20220210_NCDPR

. NORTH CARD LiNA
STATE PARKS
Division of Parks and Recreation
NC Department of Natural and Cultural Resources
Governor Roy Cooper Secretary D. Reid Wilson
February 10, 2022
Mr. Brian Wrenn, Director
NC Division of Energy, Minerals and Land Resources
Department of Environmental Quality
Via email: brian.wrenn(&ncdenr.gov
Dear Mr. Wrenn:
Thank you for this opportunity to provide additional information as follow-up to our recent
discussions concerning the North Carolina Division of Parks and Recreation's (DPR) opposition to
the proposed expansion of Wake Stone Corporation's mining activities adjacent to William B.
Umstead State Park (Umstead Park). This letter affirms our previous concerns expressed in letters
dated January 20, 2022, November 18, 2021, February 12, 2021, and May 8, 2020 (enclosed for
your reference), but also presents additional data about the adverse impacts the proposed expansion
would have on Umstead Park and the newly established East Coast Greenway State Trail.
We continue to believe that expanded quarry operations would have a significantly adverse effect
on the purposes of Umstead Park and DPR's mission of conservation, recreation, and education for
the people of North Carolina. Since our 2020 letter, Wake Stone has submitted new information to
DEQ about the company's plans for mining the 105-acre Odd Fellows tract. This information only
exacerbates our prior concerns, particularly regarding construction of a wall along a popular trail
and a bridge over Crabtree Creek. In addition, DPR was recently tasked with additional
management responsibilities in the impacted area due to the designation of the East Coast
Greenway as an official North Carolina State Trail by the North Carolina General Assembly (signed
into law by Governor Roy Cooper on June 25, 2021). A national trail that runs from Calais, Maine
to Key West, Florida, the greenway runs through Umstead Park, and a section of it along Old Reedy
Creek Road just outside park boundaries is directly adjacent to the proposed new quarry as shown
on the enclosed map. Thus, the proposed quarry would harm two significant assets of the State
Parks system, not just one. Any analysis of the proposed quarry's impact to DPR should not be
limited to only the current boundaries of Umstead Park, but rather should also consider the impact
to the East Coast Greenway.
Dwayne Patterson, Director
NC Division of Parks and Recreation NORTH CAROLINA STATE PARKS
1615 MSC - Raleigh, NC 27699-1615 Na" WoadeW
919.707.9300 / ncparks.gov

CONSERVATION
The conservation element of DPR's mission requires us to conserve and protect representative
examples of North Carolina's natural beauty, ecological features, and recreational and cultural
resources within the state parks system.
The history of Umstead's establishment as a state park in the mid-20th century is a testament to its
natural, recreational, and cultural significance then and now. This assessment is validated by
independent national and state designations of the park's significance, including: the U.S.
Department of Interior's National Natural Landmarks Program (which recognizes sites that contain
outstanding biological and geological resources) and its National Register of Historic Places; and
the State of North Carolina (as a state park and dedicated state natural heritage area).
A natural and scenic oasis
As the Research Triangle area has experienced rapid population growth and urbanization,
Umstead's value as a scenic, recreational and wildlife amenity has taken on even greater
significance in the 215t century compared to the 1930s and 40s, when the newly created park was
surrounded by large swaths of undeveloped land. During the 30 years between 1990 and 2020, the
combined population of Wake and Durham counties increased 139%, from 608,155 to 1,454,243.
Looking at that growth in terms of land conversion, a UNC Charlotte study found that in the three
Triangle counties of Wake, Durham and Orange, development occurred at an average rate of 11
acres per day between 1976 and 2005 and outpaced population growth 5 to 1. Based on those
historic trends, the study forecast the average rate of development in the three -county area would
increase to 17 acres per day by the year 2040 and would continue to outpace population growth
nearly 1.5 to 1.
Today, Umstead is indeed an oasis of natural beauty surrounded by an increasingly dense urban
landscape, attracting both active and passive recreation users seeking the solace of its quiet and
scenic spaces. Visitation numbers prove the park's growing popularity with park visitation having
more than tripled since Wake Stone's initial permit was issued (from less than 350,000 visitors in
1981 to over 1.1 million in 2021).
A critical wildlife corridor
While the public is most familiar with our recreational mission, DPR also plays an important natural
resources stewardship role, including the protection of wildlife habitat. One of our primary partners
in managing wildlife habitat is the NC Wildlife Resources Commission, which addressed the
impacts of mining and quarrying in its 2015 Wildlife Action Plan (with a 2020 Addendum) as
follows:
The primary direct impacts to wildlife resources from mining and quarries ... relate to land
conversion. Additional impacts can result if stormwater runoff is discharged offsite to
surface waters. New and expanded mines and quarries may impact high -quality terrestrial
uplands, wetlands, or streams (page 694).

We have previously addressed our concerns about the impact the quarry expansion (and associated
structures such as the proposed wall and bridge) will have on water quality and aquatic species, as
well as on terrestrial species dependent on large, contiguous, and accessible tracts of native
habitat. In addition, the proposed quarry expansion comes at a time when there is growing
consensus among biologists of the importance of large areas of urban wildlife habitat as corridors
for migrating species, and the impact that land conversion and fragmentation will have on the park's
ability to serve that role effectively. The proposed quarry, the wall along quarry boundaries, and the
bridge spanning Crabtree Creek will only exacerbate the problem by severely reducing native
habitat adjacent to Umstead Park and restricting an existing wildlife corridor.
We also have concerns about the potential impact of dust generated from the proposed quarry on the
flora, fauna, and water resources of Umstead Park, as well as the impacts of noise on the wildlife
that depend on the park.
The potential impact of dust is particularly troubling regarding the site of the proposed quarry
expansion, which will be just 100 feet from the shore of Foxcroft Lake and the aquatic species that
call it home. Even with the berm and dust control measures for the existing quarry, the park still
experiences a significant amount of fugitive dust from the mining operations. The dust covers the
leaf and other ground litter, and usually covers any saplings and low -growing vegetation up to about
three feet high. If the quarry expansion permit is approved, we fear that the entire section of forest
between the Reedy Creek parking lot and picnic area and the property line of Wake Stone Quarry
will be covered in dust, with negative effects on the ecological health of the forest.
Noise from the quarry's operations presents another challenge to Umstead's role as a wildlife
sanctuary. Research shows that man-made noise reduces wildlife's capacity to sense natural sounds,
which are critical for both survival and reproduction. Animals hunt for food, avoid predatory and
territorial threats, and call to locate group members and mates through sound and vibration. In an
area of Umstead Park that is already severely stressed from the noise generated by an adjacent
airport, nearby interstate highway and the existing quarry, expanding the quarry operations even
farther into the forest will only intensify these problems. (Noise Pollution is Pervasive in U.S.
Protected Areas. Buxton, et al., Science 356, 351-533 (2017).
Umstead Park is viewed by many conservationists as central to the Triangle's future viability as part
of a connected wildlife corridor through the urbanizing Piedmont, but the proposed quarry
expansion is a serious threat to that viability.
RECREATION
Providing access to recreational amenities is not enough to fulfill DPR's mission, as we must also
promote safe, healthy, and enjoyable outdoor recreational opportunities throughout the state. For
over three quarters of a century, we have been able to fulfill this obligation at Umstead Park;
however, the proposed quarry expansion would threaten our ability to provide such a safe, healthy,
and enjoyable experience for the estimated 45% of Umstead's annual visitors who regularly access
the park at one of its two southern entryways.
The Harrison Avenue access and the Old Reedy Creek Road access accounted for an estimated
499,001 of Umstead Park's 1,108,272 total visitors in 2021. Those numbers are expected to increase

over the next 30 years to 1,773,593 visitors accessing the park from the two southern entryways
(out of an estimated 3,483,908 total visitors in the year 2051).
As with wildlife, existing quarry operations are already negatively impacting Umstead Park's
visitors and staff with noise and vibrations, dust, and traffic.
Noise and vibrations
Visitors to Umstead are regularly subjected to current mining operation noise, including blasting
and the loading of rock onto trucks. Particularly impacted are hikers on Inspiration Trail and
Company Mill Trail, near the Harrison Avenue entrance and the current quarry. Blasting regularly
shakes the floors and walls of our ranger residence near the Harrison Avenue entrance, and visitors
have reported pet anxiety caused by blasts.
When audible to humans —and not drowned -out by construction noise —natural sounds provide
health benefits (Listening to Silence: Why We Must Protect the World's Quiet Places. Morber, J.
YaleEnvironment360: June 30, 2020). In contrast, noise pollution causes confusion, distraction,
stress, and "altered behavior and physiology in ways that directly influence both wildlife and
humans (5-9)." Research shows that anthropogenic noise, including mining, causes or exacerbates a
host of chronic health conditions such as low sleep quality, high blood pressure, increased risk of
heart attack or stroke, diabetes, and cancer.
Should the quarry expansion be permitted, blasting is anticipated to be performed twice per week (a
conservative estimate) to loosen new material for excavation. Work hours are generally from 7 a.m.
to 5 p.m. This estimate comes from the draft Wake Stone Corporation's Acoustical Study (Wake
Stone Triangle Quarry Expansion Acoustical Study Prepared For: Wake Stone Corporation 222 Star
Lane Cary, NC 27513 Prepared By: WSP USA, Inc. 100 Summer Street Boston, MA 02111,
Revision Date: 11 February 2021)
Our understanding is that the blasted stone will be hauled from the new quarry pit across the bridge
to the existing primary pit where it will be processed. The stone will be stockpiled and sold from the
same yard, scale, and entrance as the existing operation. In its permit application, Wake Stone
provided an estimate of 30 years to empty the quarry.
Blasting Frequency
Per Week
Blasts per year
Total Blasts Over 30
Year Period
2
104
3,120
3
156
4,680
4
208
6,240
While the data are clear about the impacts of quarry operations on human and wildlife populations,
the anecdotal stories we hear from both visitors and staff are compelling:
• A family was walking their dog at Umstead Park, when the adjacent Wake Stone quarry
emitted a thunderous blast. The family dog was so stunned that he could not move after the
blast, and the family had to carry him back to their vehicle.

• The Umstead park ranger living in the ranger residence near Harrison Avenue stated that at
home, "I can certainly feel when they blast. It's usually in the mid -morning (sometime
between 11 am and Ipm). It shakes the floors and walls of the house and is often audible
both indoors and outdoors." He has talked about how he must reassure his young children
each time.
• According to park rangers, when active mining operations are taking place, anyone hiking or
biking near the park/quarry boundary hears quarry noise, especially the loading of dump
trucks with large pieces of rock to be delivered up to the crushers. The number of park
visitors impacted by this noise will only increase should the quarry be permitted to expand
along the Old Reedy Creek Road entrance.
Health concerns concerning dust
Despite some dust control measures, rangers' shoes and pants are often coated in the white granite
dust that is frequently generated from mining operations at the existing quarry site. Beyond being a
nuisance, regular park visitors and staff who work outside daily have increasingly raised concerns
about the potential impact that dust might have on their respiratory systems and long-term health.
Rangers and visitors often note that Umstead Park's water resources frequently have a milky color,
including streams and drainage ditches that flow into the park. These historical observations of dust
throughout the southern part of the park raise serious questions about the environmental and health
effects that dust from the current mining operations, not to mention those of the proposed quarry
expansion, might have on the park, its visitors and DPR staff.
Traffic safety
Visitors to Umstead Park's Harrison Avenue entrance must negotiate heavy truck traffic, with the
current quarry's only vehicle exit adjacent to the entrance gate. As noted earlier, visitation at the
park has skyrocketed since the initial permit was granted in the early 1980s and given the large
volume of truck traffic at the Harrison Avenue entrance, conflicts have arisen due to visitors
parking along the street outside the entrance gate. On most weekends during good weather, the
existing lot is full by 9:30 or 10:00am, and vehicles line up at the entrance to the park, with the line
sometimes backing up close to the I-40 interchange, creating significant safety challenges for park
staff to manage. The issue has become serious enough that DPR has adjusted park hours to
accommodate an earlier opening on weekends; however, this remedy has created additional
challenges in the form of hardships incurred by an already extended staff — yet another example of
how the conditions surrounding the initial permit approval in the 1980s no longer exist as the
Triangle has continued its rapid urbanization.
To estimate visitor interactions with dump trucks transporting stone from the quarry, our staff
estimated the volume of material that would need to be moved from the quarry over the life of an
additional pit. Assuming a 75-acre pit excavated to a depth similar to the existing pit, the quarry will
remove approximately one billion cubic feet of rock. The estimated expansion (swell) of the rock
during mining is 70 to 80 percent. Five to seven million truckloads at a capacity of 10 to 16 cubic
yards (60,000 pounds per truck) will be needed to haul this volume of material offsite.

Large dump truck trips serving the new quarry site will use the existing quarry entrance and a short,
500-foot section of Harrison Avenue just outside the park entrance.
Proposed quarry material and required trips adjacent to park entrance
Area of pit
75 acres
Volume of pit
1,000,000,000 cubic feet
Volume of product
1,750,000,000 cubic feet
Trucks trips per day
350
Total truck trips required (overestimated 30
ears
6 million
Total truck trips including empty hauls
12 million
The dangerous and negative implications of these figures related to truck trips are:
1. 12 million large dump truck trips will be interacting with an estimated 32 million visitors at the
Harrison Avenue entrance on a 500-foot stretch of road.
2. Early morning visitors sometimes legally park on the road before the park opens and it is very
dangerous for cyclists, children, and all other visitors.
3. Six million large dump trucks will be making left hand turns in front of entering and exiting
Umstead traffic.
4. Six million large dump trucks will be making right hand turns in front of exiting Umstead
traffic.
The visitors entering and exiting this side of the park must contend with a steady stream of trucks
entering and leaving all day long. We recommend that an independent traffic safety study be
conducted, focused on the intersection of Harrison Avenue and Star Lane, the entrance to the
existing quarry. This is necessary because the increased vehicle traffic created by the roughly tripled
park visitation since the permit was approved in 1981 presents a fundamentally different safety
challenge today, only to be exacerbated in the coming years as park visitation continues to grow.
Compromises to the visual integrity of park and greenway scenic character
One of the greatest and most tangible impacts of the quarry expansion will be the visual impact that
it will have on park visitors and greenway users. Whereas the primary visual impact of the existing
quarry is limited to the parking area off Harrison Avenue, the proposed expansion will extend that
visual impact deep within the scenic and recreational areas of the southwestern portion of the park.
The decision to route the East Coast Greenway State Trail through the southern part of Umstead
Park demonstrated the Park's value as a refuge for outdoor recreation enthusiasts. In establishing
the East Coast Greenway's path through the Triangle, trail planners intentionally sought to connect
nearby population centers and other local parks to Umstead's natural, recreational, and scenic
amenities. After years of planning, 5.2 miles of trail within Umstead Park — much of it taking
advantage of the Reedy Creek Multi -Use Trail adjacent to and near the site of the proposed quarry
expansion — will soon be officially dedicated as part of the East Coast Greenway State Trail. The
greenway continues outside park boundaries along Old Reedy Creek Road and directly adjacent to

the proposed quarry, extending an additional 0.5 miles to both Lake Crabtree County Park and 1.1
Miles to North Cary Park.
A 16-foot-high, 1000-foot-long noise reduction wall along the East Coast Greenway and Old Reedy
Creek Road will significantly damage the visual experience for Umstead visitors and users of the
greenway. Currently, this access is along a low -traffic road that allows visitors from Lake Crabtree
County Park and Old Reedy Creek Trailhead to access Umstead, where they are greeted by a
forested setting indistinguishable from parkland on both sides of the road.
As the following illustrations demonstrate (prepared by DPR park planners), the visual experience
of visitors to this heavily used part of the park and the East Coast Greenway will be greatly altered
if the quarry and proposed wall are built, transforming this area from a natural, parkland setting to a
developed, urban, and industrial environment. Visitors would walk and bike past the proposed wall
instead of forest, marring their experience upon entering the park and their expectations for a green
oasis. The negative impact to park and greenway visitors would only be increased by anticipated
graffiti vandalism to the wall, and our park staff would likely be the recipient of complaints. The
proposed wall would not mitigate the adverse effects of the proposed quarry on this section of the
greenway and this part of the park; it would be an adverse effect in and of itself.
In addition to the wall and not captured in the above illustrations, it is likely that a new pit would be
visible from the hill that rises up from Foxcroft Lake, another significant scenic impairment for
visitors within Umstead Park.
A final note on our recreational mission is that if the permit is denied, it could provide an
opportunity to convert the 105-acre site to public use for additional trails to meet growing demand
for outdoor recreation, so approval of the permit would constitute a lost opportunity.
EDUCATION
The third key element of DPR's mission is to provide educational opportunities that promote
stewardship of the state's natural and cultural heritage. While all our state parks serve this purpose,
Umstead has arguably the greatest educational reach and impact of any of our state parks due to its
location at the center of a large metropolitan region. In addition to serving as a natural classroom for
the study of biology, botany and other natural sciences, the park itself is a real -world example of
land stewardship as reflected in its history of land reclamation, ecological succession, and public
access.

The southern end of Umstead Park is also one of North Carolina's most important cultural
landmarks in telling the story of public outdoor recreation during the Jim Crow era. As described in
our May 2020 letter, the State of North Carolina purchased what became Umstead Park for $1
(known at the time as Crabtree Creek Recreation Area), and more facilities were built as the
General Assembly made its first state parks division appropriation in the 1940s. In 1950, more than
1,000 acres of the park were established as a separate park for African Americans and named Reedy
Creek State Park. These two segregated parks were eventually united and integrated in 1966 under
the name William B. Umstead State Park.
This history positions Umstead as one of only three parks in the State Park System that represent
this segregated history of public outdoor recreation (the other two being Hammock's Beach and
Jones Lake), and it was Umstead's southern area that constituted the old Reedy Creek State Park
that was so important to African Americans across North Carolina. At a time when state and local
governments in the South are honoring such places and using them to tell a more honest story of the
legacy of Jim Crow and segregation, North Carolina should be seeking to enhance the educational
and cultural significance of this part of Umstead Park rather than compromising its integrity.
IN CONCLUSION
A second quarry would compromise all three elements of the Division of Parks and Recreation's
mission - conservation, recreation, and education. Throughout this letter, we have focused on Wake
Stone's estimate that it would need 30 years to complete quarrying operations, but it is important to
note that current mining law allows for a quarry to be mined indefinitely, meaning that the
numerous negative effects caused by a new quarry could conceivably last considerably longer than
30 years.
We firmly believe the proposed quarry and wall would have a significantly adverse effect on
Umstead Park and the East Coast Greenway, and that the proposed measures by Wake Stone will
not mitigate those adverse effects and in some instances will actually worsen the effects. When all
of the problems we have described — noise and vibrations, dust, water quality, scenic integrity,
wildlife habitat, and traffic safety — are considered cumulatively, they represent an unacceptable
degree of permanent harm to the park, the greenway, and to the visitor experience for millions of
visitors to this cherished natural area for decades to come.
Sincerely,
Dwa ne attteersson
Y
Enclosures
cc: D. Reid Wilson, Secretary, DNCR
Jeff Michael, Deputy Secretary, DNCR
Brian Strong, Deputy Director of Planning and Natural Resources
Sushma Masemore, Assistant Secretary for Environment, DEQ
Bill Lane, General Counsel, DEQ
Paul Wojoski, Supervisor, 401 & Buffer Permitting Branch, DEQ