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HomeMy WebLinkAbout20111013 Ver 1_Public Comments_20111228 (2)Edward and Glona Stafford 711 Island Dnve Chocowmity North Carol�na 27817 December 26 2011 Mr Ian McMillan North Carolma Division of Water Quahty 1650 Mail Service Center Rale�gh North Carolma 27699 1650 Reference US Army Corps Of Engmeers Action ID # SAW 2011 02235 Mr McMillan �1- �o�� 0 �� �oe DF � c28 D a_'"�SQV� ��R ?0�l AND�q��, ��N We are wntmg to oppose the North Carolma Division of Water Quality (NCDWQ) issuance of a Sechon 401 Water Quality Cerhficarion to Martm Manetta Matenals Inc associated wrth the development of a 649 acre open pit aggregate mme on the Craven Beaufort County border North Carolma We have reviewed the public notice posted by the U S Army Corps of Engmeers (Corps) and we have senous concerns on the environmental impact of this mme on Blounts Creek In particular we re concerned about the 9 million gallons per day or 3 2 BILLION gallons per year of fresh water being discharged mto Blounts Creek for the next 50 years Blounts Creek consists of large areas of estuanne wetlands that are very sensrtive to changes m saliruty Havmg lived on Little Creek a Biounts Creek tnbutary and bordered almost entirely by wetlands on both sides the sensrt�vrty to salimty is obvious In drought years the environment is nearly a true saltwater environment wrth �ellyfish bottle nosed dolphm manatee and other saltwater species �ommg the abundant menhaden sea mullet crab flounder and speckled trout populat�ons In recent yeazs several pods of bottle nosed dolphm have used the remote areas of Blounts Creek to give birth to their young In ramy years it is still somewhat salme with abundant crabs flounder and speckled trout, but other species declme This effect can also be seen on a week by week basis when stormy weather passes through The bottom l�ne is that th�s is a d�verse and sensitive estuary and changes m salimty make a huge difference in the ecosystem and is observable by residents along the creek More importantly these large changes are a part of the natural ecosystem and the diversity is natural Blounts Creek flow is almost exclus�vely ramfall and the changes discussed above are a result from day to day week to week and year to year vanations m that ramfall wrth the key word bemg vanations The tmportant fact ts that when there is no rainfall there �s v�rtually no freshwater flow and the slight ridal effect on the creek replemshes the salmrty as well as feedmg and nounshmg the estuary What happens when a constant flow of 3 2 BILLION gallons per year is mtroduced� It doesn t take a mathematic�an to see that 9 million gallons of fresh water flow every day 365 days per year for the next 50 years wtll essentially turn this creek mto a freshwater creek North Carolma has many many freshwater creeks streams and nvers from the mountams to the coast However the micro estuary wrthm Blounts Creek is relatrvely umque There is a range of estuanes wrth varymg salmrties up the several North Carohna nvers wrth salmity decreasmg each mile farther up the nver Wrthm the Pamlico Tar River there is little saliruty upstream of Washmgton NC So the numbers of estuanes wrth the temperature and salmrty charactenstics of Blounts Creek are very few within North Carohna Edward and Gloria Stafford Page 2 of 3 What effect would changmg the estuanne charactenstics have on Blounts Creek� We are not biological scientists but we can say that from a practical standpomt, we 11 no longer be able to see our healthy population of Bald Eagles feed on menhaden and mullet That effect alone would meet the defimtion and mtent of the disturbmg the eagle population as defined m the Code of Federal Regulations sect�on 50 part 22 (SOCFR22) Protect�on of Eagles which says D�sturb means to agitate or bother a bald or golden eagle to a degree that causes or is likely to cause based on the best sc�entific mformahon ava�lable (1) m�ury to an eagle (2) a decrease m rts productivity by substantially mterfenng wrth normal breedmg feedmg or sheltenng behavior or (3) nest abandonment, by substantially mterfenng wrth normal breedmg feedmg or sheltenng behavior' We believe that any adverse effect to the menhaden OR the mullet we see the eagles feedmg on all the time will substantially mterfere with their normal feedmg behavior Yet, we do not see any mention of this m the permrt apphcation Further we see m the perm�t request with the Corps where Martm Marietta Matenals Inc has stated that they don t believe they are tmpactmg any endangered species by the placement of the mme but they provide no details and there are endangered or threatened species mdigenous to the type of estuanne ecosystem wrthin Blounts Creek Has Martm Manetta Matenals Inc actually looked m Blounts Creek or have they �ust looked at the specific s�te location with no consideration of the effects downstream� Biounts Creek is part of the waters listed on the U S Fish and Wildl�fe Service s map of places the endangered Kemp s Rtdley sea turtle is known to or is bel�eved to occur Accordmg to a s�mple web search there have been several sightmgs of this endangered species as far up the nver as Bath Creek and Blounts Creek is the next creek up the nver The mformation we found on the web is about 6 years old so there may have been even more sight�ngs smce then We realize that these endangered turtles usually nest on our coastlmes however smce there are several documented sightmgs well up the Paml�co River you can t �ust totally rule them out without even looking for them 'There is a remote chance that new nestmg patterns could be evolvmg and Blounts Bay has several surtable and remote beach areas We request that smce the endangered Kemp s Ridley sea turtle has defimtely been srted and caught m nets m the Pamlico River wrthm approximately 10 mtles of Blounts Bay Martm Manetta Matenals Inc w�th mdependent overs�ght, study and publish the potenrial effects of the wastewater discharge of the proposed mme on Blounts Creek that might have adverse effects on tlus endangered species A more common visrtor to Blounts Creek dunng the summer is the federally endangered West Indian Manatee While we have not personally seen them several of our ne�ghbors have spotted them m Blounts Creek and they are listed as visrtors to our area on the U S Ftsh and Wildltfe Service s map of places the endangered West Indian Manatee is known to or is believed to occur Yet, agam we see no mention of this endangered species m the permit application with the Corps What effect will 3 2 Bill�on gallons of water per yeaz have on the habrtat they travel so far to forage tn� The Corps public notice states that they consider the econom�c tradeoffs of �ssuance of a permrt and we would assume that you would make the same considerations Any boater commg m and out of Blounts Creek can tell you that there is a huge crabbmg mdustry that works throughout Blounts Bay nght up to the border between coastal and mland waters at the mouth of Blounts Creek Agam, there s no menrion of what that 3 2 BILLION additional gallons of fresh water exitmg the mouth of the creek annually will do the crab population m Blounts Bay but we are certam that you will not find a scientist anywhere that will tell you rt will help the crab population Our North Cazolma crab mdustry is strong mdustry but they can t handle challenges to their livelihood However we see no mentton of the economic stress this wastewater will cause to the crab migrations upstream each summer Accordmg to a recent Washmgton Daily News article Martm Manetta Matenals Inc filmgs stated that (b)ecause of the type of facility proposed and extensive dtsturbance required the wetland and water impacts are unavoidable but we don t bei�eve for a mmute that the true extent of the wetland and water impacts have been documented It further stated that Martm Manetta Matenals Inc mamtams the alternatives that were considered were determmed to be �mpracticable We would mamtam that dumping 3 2 BILLION gallons of water Edward and Glona Stafford Page 3 of 3 annually down Blounts Creek is impracticable We thmk our neighbors on Blounts Creek along with the crabbmg mdustry m Beaufort County would agree Finally we believe that eastern North Carolma needs this quarry It is a quarry for road buildmg and we certamly need a considerable amount of road repair around here We can understand the economic tradeoffs of the sitmg of the mme and we don t have ob�ections for this srtmg other than the 3 2 BILLION gallons per year of fresh water proposed for Blounts Creek (or any other estuary m the area) In lookmg at the very first paragraph of the Corps notice we don t understand how the Corps can allow a permtt apphcat�on to progress this far with the intent bemg to ask the Corps for authonzation to impact a specific location but not consider the impact of the estuary downstream Is there some other permit application from Martm Manetta Matenals Inc to authorize the impact to Blounts Creek� Is this the appl�cation wtth the NCDWQ� This is not descnbed m the Corps pubhc notice Based on the mformation we have at this pomt we would propose that the NCDWQ not issue a Section 401 Water Quality Certification to Martm Manetta Matenals Inc unless they change their plan to pump wastewater from the quarry via pipelme directly to mto the Pamlico or Neuse Rivers whichever is more economically feasible for Martm Manetta Matenals Inc The large freshwater flow in these nvers would likely not be affected by the quantity of water proposed But this �s �ust one idea We humbly request the NCDWQ to strongly consider our arguments above We also request that the NCDWQ set up one or more public heanngs to get the thoughts of other concerned crtizens as th�s ts the first many of our neighbors along Blounts Creek have heard of this and many have said to us that they would like to be heard We're sure that the recreat�onal fishermen from all over the state that consider Blounts Creek to be one of the best fishmg spots m eastern North Carolina would also have somethmg to say about turnmg our creek mto a freshwater creek Finally the economic impact to the Blue Crab mdustry would be high on many crabbers mmds On a side note we real�ze the letter of the law has been met m Martm Marietta Matenals Inc permrt applicat�on but we question the timmg of requestmg a comment penod over the biggest hol�day season of the year with the last day of comments endmg on New Years Eve We only found out about this permit application through a story in the Washmgton Daily News and that wasn t published unttl December 21 2011 We have quickly summarized our concerns above based on some quick and prelimmary web searches we would certamly ltke more time to research the potentially far reachmg effects of ttus invasion of fresh water mto Blounts Creek We request that the NCDWQ respond to Martm Manetta Matenals Inc with a demal of the 401 Water Qual�ty Certification based on the potential devastatmg effects of the proposed constant fresh water mfluent In closmg we really don t want Blounts Creek to be transformed mto a wastewater dramage drtch for Martm Martetta Matenals Inc Any help you can provide is apprec�ated Smcerely � Edward A 5tafford .��1 ' '� � �'� �'' � � � •� '1 Glona B Stafford