation summary for red-cockaded woodpecker ecoregions by number of simulated populations and resilience category under future management scenarios. Under all the management scenarios, five populations fell in the very high resilience category, occurring in the East Gulf Coastal Plain (2), Sandhills (1), Mid-Atlantic Coastal Plain (1), and South-Atlantic Coastal Plain (1). (USFWS 2020)

Much of the upland Duke Energy property west of Lake Robinson and south of Secondary State Route 346 consists of forest from timber that has been harvested in the past for silviculture.

After timber was removed/harvested, areas were replanted with tree species appropriate to the

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December 2025 terrain, soils, and drainage characteristics of the site, including loblolly pine, slash pine, or longleaf pine. (NRC 2003) As previously stated, red-cockaded woodpecker will forage on these younger pines, thus presenting suitable habitat for the species.

According to the NRCs 2003 Supplemental Environmental Impact Statement for license renewal, two abandoned red-cockaded woodpecker cavity trees were located on the RNP site near the Darlington County Internal Combustion Turbine Electric Plant. Both of these cavity trees had been abandoned for many years, and field surveys confirmed that no active cavity trees or foraging habitat for the species was present. (NRC 2003) As described in Section 5.7 under the Red-Cockaded Woodpecker Safe Harbor Agreement, there have been no documented observed occurrences of red-cockaded woodpeckers in the RNP action area since the 2003 Supplemental Environmental Impact Statement (Duke Energy 2025). Still, growing populations of red-cockaded woodpeckers, as evidenced in the Carolina Sandhills, exhibit the possibility for the species to potentially expand into the action area over the 20-year license renewal term. As such, red-cockaded woodpeckers may become present within the action area while foraging or passing through to preferentially suitable foraging or nesting habitat. However, because of the sparsity of suitable foraging and nesting habitat within the RNP action area, the likelihood of red-cockaded woodpecker occurrence is expected to remain uncommon.

4.3 Monarch Butterfly The monarch butterfly is a proposed threatened species under the ESA. Adult monarch butterflies are large and conspicuous, with bright orange wings surrounded by a black border and covered with black veins. The black border has a double row of white spots, present on the upper side of the wings. Adult monarchs feed on the nectar of many flowers during breeding and migration, but they can only lay eggs on milkweed plants. For overwintering monarchs, a habitat with a specific microclimate is needed for protection from the elements, as well as moderate temperatures to avoid freezing. Monarch butterflies require healthy and abundant milkweed plants for laying eggs on and as a food source for larvae or caterpillars. By consuming milkweed plants, monarchs obtain toxins, called cardenolides, that provide a defense against predators. Additionally, nectar from flowers is needed for adults throughout the breeding season, migration, and overwintering. Monarchs are native to North and South America but have since spread to many other locations where milkweed and suitable temperatures exist.

(USFWS 2025b)

The eastern North American migratory monarch population is the largest population of monarchs, in both individuals and range. The eastern population encompasses upwards of 70 percent of the total North American monarch range. In the fall, they may fly more than 2,000 miles to reach overwintering sites in Mexico. (USFWS 2025b)

Suitable habitat for the monarch butterfly is likely present in undeveloped portions (approximately 1,013 acres) of the RNP action area that are not maintained by frequent mowing, including grasslands, shrub-scrub, herbaceous wetlands, cultivated cropland, disturbed open spaces, and pasture (Duke Energy 2025). Therefore, the likelihood of monarch butterfly

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December 2025 occurrence in the RNP action area would be occasional and limited to their fall (late September to November) and spring (April) migration and breeding periods (Table 1).

4.4 Rough-leaved Loosestrife Rough-leaved loosestrife is listed as an endangered species under the ESA. Rough-leaved loosestrife is a perennial herb that grows about 12 to 24 inches tall. The triangular shaped leaves are often opposite on shorter stems and tend to be arranged in whorls of three or four encircling taller stems. The leaves are widest at the base and have three prominent veins.

Contrary to the common name, the leaf surfaces are smooth to the touch. The yellow flowers are 0.6 inches across with yellow-orange anthers and occur on terminal racemes that are 1.2-3.9 inches long. Flowering occurs from mid-May through June, with fruits present from July through October. Stipitate glands are usually present on most parts of the plant.

(USFWS 2025c)

This species generally occurs in the ecotones between longleaf pine uplands and pond pine pocosins on moist to seasonally saturated sands and on shallow organic soils overlaying sand.

Rough-leaved loosestrife has also been found on deep peat in the low shrub community of large Carolina bays. The grass-shrub ecotone, where rough-leaved loosestrife is found, is fire maintained, as are the adjacent plant communities (longleaf pine - scrub oak, savanna, flatwoods, and pocosin). Several populations are known from roadsides and power line rights of way where regular maintenance mimics fire and maintains vegetation so that herbaceous species are open to sunlight. Fire suppression, wetland drainage, and residential and commercial development have altered and eliminated habitat for this species and continue to be the most significant threats to the continued existence of the species. (USFWS 2025c)

There have been no known occurrences of rough-leaved loosestrife in the RNP action area (Duke Energy 2025). Further, the only population of rough-leaved loosestrife known to occur in Darlington County has been extirpated (USFWS 2021). In fact, the single extant site in South Carolina is located at the Fort Jackson Army Training Center in Richland County, more than 40 miles southwest of RNP (USFWS 2025c). Additionally, suitable habitat for this species (i.e.,

transitional zones between pond pine pocosins and upland longleaf pine) is not present on site.

4.5 Southern Hognose Snake On August 29, 2025, the USFWS announced a proposal to list the southern hognose snake as a threatened species under the ESA. The southern hognose snake is the smallest of the hognose snakes. It has a sharply upturned keeled snout. The head is dusky brown above the snout, with a dark transverse bar that often occurs on the snout in front of the eyes. There is a dark brown or black stripe on either side of the neck, and a short dark stripe may occur from the rear of the eye to the corner of the mouth. The top of the body is beige or tan with three longitudinal rows of dark brown blotches outlined anteriorly and posteriorly with black and a light orange to tan stripe along the center of the back. The underside varies in color from white,

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December 2025 cream, yellowish, or pinkish brown and has faint brownish pigment, usually near the tail. The underside of the tail is the same color as the belly. (USFWS 2025d)

According to the University of Georgias Savannah River Ecology Laboratory, while historically this species was found across the Coastal Plain from southern North Carolina through most of Florida and west to southern Mississippi, today this snake is restricted to scattered populations in North Carolina, South Carolina, Georgia, and Florida. Populations are closely tied to xeric sandy habitats such as sandhills, pine flatwoods, sand ridges, and coastal dunes, though this snake may persist in agricultural or suburban areas with suitable sandy soils. Population declines are attributed to habitat loss (longleaf pine forest conversion, urban development, agriculture) and impacts from invasive fire ants (Solenopsis invicta). (SREL 2025)

According to USFWS, the current known range of southern hognose snake overlaps with the RNP action area (USFWS 2025e). The RNP action area contains pine flatwoods and sandy soils that may be suitable for the species. Because southern hognose snake prefers xeric sandy soils, the potential habitat at RNP is likely limited due to the soils moisture content (Duke Energy 2025). No occurrences of southern hognose snake have been documented on the RNP site.

4.6 Summary of Potential Species Occurrence in the Action Area Table 1 below summarizes the potential for each of the four listed species to occur in the RNP action area.

Table 1 Potential Occurrences of Federally Listed Species in the Action Area Scientific Name Common Name Period of Occurrence in South Carolina Likelihood of Occurrence in RNP Action Area Perimyotis subflavus Tricolored Bat Resident Uncommon Dryobates borealis Red-Cockaded Woodpecker Resident Uncommon Danaus plexippus Monarch Butterfly Spring (migration, breeding)

Fall (migration)

Occasional Lysimachia asperulaefolia Rough-leaved Loosestrife Resident Does not occur Heterodon simus Southern Hognose Snake Resident Does not occur (SCDNR 2015; USFWS 2024; USFWS 2025f; USFWS 2025c; USFWS 2025a)

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December 2025 5.0 PROPOSED ACTION EFFECTS ANALYSIS All RNP operations are located in previously disturbed areas, and no vegetation clearing is anticipated for the proposed action that would potentially impact habitat for the species covered in this BA. Species-specific effects analyses are described in detail below.

5.1 Tricolored Bat As previously mentioned, tricolored bats have not been recorded as occurring in the RNP action area. However, RNPs building structures and forested areas surrounding the plant potentially provide suitable roosting and maternity habitat for this species. RNP does not currently have specific requirements to track bats onsite and no specific assessment has been made of the extent or quality of tricolored bat habitat at the RNP site. (Duke Energy 2025) However, given the general habitat requirements of this species, it can be conservatively assumed that suitable habitat to varying degrees is present within the forested areas of the site as well as manmade structures at the site.

Potential impacts to the tricolored bat from the operations of RNP are discussed below (Duke Energy 2025):

Mortality or injury from collisions with plant structures: Bat collisions with plant structures at nuclear power plants are not well documented but are likely to be rare. There have been no documented bat mortality incidents at the RNP site and there will be no changes to the RNP site during the SLR period that may increase the potential risk for collisions.

Loss, degradation, or disturbance of habitat: No construction, land clearing, or other ground-disturbing activities are anticipated for the proposed action. Additionally, all plant operations, including herbicide application, are located in previously disturbed areas, and no tree clearing is anticipated for the proposed action.

Behavioral changes from continued operations, refurbishment and/or construction activities: No construction, ground-disturbing activities, or license-related refurbishment activities have been identified or proposed at the RNP site related to the proposed action. Further, operational activities during the SLR period are anticipated to be a continuation of current, normal operations at RNP. Any bat species, if present on the RNP site, has likely already acclimated to the noise, vibration, and general human disturbances associated with site maintenance, infrastructure repairs, and other site activities. Moreover, the undisturbed, forested areas surrounding the structures likely provide more suitable habitat; hence, it is unlikely that tricolored bats would establish a colony in the manmade structures at RNP. As such, behavioral changes from refurbishment and/or construction activities to tricolored bats related to the proposed action are unlikely.

H.B. Robinson Steam Electric Plant Biological Assessment 10 December 2025 Duke Energy completed the USFWS Northern Long-eared Bat and Tricolored Bat Range-wide Determination Key as part of this BA. Based on the information provided, it has been determined that the proposed action MAY AFFECT BUT IS NOT LIKELY TO ADVERSELY AFFECT the tricolored bat. Because the tricolored bat is proposed for Federal listing, the ESA does not require consultation with USFWS regarding this species, as long as the continued existence of the species is not jeopardized.

A copy of the USFWS consistency letter for tricolored bat is provided in Appendix A.

5.2 Red-cockaded Woodpecker All plant operations are located in previously disturbed areas, and no vegetation clearing is anticipated for the proposed action that would potentially impact habitat for the red-cockaded woodpecker. This species, if present on the RNP site, has likely already acclimated to the noise, vibration, and general human disturbances associated with site maintenance, infrastructure repairs, and other site activities. Moreover, the undisturbed, forested areas within the RNP action area with large, mature pine trees likely provide more suitable habitat. Further, Duke Energy maintains an avian protection procedure to ensure and plan for compliance with the requirements of all bird protection regulations and laws. Duke Energy also maintains a natural resource management program to support compliance with avian protection and endangered species, as well as an endangered species procedure to ensure compliance with the ESA.

(Duke Energy 2025) Additional information on these procedures is provided in Section 5.6 of this BA.

Duke Energy also maintains a Certificate of Inclusion for the red-cockaded woodpecker and participates in the USFWS Red-Cockaded Woodpecker Safe Harbor Agreement. This Agreement extends through 2029 and is detailed in Section 5.6 of this BA.

Duke Energy completed the USFWSs South Carolina Ecological Services Field Office Determination Key for red-cockaded woodpecker as part of this BA. Based on the information provided, it has been determined that the proposed action MAY AFFECT BUT IS NOT LIKELY TO ADVERSELY AFFECT the red-cockaded woodpecker.

A copy of the USFWS consistency letter for red-cockaded woodpecker is provided in Appendix A. The consistency letter confirms Duke Energy may rely on effect determinations reached by considering the South Carolina Ecological Services Field Office Determination Key to satisfy agency consultation requirements under Section 7(a)(2) of the ESA.

5.3 Monarch Butterfly Duke Energy does not have specific requirements to track or maintain monarch habitat at RNP.

All plant operations are located in previously disturbed areas, and no vegetation clearing is anticipated for the proposed action that would potentially impact habitat for the monarch butterfly. Any potential ground-disturbing activities associated with general operations and

H.B. Robinson Steam Electric Plant Biological Assessment 11 December 2025 maintenance would undergo environmental compliance reviews that include an evaluation of potential impacts to protected species prior to the activity occurring (Duke Energy 2025).

Duke Energy participates in the Candidate Conservation Agreement with Assurances (CCAA) for the monarch butterfly, an agreement with the USFWS designed to provide and conserve monarch habitat (Duke Energy 2025). Practices under the CCAA include application of selective herbicides, mowing, hand-cutting, leaving fallow, and in some cases native plantings and prescribed fire to protect existing habitat and over time through conservation measures increase overall habitat for monarch butterflies, and by default, other pollinators and wildlife that share the same habitat. Additional information on the CCAA for the monarch butterfly is described in Section 5.6 of this BA.

Existing regulatory programs the site is subject to, including management of herbicide applications, ensure that terrestrial habitat is protected. As such, proposed action MAY AFFECT BUT IS NOT LIKELY TO ADVERSELY AFFECT the monarch butterfly. Because the monarch butterfly is proposed for Federal listing, the ESA does not require consultation with USFWS regarding this species, as long as the continued existence of the species is not jeopardized.

5.4 Rough-leaved Loosestrife As previously mentioned, there have been no known occurrences of rough-leaved loosestrife in the RNP action area, and the species has been extirpated from Darlington County. The closest known extant population of rough-leaved loosestrife is located over 40 miles southwest of RNP.

As mentioned above in Section 4.4, suitable habitat for this species is not present on site. Given its extirpation from the county and lack of suitable habitat on site, it can be concluded that rough-leaved loosestrife does not occur in the RNP action area.

As such, the proposed action would have NO EFFECT on rough-leaved loosestrife. Therefore, no consultation with the USFWS pursuant to Section 7(a)(2) of the ESA is required for the species.

5.5 Southern Hognose Snake As mentioned in Section 4.5, there have been no known occurrences of the southern hognose snake in the RNP action area. The last observations of the species near RNP were recorded in 2008, approximately 1.5 miles west of the site as well as 5 miles north of the site.

Though limited, potential habitat for this species may exist on the RNP site. All plant operations are located in previously disturbed areas, and there are no plans for construction or other ground-disturbing activities anticipated for the proposed action. Therefore, natural areas (such as pine stands) within the RNP site where this species might occur is not anticipated to be impacted by the proposed action. In any case, any potential ground-disturbing activity associated with general operations and maintenance is expected to undergo environmental compliance reviews that include an evaluation of potential impacts to protected species prior to the activity occurring. Adequate management programs and regulatory controls are in place to

H.B. Robinson Steam Electric Plant Biological Assessment 12 December 2025 ensure that important plant and animal habitats are protected during the proposed operating term. Based on the information provided, it has been determined that the proposed action MAY AFFECT BUT IS NOT LIKELY TO ADVERSELY AFFECT the southern hognose snake.

5.6 Cumulative Effects Cumulative effects are those effects of future State or private activities, not involving Federal activities, that are reasonably certain to occur within the action area of the Federal action subject to consultation (50 CFR 402.02). When formulating biological opinions during formal section 7 consultation, the USFWS and the NMFS consider cumulative effects when determining the likelihood of jeopardy or adverse modification. During informal consultation, a Federal agency need only consider cumulative effects under the ESA in the biological evaluation if listed species would be adversely affected by the proposed action and formal section 7 consultation is necessary (USDA-NRCS 2013; USFWS 1998). Because this evaluation has concluded that the proposed SLR would not likely adversely affect the tricolored bat, red-cockaded woodpecker, monarch butterfly, rough-leaved loosestrife and the southern hognose snake, consideration of cumulative effects is not necessary.

5.7 Conservation Measures The following conservation measures include plans and procedures maintained by Duke Energy at RNP, in addition to collaborations with State and Federal agencies that are directly related to the conservation of species considered in this BA.

Duke Energy Plans and Procedures Duke Energy maintains an internal natural resource management group and program to ensure Duke Energy business units are aware of their obligation to comply with several natural resource-based compliance requirements. This program lays out requirements related to training, project planning and siting, and the permitting and regulatory compliance regarding natural resources. Managing natural resources supports compliance with avian protection, cultural resources, and endangered species, and the application of an environmental requirements review checklist. (Duke Energy 2025)

Duke Energy also possesses an avian protection procedure to ensure compliance with requirements of all bird protection regulations and laws promulgated to reduce avian mortality.

State and Federal laws protect all species of native birds found throughout the Duke Energy service area. Further, Duke Energy maintains an active USFWS Special Purpose Utility Permit (SPUT No. MB000257) and South Carolina Department of Natural Resources (SCDNR)

Migratory Bird Permit (No. MB-4-25) for RNP. (Duke Energy 2025)

Duke Energy also maintains pesticide management and compliance procedures to provide guidance to ensure the appropriate application of pesticide products required for Duke Energy

H.B. Robinson Steam Electric Plant Biological Assessment 13 December 2025 operations. These procedures detail specific requirements for pest control functions that include pesticide purchasing, application, storage, and disposal. (Duke Energy 2025)

Certificate of Inclusion for Red-Cockaded Woodpecker The Certificate of Inclusion certifies that the RNP site is included within the scope of Incidental Take Permit (No. 834071), issued to the SCDNR by the USFWS. This Incidental Take Permit was issued on March 24, 1998, and is active for a period of 30 years. This permit authorizes certain activities by participating landowners as part of a conservation plan to restore and enhance habitat for the endangered red-cockaded woodpecker. Pursuant to the Incidental Take Permit and the Certificate of Inclusion, the current and future owners of RNP are authorized to engage in any activity on such property that may result in the incidental taking of red-cockaded woodpeckers, subject only to the terms and conditions of such permit and the Red-cockaded Safe Harbor Agreement entered into pursuant thereto by the SCDNR and Duke Energy (formerly Carolina Power & Light Company) on October 28, 1999. (Duke Energy 2025)

Red-Cockaded Woodpecker Safe Harbor Agreement In 1999, the SCDNR and Duke Energy entered into a Red-Cockaded Woodpecker Safe Harbor Agreement to maintain and enhance habitat for the red-cockaded woodpecker at RNP. Under this agreement, Duke Energy provides SCDNR with reasonable notice of any activities that may result in the incidental take of red-cockaded woodpeckers within Duke Energy owned property.

Activities that may result in an "incidental take" include: any timber harvesting within a cluster, any timber harvesting within foraging habitat that reduces basal area in pine trees greater than 10 inches diameter at breast height below 3,000 square feet, application of forest chemicals within a cluster, new road construction within or near a cluster, and any new building construction within or near a cluster. All other silvicultural activities should not affect red-cockaded woodpeckers and do not require notification. (Duke Energy 2025)

In addition, Duke Energy submits brief annual reports to the SCDNR that include information on the presence or absence of red-cockaded woodpeckers, management and enhancement activities, and financial assistance and research, if applicable. No red-cockaded woodpeckers or active cavity trees have been reported at RNP as part of the Red-cockaded Woodpecker Safe Harbor Agreement. (Duke Energy 2025) Copies of the annual reports submitted to SCDNR for monitoring years 2019 through 2024 are provided in Appendix B.

Monarch Candidate Conservation Agreement with Assurances In 2022, Duke Energy signed the CCAA with the USFWS for the monarch butterfly. This agreement is designed to protect existing habitat and over time through conservation measures increase overall habitat for monarch butterflies, and by default, other pollinators and wildlife that share the same habitat. (Duke Energy 2025)

Currently, Duke Energy has enrolled a total of 1,308,909 acres of transmission and distribution rights-of-way across 105 sites in this program. There are 46 sites in the Midwest and 59 sites in

H.B. Robinson Steam Electric Plant Biological Assessment 14 December 2025 the Southeast. This acreage will increase over time as additional corridors of suitable habitat are identified. Effectiveness monitoring results provided in the latest annual compliance report indicate that 69 sites contained over 26 percent nectar plants; 41 sites contained milkweed; and 446 milkweed stems were counted during surveys. A copy of the 2024 CCAA annual compliance report, which contains the latest information on the status of the CCAA, is provided in Appendix C.

The conservation measures most frequently used for the Monarch CCAA fall under the Duke Energy integrated vegetation management (IVM) program. IVM uses best management practices for a specific site based on the conservation of the natural resources present. As mentioned in Section 5.3 above, practices include application of selective herbicides, mowing, hand-cutting, leaving fallow, and in some cases native plantings and prescribed fire.

Conservation measures are reported on a company-wide scale and are recorded using an internal environmental Geographic Information System mapping program. The entire RNP site falls under the IVM program. (Duke Energy 2025) 6.0 DETERMINATION OF EFFECTS Based on the foregoing analysis in Section 5.0 of this evaluation, and because there are no proposed changes in operation and no planned construction, land clearing, or other ground-disturbing activities associated with the RNP SLR, any potential impacts on the tricolored bat, red-cockaded woodpecker, and monarch butterfly resulting from the proposed action are anticipated to be insignificant or discountable. Therefore, the proposed action MAY AFFECT BUT IS NOT LIKELY TO ADVERSELY AFFECT the tricolored bat, red-cockaded woodpecker, monarch butterfly, and southern hognose snake. Further, rough-leaved loosestrife has no potential to occur within the action area and no potentially suitable habitat is present within the RNP action area; therefore, the proposed action would have NO EFFECT on this species.

These conclusions are listed below in Table 2.

In July 2025, Duke Energy participated in an informal consultation with the Regulatory Lead of the USFWS South Carolina Field Office. During the discussion, USFWS did not indicate substantial concerns regarding the impacts of the proposed action on the federally listed species described in this BA.

H.B. Robinson Steam Electric Plant Biological Assessment 15 December 2025 Table 2 Effects Determinations for Federally Listed Species Scientific Name Common Name Federal Status(a)

Effect Determination Perimyotis subflavus Tricolored bat FPE NLAA Dryobates borealis Red-cockaded woodpecker FT NLAA Danaus plexippus Monarch butterfly FPT NLAA Lysimachia asperulaefolia Rough-leaved loosestrife FE No Effect Heterodon simus Southern hognose snake PT NLAA a: FPE - proposed for listing as federally endangered under the ESA FPT - proposed for listing as federally threatened under the ESA FE - federally endangered under the ESA FT - federally threatened under the ESA NLAA - not likely to adversely affect

H.B. Robinson Steam Electric Plant Biological Assessment 16 December 2025 Figure 1 RNP Site Location

H.B. Robinson Steam Electric Plant Biological Assessment 17 December 2025 Figure 2 RNP ESA Action Area

H.B. Robinson Steam Electric Plant Biological Assessment 18 December 2025

7.0 REFERENCES

CP&L (Carolina Power and Light). 1974. H.B. Robinson Steam Electric Plant, 316 Demonstration Summary. December 1974. ADAMS Accession No. ML022830109.

CU (Cornell University). 2025. Red-cockaded Woodpecker, Life History. Retrieved from

<https://www.allaboutbirds.org/guide/Red-cockaded_Woodpecker/lifehistory> (accessed September 11, 2025).

Duke Energy (Duke Energy Progress, LLC). 2025. H.B. Robinson Steam Electric Plant, Unit Number 2, Subsequent License Renewal Application, Appendix E, Environmental Report. April 2025. ADAMS Accession No. ML25091A296.

NRC (U.S. Nuclear Regulatory Commission). 2003. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Supplement 13, Regarding H.B. Robinson Steam Electric Plant, Unit 2. NUREG-1437, Final Report. December 2003. ADAMS Accession No. ML033450517.

SCDNR (South Carolina Department of Natural Resources). 2015. Red-cockaded Woodpecker.

Retrieved from <https://www.dnr.sc.gov/swap/species2015.html> (accessed August 13, 2025).

SEI (Sandhills Ecological Institute). 2025. Red-cockaded Woodpeckers. Retrieved from

<https://sandhillsecological.org/education/red-cockaded-woodpeckers/> (accessed December 6, 2025).

SREL (Savannah River Ecology Laboratory). 2025. Southern Hognose Snake (Heterodon simus). Retrieved from <https://srelherp.uga.edu/snakes/southern-hognose-snake/> (accessed December 6, 2025).

USDA-NRCS (U.S. Department of Agriculture Natural Resources Conservation Service). 2013.

Preparing a Biological Assessment. Retrieved from

<https://efotg.sc.egov.usda.gov/references/public/NM/BA_Guidance.pdf> (accessed August 13, 2025).

USFWS (U.S. Fish and Wildlife Service). 1998. Endangered Species Consultation Handbook.

Retrieved from <https://www.fws.gov/media/endangered-species-consultation-handbook>

(accessed July 31, 2025).

USFWS. 2003. Red-cockaded Woodpecker (Picoides borealis) Recovery Plan, Second Revision. Retrieved from <https://ecos.fws.gov/docs/recovery_plan/030320_2.pdf> (accessed August 21, 2025).

USFWS. 2020. Species Status Assessment Report for the Red-cockaded Woodpecker (Picoides borealis), Version 1.3. Retrieved from

<https://iris.fws.gov/APPS/ServCat/Reference/Profile/124636> (accessed August 21, 2025).

H.B. Robinson Steam Electric Plant Biological Assessment 19 December 2025 USFWS. 2021. Rough-leaved Loosestrife (Lysimachia asperulaefolia) 5-Year Review: Summary and Evaluation. Retrieved from <https://www.fws.gov/node/263424> (accessed August 12, 2025).

USFWS. 2024. Endangered and Threatened Wildlife and Plants; Reclassification of the Red-Cockaded Woodpecker from Endangered to Threatened with a Section 4(d) Rule. Retrieved from <https://www.federalregister.gov/documents/2024/10/25/2024-23786/endangered-and-threatened-wildlife-and-plants-reclassification-of-the-red-cockaded-woodpecker-from>

(accessed August 21, 2025).

USFWS. 2025a. Tricolored Bat (Perimyotis subflavus). Retrieved from

<https://ecos.fws.gov/ecp/species/10515> (accessed August 13, 2025).

USFWS. 2025b. Monarch. Retrieved from <https://www.fws.gov/species/monarch-danaus-plexippus> (accessed August 13, 2025).

USFWS. 2025c. Rough-leaved Loosestrife. Retrieved from <https://www.fws.gov/species/rough-leaved-loosestrife-lysimachia-asperulaefolia> (accessed August 13, 2025).

USFWS. 2025d. Southern Hognose Snake. Retrieved from

<https://ecos.fws.gov/ecp/species/3248> (accessed September 22, 2025).

USFWS. 2025e. IPaC RNP Action Area. Retrieved from

<https://ipac.ecosphere.fws.gov/location/7PLQHJ5MLFHTXD7KPDILKQJSFA/resources>

(accessed December 11, 2025).

USFWS. 2025f. Monarch Butterfly Migration Map. Retrieved from

<https://www.fws.gov/media/monarch-butterfly-migration-map> (accessed August 13, 2025).

7.1 Figure References No.

Title In-Text Citation 1

RNP Site Location (Duke Energy 2025) 2 RNP ESA Action Area (Duke Energy 2025)

Duke Energy (Duke Energy Progress, LLC). 2025. H.B. Robinson Steam Electric Plant, Unit Number 2, Subsequent License Renewal Application, Appendix E, Environmental Report. April 2025. ADAMS Accession No. ML25091A296.

Appendix A:

Endangered Species Consultation History

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 E-MAIL ONLY Duke Energy Progress, LLC 411 Fayetteville Street Raleigh, NC 27601 May 7, 2025

SUBJECT:

NRC DESIGNATION OF NON-FEDERAL REPRESENTATIVES FOR ENDANGERED SPECIES ACT SECTION 7 CONSULTATION Tl MELINE FOR H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 SUBSEQUENT LICENSE RENEWAL

Dear Duke Energy:

The Nuclear Regulatory Commission (NRC) is responsible for conducting consultations with the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS)

(collectively, "Services") under Section 7 of the Endangered Species Act of 1973, as amended (ESA). The ESA regulations at Title 50 of the Code of Federal Regulations (50 CFR) Section 402.08 allow Federal action agencies to designate a non-Federal representative (Non-Fed Rep) to conduct informal consultation and to prepare a biological assessment. This letter provides a general timeline for the Non-Fed Rep process for the H.B. Robinson Steam Electric Plant (Robinson) Subsequent License Renewal and important background information for Duke Energy Progress, LLC (Duke) to utilize in their review.

Table 1. Section 7 Non-Federal Representative (Non-Fed Rep) Timeline Applicant agrees to be non-Fed Rep with oversight from the April 29, 2025 NRC throughout the Section 7 process NRC sends Service(s) notification of Non-Fed Rep designation Tentatively May 30, 2025 NRC and applicant initial meeting:

May 6, 2025 - Applicant

1. NRC provides applicant with list of federally protected begins BA within 90 days of species and critical habitats to address during receipt of species list.

consultation (IPaC) and designates action agency Applicant completes BA/BE representative within 180 days after receiving species list (receipt

2. NRC and applicant discuss how the biological of or concurrence with assessment (BA)/biological evaluation (BE) will be species list) developed which may include: (1) results of any on-site inspections or surveys of the action area to determine if listed or proposed species are present or occur seasonally, (2) views of recognized experts on the species at issue, (3) literature reviews, (4) an analysis o1 the effects of the action on the species and habitat, including consideration of cumulative effects, and the results of related studies, and (5) an analysis of 1

alternative actions considered by the Federal agency NRC and applicant virtual check-in meeting(s) (as needed)

Monthly check-ins as needed during applicant's development of the BA/BE (e.g., review of throughout BA/BE outline, outstandinq questions or inquiries, etc.)

development process.

Applicant submits Draft BA/BE to NRC for review October 17, 2025 NRC and applicant virtual meeting to discuss:

October 29, 2025

1. NRC's review of Draft BA/BE

2. Applicant recommends type of consultation (none, informal, formal)

• No Consultation: process ends here, and NRC will incorporate BA/BE findings into EA

• Informal Consultation: Applicant drafts letter to Services requesting its concurrence with effect determinations

• Formal Consultation: Applicant provides NRC with BA; applicant Non-Fed Rep obligations end; NRC staff finishes consultation

3. NRC discusses next steps with applicant Applicant drafts and sends NRC informal consultation letter and December 1, 2026 final BA/BE to NRC for review NRC staff concurs with BA/BE and consultation letter. Applicant By March 2026, or when sends consultation package to the Service DSEIS is published, at the latest.

Service(s) provides its concurrence By May 2026. Services have 60 days from receipt of the consultation letter to concur with the determinations or request to initiate formal consultation Table 2. Contact Information for Parties Involved Name

~ffiliation Email Phone Briana Arlene NRC, Biologist briana.arlenenrc.aov 301-415-1042 Mitchell Dehmer NRC, Environmental mitchell.dehmernrc.aov 301-415-4016 Scientist Shannon Healy NRC, Environmental shannon.healvnrc.aov 301-415-6714 Scientist Michelle Rome NRC, ETRB1 Branch michelle.romenrc.aov 301-415-0492 Chief James McRacken Duke Energy James.McRackenduke-enerav.com Elizabeth Glenn Duke Energy Elizabeth.Glennduke-enerav.com Service ESFO FWS Charleston reaulatorvfws.aov 843-727-4 707 Dropbox Melanie Olds FWS melanie oldsfws.aov 843-534-0403 2

Important Links and Guidance:

1) ESA Section 7 Guidance

a. FWS ESA Section 7 Handbook

b. NUREG 1555, Supplement 1, Revision 2, Appendix A

c. Information for Planning and Consultation (IPaC)

i. This is where the official species list will be generated by FWS ii. Licensee will be designated as an action agency representative in IPaC

2) Biological Assessment Guidance

a. Regulation: 50 CFR 402.12

b. Biological Assessment Contents

i. The results of any on-site inspections or surveys of the area affected by the action to determine if listed or proposed species are present or occur seasonally.

ii. The views of recognized experts on the species at issue.

iii. The review of literature and other information.

iv. An analysis of the effects of the action on the species and habitat, including consideration of cumulative effects, and the results of any related studies.

v. An analysis of alternative actions considered by the Federal agency for the proposed action.

3) NRC Biological Assessment Examples

a. Marsland Expansion Area In Situ Uranium Recovery BA (ML18100A229)

b. Salem Nuclear Generating Station BA (ML20156A067)

c. Turkey Point Combined License Application BA (ML15028A372)

4) NRC ESA Effect Determination Examples

a. Diablo Canyon Draft SEIS (ML24299A167), Section 3.8

b. Perry Nuclear Power Plant Draft EIS (ML24241A256), Section 3.8

c. Crystal River License Termination Plan EA (ML24081A068), Section 3.8

5) FWS Field Office Information - South Carolina Ecological Services Field Office

a. Website: https://www.fws.gov/office/south-carolina-ecological-services

b. Phone: 843-727-4707

c. Address: 176 Croghan Spur Road, Suite 200, Charleston, SC 29407-7558 If you have any questions regarding the information in this letter or would like to further discuss the timeline or milestones, please contact me by phone at (301) 415-6714 or via email at shannon.healy@nrc.gov.

Docket No. 50-261 Sincerely,

',(I_

I I ~

Digitally signed by SHANNON

~

n HEALY Date: 2025.05.07 07:12:28 -04'00' Shannon Healy, Environmental Scientist Environmental Technical Review Branch 1 Division of Rulemaking, Environment, and Financial Support Office of Nuclear Material Safety and Safeguards 3

United States Department of the Interior FISH AND WILDLIFE SERVICE South Carolina Ecological Services 176 Croghan Spur Road, Suite 200 Charleston, SC 29407-7558 Phone: (843) 727-4707 Fax: (843) 727-4218 U.:N...

1'16H,I, WIWUl'E "llffl,'l<"E In Reply Refer To:

07/01/2025 14:22:05 UTC Project Code: 2025-0116165 Project Name: H.B. Robinson Steam Electric Plant Subsequent License Renewal

Subject:

List of threatened and endangered species that may occur in your proposed project location or may be affected by your proposed project To Whom It May Concern:

The enclosed species list identifies threatened, endangered, proposed and candidate species, as well as proposed and final designated critical habitat, that may occur within the boundary of your proposed project and/or may be affected by your proposed project. The species list fulfills the requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of the Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 et seq.).

New information based on updated surveys, changes in the abundance and distribution of species, changed habitat conditions, or other factors could change this list. Please feel free to contact us if you need more current information or assistance regarding the potential impacts to federally proposed, listed, and candidate species and federally designated and proposed critical habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the Act, the accuracy of this species list should be verified after 90 days. This verification can be completed formally or informally as desired. The Service recommends that verification be completed by visiting the IPaC website at regular intervals during project planning and implementation for updates to species lists and information. An updated list may be requested through the IPaC system by completing the same process used to receive the enclosed list.

The purpose of the Act is to provide a means whereby threatened and endangered species and the ecosystems upon which they depend may be conserved. Under sections 7(a)(l) and 7(a)(2) of the Act and its implementing regulations (50 CFR 402 et seq.), Federal agencies are required to utilize their authorities to carry out programs for the conservation of threatened and endangered species and to determine whether projects may affect threatened and endangered species and/or designated critical habitat.

A Biological Assessment is required for construction projects ( or other undertakings having similar physical impacts) that are major Federal actions significantly affecting the quality of the human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2)

(c)). For projects other than major construction activities, the Service suggests that a biological

Project code: 2025-0116165 07/01/2025 14:22:05 UTC evaluation similar to a Biological Assessment be prepared to determine whether the project may affect listed or proposed species and/or designated or proposed critical habitat. Recommended contents of a Biological Assessment are described at 50 CFR 402.12.

If a Federal agency determines, based on the Biological Assessment or biological evaluation, that listed species and/or designated critical habitat may be affected by the proposed project, the agency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Service recommends that candidate species, proposed species and proposed critical habitat be addressed within the consultation. More information on the regulations and procedures for section 7 consultation, including the role of permit or license applicants, can be found in the "Endangered Species Consultation Handbook" at:

https://www.fws.gov/sites/default/files/documents/endangered-species-consultation-handbook. pdf Migratory Birds: In addition to responsibilities to protect threatened and endangered species under the Endangered Species Act (ESA), there are additional responsibilities under the Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle Protection Act (BG EPA) to protect native birds from project-related impacts. Any activity resulting in take of migratory birds, including eagles, is prohibited unless otherwise permitted by the U.S. Fish and Wildlife Service (50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)). For more information regarding these Acts, see https://www.fws.gov/program/migratory-bird-permit/what-we-do.

It is the responsibility of the project proponent to comply with these Acts by identifying potential impacts to migratory birds and eagles within applicable NEPA documents (when there is a federal nexus) or a Bird/Eagle Conservation Plan (when there is no federal nexus). Proponents should implement conservation measures to avoid or minimize the production of project-related stressors or minimize the exposure of birds and their resources to the project-related stressors.

For more information on avian stressors and recommended conservation measures, see https://

www.fws.gov/library/collections/threats-birds.

In addition to MBTA and BG EPA, Executive Order 13186: Responsibilities of Federal Agencies to Protect Migratory Birds, obligates all Federal agencies that engage in or authorize activities that might affect migratory birds, to minimize those effects and encourage conservation measures that will improve bird populations. Executive Order 13186 provides for the protection of both migratory birds and migratory bird habitat. For information regarding the implementation of Executive Order 13186, please visit https://www.fws.gov/partner/council-conservation-migratory-birds.

We appreciate your concern for threatened and endangered species. The Service encourages Federal agencies to include conservation of threatened and endangered species into their project planning to further the purposes of the Act. Please include the Consultation Code in the header of this letter with any request for consultation or correspondence about your project that you submit to our office.

Attachment( s):

Official Species List 2 of 13

Project code: 2025-0116165 07/01/2025 14:22:05 UTC USFWS National Wildlife Refuges and Fish Hatcheries Bald & Golden Eagles Migratory Birds OFFICIAL SPECIES LIST This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the requirement for Federal agencies to "request of the Secretary of the Interior information whether any species which is listed or proposed to be listed may be present in the area of a proposed action".

This species list is provided by:

South Carolina Ecological Services 176 Croghan Spur Road, Suite 200 Charleston, SC 29407-7558 (843) 727-4707 3 of 13

Project code: 2025-0116165 07/01/2025 14:22:05 UTC PROJECT

SUMMARY

Project Code:

Project Name:

Project Type:

2025-0116165 H.B. Robinson Steam Electric Plant Subsequent License Renewal Power Gen - Nuclear Project

Description:

Development of biological assessment for federally listed species for the H.B. Robinson Steam Electric Plant Subsequent License Renewal.

Project Location:

The approximate location of the project can be viewed in Google Maps: https://

www.google.com/maps/@34.419127450000005,-80.16951861954567,14z Counties: Chesterfield and Darlington counties, South Carolina 4 of 13

Project code: 2025-0116165 07/01/2025 14:22:05 UTC ENDANGERED SPECIES ACT SPECIES There is a total of 4 threatened, endangered, or candidate species on this species list.

Species on this list should be considered in an effects analysis for your project and could include species that exist in another geographic area. For example, certain fish may appear on the species list because a project could affect downstream species.

IPaC does not display listed species or critical habitats under the sole jurisdiction of NOAA Fisheries1, as USFWS does not have the authority to speak on behalf of NOAA and the Department of Commerce.

See the "Critical habitats" section below for those critical habitats that lie wholly or partially within your project area under this office's jurisdiction. Please contact the designated FWS office if you have questions.

1. NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an office of the National Oceanic and Atmospheric Administration within the Department of Commerce.

5 of 13

Project code: 2025-0116165 07/01/2025 14:22:05 UTC MAMMALS NAME Tricolored Bat Perimyotis subflavus No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/10515 BIRDS NAME Red-cockaded Woodpecker Dryobates borealis No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/7614 INSECTS NAME Monarch Butterfly Danaus plexippus There is proposed critical habitat for this species. Your location does not overlap the critical habitat.

Species profile: https://ecos.fws.gov/ecp/species/9743 FLOWERING PLANTS NAME Rough-leaved Loosestrife Lysimachia asperulaefolia No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/2747 CRITICAL HABITATS STATUS Proposed Endangered STATUS Threatened STATUS Proposed Threatened STATUS Endangered THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S JURISDICTION.

YOU ARE STILL REQUIRED TO DETERMINE IF YOUR PROJECT(S) MAY HAVE EFFECTS ON ALL ABOVE LISTED SPECIES.

USFWS NATIONAL WILDLIFE REFUGE LANDS AND FISH HATCHERIES Any activity proposed on lands managed by the National Wildlife Refuge system must undergo a

'Compatibility Determination' conducted by the Refuge. Please contact the individual Refuges to discuss any questions or concerns.

THERE ARE NO REFUGE LANDS OR FISH HATCHERIES WITHIN YOUR PROJECT AREA.

6 of 13

Project code: 2025-0116165 07/01/2025 14:22:05 UTC BALD & GOLDEN EAGLES Bald and Golden Eagles are protected under the Bald and Golden Eagle Protection Act 2 and the Migratory Bird Treaty Act (MBTA) 1. Any person or organization who plans or conducts activities that may result in impacts to Bald or Golden Eagles, or their habitats, should follow appropriate regulations and consider implementing appropriate avoidance and minimization measures, as described in the various links on this page.

1. The Bald and Golden Eagle Protection Act of 1940.

2. The Migratory Birds Treaty Act of 1918.

3. 50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)

There are Bald Eagles and/or Golden Eagles in your project area.

Measures for Proactively Minimizing Eagle Impacts For information on how to best avoid and minimize disturbance to nesting bald eagles, please review the National Bald Eagle Management Guidelines. You may employ the timing and activity-specific distance recommendations in this document when designing your project/

activity to avoid and minimize eagle impacts. For bald eagle information specific to Alaska, please refer to Bald Eagle Nesting and Sensitivity to Human Activity.

The FWS does not currently have guidelines for avoiding and minimizing disturbance to nesting Golden Eagles. For site-specific recommendations regarding nesting Golden Eagles, please consult with the appropriate Regional Migratory Bird Office or Ecological Services Field Office.

If disturbance or take of eagles cannot be avoided, an incidental take permit may be available to authorize any take that results from, but is not the purpose of, an otherwise lawful activity. For assistance making this determination for Bald Eagles, visit the Do I Need A Permit Tool. For assistance making this determination for golden eagles, please consult with the appropriate Regional Migratory Bird Office or Ecological Services Field Office.

Ensure Your Eagle List is Accurate and Complete If your project area is in a poorly surveyed area in IPaC, your list may not be complete and you may need to rely on other resources to determine what species may be present ( e.g. your local FWS field office, state surveys, your own surveys). Please review the Supplemental Information on Migratory Birds and Eagles, to help you properly interpret the report for your specified location, including determining if there is sufficient data to ensure your list is accurate.

For guidance on when to schedule activities or implement avoidance and minimization measures to reduce impacts to bald or golden eagles on your list, see the "Probability of Presence Summary" below to see when these bald or golden eagles are most likely to be present and breeding in your project area.

7 of 13

Project code: 2025-0116165 07/01/2025 14:22:05 UTC NAME Bald Eagle Haliaeetus leucocephalus BREEDING SEASON Breeds Sep 1 to This is not a Bird of Conservation Concern (BCC) in this area, but warrants attention because of the Eagle Act or for potential susceptibilities in offshore areas from certain types of development or activities.

https://ecos.fws.gov/ecp/species/1626 PROBABILITY OF PRESENCE

SUMMARY

Jul 31 The graphs below provide our best understanding of when birds of concern are most likely to be present in your project area. This information can be used to tailor and schedule your project activities to avoid or minimize impacts to birds. Please make sure you read "Supplemental Information on Migratory Birds and Eagles", specifically the FAQ section titled "Proper Interpretation and Use of Your Migratory Bird Report" before using or attempting to interpret this report.

Probability of Presence ()

Green bars; the bird's relative probability of presence in the 10km grid cell(s) your project overlaps during that week of the year.

Breeding Season ( )

Yellow bars; liberal estimate of the timeframe inside which the bird breeds across its entire range.

Survey Effort (I)

Vertical black lines; the number of surveys performed for that species in the 10km grid cell(s) your project area overlaps.

No Data(- )

A week is marked as having no data if there were no survey events for that week.

probability of presence breeding season I survey effort

- no data SPECIES Bald Eagle Non-BCC Vulnerable JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Additional information can be found using the following links:

Eagle Management https://www.fws.gov/program/ eagle-management Measures for avoiding and minimizing impacts to birds https://www.fws.gov/library/

collections/avoiding-and-minimizing-incidental-take-migratory-birds 8 of 13

Project code: 2025-0116165 07/01/2025 14:22:05 UTC Nationwide avoidance and minimization measures for birds https://www.fws.gov/sites/

default/files/documents/nationwide-standard-conservation-measures.pdf Supplemental Information for Migratory Birds and Eagles in IPaC https://www.fws.gov/

media/supplemental-information-migratory-birds-and-bald-and-golden-eagles-may-occur-proj ect-action MIGRATORY BIRDS The Migratory Bird Treaty Act (MBTA) 1 prohibits the take (including killing, capturing, selling, trading, and transport) of protected migratory bird species without prior authorization by the Department of Interior U.S. Fish and Wildlife Service (Service).

1. The Migratory Birds Treaty Act of 1918.

2. The Bald and Golden Eagle Protection Act of 1940.

3. 50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)

For guidance on when to schedule activities or implement avoidance and minimization measures to reduce impacts to migratory birds on your list, see the "Probability of Presence Summary" below to see when these birds are most likely to be present and breeding in your project area.

NAME American Kestrel Falco sparverius paulus This is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions (BCRs) in the continental USA https://ecos.fws.gov/ecp/species/9587 Bachman's Sparrow Peucaea aestivalis This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA and Alaska.

https:/ /ecos.fws. gov/ ecp/species/6177 Bald Eagle Haliaeetus leucocephalus This is not a Bird of Conservation Concern (BCC) in this area, but warrants attention because of the Eagle Act or for potential susceptibilities in offshore areas from certain types of development or activities.

https://ecos.fws.gov/ecp/species/1626 BREEDING SEASON Breeds Apr 1 to Aug31 Breeds May 1 to Sep 30 Breeds Sep 1 to Jul 31 Brown-headed Nuthatch Sitta pusilla Breeds Mar 1 to This is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions Jul 15 (BCRs) in the continental USA https://ecos.fws.gov/ecp/species/9427 9 of 13

Project code: 2025-0116165 07/01/2025 14:22:05 UTC NAME Chimney Swift Chaetura pelagica This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA and Alaska.

https://ecos.fws.gov/ecp/species/9406 Chuck-will's-widow Antrostomus carolinensis This is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions (BCRs) in the continental USA https://ecos.fws.gov/ecp/species/9604 Eastern Whip-poor-will Antrostomus vociferus This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA and Alaska.

https://ecos.fws.gov/ecp/species/10678 BREEDING SEASON Breeds Mar 15 to Aug 25 Breeds May 10 to Jul 10 Breeds May 1 to Aug 20 Painted Bunting Passerino ciris Breeds Apr 25 This is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions to Aug 15 (BCRs) in the continental USA https://ecos.fws.gov/ecp/species/9511 Prairie Warbler Setophaga discolor This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA and Alaska.

https://ecos.fws.gov/ecp/species/9513 Prothonotary Warbler Protonotaria citrea This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA and Alaska.

https://ecos.fws.gov/ecp/species/9439 Red-headed Woodpecker Melanerpes erythrocephalus This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA and Alaska.

https://ecos.fws.gov/ecp/species/9398 Wood Thrush Hylocichla mustelina This is a Bird of Conservation Concern (BCC) throughout its range in the continental USA and Alaska.

https://ecos.fws.gov/ecp/species/9431 PROBABILITY OF PRESENCE

SUMMARY

Breeds May 1 to Jul 31 Breeds Apr 1 to Jul 31 Breeds May 10 to Sep 10 Breeds May 10 to Aug 31 The graphs below provide our best understanding of when birds of concern are most likely to be present in your project area. This information can be used to tailor and schedule your project activities to avoid or minimize impacts to birds. Please make sure you read "Supplemental Information on Migratory Birds and Eagles", specifically the FAQ section titled "Proper Interpretation and Use of Your Migratory Bird Report" before using or attempting to interpret this report.

Probability of Presence ()

10 of 13

Project code: 2025-0116165 07/01/2025 14:22:05 UTC Green bars; the bird's relative probability of presence in the 10km grid cell(s) your project overlaps during that week of the year.

Breeding Season ( )

Yellow bars; liberal estimate of the timeframe inside which the bird breeds across its entire range.

Survey Effort (I)

Vertical black lines; the number of surveys performed for that species in the 10km grid cell(s) your project area overlaps.

No Data(- )

A week is marked as having no data if there were no survey events for that week.

probability of presence SPECIES JAN FEB MAR APR American Kestrel BCC-BCR Bachman's Sparrow BCC Rangewide

--- + --+ - - +-+- '

(CON)

Bald Eagle Non-BCC Vulnerable Brown-headed Nuthatch BCC-BCR Chimney Swift BCC Rangewide (CON)

Chuck-will's-widow +-- + -++- ++++ +++

BCC-BCR Eastern Whip-poor-

++++

will

-+--- + --+- ++-+-+

BCC Rangewide (CON)

Painted Bunting BCC-BCR Prairie Warbler BCC Rangewide (CON) breeding season I survey effort

- no data AUG SEP OCT NOV DEC

-+--+---+- '. -

I - + -. -+-

-- +-+---+ --------- -------+ ---- ++-----

11 of 13

Project code: 2025-0116165 Prothonotary Warbler BCC Rangewide (CON)

Red-headed Woodpecker BCC Rangewide (CON)

Wood Thrush BCC Rangewide (CON)

+- - + ++- _,_

--- --+ -

- +

Additional information can be found using the following links:

07/01/2025 14:22:05 UTC

-*---+ ---- --

Eagle Management https://www.fws.gov/program/eagle-management Measures for avoiding and minimizing impacts to birds https://www.fws.gov/library/

collections/ avoiding-and-minimizing-incidental-take-migratory-birds Nationwide avoidance and minimization measures for birds Supplemental Information for Migratory Birds and Eagles in IPaC https://www.fws.gov/

media/supplemental-information-migratory-birds-and-bald-and-golden-eagles-may-occur-proj ect-action 12 of 13

Project code: 2025-0116165 IPAC USER CONTACT INFORMATION Agency:

Name:

Address:

City:

State:

Zip:

Email Phone:

Private Entity Jay Hemmis 1601 Northwest Expressway Oklahoma City OK 73118 jhemmis@enercon.com 6789324364 LEAD AGENCY CONTACT INFORMATION Lead Agency: Nuclear Regulatory Commission 07/01/2025 14:22:05 UTC 13 of 13

United States Department of the Interior FISH AND WILDLIFE SERVICE South Carolina Ecological Services 176 Croghan Spur Road, Suite 200 Charleston, SC 29407-7558 Phone: (843) 727-4707 Fax: (843) 727-4218 U.tc-.

l'l6ill,l,WIWUl'E "llffl,'t<"E In Reply Refer To:

07/01/2025 14:24:33 UTC Project code: 2025-0116165 Project Name: H.B. Robinson Steam Electric Plant Subsequent License Renewal

Subject:

Consistency letter for 'H.B. Robinson Steam Electric Plant Subsequent License Renewal' for specified federally threatened and endangered species and designated critical habitat that may occur in your proposed project area consistent with the South Carolina Ecological Services Field Office (ESFO) Determination Key (DKey) for project review and guidance for federally listed species.

Jay Hemmis:

The U.S. Fish and Wildlife Service (Service) received on July 01, 2025 your effect determination(s) for the 'H.B. Robinson Steam Electric Plant Subsequent License Renewal' (the Action) using the South Carolina ESFO DKey for project review and guidance for federally-listed species within the Information for Planning and Consultation (IPaC) application. The Service developed this application in accordance with the Endangered Species Act of 1973 (ESA) (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.).

Based on your answers and the assistance of the Service's South Carolina ESFO DKey, you made the following effect determination(s) for the proposed Action:

Species Red-cockaded Woodpecker (Dryobates borealis)

Listing Status Threatened Consultation Status Determination No effect Your agency has met consultation requirements for the species listed above by informing the Service of the "no effect" determinations. No further consultation for this project is required for these species. This consistency letter confirms you may rely on effect determinations you reached by considering the South Carolina ESFO DKey to satisfy agency consultation requirements under Section 7(a) (2) of the Endangered Species Act of 1973 (87 Stat. 884, as amended 16 U.S.C. 1531 et seq.; ESA).

Project code: 2025-0116165 IPaC Record Locator: 175-164225071 07/01/2025 14:24:33 UTC The following species and/or critical habitats may also occur in your project area and are not covered by this conclusion:

Monarch Butterfly Danaus plexippus Proposed Threatened Rough-leaved Loosestrife Lysimachia asperulaefolia Endangered Tricolored Bat Perimyotis subfl-avus Proposed Endangered Please note that due to obligations under the ESA, potential impacts of this project must be reconsidered if: (1) new information reveals impacts of this identified action may affect any listed species or critical habitat in a manner not previously considered; (2) this action is subsequently modified in a manner which was not considered in this assessment; or (3) a new species is listed or critical habitat is designated that may be affected by the identified action. If any of the above conditions occurs, additional consultation with the South Carolina ESFO should take place before project changes are final or resources committed.

Bald and Golden Eagle Protection Act (BGEPA): Bald and golden eagles are not included in this section 7(a)(2) consultation and this information does not constitute a determination of effects by the Service. The Service developed the National Bald Eagle Management Guidelines to advise landowners, land managers, and others who share public and private lands with bald eagles when and under what circumstances the protective provisions of the BG EPA may apply to their activities. The guidelines should be consulted prior to conducting new or intermittent activity near an eagle nest.

If the Federal Action may impact bald or golden eagles, additional coordination with the Service under the Bald and Golden Eagle Protection Act (BG EPA) (54 Stat. 250, as amended, 16 U.S.C.

668a-d) may be required. Please contact Ulgonda Kirkpatrick (phone: 321/972-9089, e-mail:

ulgonda_kirkpatrick@fws.gov) with any questions regarding potential impacts to bald or golden eagles.

DKey Version Publish Date: 01/03/2025 2 of 5

Project code: 2025-0116165 IPaC Record Locator: 175-164225071 07/01/2025 14:24:33 UTC Action Description You provided to IPaC the following name and description for the subject Action.

1. Name H.B. Robinson Steam Electric Plant Subsequent License Renewal

2. Description The following description was provided for the project 'H.B. Robinson Steam Electric Plant Subsequent License Renewal':

Development of biological assessment for federally listed species for the H.B.

Robinson Steam Electric Plant Subsequent License Renewal.

The approximate location of the project can be viewed in Google Maps: https://

www.google.com/maps/@34.419127450000005,-80.16951861954567,14z DKey Version Publish Date: 01/03/2025 3 of 5

Project code: 2025-0116165 IPaC Record Locator: 175-164225071 07/01/2025 14:24:33 UTC QUALIFICATION INTERVIEW

1. Does the proposed project involve research or other actions that include the collection, capture, handling, or harassment of any individual federally listed threatened, endangered or proposed species?

No

2. Is the action authorized, funded, or being carried out by a Federal agency?

Yes

3. Are you the Federal agency or designated non-federal representative?

Yes

4. Is the project an existing structure that requires maintenance, repair, or replacement?

Yes

5. Will all project take place within the existing structure's footprint?

Yes

6. Does the project intersect the red-cockaded woodpecker AOI?

Automatically answered Yes

7. Is the action area located within suitable Red-cockaded woodpecker foraging habitat (pine or pine/hardwood stands in which 50% or more of the dominant trees are pines and the dominant pine trees are 30 years of age or older or >10-inches diameter breast height (dbh) and the midstory height does not exceed 12 feet)?

Yes

8. Will the project remove trees greater than 10-inches dbh?

No

9. Will the project occur within 200 feet of known Red-cockaded woodpecker cavity trees.

No DKey Version Publish Date: 01/03/2025 4 of 5

Project code: 2025-0116165 IPaC Record Locator: 175-164225071 IPAC USER CONTACT INFORMATION Agency:

Name:

Address:

City:

State:

Zip:

Email Phone:

Private Entity Jay Hemmis 1601 Northwest Expressway Oklahoma City OK 73118 jhemmis@enercon.com 6789324364 LEAD AGENCY CONTACT INFORMATION Lead Agency: Nuclear Regulatory Commission DKey Version Publish Date: 01/03/2025 07/01/2025 14:24:33 UTC 5 of 5

United States Department of the Interior FISH AND WILDLIFE SERVICE South Carolina Ecological Services 176 Croghan Spur Road, Suite 200 Charleston, SC 29407-7558 Phone: (843) 727-4707 Fax: (843) 727-4218 U.:N-.

l'llill&WIWUl'E "llffl,'l<"E In Reply Refer To:

07/01/2025 14:19:41 UTC Project code: 2025-0116165 Project Name: H.B. Robinson Steam Electric Plant Subsequent License Renewal Federal Nexus: yes Federal Action Agency (if applicable): Nuclear Regulatory Commission

Subject:

Record of project representative's no effect determination for 'H.B. Robinson Steam Electric Plant Subsequent License Renewal'

Dear Jay Hemmis:

This letter records your determination using the Information for Planning and Consultation (IPaC) system provided to the U.S. Fish and Wildlife Service (Service) on July 01, 2025, for

'H.B. Robinson Steam Electric Plant Subsequent License Renewal' (here forward, Project). This project has been assigned Project Code 2025-0116165 and all future correspondence should clearly reference this number. Please carefully review this letter.

Ensuring Accurate Determinations When Using IPaC The Service developed the IPaC system and associated species' determination keys in accordance with the Endangered Species Act of 1973 (ESA; 87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.) and based on a standing analysis. All information submitted by the Project proponent into IPaC must accurately represent the full scope and details of the Project.

Failure to accurately represent or implement the Project as detailed in IPaC or the Northern Long-eared Bat and Tricolored Bat Range-wide Determination Key (Dkey), invalidates this letter. Answers to certain questions in the DKey commit the project proponent to implementation of conservation measures that must be followed for the ESA determination to remain valid.

Determination for the Northern Long-Eared Bat and/or Tricolored Bat Based upon your IPaC submission and a standing analysis, your project has reached the following effect determinations:

Species Listing Status Determination

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC Tricolored Bat (Perimyotis subflavus)

Proposed Endangered No effect Federal agencies must consult with U.S. Fish and Wildlife Service under section 7(a)(2) of the Endangered Species Act (ESA) when an action may affect a listed species. Tricolored bat is proposed for listing as endangered under the ESA, but not yet listed. For actions that may affect a proposed species, agencies cannot consult, but they can confer under the authority of section 7(a)

( 4) of the ESA. Such conferences can follow the procedures for a consultation and be adopted as such if and when the proposed species is listed. Should the tricolored bat be listed, agencies must review projects that are not yet complete, or projects with ongoing effects within the tricolored bat range that previously received a NE or NLAA determination from the key to confirm that the determination is still accurate.

To make a no effect determination, the full scope of the proposed project implementation (action) should not have any effects (either positive or negative), to a federally listed species or designated critical habitat. Effects of the action are all consequences to listed species or critical habitat that are caused by the proposed action, including the consequences of other activities that are caused by the proposed action. A consequence is caused by the proposed action if it would not occur but for the proposed action and it is reasonably certain to occur. Effects of the action may occur later in time and may include consequences occurring outside the immediate area involved in the action. (See § 402.17).

Under Section 7 of the ESA, if a federal action agency makes a no effect determination, no consultation with the Service is required (ESA §7). If a proposed Federal action may affect a listed species or designated critical habitat, formal consultation is required except when the Service concurs, in writing, that a proposed action "is not likely to adversely affect" listed species or designated critical habitat [50 CFR §402.02, 50 CFR§402.13].

Other Species and Critical Habitat that May be Present in the Action Area The IPaC-assisted determination key for the northern long-eared bat and tricolored bat does not apply to the following £SA-protected species and/or critical habitat that also may occur in your Action area:

Monarch Butterfly Danaus plexippus Proposed Threatened Red-cockaded Woodpecker Dryobates borealis Threatened Rough-leaved Loosestrife Lysimachia asperulaefolia Endangered You may coordinate with our Office to determine whether the Action may affect the animal species listed above and, if so, how they may be affected.

Next Steps If there are no updates on listed species, no further consultation/coordination for this project is required with respect to the species covered by this key. However, the Service recommends that project proponents re-evaluate the Project in IPaC if: 1) the scope, timing, duration, or location DKey Version Publish Date: 05/19/2025 2 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC of the Project changes (includes any project changes or amendments); 2) new information reveals the Project may impact (positively or negatively) federally listed species or designated critical habitat; or 3) a new species is listed, or critical habitat designated. If any of the above conditions occurs, additional coordination with the Service should take place to ensure compliance with the Act.

If you have any questions regarding this letter or need further assistance, please contact the South Carolina Ecological Services and reference Project Code 2025-0116165 associated with this Project.

DKey Version Publish Date: 05/19/2025 3 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC Action Description You provided to IPaC the following name and description for the subject Action.

1. Name H.B. Robinson Steam Electric Plant Subsequent License Renewal

2. Description The following description was provided for the project 'H.B. Robinson Steam Electric Plant Subsequent License Renewal':

Development of biological assessment for federally listed species for the H.B.

Robinson Steam Electric Plant Subsequent License Renewal.

The approximate location of the project can be viewed in Google Maps: https://

www.google.com/maps/@34.419127450000005,-80.16951861954567,14z DKey Version Publish Date: 05/19/2025 4 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC DETERMINATION KEY RESULT Based on the information you provided, you have determined that the Proposed Action will have no effect on the species covered by this determination key. Therefore, no consultation with the U.S. Fish and Wildlife Service pursuant to Section 7(a)(2) of the Endangered Species Act of 1973 (87 Stat. 884, as amended 16 U.S.C. 1531 et seq.) is required for those species.

QUALIFICATION INTERVIEW

1. Does the proposed project include, or is it reasonably certain to cause, intentional take of listed bats or any other listed species?

Note: Intentional take is defined as take that is the intended result of a project. Intentional take could refer to research, direct species management, surveys, and/or studies that include intentional handling/encountering, harassment, collection, or capturing of any individual of a federally listed threatened, endangered or proposed species?

No

2. Is the action area wholly within Zone 2 of the year-round active area for northern long-eared bat and/or tricolored bat?

Automatically answered No

3. Does the action area intersect Zone 1 of the year-round active area for northern long-eared bat and/or tricolored bat?

Automatically answered Yes

4. Your project overlaps with an area where northern long-eared bats or tricolored bats may be present and roosting in trees year-round.

Do you understand that your project may impact bats roosting in trees at any time during the year?

Yes

5. Does any component of the action involve leasing, construction or operation of wind turbines? Answer 'yes' if the activities considered are conducted with the intention of gathering survey information to inform the leasing, construction, or operation of wind turbines.

Note: For federal actions, answer 'yes' if the construction or operation of wind power facilities is either (1) part of the federal action or (2) would not occur but for a federal agency action (federal permit, funding, etc.).

No

6. Is the proposed action authorized, permitted, licensed, funded, or being carried out by a Federal agency in whole or in part?

Yes DKey Version Publish Date: 05/19/2025 5 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC

7. Is the Federal Highway Administration (FHWA), Federal Railroad Administration (FRA),

or Federal Transit Administration (FTA) funding or authorizing the proposed action, in whole or in part?

No

8. Are you an employee of the federal action agency or have you been officially designated in writing by the agency as its designated non-federal representative for the purposes of Endangered Species Act Section 7 informal consultation per 50 CFR § 402.08?

Note: This key may be used for federal actions and for non-federal actions to facilitate section 7 consultation and to help determine whether an incidental take permit may be needed, respectively. This question is for information purposes only.

Yes

9. Is the lead federal action agency the Environmental Protection Agency (EPA) or Federal Communications Commission (FCC)? Is the Environmental Protection Agency (EPA) or Federal Communications Commission (FCC) funding or authorizing the proposed action, in whole or in part?

No

10. Is the lead federal action agency the Federal Energy Regulatory Commission (FERC)?

No

11. [Semantic] Is the action area located within 0.5 miles of a known bat hibernaculum? Note:

The map queried for this question contains proprietary information and cannot be displayed. If you need additional information, please contact your State wildlife agency.

Automatically answered No

12. Does the action area contain any winter roosts or caves ( or associated sinkholes, fissures, or other karst features), mines, rocky outcroppings, or tunnels that could provide habitat for hibernating bats?

No

13. Does the action area contain (1) talus or (2) anthropogenic or naturally formed rock shelters or crevices in rocky outcrops, rock faces or cliffs?

No

14. Will the action cause effects to a bridge?

Note: Covered bridges should be considered as bridges in this question.

No

15. Will the action result in effects to a culvert or tunnel at any time of year?

No DKey Version Publish Date: 05/19/2025 6 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC

16. Are trees present within 1000 feet of the action area?

Note: If there are trees within the action area that are of a sufficient size to be potential roosts for bats answer "Yes". If unsure, additional information defining suitable summer habitat for the northern long-eared bat and tricolored bat can be found in Appendix A of the USFWS' Range-wide Indiana Bat and Northern long-eared bat Survey Guidelines at: https://www.fws.gov/media/range-wide-indiana-bat-and-northern-long-eared-bat-survey-guidelines.

Yes

17. Does the action include the intentional exclusion of bats from a building or structure?

Note: Exclusion is conducted to deny bats' entry or reentry into a building. To be effective and to avoid harming bats, it should be done according to established standards. If your action includes bat exclusion and you are unsure whether northern long-eared bats or tricolored bats are present, answer "Yes." Answer "No" if there are no signs of bat use in the building/structure. If unsure, contact your local Ecological Services Field Office to help assess whether northern long-eared bats or tricolored bats may be present. Contact a Nuisance Wildlife Control Operator (NWCO) for help in how to exclude bats from a structure safely without causing harm to the bats (to find a NWCO certified in bat standards, search the Internet using the search term "National Wildlife Control Operators Association bats"). Also see the White-Nose Syndrome Response Team's guide for bat control in structures.

No

18. Does the action involve removal, modification, or maintenance of a human-made structure (barn, house, or other building) known or suspected to contain roosting bats?

No

19. Will the action cause construction of one or more new roads open to the public?

For federal actions, answer 'yes' when the construction or operation of these facilities is either (1) part of the federal action or (2) would not occur but for an action taken by a federal agency (federal permit, funding, etc.).

No

20. Will the action include or cause any construction or other activity that is reasonably certain to increase average night-time traffic permanently or temporarily on one or more existing roads? Note: For federal actions, answer 'yes' when the construction or operation of these facilities is either (1) part of the federal action or (2) would not occur but for an action taken by a federal agency (federal permit, funding, etc.)..

No

21. Will the action include or cause any construction or other activity that is reasonably certain to increase the number of travel lanes on an existing thoroughfare?

For federal actions, answer 'yes' when the construction or operation of these facilities is either (1) part of the federal action or (2) would not occur but for an action taken by a federal agency (federal permit, funding, etc.).

No DKey Version Publish Date: 05/19/2025 7 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC

22. Will the proposed Action involve the creation of a new water-borne contaminant source (e.g., leachate pond, pits containing chemicals that are not NSF/ANSI 60 compliant)?

Note: For information regarding NSF/ANSI 60 please visit https://www.nsf.org/knowledge-library/nsf-ansi-standard-60-drinking-water-treatment-chemicals-health-effects No

23. Will the proposed action involve the creation of a new point source discharge from a facility other than a water treatment plant or storm water system?

No

24. Will the action include drilling or blasting?

No

25. Will the action involve military training (e.g., smoke operations, obscurant operations, exploding munitions, artillery fire, range use, helicopter or fixed wing aircraft use)?

No

26. Will the proposed action involve the use of herbicides or other pesticides other than herbicides ( e.g., fungicides, insecticides, or rodenticides )?

No

27. Will the action include or cause activities that are reasonably certain to cause chronic or intense nighttime noise (above current levels of ambient noise in the area) in suitable summer habitat for the northern long-eared bat or tricolored bat during the active season?

Chronic noise is noise that is continuous or occurs repeatedly again and again for a long time. Sources of chronic or intense noise that could cause adverse effects to bats may include, but are not limited to: road traffic; trains; aircraft; industrial activities; gas compressor stations; loud music; crowds; oil and gas extraction; construction; and mining.

Note: Additional information defining suitable summer habitat for the northern long-eared bat and tricolored bat can be found in Appendix A of the USFWS' Range-wide Indiana Bat and Northern long-eared bat Survey Guidelines at: https://www.fws.gov/media/range-wide-indiana-bat-and-northern-long-eared-bat-survey-guidelines.

No

28. Does the action include, or is it reasonably certain to cause, the use of permanent or temporary artificial lighting within 1000 feet of suitable northern long-eared bat or tricolored bat roosting habitat?

Note: Additional information defining suitable summer habitat for the northern long-eared bat and tricolored bat can be found in Appendix A of the USFWS' Range-wide Indiana Bat and Northern long-eared bat Survey Guidelines at: https://www.fws.gov/media/range-wide-indiana-bat-and-northern-long-eared-bat-survey-guidelines.

No DKey Version Publish Date: 05/19/2025 8 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC

29. Will the action include tree cutting or other means of knocking down or bringing down trees, tree topping, or tree trimming?

No

30. Will the proposed action result in the use of prescribed fire?

Note: If the prescribed fire action includes other activities than application of fire (e.g., tree cutting, fire line preparation) please consider impacts from those activities within the previous representative questions in the key.

This set of questions only considers impacts from flame and smoke.

No

31. Does the action area intersect the tricolored bat species list area?

Automatically answered Yes

32. [Semantic] Is the action area located within 0.5 miles of radius of an entrance/opening to any known tricolored bat hibernacula? Note: The map queried for this question contains proprietary information and cannot be displayed. If you need additional information, please contact your State wildlife agency.

Automatically answered No

33. [Semantic] Is the action area located within 0.25 miles of a culvert that is known to be occupied by northern long-eared or tricolored bats? Note: The map queried for this question contains proprietary information and cannot be displayed. If you need additional information, please contact your State wildlife agency.

Automatically answered No

34. Your project overlaps with an area where tricolored bats may be present and roosting in trees year-round.

Has a presence/probable absence survey for the tricolored bat following the Service's Range-wide Indiana Bat and Northern Long-Eared Bat Survey Guidelines been conducted within the project area? If unsure, answer "No."

No DKey Version Publish Date: 05/19/2025 9 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC

35. Your project overlaps with an area where tricolored bats may be present and roosting in trees year-round.

Is suitable tricolored bat habitat present within 1000 feet of project activities? Note: If there are trees within the action area that may provide potential roosts for tricolored bats (e.g., clusters of leaves in live and dead deciduous trees, Spanish moss (Tillandsia usneoides), clusters of dead pine needles of large live pines) answer "Yes." Additional information defining suitable summer habitat for the northern long-eared bat and tricolored bat can be found in Appendix A of the USFWS' Range-wide Indiana Bat and Northern long-eared bat Survey Guidelines at: https://www.fws.gov/media/range-wide-indiana-bat-and-northern-long-eared-bat-survey-guidelines.

Yes

36. Do you have any documents that you want to include with this submission?

No DKey Version Publish Date: 05/19/2025 10 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 07/01/2025 14:19:41 UTC PROJECT QUESTIONNAIRE DKey Version Publish Date: 05/19/2025 11 of 12

Project code: 2025-0116165 IPaC Record Locator: 175-164224341 IPAC USER CONTACT INFORMATION Agency:

Name:

Address:

City:

State:

Zip:

Email Phone:

Private Entity Jay Hemmis 1601 Northwest Expressway Oklahoma City OK 73118 jhemmis@enercon.com 6789324364 LEAD AGENCY CONTACT INFORMATION Lead Agency: Nuclear Regulatory Commission DKey Version Publish Date: 05/19/2025 07/01/2025 14:19:41 UTC 12 of 12

Appendix B:

Safe Harbor Agreement Annual Reports (2019-2024)

RED-COCKADED WOODPECKER SAFE HARBOR 2019 ANNUAL REPORT For SOUTH CAROLINA LANDOWNERS Background Information Tract Name: Robinson tract Tract Owner's Name: Duke Energy, Inc.

Address: c/o Timber management, 700 East Ritchie Road (0120-40), Salisbury, NC 28146 Phone/Fax/Email: 980.373.4126 (O); 336.470.2323 (cell); 704.382.3060 (F);

Derek.Ware@duke-energy.com Contact's Name: Fred Beck, American Forest Management Address: PO Box 240, Bennettsville, SC 29512 Phone/Fax/Email: 843.454.0015 (O); 843.439.2547 (cell); 843.454.0085 (F);

fred.beck@afmforest.com List professional biologists/foresters employed or contracted to manage wildlife on the property: Fred Beck. SCRF 1142 Red-cockaded Woodpecker (RCW) Information

1. Number of active baseline clusters: 0 Acres of foraging habitat provided: 0

2. Number of active above-baseline clusters: O Acres of foraging habitat provided: 0

3. Artificial cavities installed in 2019: 0 in O clusters

4. Do baseline clusters have at least 4 suitable cavities? (No visible damage/enlarged)

Yes D / No IZI If no, how many clusters are short? Click here to enter text.

5. Number of recruitment clusters (artificial cavities installed to increase the property's population) available for RCWs: O

6. Total# of new cavity trees found in 2019: O

7. Total# of existing cavity trees lost in 2019 and how (ex: burned in RX fire, ice damage, beetles, etc) 0

Birds translocated to property? O From where? Click to enter text.

Birds translocated from property? 0 To where? Click to enter text.

Management Activities Activity Acres (these should not overlap)

Habitat for Habitat for Habitat =

Baseline RCW Above-baseline suitable &

Prescribed burning: growing season Prescribed burning: non-growing season Pine Thinning Mechanical treatment (roller chopping, etc.)

Herbicide treatment Longleaf pine planted Other (please describe)

Financial Assistance and Research clusters RCW clusters*

ORCWs

• this column only for active Above-baseline RCW clusters Were any financial assistance programs used to manage baseline clusters (surveys, burns, mechanical/ chemical treatments, artificial cavities, etc.)? No Name of program: Click here to enter text.

Objectives: Click here to enter text.

Were objectives achieved: Yes D / No D If no, why? Click here to enter text.

Was any research conducted on this RCW population during 2019? Yes D / No IZI If so, identify the researchers and briefly discuss the nature of the work: Click here to enter text.

Please describe any issues you had for this reporting year: Click here to enter text.

Please e-mail the completed report to Rcw@dnr.sc.gov or mail to RCW Project Leader, SCDNR, Wildlife and Freshwater Fisheries, P.O. Box 23205, Columbia, SC 29224-3205.

RED-COCKADED WOODPECKER SAFE HARBOR 2020 ANNUAL REPORT For SOUTH CAROLINA LANDOWNERS Background Information Tract Name: Robinson tract Tract Owner's Name: Duke Energy, Inc.

Address: c/o Forest Management, 700 East Ritchie Road {0120-40), Salisbury, NC 28146.

Phone/Fax/Email: 980.373.4126 (O); 704.638.4053 (Cell); 704.382.3060 (F);

Derek.Ware@duke-energy.com Contact's Name: Fred Beck, American Forest Management Address: PO Box 240, Bennettsville, SC 29512 Phone/Fax/Email: 843.454.005 (O); 843.439.2547 (Cell); 843.454.0085 (F);

fred.beck@afmforest.com List professional biologists/foresters employed or contracted to manage wildlife on the property: Fred Beck. SCRF 1142 Red-cockaded Woodpecker (RCW) Information

1. Number of active baseline clusters: 0 Acres of foraging habitat provided: 0

2. Number of active above-baseline clusters: 0 Acres of foraging habitat provided: 0

3. Artificial cavities installed in 2020: 0 in 0 clusters

4. Do baseline clusters have at least 4 suitable cavities? (No visible damage/enlarged)

Yes D / No X If no, how many clusters are short? Click here to enter text.

5. Number of recruitment clusters (artificial cavities installed to increase the property's population) available for RCWs: 0

6. Total# of new cavity trees found in 2020: 0

7. Total# of existing cavity trees lost in 2020 and how (ex: burned in RX fire, ice damage, beetles, etc) 0 Birds translocated to property? 0 From where? Click to enter text.

Birds translocated from property? 0 To where? Click to enter text.

Management Activities Activity Acres (these should not overlap)

Habitat for Habitat for Habitat =

Total Baseline Above-baseline suitable &

Acres RCW RCW clusters*

ORCWs clusters Prescribed burning: growing season Prescribed burning: non-growing season Pine Thinning Mechanical treatment (roller chopping, etc.)

Herbicide treatment 719 719 Longleaf pine planted Other (please describe)

• this column only for active Above-baseline RCW clusters Total acres for each activity should be equal to or less than the total acres enrolled in the RCW Safe Harbor Program (this can be found on the Certificate of Inclusion (COi))

Financial Assistance and Research Were any financial assistance programs used to manage baseline clusters (surveys, burns, mechanical/ chemical treatments, artificial cavities, etc.)? No Name of program: Click here to enter text.

Objectives: Click here to enter text.

Were objectives achieved: Yes D / No D If no, why? Click here to enter text.

Was any research conducted on this RCW population during 2020? Yes D / No X If so, identify the researchers and briefly discuss the nature of the work: Click here to enter text.

Please describe any issues you had for this reporting year: Click here to enter text.

Please e-mail the completed report to LerowM@dnr.sc.gov or mail to RCW Project Leader, SCDNR, Wildlife and Freshwater Fisheries, P.O. Box 290783, Columbia, SC 29229-0014.

RED-COCKADED WOODPECKER SAFEHARBOR2021ANNUALREPORT For SOUTH CAROLINA LANDOWNERS Background Information Tract Name: Robinson tract Tract Owner's Name: Duke Energy, Inc.

Address: c/o Forest Management, 700 East Ritchie Road {0120-40), Salisbury, NC 28146 Phone/Fax/Email: 980.373.4126 (o); 704.638.4053 (cell); 336.470.2323 {F);

Derek.Ware@duke-energy.com Contact's Name: Fred Beck; American Forest Management Address: PO Box 240, Bennettsville, SC 29512 Phone/Fax/Email: 843.454.0015 (o); 843.439.2547 (cell); 843.454.0085 (F);

fred.beck@afmforest.com List professional biologists/foresters employed or contracted to manage wildlife on the property: Fred Beck SCRF 1142 Red-cockaded Woodpecker (RCW) Information

1. Number of active baseline clusters: 0 Acres of foraging habitat provided: 0

2. Number of active above-baseline clusters: O Acres of foraging habitat provided: 0

3. Artificial cavities installed in 2021: 0 in O clusters

4. Do baseline clusters have at least 4 suitable cavities? {No visible damage/enlarged)

Yes D / No IZI If no, how many clusters are short? Click here to enter text.

5. Number of recruitment clusters (artificial cavities installed to increase the property's population) available for RCWs: O

6. Total# of new cavity trees found in 2021: O

7. Total# of existing cavity trees lost in 2021 and how (ex: burned in RX fire, ice damage, beetles, etc) 0

Birds translocated to property? O From where? Click to enter text.

Birds translocated from property? 0 To where? Click to enter text.

Management Activities Activity Acres (these should not overlap)

Habitat for Habitat for Habitat =

Total Baseline Above-baseline suitable &

Acres RCW RCW clusters*

ORCWs clusters Prescribed burning: growing season Prescribed burning: non-growing season Pine Thinning Mechanical treatment (roller chopping, etc.)

Herbicide treatment Longleaf pine planted Other (please describe)

• this column only for active Above-baseline RCW clusters Total acres for each activity should be equal to or less than the total acres enrolled in the RCW Safe Harbor Program (this can be found on the Certificate of Inclusion (COi))

Financial Assistance and Research Were any financial assistance programs used to manage baseline clusters (surveys, burns, mechanical/ chemical treatments, artificial cavities, etc.)? No Name of program: Click here to enter text.

Objectives: Click here to enter text.

Were objectives achieved: Yes D / No D If no, why? Click here to enter text.

Was any research conducted on this RCW population during 2020? Yes D / No IZI If so, identify the researchers and briefly discuss the nature of the work: Click here to enter text.

Please describe any issues you had for this reporting year: Click here to enter text.

Please e-mail the completed report to LerowM@dnr.sc.gov or mail to Matt Lerow, SCDNR, P.O.

Box 290783, Columbia, SC 29229-0014.

RED-COCKADED WOODPECKER SAFE HARBOR 2022 ANNUAL REPORT For SOUTH CAROLINA LANDOWNERS Background Information Tract Name: Robinson tract Tract Owner's Name: Duke Energy, Inc.

Address: c/o Forest Management, 700 Ritchie Road (0120-40), Salisbury, NC 28146 Phone/Fax/Email: 980.373.4126 (o); 704.638.4053 (cell); 336.470.2323 (F);

Derek.Ware@duke-energy.com Contact's Name: Fred Beck, American Forest Management Address: PO Box 240, Bennettsville, SC 29512 Phone/Fax/Email: 843.454.0015 (o); 843-439.2547 (m); 843.454.0085 (F);

fred.beck@afmforest.com List professional biologists/foresters employed or contracted to manage wildlife on the property: Fred Beck SCRF 1142 Red-cockaded Woodpecker (RCW) Information

1. Number of active baseline clusters: 0 Acres of foraging habitat provided: 0

2. Number of active above-baseline clusters: O Acres of foraging habitat provided: 0

3. Artificial cavities installed in 2022: 0 in O clusters

4. Do baseline clusters have at least 4 suitable cavities? (No visible damage/enlarged)

Yes D / No IZI If no, how many clusters are short? Click here to enter text.

5. Number of recruitment clusters (artificial cavities installed to increase the property's population) available for RCWs: O

6. Total# of new cavity trees found in 2022: O

7. Total# of existing cavity trees lost in 2022 and how (ex: burned in RX fire, ice damage, beetles, etc) 0

Birds translocated to property? O From where? Click to enter text.

Birds translocated from property? 0 To where? Click to enter text.

Management Activities Activity Acres (these should not overlap)

Habitat for Habitat for Habitat =

Total Baseline Above-baseline suitable &

Acres RCW RCW clusters*

ORCWs clusters Prescribed burning: growing season Prescribed burning: non-growing season Pine Thinning Mechanical treatment (roller chopping, etc.)

Herbicide treatment Longleaf pine planted Other (please describe)

• this column only for active Above-baseline RCW clusters Total acres for each activity should be equal to or less than the total acres enrolled in the RCW Safe Harbor Program (this can be found on the Certificate of Inclusion (COi))

Financial Assistance and Research Were any financial assistance programs used to manage baseline clusters (surveys, burns, mechanical/ chemical treatments, artificial cavities, etc.)? No Name of program: Click here to enter text.

Objectives: Click here to enter text.

Were objectives achieved: Yes D / No D If no, why? Click here to enter text.

Was any research conducted on this RCW population during 2022? Yes D / No IZI If so, identify the researchers and briefly discuss the nature of the work: Click here to enter text.

Please describe any issues you had for this reporting year: Click here to enter text.

Please e-mail the completed report to LerowM@dnr.sc.gov or mail to Matt Lerow, SCDNR, P.O.

Box 290783, Columbia, SC 29229-0014.

Background Information Tract Name: Robinson RED-COCKADED WOODPECKER SAFE HARBOR 2023 ANNUAL REPORT For SOUTH CAROLINA LANDOWNERS Tract Owner's Name: Duke Energy, Inc.

Address: c/o Forest Management, 700 Ritchie Road (0120-40), Salisbury, NC 28146 Phone/Fax/Email: 980.373.4126 (o); 704.638.4053 (cell); 336.470.2323 (F);

Derek.Ware@duke-energy.com Contact's Name: Fred Beck, American Forest Management Address: PO Box 240, Bennettsville, SC 29512 Phone/Fax/Email: 843.454.0015 (o); 843.439.2547 (m); 843.454.0085 (F);

fred.beck@afmforest.com List professional biologists/foresters employed or contracted to manage wildlife on the property: Fred Beck SCRF 1142 Red-cockaded Woodpecker (RCW) Information

1. Number of active baseline clusters: 0 Acres of foraging habitat provided: 0

2. Number of active above-baseline clusters: O Acres of foraging habitat provided: 0

3. Artificial cavities installed in 2023: 0 in O clusters

4. Do baseline clusters have at least 4 suitable cavities? (No visible damage/enlarged)

Yes D / No IZI If no, how many clusters are short? Click here to enter text.

5. Number of recruitment clusters (artificial cavities installed to increase the property's population) available for RCWs: O

6. Total# of new cavity trees found in 2023: O

7. Total# of existing cavity trees lost in 2023 and how (ex: burned in RX fire, ice damage, beetles, etc) 0

Birds translocated to property? O From where? Click to enter text.

Birds translocated from property? 0 To where? Click to enter text.

Management Activities Activity Acres (these should not overlap)

Habitat for Habitat for Habitat =

Total Baseline Above-baseline suitable &

Acres RCW RCW clusters*

ORCWs clusters Prescribed burning: growing season Prescribed burning: non-growing season Pine Thinning Mechanical treatment (roller chopping, etc.)

Herbicide treatment Longleaf pine planted Other (please describe)

• this column only for active Above-baseline RCW clusters Total acres for each activity should be equal to or less than the total acres enrolled in the RCW Safe Harbor Program (this can be found on the Certificate of Inclusion (COi))

Financial Assistance and Research Were any financial assistance programs used to manage baseline clusters (surveys, burns, mechanical/ chemical treatments, artificial cavities, etc.)? No Name of program: Click here to enter text.

Objectives: Click here to enter text.

Were objectives achieved: Yes D / No D If no, why? Click here to enter text.

Was any research conducted on this RCW population during 2023? Yes D / No IZI If so, identify the researchers and briefly discuss the nature of the work: Click here to enter text.

Please describe any issues you had for this reporting year: Click here to enter text.

Please e-mail the completed report to LerowM@dnr.sc.gov or mail to Matt Lerow, SCDNR, P.O.

Box 290783, Columbia, SC 29229-0014.

Red-cockaded Woodpecker Safe Harbor 2024 Annual Report Submitted Time: January 21, 2025 1 :18 PM Property Information Tract Name: Robinson Tract Address: PO Box 240 Tract Address Point E~n. NASA, NGA, USGS I Esri, Tom Tom, Garmin, METI/NASA, ___

Powered by Esri Tract Owner's Name: Duke Energy, Inc Contact Name: Fred Beck Contact Phone Number: (843) 439-2547 Contact Email: fred.beck@afmforest.com List any professional biologists or foresters employed or contracted to manage wildlife on the property Fred Beck SCRF 1142 Was there an ownership transfer or property sale in 20247: No

Red-cockaded Woodpecker Information Number of active baseline clusters: 0 Number of active above-baseline clusters: 0 Number of recruitment clusters available for RCWs: 0 Number of artificial cavities installed in 2024: 0 Do baseline clusters have at least 4 suitable cavities?:

Total# of new cavity trees found in 2024: 0 Total# of existing cavity trees lost in 2024: 0 Describe how trees were lost Number of birds translocated TO the property in 2024: 0 Name of donor property:

Number of birds translocated FROM the property in 2024: 0 Name of recipient property:

Is the landowner interested in receiving translocated RCW in the event they become available?: No Land Management Activities List the number of acres (can be 0) treated in 2024 using the following management techniques Prescribed burning (growing season): 0 Prescribed burning (non-growing season): 0 Pine thinning: 0 Mechanical treatment (roller chopping, etc.): 0 Herbicide treatment: O Longleaf pine underplanting: 0 Other (please describe):

Financial Assistance & Research Were any financial assistance programs used to manage RCW trees or habitat during 2024 (surveys, prescribed burning, artificial cavities, etc.)?: No List of conservation or habitat objectives:

Were these objectives achieved?:

Was any research conducted on this RCW population during 20247: No Would you be interested in receiving financial assistance for RCW-beneficial land management if funding were to become available through the SCDNR Safe Harbor Program?: No Other Please describe any issues you had for this reporting year:

Any additional questions or concerns?:

Appendix C:

2024 Monarch Candidate Conservation Agreement with Assurances Annual Compliance Report

2024 Monarch CCAA Annual Compliance Report Nationwi~e ~

MONARCH CCAA (#/if BUTTERFLY 2024 Monarch CCAA Annual Compliance Report I.

Partner Information Organization Name:

Duke Energy Certificate of Inclusion Number:

DUK2021-01 Primary Point of Contact Name:

Wilson E. Ricks Address:

13339 Hagers Ferry Road, MG03A3, Huntersville, NC 28078 Phone Number:

252-326-4244 Email:

Wilson. Ricks@duke-energy.com Acres Enrolled:

1,308,909 Adopted Acres Target:

66,015 Adopted Acres Contributed 66,015 Over Past Year:

If necessary, provide additional explanation or comments In 2025 we will be updating our Certificate of Inclusion to reflect related to the enrolled acres updates based on Nature Serve Data, Piedmont Natural Gas and adopted acres values given Data, and Renewables Projects that will be in process.

above.

January 2025 Page 1 of 7

2024 Monarch CCAA Annual Compliance Report II. Summary of Annual Net Conservation Benefit Contribution Nationwi~e ~

MONARCH CCAA (#/if BUTTERFLY Provide a short narrative of lands managed over the past year in the Agreement. Describe:

Our target adoption rate in 2024 was 66,015 acres. Our conservation measures were implemented on 66,015 acres which exceeded our goals the company set in 2022. The conservation measures most frequently used fall under our integrated vegetation management program (IVM). IVM uses the best management plan (BMP) for a specific site based on the conservation of the natural resources present. Practices include selective application of selective herbicides, mowing, hand-cutting, leaving fallow, and in some cases native plantings and prescribed fire. Conservation measures were reported on a company-wide scale and were recorded using our internal Natural Resources Viewer (environmental GIS mapping program).

All of the adopted acres within Duke Energy fall under the IVM program. A description of how these habitats are created is listed below:

Selective application of herbicide is used to control tall-growing incompatible plants within the power line rights of way (ROW). Target plants are woody trees, stems, vines, and invasive exotic species.

Maintaining low-growing vegetation and promoting pollinator plants, native grasses, and forbs creates high quality pollinator habitat.

Selective herbicides are used using the most up-to-date data and research surrounding herbicides and BMPs. Herbicides are used with a focus on environmentally responsible techniques used by certified herbicide applicators and registered by the USEPA.

Mowing ROWs is another tool used to promote pollinators, especially outside of the growing season.

Mowing has been recommended to our specialists by state and federal agency partners at certain sites to promote high quality pollinator and native wildlife habitat.

Hand-cutting is used in wetlands and in areas where heavy machinery is not environmentally preferred. Hand-cutting removes woody plants and promotes native pollinator plants and habitats.

Leaving an area fallow is applied when there is simply no need for management on the ROW based on the absence of woody stems and invasive plants.

These sites provide excellent early successional pollinator habitat without any land manipulation.

In some cases, native pollinator plantings have occurred on our ROWs. At these sites regionally appropriate pollinator mixes were used for erosion control and wildlife stewardship.

Prescribed fire is most often used on our ROWs when our ROWs intersect with county, state or federal lands.

County, state, and federal biologists and foresters, work with Duke Energy's vegetation management and asset protection specialists, to safely burn the ROWs to promote flowering plants, threatened or endangered species, and native habitats. Additionally, fire removes woody stems to create a more open grass and forb dominated landscape.

Since the onset of our IVM program, field staff, county, state, and federal partners, NGO partners, and the general public have noticed and applauded our IVM program. There has been a noticeable difference in January 2025 Page 2 of 7

2024 Monarch CCAA Annual Compliance Report Nationwi~e ~

MONARCH CCAA (#/if BUTTERFLY nectar plants, bunch grasses, milkweeds, monarchs, bees, and other butterfly abundance and species occurrence. As invasive exotic species like Chinese privet (Ligustrum saneness), autumn olive (Eleagnus umbellata), mimosa (Alibizia julibrissin), multiflora rose (Rosa multiflora), tree of heaven (Ailanthus altissima), and others are removed from ROWs there is less opportunity for them to take over and more opportunity for pollinator plants to thrive. Vegetation management specialists at Duke Energy are wildlife stewardship minded and very excited about supporting pollinator projects in their territories. From the Midwest to the mountains to the coast vegetation management specialists have mentioned they have seen an increase in butterflies and bees and the pollinator habitats they require.

In limited circumstances, some Duke Energy enrolled lands overlapped Indiana Department of Transportation (INDOT) Monarch CCAA enrolled acres. Through discussions with INDOT representative Matt Kraushar, overlap acres were determined by utilizing existing Duke Energy CCAA kmz files and cross-referencing with INDOT ROW. A GIS measurement tool was used to sum all enrolled acres that met the INDOT/Duke Energy intersection criteria. A total of 4.0 acres were determined to be overlap between INDOT and Duke Energy enrolled acres within the Monarch CCAA. Duke Energy also processed kmz files provided by Dave Appel of Hoosier Energy to determine the overlap of Monarch CCAA adopted acres with Duke Energy. Less than 0.5 acres were identified.

January 2025 Page 3 of 7

2024 Monarch CCAA Annual Compliance Report Ill. Summary of Effectiveness Monitoring Conducted Nationwi~e ~

MONARCH CCAA (#/if BUTTERFLY Provide a concise summary of effectiveness monitoring conducted and any summarized results.

Effectiveness monitoring was conducted on 105 sites across all regions. 46 sites located in the Midwest, 59 sites located in the Southeast were surveyed in the 2024 survey season, which added 14 surveys from the 2023 survey season. Monitoring was conducted by wildlife biologists and wildlife technicians and in some cases other internal staff joined for education, support, and safety. Each wildlife biologist and wildlife technician receive training through three meetings before the field season began and after the certificate of inclusion (Cl) was received.

Each monitor is well trained in wildlife species identification, vegetation measurements, and have 1 O+ years of field experience.

Results:

69 sites (65.7%) contained over 26% nectar plants.

41 sites (39.0%) contained milkweed.

446 milkweed stems were counted during the surveys.

Monitoring experimental design and data collection was reported using the sampling protocols document, the ROW as Habitat Working Group Pollinator Scorecard document, the CCAA Toolkit, and multiple meetings and trainings from UIC to support our plan. We will provide our CCAA Monitoring Study Plan and maps with this report.

Surveys in 2024 were conducted from June through October. In 2025, we will survey throughout the growing season (April through September) to get a more comprehensive dataset.

Monitoring in 2024 fulfilled and nectar plant targets and were just below the milkweed stem in the Midwest and monitoring in the Southeast fulfilled the nectar plant targets but not the milkweed stem targets. In 2025 we plan to plant over 100 milkweed stems to improve habitat for monarchs.

In Duke Energy's Midwest region for the 2024 CCAA surveys, monitoring revealed a substantial decrease in observed monarch larvae and adults from previous years. Additionally, surveyors noted multiple sites (6+) that contained no milkweed stems; multiple milkweed plants were observed, however, just outside of (and adjacent to) these survey plots. In an effort to enhance these areas, Duke Energy plans in the 2025 season to plant approximately 25 milkweed stems in suitable areas that presently lack milkweeds. In addition to these plantings, a new coordination effort with NSA Crane is slated to enhance overlapping acres, collaborate on management opportunities, and potentially combine expertise and resources to integrate pollinator management on the site. During the 2024 monitoring surveys, several areas that were randomly selected in Indiana proved to exhibit exceptionally high-quality pollinator habitat which is a promising sign for the habitat in 2025.

Duke Energy has joined a Memorandum of Understanding (MOU) in North Carolina, which is an agreement involving ROW management between Duke Energy and multiple state agencies to protect and promote important native species and native habitats on state lands throughout North Carolina.

The parties collaborate to successfully manage rare, threatened, and endangered species, sensitive or exemplary natural communities and other significant natural features within public utility powerline (i.e., transmission and distribution) easements. This partnership is made possible through communication, adaptive management, January 2025 Page 4 of 7

2024 Monarch CCAA Annual Compliance Report Nationwi~e ~

MONARCH CCAA (#/if BUTTERFLY raising awareness, and working with both private and public partners to help protected species. IVM has been used with direction through this agreement throughout North Carolina to create excellent pollinator habitats. Agency partners view pollinator habitat and monarch habitat as a principal mission in North Carolina and the MOU has been able to maximize these habitats on ROWs. Each year the MOU will be reviewed and examined to see if sites need to be added or additional species need to be protected. Duke Energy customers and business units are excited to support with groundbreaking project in North Carolina. One site within the MOU, Picture Creek Diabase Barrens, is one of the largest smooth coneflower sites in the world. Picture Creek is one of our best pollinator habitats in North Carolina and has been a great collaboration between Duke Energy IVM, state and federal agencies, NGOs, university research, and the general public to maintain arguably one of the most important habitats in the southeast which exists on our ROWs.

In 2024, Duke Energy Partnered with Wake County Parks, Recreation, and Opens Spaces on a milkweed planting project on Wake County property. Two Duke Energy employees and three Wake County employees planted 125 milkweed stems and over 300 milkweed seeds were scattered along a Duke Energy transmission right of way near Knightdale, North Carolina. The day started with a safety meeting a planting plan to scatter the milkweed stems in groups across four separate areas along the right of way. Water was also provided to give the plants a thorough watering after planting. The planting occurred on August 21 st, 2024, after a multiple week rainy stretch which should help the success rate of the stems. A survey will be conducted in the spring of 2025 to investigate if the planting was a success. Duke Energy is committed to planting over 100 additional milkweed stems in the Carolinas, over 25 milkweed stems in the Midwest, and potentially have a small milkweed planting in Florida during the 2025 season.

Duke Energy has partnered with Croatan National Forest to have a prescribed fire and right of way planning meeting for mutual benefits to promote pollinators and rare plants. The first meeting will be held in October of 2025 and will start a new partnership to promote pollinators on Duke Energy right of ways on federal lands.

This pilot project is designed to eventually spread to other federal lands across the Carolinas.

The 2024 High Springs Solar, University of Florida Pollinator Study, will have an important impact on pollinator and solar projects in Florida and throughout the Southeast. In 2023, Duke Energy Florida distributed $144,421 in a grant to the Florida Museum of Natural History (University of Florida) to evaluate the establishment of pollinator habitat at its new High Springs solar site in Alachua County. The expansion of solar farms across the U.S. is creating an abundance of bright, open spaces that require regular upkeep.

Unused areas near the solar arrays are increasingly being viewed as prime real estate for growing native flowering plants that support pollinators. Duke Energy Florida recently completed construction of a new solar site in High Springs, Florida, and approached Dr. Jaret Daniels (UF) to see if he'd be willing to conduct a feasibility study that would assess plant selection, establishment, survival, time to bloom, bloom abundance and overall cost. In 2024, Dr. Daniels and his team will be planting a variety of native wildflower species at the solar site. Very few studies, especially in the Southeast, have tested how best to establish larger-scale pollinator habitat in this type of landscape. According to Dr. Daniels, most of the information that does exist is anecdotal and not broadly applicable to a wide region. Even the most basic questions, like how many seeds to sow and in what proportions, are still open-ended. By project's end, Dr. Daniels' team will help generate more rigorous recommendations that can be broadly applicable to the southeast U.S.

January 2025 Page 5 of 7

2024 Monarch CCAA Annual Compliance Report Nationwi~e ~

MONARCH CCAA (#/if BUTTERFLY "Duke Energy wants something they can apply not just to this particular solar site, but to other sites throughout their Florida service territory, Daniels said. "We can give them something backed by data on how they can do this better and more effectively, to benefit the pollinators and also maximize their impact."

"Duke Energy is excited to work with Dr. Daniels and team to discover best practices for successful pollinators at our solar facilities," said Melissa Seixas, Duke Energy Florida state president. "Duke Energy is committed to environmental stewardship, and ensuring we do everything we can to preserve and enhance pollinator habitats that are vitally important to our ecosystems and the health of our planet." "Dr. Daniels' work will help us understand how to prepare our facilities to have a healthier and more thriving environment for the monarch butterfly and other declining species," said Seixas. The University of Florida and Duke Energy were able to get started in late fall 2024, but access to the site has presented some challenges. Our primary contact for access, Daniel Snipes, informed us that someone from Duke needs to be present for us to gain access, which requires significant coordination of schedules. Daniel is understandably very busy, so arranging access and confirming access dates has been a bit delayed. Additionally, we've encountered some unexpected issues on-site, particularly with sinkholes. During a recent visit, we identified at least 10 areas where visible holes appear to be developing. When we inserted a pole into some of these holes, it didn't seem to make contact with anything for a couple of feet, suggesting they could be forming into something more significant. At this point, we are working to finalize access to complete the broadcast of the seed mixes. We'll proceed with the spring plug/container/seed installation in March or April of 2025. We've also updated the site layout and plan below:

Research Planning for Duke Energy Solar Project Project title: Evaluation of flowering plant establishment at Duke Energy's High Springs solar power plant Project goal: Provide cost-benefit analysis metrics to Duke Energy for establishing pollinator habitat using different flowering plant installation treatments Research questions:

• What plant installation rates and techniques can provide optimal floral resources for pollinators while maximizing cost effectiveness?

• How much does each treatment cost per acre to install? To maintain per year?

• What provides the highest establishment of bloom resources?

• Does repeated seeding during subsequent seasons create higher densities of floral resources?

• Does bloom phenology vary based upon the plant installation technique?

• What technique requires the least amount of initial labor? Long-term labor?

• What are the average yearly costs associated with maintaining/enhancing this pollinator habitat?

January 2025 Page 6 of 7

2024 Monarch CCAA Annual Compliance Report Nationwi~e ~

MONARCH CCAA (#/if BUTTERFLY IV. Upcoming Year Annual Forecast Describe any changes you would like to make to your Certificate of Inclusion or CCAA implementation, if applicable. If necessary, please indicate a timeframe that you would like to discuss these changes with the UIC team.

Provide any other general comments about your CCAA implementation or this annual report..

Provide and briefly describe any other supporting documentation you would like to include In 2025, we plan to communicate more with our internal customers (e.g., transmission, distribution, natural gas departments, and regulated renewables within Duke Energy) to ensure we are aware of all pollinator areas and also hope to motivate customers to incorporate pollinator management into their land management activities where feasible. We are continuously training the Monarch CCAA requirements and responsibilities to these internal customers.

Duke Energy has scheduled meetings throughout 2025 to find and update enrolled lands and adopted acres for the 2025 annual report. There are a number of potential projects in Florida, the Carolinas, and the Midwest that will include additional pollinator habitat within transmission, distribution, and natural gas ROWs, as well as renewable pollinator projects. Duke Energy will communicate with UIC to ensure the proper time to provide acreage changes and updated maps and shapefiles needed.

In 2025 we will be updating our Certificate of Inclusion to reflect updates based on Nature Serve Data, Piedmont Natural Gas Data, and Renewables Projects that will be in process.

In 2025 we are committed to planting over 100 milkweed stems to enhance our sites. Additionally, we plan to survey over 100 plots in 2025.

V. Attachments Include attachments:

A copy of your implementation Compliance Tracking spreadsheet - Attached A copy of your Effectiveness Monitoring spreadsheet -Attached A map displaying the locations where monitoring was conducted -Attached Documentation necessary to support your supplemental measure discounts, if applicable -

Attached January 2025 Page 7 of 7