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
Nashville District Corps of Engineers
Regulatory Branch (Attention: Scott Fanning)
3701 Bell Road, Nashville, TN 37214
On your correspondence note the permit File Number 2010-00546
Richland Creek Watershed Alliance