Richland Creek Watershed Alliance blog

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Saturday, June 19, 2010

Addressing Your Questions- What are the Benefits or Foreseeable Detriments?

Since our last blog RCWA has received numerous questions and concerns about the Rogers Group project and permit request to relocate a 800 foot reach of Richland Creek. That is good news- many stakeholders are looking at water resource issues and asking good questions to better understand this essential but sometimes controversial topic.
At the north end (top) of the quarry, east of what looks to be an upside down foot, is a dip. This is the stream channel Rogers Group proposes to fill-in and where the quarry wall collapsed during the flood. You can clearly see there is no riparian area remaining on the quarry's side of creek due to mining encroachment. Rogers Group describes this as the "flood destroyed channel" in their permit request.

The Group proposes their new stream channel to be connected from the uppermost part of dip to the toe of that upside down foot, north of the existing channel. They also propose to add a second "high flow channel" between the natural and new channel- across the middle of the bottomland, the dip.

What happens to the wildlife, aquatic wildlife and habitat that is there now? I think you know the answer (gone). What is Rogers Group timeline for the work to be finished and what assurances does the public have they will be completed as described? When does Rogers Group anticipate the habitat, wildlife and aquatic life to return? Where are the design plans for this mitigation and why are they not submitted with this permit? This needs to be a one-permit process with both the proposal and mitigation design plans included, now, before any permit is granted for public viewing.

As you can see on the aerial above, encrouachmet has eaten away much of the habitat already. This is why this reach of stream is on the Environmental Protection Agency's 303d Impaired List for "habitat alteration" already. Once listed on the 303d, the objective is to get delisted. When does this process begin, what is the end- game for a quarry? You may know the answer to this too.
This second aerial map (left) has the flood coverage overlay showing the mine filled up with flood water. It has been pointed out we are lucky that the quarry was there because it prevented the homes from flooding (southwest of quarry).

Quarries often become lagoons, harbors and marinas once the mining operation is done and someone else invests. Rock Harbor, just south of this view, was once a quarry. Do you think the quarry wants to mine in the future where the houses are now? Do you think any other areas of the quarry will collapse, withstand a future flood, given the loss of riparian area and erosion there now? Should we be grateful there is now a big hole where once there was an aquifer, riparian area and wildlife?

The overview aerial (right) shows the extent of the flood, after the Cumberland River left it's banks. Rogers Group is moving the stream channel north, towards and into the floodway. Of course, it is unresonable to move it anywhere else- that is where the mine is located.

Hydrology is a science that deals with the properties, distribution and circulation of water, beneath and above the ground. It is a complicated subject but very important, as we all now know after the flood. Hang in there for a second longer. Remarks received from several readers have questioned the impacts this project proposal may have on the homes southwest of the quarry, other properties and businesses in the vicinity and even upstream.

One of these remarks made by a hydrologist suggests "this has not been adequately covered and more deliberation is needed for this project proposal." He asks "will the new diversion channel alter drainage for the entire watershed, making the creek drain faster or slower?" He continues, "straightening the reach, as the application indicates, tends to increase velocity and increase drainage-efficiency, ... will this bring more flash floods at the prision or businesses on the north side of the creek or bring more flood dangers to neighborhoods in the lower part of Richland Creek? Good questions don't you think? We certainly don't want to create another environmental disaster for Nashville.

Okay I am saving the best part for last. There has been several sightings of the Environmental Protection Agency's Threatened Alligator Snapping Turtle in Richland Crek and one sighting that I know of here. If you don't know much about this prehistoric looking creature, they can live to be very old, they clean our streams and there use to be gobs of them but because of pollution, habitat alteration and the harvesting of them for food they have dissappeared quickly and very few places left for them. They don't do well in captivity.

RCWA contacted the US Fish & Wildlife Service to conduct a survey here for this special turtle, since the applicant said, "a formal consultation procedures with the U.S. Fish and Wildlife Service is not planned at this time." They just didn't know they had these amazing creatures living on the stream bank and laying on their back in the stream with their mouth wide open and eating fish and anything else they want. The fish think they see a minnow and swim towards and into these marvelous creatures mouth. See 3 incredible videos of the Alligator Snapping Turtle underwater from the ARKIVE website here. Just click the purple.

If you find our work worthy, you can visit our website to find out how to join RCWA, help us out or be on the readers list. Thanks for taking the time to read this blog. The aerials here were courtesy of http://maps.nashville.gov/empublic_viewer/.

THE BOTTOM LINE_________________________________________________is-
We need this permit process delayed and a public hearing granted for this project proposal because: more deliberation and discussion is needed for the public's comprehension and confidence that we are not creatiing a public hazard; more information and reveiw of the impacts on wildlife, habitat and aquatic wildlife is necessary and; so the applicant (Rogers Group) can provide mitigation designs and timelines to the public. This should be a one-permit process and the mitigation design plans included in this permit application.

To read the Rogers Group, Inc. (REOstone quarry) permit request #10-17 go to this link
COMMENT PERIOD EXTENDED FROM JUNE 29 to JULY 14 (updated June 28th)
Please address your coments by July 14, 2010 to:
Nashville District Corps of Engineers Regulatory Branch (Attention Scott Fanning)
3701 Bell Road, Nashville, TN 37241
Scott.Fanning@usace.army.mil


Your participation is crucial. There is only 10 days left to submit comments!

Thanks.
Richland Creek Watershed Alliance
rcwa@comcast.net

DO WE NEED TO DELAY THIS PROCESS AND HAVE A PUBLIC HEARING?
What do you think?

Wednesday, June 16, 2010

Public Hearing Needed - Reostone Quarry Requests Permit to Relocate Richland Creek

On June 14th, 2010 the U.S. Army Corps of Engineers (USACE) Nashville District put out a Public Notice (Number 10-17) stating the Rogers Group Inc., Reostone Quarry was requesting a permit to relocate a large segment of Richland Creek as a result of the flood May 1 - 2, 2010 because "350 linear feet of their quarry wall was breached." Rogers Group is proposing and requesting a permit to move hundreds of linear feet of Richland Creek, fill-in the existing channel and then divert it into a new channel.

Moving the stream channel will have undue adverse effects on wildlife, habitat and aquatic wildlife.

Reostone claims the destruction of their quarry wall was the flood rather than the placement of the mining operations up against the stream and poor management practices over many years.

Is not Rogers Group Inc. reponsible for the breach of their own quarry wall?
Streams are known to swell from their stream banks and why adequate riparian area is needed. Floods are to be expected and are predicted to occur. The quarry was built right up to the stream with no riparian area before the Clean Water Act was enacted. Nothing much has changed since, except the deterioration of the stream bank from their poor managment practices and violations. RCWA wrote and showed photos of the sheathing of the quarry's wastewater on stream bank in 2008 and repeated the issue in 2009 when Reostone receieved a Notice of Violation for improper wastewater release and a 338% exceedence of Total Suspended Solids (TSS)- a 13,516 mg/L analysis result with just a 40 mg/L allowed. The quarry operations have degraded the stream bank and impacted the water quality. The quarry operations have been removing the limestone bedrock and crushing it for profit for decades. It was inevitable the stream bank's integrity would degrade overtime. Now the quarry is approximately 500 feet deep, 1/2 mile long and 1/4 mile wide and blaming the 2010 May flood?

To see photos and read old CreekVoice articles mentioned above go to- the Fall 2008 article, "Downstream, out of sight, out of mind" and to the 2009 article, "Stakeholder reports milky white substance flowing into Richland Creek."
There was also a story on WSMV about the 2009 issue, http://www.wsmv.com/video/20685107index.html.

Rogers Group Incorporated claims that the entire reach of Richland Creek within the project area is an embayment of the Chetham Reservoir, caused by the flood and implies that this perennial stream, Richland Creek, is not a free flowing sream but filled with backwater from the Cumberland River.

RCWA does not accept Rogers Group assumption that Richland Creek is not a free flowing perennial stream at this project area. The flow at this project area varies from the controls madel by the U.S. Army Corp of Engineers- management of the Chetham Dam Reservior cause backwashes to mouth of Richland Creek.
Richland Creek has been a free flowing stream for thousands of years.

This section of Richland Creek is listed on the EPA 303(d) Impaired List for "habitat alteration" and the Rogers Group is requesting a permit to alter the stream more?
Examples of human impacts that result in habitat alteration are stream channel modification, land drainage, channel straightening and widening, riparian vegetative removal and stream sand or gravel mining. It is the intent of the 303 d listing for a stream to be restored and removed from the list not to aggrevate the alteration with more alteration? The public wants the stream restored, protected and enhanced, not destroyed and relocated. There has been no effort to protect this waterway in the decades the quarry has occupied this land. USACE should deny this permit request and question any future quarry operations here at all.

The USACE are accepting comments from the public for only 15 days which is unusual because normally there is a 30 day public comment period. To request that a public hearing be conducted on this issue you must also comment why you think a public hearing is necesary.

To read the Rogers Group permit request go here-->> http://www.lrn.usace.army.mil/cof/notices/PN%2010-17.pdf

Please address your comments by June 29, 2010 to-
Nashville District Corps of Engineers
Regulatory Branch (Attention: Scott Fanning)
3701 Bell Road, Nashville, TN 37214
Scott.Fanning@usace.army.mil

On your correspondence note the permit File Number 2010-00546

Thanks
Richland Creek Watershed Alliance