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Home My WebLink About20111013 Ver 1_Public Comments_20111229Edward and Glona Stafford 711 Island Dnve Chocowinrty North Carolma 27817 December 26 2011 Mr Ian McMillan North Carolma Division of Water Qualrty 1650 Mail Sernce Cerner Raleigh, North Cazohna 27699 1650 Reference US Army Corps Of Engmeers Action ID# SAW 2011 02235 Mr 1VIcMillan II-1��3 Lr�� 0 �� QV �EC � �� D Z� �� S�ANpsT �RQ�q(�Ty'l �R,��R�H We aze wntmg to oppose the North Caroluia l?ivision of Water Quahty (NCDWQ) issuance of a Section 401 Water Quality Cerhfication to Marhn Manetta Matenals Inc associated wrth the development of a 649 acre open prt aggregate mme on the Craven-Beaufort Coimty border North Carolma We have reviewed the pubhc notice p�ted by the U S Army Corps of Engineers (Corps) and we have senous concems on the environmental unpact of th�s nune on Blounts Creek In particulaz we re concemed about the 9 milhon gallons per day or 3 2 BII.LION gallons per year of fresh waler bemg discharged urto Blourns Creek for ihe nea�t 50 years Blounts Creek consists of large areas of estuanne wetlands thax are very sensrtive to changes m saluuty Havmg hved on Lrttle Creek, a Blourns Creek tnbutary and bordered almost ernirely by wetlands on both sides the sensit�vrty to saluuty is obv�ous In drought years the envuonment �s nearly a true saltwater envuonment, wrth �ellyfish, bottle nased dolphm, manatee and other saltwater species �ommg the abundant menhadeq sea mullet, crab flounder and speckled trout papulahons In recent years several pocls of bottle nosed dolplun have used the remote azeas of Blounts Creek to give b�rth to theu young In ramy years rt�s shll somewhat saUne wrth abundam crabs flounder and speckled trout, but other species dechne Tlvs effect can also be seen on a week-by-week bas�s when stormy weather passes through The bottom lme is that tlus �s a diverse and sensihve estuary and changes in salinity make a huge difference m the ecosystem and is observable by residents along the creek More unportantly these large changes are a part of the natural ecosystem, and the d�versrty �s natural Blounts Creek flow �s a.lmost efcclusively rau�►fall, and the changes discussed above aze a result from da.y to da.y week to-week, and year to-year vanations m that ra.mfall wrth the key word bemg vanations The important fact is that when there is no ramfall there is vutually no freshwater flow and the shght tidal effect on the creek reple�ushes the saluuty as well as f+eed�ng and nounslung the estuary What happens when a constant flow of 3 2 BILLION gallons per year �s mtroduced� It doesn t take a mathematician to see that 9 rrulhon gallons of fire,sh water flow every day 365 days per year for the next 50 years will essent�ally tum tlus creek uito a freshwater creek North Carohna has many many freshwater creeks streazns and nve� from the mountasns to the coast However the rrucro-estuary wrth�n Blounts Creek �s relat�vely unique There is a range of estuanes wrth varymg sahmbes up the several IVor�h Cazolina nvers wnh salmrty decreasmg e,ach nule farther up the nver Wrtiun the Pamhco-Tar Rrver there is lrttle sal�nrty upstream of Washmgton, NC So the numbers of estuanes v�nth the temperature and sahmty charactenshcs of Blounts Creek are very few wrthm North Carolu�a Edward and Glona Stafford Page 2 of 3 What effect would changmg the estuanne charactensrics have on Blounts Creek� We are not biological scientists but we can say tbat from a prachcal standpourt, we Il no Ionger be able to see our heaithy populatron of Bald Eagles fced on menhaden and mullet That effect alone would meet the defimhon and mtent of the disturbmg the eagle populaUon as defined m the Code of Federal Regulations secUon 50 part 22 (SOCFR22) Protection of Eagles wluch says "Disturb means to agrtate or bother a bald or gotden eagle to a degree that causes or is likely to cause based on the best scientific uiformat�on avazlable (1) m�ury to an eagle (2) a decrease m rts producUvrty by substanUally mterfenng with normal breed�ng feedmg, or sheltenng behavior or (3) nest abandonment, by substantlally irrterfenng wrth normal breedmg feed�ng, or sheltering behavior' We beheve t�at any adverse effect to the menhaden OR the mullet we see the eagles feed�ng on all the tune will substantYally mterfere with theu normal feedmg behavior Yet, we do not see any menrion of tlus m the pernut appvcat�on Further we see m the pernut request wrth the Coips where Martin Manetta Matenals Inc has stated that they don t beheve they are unpachng any endangered species by the placement of the muie but they provide no details and there are endangered or threaiened sgec�es md�genous to the type of estuarme ecosystem wrthm Blourns Creek Has Martm Manetta Matenals Inc actually looked in Blouirts Creek, or have they �ust looked at the specific srte IocaUon, wrth no considerahon of the effects downstream� Blourrts Creek is part of the waters listed on the U S F�sh and Wildlife Service s map of places the enda.ngered Kemp's Ridley sea turtle is known to or is heheved to �cur Accordmg to a simple web search, there have been several sight�ngs of ttus endangered species as faz up the nver as Bath Creek, and Blounts Creek �s the next creek up the nver The inforination we found on the web is about 6 years old, so there may have been even more sightmgs smce then We reahze that these endangered turtles usually nest on our coastlmes however since there are several documented s�ghtings well up the Pamhco River you can t �ust totally rule them out w�thout even lookmg for them There �s a remate chance that new nest�ng patterns could be evolving, and Blou�s Bay has several swtable and remote beach areas We request that su►ce the endangered Kemp s Ridley sea turtle has defimtely been srted and caught m nets m the Pamhco Rrver withm approximately 10 miles of Blounts Bay Martm Manetta Matenals Inc with mdependern oversight study and pubhsh the pate�al effects of the wastewater discharge of the proposed mme on Blounts Creek that trught have adverse effects on this endangered species A more common visrtor to Blourts Creek durmg the summer �s the federally endangered West Indian Manatee Wlule we have not personally seen them several of our ne�ghbors have spatted them m Blouirts Creek, and they are hsted as visrtors to our area on the U S F�sh and Wildlife Service s map of places the endangered West Indian Manatee �s known to or �s behev� to occur Yet, agaiq we see no menhon of tlus enda.ngered species m the germrt apphcabon vvrth the Corps What effect will 3 2 Bill�on gallons of water per year have on the habrtat they travel so far to forage �n� The Corps pubhc notice state.s that they consider the econoiruc tradeoffs of issuance of a pernut, and we would assume that you would make the same consideraLons Any boater commg m and out of Blounts Creek can tell you that there is a huge c�abbmg mdustry that works throughout Blounts Bay nght up to the border between coastal and mland waters at the mouth of Bloums Creek Agam, there s no mention of what tha.t 3 2 BILLION addrtional gallons of &esh water ex�tmg the mouth of the creek annually will do the crab populahon in Blounts Bay but we are certasn that you will nat find a scientist anywhere that will tell you rt will help the crab population Our North Carolma crab mdustry is strong mdustry but they can t handle challenges to theu hvelihood However we see no menhon of the econorruc stress tlus wastewater will cause to the crab m►grahons upstream each summer Accord►ng to a recent Wastungton Daily News asticle Marhn Manetta Matenals Inc filmgs stated that (b�Cause of the type of fa.cihty proposed and e�rtensive d�sturbance reyu�red, the wetland aiad water unpacts are unavoidable but we don t beheve for a rrunute that the true extern of the wetland and water �rnpacts have been documented It further stated that Marhn ARarietta Matenals Inc mamtau�s the altematives that were considered were deternuned to be unprachcable We would ma.intam that dumping 3 2 BILLION gallons of water Edward and Glona Stafford Page 3 of 3 a.nnually down Blounts Creek is unpracUc�ble We thmk our ne�ghbors on Blowrts Creek, along wrth the crabbuig mdustry m Beaufort Courny would agree Finally we beheve that eastem North Carolma ne�ds this quarry It �s a quarry for raad bwlduig and we certaanly need a considerable amount of road repau around here We can understand the economic tradeoffs of the sihng of the rrune and we don't have ob�ect�ons for tivs sihng other than the 3 2 BILLION gallons per year of fresh water proposed for Blourns Creek (or any other estuary m the azea) In loolang at the very first paragraph of the Corps notYCe we don t understand how the Corps can allow a permrt apphcarion to progress ttus far vv�th the urteirt bemg to ask the Corps for authonzation to unpact a specific location but not consider the impact" of the estuary downstream Is there some other pernut appl�caUon from Mamn Manetta Matenals Inc to authonze the impact to Blounts Creek� Is tlus the apphcahon v�nth the NCDWQ� This �s not descnbed m the Corps pubhc notice Based on the mformabon we have at this pourt, we wauld propase that the NCDWQ not �ssue a Section 401 Water Qual�ty CerhficaUon to Marhn Maneaa Matenals Inc unless they change their plan to pump wastewater from the quarry via pipehne directly to mto the Pamlico or Neuse Rivers wluchever is more econoirucally feasible for Martm Manetta Matenals Inc The large freshwater flow m these nvers would Iikely not be affected by the quantity of water proposed But this is �ust one �dea We humbly request the NCDWQ to strongly cons�der our argumetrts above We also request that the NCDWQ set up one or more public hearuigs to get the thoughts of other concerned crtizens as tlus is the first many of our neighbors along Blounts Creek have heard of tlus and many have said to us that they would hke to be heard We re sure that the recreaUonal fishermen from all over the state that cons�der Blounts Creek to be one of the best fishu►g spots m eastern North Cazolma would also have somethmg to say about turmng our creek mto a freshwater crcek Fu�ally the econonuc unpact to the Blue Crab industry would be lugh on many crabbers mmds On a side note we realize the letter of the law has been met m Martm Manetta Matenals Inc pemut apphca.tion, but we question the timmg of requesting a commem penod over the biggest holiday season of the year vcnth the last day of commems enduig on New Years Eve We only found out about tlus pernut apphcahon through a story in the Washington Daily News and tbat wasn t pubhshed unhl December 21 2011 We have quickly summanzed our concerns abave based on some quick and prehmmary web searches we would certamly like more time to research the pote�ally far-reaclung effects of tlus mvasion of fresh water mto Blounts Creek We request that the NCDWQ respond to Marhn Manetta Matenals Inc wrth a denial of the 401 Water Qualrty Cemfic�oq based on the potenhal devastatmg effects of the proposed constant fresh water mfluern In closmg we really don t want Blounts Creek to be transformed mto a wastewater dramage drtch for Martm Manetta. Matenals Inc Any help you can provide �s appreciated Smcerely Edward A Stafford Glona B Stafford