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North Carolina Wildlife Resources Commission Cameron Ingram, Executive Director Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 MEMORANDUM TO: Lyn Biles, Environmental Assistance and SEPA Coordinator NCDENR Division of Environmental Assistance and Customer Services FROM: Olivia Munzer, Western Piedmont Coordinator Habitat Conservation DATE: 10 December 2024 SUBJECT: Scoping for a Rezoning Application and Environmental Assessment for Bully Self Storage Facility at 9900 NC Highway 57, Rougemont, Orange County, North Carolina. DEQ No. 25-0093. Biologists with the North Carolina Wildlife Resource Commission (NCWRC) have reviewed the subject document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e) and North Carolina General Statutes (G.S. 113-131 et seq.). Justin Chandler has submitted a Rezoning Application and an Environmental Assessment for the development of Bully Self Storage located at 9900 NC Highway 57, Rougemont, Orange County, North Carolina. Of the 80.52-acre site, 9.66 acres will be developed into 40 commercial storage buildings; a map does not delineate the entire property boundary clearly. The property contains a single pond on the northeast side of the property and three streams; however, none of the maps depicts all the streams and the pond. The site is surrounded by a concrete plant, racetrack, solar plant, rock quarry, and wooded lands. The Applicant indicates the storage will replace the racetrack, yet the site plans show the storage facility built adjacent to the racetrack. According to the documents provided, three unnamed tributaries to South Flat River in the Neuse River Basin flow through the site, one of which occurs near the development zone. The property contains a single pond on the northeast side of the property outside of the development zone. We have no known records for state or federally listed rare, threatened or endangered species within or adjacent to the site. However, the proposed federal endangered and state endangered tricolored bat (Perimyotis subflavus) is known to occur in Orange County. The lack of records from the site does not imply or confirm the absence of federal or state-listed species. An on-site survey is the only means to determine if the proposed project may impact federal or state rare, threatened, or endangered species. We have some concerns with the Project. We prefer the storage facility replace the racetrack rather than be built adjacent to the racetrack and the mature forest is felled for the facility. The project footprint 181