20190035 Ver 1_Public Comments_20230915

Baker, Caroline D
From: Lisa Stroup <[e-mail]>
Sent: Friday, September 15, 2023 7:36 PM
To: Chad Brown; Allen Fraley; [e-mail]; [e-mail];
[e-mail]; [e-mail];
[e-mail]; Homewood, Sue; Taylor, Shawn A; Kastrinsky, Josh;
Lawyer, Mike; Parr, Adam
Subject: [External] Piedmont Lithium Project County Commissioner Meeting August 8 2023
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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The following questions were submitted to the Gaston County Commissioners in advance of the scheduled August 8th
meeting with Piedmont Lithium. Three questions were asked during the meeting, due to time constraints. However, as
instructed by Commissioner Chad Brown, the full list of questions were emailed to Adam Gaub on 8-9-23. Below are the
incomplete answers from Piedmont Lithium and the Gaston County Commissioners, provided by Dandria Bradley
received on September 6, 2023. As well as additional information pertaining to the rules and regulations surrounding
permitting.
I have communicated with multiple local, state and federal agencies and individuals representing those agencies, the
Governor of NC and the NC Senate Representative of the lack of broadband internet service access and cell phone
service in the immediate community and how this has and continues to hinder our ability to access and participate in
every stage of this project development and permit application process. To date, no individual nor agency has provided
any solutions nor afforded any viable means for accessing the information nor for allowing the affected communities
adequate opportunities for public participation in these decisions.
Please note that the answer provided for question 1A was not a truthful statement, as observed in the ADI #3 response
submitted to NC DEMLR. Per the 2019 Section 404 Permit (SAW-2018-01129), the permitted project area is for 917
acres., Figure 1 of the document shows the project site location covered by the existing 404 permit. The following terms
of coverage are provided in the US ACE document details:
Waste Rock: Approximately 781 linear feet of perineal stream channel, 2,283 linear feet intermittent stream channel,
0.14 acres jurisdictional wetlands and 0.16 acres jurisdictional open water pond/impoundment.
Put Shell Area: approximately 249 linear feet perennial stream channel and 2,264.5 linear feet intermittent stream
channel.
Internal Access and Road Stream Crossing: approximately 178 linear feet perennial stream channel.
Stormwater BMP: approximately 55 linear feet perennial stream channel.
Total Impact Authorized: 5,810.5 linear feet jurisdictional stream channel, 0.14 acres jurisdictional wetlands and 0.16
acres jurisdictional pond/ impoundment.
Latitude and Longitude: 35.387869,-81.286758

1A- The proposed project plans and property boundaries have changed substantially since the 2021 public meeting and
mine permit application submittal. What state and/or federal regulatory permits/certifications have been modified or
additional (new) permits/certifications applied for or received to reflect these changes?
Question was modified to read: The project's scope, shape and size has substantially changed from 2021 to now; given
these changes, what regulatory permits have been amended or are required to be added to reflect these changes.
A: No, the project scope, size and shape have not changed since the state mining permit application was submitted in
August 2021. There are 1,548 acres within the project boundary, as described by the permit application.
1b- How has the public been included in the process and informed of the changes?
Modified question: How has the public been kept abreast and then allowed the availability to be able to comment on
these permits?
A: The mine permit application, three related rounds of questions from DEMLR, and subsequent responses from
Piedmont Lithium have been made available online through DEQ's website. Public comment has been allowed
through DEMLR's process, including a public meeting that was held in November 2021 at the Gaston County
Courthouse. DEMLR has continuously been open to comment on these matters. Other pending permits (e.g. air,
wastewater) will be made available by their respective, responsible agencies and there will be an opportunity for the
public to comment.
2- According to the original 404/401 certificate, Piedmont Lithium must mitigate unavoidable stream and wetland
losses.
a -What sites have been selected for this mitigation?
No answer provided
NOTE: According to CWA Section 404 (b)(1) Subpart J
230.93 (k)(4) if mitigation bank or in -lieu fee oroeram is used. for Individual aermits the saecial conditions must identi
the saecific mitigation bank or in -lieu fee oroeram that will be used.
230.94(c)(1) for individual aermits that use mitigation banks or in -lieu fee oroerams. saecial conditions must include the
name of the saecific bank or in -lieu fee oroeram to be used.
b-Have additional mitigation requirements been added due to the increased acreage or changed project boundaries?
No answer provided
NOTE: ADI #3, submitted 9-1-2023, Liner System Basis of Design
(Draft) under the heading Selected Liner System Phase 2 footnote
states; "In advance of Phase 2 construction activities (structural fill,
liner system, waste rock placement), a modification to the existing
Clean Water Act Section 404/401 Individual Permit will be required
for the stream impact." See below for the link to the USACE Section
404 hermit files and public notice.

3- What has or will Gaston County Government Agencies and Officials and State and Federal Agencies do to ensure that
affected property owners are properly notified with updated, accurate information? Who will ensure informative and
accurate disclosures have been provided during any contract negotiations both directly and indirectly related to this
project in order to protect the citizens of this county and property owners from fraud or misrepresentation?
No answer provided
4- In the mine permit application, under the Waste Water Consideration Update document, Piedmont Lithium makes a
statement that further negotiations with the City of Gastonia and Gaston County are ongoing for alternative
infrastructure to connect to Long Creek WWTP.
a -What are the options are available for this connection?
No answer provided
b-How will the extension be installed, managed, maintained and funded?
No answer provided
c-How will the public be afforded participation and to what extent?
No answer provided
5- Portions of the project area and adjacent areas are affected by the former Hallman -Beam Mine, Bessemer City
Quarry, Pre -Regulatory Landfill, City of Gastonia Bio-Solid Residual Facility and various Hazardous Release Sites.
How will Gaston County and other permitting and regulatory agencies ensure Environmental Justice and prevent these
areas from being subjected to inequitable adverse environmental an cumulative impacts?
No answer provided
6- How will those community members be protected? Specifically address existing exposures and health consequences
and address what programs, funding and reporting will be available to provide information and assurances that no
cumulative impacts are occurring and continued measures to detect effects during and after the proposed project?
No answer provided
7- According to the Air Quality and PSD Permit Application, Piedmont Lithium states they are required to notify the
agricultural community that their
emissions will impact crop yields. As a member of the agricultural community in Gaston County, we have not received
any information regarding how the proposed emissions will impact our crops.
Modified question: The air quality permit and PSD application Piedmont submitted states that they were required to
notify agricultural producers their emissions would affect crop yields — what crops will this affect?
A: Air quality modeling was done as part of the air permit application. These models must be validated by the North
Carolina Department of Air Quality. Once validated, the specifics of the emission profiles outside of the permit
boundary will be communicated, as required, to the public.

a -Of greatest concern is how the emissions will impact crops, which crops will be affected, duration of the impacts, and
are bio cumulative impacts anticipated?
Modified question: How are you planning to notify the agricultural community?
A: Based on water and air quality modeling, we do not believe there will be any material impact on the quality of
water or the air outside of the permit boundary, therefore, not affecting area crops.
A: The water and air permits we expect to receive will have specific limits and monitoring requirements. If we were
not to meet our limits, there are reporting requirements to the responsible agency, and, depending on the impact, any
area impacted would be properly notified.
The answers provided do not sufficiently answer the questions
presented. How and in what form will the agricultural community
be notified? How will losses in crop production be mitigated? What
testing and reporting have been completed that provide scientific
evidence that no discharge nor emission will cause bioaccumulation
in any plant or animal crops? What geographic radius beyond the
project area will be impacted by any discharges or emissions, and
where are these maps and documents located? Who will ensure
oversight for monitoring and testing for the specific limitations in
permits? How can the immediate affected communities participate
in these permit decisions when we have inadequate access to the
technology necessary to view online documents?
b-Will these impacts be mitigated to offset the financial losses of the agricultural producers?
No answer provided
c-How will food security, or rather the decreased food security for the County and adjacent communities be mitigated?
No answer provided
d-What is the radius or range of the anticipated crop impacts?
No answer provided
e-Are these impacts considered in an isolated manner or are other industrial emissions included to provide a more
accurate understanding of how the agricultural community will be negatively impacted?
No answer provided
4

NC General Statutes and Administrative Code warrants that cumulative impacts be considered and investigated. Where
can I find these reports?
8- Many agricultural producers in Gaston County and surrounding Counties are completely dependent upon their
productivity yields as their sole income source. How will Gaston County and State Agencies protect these community
members from the multiple negative impacts of this project; specifically address the non -inclusive impacts of; lack of
water, water contamination, water runoff and erosion, lost viable crop land and poor crop yields from emissions,
decreased property value, increased risk for agriculture loan payback for fertilizer and seed in relation to the stated
negative crop yield impacts.
No answer provided
9- How will Gaston County and/or other agencies provide adequate access to reliable cell phone signal and broadband
internet service in and around the project areas? Currently there are large gaps, especially in the area of the proposed
mine pit excavation sites. As commonly known, mining has a high potential for work related hazards that could result in
transportation problems, property damage and/or human injuries or death. Without strong, reliable sources of
communication, the proposed project will place Piedmont Lithium employees, adjacent property owners, adjacent
businesses, churches, school children and travelers at an increased and unnecessary risk for disabling injuries if
communication systems are not available and installed prior to the startup of any portion of the project. The project
area is located in an already geographical isolation area of the county. Even if emergency services are built in close
proximity to the project area, without adequate communication systems, these services are not attainable.
A: A full telecoms package is being planned as part of the project, which will help improve access for nearby
neighbors.
Please provide details for the telecom package mentioned. Will this
be exclusively for your project area?
Original Public Notice 404 Permit
https://www.saw.usace.army.miI/Missions/Regulatory-Permit-Program/Public-Notices/article-view-
display/Article/1733611/saw-2018-01129/
Regards,
Lisa Stroup