20210106_N-Lew_Foxcroft_arch

From: Wrenn, Brian L
To: Miller. David; Parr, Adam
Subject: FW: [External] Public Comment opposing the Mining Permit Application for Permit 92-10, rebuttal to the
archaeology survey
Date: Wednesday, January 6, 2021 2:00:42 PM
Attachments: Foxcroft lake rebuttal to archaeology report 2020 01 06.pdf
Thanks,
Brian Wrenn, Director
Division of Energy, Mineral, and Land Resources
919-707-9222 (0)
919-218-7536 (M)
From: Natalie Lew <[e-mail]>
Sent: Wednesday, January 6, 2021 1:55 PM
To: Wrenn, Brian L <[e-mail]>; NCMiningProgram
<[e-mail]>
Subject: [External] Public Comment opposing the Mining Permit Application for Permit 92-10,
rebuttal to the archaeology survey
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Good afternoon Mr. Wrenn and others,
Please find attached a public comment to be included in the Public Comments opposing the
Mining Permit Application for Permit 92-10. Please confirm receipt and that this will be
included with the public comments.
Thank you very much.
-Natalie
It is the time you have wasted for your rose that makes your rose so important... from "The Little
Prince"

Foxcroft Lake
A significant feature on the Odd Fellows and one of many
Reason why the Triangle Quarry expansion permit should be denied
The following is a comment regarding Wake Stone Corporation's responses to NC DEMLR's
July 23, 2020 Request for Supplemental Information Letter (Triangle Quarry Mining Permit 92-
10 Expansion / Modification Application).
Question 18 of NC DEMLR's letter asks "Please provide a comprehensive archaeological survey
conducted by an experienced archaeologist on the Odd Fellows tract. We recommend consulting
with the NC Office of State."
The response to this question is in a document written by ACC, Inc. titled "Archaeological
Survey of the Oddfellows Tract, Wake County, North Carolina" which was specifically
"Prepared for Wake Stone Corporation." Page numbers noted in this document are in reference
to that document.
The response to Question #18 is incomplete as it fails to address the full significance of the
recent history and current culture.
Per a Google search, an "Archaeological field survey is the methodological process by which
archaeologists collect information about the location, distribution and organization of past human
cultures across a large area."
The Management Summary (page ii) indicates that "The goals of this investigation were to
identify all archaeological resources located within the project tract, assess those resources for
eligibility to the National Register of Historic Places (NRHP), and advance management
recommendations, as appropriate."
William B. Umstead State Park is adjacent to the Odd Fellows tract. As noted on page 20, "In
1995, William B. Umstead State Park was listed on the National Register of Historic Places as
the Crabtree Creek Recreational Demonstration Area (Moss 1995). This resource was
determined to have areas of significance for the period between 1933 and 1943 related to:
Architecture; Landscape Architecture; Entertainment/Recreation; Political/Government; and
Conservation." This listing in the NRHP includes not only the structures within the Park, this
listing includes the forest —all of the land, all of the trees, and all of the features on the land,
including Foxcroft Lake.
Per a Google search, the term archaeological resource means "any material remains of past
human life or activities which are of archaeological interest..." In addition to building structures
and artifacts, these material remains can include features like bodies of water (e.g., ponds, lake),
creeks, trails, and forests.
To be eligible for NRHP, archaeological resources should be >= 50 years old.
The history of the Boy Scouts; the orienteering club; and the local citizens who have used this
area in the past 100 years, is of "archaeological interest" and must not be discarded,
6/Jan/2021 (N. Lew) Page 1 of 5

Foxcroft Lake
A significant feature on the Odd Fellows and one of many
Reason why the Triangle Quarry expansion permit should be denied
misrepresented, or ignored. This land would not be on the North Carolina State Park's critical
acquisition list if it were insignificant.
The Management Summary (page ii) indicates that "Prior to beginning field work, factors such
as soil drainage and topography were used to define portions of the project tract that had high
potential for the presence of archaeological deposits. These areas total approximately 35 acres
(14.2 ha) and include ridge tops, knolls, and ridge toes." So, this "comprehensive archaeological
survey" was not very comprehensive as in only included 35 acres of the 105-acre tract, which is
only about 33% of the total area. The remaining 70 acres that were "considered to have low
archaeological potential" and only "surveyed by pedestrian walkover" seem to be very
unimportant to this "comprehensive archaeological survey." But these "low archaeological
potential" areas are the areas that make this tract of land so special, so significant, and so
important to the recent past and to the current times ... the steep terrain and ravines, etc. This
66.6% of the land, along with the other 33.3% of the land holds huge significance to the recent
past and the current culture. Doesn't 100% beat out 33%?
The Management Summary (page ii) concludes with "As no significant archaeological sites will
be impacted by the proposed development, clearance to proceed is recommended." To
recommend a "clearance to proceed" based on such a narrow study is ludicrous. This conclusion
is incorrect.
Page 1 notes that "an extensive network of walking and bicycle trails is present throughout the
tract." The basis for these trails started in 1958 when the Odd Fellows purchased this land for the
purpose of establishing the Odd Fellows Camp and to facilitate Scouting youth outings and
activities, including outdoor recreation activities like overnight camping, swimming, and hiking.
The RDU Airport Authority ALLOWED the Scouting groups to use this land until just very
recently. Thus, for just over 60 years, the Odd Fellows tract has served as an active facility for
Scouts to camp, swim, hike, etc.
Page 1 belittles an important feature of the Odd Fellows tract, Foxcroft Lake, by referring to it as
a "a small pond." Foxcroft Lake, actively used by the Boy Scouts and purposely enhanced and
maintained by the Odd Fellows, is not a small pond as it is almost 3 acres in size, a lake.
At this moment, Foxcroft Lake is on a list of Wake County Physical, Cultural & Historical
Features: https://northcarolina.hometownlocator.com/maps/feature-
map,ftc,2,fid,999491,n,foxcroft%20lake. cfm
The United States Geological Survey (USGS) classifies Foxcroft Lake as a Reservoir:
https:Hgeonames.us _ sg gov/aapex/f?p=GNISPQ:3:::NO::P3_FID:999491 and the Geographic
Names Information System (GNIS) ID for Foxcroft Lake is 999491.
Why is this information not mentioned in the report by ACC, Inc.? The authors of this report
have failed to do sufficient and adequate research and to report all relevant facts.
Foxcroft Lake lies in both Umstead State Park and in Odd Fellows, thus physically linking these
two entities. The waters of Foxcroft Lake flow into Crabtree Creek just upstream of the border
with Umstead State Park. Thus, the waters from Foxcroft Lake flow into Umstead State Park
6/Jan/2021 (N. Lew) Page 2 of 5

Foxcroft Lake
A significant feature on the Odd Fellows and one of many
Reason why the Triangle Quarry expansion permit should be denied
and make protection of Foxcroft Lake critical. Most importantly, the upper portion of Foxcroft
Lake lies within Umstead State Park. Since Umstead State Park, inclusive of forest and land
mass is on the NRHP, the upper portion of Foxcroft Lake is already on the NRHP. Thus,
Foxcroft Lake in its entirety must be protected and preserved.
Page 2 indicates how background research was conducted on Odd Fellows. Of note, the research
did NOT include visiting the location of the Odd Fellows lodge where the actual records are
kept. The research only included "communications with the Independent Order of Odd Fellows
Sir Walter Raleigh Lodge 411 ... to understand land use during their ownership of part of the
tract." This is another example of a narrow focus and misleading conclusions of the
investigation. Had they gone to actually look at the hard copy records maintained by the Odd
Fellows, then they would have known that their conclusion that Foxcroft Lake was created
between 1964 and 1971 (page 29) is wrong.
Based on records from Odd Fellows, it can be confirmed that the Odd Fellows enhanced this
body of water in March of 1959 with a dam, road, and gate. They also stocked the pond with
fish in May of 1959, suggesting that this body of water had already been established for some
time as a new pond/lake cannot be immediately stocked with fish. The trail system and camping
sites started in this time frame also.
Thus, Foxcroft Lake was a swimmable pond stocked with fish on or before the spring of 1959.
This makes Foxcroft Lake at least 61 years old. This lake was actively used until just 2 or so
years ago when the RDUAA forbade the Scouts from returning to their long -used camp site.
Given the long history of the Scouts using Foxcroft Lake and the Odd Fellows land, this area is
historically important and must be cherished and preserved.
Page 29 indicates that "A 1964 topographic map of the project area does not show the pond and
structure, indicating they were constructed between 1964 and 197 L" The scale of the 1964
topographical map referenced on page 32 of the report as Figure 3.8 is of too large an area for
Foxcroft Lake to be seen as evidenced by other known lakes that are also missing from that map.
The NCDOT ariel photo shown below (which is easily available over the Internet) from March
11, 1964 (per the date on the photo "3 11 64") clearly shows that Foxcroft Lake was well
established as of 1964. The large clearing next to the lake (the access area for Scouting
activities) demonstrates that Foxcroft Lake was an actively used area as of 1964. We all know
that this was an actively used area until just recently when the RDUAA stopped honoring the
Boy Scout's historical 50+ years of use of this area.
6/Jan/2021 (N. Lew) Page 3 of 5

Foxcroft Lake
A significant feature on the Odd Fellows and one of many
Reason why the Triangle Quarry expansion permit should be denied
i
Crabt_Creek
William B. Umstead
Page 1 indicates that the Background Research "served to identify previously recorded resources
in the project tract and its vicinity, in addition to providing data on the prehistoric and historical
context of the project tract." But the recent past and current importance were not addressed in
this report.
Page 6 indicates that "Artifacts and/or features less than 50 years in age would not be considered
a site without a specific research or management reason." But Foxcroft Lake and the extensive
network of trails are important features that have been in existence for more than 50 years and
more than 60 years.
Page 7 indicates "Sites that exhibit little or no further research potential are recommended not
eligible for the NRHP, and no further investigation is proposed. Sites for which insufficient data
could be obtained at the survev level are considered unassessed and preservation or more in-
depth investigation is advocated." The "Archaeological Survey of the Oddfellows Tract" report
has insufficient information on features older than 50 years - Foxcroft Lake, the trail system, and
maybe a few other features - so these sites should be considered unassessed and thus preserved.
Page 9 acknowledges Crabtree Creek and its flooding: "The southern and eastern portions of the
project tract front Crabtree Creek, a tributary of the Neuse River. Crabtree Creek begins in Cary
and empties into the Neuse River near Anderson Point Park in east Raleigh. The creek is known
for frequent flooding due to its often -restricted floodplain, and development in Wake County has
increased storm runoff resulting in flooding." We do not need a quarry given the flooding issues.
Page 19 indicates "The economic importance of the county has grown since the middle twentieth
century. Much of this growth has occurred in the public sector, which provides statewide
6/Jan/2021 (N. Lew) Page 4 of 5

Foxcroft Lake
A significant feature on the Odd Fellows and one of many
Reason why the Triangle Quarry expansion permit should be denied
government services, and as a result of the success of the Research Triangle Park, a regionally
important center for technology -based industries (Powell 1989)." 4 All the more reason we
need to protect Umstead State Park, preserve the Odd Fellows, and NOT have a quarry on Odd
Fellows. With increased population comes an increased need for Umstead State Park given the
ever -decreasing forested recreation space. A logical addition to Umstead State Park is Odd
Fellows, especially since they are physically linked by Foxcroft Lake, a lake that qualifies in full
for NRHP. A valid market value offer of $6.4 million has been made to purchase Odd Fellows
for incorporation into Umstead State Park. Yes, we need quarry material. But there are two other
quarries in the area (one off of Duraleigh and one off of Westgate) both of which have recently
expanded. Also, Wake Stone has said that they have 200 years of quarrying remaining at their
Knightdale location and they already OWN (private land) about 400 or so acres at the Knightdale
Quarry location, plenty of land on which to expand. Wake Stone does not need to quarry a small
piece of land that is adjacent to a state park, deeded to the 4 public owners of the airport, and one
on which a $6.4 million offer has been made to purchase for incorporation into the state park.
Page 20 says `By 1946 1,223 acres had been acquired by RDUAA (No Author 2020a), and it has
been, and continues to be, an important factor in the growth of the Research Triangle region."
This statement demonstrates the bias of the report writer as he concludes that RDU is an
"important factor in the growth of the Research Triangle region" without consideration of the
importance of the neighboring William B. Umstead State Park (which existed PRIOR to the
airport). The report author mentions the 1995 status of The William B. Umstead State Park in
that it has "local significance as a recreational demonstration area..." This 25-year-old
assessment is outdated and does not account for the current state, regional and national
significance of the Umstead State Park area, including the Old Reedy Creek greenway recreation
corridor. Our area has grown immensely, so the importance and usage of both the airport and
Umstead State Park have also both grown. The proximity of Umstead State Park and the
recreation and tourism opportunities it offers to this metro area is also an important factor in the
growth of the Research Triangle region. This fact must not be ignored.
Page 28 is an example of the report focusing on the airport without consideration for Umstead
State Park. "The Raleigh Durham International Airport is governed by the Raleigh Durham
Airport Authority which was established in 1939. An eight -member board manages the airport's
day-to-day operations. Two board members are each appointed by Wake County, the city of
Raleigh, Durham County, and the city of Durham. The number of passengers served has
increased 55 percent since 2011. To address this growth, the airport plans to invest over 2 billion
dollars in the next 10 years on facility expansion (No Author 2020b)." 4 What about the
growth in Usage of Umstead State Park? What about the very high usage of the historic African -
American entrance and the Old Reedy Creek entrance, both of which are directly (and
negatively) affected by Wake Stone's quarry efforts?
As supported by the multitude of reasons in this writeup, not only must the conclusion that
"clearance to proceed is recommended" in the "Archaeological Survey of Odd Fellows" be
denied, but the entire Triangle Quarry Permit Expansion Permit must be denied.
6/Jan/2021 (N. Lew) Page 5 of 5