HomeMy WebLinkAbout20210831-J-Spooner_Plan_RevisionsKastrinsky, Josh
Subject: Mining Permit Application, 92-10, Agency Review needed due to Revisions
From: Jean Spooner [mailto:umsteadcoalition@gmail.com]
Sent: Thursday, August 26, 2021 1:27 PM
To: Wrenn, Brian L <brian.wrenn@ncdenr.gov>
Cc: Miller, David <david.miller@ncdenr.gov>; Biser, Elizabeth <Elizabeth.Biser@ncdenr.gov>; Wilson, Reid
<Reid.Wilson@ncdcr.gov>; Michael, Jeff <ieff.michael@ncdcr.gov>; Patterson, Dwayne
<dwayne.patterson@ncparks.gov>; Garrison, Gabriela <gabriela.garrison@ncwildlife.org>; Galamb, Eric
<Eric.Galamb@ncagr.gov>; Wojoski, Paul A <Paul.Woioski@ncdenr.gov>; Wilson, Nat <nat.wilson@ncdenr.gov>; Jones,
Brandon H <bhiones@ncdot.gov>; Gledhill-earley, Renee <renee.gledhill-earley@ncdcr.gov>; fmr.kevin.cherry
<fmr.kevin.cherry@ncdcr.gov>; Bartos, Ramona <Ramona.Bartos@ncdcr.gov>; Ellis, John <iohn ellis@fws.gov>
Subject: [External] Mining Permit Application, 92-10, Agency Review needed due to Revisions
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August 26, 2021
MEMORANDUM
To: Dr. Brian Wrenn, Director, NC Division of Energy, Minerals and Land Resources (DEMLR), DEQ
From: Jean Spooner, Chair
The Umstead Coalition
Subject: Mining Permit Application, 92-10, Agency Review needed due to Revisions
cc: David Miller, Mining Specialist, DEQ-DEMLR
Elizabeth Biser, Secretary, DEQ
Reid Wilson, Secretary, NC Department of Natural and Cultural Resources (DNCR)
Jeff Michael, Deputy Secretary, NC DNCR
Dwayne Patterson, Director, NC Division of Parks and Recreation, DNCR
Gabriela Garrison, Eastern Piedmont Habitat Conservation Coordinator, NC Wildlife Resources Comm.
Eric Galamb, NC Division of Soil and Water Conservation
Paul Wojoski, Supervisor, 401 and Buffer Permitting Branch, DEQ-Div of Water Resources (DWR)
Nat Wilson, Ground Water Management Branch, DEQ-DWR
Brendon H. Jones, PE, Division Engineer, Division Five, NCDOT
Renee Gledhill -Earley, Environmental Review Coordinator, State Historic Preservation Office
Dr. Kevin Cherry, Deputy Secretary, State Historic Preservation Office of Archives and History
Ramona M. Bartos, Deputy, State Historic Preservation Office
John Ellis, US Fish & Wildlife Service
Responses to DEQ Mining Division's ADI 4, 5, and 6 dated August 12, 2021, and posted on the department's
Laserfiche site on August 16, 2021 include significant revisions to Wake Stone's previous plans.
For instance, these latest plans replace approximately 3,250 linear feet of earthen buffer berms with a varying height
(16'-24') wall, expands the area of disturbance, further reduces committed buffers, and shifts blasting explosions
much closer to the Park, the East Coast Greenway, and the Dunn residence.
The Neuse River waterlog (Necturus lewisi) was re -confirmed this past March, 2021 in Crabtree Creek
downstream. In June, 2021 the Neuse River waterdog received full listing as "Threatened" by the US Fish
& Wildlife Service. https://www.fws.gov/southeast/wildlife/amphibians/neuse-river-waterdog/
These changes are significant and State agencies, regulators, and the public deserve an opportunity to review and
comment on the new plan. NC Division of Parks and Recreation (aka, NC State Parks), in particular, should have a
chance to review these plans prior to any decision regarding permit modification.
Wake Stone's Site Plan still lacks an NC licensed professional engineer's seal, and each sheet includes qualifying
statements regarding their accuracy, specifically noting they have not been verified for use as a basis for
design/construction.
The erosion control plans appear to violate NCGS 143-214.7 (c3) and may require redesign to achieve compliance.
Given the amount of information provided, the changes from earlier plans, and the unreliability of the Site Plan's
accuracy, it would be prudent to issue an ADI to Wake Stone that would have them cloud or otherwise draw attention
to the changes from the original submittal. This would allow agencies who reviewed only the original plans to more
expeditiously conduct their reviews of the new plans.
The appropriate action is for DEMLR to issue an ADI prior to consideration of any Decision on Permit Modification
#92-10 to assure relevant agencies and the public have had sufficient opportunity to review and comment on the new
plans, including any corrections to the E&SC plans.
Thanks for supporting William B. Umstead State Park!
Jean Spooner, Chair
The Umstead Coalition
PO Box 10654
Raleigh, NC 27605
cell 919-602-0049
Virus -free. www.avast.com