Letter from Division of Natural and Cultural Resources

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper Office of Archives and History
Secretary Susi H. Hamilton Deputy Secretary Kevin Cherry
May 7, 2020
Brian Wrenn, Acting Director
NCDEQ/Division of Energy, Mineral & Land Resources
Via email: Brian.wrenngncdenr.gov
Re: Expand Wake Stone Triangle Quarry, Odd Fellows Tract adjacent to Umstead Park, Raleigh, Wake
County, GS 20-0841
Thank you for providing the April 8, 2020, mining permit modification application for the above -referenced
expansion project. We have reviewed the application and offer the following comments.
As noted in the application, Wake Stone Corporation is aware of the public concern raised by its proposed
expansion immediately adjacent to William B. Umstead State Park, which was listed in the National Register of
Historic Places (NRHP) in 1995 as the Crabtree Creek Recreational Demonstration Area. We, too, are
concerned by the proposal as we believe it may adversely affect the characteristics that made and continue to
make the park eligible for National Register listing.
The Crabtree Creek Recreational Demonstration Area is an important example of a Depression -era public
works project, the purpose of which was to convert exhausted farmland into an outdoor recreational park.
Significant for its architecture, landscape architecture, and conservation management techniques, the 5,337-acre
park was one of two Recreational Demonstration Areas established in North Carolina by the federal
government in the 1930s.
The genesis of the park occurred in 1934 when the Resettlement Administration began assembling tracts of
farmland for reclamation and reforestation. Following the land acquisition, the Civilian Conservation Corps
(CCC) and the Works Progress Administration took the lead on next steps. Under the supervision of architects,
landscape architects, foresters, and engineers, young CCC recruits labored to build rustic -style group camps,
bridges, roads, trails and picnic areas. They also planted forests, dammed creeks to create lakes, and instituted
land management practices to reverse the land erosion caused by years of poor agricultural practices. The result
of this effort is North Carolina's premier collection of New Deal rustic architecture and landscape architecture.
The majority of the park's natural landscape features, which include streams, drainage areas, ridges, and forest,
remain essentially unchanged. With over thirty miles of bridle/bicycle trails and hiking paths, the park is one of
the most visited in North Carolina and offers a nature -based retreat in one of the fastest developing counties in
the state.
Given its historical significance as a recreational area centered on restoration of the landscape through
landscape design and land -management as well as a rustic retreat from increasing urbanization, we believe that
the following concerns need to be more thoroughly addressed.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

Tree clearing of 59.3 acres of trees and removal using Reedy Creek Road.
• Please address the noise and dust this activity will create as well as the safety issues raised for
hikers using the road as a major access point to Umstead Park.
Construction of fifteen foot (15') tall vegetative berms set fifty feet (50) behind the permit limit
boundary.
• We understand these berms are supposed to provide a visual and noise buffer for the park as
well as to discourage public access. However, it will take some time to build the berms and
decades for them to be vegetated sufficiently to serve this purpose. In the meanwhile, the bare
or nearly bare berms will be visual landscape elements that are incompatible with the very
reason for creation of the park as a forested recreation area.
• The applicant anticipates that these berms will also mitigate the increased noise of the quarry
closer to the park. Please substantiate this claim.
• It is stated that, if necessary, a security fence eight feet (8'), topped with three strands of
bobbed -wire, will be installed along the perimeter by either Wake Stone or the RDU Airport
Authority. We believe that a fence is completely out of keeping with the landscape of the park
and its recreational character and significance as set forth in the National Register listing. Please
offer other options.
Lighting of the quarry is not thoroughly addressed.
• Please provide documentation that there will be no increase of night lighting that can adversely
affect the night-time experience of the park as a rustic retreat.
In addition to the above comments that relate to potential adverse effects upon the National Register -listed
historic property, we offer the following on the potential archaeological resources.
There are no recorded archaeological sites within the boundaries of the mine expansion project area;
however, this area has never been systematically surveyed to determine the location or significance of
archaeological resources. Previously recorded archaeological sites within a half mile of the project area
suggest that landforms associated with Crabtree Creek and its tributaries have a high probability for
containing pre -colonial American Indian archaeological sites associated with quarrying gravels from stream
deposits. In addition, the 1914 Wake County soil survey map shows one structure in the mine expansion
area, and archaeological remains associated with this structure may be present in the parcel.
We believe that a comprehensive archaeological survey conducted by an experienced archaeologist is required
before further consideration of issuance of the necessary state permits for the quarry's operation. The purpose
of this survey will be to identify and evaluate the significance of archaeological sites that may be damaged or
destroyed by the proposed project.
Please note that our office now requests consultation with the Office of State Archaeology Review
Archaeologist to discuss appropriate field methodologies prior to the archaeological field investigation. A list
of archaeological consultants who have conducted or expressed an interest in contract work in North
Carolina is available at https: / /archaeology.ncdcr.Vov/archaeological-consultant-list. The archaeologists
listed, or any other experienced archaeologist, may be contacted to conduct the recommended survey.
One paper and one digital copy of all archaeological reports addressing work in the project area, as well as
one digital copy of the North Carolina site form for each site recorded, should be forwarded to the Office of
State Archaeology through this office for review and comment as soon as they are available and in advance

of any construction or ground disturbance activities. Office of State Archaeology report guidelines are
available at https://files.nc.gov/dncr-arch/OSA Guidelines Dec2017.12df.
An adverse effect to the National Register -listed property arising from the activities proposed under the
requested permit could trigger referral to the North Carolina Historical Commission for further review under
NC 121-12(a).
In short, industrial mining is generally not conducive to the support and promotion of or compatible with the
very elements that led William B. Umstead State Park to being listed on the National Register of Historic
Places: land restoration through landscape design and outdoor recreation. For this reason, expansion of quarry
activity is of great concern to the State Historic Preservation Office and Office of State Archaeology. In
addition, there is a high degree of probability that the potential impact area contains undiscovered prehistoric
American Indian archaeological resources that the proposed activities could threaten. For these reasons, we
need and request additional information from the applicant concerning how it plans to address these issues
before our offices can then provide final comments upon the permit request.
Thank you for your cooperation and consideration. If you have questions concerning the above comments
made under Executive Order XVI and NC GS 121-12(a), please contact Renee Gledhill -Earley, Environmental
Review Coordinator, at 919-814-6579 or environmental.reviewkncdcr.gov. In all future communication
concerning this project, please cite the above -referenced tracking number.
Sincerely yours,
Ramona M. Bartos, Deputy
State Historic Preservation Officer
cc: Reid Wilson, Chief Deputy Secretary reid.wilsonkncdcr.gov
Kevin Cherry, Deputy Secretary kevin.cherLykncdcr.gov
Dwayne Patterson, State Parks dwayne.patterson(kncparks.gov