20230801_Wildlife_Mitigation

RAFTING AND DESIGN O
SERVICES,INC.
6728 Carbonton Road
Sanford, NC 27330
[phone]
North Carolina Wildlife Resources Commission
Mitigation Plan for Havelock Drugstore Mine
Based on comments received from Adam Parr at NCDEQ for a mine permit application
for a permit in Martin County(Havelock Drugstore Mine), Maria Dunn at the North Carolina
Wildlife Resources Commission provided a letter explaining the possible existence of at-risk
species within the project area. The possible existence of these species in the area was unknown
at the time of permit submittal, and in response, we are providing a mitigation plan for potential
impacts.
An at-risk species referenced is the Atlantic Sturgeon. The proposed mine is within 1-2
miles from the Roanoke River which is a critical habitat for the Atlantic Sturgeon. The NCWRC
letter mentioned the mine being completely surrounded by wetlands as a possible concern, as if
there is any drawdown of water it could affect the surrounding ecosystem, and possibly the
Atlantic Sturgeon. Because of this, mine plan has changed operation from pumping and
dewatering the pits to facilitate the excavation, to mining the pits wet. This process would consist
of simply digging out the material with an excavator, even in the presence of water, and piling up
the material within the pit to let the water drain back into the pit. There will be no outlets of
water to the surrounding areas and all water will be trapped within the pit berms that surround
the various pits. This change should mend any concerns referencing any affect to surrounding
wetlands and the Roanoke River, as no groundwater will be leaving the pit areas.
Additionally,NCWRC mentioned access to the site as an item needing to be addressed.
The site will be accessed by an existing road(View Nicholson Road), which is connected to a
multitude of forestry roads which layout through the site. Any crossings of wetlands, existing or
proposed will be brought up to NCDEQ standards. The detail for wetlands crossings has been
added to the plans to show how all wetlands will be crossed and maintained to NCDEQ
standards, to make sure of no additional impacts. In short, the wetlands crossings will include

culverts to connect either side of the wetlands to facilitate water flow back and forth from the
neighboring wetlands.
The next at-risk species that could be in the area is the Monarch Butterfly. The Monarch
Butterfly is a milkweed butterfly, meaning that they lay their eggs on Milkweed, which is the
only plant that their caterpillars can eat. Milkweed grows in fields, edges of forests, and along
roadways. The proposed mine will consist of 6 foot high berms completely surrounding the pits
that will be vegetated. When the berms are seeded for vegetation, the operator will use a seed
mix that includes a milkweed that is native to the area such as whorled milkweed. The existing
areas where the mining pits will be located are predominantly planted pine forests, therefore the
planting of milkweed will be a net gain of milkweed for the area and for the Monarch Butterfly.
Another at-risk species is the Tricolored Bat as well as the Long-eared Bat. Much of the
research done for these bats comes from a document created by the White-Nose Syndrome
National Plan (https:llwww.srs fs.usda.gov/pubs/misc/misc 2020_perry_OO1.pdf). These species
live within forest ecosystems and rely on wetlands and forests for their basic needs such as food,
water, and roosting. These bats forage within forests and riparian areas. There is a lot of forest
area for these bats to roam through for their basic necessities, as well as thousands of hardwood
trees within the wetlands and surrounding areas for roosting. The proposed mine will cut the
existing planted pines where the pits are located. These trees were previously planted to
eventually be harvested under a forestry use. Even though these trees are under a forestry use to
be cut, we have decided to add some additional mitigation techniques to help add some roosting
habitat from where the planted pines will be removed.
Bat houses will be the main addition for bat habitat within the property boundary. On the
outsides of the pits between the wetlands and the pit berms, bat houses will be placed around the
perimeter of each pit to help add back any roosting habitat that may be lost during the cutting of
the pines located within the pit areas. All bat houses will be at least 12 feet off of the ground and
placed on non-treated wood poles. The best locations for bat houses according the the White-
Nose Syndrome National Plan is around edges near streams, rivers, or lakes. During the
construction of the mine pits as well as the reclamation, multiple lakes will be formed, where the
bat houses should prove to be useful when located on the edges of those openings. These lakes
will also benefit the bats as bats do not stop flight to drink water, as they simply jet across the
water and scoop water into their mouths. These lakes will be an open area where these bats will
have a large runway to make their swoops to the water, not interfering with their flight paths. In
addition to the bat houses, where a wetland crossing will need to be upgraded to NCDEQ

standard, the operator may also opt to place concrete box culverts to not only help with
maintaining the water flow between the wetlands, but also to provide bat roost habitat in the
event that the bats are found within the area. According to the above referenced document, "box
culverts provide summer roosts for many bats. In southern areas, these sites are also used for
hibernation" (www.whitenosesyndrome.org). With these additions, we hope to maintain the
subject bat species' habitat and their populations within the area for many years to come.
These changes and mitigation techniques will ensure that the project will not adversely
impact wildlife in the area. Please feel free to contact our office for more information regarding
the plan proposed in this letter.

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