20061048 Ver 1_Other Agency Comments_20060615 (2)

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STATE OF NORTH CAROLINA
DEPARTIV~NT OF TRANSPORTATION
MICHAEL F. EASLEY
GOVERNOR
June 15, 2006
STAN M. WHITE LYNDO TIPPETT
BOARD MEMBER SECRETARY
P. O. DRAWER 1447, NAGS HEAD, NC 27959
North Carolina Environmental Management Commission
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Avon/Kinnakeet Sand Mine Permit Expansion Application
Dear Commission Members:
I would like to express my strong support for EMC's approval of DWQ's request for the
Avon/Kinnakeet Sand Mine's exemption from surface water quality standards on Hatteras
Island. As the presentation and project summary have indicated, because the US Army Corps of
Engineers lacks jurisdiction over the mining activity, but maintains principal jurisdiction over the
wetlands allocated on the site, no avenue exists for the project to mitigate the water quality
impacts that DWQ anticipates.
If approved, the proposed exemption will satisfy DWQ's 2001 expansion application review
comments, and allow DLR to proceed in their evaluation. As was stated, the project will follow
existing Isolated Wetland Rules' mitigation requirements and is therefore not requested special
treatment, just an avenue to move forward.
The strong public need for sand from the Kinnakeet Mine is the reason for my request. It is vital
to the NCDOT's timely and appropriate response to normal maintenance, and emergency repair
on Hatteras Island.
NCDOT completed 100x core drillings 25 to 28 feet deep on the site that were tested for
compatibility and approved for dune restoration in November i 999. No other identified site on
Hatteras Island can provide material approved by the US Park Service and NCDOT for dune
restoration in the Cape Hatteras National Seashore. Without having an adequate stockpile of
approved restoration material on hand, NCDOT will be forced to have approved material
delivered from off the island.
When the inlet Hurricane Isabel created was filled and NC 12 was restored, for example, a mine
on the Currituck County mainland was the nearest source of approved restoration material. It
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was transported to the site at a cost of four to six dollars per cubic yard. Not only was the cost
increased significantly, the transport of material from a mine so far from the site slowed
restoration considerable.
Previously, approximately 18,000 tandem truckloads of sand from the Kinnakeet Mine were used
in the NC 12 Relocation/Dune Replenishment Project in the Cape Hatteras National Seashore,
north of Buxton. If this material had been trucked in from the Currituck County mine, the
additional cost to NCDOT, and thereby North Carolina taxpayers, would have been significant.
In addition to the significant cost savings, much of the project was completed by the middle of
the 2004 hurricane season, much quicker than if materials had been delivered from off the island.
As I've indicated in letters to Mr. Hollowell and Cyndi Karoly, sand from this mine is vital to
our anticipated dune restoration efforts, not to mention the needs of North Carolina citizens and
visitors.
I respectfully urge you to accept DWQ's request for an exemption to water quality standards for
the Kinnakeet Sand Mine. Without stockpiled material from this site that is readily available at
moment's notice, I'm afraid that NCDOT will be unprepared for the eventuality that looms.
It is my heartfelt hope that North Carolina will not experience the unfortunate outcome of being
Ill-prepared for emergencies this fall, as did Louisiana, Texas, and Mississippi last fall.
Sincerely,
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Stan M. White
BuilderBroker