20111013 Ver 1_Public Comments_20120118

Strickland, Bev
From: Mcmillan, Ian
Sent: Wednesday, January 18, 2012 3:21 PM
To: Strickland, Bev; Dennison, Laurie
Subject: FW: Martin Marietta Materials, Inc.
Attachments: 404-401—Martin Marietta Vanceboro Final.pdf
DWQ 11 -1013
Ian J. McMillan, PWS, GISP
NCDENR/Division of Water Quality - Wetlands and Stormwater Branch
1650 Mail Service Center
Raleigh, NC 27699 -1650
Office: (919) 807 -6364
Fag: (919) 807 -6494
Email: ian.mcmillan.denr(a�,gmail.com SENT TO MY PHONE
Email: ian.mcmillan(a�,ncdenr.gov
E -mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Dunn, Maria T.
Sent: Wednesday, January 18, 2012 1:38 PM
To: William .G.WescottCa)usace.army.mil; Mcmillan, Ian
Cc: Homan, Justin M.; Wynne, Bennett; Hart, Kevin
Subject: Martin Marietta Materials, Inc.
William and Ian,
Please accept the attached comments for the Martin Marietta Materials, Inc. project located in Beaufort and Craven
Counties. If you have any comments or questions, please give David Cox or myself a call.
Thank you.
Maria
Maria T. Dunn, NE Permit Coordinator
North Carolina Wildlife Resources Commission
943 Washington Square Mall, Washington, NC 27889
(252) 948 -3916 / www.ncwildlife.org
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.

rr�
IQ North Carolina Wildlife Resources Commission IQ
Gordon Myers, Executive Director
MEMORANDUM
TO: William Wescott
Washington Field Office
US Army Corps of Engineers
And
Ian McMillan
NC Division of Water Quality
FROM: David R. Cox, Technical Guidance Supervisor
Habitat Conservation Program
DATE: January 18, 2012
SUBJECT: Comments on Public Notice for Section 404 Permit Application for Martin
Marietta Materials, Inc., Beaufort and Craven Counties, North Carolina.
SAW 2001 -02235
DWQ No 20111013
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
public notice and permit application with regard to impacts on fish and wildlife resources. The
project site is located approximately seven miles east of US Hwy 17 on the Beaufort- Craven
County border between the communities of Wilmar, NC and Blounts Creek, NC. The site is
located on the drainage basin divide between the Neuse River and Tar - Pamlico River Basins.
Our comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U. S.C. 661 et seq.), Sections 401 and 404 of the Clean Water
Act (as amended), and Coastal Area Management Act (G.S. 113A -100 through 113A -128), as
amended.
The applicant, Martin Marietta Materials, Inc. proposes to develop a 649 acre open pit
aggregate mine within a 1,664 acre project area. The site is currently owned and managed by the
Weyerhaeuser Corporation for the silviculture of loblolly pine. Impacts associated with the direct
mining of the land include permanent impacts to 6.69 acres of wetlands and 58,671 linear feet of
jurisdictional ditches. To mitigate for the proposed wetland impacts, the applicant proposes to
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

Martin Marietta Materials, Inc. Page 2 January 18, 2012
restore 6.75 acres of non - riparian wetlands via payment into the North Carolina Ecosystem
Enhancement Program (NCEEP). In addition to Section 404 and Section 401 permits, a NPDES
permit will be pursued to discharge water pumped from the Castle Hayne aquifer into the
headwater system of Blounts Creek in the Tar - Pamlico Basin. The proposed facility may be
operational for 50 years. The waters of Blounts Creek are classified C, Sw, NSW by the
Environmental Management Commission, are subject to the Tar - Pamlico Basin Buffer Rules,
and are designated an anadromous fish spawning area (AFSA) by the NC Wildlife Resources
Commission.
The NCWRC has reviewed the information provided in the Public Notice and permit
application. We do not believe the mining of 6.69 acres of wetlands and impact to 58,671 linear
feet of jurisdictional ditches will have significant adverse impacts to wildlife resources as
proposed. Generally the NCWRC prefers on -site and in -kind mitigation for impacts rather than a
purchase of credits toward mitigation. Therefore, we request the mitigation ratio be raised from
an approximate 1:1 credit purchase to a 2:1 purchase for the unavoidable wetland impacts within
the mining area.
In addition to the impacts to the above mentioned wetlands and jurisdictional ditches, we
believe the project will impact the riparian wetlands and waters of Blounts Creek with the
discharge of significant aquifer waters from the mine operation. A Geomorphic and Hydraulic
Analysis prepared by Kimley -Horn and dated July 14, 2010 states that a dewatering discharge of
12 MGD has been assumed for the build -out condition of the mine. An introduction of 12 MGD
of water may significantly impact Blounts Creek by many aspects including substantial now
increases, introduction of higher metal concentrations, a decrease in salinity and conductivity,
elevation of pH, an overall change to the geomorphology of the head water system, and potential
conversion of riparian wetlands from brackish to more fresh. All of these factors lead to a change
in habitat and ability of aquatic species to utilize habitats currently available.
Blounts Creek is a system that supports numerous and varied fish species including
striped bass, largemouth bass, yellow perch, black crappie, catfish, American eel, various shad
species, and sometimes flounder and sea trout. These fish utilize Blounts Creek seasonally
depending on water temperatures and water column parameters such as salinity. Due to the
variety of gamefish and other popularly sought fish, Blounts Creek is heavily used by
recreational fishermen. A change in the flow and water chemistry of the creek may discourage
several species from using the creek and therefore impact a public resource. In addition to
providing habitat to important gamefish, Blounts Creek is a designated anadromous fish
spawning area. This designation means conditions are present and favorable to provide spawning
opportunities for anadromous fish such as striped bass and blueback herring, a species of fish
historically found in this system. The direct introduction of such flow would likely move the
fresh -salt barrier downstream, inhibiting access of these species to the hard bottom wetlands and
headwater habitats they require to spawn. This change could be especially detrimental to
blueback herring, a species under such population stress that the NC Division of Marine
Fisheries and the NCWRC currently do not allow harvest of this species in an effort to increase
population numbers. Other measures considered to potentially help these populations include

Martin Marietta Materials, Inc. Page 3 January 18, 2012
habitat restoration. Habitat restoration would likely focus on areas of historical use, such as
Blounts Creek to increase the chance of success.
In order to better assess impacts that such a large project would have to the wetlands and
surface waters of the Blounts Creek system, the NCWRC requests the following information be
provided:
— The applicant has submitted data from a single fish sampling event and determined that
there would be no impacts to aquatic species with the project as proposed. We do not
believe a one day backpack shocking and fyke net event can describe the ecology of this
system. Important species such as striped bass and American eel, a federal species of
concern, have recently been sampled in the system by others. Blueback herring may also
be present, but due to low population numbers are difficult to find. Our concerns
regarding the spawning of anadromous species cannot be addressed with the submitted
sampling event due to the absence of egg, larvae, and juvenile sampling. In order to
understand the impacts this proposed project may have on wildlife resources, we need
multi -stage aquatic resource data from the site to better represent the extent of existing
habitats and how they are utilized.
— The headwater system of Blounts Creek may be dry during certain seasons. The
discharge of water directly to the system could significantly increase the amount of water
in the headwaters. This hydrologic transition is exacerbated with the discharge occurring
year round with no infiltration or evapotranspiration of water through the watershed. In
order to understand how this change in discharge will impact wildlife resources, the
project proposal should include a pre and post hydrologic curve.
— The mining project is located on the Neuse Basin and Tar - Pamlico Basin divide.
Depending on withdrawals, an inner basin transfer (IBT) may be necessary. IBTs involve
a variety of wildlife resources impacts that would need to be incorporated with this
project proposal. If applicable, this information should be provided and calculated at
maximum build out discharge.
— With the additional water from this project, riparian areas may be flooded, potentially
reducing the area of the Tar - Pamlico buffer or extending the creek's banks onto private
properties. Additional natural factors that could contribute to these habitat changes
include large storm events and debris jams or beaver dams. The impact of these changes
on wildlife resources should be considered but require additional information related to
the increased creek volume and its reach downstream.
— Potential impacts to habitats and aquatic resources are not limited to increased water
flows and decreased salinities. Fluctuations in other parameters such as pH and minerals
may also occur. Changes in these parameters will likely introduce more algal blooms and
fish kills. Available information on discharge chemical concentrations and ambient creek
conditions should be provided to assist with these considerations.

Martin Marietta Materials, Inc. Page 4 January 18, 2012
— Impacts to wetland and aquatic resources should be avoided if at all possible, then
minimized, or mitigated for if other alternatives are not feasible. Avoidance and
minimization of impacts to the Blounts Creek system could be demonstrated if the
discharge water did not have to be introduced to surface water, such as a conversion to a
potable resource. Eliminating or reducing the discharge may address most of the concerns
regarding wildlife resources.
The NCWRC appreciates the opportunity to review and comment on this permit application. If
you need further assistance or additional information, please contact me by phone at ((919) 528-
9886 or email at david.cox @ncwildlife.org.
ec: Kevin Hart, NCDMF
Bennett Wynne, NCWRC
Justin Homan, NCWRC