The URL can be used to link to this page

Home My WebLink About20111013 Ver 1_Public Comments_20120103Residents of the Bay Harbour Community c/o Dave McFarland President 100 Bayview Drive Chocowinity, North Carolina 27817 9133 December 27 2011 Mr Ian McMillan North Carolina Division of Water Quality 1650 Mail Service Center Raleigh NC 27699 1650 Reference US Army Corps of Engineers Action ID # SAW 2011 02235 Dear Mr McMillan AN 4 2012 kkJoS AND STORM, q ER BRANCH We the undersigned are writing to oppose the North Carolina Division of Water Quality (NCDWQ) issuance of a Section 401 Water Quality Certification to Martin Marietta Materials, Inc associated with the development of a 649 acre open pit aggregate mine on the Craven Beaufort County border North Carolina We have reviewed the public notice posted by the U S Army Corps of Engineers (Corps) and we have serious concerns on the environmental impact of this mine 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 into Blounts Creek for the next 50 years Blounts Creek consists of large areas of estuarine wetlands that are very sensitive to changes in salinity Living on Blounts Creek tributary which is bordered almost entirely by wetlands on both sides the sensitivity to salinity is obvious In drought years the environment is nearly a true saltwater environment, with jellyfish, bottle nosed dolphin manatee and other saltwater species jommg the abundant menhaden sea mullet, crab, flounder and speckled trout populations In recent years several pods of bottle nosed dolphin have used the remote areas of Blounts Creek to give birth to their young In rainy years, it is still somewhat saline with abundant crabs flounder and speckled trout, but other species decline This effect can also be seen on a week by week basis when stormy weather passes through The bottom line is that this is a diverse and sensitive estuary and changes in salinity 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 exclusively rainfall and the changes discussed above are a result from day today week to -week, and year to-year variations in that rainfall with the key word being variations The important fact is that when there is no rainfall there is virtually no freshwater flow and the slight tidal effect on the creek replenishes the salinity as well as feeding and nourishing the estuary What happens when a constant flow of 3 2 BILLION gallons per year is introduced? It doesn t take a mathematician to see that 9 million gallons of fresh water flow every day, 365 days per year for the next 50 years will essentially turn this creek into a freshwater creek North Carolina has many, many freshwater creeks, streams, and rivers, from the mountains to the coast However the micro- estuary within Blounts Creek is relatively unique There is a range of estuaries with varying salinities up the several North Carolina rivers, with salinity decreasing each mile farther up the river Within the Pamlico-Tar River there is little salinity upstream of Washington NC So the numbers of estuaries with the temperature and salinity characteristics of Blounts Creek are very few within North Carolina What effect would changing the estuarine characteristics have on Blounts Creek9 We are not biological scientists, but we can say that from a practical standpoint 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 definition and intent of the disturbing the eagle population as defined in the Code of Federal Regulations section 50 part 22 (50CFR22) "Protection of Eagles' which says 'Disturb means to agitate or bother a bald or golden eagle to a degree that causes or is likely to cause based on the best scientific information available, (1) mjury to an eagle, (2) a decrease in its productivity by substantially interfering with normal breeding feeding or sheltering behavior or (3) nest abandonment, by substantially interfering with normal breeding, feeding, or sheltering behavior " We believe that any adverse effect to the menhaden OR the mullet we see the eagles feeding on all the time will substantially interfere with their normal feeding behavior Yet, we do not see any mention of this in the permit application Further, we see in the permit request with the Corps where Martin Marietta Materials Inc has stated that they don t believe they are impacting any endangered species by the placement of the mine but they provide no details and there are endangered or threatened species indigenous to the type of estuarine ecosystem within Blounts Creek Has Martin Marietta Materials Inc actually looked in Blounts Creek, or have they just looked at the specific site location with no consideration of the effects downstream9 Blounts Creek is part of the waters listed on the U S Fish and Wildlife Service s map of places the endangered Kemp s Ridley sea turtle is known to or is believed to occur According to a simple web search there have been several snghtmgs of this endangered species as far up the river as Bath Creek, and Blounts Creek is the next creek up the river The information we found on the web is about 6 years old so there may have been even more snghtmgs since then We realize that these endangered turtles usually nest on our coastlines however since there are several documented snghtmgs well up the Pamlico River you can trust totally rule them out without even looking for them There is a remote chance that new nesting patterns could be evolving and Blounts Bay has several suitable and remote beach areas We request that since the endangered Kemp s Ridley sea turtle has definitely been sited and caught in nets in the Pamlico River within approximately 10 miles of Blounts Bay, Martin Marietta Materials Inc with independent oversight, study and publish the potential effects of the wastewater discharge of the proposed mine on Blounts Creek that might have adverse effects on this endangered species A more common visitor to Blounts Creek during the summer is the federally endangered West Indian Manatee While we have not personally seen them several of our neighbors have spotted them in Blounts Creek, and they are listed as visitors to our area on the U S Fish and Wildlife Service s map of places the endangered West Indian Manatee is known to or is believed to occur Yet, again we see no mention of this endangered species in the permit application with the Corps What effect will 2 Billion gallons of water per year have on the habitat they travel so far to forage in? The Corps public notice states that they consider the economic tradeoffs of issuance of a permit, and we would assume that you would make the same considerations Any boater coming in and out of Blounts Creek can tell you that there is a huge crabbing industry that works throughout Blounts Bay right up to the border between coastal and inland waters at the mouth of Blounts Creek Again, there s no mention of what that 3 2 BILLION additional gallons of fresh water exiting the mouth of the creek annually will do the crab population in Blounts Bay but we are certain that you will not fmd a scientist anywhere that will tell you it will help the crab population Our North Carolina crab industry is strong industry but they can t handle challenges to their livelihood However we see no mention of the economic stress this wastewater will cause to the crab migrations upstream each summer According to a recent Washington Daily News article Martin Marietta Materials Inc filings stated that (b)ecause of the type of facility proposed and extensive disturbance required, the wetland and water impacts are unavoidable, but we � don t believe for a mmute that the true extent of the wetland and water impacts have been documented It further stated that Martin Marietta Materials, Inc maintains the alternatives that were considered were determined to be impracticable We would maintain that dumping 3 2 BILLION gallons of water annually down Blounts Creek is impracticable We think our neighbors on Blounts Creek, along with the crabbing industry in Beaufort County would agree Finally, we believe that eastern North Carolina needs this quarry It is a quarry for road building and we certainly need a considerable amount of road repair around here We can understand the economic tradeoffs of the siting of the mine and we don t have objections for this srtmg other than the 3 2 BILLION gallons per year of fresh water proposed for Blounts Creek (or any other estuary in the area) In looking at the very first paragraph of the Corps notice we don t understand how the Corps can allow a permit application to progress this far with the intent being to ask the Corps for authorization to "impact" a specific location, but not consider the impact of the estuary downstream Is there some other permit application from Martin Marietta Materials Inc to authorize the "impact to Blounts Creek9 Is this the application with the NCDWQ9 This is not described in the Corps public notice Based on the information we have at this point, we would propose that the NCDWQ not issue a Section 401 Water Quality Certification to Martin Marietta Materials, Inc, unless they change their plan to pump wastewater from the quarry via pipeline directly to into the Pamlico or Neuse Rivers, whichever is more economically feasible for Martin Marietta Materials, Inc The large freshwater flow in these rivers would likely not be affected by the quantity of water proposed But this is just 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 hearings to get the thoughts of other concerned citizens as this is 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 recreational fishermen from all over the state that consider Blounts Creek to be one of the best fishing spots in eastern North Carolina would also have something to say about turning our creek into a freshwater creek Finally the economic impact to the Blue Crab industry would be high on many crabbers mmds On a side note we realize the letter of the law has been met in Martin Marietta Materials, Inc permit application but we question the timing of requesting a comment period over the biggest holiday season of the year with the last day of comments ending on New Years Eve We only found out about this permit application through a story in the Washington Daily News and that wasn t published until December 21 2011 We have quickly summarized our concerns above based on some quick and preliminary web searches we would certainly like more time to research the potentially far reaching effects of this invasion of fresh water into Blounts Creek We request that the NCDWQ respond to Martin Marietta Matenals, Inc, with a denial of the 401 Water Quality Certification, based on the potential devastating effects of the proposed constant fresh water influent. Please don t allow Blounts Creek to be transformed into a wastewater drainage ditch for Martin Marietta Materials Inc i We enjoy this region because of the beauty of the Creek and its wildlife and with this mming/quarry operation in place that will all be gone Please stop this permit and development of this operation Sincerely 1 1 IS r f a ( 1 3 5 ) S 3 } 1 3 1 € { I t S) t 1 )Y t f f s t 7 f � It 4 S F { r t F { l 4 1 Sir L f ft ? t € S 7 t 7 S t i € ✓ 3 ; z f i J F � C ) J S ) ) a J s € Y t ) Si Print Name c�S�a�c�� A� n'UoMI� TAI �� C-1 5-+ 3 (.av\ �re.5ex J h k,,) S rl-,wc yy n 5//%3 Address SO0 Is�A.3 ,I /uI 1jmilr 4f�.� Gvev�r✓s�, ✓) c s` L P,, S Wa,+ers5 br ��I�C�Wrh►' lr Mary ROXahAQ Ueei"s O/fc( VeAj 64V K Ela-c h e Shur dd-k� /os whil-Its L;oGC VA C l e c (,/)A/) r ) /vc 7 -7 1,06- Watee.�, Ed je P r (Ac, .,w,, t /UG L, 4rx 5 KKR a7,517 561) I-lv,4-4,,9v,- i -i.ecv Dr 97 ,V17