20211202_Umstead_Coalition

The Umstead Coalition
The P.O. Box 10654
Umstead Raleigh, NC 27605-0654
Coalition [phone]
http://umsteadcoalition.org facebook.com/umsteadcoalition meetup.com/umsteadcoalition
December 2, 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
Subject: Major VISUAL and NOISE impact — CLEAR line of sight from significant acreage within William B.
Umstead State Park— DENY permit application due to "Significant Adverse Effects on the purposes of a publically
owned park, forest, or recreational area" (per G.S. Chapter 74-Article 7, 74-51(d) of the 1971 Mining Act).
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, the Old Reedy Creek Recreational Area, private residences,
and public infrastructures.
In May, The Umstead Coalition submitted photos and topographic information to DEQ that clearly showed the proposed
quarry would be visible from William B. Umstead State Park. DEQ-Mining did follow-up with an Additional Information
(ADI) request to Wake Stone to provide renderings. In a recent submission to DEQ-Mining, Wake Stone submitted their
(so-called) "renderings." The renderings provided by Wake Stone are incomplete and misleading. They were nothing
more than selected existing photos with over -imposed image of walls. Moreover, Wake Stone also failed to provide the
photo view locations requested by DEQ. Furthermore, Wake Stone mislabeled their proposed wall types.
The images submitted by Wake Stone are misleading because the natural undisturbed forest and natural topography
remains visible —unrealistic due to the fact the hills, stream, vegetation are proposed to be destroyed. The responses from
the applicant do not reflect the real impact of the proposed project, as they do not show the proposed quarry impacts. This
is illogical as the wall is proposed by the applicant to block the sight and sounds of the crushed rock quarry from invading
into a state park and effecting a nearby residence. Wake Stone has failed to show that their wall and 25ft buffer would
meet this requirement-, which we believe, would fail to do so.
To confirm the proposed mining operation would be clearly visible from within William B. Umstead State Park, The
Umstead Coalition contracted with a StructionLab to provide renderings. Our renderings show both the wall (and fence)
and the site plans proposed by the applicant in a true topo scale allowing DEQ and the public to see what the applicant
proposes. StructionLab, using actual topography of the site, created our Renderings and presentation. Their work shows a
rendered before and after view, and shows the applicant site plan included in each image. The images are to scale and
respectful of the topography. The actual trees are conceptual as there is not current capability to render actual trees. See
below for summary of data sources used.
At our request, StructionLab has provided a public link with sliders to illustrate the current and proposed site conditions
and views:
https:Hsway.office.com/RkHoCu3Kwa69U6rw?ref=Link
V The Umstead Coalition v
Dedicated to preserving the natural integrity of W.B. Umstead State Park and the Richland Creek Corridor

Our previously submitted photos taken within William B. Umstead State Park, topographical maps, and these professional
renderings submitted with this letter confirm that a significant acreage within our Park would be severely impact by
VISUAL view of the proposed quarry pit, quarry operations, and hundreds of massive quarry trucks per day traveling over
Crabtree Creek just upstream of our State Park.
This is unacceptable, disaster for a NC State Park and a Park listed under the National Register of Historic Places, in large
part due to its "forest landscape." The Park and the Public Interest in it were fiercely fought for protection in the 1981
Permit for the quarry now on the south side of Crabtree Creek. The public and the Park relied upon the 50-year Sunset
Clause and larger buffers (as re -affirmed by the recent letter from the NC Division of Parks and Recreation to DEQ.
The proposed buffers are insufficient. The proposal is only 25 feet buffer from William B. Umstead State Park a private
residence and Old Reedy Creek Road/East Coast Greenway, only 50 feet "buffer" along Foxcroft Lake and Crabtree
Creek, then pit perimeter road and drop-off. The forest and hills on the Odd Fellows tract would be devastated. The 300-
400 ft. deep pit (and its noisy industrial operations) would be in close and clear view of a significant acreage within
William B. Umstead State Park. Concurrently, the loss of the hills and forest on the Odd Fellows tract will eliminate the
current noise mitigation from 1-40 into the Park. In addition, the massive quarry trucks on the proposed bridge over
Crabtree Creek would be visual, carrying NOISE well into William B. Umstead State Park. A triple whammy!
Because the steep rise in topography within William B. Umstead State Park above Foxcroft Lake and the clear view
across Foxcroft Lake, it is NOT feasible to obstruct the view (and noise penetration) from the Park all the way to the
interior of the pit or the quarry trucks on the bridge. And, the close proximity to the industrial quarry operations around
and in the pit, as well as the bridge over Crabtree Creek will create a devastating (unnatural, blasting, rocks crashing into
metal truck beds, truck engines, etc.) detrimental level of noise for our Park users.
The renderings we provide in this Public Comment letter allow DEQ and the public to see clearly what the applicant has
proposed, it is obvious to us that the proposal before DEQ on the expansion of the Wake Stone Quarry onto the
Oddfellows Tract will have significant adverse effects on William B. Umstead State Park, a private residence, the East
Coast Greenway, Crabtree Creek, a vital wildlife corridor and more.
In fact the renderings make clear that the applicant seeks DEQ approve to dig too large a quarry for too small a site. The
buffers proposed are woefully insufficient and incompatible for such an intense use next to a State Park.
Both the Mining Act of 1971, DEQ regulations on mining and the Mining permit Application, speak to the need to shield
proposed quarry operations from public view. The Mining Act of 1971 and the Rules approved by DEQ clearly give
grounds for denial based upon direct visual and noise impacts to a Park and Recreational Area. For example, a proposed
mine with views from the Appalachian Trail was denied. Reference of the Law and regulations that are the basis for
denial can be found in the Mining Act of 1971 and 15A NCAC 05B .0105 CONDITIONS WHICH MAY BE
INCLUDED IN PERMIT, including:
(4) That the operation will constitute a direct and substantial physical hazard to public health and safety
or to a neighboring dwelling house, school, church, hospital, commercial or industrial building, public road or
other public property, excluding matters relating to use of a public road;
(5) That the operation will have a significantly adverse effect on the purposes of a publicly owned park,
forest or recreation area;
(7) That the applicant or any parent, subsidiary, or other affiliate of the applicant or parent has not been
in substantial compliance with this Article, rules adopted under this Article, or other laws or rules of this
State for the protection of the environment or has not corrected all violations that the applicant or any parent,
subsidiary, or other affiliate of the applicant or parent may have committed under this
These conditions may, among others, include a requirement of visual screening, vegetative or otherwise, so
as to screen the view of the operation from public highways, public parks, or residential areas, where the
Department finds screening to be feasible and desirable. Violation of any conditions of the permit shall be
treated as a violation of this Article and shall constitute a basis for suspension or revocation of the permit.
VThe Umstead Coalition v
Dedicated to preserving the natural integrity of W.B. Umstead State Park and the Richland Creek Corridor

The revised plan submitted by the Applicant on August 12, 2021 fails to meet the requirements of the law. Our renderings
show clearly that the applicant's proposal to put a new pit and quarry operations only 25ft from William B Umstead State
Park, will expose park visitors to all of the sights and sounds of mining. The use of concrete (or PVC) walls are at best a
poor substitute for forested buffers that are and have always been required at this site.
Further, a pit close to the park and the nearby residence would place the public at risk for personal injury from the effects
of blasting so close to a park and residence. The applicant has failed to provide any justification or evidence, as required
by the law and the application, that they can safely blast in such close proximity.
Based on this alone the permit modification request must be denied outright. What they propose is inconsistent with the
original 1981 mining application approval, the law and DEQ regulations. The proposal places the public at serious risk of
injury to both persons and property, and proposes a significant adverse effect on the public purposes of park or forest.
The renderings we submit here as part of the Public Comments clearly show there is no feasible way to provide visual
screening or noise screening to the proposed new quarry pit and its operations on the north side of Crabtree Creek. The
Permit Application must be denied.
Dr. Jean Spooner, Chair
CC:
The Honorable Governor Roy Cooper
David D. Miller, Mining Engineer, DEQ-DEMLR
Elizabeth Biser, Secretary, NC DEQ
Sushma Masemore, Deputy Secretary for the Environment, NC DEQ
Reid Wilson, Secretary, NC Department of Natural and Cultural Resources (NCR-DPR)
Jeff Michael, Deputy Secretary, NCR-DPR
Dwayne Patterson, Director, NCR-DPR
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
Heather Jacobs Deck, Executive Director, Sound Rivers
Wake County Commissioners
City of Raleigh Council Members
Durham County Commissioners
Durham City Council Members
Town of Cary Council Members
Town of Morrisville Council Members
Senator Wiley Nickel
Senator Jay Chaudhuri
Representative Joe John
Representative Cynthia Ball
Representative Gale Adcock
RDUAA Board members
Attachments:
Some of the renderings prepared by StructionLab. More at: https://sway.office.com/RkHoCu3Kwa69U6rw?ref=Link
V The Umstead Coalition v
Dedicated to preserving the natural integrity of W.B. Umstead State Park and the Richland Creek Corridor

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StructionLab
Model 8& Render Information Qualification Document
The information used to create the models and renderings associated with
the Umstead Park Triangle Quarry Expansion project has been obtained
from the following sources-
1. Land Contour Data & Topographic Information
Land Contour Data and Topographic Information for the project
site has been sourced from Autodesk Infraworks_ Autodesk
Infraworks is one of the most used software in the Virtual Design
and Construction environment for the planning and design of
infrastructure projects. This software enables us to create data -rich,
3-dimensional, terrain site models from a selected reap area.
Digital terrain model data in Infraworks is sourced from one of the
following sources, depending on where in the world you have
selected your map area, USGS 10 and 30 meter data, SRTMGL1
30m data or ASTER GDEM v2 30m.
2. Mining Durnp Trucks
Mining dump truck dimensions were procured from the catalogue
web site of one of the most well -renowned mining and industrial
equipment manufacturers. This information is kept up to date by
the manufacturer. The dump truck models are dimensionally
accurate and have been modeled to catalogue specifications.
3. Site Context
All other information related to site context — road widths wall
heights, quarry & basin depths, limits of clearing area etc. were
sourced from the Wake Stone Site Plan set dated August 4'1'r 2021.
Note: Tree placement in the model and renders is conceptual_
Infu•-)StruclionLab cum
1►The Umstead Coalition 1r
Dedicated to preserving the natural integrity of W.B. Umstead State Park and the Richland Creek Corridor