20221391 Ver 1_WRC Comments_20221019

Staff Review Form
NORTH CAROLINA
Envlronm¢ntcl Qvofiry
Updated September 4, 2020
Staff Review
Does this application have all the attachments needed to accept it into the review process?*
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ID# *
20221391
Version* 1
Is this project a public transportation project?*
Yes
• No
Reviewer List: * Robert Tankard:eads\rbtankard
Select Reviewing Office: *
Washington Regional Office - [phone]
Does this project require a request for payment to be sent?*
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No

Project Submittal Form
Please note: fields marked with a red asterisk * below are required. You will not be able to submit the form until all
mandatory questions are answered.
Project Type: *
For the Record Only (Courtesy Copy)
New Project
Modification/New Project with Existing ID
More Information Response
Other Agency Comments
Pre -Application Submittal
Re-Issuance\Renewal Request
Stream or Buffer Appeal
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Please choose the commenting agency. *
DCM Comments DCM Permit
DFM Comments USFWS Comments
WRC Comments Other
Project Contact Information
Name: Maria Dunn
Who is submitting the information?
Email Address: [e-mail]
Project Information
Existing ID #:
20221391
20170001 (no dashes)
Existing Version:
1
Project Name: Placement of Olivine Sand nearshore waters off Town of Duck Shoreline
Is this a public transportation project?
Yes
No
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
Yes No Unknown
County (ies)
Dare
Please upload all files that need to be submited.
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CMDF_Vesta_Town of Duck_NCWRC^.pdf 1.16MB
Only pdf or kmz files are accepted.

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By checking the box and signing box below, I certify that:
• I, the project proponent, hereby certifies that all information contained herein is true, accurate, and complete to the
best of my knowledge and belief.
• I, the project proponent, hereby requests that the certifying authority review and take action on this CWA 401
certification request within the applicable reasonable period of time.
• I agree that submission of this online form is a "transaction" subject to Chapter 66, Article 40 of the NC General
Statutes (the "Uniform Electronic Transactions Act");
• I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General
Statutes (the "Uniform Electronic Transactions Act");
• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a
written signature; AND
• I intend to electronically sign and submit the online form.
Signature:
Submittal Date: Is filled in automatically.

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRAXTON DAVIS
Director
October 6, 2022
MEMORANDUM:
NORTH CAROLINA
Environmental Quality
FROM: Gregg Bodnar, Assistant Major Permits Coordinator
NCDEQ - Division of Coastal Management
400 Commerce Ave_, Morehead City, NC 28557
Fax: [phone] (Courier 04-16-33)
gregg.bodnarglacdenngov
SUBJECT: CAM/Dredge & Fill Review
Applicant: Vesta North Carolina, PBC
Project Location: Offshore of Town of Duck, in Dare County
Proposed Project: Deploy olivine sand off the shoreline of Duck, approximately 2000' from the
northern limit of the Duck Field research facility.
Please indicate below your agency's position or viewpoint on the proposed project and
return this form to GregA Bodnar at the address above by October 27, 2022. If you have any
questions regarding the proposed project, contact Heather Coats (910-796-7302) when appropriate, in-
depth comments with supporting data is requested.
REPLY: This agency has no objection to the project as proposed.
*"Additional comments may be attached**
This agency has no comment on the proposed project.
This agency approves of the project only if the recommended changes
are incorporated. See attached.
This agency objects to the project for reasons described in the attached
/ comments.
PRINT NAME Mc- h, e� - I . -- �1tA n
AGENCY
SIGNATURE
DATE
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North Carolina Department of Environmental Quality I UNtsion of Coastal Management
�Q_ E Q Elizabeth City Office 1 401 South Griffin Street, Suite 300 1 Elizabeth City. North Carolina 27909
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-= North Carolina Wildlife Resources Commission D
Cameron Ingram, Executive Director - -
MEMORANDUM
TO: Gregg Bodnar
Division of Coastal Management
North Carolina Department of Environmental Quality
FROM: Maria T. Dunn, Coastal Coordinator
Habitat Conservation Division
DATE: October 18, 2022
SUBJECT: CAMA Dredge/Fill Permit Application for Vesta North Carolina, PBC, Dare
Colony, North Carolina.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the permit
application with regard to impacts on fish and wildlife resources. The project site is located at offshore the
Town of Duck within the nearshore area of the Atlantic Ocean. Our comments are provided in accordance
with provisions of the Coastal Area Management Act (G.S. 113A-100 through 113A-128), as amended,
Sections 401 and 404 of the Clean Water Act, as amended, the Endangered Species Act of 1973, as
amended (16 U.S.C. 1531 et seq.), the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16
U.S.C. 661 et seq.), the Magnuson -Stevens Fishery Conservation and Management Act (FCMA), as
amended (16 U.S.C. 1801 et seq.), and the Migratory Bird Treaty Act (16 U.S.C. 703-712 et seq.).
Vesta North Carolina, PBLLC (Vesta) proposes to implement a pilot study to evaluate the potential
effectiveness of a large-scale project that would try to address the effects of climate change through the
sequestration of carbon, the reduction of the rate of ocean acidification, and shoreline protection to bolster
coastal resiliency. The applicant's proposal is to mine and mill olivine material from an upland mine to a
grain size similar to native material and then deploy 20,000 CY via multiple barges or split hull stows
into a 76.4 acre area (4,970' by 670') at the approximate -25' depth contour of the Atlantic Ocean, 2,000'
off the beach from the northern limit of the Duck Field Research Facility to Pintail Drive. Monitoring of
the project would be conducted by the applicant, the US Army Corps of Engineers (USACE) Research
and Development Center (ERDC), and UNC-Greensboro for minimum 24-month period. Previous project
discussions during scoping meetings and correspondence included larger amounts of olivine placed on the
ocean shoreline. Due to statements and concerns received during these discussions with regard to
environmental impacts to shorebirds, sea turtles, and invertebrates, the project reduced the overall amount
of material to be placed as well as the relocated the placement area from the ocean shoreline to the
nearshore area.
Mailing Address: Habitat Conservation - 1721 Mail Service Center • Raleigh,. NC 27699-1721
Telephone: [phone] • Fag: [phone]

Page 2
The NCWRC has reviewed the current project proposal and has participated in previous scoping
meetings. We appreciate the efforts to address some of the concerns presented during the scoping meeting
as they relate to wildlife resources that utilize the ocean shoreline and the overall size of the project.
While some of our concerns have been addressed, we still have the following comments:
The proposed olivine material is a non-native substance on the beaches and nearshore area of
North Carolina. The introduction of this material and its effects on the environment are unknown.
Toxicity sampling was done on a short-term basis and may not have had adequate time for olivine
to dissolve and release chemicals that affect the test parameters. The introduction of any non-
native material is concerning with regard to its chemical as well as physical influence on the
environment. Appropriate tests should be conducted and unwanted impacts should be anticipated
and remediation plans implemented as part of any project proposal.
• At the time of the public notice, the mine location was not known. This location as well as the
amount of carbon it would take to implement the project is beneficial information in discerning
the effectiveness of project in relation to the stated purpose and need.
• The 20,000 CY of fill is a reduction from the previous proposal, but still is a significant amount
of fill over a large deposition area. If permitted, the project should be designed to have the
smallest footprint needed to gather data.
Documentation states olivine dissolves at a slow rate. It could not be determined if this rate is too
slow to have noticeable detection during the 24-month monitoring period. Therefore, impacts
from the deployment of a non-native material may not be fully understood at the end of the
monitoring period. Using incomplete information from this pilot study to mare a determination
on if a large-scale project can be done with acceptable risks and impacts on environmental
impacts is concerning.
• While the pilot study is less likely to impact nesting sea turtles, it should be noted that the area
near the deposition site is a critical habitat area for loggerheads, LOGG-N-01, and sees significant
use by swimming sea turtles. Impacts to benthos in the area and how it may affect foraging
should be explored.
• Atlantic sturgeon use areas near the deposition zone. Impacts to benthos in the area and how it
may affect foraging should be explored.
• The public notice states the area will be monitored for a minimum of 24-months. Details of the
monitoring did not include if the material would be removed at the end of the monitoring period
or if the material would be removed if it is distributed outside the 76.4-acre deployment area.
Overall, the NCWRC is concerned with the magnitude of the project and whether or not the project
design and monitoring will be effective enough to discern if the proposal could be expanded and used as a
management tool to address negative results of climate change. A reduction in the size and scope of the
project as well as details on the carbon expended to facilitate the project, material source, and monitoring
details would address some of these concerns.
We appreciate the opportunity to review and comment on this permit application. If you need further
assistance or additional information, please contact me at [phone] or at
maria.dunnL&ncwildlife.ar�;