20221391 Ver 1_More Info Received_20230130

VESTA
January 30, 2023
Robert Tankard, Assistant Regional Supervisor
Water Quality Regional Operation Section
Division of Water Resources, NCDEQ
Washington Regional Office
www.vesta.ea rth
PECEI` ED
F E S :` j?3
r�ca-.VVATT-:R RESOURCES
Subject: Response to Request for Additional Information relating to Placement of Olivine
Sand in Nearshore Waters of The Town of Duck Shoreline and other Supplemental
Questions received from Resource Agencies in North Carolina.
Dear Mr. Tankard,
On September 9, 2022, Coastal Protection Engineering of North Carolina, Inc. ("CPE"), on
behalf of Vesta North Carolina, PBLLC ("Vesta"), a wholly owned subsidiary of Project Vesta,
PBC, submitted a complete CAMA Major Permit application to the North Carolina Division of
Coastal Management ("NC DCM") for a project entitled "Placement of Olivine Sand Within the
Nearshore Waters Off the Town of Duck's Oceanfront Shoreline" (the "Project").
On December 7, 2022, the North Carolina Division of Marine Fisheries ("NC DMF") submitted
comments regarding the Project to NC DCM, which comments were similar to comments NC
DMF previously submitted regarding the Project to the United States Army Corps of Engineers
("USACE") in response to Public Notice SAW-2022-0I747 on October 10, 2022.
On ,January 9, 2023, Vesta received a comment letter dated January 9, 2023, from the North
Carolina Division of Water Resources ("NC DWR") in the form of a Request for Additional
Information ("RFI"). As stated in the RFI, that document relates to the application for a 401
Water Quality Certification from NC DWR for the project.
Beginning on January 10, 2023, Vesta engaged in a series of discussions with representatives
of certain resource agencies in North Carolina, including Braxton Davis, Director of NC DCM;
Bill Lane, Deputy Secretary for Policy and Legal Affairs/General Counsel, North Carolina
Department of Environmental Quality ("NC DEQ" ); Kathy Rawls, Director of NC DMF; and
Richard Rogers, Director of NC DWR. In advance of the most recent of such discussions,
Vesta received an informal list of questions compiled by these representatives and, during such
discussions, other questions and comments were provided to Vesta verbally.

Vesta appreciates the continued opportunity to address these remaining questions and
comments. As highlighted during our recent discussions, Vesta desires to work
collaboratively with all parties interested in the Project and welcomes such dialog,
including with respect to the Vesta Detailed Monitoring Plan Proposal attached hereto as
Exhibit A.
Vesta hereby provides responses to the RFI as well as responses to the supplemental questions
raised by the representatives of North Carolina's resource agencies described above. We have
provided specific responses to NC DWR's formal comments and narrative responses to the
supplemental questions received via email and verbally during discussions with the
representatives of North Carolina's resource agencies described above. Vesta's responses are
designed to assist the applicable North Carolina regulatory authorities in the due diligence
activities being conducted by them as part of the review process for the pen -nit applications
described above; Vesta's responses are therefore not to be construed as a waiver of any legal
rights it or its affiliates may have under applicable law. We understand that the questions raised
to date comprise all of the remaining outstanding questions from the State of North Carolina
relating to Vesta's permit application for the Project. However, should additional discussion be
deemed necessary in order for the applicable regulatory authorities to grant the permits Vesta
seeks, then Vesta will be happy to make itself available for such additional discussion.
As highlighted below and in our recent meetings with the representatives of North Carolina's
resource agencies described above, obtaining the permits applied for by Vesta is a critical step in
determining the viability and efficacy of Coastal Carbon Capture as a solution for mitigating the
worst effects of climate change. Vesta eagerly awaits NC DCM's decision on its CAMA permit
application and NC DWR's decision on its requested water quality certification. If we can
provide any additional information which would be helpful to the North Carolina resource
agencies' review processes, we respectfully request that such agencies make requests as soon as
possible to enable the sensitive project schedule to proceed as currently designed.
I. Reasons for Granting the Permits
Below we reiterate for maximum clarity the reasons Vesta believes the Project should be
permitted so as to provide a framework for reviewing Vesta's responses set forth herein:
• The composition of the olivine sand to be used in the Project is substantially similar
to the composition of native sand in North Carolina: Olivine, while not native to the
Duck coastal environment, exists naturally in North Carolina and is very similar in
composition to other sand already found along the North Carolina coastline. As
explained in detail in our prior discussions, all North Carolina beach sand is already
undergoing the same natural weathering process with substantially similar dissolution
products that the olivine sand proposed to be deployed in the Project will undergo and

produce. The important dif-Terence is that the weathering of the olivine sand proposed to
be deployed in the Project is expected to result in the net reduction of carbon dioxide
from the atmosphere.
• The Project is not so significantly large as to create meaningful risk to water quality:
The Project has been sized and designed to minimize and avoid impacts while meeting
the purpose and needs of the Project. The residence time of the significant water volume
in the Duck coastal environment is hours to days, and the small amount of olivine sand
proposed to be deployed in the Project will dissolve over decades. Therefore, at this
scale, it is not possible that this project will affect water quality in a measurable or
impactfuf way. For this reason, the Project is substantially similar to a subscale
traditional nearshore berm placement of the type routinely permitted across the United
States, including in North Carolina, and for which no significant impact should be
expected.
• The Project is designed to cause the olivine sand to mix with the existing native
sand, eventually resulting in very limited or no expected impacts on the benthic
environment. The olivine sand is proposed to be placed in ---25' of water and, according
to robust numerical modeling efforts, has been determined to remain offshore and not
likely to migrate to the beach. It will, however, mix with existing sediment found in
proximity to the deployment area. In contrast to beach nourishment projects designed to
minimize movement of placed sand, the Project is designed to ensure the placed sand
moves and mixes with existing sand to nearly undetectable levels. This mixing process
ensures there will be no significant impacts on the benthic environment.
• The potential positive impact of generating critical data to help develop this climate
restoration solution, in line with North Carolina's climate objectives, far outweighs
any plausible adverse ecological effects. As you know, North Carolina intends to reach
carbon neutrality by 2050. As with all other jurisdictions seeking net carbon neutrality,
decarbonization will not alone be sufficient to reach this goal. Because the beach near the
Town of Duck and the USACE Field Research Facility ("FRF") is perhaps the best
studied coastline in the world, the proposed site for the Project has the potential to
generate nearly all of the data necessary to determine whether Coastal Carbon Capture
has the ability to meaningfully remove carbon dioxide emissions and impact climate
change in North Carolina and elsewhere, all with substantially less expected adverse
ecological effects than will be created by the Town of Duck's already approved and
permitted 2023 beach nourishment project.
H. Vesta Responses to DWR's January 9th RFI
NC DWR Comment #I, "Avoidance and Minimization of Impacts: The applicant has several pilot
projects ongoing in New York, the Dominican Republic and possibly South Carolina. Why is this
project needed in Dare County and why the project and impacts can't be minimized or
relocated?"

Vesta Rc�sl)onse #I. Vesta currently has one pilot of Coastal Carbon Capture operational on Lone
Island, New York, as well as a small experimental trial located in a tidal marsh on Cape Cod,
MA. Vesta does not have a pilot in South Carolina or the Dominican Republic.
The coastline of Dare Country, and in particular, the Town of Duck, is the ideal place for the
proposed pilot in terms of the Project's purpose and needs to quantify carbon removal, as well as
minimizing environmental impact, for the following reasons:
(1) The Town of Duck is home to the USACE FRF. The FRF has collected over 30 years of
data on the hydrodynamics and sediment transport of the Duck coastline, making it
arguably the best studied coastline in the world. Vesta has already leveraged this
outstanding knowledge base to generate an extensively calibrated and robust model of
olivine sediment transport at the proposed Project site. This sediment transport model has
been essential in designing the Project to ensure that little to no olivine sand transports to
the beach, thereby minimizing environmental impact. This model will continue to play a
key role in developing a mechanistic understanding of how olivine transports in the
nearshore environment during the Project.
(2) Vesta is collaborating with scientists at the USACE FRF to monitor sediment transport
during the Project (see attached Exhibit A, Vesta Detailed Monitoring Plan). This work
is being partially funded by a grant through the USACE's Engineering with Nature
Program. The proximity to, and collaboration with, the FRF ensures access to the
outstanding infrastructure the FRF has developed to monitor sediment transport in the
challenging wave conditions found at the Outer Banks (e.g. the Light Amphibious
Resupply Cargo vessel or LARC). This in turn facilitates the Project's purpose and needs
to document carbon removal.
(3) The Project site is also located near the world -class Coastal Studies Institute (Wanchese,
NC). Vesta is collaborating with a number of scientists from the Coastal Studies Institute,
as well as UNC-Wilmington, to conduct an ecological monitoring program for the
proposed pilot (see attached Exhibit A, Vesta Detailed Monitoring Plan).
(4) The highly energetic wave climate of the Dare County coastline is ideal for both
maximizing carbon removal efficiency associated with olivine sand, while
simultaneously minimizing environmental impact. High wave energy and sediment
transport of the olivine sand will ensure that it is integrated into the native sediment in a
thorough and timely manner, becoming a trace component of the sediment and nearly
undetectable, and as such, allowing the sediment to quickly return to prc-placement
conditions. This is essential for minimizing environmental impact. Additionally, wave
energy drives advection of water through the sediment, essentially recharging the water in
contact with the olivine sand. This recharge dilutes any olivine dissolution products,
maintaining concentrations at undetectable levels and thereby minimizing environmental
impact. By ensuring the water does not become saturated with respect to olivine
dissolution products, this recharge also promotes high rates of carbon removal and
enhances the Project's anticipated success.

NC DWR Comment #2: Cause or contribute to a violation of water quality standards which
could also result in secondary or cumulative impacts: The Division and other resource agencies
have expressed concerns that the placement of this material could impact the resources that are
regulated. This placement of mined olivine material may impact the habitat biological integrity
of aquatic wildlife including macrobenthos on a short term and possibly a long-term basis. The
secondary impacts are unknown. The proposed impacts are filling approximately 76 acres of
open water classified as "SB" waters as per 15A NCAC 02B .0300. The protected uses of the
waters are included in 15A NCAC 02B .0222 which is described as primary contact recreation
and any other usage specified by the "SB" classification.
a. The protected standards for classified " SB" waters are listed in 15A NCAC 0213.0220
which include:
(1) The best usage of waters classified as SB shall be aquatic life propagation, survival,
and maintenance of biological integrity (including fishing, fish, and Primary Nursery
Areas (PNAs)); wildlife; secondary contact recreation as defined in Rule .0202 in this
Section; and any usage except primary contact recreation or shell fishing for market
purposes. All salt waters shall be classified to protect these uses at a minimum.
(2) The best usage of waters classified as SB shall be maintained as specified in till's Rule.
Any source of water pollution that precludes any of these uses on either a short-term or a
long-term basis shall be deemed to violate a water quality standard
Vesta Response #2: Vesta does not believe the proposed Project could have a significant impact
oil aquatic wildlife, including macrobenthos, for the following reasons:
(1) The deployment has been sized and designed to minimize and avoid impacts while
meeting the purpose and needs of the Project. Extensive sediment transport modeling of
the proposed placement has indicated that deployment of less than 6,150 cubic yards of
olivine sand would likely result in high rates of sediment loss during 1-2 year return
period hurricanes and 5 year return period hurricanes (Nor'easters), such that the
Project's purpose and needs would no longer be met. In other words, a deployment of less
than the proposed 6,150 cubic yards would result in not enough sand remaining to
facilitate monitoring of carbon removal efficiency. As such, 6,150 cubic yards of olivine
sand is the amount of material that both meets the Project's purpose and needs whilst
minimizing environmental impact. A —6,000 cu yd placement will not cause significant
turbidity and would have a total Project footprint of only —6-acre. This represents an
incredibly small benthic area when considered in the context of the substantial coastline
of the Outer Banks, and as such, is not likely to cause significant harm. As explained in
more detail below, Vesta is willing to agree to a permit condition governing the maximum
amount of olivine sand used in the Project so that NC DWR and other resource agencies
in North Carolina will have confidence that Vesta is only deploying the minimum amount
ofolivine necessary to conduct the Project.
(2) Olivine sand is very similar in composition to the sand already found in North Carolina.
As explained in prior discussions, all NC beach sand is already undergoing the same
natural weathering process that the olivine sand would undergo with substantially similar
dissolution products. Olivine ((Mgo.92Feo.og)2SiO4) is a silicate mineral just like quartz
(SiO,), the most abundant mineral in NC beach sand. As such, the major components of

the two minerals (silicon and oxygen) are the same, and as a silicate -based mineral, the
structure of the mineral is such that it feels like native quartz beach sand. Magnesium is a
common constituent of carbonate beach sand, and in general, is the third most abundant
ion in seawater, behind potassium and chloride (NaCl, or salt). Lastly, minerals with
primary metal components naturally make up 2-8% of NC beach sand and include garnet
(Fe;Al,(SiO<,),), zircon (ZrSiO,), ilmenite (FeTiO;), hematite (Fe,O,), and magnetite
(Fe;O,).
(3) Given the small size of the proposed Project, the slow dissolution rate of olivine
(decades), and the short residence time of water along the Duck coastline (hours to days),
dilution of dissolution products makes it not possible that this project will affect water
duality in a measurable or impactful way.
(4) Furthermore, because the olivine sand will disperse over time through natural sediment
transport processes, any impacts, including to the benthos or water duality resulting from
the olivine or its dissolution products, would be highest at the start of the Project and
decrease through time as the concentration of olivine sand in any given area declines to
nearly undetectable levels. As such, observations about environmental impacts made
during the monitoring period will be conservative with regards to future years and
decades. The highly energetic wave climate of the Outer Banks will ensure quick and
thorough integration of the olivine sand into the native sediment, rapidly returning it to
near pre -placement conditions and in turn, minimizing environmental impact.
(5) Nevertheless, quantifying carbon removal efficiency and any environmental impacts,
positive or negative, are the primary objectives of the proposed pilot. As such, Vesta has
prepared a Vesta Detailed Monitoring Plan (see attached Exhibit A) that describes the
planned efforts to monitor water, sediments, ecology, and sediment transport at the
project site over a minimum of two years.
1111. Vesta Responses to Supplemental Questions from North Carolina Resource Agencies
A. Vesta Operations
We note initially that certain of the questions Vesta received pertain to Vesta's economic model
and supply chain. We therefore think it will be helpful to provide a brief overview of Vesta's
operations.
Project Vesta, PBC, the sole parent entity of permit applicant Vesta North Carolina, PBLLC, is a
Delaware Public Benefit Corporation with the following stated public benefit in its charter
documents: "to promote positive effects (or reduce negative effects) on the environment,
including by protecting coastlines and oceans and by removing carbon dioxide from the
atmosphere." Vesta North Carolina, PBLLC has adopted this same public benefit statement,
meaning the Vesta family of companies is formally committed in its highest level organizing
documents to achieving the mission of, among other things, removing carbon dioxide from the

atmosphere and protecting coastlines. In short, Vesta was created for the purpose Ofensuring the
responsible development of Coastal Carbon Capture and has bound itself to that ethos formally.
Vesta is funded by philanthropists and investors who are focused on financing climate solutions.
An example is the Grantham Foundation, a 501(c)(3) which funds potential climate solutions.
The proposed project in Duck would be funded by Vesta, utilizing donations originating from the
Grantham Foundation and other similar tinders. While Vesta may sell carbon removal products
resulting from the Project, the income from these sales are not expected to exceed the cost of
funding the Project and will therefore only be used to partially offset the costs of the Project.
In terms of Vesta's supply chain, we would naturally prefer to source the olivine for the Project
from within North Carolina. We have been in touch with the owners of an inactive olivine mine
in North Carolina; they cannot supply olivine at this time. Given that situation, we cannot
commit to sourcing olivine from within North Carolina, but we will always seek bids from
suppliers within the state where possible, and evaluate them on their merits.
Regarding the Project's net removal of carbon dioxide from the atmosphere, we note that
removing carbon dioxide from the atmosphere on a net basis is not a requirement to meet the
stated purpose and needs of the Project. The goal of doing a pilot project is not to impact the
climate but rather to understand the viability and efficacy of Coastal Carbon Capture as a carbon
removal tool. However, we note here, as we have elsewhere, that the Project is expected to
produce net permanent removal of carbon dioxide from the atmosphere, which removal would
not have occurred but for the actions undertaken in the Project. In the interest of transparency we
provide here further information about the analysis which led us to this conclusion. We have
conducted a "life cycle assessment" or "LCA," to examine the carbon dioxide emissions
("process emissions") and removal of Coastal Carbon Capture in order to determine expected
carbon dioxide removal net of process emissions. This analysis shows that transportation and
deployment of the olivine will contribute the vast majority of process emissions, with shipping as
the largest single contributor. Shipping by bulk carrier has an average CO, Energy Efficiency
Operational Indicator (EEO1) of 7.6 gCO2/tonne-nm according to the International Maritime
Organization Greenhouse Gas Study, leading to process emissions of <300t CO, from shipping.
Analyses of all other aspects of the supply chain yield a sum of total emissions which is well
below even the lowest estimates for the total carbon removal from the project. We plan to refine
the LCA as one of the outputs of the Project (for example by incorporating emissions fi-om the
actual equipment used to deploy the olivine) and this will be made available as part of Vesta's
reporting of the results.
B. Project Size
Much of Vesta's correspondence with resource agencies in North Carolina has centered on the
size of the proposed Project. Initially, Vesta proposed a Project size which would have been

ideal for effectively conducting the scientific research program designed for the Project. Vesta
appreciates the resource agencies' preference for the Project to be sized at its absolute minimum.
As discussed in detail during the January 25, 2023) meeting with NC DMF, NC DCM, and NC
DWR representatives, Vesta is happy to agree to a permit condition that reflects a minimized
placement size for the proposed olivine sand and is reiterating that sentiment here. For the
reasons set forth above, 6,150 cubic yards of olivine sand is the amount of material that both
meets the Project's purpose and needs while minimizing environmental impact. Should a permit
condition be made, Vesta requests the condition allow i p to 7, 000 cubic_yards of olivine sand in
acknowledgement of possible overages during material production as well as losses during
transport and deployment of the material.
C. Project Location
Additionally, NC DMF inquired about the reason for the proposed Project location slightly
shoreward of the Depth of Closure (DOC). The placement location must remain shoreward of the
DOC, and not further offshore, for a few reasons. The DOC represents the location along the
cross -shore profile where energy from waves no longer touches the seafloor, and in turn,
sediment transport becomes small or non-existent. Transport of the olivine sand will ensure that
it is integrated into the native sediment in a thorough and timely manner, becoming a trace
component of the sediment and nearly undetectable, and as such, allowing the sediment to
quickly return to pre -placement conditions. This is essential for minimizing environmental
impact. Additionally, wave energy on the seatloor drives advection of water through the
sediment, essentially recharging the water in contact with the olivine sand. This recharge dilutes
any olivine dissolution products, maintaining concentrations at undetectable levels and thereby
minimizing environmental impact. By ensuring the water does not become saturated with respect
to olivine dissolution products, this recharge also promotes high rates of carbon removal and
enhances the Project's anticipated success. As noted in the permit application, monitoring
logistics also become extremely challenging in deeper waters. Taken together, Vesta has
proposed to place the olivine sand slightly shoreward of the DOC but simultaneously as far from
the beach as possible to address the additional goal of keeping the olivine sand off the dry beach
so as to not impact sea turtle nesting habitat or beach aesthetics.
D. Project Timing
NC DMF also sought to understand the rationale behind the proposed timing of the Project in
spring (e.g. June, July). There are a number of reasons why Vesta believes this is the necessary
placement window. These are outlined here:
(1) A June -July placement is outside the key transit periods for Atlantic Sturgeon (winter)
as well as North Atlantic Right Whales (fall, spring). As such, the proposed placement
tirne minimizes environmental impact to these important species.

(2) Due to the small volume of this project, the type of vessel that would deploy the
material are small split -bull scows, for example. These small vessels are not capable of
operating safely in the Outer Banks' winter wave conditions.
(3) Allowing for natural transport processes to quickly and thoroughly integrate the
olivine sand into the native sediment is essential for returning the sediment to effectively
pre -deployment conditions, and in turn, minimizing environmental impact. Quick
integration of the olivine sand is best accomplished by placing the material in June -July
and utilizing the high wave intensity hurricane season (late August -November).
(4) To meet the purpose and needs of the project it is critical to conduct monitoring for at
least two months before hurricane season. This ensures that some carbon removal data
can be generated (and the Project's purpose and needs met) should, for example, a
low -frequency, high intensity (e.g. 100 year return period) storm occur early in hurricane
season.
(S) Scientists at the USACE FRF have received a grant from the USACE Engineering
With Nature program to collaborate with Vesta on the sediment monitoring program. The
majority of this funding is allocated for FY 2023, which concludes in September 2023.
As a result, the purpose and needs of the Project will be best met by deploying in June
and leveraging the FRF resources and capabilities during the applicable funding window.
E. Monitoring Plan
In addition to the above, NC DMF raised a number of questions seeking more detail on the
monitoring plan for the proposed pilot, for example, trawling survey design, number of core
samples, monitoring of the beach. In response to these questions and others provided in previous
comments, Vesta has prepared and attached the Vesta Detailed Monitoring Plan (Exhibit A).
Below are also a few bullet points to provide clarity on the science behind Coastal Carbon
Capture and the scientific aspects of the proposed pilot:
• Given the small size of the proposed Project, the slow dissolution rate of olivine
(decades), and the short residence time of water along the Duck coastline (hours to days),
this Project will not measurably impact alkalinity levels in the water column. The
reference to alkalinity generation and offsetting ocean acidification in the EA pertains to
the co -benefit of deploying olivine sand at significant scale, in tandem with a meaningful
impact on global CO, levels and climate change.

• Key water duality metrics such as pH, dissolved oxygen, turbidity, and chlorophyll A will
be made continuously over the course of the project, a minimum of' 2 years, via
deployment of an FX02 sonde (see Exhibit A, Vesta Detailed Monitoring Plan). Vesta
is not expecting any significant impact to water quality based on the slow dissolution rate
of the olivine sand as compared to the residence time of water in the nearshore waters of
duck. Dilution will ensure there are no adverse impacts on water quality.
Nevertheless, because the olivine sand will disperse over time through natural sediment
transport processes, any impacts, including to water quality, would be highest at the start
of the project and decrease through time as the concentration of olivine sand in any given
area declines to nearly undetectable levels. As such, observations about environmental
impacts, including to water quality, made during the monitoring period will be
conservative with regards to future years and decades.
+ It was noted in the January 25, 2023 meeting with NC DMF, NC DCM, and NC DWR
representatives that although olivine is a non-native mineral to the coastline of NC, the
constituents that comprise olivine are commonly found. Olivine ((Mg0.92Feo,,,)2SiOJ is a
silicate mineral just like quartz (SiO,), the most abundant mineral in North Carolina
beach sand. As such, the major components of the two minerals (silicon and oxygen) are
the same, and as a silicate -based mineral, the structure of the mineral is such that it feels
like native quartz beach sand. Magnesium is a common constituent of carbonate beach
sand and in general, is the third most abundant ion in seawater, behind potassium and
chloride (NaCI, or salt). Lastly, minerals with primary metal components naturally make
up 2-8% of North Carolina beach sand and include garnet (Fe3AI,_(SiO,)3), zircon
(ZrSiO,), ilmenite (FeTiOA hematite (Fe,03), and magnetite (Fe;O,,).
• NC DMF noted that "Even if the project is part on hold until there are results frown other
studies, the locations of those studies may not be representative of the conditions of
coastal NC (water/sediment circulation, wave patterns/intensity/etc.. weather/climate,
etc.)_„
Meaningful insights into potential environmental impact can be gleaned by laboratory
tests and other studies. This underpins the utility of testing model organisms, for
example. Nevertheless, the NC DMF is correct that a comprehensive analysis of potential
impact is best assessed on a site -specific basis. Hence the need for small-scale, well
designed, and highly monitored pilot projects such as the one proposed by Vesta for the
nearshore waters of Duck.
• NC DMF noted that "The Vesta response stating they will have marine mammal
observers dare to any sound impacts .satisfies that concern. Additionally, confirmation of

1he aclual footprint reduces concerns over lurbiclili: but other aplVicallis are often
required to mmnilor turbidity and slop if it exceeds a ccrlain level."
Vesta's Deployment Monitoring plan includes turbidity measurements (see Exhibit A,
Vesta Detailed Monitoring Plan).
F. Project Precedent and Future Plans of Vesta
Finally, certain questions received by Vesta suggest the North Carolina resource agencies are
concerned about the precedential effects of granting the permits for which Vesta has applied. We
would like to address this concern in some detail.
Vesta is a science -first organization. If and to the extent the scientific goals of the pilot Project in
Duck are met and Vesta concludes from a science perspective that Coastal Carbon Capture is a
viable and effective method of atmospheric carbon dioxide removal, then it will likely be
environmentally beneficial for Vesta and others to move forward with additional deployments of
Coastal Carbon Capture, potentially at larger scale. Any such future deployment of Coastal
Carbon Capture — whether small or large, onshore or nearshore, in shallow or deep water, in
North Carolina or elsewhere in the United States — would, as with any coastal construction
project, be subject to state and federal law and permit review by applicable regulatory bodies.
Because all such olivine sand deployments in the future would naturally occur on a case -by -case
basis within a robust regulatory framework, Vesta is confident that those tasked with managing
and protecting public resources will be empowered to assist developers of Coastal Carbon
Capture with designing carbon removal projects in an environmentally sound manner. Vesta
believes that a permit granted for the proposed Project will be but a single instance of
well-informed regulatory authorities evaluating and determining the appropriateness of a
one-time deployment of Coastal Carbon Capture. Because that initial review will have set an
excellent precedent for rigorous and thorough project and monitoring program design, we expect
that future permit applicants will be tasked with seeking permits in a similarly rigorous and
thorough process tailored for the specific location proposed for the deployment. With these
myriad procedural and substantive protections already in place, we expect the risk of
inappropriately permitting deployments of Coastal Carbon Capture to be very low.
The Vesta team thanks the North Carolina resources agencies for their transparent approach in
raising questions and concerns about the Project. We are grateful for the State of North
Carolina's curiosity and openness to our responses, and we stand ready to continue to be
responsive to any further inquiries. It is critically important to Vesta not only to proceed with this
project but to do so on the timing we originally proposed when we first applied for the CAMA
permit in July of 2022. Given that it takes time to plan for project construction, we hope to work

swiftly and collaboratively with the resource agencies in the State of North Carolina to complete
this process and secure the permits we are seeking.
Sincerely,
Tom Green, CEO
Grace Andrews, Head of Science
Douglas Edwards, General Counsel and Head of Operations
Project Vesta, PBC
Vesta North Carolina, PBLLC
cc: Bill Lane, Deputy Secretary for Policy and Legal Affairs, NC DEQ (via e-mail);
Braxton Davis, Director, Division of NC DCM (via e-mail);
Kathy Rawls, Director of NC DMF (via e-mail);
Richard Rogers, Director of NC DWR (via e-mail);
Josh Pelletier, USACE Washington Field Office (via e-mail)
Gregg Bodnar, DCM Morehead City (via e-mail)
Maria Dunn, NC WRC — WaRO (via e-mail)
Jimmy Harrison, NC DMF — WaRO (via c-mail)
Vesta hereby expressly reserves and does not waive any rights related to NC DWR's review of
the application for 401 Water Quality Certification pursuant to 15A NCAC 02H.0500 et seq.

Exhibit A
Vesta Detailed Monitoring Plan
[see attached]

Placement of Olivine Sand Within the Nearshore Waters off the Town
of Duck's Oceanfront Shoreline
Vesta Detailed Monitoring Plan
Prepared January, 2023

1
2
3.
4
5.
7.
Table of Contents
Overview
2
Deployment Monitoring
3
2.1 Mobile Megafauna
5
2.2 Water Quality
5
Water Chemistry
5
3.1 Continuous Water Column Monitoring
7
3.2 Water Column Discrete Sampling
7
3.3 Porewater Discrete Sampling
7
3.4 Benthic Flux Discrete Sampling
7
3.5 Water Column "Snapshots"
g
Sediments
g
4.1 Sediment Core Surveys
g
Ecology
g
5.1 Benthic Infauna
g
5.1.1 Benthic Infauna Community Structure
g
5.1.2 Benthic Infauna Trace Metals
10
5.2 Benthic Mobile Fauna
10
5.2.1 Benthic Mobile Fauna Community Structure
10
5.2.2 Benthic Mobile Fauna Trace Metals
10
5.3 Phytoplankton and Zooplankton
11
5.3.1 Phytoplankton and Zooplankton Community Composition
11
5.3.2 Demersal Zooplankton Recruitment
11
Hydrodynamics and Sediment Transport
11
6.1 Bathymetry Surveys
11
6.2 Wave Climate
12
6.3 Tides
12
References
12
1

1. Overview
Vesta is developing Coastal Carbon Capture (CCC), a Carbon Dioxide Removal (CDR) strategy
that combats climate change by placing olivine sand in coastal waters. Vesta is proposing a pilot
placement of olivine sand as a nearshore berm off of Duck, NC. The project is currently scoped
to place up to —20,000 cubic yards of olivine sand —1,500 ft from the shoreline at a water depth
of --25 ft. Vesta has noted in its correspondence with DCM, DMF, and DWR that it would be happy
to receive a permit condition limiting the placement size to —7,000 cu yd olivine sand. A --7,000
cu yd project would be expected to have a footprint of —6-acres. Construction of this project is
planned for spring 2023, approximately June and/or July. The placement window is such that the
olivine sand will be deployed outside of key migratory periods for protected species such as
Atlantic Sturgeon (fall/winter) as well as North Atlantic Right Whales (spring/fall).
Vesta plans to conduct an extensive monitoring program for the proposed project aimed at 1)
quantifying the efficiency of COZ removal from the atmosphere and 2) quantifying environmental
impacts, positive or negative. The monitoring program encompasses a suite of hydrodynamic
geochemical, sedimentological, and ecological parameters observed pre- and post- deployment
in both control and treatment areas. This follows a Before -After -Control -Impact (BACI) design.
Vesta is committed to monitoring the project for a minimum of 2 years. A project map and sampling
timeline is provided below (Figure 1, Table 1)
Vesta will be conducting aspects of the monitoring program in collaboration with scientific partners
from the Coastal Studies Institute (Wanchese, NC), UNC-Wilmington, UNC-Greensboro and the
US Army Corps of Engineers (USACE).
2

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Duck Monitoring l
Program �.JI
Legend
Monitoring Locations
0 Survey Points
ti Sediment Cores
•� BFC Lander
(Ind. 3 repeat samples)
qJ Benthic ftology
(ind. 3 repeat samples)
• Porewater (PW)
x Seawater (5W)
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• Tide Gauge
iBathymetry Survey
Boundary
Deployment Sountlaries
p Deployment Area
p DePoyment Corridor
Basemap
1 ft Contours
OSM Standard
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Figure 1. Map of monitoring locations (see key) in the proposed project area divided into three zones:
Control North, Olivine, and Control South. Exact locations are subject to change and dependent on
weather, logistical constraints, and other practical considerations. Monitoring locations will also likely
evolve as preliminary datasets are generated and the scientific understanding of the site advances.
3

B I Month (Year 1) I Month (Year 2)
1 1 2 3 4 5 6 7
8 9
10 11 12 1 2 3 4 5 6 7 8 9 10 1T 12
Continuous Water
Chemistry
Discrete Water
Chemistry
Sediment Cores
Benthic Intauna
Community
Structure
Benthic infauna
Trace Metals
Benthic Mobile
Fauna Community
Structure
Benthic Mobile
Fauna Trace
Metals
Phyto/Zooplankton
Community
Composition
Demersal
zoopiankton
experiment
Bathymetry"
Wave Climate
Tides
Table 1. Gantt chart of monitoring initiatives. "B" represents the baseline, pre -deployment period and may
extend for longer than one month, as permissible. Precise timing of sampling surveys are sea -state
dependent and may also evolve throughout the project based on preliminary data and method refinement,
in collaboration with Vesta's scientific partners. Subsequent to pre- and post- deployment surveys,
bathymetry survey (*`) timing is targeted toward pre- and post- storm events and wilt be determined in
real-time.
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2. Deployment Monitoring
2.1 Mobile Megafauna
Vesta will ensure a professional Marine Mammal Observer is present during olivine sand
placement to avoid interactions between deployment vessels and marine mammals or other
protected species. Additionally, a small vessel will be present conducting side -scan sonar
surveys in real-time to identify and avoid protected species present, such as sea turtles, in the
area at time of deployment. Side scan sonar will also detect Atlantic sturgeon in the deployment
area, however planned construction will take place during low season for this species. Vesta plans
to conduct the real-time side scan sonar surveys in collaboration with scientists from USACE.
2.2 Water Quality
During and immediately after olivine sand placement, water quality snapshots will be recorded on
an AquaTROLL 500 sonde to monitor both within and outside of the placement area. The
AquaTroll will also record snapshots of water turbidity created due to project construction. See
section 3.5 for details on the AquaTROLL 500.
3. Water Chemistry
To monitor water chemistry, the program will include continuous measurement of water column
chemistry by multiparameter sonde deployments (e.g. YSI EXO2), as well as monthly discrete
sampling in the form of water column, porewater, and benthic flux chamber (BFC) surveys.
Additionally, an AquaTRO1_L 500 sonde will be used to perform water quality "snapshots" of the
water column alongside the discrete sampling surveys. A list of all water chemistry parameters to
be measured and their significance is provided in Table 2.
5

PARAMETER
RESERVOIR
SIGNIFICANCE
water column (continuous)
water column (snapshot)
environmental impact
ph
water column (discrete)
porewater (discrete)
carbon removal
benthic flux (discrete)
water column (continuous)
water column (snapshot)
environmental impact
dissolved oxygen (DO)
water column (discrete)
porewater (discrete)
carbon removal
benthic flux (discrete)
total algae (Chlorophyll,
water column (continuous)
environmental impact
Phycocyanin & Phycoerythrin)
water column (snapshot)
turbidity
water column (continuous)
environmental impact
water column (snapshot)
water column (continuous)
water column (snapshot)
environmental impact
temperature
water column (discrete)
porewater (discrete)
carbon removal
benthic flux (discrete)
water column (continuous)
water column (snapshot)
environmental impact
salinity/conductivity
water column (discrete)
porewater (discrete)
carbon removal
benthic flux (discrete)
iron and sulfide
porewater (discrete)
carbon removal
water column (discrete)
total alkalinity
porewater (discrete)
carbon removal
benthic flux (discrete)
water column (discrete)
dissolved inorganic carbon (DISC)
porewater (discrete)
carbon removal
benthic flux (discrete)
water column (discrete)
nutrients
porewater (discrete)
environmental impact
benthic flux (discrete)
water column (discrete)
environmental impact
trace metals
porewater (discrete)
benthic flux (discrete)
carbon removal

dissolved organic carbon (DOC)
water column (discrete)
environmental impact
carbon removal
i ame [. vvater chemistry monitoring overview: parameters that will be measured, the reservoirs in which
they will be measured, and the significance of the parameter for meeting the monitoring objectives.
3.1 Continuous Water Column Monitoring
A multiparameter sonde (e.g. YSI EX02) will be deployed in close proximity to the olivine
placement area to monitor key biogeochemical parameters within bottom waters. The EX02 is
equipped with sensors to monitor pH, Dissolved Oxygen, Total Algae (Chlorophyll, Phycocyanin
& Phycoerythrin), Turbidity, Temperature, and Salinity (Table 2). The sonde will be deployed prior
to olivine placement to establish pre -placement water quality conditions and will continue for the
duration of the project (see Gantt Chart, Table 1). Sonde deployment periods will run for 4 - 6
weeks, between which the sonde will be serviced in preparation for the following deployment. All
sonde data will be corrected for calibration and bio-fouling drift.
3.2 Water Column Discrete Sampling
The water column will be discreetly sampled using Niskin surveys. Surveys will include a minimum
of 4 sample locations with two in both of the olivine placement and control areas. Collected
samples will be processed by Vesta staff according to best oceanographic sampling practices
(Dickson et al., 2007). In house analyses will be performed shortly after sample collection, and
samples for external analysis will be shipped appropriately. The first Niskin survey will be
conducted approximately one month prior to olivine placement, with subsequent surveys
occurring monthly for the duration of the project (sea -state dependent, Table 1)
3.3 Porewater Discrete Sampling
Porewater surveys will be conducted using USACE Field Research Facility (FRF) resources to
access sample locations and deploy survey instrumentation. Surveys will include 5 sample
locations (Figure 1). Sample locations were chosen to correspond to ecological sampling
locations for data intercomparison, as well as to investigate olivine dissolution efficiency across
berm thicknesses. Porewater samples will be collected at a minimum 5 depths per sampling
location. Collected samples will be processed by Vesta staff according to best oceanographic
sampling practices (Dickson et al., 2007). In house analyses will be performed shortly after
sample collection, and samples for external analysis will be shipped appropriately. The first
porewater survey will be conducted approximately one month prior to olivine placement, with
subsequent surveys occurring monthly for the duration of the project (sea -state dependent, Table
1),
3.4 Benthic Flux Discrete Sampling
BFCs are acrylic chambers that are filled with seawater and placed on the sediment -seawater
boundary, thereby trapping a parcel of seawater against the boundary and allowing olivine
dissolution products to accumulate through time. This parcel of water can then be measured for
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the parameters listed in Table 2. BFC surveys will be conducted using USACF FRF resources to
access sample locations and deploy survey instrumentation. Surveys will include 3 sample
locations, which were chosen to investigate olivine dissolution efficiency across different berm
thicknesses (Figure 1). Replicate sampling will take place at each sample location. Collected
samples will be processed by Vesta staff according to best oceanographic sampling practices
(Dickson et al., 2007). In-house analyses will be performed shortly after sample collection, and
samples for external analysis will be shipped appropriately. The first BFC survey will be conducted
approximately one month prior to olivine placement, with subsequent surveys occurring monthly
for the duration of the project (sea -state dependent, Table 1).
3.5 Water column "snapshots"
An In -Situ Aqua TROLL 500 multiparameter water quality sonde will be used in conjunction with
niskin, porewater, and BFC surveys in order to capture real time "snapshots" of key water quality
parameters (Table 2) of bottom waters at each sample location. This information will assist in the
interpretation of discrete sample datasets resulting from the surveys.
4. Sediments
4.1 Sediment Core Surveys
Sediment cores will be collected during each porewater and benthic flux chamber survey in order
to characterize the physical, chemical, and biological characteristics of sediments at each
sampling location. Core locations (Figure 1) will follow those of the porewater and BFC surveys,
with coring equipment deployed in coordination with the USACE FRF. Once collected, cores will
be subsampled at depth intervals of interest (typically 4-5 subsamples) and dried prior to analysis.
Sediment samples will be selectively analyzed for the parameters listed in Table 3 in order to
quantify the efficiency of olivine dissolution, track olivine and native sediment distributions through
time, and/or study the environmental impacts of the project. Core sampling frequency will match
that of porewater and BFC surveys, approximately monthly (sea -state dependent, Table 1) with
add -on sediment core and/or grab sample collection as needed, including at the dry beach should
any olivine migrate to the shore. Vesta's scientific collaborators at the USACE FRF will conduct
additional sediment core surveys and grab samples approximately four times per year, as USACE
Engineering with Nature program funding permits.
In addition to informing carbon removal efficiency, the sediment samples will be used to determine
the spatial distribution of olivine from the deployment site and its transport pathways through time.
Grain size analysis will be used to understand the horizontal and vertical sorting of olivine within
the native sediment. The results will be combined with changes in bed elevation derived from
repeat bathymetric surveys (see Section 6) to support identification of the spatial distribution of
olivine.
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PARAMETER
SIGNIFICANCE
Trace Metals
carbon removal
environmental impact
Total Inorganic Carbon (TIC)
carbon removal
Total Organic Carbon (TOC)
carbon removal
Grain Size
carbon removal
sediment transport
Bulk Mineralogy
carbon removal
sediment transport
Microbial Community DNA
carbon removal
environmental impact
Table 3. Sediment monitoring overview: parameters that will be measured and the significance of the
parameter for meeting the monitoring objectives.
5. Ecology
The Ecology Monitoring Program aims to measure the potential impacts of olivine sand placement
on marine biota. To meet this objective, community structure of the marine flora and fauna will be
compared between the olivine deployment site and two control sites following a Before -After -
Control -Impact (BACI) design. Recovery timelines following sand placement can be compared to
results from prior peer -reviewed publications. In addition, the program assesses ecotoxicological
impacts of olivine through trace metal concentration and bioaccumulation surveys of benthic
infauna. The monitoring program focuses on organisms at the base of the food web (benthic
infauna, benthic mobile fauna, phytoplankton, and zooplankton). By studying the impact on those
communities, information about the potential impact to organisms from higher trophic levels
(migrating fish, sea turtles, marine mammals) will be obtained.
5.1 Benthic infauna
5.1 A Benthic Infauna Community Structure
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To assess the impact of olivine sand on benthic infauna community structure and diversity,
sediment cores will be collected from three distinct zones: Control North, Olivine, and Control
South. In each zone, 3 replicate sediment push cores will be collected from 3 sites by SCUBA
divers (Figure 1). Sediment cores are then sieved, macrofauna are sorted and preserved, and
then analyzed taxonomically. To capture natural seasonal variability, sampling for this activity will
take place 4 times per year. Surveys will begin prior to olivine placement and continue for 2 years
post -deployment to span a sufficiently long period to document infauna recovery. This work will
be conducted in collaboration with scientists from the Coastal Studies Institute.
5.1.2 Benthic infauna Trace Metals
To assess the ecotoxicological effect of olivine on benthic infauna communities, macrofauna will
be sampled using the same techniques as for community structure surveys. Collected sediment
is sieved and macrofauna are sorted. Macrofauna individuals are then kept alive in seawater for
48 hours to clear their gut content. Afterwards, macrofauna individuals are dried and sent for trace
metals analysis. The post -deployment sampling will occur at least two or three months after olivine
deployment to allow for the inhabiting organisms to recolonize. Additionally, to assess any
potential long-term ecotoxicological effects, sampling will also occur a year after deployment. This
work will be conducted in collaboration with scientists from the Coastal Studies Institute.
5.2 Benthic Mobile Fauna
5.2.1 Benthic Mobile Fauna Community Structure
To assess the impact of olivine on mobile benthic community structure and diversity, bottom trawl
surveys will be conducted from three distinct zones: Control North, Olivine, and Control South. To
report mobile fauna community structure and diversity, the content of the trawl is sorted, species
identified and photographed, and their relative abundance recorded before being returned to the
collection area. To capture natural seasonal variability, sampling for this activity will take place 4
times per year. Surveys will begin prior to olivine placement and continue for 2 years post -
deployment to span a sufficiently long period to document recovery. This work will be conducted
in collaboration with scientists from the Coastal Studies Institute.
5.2.2 Benthic Mobile Fauna Trace Metals
To assess the ecotoxicological effect of olivine on mobile benthic communities, mobile benthic
fauna will be sampled during mobile benthic fauna trawl surveys described above. After the
taxonomic assessment, three living individuals of each species are collected and placed in
seawater holding tanks. Individuals are kept alive for 48 hours to clear their gut content.
Afterwards, individuals are dried and sent for trace metals analysis. The post -deployment
sampling will occur at least two or three months after olivine deployment to allow for the inhabiting
organisms to recolonize and potentially bioaccumulate trace metals. Additionally, to assess any
potential long term ecotoxicological effects, sampling will also occur a year after deployment. This
work will be conducted in collaboration with scientists from the Coastal Studies Institute.
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5.3 Phytoplankton and Zooplankton
5.3.1 Phytoplankton and Zooplankton Community Composition
To assess the impact of olivine on phytoplankton and small zooplankton community structure,
relative abundance, and diversity in the water column and sediment, a water column microbial
community sample is collected by passing water collected in a Niskin bottle through a 0.45um
filter. Niskins will be collected across three distinct zones: Control North, Olivine, and Control
South. Microbial communities in the sediment will be sampled using a cryolander or contact core.
To characterize the diversity and abundance of microbial communities, the samples will undergo
a DNA extraction step and illumina tag sequencing. A baseline survey will take place prior to
olivine sand deployment. Then, sampling will occur monthly throughout the immediately following
months and subsequently quarterly for up to 2 years post olivine sand deployment. This work will
be conducted in collaboration with scientists from UNC-Wilmington.
5.3.2 Demersal Zooplankton Recruitment
Demersal (benthic) zooplankton can serve as an important food source and trophic link in coastal
ecosystems. To assess whether demersal zooplankton preferentially settle between olivine and
native sediment mixes, we will use reentry traps to test differences in demersal recruitment across
different volumes of olivine and native sand. Reentry traps containing the sediment mixes will be
deployed off of the USACE FRF Pier at night and left until day where zooplankton will recruit to
these different substrates. Traps will be recovered and zooplankton abundance and community
composition will be characterized. Oceanographic conditions at the FRF Pier are sufficiently
similar to the project site to test for recruitment to different sand substrates. Vesta, in collaboration
with scientists from UNC-Wilmington, will conduct this experiment over three 24-hour periods in
the months immediately following sand deployment.
6. Hydrodynamics and Sediment Transport
A hydro-morphodynamic model (Delft3D) was used to design the olivine deployment and predict
the transport of olivine through time under different wave climate conditions. During the pilot
project, a variety of surveys will be conducted to (1) track the transport of olivine through time, (2)
understand the hydrodynamic drivers of sediment transport (3) further calibrate the Delft3D model
and (4) predict future transport behaviors to guide the spatial and temporal frequency of
monitoring efforts.
6.1 Bathymetry Surveys
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Bathymetric surveys pre- and post- deployment will be used to identify the initial footprint and
geometry of the olivine placement, within the tolerance of the employed method and equipment.
Repeat surveys will be collected during the monitoring period with an emphasis on capturing pre -
and post- storm conditions. The surveys will be used to determine geomorphic change and infer
the movement and dispersion of the olivine berm through time according to changes in bed
elevation near the deployment site. The surveys will infer the likely location of the berm until the
point at which it has dispersed to a thickness less than the resolution of the survey equipment.
Combining Bathymetric change with data from sediment core surveys and grab samples (see
Section 4) can be used to map the spatial distribution of olivine to a greater resolution and with a
higher level of confidence than either survey alone.
6.2 Wave Climate
The wave climate plays a key role in controlling the amount of energy a system is subject to and
in which direction that energy is focused (e.g longshore, cross -shore). This determines the
potential for olivine to be transported, the rate of transport and the transport pathway itself. It can
also be important in interpreting water geochemistry data.
Hourly wind and wave data for the site is collected by NOAA's National Data Buoy Center (NDBC).
Two Datawell Directional Waverider Buoys are available, deployed in 85 ft water depth
approximately 11.5 miles offshore of the Town of Duck (NDBC Station 44100) and in 55 ft water
depth approximately 2.3 miles offshore (NDBC Station 44056). Further nearshore wave and
current measurements are recorded by an FRF Acoustic Wave and Currents (AWAC) profiler,
deployed in 20 ft water depth approximately 0.3 miles offshore.
6.3 Tides
The tidal signal can be used in conjunction with sedimentological and geochemical data to
determine its effect on the transport of olivine and water geochemistry. The NOAA tide gauge
station (Station ID: 8651370) is installed on the USACE= FRF pier and records water levels at 6
minute intervals.
7. References
Dickson, A. G., Sabine, C. L., & Christian, J. R. (2007). Guide to best practices for ocean COZ
measurements. North Pacific Marine Science Organization.
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