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ADGA Realty seeks a new permit to excavate 1/2 million cubic yards of sand to expand mining operation off Mayflower Road.
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CLWC files a Request for Superseding Determination of Applicability with MassDEP; presents evidence that the new permit application is within regulated areas, will impact resource areas.
Wetlands aren’t mines! Wetlands are highly sensitive environmental areas, fostering biodiversity, groundwater and surface water protection, and drinking water filtration. They are protected under state law, which prohibits the removal, dredging, filling, or altering of wetlands, and their buffer zones, without a permit. Anyone in Massachusetts can file a Request for Determination of Applicability if they think a proposed development will impact wetlands.
June 2026: CLWC files for Superseding Determination of Applicability with the MassDEP
Following a negative determination of applicability from the Carver Conservation Commission on the latest earth removal application by ADGA Realty, CLWC filed a request for the MassDEP to review the application. Too many wetlands and natural resource areas are at stake to allow this earth removal application to go unregulated.
The grounds for the filing are the following:
- Illegal squaring off of the bogs
- Inaccurate wetlands delineation
- Illegal filling of perennial streams
- Ongoing violations
About the ADGA Realty mining application
ADGA has applied to the Carver Earth Removal Committee for another massive sand and gravel mining permit.
The location is shown below, on Carver Assessors parcels 122-18, 122-10, 122-2, 122-4 & 5-2.
The company strategically mischaracterizes the mining application as building a cranberry pond. It claims this mining is “incidental” to cranberry agriculture in order to evade local land use laws. The land is currently upland Pine Barrens forest.
The Chair of Carver Earth Removal Committee, Scott Hannula, is to run mining operation; an investigation reveals Scott Hannula’s connections to sand mining, trucking and using cranberry agriculture to get permits: read more here.
The current application is for 430,000 cubic yards of sand and gravel that will take years to mine out of the ground. The company will clear-cut the forest, level the hills and mine in the Sole Source Aquifer.
More information:
View the mining application on the Carver Earth Removal webpage here
The Carver Conservation Commission determined that a previous project impacted wetlands.
View the Positive Determination for an RDA by the Carver Conservation Commission here.
Impact to Aquifer, Wetlands, Waterways and Natural Resources
ADGA’s proposed mine borders Cedar Swamp wetlands and a perennial stream. The earth removal project will go right up to the border of Priority Habitat for Rare Species. The company will mine and dredge in the Sole Source Aquifer for sand and gravel. This is a federally designated aquifer for 200,000 people.
Natural Resources Directly Impacted by the Mining:
- BioMap Core Habitat
- BioMap Critical Natural Landscape
- 6.5 acres of Wooded upland forest will be destroyed
- The Plymouth Carver Sole Source Aquifer
See the map below of impacted resources areas:
Upcoming Public Hearings
- Tuesday, August 11, 2026, 3 pm: Carver Earth Removal Committee
Previous Procedural History
On October 1, 2025, the Carver Conservation Commission heard from Community Land and Water Coalition and Carver residents that a new permit application by ADGA Realty for sand mining falls within a regulated area adjacent to wetlands, and should require a Notice of Intent filing under the Massachusetts Wetlands Protection Act and the Carver Wetlands Protection Bylaw. The Conservation Commission voted unanimously that these wetlands were protected under the local bylaw. The applicant must now file a Notice of Intent for the project.
On September 2, 2025, Community Land and Water Coalition (CLWC) filed a Request for Determination of Applicability with the Carver Conservation Commission on whether the new sand mining permit application by ADGA Realty should be regulated under the Wetlands Protection Act. ADGA Realty seeks to remove almost 1/2 a million cubic yards of sand from the Plymouth Carver Sole Source Aquifer. CLWC determined through a thorough review of the project that it actually impacts the Buffer Zone to Bordering Vegetated Wetlands, a regulated area, and therefore should require a Notice of Intent filing under the Wetlands Protection Act and the Carver Wetlands Protection Bylaw. Wetlands and their buffer zones are protected areas in the State of Massachusetts, because they protect our water quality and provide important species habitat. Anyone can file a RDA; read about the process here.
Read CLWC’s September 2, 2025 RDA filing here:
2025.09.02 CLWC RDA 0 Mayflower Road Carver FINAL
On June 11, 2025: ADGA Realty filed a new application for an earth removal permit, to extract almost 1/2 million cubic yards of sand from the Plymouth Carver Sole Source Aquifer in Carver. You can find the application materials here.
The proposed mining will level a 8-acre hill within the Aquifer Protection Overlay District and impact private drinking water wells — some located just 850 feet away. The project is located within Critical Natural Landscape and adjacent to Core Habitat and Priority Habitat of Rare Species.
The applicant withdrew their previous application after a positive RDA determination from the Conservation Commission (see the public hearing here and listen to the Conservation Commission’s opinion that the project will impact protected resource areas). The positive RDA finding means the applicant would have had to file a Notice of Intent to work within the buffer zone to wetlands. However on June 11, 2025 the applicant has submitted a new application that makes it appear the that project does not impact established wetlands.
On April 16, 2025, the Carver Conservation Commission voted unanimously that wetlands laws apply to a sand and gravel mining project proposed at a cranberry bog site. The Commission’s vote is a major victory for the protection of wetlands and waterways. For decades, the cranberry industry has conducted sand and gravel mining in wetland areas under the claim that it was “agriculture” and thus exempt from permits. This has led to major destruction of wetlands, rivers, streams, and wildlife habitats.
For the past several years, CLWC has been working with its legal team and experts to demonstrate that industrial-scale mining is not cranberry agriculture. An internationally recognized hydrologist submitted a report to the Commission outlining the threats to water resources posed by the project. The Carver Conservation Commission carefully considered CLWC’s scientific and legal information and agreed that the law does not exempt the project from requiring a permit.
Read the comment letter submitted to the Carver Conservation Commission by expert hydrologist Scott Horsley here:
Horsley Comment Letter Carver Mayflower Road
Below are maps. The areas outlined in red are the parcels identified in the company’s application.
Above: Parcel 122 – 2
Above: Parcel 122-18
Above: Parcel 122-10
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