HomeMy WebLinkAboutWildlife Impacts of Proposed Odd Fellows Quarry v2 (3)Wildlife Impacts of Proposed Odd Fellows Quarry
Ron Sutherland, Ph.D.
Chief Scientist, Wildlands Network
Relevant grounds for denial of Wake Stone's mining permit by NC DEQ:
(d) The Department may deny the permit upon finding:
(2) That the operation will have unduly adverse effects on potable groundwater supplies,
wildlife, or fresh water, estuarine, or marine fisheries;
Unduly: Defined as "1. Excessively, or 2. In an inappropriate, unjustifiable, or improper manner"
Adverse: Defined as "1. Unfavorable or antagonistic in purpose or effect, or 2. Opposing one's
interests or desire, or 3. Being or acting in a contrary direction; opposed or opposing.
[from Dictionary.com]
(5) That the operation will have a significantly adverse effect on the purposes of a publicly
owned park, forest, or recreation area;
Significant: Defined as "1. Important; of consequence"
[from Dictionary.com]
Note: Each qualifying reason stands alone as grounds for denial of the permit, there is no need to show
that more than one such rationale exists. However, in the case of the proposed Odd Fellows quarry, as
you heard during the two different public hearings, Wake Stone's proposal undeniably meets many of
the denial criteria all at once. Here we focus on the two criteria listed above.
Statement 1. Building a new rock quarry on the border of Umstead State Park will have unduly
adverse effects on the wildlife within Umstead State Park, for the reasons outlined below.
1. Direct Loss of Wildlife Habitat at the beautiful Odd Fellows tract of public forest
A. The quarry would directly destroy or significantly degrade 100 acres of beautiful woodland
habitat directly adjacent to the state park, reducing the total forested area of Umstead's ecosystem by a
significant and nontrivial amount (nontrivial given all of the other habitat that has already been lost, and
the park's relatively constrained size to begin with). These woods are occupied by box turtles, deer,
raccoons, various snake species, salamanders, understory plants and wildflowers, numerous tree
species, etc. Loss of this habitat directly reduces the chances that the wildlife inside of Umstead State
Park will be able to maintain viable populations in the future (see also loss of habitat connectivity
below). The current opportunity cost for replacing 100 acres of mature hardwood and mixed pine
forests on the border with Umstead State Park is enormous - there are few if any such tracts available,
and the cost to the public to protect such additional wildlife habitat would be quite high, much higher
we think than any benefits provided by the addition of a new rock quarry next to the state park.
B. The quarry would cause partial or complete destruction of several small streams and rivulets
that now exist on the Odd Fellows tract, and which currently provide important habitat for stream fish,
crayfish, salamanders, other aquatic insects. These small forested streams are also quite important for
delivering relatively clean water into Crabtree Creek, helping reduce the impacts of other developments
and pollution sources upstream.
2. Degradation of Adjacent Wildlife Habitat in Umstead State Park
A. Light impacts - artificial lights from the quarry operations would significantly affect moths and
other nocturnal animals. As many people know, moths are attracted at their peril to artificial lights. The
interior forest of Umstead provides a relatively dark space for these insects to complete their life cycles,
but a brightly -lit quarry operations area will diminish the quality of darkness in the park, and attract
moths and other nocturnal insects out of the park and direct them to the quarry pit instead.
B. Noise impacts - constant blasting and truck noise will scare off many species - especially
human -sensitive creatures such as bobcats. Noise from the quarry will also interfere with the ability of
other wildlife to communicate with each other - for example birds have been shown to have trouble
hearing each other in noisy urban environments. The noise profile from the quarry would likely exceed
that of a typical urban/industrial environment, given the regular episodes of explosive blasting, and the
steady passage of large diesel trucks and giant machinery.
C. Dust impacts - dust from quarry operations coats tree and plant leaves, disrupting
photosynthesis, and coats insects and smaller wildlife, especially sensitive species such as amphibians
that breathe through their skins. Dust control is just not something that a rock quarry can reliably
deliver, they are in the business of pulverizing rock and that process inevitably creates substantial
amounts of new dust on a daily basis.
D. Edge effects - creation of a new quarry pit will open up a new forest edge along the border of
Umstead State Park, with detrimental impacts on plants and wildlife that rely on forest interior
conditions. The sunny, dry, and windy conditions along the newly opened edge will kill trees, promote
invasive species spreading into the park, promote nest parasite bird species (such as cowbirds) moving
into the park, and reduce the number of forest interior bird species that can survive in that portion of
the park along the border with Odd Fellows.
E. Water pollution - runoff with sediment and quarry tailings will inevitably escape into Crabtree
Creek. The existing quarry, despite claims to the contrary by Wake Stone, has spilled polluted runoff into
the creek, including dust/sediment and also rust/metal contamination from aging pipes. The new quarry
will do the same. This water pollution will enter the creek upstream from the State Park, and then flow
through the otherwise beautiful habitats of Crabtree Creek inside the protected park. Countless trucks
full of dusty rock crossing a small bridge directly over Crabtree Creek will also serve to help spill
sediment into the creek on a regular basis. Excess sediment ruins fish spawning habitat and interferes
with aquatic photosynthesis and aquatic food chains. All of this assumes that the creek itself won't
collapse entirely due to significant and absurd levels of excavation on both sides from the old quarry and
the new quarry. If the creek collapses, this will have catastrophic impacts that have not been adequately
assessed or even imagined by Wake Stone. It is also possible that new landslides into the creek could
happen due to blasting errors, as has already happened in the history of the old quarry.
3. Substantial and nearly complete removal of habitat connectivity for wildlife between Umstead and
nearby public forests
A. the southern end of Umstead represents the best chance to make sure the state park remains
ecologically connected to other natural areas, particularly Jordan Lake, which has over 40,000 acres of
public forest/gamelands. Jordan Lake's forests are also connected (via several large rivers) to the
broader network of habitat across North Carolina, and it is essential to try to keep Umstead linked
together with that network.
B. maintaining connectivity is now viewed by ecologists and conservationists as essential for
protecting wildlife populations, especially wide-ranging species that need more acreage than a medium-
sized park like Umstead can provide on its own. Examples would include bobcats (1000-3000 acres each,
vs. 5500-acre state park), wild turkey (several hundred to 1000 acres each), eastern kingsnakes (100
acres each), and others. Umstead can retain these important species, but only if Umstead remains
connected to a larger network or matrix of habitat. Rapid urban development over the past 30 years has
nearly cut the park off from other blocks of wildlife habitat, making it all the more important that the
potential linkage between the south side of Umstead and Jordan Lake is protected and restored. Losing
the last viable connection to the outside habitat network would have excessive negative impacts on the
wildlife inside Umstead State Park, and on the park's purpose.
C. Destruction of the Odd Fellows forest and replacement with a fenced -in quarry pit would
block much of this potential connectivity directly, by greatly restricting the ability of wildlife to move
along Crabtree Creek and under Interstate 40. The pit itself poses a lethal obstacle to most terrestrial
species of wildlife, and the fencing would also block many species from even trying to navigate through
the area to reach better habitats on the other side.
D. The Crabtree creek corridor, which passes through a relatively wide bridge under the highway
(this bridge could be improved in the future to provide even more room for wildlife and human
greenway trails) would become an absurdly narrow elevated aqueduct, flowing between two deep holes
in the ground! The fencing and lights and steady truck traffic over the proposed creek bridge (which
would completely cut off what is left of the creek corridor for wildlife) would all combine to make sure
that few species are able or willing to move along Crabtree Creek to get to the other side of 1-40.
E. The steady truck traffic between the new quarry and the existing processing facilities on the
other side of Crabtree Creek would not just discourage animals from moving along the creek, the trucks
would directly run many animals over. This roadkill would greatly diminish habitat connectivity along
what is left of the Crabtree Creek corridor and it would likely cause a localized decrease in population
density for roadkill sensitive species (such as box turtles, salamanders, snakes) inside Umstead State
Park. The quarry expansion would essentially be adding a high traffic road to the edge of the state park,
with obvious negative consequences for the wildlife inside the park.
F. The 286 lands managed by the Airport across Old Reedy Creek Rd from Odd Fellows are also
quite important for potential connectivity between Umstead and Jordan Lake, but currently lack a safe
route for wildlife to get to Lake Crabtree Park - the 1-40 bridge over Crabtree Creek is essential for that
connection. Furthermore it is our understanding that Wake Stone includes the 286 lands in its eventual
quarry expansion plans, and RDU Airport may have already zoned that property for
commercial/industrial use. It is also our understanding that RDU Airport Authority plans to destroy the
wildlife habitat at Lake Crabtree County Park (on the other side of 1-40) and replace the upland forests
there with with commercial development, which would further seal off Umstead State Park from any
chance of being connected to Jordan Lake. All of these destructive activities on publicly -owned forest
lands (the public owns Odd Fellows, 286, and Lake Crabtree County Park) must be prevented to save and
protect the wildlife at Umstead State Park.
4. Prevention of timely reclamation of the existing rock quarry location south of Umstead
A. The existing Wake Stone quarry never should have been built next to the state park in the
first place. In fact, it is our understanding that NC DEQ denied the mining permit to Wake Stone, on the
reasonable and defensible grounds of the potential damage the quarry would cause to Umstead State
Park, and NC DEQ was overruled with some subterfuge or another by the NC Mining Commission. Thus
NC DEQ has direct precedent for denying the expansionary plans of Wake Stone again, only this time we
hope you will do so in a way that does not allow the Mining Commission to reinstate the permit after
you deny it.
B. Wake Stone's existing quarry operations were scheduled to cease by 2031. Nothing can fully
mitigate the permanent and serious impacts of that quarry on the park and its wildlife. But it does seem
clear to us that removing the industrial quarry equipment and facilities on the border of the park,
allowing the quarry to fill with water, and ceasing the regular blasting noises and steady truck traffic
along the southern border of the park will at least reduce the impacts of the quarry on Umstead wildlife.
Such efforts to reduce the impacts of the quarry should be commencing in just 10 years (or less, if the
existing quarry ceases operations prior to 2031).
C. It is our understanding that the Odd Fellows quarry cannot proceed economically without
having access to the existing quarry processing facilities. If the new quarry is allowed to proceed, this
will result in the old quarry site continuing to be a hub of industrial operations and truck traffic for
decades to come. Thus the question of whether to permit the new quarry facility at Odd Fellows has
direct implications for the potential for any mitigation at the existing quarry facility during the
foreseeable future (e.g. during the professional careers of all staff involved in this permitting process).
Not only should NC DEQ deny the permit for the quarry expansion, you should also reinstate the Sunset
Clause to make sure the existing quarry closes down by 2031 so that mitigation and reclamation
measures, as inadequate as they will be, can proceed.
Statement 2. Adverse impacts on the wildlife and biological resources of the park will furthermore
cause significant adverse effects on the purposes of Umstead State Park.
1. To directly quote the Umstead State Park management plan (available online at
https://files.nc.gov/ncparks/481/WIUM%20GMP%20FINAL%20112117.pdf):
The 1987 State Parks Act defines the purposes of the state parks system. It establishes
that: The State of North Carolina offers unique archaeologic, geologic, biologic, scenic
and recreational resources. These resources are part of the heritage of the people of
this State. The heritage of a people should be preserved and managed by those people
for their use and for the use of their visitors and descendants.
Hence it is quite clear that a rock quarry that severely impacts and degrades the biologic, scenic, and
recreational resources of Umstead State Park would also negatively impact the purposes of this popular
and well -loved unit of the State Parks system of North Carolina. The Umstead Management plan
document referenced above goes on to note, in regards to Umstead:
Deed restrictions specify that the park must serve "public park, recreation, and
conservation purposes" or revert to federal ownership.
Therefore, it is also quite clear that the legally required mandate of Umstead State Park in particular is
to serve "public park, recreation, and conservation purposes", all of which would be harmed by the
construction of another rock quarry immediately adjacent to Umstead. Not only would the quarry
impact the recreational value and experience of the park, it would also damage the wildlife of the park
as outlined above, which would prevent the park from serving its conservation purposes as well.
For the reasons outlined above, NC DEQ must deny the permit to Wake Stone to develop a new rock
quarry at the Odd Fellows site next to Umstead State Park.