20220241 Ver 1_USACE Compiled PN Comments SAW-2019-00233_20220408

Strickland, Bev
From: Thompson, Emily B CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, April 8, 2022 10:17 AM
To: Thomas Brown; Homewood, Sue
Cc: Pullinger, Robert C; Perry, John M
Subject: [External] RE: Belgrade Quarry Expansion - DWR#20220241
Attachments: Compiled PN Comments_SAW-2019-00233.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Good morning Thomas and DWR,
I compiled the comments USACE received during the public notice; please see attached. Again, I figured I would send
these on for you to review/start addressing, and I will likely be sending our letter to MMM sometime next week. Please let
me know if you have any questions.
I hope everyone has a nice weekend,
Emily
Emily B. Thompson
Regulatory Specialist
U.S. Army Corps of Engineers
Washington Regulatory Field Office
2407 W. 5th Street
Washington, NC 27889
[phone]
[e-mail]
We at the U.S. Army Corps of Engineers Regulatory Branch are committed to improving service to our customers. We
would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: Thomas Brown <[e-mail]>
Sent: Thursday, March 24, 2022 7:40 AM
To: Homewood, Sue <[e-mail]>; Thompson, Emily B CIV USARMY CESAW (USA)
<[e-mail]>
Cc: Pullinger, Robert C <[e-mail]>; Dunn, Maria T. <[e-mail]>; Perry, John M
<[e-mail]>
Subject: [Non-DoD Source] RE: Belgrade Quarry Expansion - DWR#20220241
Sue,
Thank you for the comments. We will be working on our response, but would like to respond to DWR and the Corps in
one response. Depending on when we receive comments from the Corps, we may need to request an extension. We
will keep you informed.
Thank you again,
i

Thomas Brown, PWS
Wetland Specialist I East Division
Martin Marietta
2235 Gateway Access Point
STE 400, Raleigh, NC 27607
m. (919) 268- 5297
e. [e-mail]
www.martinmarietta.com
From: Homewood, Sue <[e-mail]>
Sent: Wednesday, March 23, 2022 1:31 PM
To: Thompson, Emily B CIV USARMY CESAW (US) <[e-mail]>; Thomas Brown
<[e-mail]>
Cc: Pullinger, Robert C <[e-mail]>; Dunn, Maria T. <[e-mail]>; Perry, John M
<[e-mail]>
Subject: Belgrade Quarry Expansion - DWR#20220241
EXTERNAL EMAIL
Please see attached. Hard copies will not be sent unless requested.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
2

Thompson, Emily B CIV USARMY CESAW (USA)
From: Jocelyn Karazsia - NOAA Federal <[e-mail]>
Sent: Thursday, February 24, 2022 4:25 PM
To: Thompson, Emily B CIV USARMY CESAW (USA)
Subject: [URL Verdict: Neutral][Non-DoD Source] SAW-2019-00233 Martin Marietta Materials, Inc. (Mr. Ron Kopplin)
Hi Emily,
NOAA's National Marine Fisheries Service (NMFS) reviewed the project described in public notice SAW-2019-00233, dated February 24, 2022. Based on the
information in the notice, we confirm the District's determination that the proposed work would occur in the vicinity of essential fish habitat (EFH) designated by
the South Atlantic Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS. Present staffing levels preclude further analysis of the
proposed work and no further action is planned. This position is neither supportive of nor in opposition to authorization of the proposed work. If further
coordination on this action is needed, please let us know.
Jocelyn Karazsia
Acting Atlantic/Caribbean Branch Chief
NOAA National Marine Fisheries Service
Southeast Region, Habitat Conservation Division, West Palm Beach Office
Google voice: [phone]
Forwarded message
From: CESAW-PublicNoticeList <[e-mail]>
Date: Thu, Feb 24, 2022 at 3:14 PM
Subject: US Army Corps of Engineers Public Notice
To:
As you requested, you are hereby notified that Wilmington District, United States Army Corps of Engineers has issued a Public Notice. The text of
this document can be found on the Public Notices portion of the Regulatory Division Home Page. Each Public Notice is available in ADOBE ACROBAT
(.pdf) format for viewing, printing or download at https://www.saw.usace.army.mil/Missions/Regulatory-Permit-Program/Public-Notices/
As with anything you download from the Internet, be sure to check for viruses prior to opening. The current notice involves:
i

Thompson, Emily B CIV USARMY CESAW (USA)
From: Kim Williams <[e-mail]>
Sent: Saturday, February 26, 2022 10:58 AM
To: Thompson, Emily B CIV USARMY CESAW (USA)
Subject: [Non-DoD Source] Martin Marietta Expansion in Jones County
I have read the article on the expansion of the Martin Marietta quarry in Jones County. I lived in that area for 24 years. The company has done some high
explosive charges, which sent waves underground. Highway 58, just beyond the Catfish Road vibrates when heavy trucks pass over it. Limestone is fragile and it
is just a matter of time before there is a sinkhole. The area beyond the quarry has a high amount of limestone. The residents' wells in that area have dried
up. Martin Marietta should have it's history of practices considered. I did all I could do, to alert the NC Mining, but this company is a powerful international
company
Have a good day and a better evening! Kim Williams
It is better to listen with the intent to understand, than to listen with the intent to reply.
1

Thompson, Emily B CIV USARMY CESAW (USA)
From: Bowers, Todd <[e-mail]>
Sent: Thursday, March 17, 2022 2:58 PM
To: Thompson, Emily B CIV USARMY CESAW (USA)
Subject: [URL Verdict: Neutral][Non-DoD Source] EPA comments on PN SAW-2019-00233 MMM Belgrade Quarry
Emily,
The EPA Region 4 Ocean, Wetlands and Streams Protection Branch has reviewed the subject Individual Permit Public Notice under DA Action ID
SAW-2019-00233 dated February 24, 2022. It is our understanding that the applicant, Mr. Ron Kopplin of Martin Marietta Materials (MMM) is
seeking Department of the Army authorization to discharge fill material in 8.96 acres of wetlands and 899 linear feet of stream, associated with
the expansion of the existing Belgrade Quarry in Jones County, North Carolina.
Specifically per the Public Notice:
As stated by the applicant, the overall project purpose is to cost-effectively continue operation of the limestone aggregate quarry facility at Belgrade
by expanding the existing quarry area to mine suitable stone reserves in a systematic and economically viable fashion for supply to the market
during the short and medium term.
According to the applicant, MMM is currently mining the northern portion of the existing North Pit, and they propose to expand it approximately 8
acres. MMM is proposing to move a previously modified stream north, around the proposed mining area containing limestone reserves. Impacts
associated with moving this segment of stream would be 793 linear feet.
Additionally, MMM proposes two new road crossings, expanding an existing road crossing, and mining within wetlands. A new haul road is
proposed in the southeast corner of the current pit limits and would be in alignment with an existing road that travels to the plant area. This haul
road would cross two wetland areas with a total of 0.45 acres of wetland impacts. MMM proposes to expand and upgrade an existing crossing,
located at the north-eastern tip of the proposed pit, which would be used as a product haul road. This expansion would result in 0.18 acres of
wetland impacts. A second proposed haul road would impact 0.90 acres of wetlands and 106 linear feet of stream. The applicant has stated it is
proposed in the narrowest area of the wetland system that divides the two pits and would allow for the safest and most direct travel for hauling
overburden material to the existing mined out southern end of the current pit. MMM proposes to mine 7.43 acres of wetlands for the Bender Pit.
MMM proposes to mitigate for impacts to 8.96 acres of wetland at a 11.6:1 ratio by preserving approximately 94 acres of wetland and 10 acres
of non -wetland floodplain, located within a 104-acre property owned by MMM. The 104-acre property is located adjacent to the Croatan National
Forest and is comprised of high -quality Riverine Swamp Forest wetland, located in the floodplain of the White Oak River, just downstream of the
proposed Bender Pit.
1

At this time, EPA Region 4 has a few site -specific comments, concerns and recommendations with the project as presented in the Public
Notice. Several questions exist pertaining to the on -site permittee-responsible mitigation (PRM) to be provided by MMM as preservation of aquatic
resources.
1. EPA acknowledges and appreciates the applicant's avoidance of much of the wetlands to the east of the Bender Pit. Does MMM have any
plans to expand the pit and mine these areas in the future? Would MMM be interested in preserving these areas if a potential threat of
future mining exists in order to prevent their destruction? What is the functional condition of these avoided wetlands per the North Carolina
Wetland Assessment Method (NCWAM)?
2. MMM has offered a substantial amount of mitigation for wetland impacts but several issues or questions remain. There are several aspects
of the applicant's compensatory mitigation plan that may not be suitable and more information needs to be known in order for a full analysis
of their replacement for lost aquatic resource function to be completed.
a. The condition, per NCWAM, of the 7.43 acres of wetlands proposed for impact in the Bender Pit should be known so that a proper
replacement of function can be determined.
b. The condition, per NCWAM, of the wetlands proposed for preservation should be known as well. Since no functional uplift is to be
gained by a purely preservation approach to providing mitigation, it is imperative that the applicant provide additional information to
justify preservation. Preservation of a particular area should protect wetlands of exceptional quality and provide important physical,
chemical, or biological functions for the watershed.
c. The applicant should also demonstrate a clear and present threat to their continued existence, and a protective instrument such as a
conservation easement should be established to provide evidence that these wetlands will be protected in perpetuity.
d. Per the 2008 Mitigation Rule, preservation may also be used as the only form of compensatory mitigation, at the discretion of the
district engineer, but this should only be allowed where preservation of specific resources has been identified as a high priority using
a watershed approach, and in this case higher compensation ratios should be required. The applicant has chosen a strategy that
includes a replacement ratio of 11.6:1 which seems to meet this criteria but is not much above the standard minimum of 10:1
replacement to impact ratio.
e. EPA recommends that the applicant choose a mitigation strategy that involves some sort of demonstrable uplift in aquatic resource
function such as restoration, rehabilitation, or enhancement in conjunction with preservation.
3. The condition and status of the "previously modified" stream to the north of the North Pit needs to be known.
a. Why was this stream "modified" and was it used for any compensatory mitigation credit for past mining impacts?
b. What is the current condition of the stream per the North Carolina Stream Assessment Method (NCSAM) and what is the expected
condition following relocation?
c. Will this stream be restored using Natural Channel Design and are there any plans to monitor or protect this stream under a
conservation easement or similar instrument?
4. If the stream impacts will not be properly compensated for on -site, purchasing a suitable amount and type of credits from an established
mitigation bank or in -lieu fee site should be considered. Replacing stream impacts with wetland credits, however obtained, is an out -of -kind
replacement and highly discouraged per the 2008 Compensatory Mitigation Rule.
Thank you for the opportunity to provide feedback on DA Action ID SAW-2019-00233 seeking Department of the Army authorization to discharge fill
material in 8.96 acres of wetlands and 899 linear feet of stream, associated with the expansion of the existing Belgrade Quarry in Jones County,
North Carolina.
Best Regards,
2

Todd Bowers
Todd Allen Bowers
US EPA Region 4 Oceans, Wetlands and Streams Protection Branch
61 Forsyth St. SW
Atlanta, GA 30303
404.562.9225 * *
[e-mail]
epa.gov
**Note: I am currently teleworking and away from the office. Please contact me via email or at 919.523.2637.
"Do unto those downstream as you would have those upstream do unto you."
— Wendell Berry
From: CESAW-PublicNoticeList <[e-mail]>
Sent: Thursday, February 24, 2022 2:25 PM
Subject: US Army Corps of Engineers Public Notice
Importance: High
As you requested, you are hereby notified that Wilmington District, United States Army Corps of Engineers has issued a Public Notice. The text of
this document can be found on the Public Notices portion of the Regulatory Division Home Page. Each Public Notice is available in ADOBE ACROBAT
(.pdf) format for viewing, printing or download at https://www.saw.usace.army.mil/Missions/Regulatory-Permit-Program/Public-Notices/
As with anything you download from the internet, be sure to check for viruses prior to opening. The current notice involves:
Corps Action ID#: SAW-2019-00233
Applicant: Martin Marietta Materials, Inc.
Mr. Ron Kopplin (Jones County)
3

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper Office of Archives and History
Secretary D. Reid Wilson Deputy Secretary, Darin J. Waters, Ph.D.
March 21, 2022
Emily Thompson
US Army Corps of Engineers
Washington Regulatory Field Office
2407 West Fifth Street
Washington, NC 27889
[e-mail]
RE: Belgrade Quarry Expansion, Onslow County, ER 85-8058
Dear Ms. Thompson:
Thank you for your February 28, 2022, submission concerning the above -referenced project. We have
reviewed the project and offer the following comments.
We have determined that the project as proposed will not have an effect on historic structures.
While the northern expansion of the Belgrade Quarry falls within previously agriculturally disturbed land,
the Area of Potential Effect (APE) of the proposed Bender Pit is in proximity to a number existing
prehistoric and historic archaeological sites and contains geographical features that suggest site probability.
Due to this, along with the lack of any previous archaeological surveys in the proposed Bender Pit APE, we
recommend a comprehensive archaeological survey be undertaken prior to any ground disturbing activities
in the project area.
The purpose of this survey is to identify archaeological sites and make recommendations regarding their
eligibility status in terms of the NRHP. This work should be conducted by an experienced archaeologist
who meets the Secretary of the Interior Professional Qualifications Standards. A list of archaeological
consultants who have conducted or expressed an interest in contract work in North Carolina is available at
https://archaeology.ncdcr.gov/archaeological-consultant-list. The archaeologists listed, or any other
experienced archaeologist, may be contacted to conduct the recommended survey. Please note that our
office requests consultation with the Office of State Archaeology Review Archaeologist to discuss
appropriate field methodologies prior to the archaeological field investigation.
One paper copy and one digital copy (PDF) of all resulting archaeological reports, as well as a digital copy
(PDF) of the North Carolina Site Form for each site recorded, should be forwarded to the Office of State
Archaeology (OSA) through this office, for review and comment as soon as they are available and in
advance of any construction or ground disturbance activities. OSA's Archaeological Standards and
Guidelines for Background Research, Field Methodologies, Technical Reports, and Curation can be found
online at: https://files.nc.gov/dncr-arch/OSAGuidelinesDec2017.pdf.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

ER 85-8058, March 21, Page 2 of 2
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or [e-mail]. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
Lc( Ramona Bartos, Deputy
[] State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

Catawba Indian Nation
Tribal Historic Preservation Office
1536 Tom Steven Road
Rock Hill, South Carolina 29730
Office 803-328-2427
MP MP MP MP 4M1. MP MP MP MP MP
MP MP MP MP 4M1. MP MP MP MP MP
March 24, 2022
Attention: Emily Thompson
Corps of Engineers, Wilmington District
2407 West Fifth Street
Washington, NC 27889
Re. THPO # TCNS # Project Description
2022-56-16 SAW-2019-00233 — expansion of the existing Belgrade Quarry in Jones Co., NC
Dear Ms. Thompson,
The Catawba have no immediate concerns with regard to traditional cultural properties,
sacred sites or Native American archaeological sites within the boundaries of the
proposed project areas. However, the Catawba are to be notified if Native American
artifacts and / or human remains are located during the ground disturbance phase
of this project.
If you have questions please contact Caitlin Rogers at 803-328-2427 ext. 226, or e-mail
[e-mail].
Sincerely, �}
lt(.r.--
Wenonah G. Haire
Tribal Historic Preservation Officer

Coastal Carolina Riverwatch
700 Arendell Street, Suite 2
Morehead City, North Carolina 28557
March 26th, 2022
US Army Corps of Engineers, Wilmington District
2407 West Fifth Street
Washington, North Carolina 27889
Dear Ms. Thompson,
/fi Iet �i,�I RIVERWATCH
Thank you for the opportunity to submit comments regarding the Martin Marietta Materials, Inc.
application associated with the expansion of Belgrade Quarry in Jones County, North Carolina.
We submit these comments on behalf of Coastal Carolina Riverwatch. We represent a coalition of
eastern North Carolina citizens, committed to protecting the waterways of the White Oak River
Basin.
1. The proposal's purpose and need are too narrowly defined. On page 3 of the "Public Notice,"
the applicant states the purpose of this project is "to cost-effectively continue operation of the
limestone aggregate quarry facility at Belgrade by expanding the existing quarry area to mine
suitable stone reserves in a systematic and economically viable fashion for supply to the market
during the short and medium term"
This purpose does not indicate the Corps has exercised independent judgment. The Corp should
have a basis to set up alternatives and select the best. It also does not notify the public that the
Bender Pit is a new proposed pit, not an expansion of the existing mine pit farther north. Finally,
the purpose and need as currently articulated are too narrowly drawn to allow consideration of
alternatives, such as alternate locations.
2. The application shows that aggregate mining at the proposed expansion is not a
water -dependent use, because the applicant states most of the proposed mining is uplands.
a. Because the use is not water -dependent, the applicant has not met its burden to
rebut the presumption that wetlands can be avoided'.
b. The lack of a water -dependent use may affect the avoidance and minimization
criteria for this proposal.
3. The proposal's impacts may be greater than the total acreage of wetlands impacts (8.96).
LII / Legal Information Institute. 2022. 40 CFR § 230.10 - Restrictions on discharge.<https://www.law.cornell.edu/cfr/text/40/230.10>
CoastalCarolinaRiverwatch.org
1

a. The Bender Pit expansion site is entirely surrounded by jurisdictional wetlands.
Compare the side -by -side images below. There is also a 6.19-acre freshwater pond
directly adjacent to the new proposed pit (shown in blue on the map at right).
Belgrade Quarry
Proposed Bender Pd
SWAM
Legend
Proposed Bender Pit
Road Crossings
- &ream Impacts
- Srmam
WMfTM_Im(iKb
WSk 4 Boundary
Q ppprosmate COMM PIS Llmlla
b. Excavating the upland separating the White Oak River and Black Swamp Creek
may alter existing hydrology over a larger area. There is a need for more
information about how the expansion will affect the surrounding hydrology.
c. One of the proposed haul roads goes over a major wetlands complex. This road
may not be justified, and more information is needed to evaluate how the road
would affect the wetland complex. Additionally, there seems to be another way to
access the pit through uplands, raising questions of whether the proposal
adequately avoids and minimizes impacts to wetlands.
d. Impacts to edge of jurisdictional wetland boundary and the freshwater pond
adjacent to Black Swamp Creek may require a Clean Water Act § 402 discharge
permit2.
4. A jurisdictional determination is necessary for the proposal.
a. There is no approved jurisdictional determination (AJD) for this proposal.
Although the applicant is proceeding on a preliminary jurisdictional determination,
satellite photos indicate some land clearing and some ditches present. This presents
a question of whether those activities have altered the natural hydrology and
influenced the jurisdictional determination, and if so, whether this alteration was
legal under Clean Water Act § 4043. Accordingly, an AJD is needed for this proposal
to proceed.
2 US EPA. 2022. Clean Water Act, Section 402: National Pollutant Discharge Elimination System I US EPA.
<https://www.epa.gov/cwa-404/clean-water-act-section-402-national-pollutant-discharge-elimination-system>
s US EPA. 2022. Overview of Clean Water Act Section 404 I USEPA.<https://www.epa.gov/cwa-404/overview-clean-water-act-section-404>
2

5. The preservation of existing wetlands does not accomplish the mitigation needs for this
project.
a. According to the mitigation hierarchy in 40 C.F.R. § 230.93(a)(2)4 provides that
mitigation by restoration is generally preferable to establishment, enhancement, or
preservation. With regard to the use of mitigation banks in particular, §
230.93(b)(2)5 describes a number of benefits to using mitigation bank credits and
then provides that "[f]or these reasons, the district engineer should give preference
to the use of mitigation bank credits when these considerations are applicable"
Furthermore, § 230.93(b)(3)6 provides that, under certain conditions described in
the regulation, "in -lieu fee mitigation, if available, is generally preferable to
permittee-responsible mitigation" Also, § 230.93(e)(1)7 provides that in -kind
mitigation is generally preferable to out -of -kind mitigation.
b. The applicant's proposed preservation of the 404 jurisdictional wetlands on the
preservation tract are not likely subject to development in the future, meaning the
preservation of the land does not compensate for the losses the proposal would
cause.
c. There may be more meaningful mitigation opportunities elsewhere, e.g. habitat
or hydrologic restoration elsewhere in the White Oak watershed to help offset
impacts of the proposal.
6. The provisions for appropriate stormwater management are vague, leading to question of
sufficiency.
a. On Page 5 of the "Public Notice" document, the applicant states intent "to
minimize impacts to wetlands and other waters, MMM will use stormwater
management and erosion control techniques that preserve downstream water
quality." This does not specify methods of stormwater management, nor indicate
if stormwater provisions have been developed or proposed by appropriate,
unbiased engineers and/or field experts.
7. Finally, we emphasize the importance of careful and diligent review and consultation of
other sections listed in "Public Notice" regarding essential fish habitats, cultural resources, and
endangered species.
4 LI I / Legal Information Institute. 2022. 40 CFR § 230.93 - General compensatory mitigation
requirements.https://www.law. corn ell. ed u/cfr/text/40/230.93
See 40 CFR § 230.93
6 See 40 CFR § 230.93
See 40 CFR § 230.93
3

For these reasons, we respectfully request that the Us Army Corps of Engineers not issue permit for
the work proposed by the applicant. Moving forward, we request a careful assessment of the above
considerations and a thorough evaluation of potential impacts.
Respectfully,
,azi,6
Lisa Rider, Executive Director
Coastal Carolina Riverwatch
[e-mail]
ZALL,, C)oLv
Rebecca Drohan, White Oak Waterkeeper
Coastal Carolina Riverwatch
[e-mail]
4

Thompson, Emily B CIV USARMY CESAW (USA)
From: Lauren Daniel <Iaurendanie101 @gmail.com>
Sent: Monday, April 4, 2022 11:41 AM
To: Thompson, Emily B CIV USARMY CESAW (USA)
Subject: Re: [URL Verdict: Neutral][Non-DoD Source] Martin Marietta Quarry in Jones Co.
To Whom it May Concern;
I am writing to voice my concern about the planned increase in the mining area in Jones County by Martin Marietta. Before this permit is authorized, I'd like to
make 3 key points for consideration:
1- If Martin Marietta intends to continue dewatering, this will continue to decrease the water quality and alter the natural water quantity flowing through
the White Oak River. Section 404 of the CWA reminds us that no discharge may be permitted if the nation's waters would be significantly degraded. I'd like to
point to how fragile our smallest river basin in NC is. Using the latest approved 303d list, the White Oak River has several impaired streams and monitoring sites
frequently prohibit shellfish harvesting due to several parameters not meeting criteria.
2- If Martin Marietta continues to expand their mine, the White Oak River will struggle to ever meet criteria thus prohibiting harvesting shellfish or other
wildlife. We need to work together as a community to manage this water resources so it can support the economy in other ways besides mining
operations. Without seeing a valid Environmental Impact Statement with quantitative values and consistent monitoring on site, it is impossible to suggest the
expansion of such an effort will not continue to degrade the ability for this river to support its natural ecological diversity. Expanding the mine in conjunction
with the imminent development, the White Oak River has no chance to ever support ecological diversity. Discharging water into the river with extensive
suspended solids will absolutely degrade its quality. Please take a moment to consider the latest basin plan written for the WOR- and notice the primary
classifications for this river rely heavily on maintaining the highest water quality.
3- Destroying Wetlands is not a sustainable way to manage our water resources. As Carteret County (downstream of site) continues to rubber stamp riverside
development, allowing the wetlands on the MMM site to be destroyed and "moved" will simply continue to knock down the dominoes toward degrading the
White Oak's Water Quality. We depend on these wetlands to soak up flood waters during hurricanes and large storms. We also depend on these wetlands to
provide habitat for the wildlife our community values. I know that many folks scoff at the impacts to endangered species, however it's important to recognize
that this permit is one of the hundreds of similar efforts to degrade the natural environment and hydrology of Eastern North Carolina's valuable coastal
ecosystem. Please note that there are several oyster leases in the White Oak River and as the Shellfish Farming Industry continues to grow, there is an increased
need to protect our human impacts to the river. Moreover, there are already existing portions of this river that COULD allow for shellfish harvesting, but are
closed permanently due to water quality degradation. Let's not add to this problem by authorizing an expansion for the Bender Pit, or any additional mining.
Finally, I would like to point out that I completely support economic growth in our area, however this must be done without impeding the natural ecosystems
that thrive here and draw tourism (and drive our community's overall economy). I'd also like to point out that local community members are deeply concerned
with continued impacts to the hydrology in our area but do not have the technical knowledge to address complex permit requests- so please do not interpret a
lack of public comment about this as a lack of interest or concern. The people in these surrounding communities are deeply concerned about the continued
expansion of commercialized development in these coastal counties. Our children deserve to inherit these lands without also inheriting catastrophic
environmental degradation issues.
Thank you for your time and consideration,
1

Lauren Daniel
Peletier, North Carolina
On Mon, Apr 4, 2022 at 10:58 AM Lauren Daniel <[e-mail]> wrote:
Sounds wonderful. I will write up some comments now and send them to you within the hour. Do you send these comments electronically? If so, if I include
hyperlinks in my comments, can those links be included? Also- can I expect any response to my comments from Martin Marietta?
Thanks for your time,
Lauren
On Mon, Apr 4, 2022 at 10:39 AM Thompson, Emily B CIV USARMY CESAW (USA) <[e-mail]> wrote:
Good morning Lauren,
The article references the public notice issued, and there you will find additional information about the project. The public notice commenting period has ended,
and I'm working on compiling comments this week to send to the applicant. After reviewing, please send any questions you may have to me as soon as possible.
Sincerely,
Emily
Emily B. Thompson
Regulatory Specialist
U.S. Army Corps of Engineers
Washington Regulatory Field Office
2407 W. 5th Street
Washington, NC 27889
[phone]
2

[e-mail]
We at the U.S. Army Corps of Engineers Regulatory Branch are committed to improving service to our customers. We would appreciate your feedback on how
we are performing our duties. Our automated Customer Service Survey is located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: Lauren Daniel <[e-mail]>
Sent: Thursday, March 31, 2022 8:19 AM
To: Thompson, Emily B CIV USARMY CESAW (USA) <[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] Martin Marietta Quarry in Jones Co.
Hi Emily -
I'm curious to learn more about this proposed project. Is there any additional information for me to review and share with the community? I'm mostly
interested in learning the impacts of this quarry to the adjacent river. The article about this project provides little data about the proposal- so I'm hoping you
may have some additional information included on the permit request? My main concern is learning about how the draw down of the water table will impact
the base flow of the White Oak River as this river already struggles with nutrient loading.
Thanks for any help/data you can provide.
-Lauren
3

Thompson, Emily B CIV USARMY CESAW (USA)
From: Dunn, Maria T. <[e-mail]>
Sent: Thursday, April 7, 2022 4:03 PM
To: Thompson, Emily B CIV USARMY CESAW (USA)
Subject: [Non-DoD Source] Martin Marietta Materials Belgrade Quarry, Jones County
Good afternoon Emily. I hope you are well.
NCWRC has reviewed the public notice for the above project. We exchanged some dialogue with you and NCDWR, but neglected to comment officially during
the comment period. I apologize for this oversight but do hope the following comments can be considered during your review of the applicant's request.
MMM Belgrade proposes to expand their existing quarry to include the fill of 8.96 acres of wetlands and 899' of stream. These wetland impacts are primarily
within a leased area known as the Bender Pit. The Bender Pit is the applicant's preferred alternative, proposing to mine an area with wetland impacts whose
lease will expire and may not be renewed rather than proceed to an owned parcel with no wetland impacts. Since the NCWRC does not review a project on the
basis of economics, but rather impacts to environmental resources, we have concern with the project as proposed. We believe avoidance and minimization of
impacts to wetlands has not been adequately demonstrated and should be further discussed.
Wetlands provide important wildlife opportunities and perform necessary water quality functions. The project area is adjacent to several tributaries and creeks
of the White Oak River, including Black Swamp Creek, an unnamed tributary to the White Oak River, and the White Oak River itself. The Bender Parcel is partially
wooded and exhibits hydric soils. The applicant has proposed avoidance of some wetland areas but could further reduce wetland impacts to the parcel if the
lower (southern) portion of the tract that is wooded and is bisected by a wetland is avoided. This would minimize wetland fill and provide hydrologic and wildlife
connectivity (aquatic and terrestrial passage) between Black Swamp Creek, the White Oak River, and other habitats past the confluence of these systems
upstream the proposed mitigation site. Additional wetland areas near the edge of the Bender parcel that could be avoided include the eastern most wetland and
the wetland/headwater stream. This alternative to further reduce impacts in the Bender parcel was not explored in the public notice but could be a viable
option. Additional minimization of wetland impacts in the northern and western sections may possible if after a reduction in minable area within the Bender
parcel leads to less need for two haul roads — each of which requires wetland fill.
Overall, the NCWRC requests additional avoidance and minimization of wetland and stream impacts be examined. This may include the reduction of wetland
impacts within the Bender parcel or the elimination of the Bender parcel all together. If wetland impacts are authorized, we request mitigation for the impacts
be appropriate, potentially including higher ratios or different types of mitigation than currently proposed.
Thank you for the opportunity to comment on this proposal. Please continue to include the NCWRC in discussions as this project progresses.
Maria
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Maria T. Dunn
Coastal Coordinator
NC Wildlife Resources Commission
943 Washington Sq. Mall
Washington, NC 27889
office: 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.
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