20210604_J-Spooner_Buffer

From:
Jean Spooner
To:
Wrenn. Brian L
Cc:
Garrison, Gabriela; john ellis(obgws.gov; Miller, David; Smith, Dannv; Wojoski, Paul A; Nicholson, John A.;
Masemore, Sushma; Wilson, Reid; Michael, Jeff; Patterson, Dwayne; Eudy. Ken; contactaov; Strong, Brian;
Letchworth, Scott; cassie.gavin; Hwa Huang; cynthia.satterfield()sierraclub.org; Matthew Starr;
heatherCabsou nd rivers. org
Subject:
[External] Neuse Buffer (Final) Authorizations must be required for proposed new rock pit next to Umstead State
Park
Date:
Friday, June 4, 2021 5:28:49 PM
Attachments:
Umstead Coalition-Neuse Buffer Authorizations must be completed prior to Permit Decision, Public Comment.odf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Mr. Wrenn:
Please accept and include this letter, with the attached, as part of the Public Comments in evaluating
the 92-10 Mining Permit Application. The Permit Application must be denied because the proposed
new mining operation would have a significant adverse effect upon the purposes of a William B.
Umstead State Park and the Old Reedy Creek Recreational Area per N.C. Gen. Stat. §74-5(d)(5).
William B. Umstead State Park, including its forest landscape, is listed on the National Register of
Historic Places and one of the most visited NC State Parks.
DEQ-DEMLR should issue an Additional Information (ADI) Request Letter to ask for the FINAL
and complete Neuse Buffer Authorization for the fence, bridge, and retaining walls, or immediately
denial Permit Application. (unless you are planning to issue an immediate permit application denial).
See attached for supporting materials.
Thanks for supporting William B. Umstead State Park!
Dr. Jean Spooner, Chair
The Umstead Coalition
PO Box 10654
Raleigh, NC 27605
cell 919-602-0049
This email has been checked for viruses by Avast antivirus software.
www.avast.com

t` The Umstead Coalition
rn�' P.O. Box 10654
Umstead Raleigh, NC 27605-0654
Coalition [phone]
http://umsteadcoalition.org facebook.com/umsteadcoalition meetup.com/umsteadcoalition
B. W. Wells Association New Hope Audubon Society Orange -Chatham Group Sierra Club
Capital Group Sierra Club NC Herpetological Society Raleigh Ski and Outing Club, Inc.
Eno River Association NC League Conservation Voters Foundation Rockingham Naturalist's Club
Friends of State Parks NC Wildlife Federation Friends of Jockey's Ridge
Headwaters Group Sierra Club NC Native Plant Society Sound Rivers
Wake Audubon Society
June 1, 2021
Mr. Brian Wrenn, Director
Division of Energy, Mineral and Land Resources
N.C. Department of Environmental Quality
1612 Mail Service Center
Raleigh, N.C. 27699-1612
Re: Neuse Buffer Authorizations must be required for fence, retaining walls, bridge— INCOMPLETE Application
Please accept and include this letter as part of the Public Comments in evaluating the 92-10 Mining Permit Application.
The Permit Application must be denied because the proposed new mining operation would have a significant adverse
effect upon the purposes of a William B. Umstead State Park and the Old Reedy Creek Recreational Area per N.C. Gen.
Stat. §74-5(d)(5). William B. Umstead State Park, including its forest landscape, is listed on the National Register of
Historic Places and one of the most visited NC State Parks.
DEQ-DEMLR should issue an Additional Information (ADI) Request Letter to ask for the FINAL and complete Neuse
Buffer Authorization for the fence, bridge, and retaining walls, or immediately denial Permit Application
Wake Stone Corporation provided misleading information on their proposed stream buffers by implying they are
proposing "100-foot stream buffers." This is not the case. In examination of the Mining Permit Application and Site
Plans, the "100-foot buffer" has no resemblance to what the public, nor most agencies, consider a "buffer" because Wake
Stone is proposing "unexcavated buffers" which allow deforestation, grading, stockpiling, roads and quarry
trucking, fill on steep stream slopes, retaining walls, heavy noisy surface mining equipment, fencing, etc. (a
deforested, disturbed mess). To add to this insult, Wake Stone asked DEQ to move their "buffers" from "top of bank" to
centerline of Crabtree Creek— which also substantially decreases the buffer width (Crabtree Creek is about 60-feet wide).
Effectively, the Neuse Buffers are the only remaining stream buffers separating two 300-feet plus deep mining pits, as
proposed by the Wake Stone's Mining Permit Application. Neuse Buffers alone on Crabtree Creek steep slopes are
unlikely to be sufficient to prevent adverse impacts on Crabtree Creek and William B. Umstead State Park. The proposed
substantial reduction of Stream buffers on BOTH the south and north side of Crabtree Creek makes compliance with the
Neuse Buffer Rules critical.
The Mining Permit Application is incomplete. Among the missing components are the (final)) Neuse Buffer
Authorizations for:
• Fence and forest removal across Foxcroft Lake affecting more than 1.5 acres of wetlands
• Fence and forest removal across major tributaries to Crabtree Creek
• Approximately 1,700 linear feet of forest removal with massive retaining walls along steep slopes Crabtree Creek to
hold back new fill to widen the pit perimeter road (associated with the proposed bridge across Crabtree Creek)
• Massive 60-foot wide bridge proposed across Crabtree Creek just upstream (and in the viewscape of) William B.
Umstead State Park, with its proposed temporary and permanent destruction of Neuse Buffers. A Neuse Buffer
Authorization is under Appeal contending that the Application failed to provide justifications and alternatives for the
required avoidance, minimization and BMPS. The final location of the proposed bridge impacts ALL the other
aspects of the proposed new pit.
r The Umstead Coalition v
Dedicated to preserving the natural integrity of W.B. Umstead State Park and the Richland Creek Corridor

Failure by Wake Stone to obtain the Neuse Buffer Authorizations (and in most of these buffer impacted, not even apply)
means that full impacts to the Neuse River buffers are not known, nor evaluated and the Mining Permit Application
should be denied.
Why are the Neuse Buffers Rules so vital in this project evaluation? As highlighted below, the Neuse Buffers are
essentially the last line of protective defense for Crabtree Creek and William B. Umstead State Park. In the current
Application, Wake Stone Corporation is requesting much of their remaining stream buffers outside the Neuse Buffers to
be destroyed, as well as some of the Neuse Buffers themselves. Tragically and in violation of public trust and promises,
the stream buffers Wake Stone Corporation committed to preserving in 1981- would be destroyed if permit Application is
approved.
William B. Umstead State Park "receives" Crabtree Creek downstream of the quarry operations. Stream buffers are vital
to the stream habitat, stream water quality, and connected wildlife corridor.
The Neuse River Waterdog salamander (Necturus lewisi) has been documented within William B .Umstead State Park
in Crabtree Creek (2004, as well as earlier). The Neuse River Waterdog salamander was found as recently, within the last
3 months (week of March 7, 2021) in Crabtree Creek. The firm RK&K under contract with NCDOT found the Neuse
River waterdog salamander near Capital Boulevard, downstream of William B. Umstead State Park. It is reasonable to
assume that the Neuse River waterdog salamander still lives in Crabtree Creek within William B. Umstead State Park.
Sediment from unstable stream banks and direct discharges have been an issue with the existing Triangle Quarry.
Protection of the stream buffers is critical.
Because of its limited range (only found in the Neuse and Tar River Basins, NC) and sensitivity to pollution and habitat
alteration, the Neuse River waterdog is listed as a species of special concern by the state of NC (listed in 1990). Its
current Federal status per US Fish and Wildlife website is "At -risk species."
(https://www.fws.gov/southeast/wildlife/amphibians/neuse-river-waterdog/). The Fish and Wildlife Service has proposed
the Neuse River waterdog salamander be listed as "threatened species."
Per Wake Stone Corporation's application, the stream buffers are proposed to be severely reduced:
South side of Crabtree Creek - stream reach on the northwest side of the existing quarry pit:
• Clearing limit just beyond the 50ft Neuse Buffers
• All buffers within the "clearing areas" reclassified from undisturbed to "unexcavated" to allow for back fill on the
steep stream banks with retaining walls confining Crabtree Creek its 100-year flood level, pit perimeter roads,
clearing, etc. Neuse Buffers would be the only remaining protections
• Measurement of Site Plan "buffers" from the `nonsensical' centerline of Crabtree Creek (which makes the 50ft of the
Neuse Buffers the only stream buffer protection remaining on this site
• A small portion of the Crabtree Creek currently has a retaining wall for the pit perimeter road at the 50ft Neuse
Buffer limit. This corresponds to the stream reach where Wake Stone Corporation's blasting caused a massive
streambank slide and the blockage of 90 percent of Crabtree Creek (1992). Sadly, the streambank in this area still
remains mostly treeless and with a narrow stream buffer on steep stream bank.
• —1,700 linear feet of this stream reach is proposed to have massive retaining walls installed just at the 50ft Neuse
Buffer limits; followed by backfill of Crabtree Creek's steep stream bank behind the retaining walls to enable the
current pit perimeter roads to be expanded from their current —18ft width to 60plus ft wide. These proposed
retaining walls are up to 30 feet tall and would confine the stream to the 100-year flood level.
• Temporary impacts to Zone 1 and Zone 2 of Neuse Buffers by installation on the —1,700 linear feet of the retaining
wall (see below)
• Temporary and permanent impacts to Zone 1 and Zone 2 of Neuse Buffers by the proposed massive 60-foot wide
bridge over Crabtree Creek.
• Bottom line: the submitted application leaves little to no effective buffers outside Neuse Buffer and substantial
temporary and permanent destruction of Neuse Buffers — a Neuse Buffer Authorization must be required for the
retaining walls and bridge
r The Umstead Coalition v
Dedicated to preserving the natural integrity of W.B. Umstead State Park and the Richland Creek Corridor

South side of Crabtree Creek- stream reach on the northeast side of existing quarry pit (north side of this reach is
William B. Umstead State Park):
• Measurement of Site Plan "buffers" from the `nonsensical' centerline of Crabtree Creek
• Deforestation and increase the pit perimeter/haul roads by destroying the existing buffer. This decrease resulting
from the (ridiculous) "assertion" that the stream buffers should be measured from the centerline of Crabtree Creek (a
loss of up to 50ft of buffer width as compared to current buffer).
• Change the "undisturbed buffers" to "unexcavated buffers." Unexcavated buffers can be devastating and include
deforestation, sediment controls structures, roads, crushers, stock piles, etc. This is direct violation of the Final
Decision of the Mining Commission dated April 3, 1981 that states "The 250' buffer area on the northern boundary
and the 100' buffer area on the eastern boundary of Wake Stone's property is considered by the Commission to
permanent buffer zone."
North side of Crabtree Creek — stream reach for proposed new quarry pit:
• Measurement of Site Plan "buffers" from the `nonsensical' centerline of Crabtree Creek
• Buffers classified as "unexcavated" to allow for forest removal and back fill on the steep stream banks, pit perimeter
roads, clearing, fencing, etc. Neuse Buffers would be the only remaining protections
• Temporary and permanent impacts to Zone 1 and Zone 2 of Neuse Buffers by the proposed massive 60-foot wide
bridge over Crabtree Creek.
• Foxcroft Lake would have only the 50 feet Neuse buffer for "protection" from the pit perimeter road and pit drop-off.
• Deforestation within Zone 2 of the steep Crabtree Creek Neuse Buffers for the security fence at tributary crossings
• 25-feet wide deforestation along the fence crossing Foxcroft Lake. The upper portion of Foxcroft Lake is within
William B. Umstead State. The outflow is into Crabtree Creek just upsteam of William B. Umstead State Park (yup,
it's a loop —water flows from the Park into Foxcroft Lake, then to Crabtree Creek and right back to our Park).
• 25-ft deforestation along the fence crossing of streams and wetlands on the Odd Fellows tract
There are essentially NO stream buffer protections proposed by Wake Stone Corporation on either side of Crabtree Creek
where they have, or proposed pit perimeters — beyond what should be required by the Neuse Buffer Rules. That makes
the Neuse Buffers the "last stand" for protections along both sides of Crabtree Creek. Crabtree Creek would be
"suspended" above two 400-ft deep rock pits, with only remaining 50ft (or less) Neuse Stream buffers on both sides of
Crabtree Creek.
If the permit is not denied immediately, then DEQ-DEMLR should issue an Additional Information (ADI) Request Letter
to ask for the FINAL and complete Neuse Buffer Authorizations for the bridge, fence, and retaining walls. The following
highlights why each of these must have submitted Neuse Buffer Applications and final Neuse Buffer Authorizations per
the Neuse Buffer Rules:
Massive BRIDGE - 60-foot wide (width of 4 highway lanes) bridge over Crabtree Creek just upstream and in
the VIEWSCAPE of William B. Umstead State Park for massive and noisy (and extremely large, 75yd-3, quarry
trucks. There are alternatives for avoidance, minimization, and appropriate BMPS). There was a Neuse Buffer
Authorization issued, with almost no avoidance or minimization justification in the Application; the
Authorization is in the Appeal process. The Appeal must be allowed to proceed to allow full compliance with the
Neuse Buffer Rules.
• It would NOT be appropriate for DEQ-Mining to issue a Decision of the Mining Permit which could
then put an unfair and extreme bias on the outcome of the Appeal - to the detriment of William B.
Umstead State Park! The Appeal needs to be allowed to have a fair decision process.
2. FENCE and deforestation across Foxcroft Lake (which would impact more than and 1.5 acre of
wetlands) and crossing tributaries to Crabtree Creek. The fence and removal of forest (25-foot wide swath along
fence route) on the Odd Fellows Tract WOULD have a significant impact on the Neuse Buffers. Wake Stone
should be required to obtain a Neuse Buffer Authorization because.
• 25-foot wide deforestation is proposed (I Oft on outside side, 15 feet on the other side) in the swath for
the fence.
r The Umstead Coalition v
Dedicated to preserving the natural integrity of W.B. Umstead State Park and the Richland Creek Corridor

• Trees would be removed in Zone 1 at the Foxcroft Lake fence crossing. Removal of forest vegetation
WOULD occur. See below for a portion of Wake Stone's submitted Site Plan showing fence crossing, as
well as photo of crossing location at Foxcroft Lake. 15A NCAC 02B .0714 (11)(f)(iii) Table of Uses.
Fence is therefore only "Allowable upon Authorization" (Wake Stone has highlighted incorrect
column in the Table of Uses)
a) See photos attached. Forest trees would be removed in Zones 1 and 2 to create a 25-foot wide
swath along fence.
b) The upper portion of Foxcroft Lake is within William B. Umstead State Park and a popular area
for Park visitors. A fence crossing Foxcroft Lake would cause great environmental harm to
Foxcroft Lake/wetlands due to forest tree removal and the backup of debris caused by such a
fence- changing the wetland hydrology and habitat.
c) The source of water to Foxcroft Lake is William B. Umstead State Park. Foxcroft Lake drains to
Crabtree Creek just upstream of William B. Umstead State Park. Protection of Foxcroft Lake
wetland and its riparian buffers is essential to not only protect the wetland habitat, but the water
quality of Crabtree Creek within our State Park and the protected Neuse River waterdog.
• Foxcroft Lake/ wetlands are protected under 15A NCAC 02J .0506 (see 15A NCAC 02B .0714 (3)(c)).
Foxcroft Lake is more than 1.5 acres (e.g., well over total impacts of one -tenth of one acre of Class WL
wetland.
• Trees would be removed in Zone 1 for any crossing of tributaries to Crabtree Creek and any crossing of
Crabtree Creek itself. RDUAA's fence proposal called for fencing with 30-foot deforestation path
around the entire perimeter, including along Crabtree Creek
1,700 linear feet of massive RETAINING WALLS along Crabtree Creek. These are up to 30 ft tall, made up
of stacks of blocks of concrete 2x3x6' each weighing 4,200 lbs. These retaining walls are proposed to be used to
DECREASE the existing stream buffer on the existing quarry site by a substantial amount and then fill in the
steep Crabtree Creek riparian buffer behind them to widen the pit perimeter roads from —18 feet wide to 60ft
wide to accommodate the massive quarry trucks on the bridge. The result is that the massive retaining walls
would be built to confine Crabtree creek at the approximately 100-year flood level. The construction of these
retaining walls will severely impact the trees in Zone 1 (inner 30 feet from Crabtree Creek riparian area) due to
digging and equipment necessary to construct the footings and install the retaining walls. Wake Stone should be
required to obtain a Neuse Buffer Authorization and, if approved, provide mitigation. Note: if the bridge were
moved upstream away from the Park and closer to I-40, these retaining walls would not be necessary.
• Per 15A NCAC 02B .0714 (3)(g) "No new clearing, grading or development shall take place nor shall
any new building permits be issued in violation of this Rule."
• The retaining walls are —1,700 linear feet (e.g., far exceed 300 linear feet impacts to perennial streams
and therefore require mitigation, as well as Authorizations.
DEQ-DEMLR should require Application(s) for these the Neuse Buffer Authorizations. NO mining permit decision
should be made without. The Neuse Buffer Rules need to be followed; the law requires AVOIDANCE,
MINIMIZATION, and BMPS. This process should not be short-circuited - avoidance, no minimization, and
inadequate BMPS MUST be allowed to be fully complied per the law.
Of course, Permit denial would not require Neuse Buffer Authorizations. That is the best path to prevent adverse
effects on William B. Umstead State Park, its connected recreational corridor, and private residences.
NC Division of Parks and Recreation (DPR) requested DENIAL of the proposed permit modification (letter dated
February 12, 2021) due to the combined effects to the park of "noise, sedimentation and water quality, dust and air
quality, traffic, habitat loss, blasting vibrations, and loss of park expansion opportunity."
The evidence is strong for Permit Denial. DEQ-DEMLR must take seriously the serious concerns raised by NC Division
of Parks and Recreation and the public.
r The Umstead Coalition v
Dedicated to preserving the natural integrity of W.B. Umstead State Park and the Richland Creek Corridor 4

NC DEQ must DENY the proposed Mining Permit for a new mine on the Odd Fellows Site because "the proposed new
quarry operations would have an significant adverse effect upon the purposes of a publically owned park, forest, or
recreational area" including William B. Umstead State Park and it's connected Old Reedy Creek Road recreational
corridors (per G.S. Chapter 74-Article 7, 74-51(d) of the 1971 Mining Act).
�e�
Dr. Jean Spooner, Chair
CC:
John Nicholson, Interim Secretary for Environment, NC DEQ
Sushma Masemore, Assistant Secretary for the Environment, NC DEQ
Paul Wojoski, Supervisor, NC Division of Water Resources -NC DEQ
Danny Smith, Director, NC Division of Water Resources -NC DEQ
Reid Wilson, Secretary, NC Department of Natural and Cultural Resources (NCR)
Jeff Michael, Deputy Secretary, NCR
Dwayne Patterson, Director, NC Division of Parks and Recreation (NCR-DPR)
The Honorable Governor Roy Cooper
Ken Eudy, Office of Governor Roy Cooper
David D. Miller, Mining Engineer, DEQ-DEMLR
Brian Strong, Deputy Director, Planning and Natural Resources, NCR-DPR
Scott Letchworth, Park Superintendent, William B. Umstead State Park, NCR-DPR
Cassie Gavin, Senior Director of Government Relations, N.C. Sierra Club
Cynthia Satterfield, Acting State Director, N.C. Sierra Club
Hwa Huang, Group Chair, Capital Group - N.C. Sierra Club
Matthew Starr, Upper Neuse Riverkeeper, Sound Rivers
Heather Jacobs Deck, Executive Director, Neuse Riverkeeper
Gabriela Garrison, Eastern Piedmont Coordinator, Habitat Conservation, NC Wildlife Resources Commission
John Ellis, US Fish and Wildlife Service
Attachments:
Fence. Multiple fence locations where forest removal in the Neuse Buffers is depicted on the Mining Permit Site Plans.
25-ft wide deforestation within stream and wetland buffers. Wetlands impacted. Photos and enlargements of submitted
Site Plan.
Bridge and retaining wall locations. Google maps and submitted plans.
r The Umstead Coalition v
Dedicated to preserving the natural integrity of W.B. Umstead State Park and the Richland Creek Corridor 5

Fence, plus 25-foot wide forest removal is
proposed in at least 4 Neuse Riparian Buffer
Areas. Neuse Buffer Authorization required

Fence location crossing Foxcroft Lake (wetlands) and tributary to
Crabtree Creek. Source Page 3 of 11, Wake Stone Site Plan, Permit
Application.
Ax xx I Fence symbol on plan Fence, plus 25' wide forest
r moval inside NRB
Proposed ermit Boundary
William B. Umstead State Park r
.8440 J 1 ` '.100'
raa7L exc aka ( R
_ Lat:N358438
I
ED BUre.d+ts<rx-FFi Lo :W78. 1 I
25 FOOT UNDI57URBER l l
,t1 wcNand Fling, 222 5 6Stream 6
1 ,R,/0.14 Ac,
q --_ 245 Linear Feet �
of j I 5U NRiver
fit, p � f \ Hi�ariarZ'8uffer� _ � � �
5q' EUFFFR FROM STRFAM ~
Sd i7VPFl:e FROM inirrg Permit Sdpwlted) `
Dashed Line D notes Perimeter (A �
Proposed Pit d Perimeter Road
1.3 Acres Foxcroft \ stream 1 J \ ` .
50' Neuse Hiv �
303-linear Feet Riparian Bu,*
J Dashed Line Denotes
/ j \ open Watee 50' BUiTTR FROM STREAM � \
Proposed Clearing Limits 1` es,eotsSq,Ft./1,51k. — (NnngNrmirSripuiamrn
band Fringe--
- f ( \ 62225q. rt.ai—
\ �. \ ✓ f'Y BUITFA FRnM
d
TCyMPQRA 2Y w,eetland j�
` T1 MI RA'In /F3ASNk3 / / i213Sq.
At ♦♦
�
Observo wellJ ,iti/� �� ! ,r �`� ♦`�
\ Q 1 d �a' Cut RT / /•5�s�'� ♦ f
r ,,
•n A,� Stream 2
/1 \ - 252Unear Fee/

tIN35.8408 _ / �i
10— j 781
50 BUFFER FRO ♦ J / �'
g Permit Stipulated
\ \� \\\ ♦ 50' Neuse Rive Rive
u
��� = ` 50 ease �f
\\ l sari n ff ' � � , __
,�— ` farms
p
a
\1 �
.7798 J

t tm
4-1

Foxcroft Lake at proposed fence crossing. Taken
from William B. Umstead State Park., April 8, 2020
. . . . . . . . . . . .

Proposed Bridge Over Crabtree Creek
Retaining Walls to fill Crabtree Steambanks
and widen existing pit perimeter road (to
accommodate proposed location of bridge

Bridge and Retaining wall proposed locations per Submitted "Wall Drawings" submitted as part of Mining
Permit Application Solid black lines are bridge and retaining walls proposed

Google Earth of Existing Wake Stone Corp Triangle quarry looking Southeast. Pit Perimeter roads are
white areas around pit.
Crabtree Creek Foxcroft Lake

Crabtree Creek is highlighted in BLUE. Approximate location of bridge and retaining walls in mr-u.
Approximate fill of Crabtree Creek streambanks to widen existing pit perimeter roads on the south side of
Crabtree Creek in WHITE. Approximate location of William B. Umstead State Park boundary is GREEN.
Crabtree Creek flows from Crabtree Lake (top of photo) to William B. Umstead State Park (right and
bottom of photo).: - .4 1 ; .� 4,:���y►;:.h -a�
a
R:

"Iftwd
Cohedun
Phl
Mal�rl.l Nome
ColorI
IIWM)
(P.f)
fd4W
WwFitl
.
120
0
30
Res Ml
.
120
250
28
PwR
.
13D
1W
38
Crystalline Rack
.
145
0
45
Reinforced Fill
121)
0
30
100 year flood
elevation: —261'
ry
.1M .I Rn .1M
Retaining wall, just at Neuse Buffer 50'
from top of bank. Essentially holding
back all waters above 100-year flood.
Steam will no longer be able to access
its historic floodplain
1.54
23 #t
,r
Typical page from Retaining Wall Plan
inform, Our Annotations in Red were
added. Plans show retaining wall up to
-30ft tall.
Blue=existing soil
Grey = proposed back fill to expand
width of existing retaining walls
7ftn .14n .107 .,,n .11r1 .11n .Inn .an .An .7n .rin .Fn An .3r .7n .1n n
nq
Wakestane Quarry Wail
Giobal Stability
rt Wakestone Quarry
Wall
An a•
AKA
A*J N.,,�.
6235.24.002
_
wm.r
S&ME
Sta 3+00 Wall
5Akr" Wakestone.slmd
°i" 315/2020

Typical Crabtree Creek section where proposal to build new retaining wall to
just outside 50' Neuse Buffer, filling in stream bank behind to build bridge and
widen pit perimeter roads. Photo taken from navigable waters of Crabtree
Creek. Digging for footing and construction will require BIG, wide equipment
(e.g., trackhoe) and create forest removal in Zone 2, sever impact to forest roots
and viability in Zone 1. Note existing retaining wall which has pit perimeter road
behind. Photo taken from navigable waters of Crabtree Creek.