20131093 Ver 2_NCWRC Comments_20181221

Carolina Wildlife Resources Commission
Gordon Director
TO: Brenda Harms
Division of Energ., Mineral, and Land Resources
North Carolina Department of Environmental Quality
FROM: Maria T. Dunn
Habitat Conservation Division
SATE: December 21, 2018
SUBJECT: Mining Permit Application for Iluka Resources (NC) LLC, Aurelian Springs Mine,
Halifax. County, North Carolina.
Biologists with the North Carolina Wildlife Resources Cominission (NCWRC) reviewed this permit
application with regard to impacts of the mine on fish and wildlife resources. Our comments are provided
in accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 1.6
U� S.0 661-667d), Section 4O1(b) of the Clean Water Act of 1977 (as amended), and the North Carolina
Mining Act of 1971 (as amended, 1982; G.S. 74-76 et. seq., 15 NCAC 5).
The applicant is requesting a new permit to mine dmenite and zircon sands across 3,769 acres within
Halifax Count., excavating the landscape to an average depth of -10' to -15' with a maximuin depth of
-40'. This is a recirculation of a permit application that began in 2013. Information received from
NCDEMLR indicates the 2018 raining permit application is the same as during the 2013 process. Details
regarding wetland and stream impacts, wetland and stream crossings, monitoring of mine impacts to
adjacent wetlands and streams, response to spills, watershed sedimentation and erosion impacts to aquatic
habitats, urine advance, reclamation practices, and recommendations made during the :2014 review were
not included in the package received on December 16, 2.1118. Therefore, the NCWRC requests the
applicant coordinate with our agency, as well as other state and federal regulatory and resource agencies,
to address enviromnental concerns prior to the issuance of a thine permit.
The proposed project area is within the Tar River basin. This basin includes .watersheds such as Bear
Swamp, Rock-); Swamp, and Little Fishing watersheds that provide important habitat opportunities for
numerous federal Endangered Species Act (ESA) listed species as well as state listed species. Species
found in these areas include Dwarf Wedgemu sel (Alasmidonla heterodon), Triangle Floater
(Alasmidonta undulata), Notched Rainbow (Y llosa constricta), Atlantic F'igtoe (Fusconaia rnasoni), Tar
River Spincymussel (Elliptio steinstansana), Yellow Larnpmussel (Lampsilis cariosa), Roanoke Slabshell
Mailing Address: Habitat Conservation 8 172.1 Mail Service Center - Raleigh, NC 27699-1721
Telephone: [phone]-O220 - Fax: [phone]

(,—Oliptio roanolwnsis), Creeper, (Strophitus undulates), Eastern Lanipmussel (Lampsilis radiata),
Carolina Madtorn (Noturus furiosus), Least Brook. Lamprey (Larnpetra aepjptera), North Carolina Spine
Crayfish (Orconectes carolinensis), and Neuse River Waterdog ( ecturus lewisi). These aquatic species
are highly susceptible to sedimentation and could easily have substantial population impacts from a
largescale watershed project.
To minimize impacts to the important aquatic resources listed above, careful planning is prudent.
Additional information regarding wetland and stream impacts for the project area, mine advance, and
layout is essential to assess impacts to wildlife resources. This information also needs to be provided to
insure avoidance and niiriirnization of wetland and stream impacts have been demonstrated. Management
practices to minimize sedimentation in these systems may include directional boring of wetlands and
streams, minimal crossings of wetland and streams, and detailed sedimentation and erosion control plans
with monitoring plans.
Perhaps one of the most effective measures to minimize sedimentation and erasion in aquatic systems are
vegetated buffers. The NC Division of Water Resources recognizes the Tar River Basin as a nutrient
sensitive basin and has therefore Implemented the Tar -Pamlico Buffer Rules that establish a 50' buffer
adjacent subject streams. it is the position of the NC RC that thins buffer width is not sufficient to
provide the needed protection for the sensitive aquatic habitats in the project area. A 200' vegetated
buffer on all perennial streams and a 100' vegetated buffer on all intermediate streams and creeks would
be more sufficient. Due to the sensitivity of the environment, .100' wetland buffers could also be
implemented. These measures, as well as Gathers to minimize secondary,-` and cumulative impacts, can be
found in NCWRC's Guidance Memorandum to Address and Mitigate Secondary and Cumulative lanpacts
to Aquatic and Terrestrial Wildlife Resources and Water Quality (August 2002;
13�'-/70- Secondarvin
dCUTIR11�1t, V'11111) f),
The NCWRC appreciates the opportunity to review this permit application and looks forward to the
additional information requested above. Staff loop forward to working with the applicant during this and
other permit application processes. Please do not hesitate to contact me by email at
f naria.dun rr,� cw11i1dlife.oro or by phone at [phone].
Cc: Alexander, Tasha — USACE
Wells, Emily —USFWS
Higgins, Karen - NCDWR
Snaith, Danny — NCDWR