20111013 Ver 2_Public Comments_20130411 (2)

Strickland, Bev
From: Karoly, Cyndi
Sent: Thursday, April 11, 2013 3:16 PM
To: Strickland, Bev
Subject: FW: Proposed Vanceboro Quarry Application
Attachments: 4 -11 -13 - Comments on Proposed Vanceboro Quarry Application.pdf
From: Robin Dunn [mailto:rdunnCa)selcnc.org]
Sent: Thursday, April 11, 2013 3:15 PM
To: Karoly, Cyndi
Cc: Geoff Gisler; Jack Dafoe; 'riverkeeper @ptrf.org'
Subject: Proposed Vanceboro Quarry Application
Ms. Karoly-
Please accept the attached comments on the proposed Vanceboro Quarry Application for a 401 Water Quality
Certification and Application for New NPDES Discharge Permit for Martin Marietta Materials, Inc. These comments are
being submitted on behalf of the Pamlico -Tar River Foundation. The original is being sent via US Mail.
Robin Dunn
Administrative Legal Assistant
North Carolina State Bar Certified Paralegal
Southern Environmental Law Center
601 West Rosemary St., Suite 220
Chapel Hill, NC 27516
(919) 967 -1450
rdunn .selcnc.org

SOUTHERN ENVIRONMENTAL LAW CENTER
Telephone 919 - 967 -1450 601 WEST ROSEMARY STREET, SUITE 220 Facsimile 919 - 929 -9421
CHAPEL HILL, NC 27516 -2356
April 11, 2013
Via US and Electronic Mail
Cyndi Karoly
Branch Manager, Wetlands and Stormwater Branch
N.C. Division of Water Quality
1650 Mail Service Center
Raleigh, NC 27699 -1650
Re: Martin Marietta Materials — Proposed Vanceboro Quarry Application for
401 Water Quality Certification and Application for New NPDES Discharge
Permit
Dear Ms. Karoly:
Please accept these comments on the draft permit to discharge wastewater under the
National Pollutant Discharge Elimination System ( "NPDES permit ") and the application for a
401 Water Quality Certification ( "water quality certification ") for Martin Marietta Materials, Inc.
( "MMM ") to discharge 9.0 MGD of mine dewatering wastewater from its Vanceboro quarry to
an unnamed tributary of Blounts Creek in the Tar - Pamlico River Basin. The Southern
Environmental Law Center ( "SELC ") submits these comments on behalf of the Pamlico -Tar
River Foundation ( "PTRF "). PTRF is a private, non - profit organization that has been dedicated
to protecting, preserving, and promoting the Tar - Pamlico River and its watershed since 1981.
SELC is a private, non - profit legal organization that seeks to protect and preserve the
Southeastern environment. These comments supplement separate comments submitted by PTRF
on March 14, 2013 ( "March 14 comments ").
Based on a review of studies submitted by MMM to the North Carolina Division of
Water Quality ( "DWQ "), the proposed discharge would violate state water quality standards. In
addition, MMM has failed to provide sufficient information to allow for proper review of the
water quality certification application. For these reasons, DWQ would be acting arbitrarily and
capriciously if it were to issue a final permit or a water quality certification for the proposed
discharge.
L The proposed discharge would violate state water quality standards.
The proposed discharge from MMM's quarry would violate state water quality standards
for two reasons.
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First, the proposed discharge would violate state water quality standards because it would
degrade an existing use of Blounts Creek by precluding maintenance of the creek's "biological
integrity." North Carolina's antidegradation rule states that a project "shall not be permitted
unless the existing uses are protected." 15A N.C. Admin. Code 02B .0201(b); 40 C.F.R.
§ 131.12(a)(1). In addition, 'DWQ may only issue a water quality certification when it
"determines water quality standards are met, including protection of existing uses." 15A N.C.
Admin. Code 02H .0506(a). As a Class C water, Blounts Creek is subject to a "best usage of
waters" narrative water quality standard, which provides that these waters "shall be suitable for
aquatic life propagation and maintenance of biological integrity, wildlife, secondary recreation,
and agriculture." 15A N.C. Admin. Code 02B .0211(2). Biological integrity is "the ability of
an aquatic ecosystem to support and maintain a balanced and indigenous community of
organisms having species composition, diversity, population densities and functional
organization similar to that of reference conditions." 15A N.C. Admin. Code 02B .0202(11)
(emphasis added). Under the "best usage of waters" standard, "[s]ources of water pollution
which [sic] preclude any of these uses on either a short-term or long -term basis shall be
considered to be violating a water quality standard." 15A N.C. Admin. Code 02B .0211(2).
Therefore, a discharge that precludes the maintenance of biological integrity is in violation of
state law. As discussed below, the proposed discharge will preclude the maintenance of
biological integrity by causing a change in the species composition of Blounts Creek on both a
short-term and a long -term basis.
As described in PTRF's March 14 comments, Blounts Creek is a coastal, blackwater
stream, a type of system that is naturally more acidic and more brackish (saline) than other
freshwater stream systems. The upper portion of Blounts Creek is secondarily classified as a
swamp water. Swamp waters ( "Sw ") are "waters which [sic] have low velocities and other
natural characteristics which [sic] are different from adjacent streams." 15A N.C. Admin. Code
0213.0101(e)(2). The natural characteristics of a swamp water— low flow, low concentrations
of dissolved oxygen, high concentrations of tannins, and low pH — are what create Blounts
Creek's particular habitat. These defining characteristics must be protected to maintain
biological integrity.
Blounts Creek is an aquatic nursery area for numerous species.I In particular, the creek
is used for spawning migrations and nursery areas by anadromous fish species, such as striped
bass, and the creek is a designated Anadromous Fish Spawning Area.2 Blounts Creek also
supports several anadromous fishes of interest to the National Marine Fisheries Service
( "NMFS "),3 as well as the facultatively catadromous American eel, a Federal species of
concern.4
' Letter from Kevin Hart (North Carolina Division of Marine Fisheries) to Ian McMillan (North Carolina Division of
Water Quality), January 3, 2012, at 1.
2 Letter from David R. Cox (North Carolina Wildlife Resources Commission) to William Wescott (US Army Corps
of Engineers) and Ian McMillan (DWQ), January 18, 2012, at 2.
3 See Letter from Heather Deck (Pamlico -Tar River Foundation) to Tom Belnick (DWQ), March 14, 2013, at 3.
4 USFWS Endangered Species, Threatened Species, Federal Species of Concern, and Candidate Species, Beaufort
County, North Carolina, available at http: / /www.fws.gov /raleigh /species /cntylistibeaufort.httnl (last visited April 9,
2013).

It is undisputed that the proposed discharge would change the water chemistry of Blounts
Creeks In fact, MMM's own consultants have projected that the discharge could change the
creek's water chemistry to the extent that the supplementary state classification of upper Blounts
Creek as a swamp water would no longer apply.6 If Blounts Creek were to lose the
characteristics of a swamp water, its biological integrity would be lost as well. The N.C.
Wildlife Resources Commission ( "NCWRC ") has predicted that just such a scenario could occur
if the discharge is approved. In general, changes in flow, salinity, pH, and metal concentrations
caused by the proposed discharge, and the "potential conversion of riparian wetlands from
brackish to more fresh," could "lead to a change in habitat" and "discourage several species from
using the creek. ,7 The NCWRC has also stated that the introduction of fresh water from the
proposed discharge "would likely move the fresh -salt barrier downstream, inhibiting access of
[anadromous fish species] to the hard bottom wetlands and headwater habitats they require to
spawn. "8 This could have an especially detrimental effect on the blueback herring, an imperiled
species that historically uses habitats like Blounts Creek.9 The North Carolina Division of
Marine Fisheries ( "NCDMF ") has stated that changes in salinity could reduce the presence of
speckled trout.10 Fluctuations in metals or pH could lead to more algal blooms and fish kills."
Potential changes in creek turbidity and nutrient composition could potentially affect fish species
by changing the extent or composition of Blounts Creek's submerged aquatic vegetation
( "SAV ") beds. 12
In its October 30, 2012, technical memorandum for MMM, CZR Incorporated ( "CZR "),
concludes that the change in water chemistry caused by the discharge could alter the creek's
species composition. For example, CZR states that the expected increase in pH "may provide
more suitable habitat (water column) for a more diverse realm of freshwater fish species [and]
may create more suitable habitat for ... all diadromous fish species." 13 They suggest that
changes in pH could have also have an unknown, unquantified effect on aquatic plant species. 14
Regarding salinity, CZR concludes that "[t]he addition of a constant input source of freshwater
from the upstream quarry dewatering outfall will likely move the salt wedge further downstream
in Blounts Creek," but states that this is not a major concern because fish species "are mobile"
and can move downstream. 15 Finally, regarding flow, CZR states that "[i]f both stream flow and
velocity increase ... then a potential compositional change may occur to the benthic invertebrates
inhabiting Blounts Creek [including a] change [in] the amounts and proportions of benthic
shredders and collector- gatherers." 16 In sum, the proposed discharge would disrupt existing fish,
5 Technical Memorandum. Stability, Flood, and Water Quality Analyses, Vanceboro Site, Martin Marietta
Materials, Craven and Beaufort Counties, North Carolina. Kimley -Horn and Associates, Inc. September 6, 2012
(4, 9, 12)
6 Technical Memorandum to address potential direct and indirect effects on identified fish populations from
predicted changes in Blounts Creek water quality. CZR Incorporated. October 30, 2012 (10).
7 Cox letter, at 2.
$ Id.
9 Id.
10 Hart letter, at 1.
11 Cox letter, at 3.
12 See Deck letter, at 9.
13 CZR technical memorandum, at 5.
14 Id., at 8 -9.
u Id., at 7.
16 Id., at 14.

vegetation, and benthic communities, the very aspects of the aquatic environment protected by
the standard for biological integrity.
The impacts to Blounts Creek may be even greater than suspected. As detailed in
PTRF's March 14 comments, CZR's memorandum is flawed in several ways that could result in
an underestimation of species impacts. 17 It does, however, provide enough information to
conclude that the proposed discharge would lead to an alteration in the natural species
composition and distribution in Blounts Creek. Indeed, the memo does not dispute the loss of
existing biological integrity, but attempts to minimize this loss by promising habitat for new
species. The memo also raises questions of how an influx of freshwater species would affect
species composition through increased competition for resources and for spawning and nursery
habitat.
North Carolina water quality standards require maintenance of the existing, natural
"species composition, diversity, population densities and functional organization," or the
biological integrity of Blounts Creek. The currently available evidence demonstrates, however,
that the proposed discharge would affect the biological integrity of Blounts Creek and degrade an
existing use.
Second, the proposed discharge would violate state water quality standards because it
would violate the pH standard for Class C waters. The standard provides that "pH ... shall be
normal for the waters in the area, which generally shall range between 6.0 and 9.0 except that
swamp waters may have a pH as low as 4.3 if it is a result of natural conditions." 15A N.C.
Admin. Code 02B .0211(g). The proposed discharge would raise the current pH in Blounts
Creek from a range of 4.0 -5.5 to a predicted 6.3 -6.9. The pH standard prohibits this large
increase because the pH of the waters downstream of the discharge sites would no longer be
"normal" for the acidic, blackwater creek, or "normal" as compared to the pH conditions
upstream of the discharge. The pH standard is consistent with the protection of existing uses in a
system like Blounts Creek. Maintaining existing pH and the factors that contribute to it are
essential to maintaining biological integrity. DWQ cannot permit a discharge that will so
dramatically change the normal pH levels of Blounts Creek.
For these reasons, the proposed discharge would violate state law and DWQ must not
issue a final NPDES permit or a 401 water quality certification. The degradation of an existing
use and the violation of the pH water quality standard are sufficient bases for denying the permit
and certification. However, MMM has also failed to provide adequate information to support the
proper review and issuance of a water quality certification.
17 Deck letter, at 6 -7. In addition to the problems mentioned in the March 14 comments, CZR's assessment is
flawed because it minimizes the discharge's effect by stating that changes in flow and salinity will be within the
range of natural variability. See, e.g., CZR technical memorandum, at 7. Unlike natural events that cause
fluctuations in background conditions, such as coastal storms, the discharge would permanently increase flow and
permanently move the salt wedge downstream. Permanent changes may have very different effects than natural,
sporadic fluctuations.

H. MMM has not shown a lack of practical alternatives to the proposed discharge.
The Division of Water Quality may only issue a water quality certification upon
determining that the proposed activity "has no practical alternative." 15A N.C. Admin. Code
02H .0506(b)(1). A lack of practical alternatives "may be shown by demonstrating that,
considering the potential for a reduction in size, configuration or density of the proposed activity
and all alternative designs the basic project purpose cannot be practically accomplished in a
manner which [sic] would avoid or result in less adverse impact to surface waters or wetlands."
15A N.C. Admin. Code 02H .0506(f). This showing is distinct from a NPDES permit
applicant's duty to submit an engineering report assessing alternatives to a proposed discharge
and demonstrating that "the most environmentally sound alternative was selected from the
reasonably cost effective options." See 15A N.C. Admin. Code 02B .0201(f); 15A N.C. Admin.
Code 02H .0105(c)(2).
MMM has submitted an engineering alternatives analysis that assesses five
technologically - feasible options for disposing of the mine dewatering waste, and identifies the
proposed discharge into Blounts Creek as the lowest cost alternative. 18 This analysis shows that
there are at least four alternatives to the proposed discharge that are technologically feasible and
would allow for the project's basic purpose to be practically accomplished. In light of these
multiple options, MMM must more fully assess the possibility of connecting to an existing water
supply system, re- injecting the groundwater, or using some combination of these two
alternatives. MMM also must assess the economic practicality of each alternative in light of the
impact of the discharge and the benefits of environmental protection. Finally, MMM must
consider how changes in design and operation of the mining operation would affect discharge
volumes and change the calculations for each alternative or combination of alternatives. Until
MMM conducts additional analysis, they have not demonstrated that there is a lack of practical
alternatives to the proposed discharge and DWQ cannot issue a water quality certification.
III. MMM has not provided adequate information for DWQ to properly assess the
proposed discharge's impacts.
Under the state water quality certification regulations, DWQ may only issue a
certification after it has determined that the proposed activity "will minimize adverse impacts [to
the waters] ... does not result in the degradation [of the waters and] does not result in cumulative
impacts ... that cause or will cause a violation of downstream water quality standards." 15A
N.C. Admin. Code 02H .0506(b). PTRF's March 14 comments note several areas where a
determination of cumulative impacts cannot be made because the information provided by
MMM is lacking. We emphasize that MMM must calculate impacts based on the fact that the
increased flow will be permanent, and not consistent with natural fluctuations. In addition,
MMM must also provide more information in the following areas:
• Aquatic vegetation and benthic organisms: MMM must more fully analyze the
effect of the discharge on aquatic vegetation, including the submerged aquatic
" Engineering Alternatives Analysis, Vanceboro Quarry, Martin Marietta Materials, Beaufort and Craven Counties.
Groundwater Management Associates, Inc. September 14, 2012.

vegetation ( "SAV ") beds, as well as on benthic organisms in the upper portion of
Blounts Creek, which cannot migrate if the salt wedge moves permanently
downstream;
• Increased habitat for freshwater species: MMM must more fully analyze the
impact on resident species from increased use of the Blounts Creek habitat by
freshwater species. As mentioned in the March 14 comments, MMM's biological
sampling data is inadequate for determining the creek's current species
composition;
• Temperature: Currently, there is no analysis of the temperature differences
between the discharge water and Blounts Creek. MMM must analyze the effect
of the discharge on the creek's water temperature;
• Metals: MMM must more fully analyze the effect of metals in the proposed
discharge on the species in Blounts Creek. MMM must consider the specific
characteristics of the brackish creek system and its native species, rather than
relying on studies based on distinct stream systems. MMM must also consider the
effect of spills at the quarry site on the discharge;
• Increased flow: MMM must more fully analyze the effect of the discharge on
sedimentation and turbidity, and the effect of increased flow on spawning habitat.
MMM must also analyze the effect of increased flow on wetlands and should
calculate flooding and erosion risks considering the effect of wind on the
movement of water. Finally, MMM must ensure that all calculations take into
account the potential built -out flow of 12 MGD; 19
• Large storm events: MMM must analyze the effect of abnormal storm events
when combined with increased flow on the salinity, habitat composition, and
stability of Blounts Creek, especially considering the low turnover rate of water in
the creek. MMM must also consider the effect of large rainfall events at the
quarry site; and
• Pamlico River and Pamlico Sound: MMM must analyze the impact of
introducing a new, permanent source of fresh water into the Pamlico River and
Pamlico Sound, especially when combined with existing large discharges of fresh
water downriver of Blounts Creek.
IV. Conclusion
For the above reasons, DWQ must not issue a final NPDES permit or a water quality
certification for the proposed discharge to Blounts Creek at this time. Based on the preliminary
analysis, any large, permanent discharge of fresh water into upper Blounts Creek would violate
state water quality standards. However, we believe that the permitting process will benefit from
a further investigation of impacts and alternatives.
19 Engineering Alternatives Analysis, at 2 -3

We appreciate the opportunity to submit these comments. Please contact me at (919)
967 -1450 if you have any questions.
Sincerely,
Geoffrey R. Gisler
CC: (via email)
Heather Deck, Pamlico -Tar River Foundation

Les and Elaine Sheridan
560 Harbour View Drive
Chocowinity, NC, 27817
NC Division of Water Quality
943 Washington Square Mall
Washington, NC 27889
RE: Vanceboro Quarry Project
We are residents of Chocowinity, NC, with waterfront property on Blounts Creek. We built our home
here in 2010, hiring local contractors, local trades people, and we continually invest in the greater
community of Beaufort County. We did this because we found a spot on Blounts Creek with all of its
unique and pristine characteristics ... foremost of which is the brackish coastal environment which
supports blue crabs, dolphins, flounder and the many aquatic fish and animals found in this brackish
environment.
We realize that our investment in the community is nowhere near the kind of investment proposed by
Martin Marietta Materials, Inc. for their Vanceboro Quarry Project. We realize that money and power
often drive political decisions.... and, while it should not be, the Vanceboro Quarry Project may well be a
political decision. HOWEVER, the state of North Carolina through its Division of Water Quality (DWQ) is
charged with a purpose stated in its own standards "15A NCAC 02c.010 (b) Purpose. Consistent with the
duty to safeguard the public welfare, safety, health and to protect and beneficially help develop
groundwater resources of the state..." In this situation the charge to DWQ is twofold: first, the
protection of the unique and delicate brackish ecosystem which supports aquatic species prevalent in
Blounts Creek; and second, the protection of the Castle Haynes aquifer. To destroy or compromise
either of these is to the detriment of the public welfare, and to the groundwater resources of the state.
When Martin Marietta Materials, Inc. began the Vanceboro Quarry Project process some years ago, they
collected data about the comparative costs of various methods of discharging mining waste water. They
concluded that the least expensive solution was the best - that being the discharge of mining waste
water into Blounts Creek. However, they failed to conduct the kind of accurate data collection and deep
analysis regarding the impact of the discharge of 9 —12 million gallons per day of fresh mining waste
water into the brackish Blounts Creek ecosystem. The benefit of the doubt might allow that this "best
solution may have been uninformed oversight, that MMM's scientists lacked knowledge about the
unique brackish environment which is Blounts Creek. This possible oversight might be supported by
their comments about the advantages of this discharge in supporting freshwater species. If this position
WAS uninformed oversight, adjustments should have been made upon CLEAR information about the
brakish nature of the creek. However, it appears that Martin Marietta Materials Inc. continues to ignore
the fact that the injection of such a large quantity of fresh water will probably destroy the saltwater
species living in our creek. Perhaps they knew but expected no reaction regarding the impacts on the

creek. When challenged, they presented impact data which has since been found faulty with input by
scientists who have no financial gain for their research. Martin Marietta has yet to demonstrate that the
discharge will NOT damage the delicate balance of the creek's ecosystem.
In addition to the issues surrounding the creek's ecosystem, they have not adequately addressed the
depletion of the Castle Haynes aquifer. The quantity of groundwater depleted will reach 109 -219 billion
gallons of water over the 50 years projected for the project. To assert that this will not have an impact
on the aquifer is irresponsible. They have already admitted that there could be a loss of water to
individual wells in the area — as stated for the Coastal Review Online, February 23, 2012, "Company
officials say they will work with area residents to provide new pumps or deeper wells to offset loss of
water to individual wells." They are already preparing to "fix' a problem that need not occur at all.
In 2007 — 2008, North Carolina enacted a policy of drought management. In the words of DWQ, "North
Carolinians are encouraged to continue water efficiency habits adopted during 2007 — 2008 to help with
any future deficits the state may face." The amount of aquifer depletion proposed by Martin Marietta is
18,750 times the DWQ estimate of 640 gallons per day use by typical families, families which will
continue to use water while the aquifer is being depleted. Will these families be asked to reduce their
consumption in the name of drought management while Martin Marietta continues to deplete
resources astronomically? The Drought Management Council for NC meets on April 18 to address the
"effectiveness of decreased groundwater withdrawals in the area(s)" including Beaufort and Craven
counties. It would be most appropriate for this council to specifically address the Vanceboro Quarry
Project and its long term impact before any consideration is given to the current proposal.
We have attended hearings where attendees, neighbors and friends have stated that they are not
opposed to the development of the Vanceboro Quarry Project —just that the nature of the discharge
needs to be addressed. On the face of it, this seems an admirable stance. HOWEVER, if Martin
Marietta's future performance mirrors the past with distortions of data and illogical conclusions,
perhaps the mine project permit should be flatly denied. Martin Marietta needs to return to its well
funded drawing boards and come up with alternatives which do not kill the delicate balance of a unique
coastal wetland environment. These alternatives have been suggested but dismissed. Perhaps further
research by Martin Marietta will demonstrate that the Creek can be protected, the aquifer maintained,
and that they can mine their product successfully.
Their current proposal, as developed, should be denied.
Les and Elaine Sheridan
560 Harbour View Drive
Chocowinity, NC 27817

Les and Elaine Sheridan
560 Harbour View Drive
Chocowinity, NC, 27817
NC Division of Water Quality
943 Washington Square Mall
Washington, NC 27889
RE: Vanceboro Quarry Project
We are residents of Chocowinity, NC, with waterfront property on Blounts Creek. We built our home
here in 2010, hiring local contractors, local trades people, and we continually invest in the greater
community of Beaufort County. We did this because we found a spot on Blounts Creek with all of its
unique and pristine characteristics ... foremost of which is the brackish coastal environment which
supports blue crabs, dolphins, flounder and the many aquatic fish and animals found in this brackish
environment.
We realize that our investment in the community is nowhere near the kind of investment proposed by
Martin Marietta Materials, Inc. for their Vanceboro Quarry Project. We realize that money and power
often drive political decisions.... and, while it should not be, the Vanceboro Quarry Project may well be a
political decision. HOWEVER, the state of North Carolina through its Division of Water Quality (DWQ) is
charged with a purpose stated in its own standards "15A NCAC 02c.010 (b) Purpose. Consistent with the
duty to safeguard the public welfare, safety, health and to protect and beneficially help develop
groundwater resources of the state..." In this situation the charge to DWQ is twofold: first, the
protection of the unique and delicate brackish ecosystem which supports aquatic species prevalent in
Blounts Creek; and second, the protection of the Castle Haynes aquifer. To destroy or compromise
either of these is to the detriment of the public welfare, and to the groundwater resources of the state.
When Martin Marietta Materials, Inc. began the Vanceboro Quarry Project process some years ago, they
collected data about the comparative costs of various methods of discharging mining waste water. They
concluded that the least expensive solution was the best - that being the discharge of mining waste
water into Blounts Creek. However, they failed to conduct the kind of accurate data collection and deep
analysis regarding the impact of the discharge of 9 —12 million gallons per day of fresh mining waste
water into the brackish Blounts Creek ecosystem. The benefit of the doubt might allow that this "best
solution may have been uninformed oversight, that MMM's scientists lacked knowledge about the
unique brackish environment which is Blounts Creek. This possible oversight might be supported by
their comments about the advantages of this discharge in supporting freshwater species. If this position
WAS uninformed oversight, adjustments should have been made upon CLEAR information about the
brakish nature of the creek. However, it appears that Martin Marietta Materials Inc. continues to ignore
the fact that the injection of such a large quantity of fresh water will probably destroy the saltwater
species living in our creek. Perhaps they knew but expected no reaction regarding the impacts on the

creek. When challenged, they presented impact data which has since been found faulty with input by
scientists who have no financial gain for their research. Martin Marietta has yet to demonstrate that the
discharge will NOT damage the delicate balance of the creek's ecosystem.
In addition to the issues surrounding the creek's ecosystem, they have not adequately addressed the
depletion of the Castle Haynes aquifer. The quantity of groundwater depleted will reach 109 -219 billion
gallons of water over the 50 years projected for the project. To assert that this will not have an impact
on the aquifer is irresponsible. They have already admitted that there could be a loss of water to
individual wells in the area — as stated for the Coastal Review Online, February 23, 2012, "Company
officials say they will work with area residents to provide new pumps or deeper wells to offset loss of
water to individual wells." They are already preparing to "fix" a problem that need not occur at all.
In 2007 — 2008, North Carolina enacted a policy of drought management. In the words of DWQ, "North
Carolinians are encouraged to continue water efficiency habits adopted during 2007 — 2008 to help with
any future deficits the state may face." The amount of aquifer depletion proposed by Martin Marietta is
18,750 times the DWQ estimate of 640 gallons per day use by typical families, families which will
continue to use water while the aquifer is being depleted. Will these families be asked to reduce their
consumption in the name of drought management while Martin Marietta continues to deplete
resources astronomically? The Drought Management Council for NC meets on April 18 to address the
"effectiveness of decreased groundwater withdrawals in the area(s)" including Beaufort and Craven
counties. It would be most appropriate for this council to specifically address the Vanceboro Quarry
Project and its long term impact before any consideration is given to the current proposal.
We have attended hearings where attendees, neighbors and friends have stated that they are not
opposed to the development of the Vanceboro Quarry Project —just that the nature of the discharge
needs to be addressed. On the face of it, this seems an admirable stance. HOWEVER, if Martin
Marietta's future performance mirrors the past with distortions of data and illogical conclusions,
perhaps the mine project permit should be flatly denied. Martin Marietta needs to return to its well
funded drawing boards and come up with alternatives which do not kill the delicate balance of a unique
coastal wetland environment. These alternatives have been suggested but dismissed. Perhaps further
research by Martin Marietta will demonstrate that the Creek can be protected, the aquifer maintained,
and that they can mine their product successfully.
Their current proposal, as developed, should be denied.
Les and Elaine Sheridan
560 Harbour View Drive
Chocowinity, NC 27817