20211021_DNCR_Piedomont_Comments

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
October 21, 2021
MEMORANDUM
W
FROM
SUBJECT:
Brenda M. Harris
Mining Program Secretary
Land Quality Section
Ramona BartosPAI�+pa"u.UUx.
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
brenda.harris&ncdenr. og_v
Mining Permit Application for Piedmont Lithium Carolinas, Inc., Carolina Lithium Project,
Gaston County, ER 18-0800
Thank you for your letter of September 3, 2020, concerning the above project. We have conducted a review
of the project and offer the following comments. We apologize for the delay in our response and any
inconvenience it may have caused. For future submissions, please submit electronically to the
Environmental.Review&ncdcr.gov inbox.
We note that the project area covered by this mining permit application incudes an area that was previously
reviewed by this office for Section 106 compliance purposes due to the project sponsor, Piedmont Lithium,
Inc., applying for a Section 404 of the Clean Water Act permit with the U.S. Army Corps of Engineers
(Corps Action ID Number: SAW-2018-01129). This original project area was subject to intensive
archaeological survey between 2018 and 2019 and our office concurred that no known archaeological sites
listed in or eligible for listing in the National Register of Historic Places (NRHP) would be adversely
impacted by the proposed project.
The area included in this most recent review provided by your office appears to include an additional
1,000+ acres, mostly west and north of the area that was previously reviewed and surveyed. We note that
there are five newly recorded archaeological sites (31 GS398-402) within the recently added portion of the
project area, including two cemeteries. None of these five newly recorded sites have an NRHP
determination associated with them. Based on when these sites were recorded, in August 2021, the project
area was presumably recently surveyed for the Piedmont Lithium mine project.
We request to review the findings of any such survey in the form of a technical report that meets the Office
of State Archaeology's Archaeological Standards and Guidelines for Background Research, Field
Methodologies, Technical Reports, and Curation, which can be found online at: hlt2s:Hfiles.nc.gov/dncr-
arch/OSA Guidelines Dec20l7.Ddf
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

ER 18-0800, October 21, Page 2 of 2
Please note that cemeteries are protected under NC General Statutes Chapter 14-148 and 14-149, and are
afforded consideration under Chapter 65. If unmarked human skeletal remains are encountered during
construction, the provisions of North Carolina General Statute Chapter 70, Article 3 apply. Construction
activities should immediately cease and the county medical examiner should be contacted.
We are unable to accurately assess impacts to historic properties within the proposed Area of Potential
Effect. We recommend a historic architecture survey of properties 50 years of age or older that are within
or directly adjacent to the APE. The survey should be conducted by a Secretary of the Interior Qualified
Architectural Historian and a report submitted to us for review and comment.
To ensure timely review, review our Historic Structure Survey Report (HSSR) Standards for guidance on
report requirements (hM2s://www.ncdcr.gov/state-historic-preservation-office/environmental-
review/historic-structure-survey-report-standards). Missing deliverables will cause a delay in processing.
Contact Katie Harville, Environmental Review Specialist, katie.harville(a),ncdcr.gov, with any questions
you may have regarding deliverables or the survey requirements.
These comments are made in accord with G.S. 121-12(a) and Executive Order XVI. If you have questions
regarding them, please contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or [e-mail]. In all future communication concerning this project, please cite the
above -referenced tracking number.
Cc: Amanda Jones, USACE amanda.: o� nesgusace.army.mil
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898