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Home My WebLink About19950991 Ver 2_Public Notice Comments_20240112 (2)DocuSign Envelope ID: C3C0129E-0339-43A8-9E82-02ADE5F3FDB0 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality January 12, 2024 Corps Action ID# SAW-2020-00807 DWR# 19950991v2 Richmond County Dicky Harmon U.S. Army Corps of Engineers Raleigh Regulatory Field Office Delivered via email to: Richard.G.Harmon@usace.army.mil Subject Project: Vulcan Materials Rockingham Quarry Expansion Dear Mr. Harmon: On behalf of the NC Division of Water Resources, we respectfully request that you consider the following comments within your review of the 404 Individual Permit request for the above referenced project: 1. The applicant has stated that the purpose of the project is to expand mining at the existing Rockingham Quarry facility. The Division requests that you consider whether this purpose has been so narrowly defined as to preclude a thorough alternatives analysis. Alternative #3 appears to meet the screening criteria established by the applicant. The applicant indicates it was eliminated because availability of the land is unknown. The Division requests that you consider whether elimination of this alternative meets the required federal evaluation process. 3. Alternative #4 appears to meet the screening criteria established by the applicant, and the applicant's acknowledgement that the property is currently within the permitted mine area indicates that it has been determined to be viable despite the location. The applicant appears to have eliminated this alternative for location, although it is within the screening criteria of 1 mile radius of the existing mine. The applicant also indicates that it was eliminated due to the need to use public roads to move materials, however the applicant clearly states in their screening criteria that the alternatives are not required to be within the permitted mine boundary but rather travel distances should be minimal, which appears to indicate that use of public roads is an acceptable condition. North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 NORTH CARCLINA 919.707.9000 DocuSign Envelope ID: C3C0129E-0339-43A8-9E82-02ADE5F3FDB0 Martin Marietta DWR# 20220241 Request for Additional Information Page 2 of 3 4. The applicant indicates that additional potential alternative sites were considered by were dismissed because they did not meet the purpose and need or determined infeasible, however they do not provide any details related to this decision. Given the restrictive nature of the applicant's stated purpose and need and siting criteria that is not sufficiently supported with details or data, the Division requests that you consider whether dismissal of these alternatives is premature. The applicant appears to have used the "Undetermined" category within the alternatives comparison table as a negative factor for some alternatives. The Division requests that you consider whether comparing unknown information on some sites with known information on the preferred site meets the required federal evaluation process. 6. The alternative comparison table provided does not equally compare the sites. For example: The applicant compares impacts to streams and wetlands after avoidance and minimization for the preferred alternative, with total features within the property for all other alternatives. It should be noted that if total jurisdictional features on each site were considered the preferred alternative site would have a very different result for this criterion. b. The applicant compares site specific data collected during onsite surveys for natural and cultural resources on the preferred alternative site with a desktop analysis of available data for all other sites. c. The comparison for Transportation indicates that existing transportation routes and infrastructure would be utilized for Alternative 2 and Alternative 3 however they are given a different "score". This appear to indicate a difference in this criterion despite the text indicating that this criterion is the same for both alternatives. We recognize that the applicant should not be expected to conduct thorough field verified analyses for all alternatives, but recommend that for an appropriate comparison, they modify the comparison table to use the same level of detail and information for all alternatives. 7. The applicant has proposed Permittee Responsible Mitigation (PRM) but has not provided any specific information within this application. The Division recommends that a full and thorough review of the Turkey Mitigation Site and legal documentation to ensure that mitigation will be successfully fulfilled be conducted in accordance with federal regulations prior to authorization of impacts under Section 404. 8. The Division is unable to complete a review of the project for compliance with 15A NCAC 02H .0506 at this time. The Division has requested additional technical information from the applicant and requests that the USACE also consider the attached letter during the review of the application. �� North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 NORTH CAROLINA 919.707.9000 0—p Mo Emimnmen quay DocuSign Envelope ID: C3C0129E-0339-43A8-9E82-02ADE5F3FDB0 Martin Marietta DWR# 20220241 Request for Additional Information Page 3 of 3 Thank you for your considering the Division's comments during your review of this Individual Permit. If you have any questions, please contact Sue Homewood at 336-813-1863 or sue.homewood@deq.nc.gov. Sincerely, IS DocuSigned by: ftp�u, bass 980C5097DWE4E9... Stephanie Goss, Supervisor 401 & Buffer Permitting Unit Electronic cc: JC Weaver, Civil & Environmental Consultants Inc. Gabriela Garrison, NCWRC DWR 401 & Buffer Permitting Branch file Filename: 19950991v2 Vulcan Rockingham Quarry Exp - Richmond - PN comments to USACEdocx.docx REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 NORTH CAROLINA 919.707.9000 naparMeM of EmironmanW 9uallly