20220241 Ver 1_USACE More Info Requested_20230109

Baker, Caroline D
From: Thompson, Emily B CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, January 9, 2023 5:55 PM
To: Thomas Brown
Cc: Homewood, Sue; Lastinger, James C CIV USARMY CESAW (USA); Dunn, Maria T.;
Davis, Erin B
Subject: RE: [External] Martin Marietta Belgrade Quarry Draft Wetland Monitoring Plan
Attachments: Proposed Bender Pit southern portion.pdf
Follow Up Flag: Follow up
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Good afternoon,
Thank you, everyone, for meeting onsite last week. In the email below, we asked MMM to define how much limestone is
"enough" based on the exploratory drilling that has taken place. MMM asked if they needed to provide specific numbers
(tonnage) for the amount or if the number of years would be sufficient. We briefly discussed some industry
standards/parameters — depth of limestone, depth of overburden, etc. — that would influence this definition. It would be
sufficient to provide a narrative of these parameters in detail (as screening criteria) and then describe the reserves on the
sites and how they compare. MMM also asked if they would have to design a facility for every alternative — no, only the
alternatives where there are known limestone reserves and where no exploratory drilling has occurred before. The other
offsite alternatives would likely drop out due to other established screening criteria. The plans do not have to be engineer -
scale drawings, but they should show the footprint and the overlapping/proposed estimated impacts to aquatic resources
using desktop tools (ex. NWI and NC CREWS).
As discussed, there are concerns about other potential alternatives not considered that could avoid/minimize impacts
within the Bender Pit — specifically regarding the aquatic passage between Black Swamp Creek on the east and a UT on
the west (where an abandoned road separates the wetlands with the proposed pit) and the Bald Eagle nest in the
southern portion of the site. If this area were avoided altogether, this would reduce the amount of wetlands impacted and
avoid potential impacts to the Bald Eagle nest within 660' of the southeast corner of the pit. MMM needs to demonstrate
why this southern portion could not be avoided altogether. If this can be demonstrated, MMM also needs to
consider/address other designs that would minimize the impacts to the wetlands. An example would be creating two pits
with berms N/S of the wetland and a road crossing that would provide aquatic passage between the two wetland systems
(oversimplified drawing attached). We're working towards determining the LEDPA; this information is required to analyze
the alternatives.
For the mitigation plan, we discussed providing more details on the history and existing site conditions (i.e., vegetative
types), comparing the proposed preservation site to the proposed impact areas, and detailing the demonstrable risk to the
proposed preservation area.
Lastly, we discussed that the wetlands on the proposed preservation site would be delineated — MMM sent an old survey
of the uplands, but the wetlands were not quantified. A map showing the uplands/wetlands quantified and the property
boundaries would be necessary.
We discussed some of this information onsite but need everything included in the final submittal. Please let me know if
you have any questions.
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]
[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: Thompson, Emily B CIV USARMY CESAW (USA)
Sent: Friday, December 23, 2022 4:01 PM
To: Thomas Brown <Thomas.Brown@ martinmarietta.com>
Cc: Homewood, Sue <[e-mail]>; Lastinger, James C CIV USARMY CESAW (USA)
<[e-mail]>
Subject: RE: [External] Martin Marietta Belgrade Quarry Draft Wetland Monitoring Plan
Good afternoon everyone,
Below are the Corps' responses to the monitoring plan, mitigation plan, and the alternatives analysis.
Monitoring Plan:
• Wells need to be consistently distanced from the edge of the wetland, 50 and 100 feet at each of these
locations, with an appropriately scaled map.
• Additional wells (at least 2 as described above) need to be located between the overburden and haul road
impacts to monitor the upper reaches of wetland system.
Mitigation Plan:
• I see some discrepancies between the monitoring plan saying the total impacts to wetlands would be 7.43 acres
vs. the proposed mitigation plan staying at 8.96 acres. I think you are referencing impacts only within the Bender
Pit, but there are 1.53 acres proposed for road crossings as well. It comes across as misleading because at first, I
thought there was some additional minimization.
• You already caught this issue, but to be sure, there are 106 linear feet of stream impacts associated with the
overburden road/Bender Pit and an additional 793 linear feet of stream impacts associated with the North Pit
for a total of 1,005 stream credits.
• Enclosed is a template for the Conservation Easement for The Barn Group/MMM to complete — this can be
completed now, send to USACE to review with Office of Counsel, and then can be recorded within the required
time as described in the Special Conditions
Alternatives Analysis:
• Clearly define specific siting/screening criteria, this is what we understand from the narrative, but please
confirm/add to in the final version.
o Logistics:
■ Production
■ Site size/acreage minimum = 300 acres in size
• 200-acre pit, 25 acres of overburden storage, berms, and buffers; 75 acres for a plant,
shop, scale house, employee building, roads, and infrastructure
o Geology:

■ Presence/Amount/Quality of aggregate to be mined — please define how much is enough based
on exploratory drilling to warrant a quarry in this area.
o Market area:
■ Location/haul distance = 5-mile radius
■ Serving time = 10 — 20 years
o Cost:
■ Land — availability for acquisition
■ Production
■ Transportation
o Impacts to Aquatic Resources:
■ Wetlands & streams quantified
• Create a table to compare all the off -site alternatives and the preferred alternative.
• Include a comparison of the wetland impacts for each of the onsite alternatives.
Some of this information may have been submitted before, but we would like to see everything included in one,
comprehensive document. It is late afternoon the Friday before Christmas, so bear with me if you don't understand
something above — feel free to reach out and we can discuss.
Merry Christmas and see y'all in the New Year!
Emily
Emily B. Thompson
Regulatory Specialist
U.S. Army Corps of Engineers
Washington Regulatory Field Office
2407 W. 5th Street
Washington, NC 27889
[phone]
Emily. B.Thompsona-usace.army. mil
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: Homewood, Sue <[e-mail]>
Sent: Wednesday, December 14, 2022 4:48 PM
To: Thomas Brown <Thomas.Brown@ martinmarietta.com>
Cc: Thompson, Emily B CIV USARMY CESAW (USA) <[e-mail]>; Davis, Erin B
<[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: [External] Martin Marietta Belgrade Quarry Draft Wetland
Monitoring Plan
Hi Thomas,
Its good that you were able to find a conservation easement holder. DWR would like to schedule a site visit to the parcel
being donated to ensure that it would qualify for preservation credit. Erin Davis will be the DWR staff to conduct the
site visit. Erin recommends that WRC be invited to the site visit also. I'll let Emily weigh in on who at USACE should be
invited.

Unfortunately DWR is working against the Federal Reasonable Period of Time to make a final 401 decision by the end of
January. We didn't want to schedule this site visit until we were sure that the CE issue was going to work out, but now
we are short on time. Could you start the process to arrange a site visit asap please?
Also, Erin re-evaluated the Bachelor's Delight Mitigation Site and we no longer have concerns regarding preservation
credits at that site so it seems that with MMM satisfying 75% of the DWR wetland mitigation requirements by payment
into that bank and the remainder 25% of the DWR wetland mitigation requirement with the donation of
property/preservation then we can finalize the mitigation concerns we had.
I have also reviewed your wetland monitoring plan and am satisfied with the proposal.
Please let me know if you have any questions or comments and Happy Holiday Season.
Thanks,
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
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From: Thomas Brown <Thomas.Brown@ martinmarietta.com>
Sent: Friday, November 18, 2022 2:30 PM
To: Thompson, Emily B CIV USARMY CESAW (USA) <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: [External] Martin Marietta Belgrade Quarry Draft Wetland Monitoring Plan
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Emily,
Please see the attached draft monitoring plan for Belgrade. I hope to follow up next week with the draft updated
mitigation plan and draft updated alternatives analysis.
For the proposed preservation, we plan to give the property to "The Barn Group" to hold in a conservation
easement. Could you give me some guidance on what you need from them?
Here is a link to their website: https://www.thebarngroup.org/
Thanks again,

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