20140356 Ver 1_More Info Received_20140731

Wetland and Natural Resource
Consultants, Inc.
US Army Corps of Engineers
Asheville Regulatory Field Office
Attn: Mrs. Tasha Alexander
151 Patton Avenue, Room 208
Asheville, North Carolina 28801 -5006
Re: Request for Additional Information — Response from Applicant
The Quartz Corp, USA — Pine Mountain Mine, 577.1 Acres
Corps Action ID: 2013 -01376
Mitchell County (Parcel ID: 0882 -00 -52 -1389)
Spruce Pine, Mitchell County, North Carolina
Tasha
July 28, 2014
WNR Project # TQC -1004
RECEIVED
!Ill. , .11 2014
DENR -LAND QUALITY
STORMWATER PERMITTING
Based on your letter dated June 12, 2014, your agency requested additional information to continue
your review of the permit request for Pine Mountain Mine. Four comment letters and one email were
received during the public notice. We address these comments and email below.
North Carolina Wildlife Resources Commission (WRC)
We appreciate Mr. Doug Besler's comment letter and support of the Beaver Creek preservation
proposal for mitigation. Doug did participate in the agency site visit to Pine Mountain Mine and the
Beaver Creek site on May 12, 2014. We reference some of Doug's comments in this cover letter.
Eastern Band of Cherokee Indians (EBCI) Tribal Historic Preservation Office (THPO) and
State Historic Preservation Office (SHPO)
We appreciate Mr. Tyler Howe's (THPO) and Mrs. Renee Gledhill - Earley's (SHPO) comment letters. I
spoke with Tyler, after you issued your letter requesting additional information, about the request for
a phase 1 archaeological survey. Tyler agreed to review the information contained in Attachment 1
of this package. Tyler will determine after reviewing this information whether he still wants a phase
1 on the entire property, whether the phase 1 is limited to certain areas on site, or whether a phase
1 is no longer requested due to the extensive disturbance and remaining steep topography. Enclosed
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in Attachment 1 are a summary of the history, a summary of the slope analysis study, a spreadsheet
that summarizes the slope analysis study, an aerial slope analysis map, a USGS slope analysis map,
and representative photographs from the project site. I have emailed and mailed a copy of
Attachment 1 to Tyler for his review and comment.
Mrs. Glenda Hollifield
We appreciate Mrs. Hollifield's comments, however, her property is not located downstream of Pine
Mountain Mine. Her property is located downstream of Unimin's mine. Please see the enclosed maps
in Attachment'2. The Quartz Corp's (TQC) Pine Mountain Mine project must be approved through
programs such as yours; the NC Division of Water Resources; the NC Division of Energy, Mineral, and
Land Resources; and the NC Division of Air Quality in order to begin operation. All of these agencies
have stringent requirements to ensure that`the natural resources are protected.
Southern Environmental Law Center (SELC)
The Quartz Corp and their consultants (Wetland and Natural Resource Consultants / Unique Places)
met with SELC and Western North Carolina Alliance (client) on 'J'une 25, 2014'in Asheville. It seemed
as if SLLC and their client were not familiar with the existing site conditions at Pine Mountain Mine as
well as the mining and NOV'history at the site. Their client's primary concern seemed to be related
to erosion and sedimentation control as is discussed in the WNCA section below.
"1.'The Quartz Corp (TQC) has artificially constrained its project purpose. A
permitting agency may ,not accept an applicant's purpose and need which is so
narrow that only a single alternative could satisfy it. Likewise, the purpose and
need ray not exclude consideration of reasonable, and, /or practicable alternatives
that would avoid and /or minimize aquatic impacts."
The impacts are necessary to maintain the business plan which requires access to high ground and
resolution of a mining violation that was committed by a neighboring competitor. The quartz
resources to be mined are ,located at Pine Mountain Mine and are scarce both in the area and
worldwide. The facilities, including the plant, maintenance facilities, infrastructure roads, etc, are
already constructed at Pine Mountain Mine. The proposed alternative purpose is "To continue mining
the applicant's quartz, mica, and feldspar reserves in an economically feasible manner."
"2. As a result of a narrow purpose, TQC potentially excludes consideration of
reasonable alternatives that would avoid and /or minimize aquatic impacts. TQC
does not consider any alternatives to its proposed project, geographic or
functional."
Alternatives were analyzed and presented during multiple site meetings and pre - application meetings.
These included alternate routings for the stream relocation, alternate roadway routings, and site
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plans that included the requirement for additional stream impacts, almost three times the amount of
stream impacts being requested. The application explained that the requested impacts are necessary
to resolve a Notice of Violation, to access high ground, and to construct a storm water pond. The
application stated that the quartz, mica, and feldspar are resources that are geographically restricted
and that other practicable sites are not available. Functionally, there are no economically or
technologically viable alternative sites for high quality quartz within the marketplace that are available
for purchase,. Not mining at Pine Mountain Mine would create a financial burden for The Quartz
Corp. The existing infrastructure can be utilized by continuing a mining operation that was begun in
1937 and continued by other companies, prior to The Quartz Corp. Additional stream impacts would
likely be necessary even if another property in the area had comparable resources available to mine
given the fact that new infrastructure would need to be built as well such as railways, a processing
plant, infrastructure roads, maintenance facilities, etc.
"3.'The artificially narrow purpose improperly limits the scope of analysis. The
scope of the required impacts analysis and alternatives- analysis must be broader
than this particular site."
The quartz natural resources being sought at Pine Mountain Mine are extremely scarce and only
occur'in two locations worldwide. The majority of the impacts.(73.8 %) being requested are to
resolve a violation that was done by a competing mining company. Resolution of this violation will
likely improve water quality downstream. TQC has looked for other economically viable properties
that could produce the quality of quartz available at Pine Mountain Mine with no success. As they are
identified TQC will pursue economically viable properties within the geographic service area of their
existing facilities in the future. Since no other viable local sites are available TQC, is limited to
expanding the Pine Mountain Mine facilities. The scope of analysis is therefore limited to on -site
alternatives which have been exhaustively discussed'.
Previous site plans that would have required over 3,100 linear feet of stream impacts would have
been easier to construct, closer in proximity to the mine area, and would have allowed shorter
trucking distances for the disposal of mine waste and delivery of products to the processing plant.
The requested impacts are the minimum necessary to allow for the development of Pine Mountain
Mine for the intended use. The 1,220 linear feet of stream impacts requested is a reduction of over
61% from one of the previous impact plans that were reviewed earlier'in the permitting process by
the regulatory agencies.
The initial layout of roads and facilities were designed to maximize site development and follow ideal
and fluid routes for truck and equipment travel within the mine. The site plan was then revised
multiple 'times to minimize stream and wetland impacts to the greatest extent practicable. Some of
the practices used to reduce impacts include using existing road corridors and existing stream
crossings, shifting road and developed area layouts upslope or upstream, building roads and
developed areas above endpoints, and avoiding the majority of the main stream at the mine, Little
Bear Creek.
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One of the previous site plans, which would have made development of the mine easier from a
construction standpoint, required 3,135 linear feet of stream impacts. Another previous version of
the site plan required 2;011 linear feet of stream impacts. The current mine impact, plan, which is
the minimum required for, development of the mine, requires 1,220 linear feet of stream impacts.
"4. The, application'fails,to disclose and discuss cumulative'impacts. TQC
acknowledges the "potential to produce cumulative -and secondary effects" but
states, with no analysis, that these will be "minimal" and that there will be no
"major impairment" of=water resources."
88.5% (1,020 linear feet) of the impacts are to poor quality streams. The sediment laden streams
are a result of pre Clean Water Act activities thattook place at the property starting in 1937 but have
not been a result of activities completed by TQC. 1,020 linear feet'of impacts will very likely improve,
downstream water quality and this thought was iterated by W,RC in their comment letter. The two
road crossings have been designed to allow for aquatic life passage. No long term impact to the
resource should occur at these two locations. There is 180 linear feet of proposed impacts for the
construction of a storm water retention pond on a poor quality unnamed tributary to the North Toe
River. This ,stream is entrenched and its valley has been used for dumping in the past. The
construction of the pond will help protect downstream water quality.
Short term temporary turbidity impacts may occur during construction downstream of the proposed
impacts but resolution of the NOV and construction of the storm water BMP should beneficially
outweigh these potential temporary impacts. Some temporary impacts were included in the
application. The long term water quality benefits far outweigh any potential short term impact. The
mine has been in operation since 1937 so continued mining at Pine Mountain Mine is not expected to
create,additional development in the area.
The sediment and erosion control devices for Pine Mountain' Mine have been designed for the 25 year
storm event as required by the Mining Act. The Quartz Corp installs the required designed devices
and customarily increases their volumes and dimensions in order to better control erosion and
sedimentation. The Mining Act erosion control minimum requirements are regularly exceeded at Pine
Mountain Mine. In summary, there are over 75 sediment and /or water quality basins proposed on
the plan within the Pine Mountain Mine, permit boundary. There are ,6.77 miles of rip rap ditches
proposed and 121 miles; of •grassed swales, proposed which accumulate to, 9.99 miles of ditches and
swales.
"5. 33 C.F.R. 332.2 requires compensatory mitigation be provided to offset
unavoidable adverse impacts once all appropriate and practicable, avoidance and
minimization has been achieved. Permit applicants are responsible for proposing
an appropriate compensatory mitigation option to offset unavoidable impacts."
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Functional Replacement of Mitigation
This section of the response letter is similar information that was provided to NC DWR in response to
their request for additional information regarding the proposed Beaver Creek Preservation mitigation
plan.
We are of the opinion that the application, and the subsequent site inspection, supports our position
that the large majority of the impacts at the Pine Mountain Mine site are to poorly functioning
systems. As detailed 'below, '88'.°'5 % of the streams have low ecological functions and values. The
mitigation plan and the subsequent site visit support our position that the mitigation site at Beaver
Creek is highly functioning, within, close proximity to the impacts, and provides in -kind mitigation.
Preserving the ecological viability of the Beaver Creek, water, shed with high mitigation ratios of high
ecological functions, is the applicant's preferred, method to replace losses of poor quality systems:
The preservation site will be fully functioning and viable at the time of the impacts and the
preservation ensures that the system will continue to fully function without disruption in perpetuity.
In contrast, the onsite and EEP options are not immediately viable and are subject to external
disruptions both upstream and downstream, thus compromising a continuum of ecological uplift.
Little Bear Creek and its tributaries are lower quality streams and have been impacted by historic
activities completed by other companies at the project site. The proposed impacts to streams and
their functions are limited due to the existing low quality; therefore, replacement of function through
restoration is less applicable for this project. Mr. Doug Besler, NC WRC, stated in his comment letter
that "Little Bear Creek in the vicinity and downstream of the Pine Mountain Mine is severely impacted
from sediment and has a depauperate fish community. Given the extent of sediment impacts from
the current mining operations, the proposed alterations to the tributary streams may, over time,
reduce additional sediment impacts in the watershed." The current sediment impacts have occurred
from previous mining operations that began in 1937.
900 linear feet (73.8 %) of the 1220 linear feet proposed for impacts are related to the resolution of a
land quality violation 'that was incurred by an ,adjacent mining company. The 900 linear feet consists
of two 450 linear foot impacts, on ,unnamed, poor quality tributaries to Little Bear Creek. The Quartz
Corp has accepted the, financial responsibility of resolving this Notice of Violation, even though they
were not the 'responsible party: While they did give permission to the other company to dump at the
site, the dumping method, which created the violation, was not approved by The Quartz Corp. The,
resolution of this violation includes constructing retaining walls to stabilize the dump area and reduce
erosion, within these two poor quality and previously impacted unnamed tributaries to Little Bear
Creek. It is likely, and WRC supports this belief, that resolution of the violation will result in an
improvement in downstream channel stability and water quality.
180 linear feet (14.8 %) of the 1220 linear feet proposed for impacts are a result of the construction
of a storm water retention pond on a poor quality unnamed tributary to the North Toe River. This
stream is entrenched and its valley has been used for dumping in the past. The construction of the
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pond will help protect downstream water quality. These three proposed impacts total 1080 linear
feet (88.5 %) of the total impacts proposed. These impacts will occur on poor quality and previously
impacted unnamed tributaries to Little Bear Creek and North Toe River. The proposed work at these
locations will very likely improve downstream water quality.
The, remaining 140 linear feet (11.5 %) -of proposed impacts occur on Little Bear Creek proper at two
different locations and are road crossings necessary to access high ground across the stream. Little
Bear Creek is a good quality stream. One of'these locations has an existing culvert that was installed
prior to current design standards which include counter - setting. This culvert'is perched at the outlet
and not buried to allow for aquatic life movement or natural substrate within the culvert. This culvert
will be removed and replaced with 100 linear feet of new, improved culvert which will result in 40
linear feet of new rimpact at this location. The second and upper road crossing ,on ,Little Bear Creek is
a new culvert, and is necessary for construction of a haul road to access a waste dump site. This
culvert will also be constructed to allow for aquatic life movement. These culverts wi11 be designed to
provide in- stream, habitat of the naturally occurring stream bed such as cobbles, gravels, and sands
therefore significantly limiting the ecological and functional impact ,of the proposed activities.
In terms of a restoration alternative, apportioning a small amount of the mitigation requirement to a
restoration component would be ecologically insignificant due to the small scale. The, Beaver Creek
preservation project has a larger, watershed scale and thus the most ecological benefit. Any amount
of the mitigation that is apportioned to restoration will impact the opportunity to preserve the entire
East Fork of Beaver Creek watershed and possibly render it infeasible because there would not'be
enough mitigation required to justify doing the full extent of preservation. Preserving only a portion
of the streams within the East Fork of Beaver ,Creek would be much less ecologically significant and
would result in the loss of a watershed -based approach. Additionally, the Beaver Creek preservation
project has high mitigation ratios compared to the proposed stream impacts. The ratios, will be 12:1
to 15:1 compared to the NC IRT 2012 preservation guidance that requires 10:1 for permittee-
responsible preservation, and 5:1 for in -lieu fee and mitigation bank projects. The applicant is
proposing to preserve 2 to 3 times the linear footage of streams that would be preserved if EEP or a
mitigation bank offered high quality preservation credits for the project. -�
Given the existing low quality of streams on site and limited additional functional loss, if any, due to
the proposed activities and impacts,, high quality preservation with high ratios is an appropriate form
of compensatory mitigation for this particular project.
The 2008 Federal Rule supports this approach of considering the relative ecological importance of
both the impacts and proposed mitigation. CFR §332.8 states, "In determining this higher ratio for a
preservation -based proposal, the district engineer must consider the relative importance of both the
impacted and the preserved aquatic resources in sustaining watershed functions."
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Indeed, the 2008 Federal Rule recognizes that, "the main purpose of preservation is to prevent a
future ,loss of resources, not to provide, a gain (Federal Register Vol. 73, No. 70, pp 19624). The
significantly higher ratios for preservation ,account for this.
ffli tion Hierarchy and Selection of Seaver Creek Preservation Proiect
The Beaver Creek preservation project was selected as the most appropriate and ecologically
significant form of mitigation, in accordance with the'2008 Federal Rule, as follows:
1. Bank Option
• There are no mitigation banks in the project area.
2. EEP Option
• EEP restoration credits are available in the 8 -digit HUC from three sites. However, none of the
sites are located in the local watershed (12 -digit HUC) of Pine Mountain Mine.
• The Beaver Creek preservation site is located much closer to Pine Mountain Mine than the EEP
sites; in fact, it is the adjacent watershed. See the figure below.
• The Beaver Creek preservation site provides the closest in -kind mitigation compared to the
EEP sites in terms of more similar stream slope and habitat, stream order and elevation, and
watershed area. Beaver Creek reflects the unique ecological character of Little` Bear Creek
watershed before it was impacted by historical mining activities, whereas the EEP sites are in
farm fields located in valleys, which are different in character from the impact site. In fact, the
2008 Federal Rule supports the use of preservation as the preferred mitigation for "difficult to
replace" resources such as' streams and certain wetland areas, as described below.
• The Beaver- Creek project provides the highest ecological benefit compared to the EEP sites
due to its high ratios, large size; watershed approach, and biological significance (high quality
cold water stream habitat, known trout populations, unique wetland /„seep habitat, and rare
natural communities and species), and is a state- recognized conservation priority.
• The Beaver Creek project'would have the added societal, benefit of permanently protecting a
municipal water supply.
• As noted above in the, previous section, apportioning some of the mitigation need to EEP
credits would challenge the feasibility of preservation the entire East Fork of Beaver Creek
watershed.
Mitigation through the Beaver Creek project would be completed in advance of issuing the
permit, whereas the EEP projects are not yet closed, and have no guarantee of success.
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3. On -site Restoration /Enhancement Option
• The 2008 federal rule states a preference for a watershed -based mitigation approach over an
onsite mitigation approach. The Beaver Creek preservation project takes a watershed -based
approach.
• Given the existing conditions at the mine site and proposed continuation of mining, the
restoration of a small section of stream onsite would be ecologically insignificant. WRC
concurs, stating in their comment letter, "We feel that on -site mitigation would be extremely
expensive and relatively insignificant given the totality of impacts at the Pine Mountain Mine."
• The location in which on -site restoration could be done is already existing sedimentation
basins and therefore already provides some positive benefit to downstream water quality.
Therefore, additional functional uplift by stream restoration would be limited
• Controlling storm water and additional sedimentation from mining activities is the primary
driver of water quality and stream function. This is already being addressed through the new
mining permit in the number of sediment and water quality basins being required. There are
over 75 basins shown on the mining application master plan. In- stream restoration would
have limited added benefit.
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• There is another mining company plant and other infrastructure facilities downstream of Pine
Mountain Mine. Therefore, the benefits of restoration upstream would be limited, constrained,
and possibly reversed by downstream future actions. See the figure below.
• Mitigation through the Beaver Creek preservation project would be completed in advance of
issuing the permit, whereas onsite restoration would be completed after the fact, with no
guarantee of success.
• For these reasons, the onsite restoration option is less practical and less ecologically significant
than the Beaver Creek preservation project.
4. Off -site Restoration /Enhancement Option
• The Quartz Corp does not own other property as close to the Pine Mountain Mine as the
Beaver Creek preservation project that has the potential for stream restoration /enhancement.
• By using the Beaver Creek project, The Quartz Corp will not be the responsible party for
providing the mitigation and the mitigation will be completed prior to the proposed stream
impacts taking place.
• The Quartz Corp is not aware of any other property within the 12 digit HUC code that contains
candidate streams for restoration appropriate for mitigation.
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The Beaver Creek preservation project streams are more comparable to the streams at Pine
Mountain Mine than other stream restoration sites, which are likely to be in an
agricultural /valley setting.
The Beaver Creek preservation project provides a higher ecological benefit relative to any other
option. WRC prefers, using the Beaver Creek preservation project for the mitigation of .impacts at the
Pine Mountain Mine. According to the WRC comment letter "The quality of the aquatic and terrestrial
habitat within the [Beaver Creek] watershed is very high with unique wetland and hydrologic
communities and, in our opinion, represents a unique opportunity to mitigate for mine impacts by
preserving very high quality habitat that is in close proximity to the actual impact. We prefer this
option over EEP credits in this circumstance because the EEP credits would be at'a more distant
location that would probably not have the biological potential of the upper Beaver Creek watershed."
Consistency with NC IRT 2012 Preservation Guidance and 2008 Federal Rule
The NC Interagency Review Team (NC IRT) issued a guidance entitled "Use of Stream Preservation
as Compensatory Mitigation in North Carolina" (NC IRT, 2012), which is based on the 2008 Federal
Mitigation Rule (USEPA, USACE, 2008) and, associated regulations. The Beaver Creek preservation
project meets all of the primary criteria and many of the secondary criteria as shown in the tables
below. It is therefore consistent with the 2012 Guidance and 2008 Federal Rule.
Primary Preservation Criteria from 2012 Guidance and 2008 Federal Rule
`,Primary, Preservation Criteria, °' -
Does, Pro jectMeet,Criteria?
_
The resources to be preserved provide
Yes; the project watershed provides a
important physica'I, chemical, or'biological
municipal drinking water supply,, and high
functions for the watershed.
quality habitat for a number of rare
species and natural communities.
Yes; the project will protect an entire sub -
The resources to be preserved contribute
watershed and encompass seeps,
significantly to the ecological,
headwaters, and unique natural
sustainability of the watershed.
communities, thereby supporting
ecological sustainabili .
Determined 'by DE; preservation is
Preservation is determined by the district
appropriate given the limited nature of the
engineer to be appropriate and
impacts; proximity to the impact site,
"in-
practicable.
streams being kind" and higher quality
than the impacted streams, and ecological
import nce/ watershed approach.
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Secondary Preservation Criteria from 2012,Guidance
Secondary'Pr,_eservation�Criteria ,3
Yes; the watershed has threat from
The resources are under threat of
logging, mineral extraction, spring
destruction or adverse modifications.
development and other extractive use. See
Streams in a watershed that is, known to
"Threats "'section below.
The preserved site will be permanently
Yes; the preserved site will be
protected through an appropriate legal
permanently protected through a
instrument.
conservation easement.
Secondary Preservation Criteria from 2012,Guidance
Secondary'Pr,_eservation�Criteria ,3
Does Projed_Meet,Criteriai?. -
j_
Streams in a watershed that contains an
Yes; the project watershed is an
SNHA as identified by the NC NHP
"Outstanding" quality,SNHA
Streams in a watershed that is, known to
Yes; there are multiple state and federally
provide habitat for state or federally listed
listed species both observed and expected
endangered or threatened species.
to occur in the project watershed.
Streams in a watershed that High Quality
Yes; the project watershed is WS -I Water
Waters, Outstanding Resource Waters,
Supply Watershed, High Quality Water,
Trout Waters, or Water Supply
and Trout Water
Watersheds.
Streams in a watershed that contains
Yes; the watershed has unique and high
unique and /or high quality habitat that is
quality habitat and is adjacent to Spruce
adjacent or within an area experiencing
Pine, the. largest town in the County.
an' increase in population or development ,
Spruce Pine, while small, has seen steady
trend.
growth over the last decade.
The 2012 guidance and 2008 Federal Rule further note that, while preferable for preservation to be
done in conjunction with restoration and /or enhancement activities, this "requirement may be waived
by the district engineer where preservation has been identified as a high priority using a watershed
approach, but compensation ratios shall be higher." It continues, "Stand -alone preservation
projects...may be allowed in special circumstances and should only be proposed for sites that are of
exceptional quality or have been identified as unique or high priority areas." The proposed project is
a special circumstance for the reasons described above, the preservation is of exceptional quality,
unique, and a high priority as described in the Mitigation Plan, and the proposed ratios are sufficiently
high to account for the all- preservation approach, making the Beaver Creek mitigation proposal in
line with regulatory guidance.
Additionally and of particular note to this project, CFR §332.3 ("General compensatory mitigation
requirements" section) states, "For difficult -to- replace resources- (e.g., bogs, fens,,,springs, streams,
Atlantic white cedar swamps) if, further avoidance and minimization is,not practicable, the required
compensation should be provided,'if, practicable, through in -kind rehabilitation, enhancement, or
preservation since there is greater certainty that these methods of compensation will successfully
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offset permitted impacts" [emphasis added]. The text of the 2008 Rule in the Federal Register
further notes, "'Preservation is particularly valuable for protecting unique, rare, or difficult-to- replace
aquatic resources, such as bogs, fens and streams, and:,may be the most appropriate form of
compensatory mitigation for those resources" (Vol. 73, No. 70, pp 19635). The historic features of
the Little Bear Creek watershed prior to mining activities were indeed unique and difficult to replace
(high gradient trout streams and'stream -seep complexes). The similarity of the resources of the,
Beaver Creek watershed represent a unique opportunity to provide in -kind mitigation of these difficult
to replace resources through preservation, as suggested by the 2008 Rule.
"6. TQC failed to account for impacts and mitigation from stream relocation. The
initial application did not capture impacts associated with stream relocation. The
subsequent application addendum submitted by TQC addresses impacts and
monitoring post - construction. In addition to this information, the Corps requests
stream quality assessment forms and detailed construction plans for the proposed
channel relocation."
Attachment 3 contains stream quality assessment forms and construction plans for the stream
relocation. The majority of the stream reach that will be relocated has been impacted by past
activities at the site prior to The Quartz Corp. This stream currently flows through a very disturbed
area of the mine and does not have a surface hydrologic connection to Little Bear Creek. A decision
of no mitigation required was established during pre - application meetings with your office. The
stream relocation project has been re- designed three times to avoid additional disturbance to young
forested areas and to place the stream in the optimal location for long term stability. It is likely that
more stream linear footage will result than is currently there. The relocated stream will be more
stable than 'the current condition due to the fact that it will flow in a ,bio- engineered valley with
bedrock substrate as opposed to a loose, unstable road bed. Water quality should also improve in
the relocated stream compared to the current condition given as it currently dumps out onto a mining
floor bench. A surface hydrologic connection with Little Bear Creek will be established. The haul
road that will 'be adjacent to the relocated stream must'be designed at 12.5% slope. The relocated
stream has been designed at 2% slope. The existing slope is 4 -10% so a gentler slope should be
more stable as well. A rock lined swale has been included in the design in order to equalize the two
slopes. Added to the post- construction monitoring for the stream relocation project will be visual and
photographic monitoring where the unnamed tributary and newly constructed stream relocation
confluence occurs.
"7. TQC ,must demonstrate why the proposed preservation is adequate
compensation. Specifically, the streams proposed to be protected by a 300 -foot
buffer within a conservation easement are already protected by a 300 -foot
restrictive covenant. That covenant precludes cutting of trees and land - disturbing
activities in the 300 -foot buffer, except to serve enhancement purposes. The
applicant has not demonstrated the buffers are under external, demonstrable
threats."
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In a subsequent letter dated July 16, 2014, SELC re- stated their concern about the threat, to
the watershed. This concern `is addressed below.
Threats,to Beaver Creek and Existing Level of Protection /Buffers
This section of the response letter is similar information that was provided to NC DWR in response to
their request for additional information regarding the proposed Beaver Creek Preservation mitigation
plan.
The Town of Spruce Pine can legally allow logging within the Beaver Creek watershed and has
considered logging in the past on a watershed tract they owned in order to generate revenue. Town
Council meeting minutes dated August 13, 2012 state, "The Town has not decided whether to sell
the property to a private purcha_"ser or public conservancy or whether to log the, property.... timbering
is not out of the question."
Logging is allowed within WS -I watersheds provided 'that foresty 'Best Management Practices (BMP)
are followed. These BMP's suggest a 50' stream buffer, so logging could occur to within 50' of
streams in the watershed despite the WS -I classification. Given the steep topography and erosive
soils in the watershed, a 50' buffer would not be sufficient to protect water quality in the watershed.
The Beaver Creek watershed tract deed includes covenants that provide a 300 "wooded buffer to
streams. However, these buffers are not surveyed so their limits are unclear,. They appear only to
extend to streams shown on the USGS topographic map, as shown in Exhibit C of the deed
(previously submitted with the IP application package). The buffered areas do not include all
tributaries and stream /seep complexes. The proposed mitigation project will extend a 300'
permanent buffer via conservation easement to include all jurisdictional streams in the watershed,
including tributary streams, and connected seep areas, which are not currently protected.
Prior to the purchase by Rocky River Hydro, streams within the watershed tract were not buffered.
While the primary motivation of purchasing the tract was to add to the surrounding land portfolio,
Rocky River Hydro also retained the rights to develop mitigation credits on the property, as noted in
the covenants.
The covenants legally can be revoked or revised by the Town of Spruce Pine at any time, such as to
reduce the buffer to allow logging to within 50' of the streams, or to permit other extractive uses as
allowed by WS -I rules, if the Town were to find this in their best interest. Given the Town's past
expressed interest in timbering to generate economic revenue, this is a reasonable possibility.
Additionally, the landowner could petition for revocation of the covenants based on factors such as
economic hardship. Covenants are based on common law doctrines, which make them more subject
to termination based on such factors. In contrast, a conservation easement is based in state statues,
and thus has the weight and enforceability of state law in perpetuity.
Asheville Office
775 Haywood Road, Suite D
Asheville, NC 28806
828 -712 -9205 mobile

In terms of enforcement, the covenants do not require monitoring and stewardship, so their
enforcement is questionable.
Given the high value of and accessibility to the timber (as previously documented as a supplement to
the IP application package) and potential value of mineral resources in the Beaver Creek watershed,
there is clear economic incentive for both the landowner and the'Town to consider revising the
covenants to Fallow extractive use:
The watershed, though a WS -I, Is now under private ownership. Following discussions with DWR, it
Is unclear whether this classification could be retained if a future landowner were to petition for a
reclassification, given that state rules describe the WS -I classification as applying to watersheds in
public ownership. Additionally, if the Town were to abandon the use of the Beaver Creek reservoir
and move their water supply to another source, the Beaver Creek watershed would likely be
reclassified and the covenants lifted, because they are Intended to protect the operation of the water
supply. The Beaver Creek reservoir currently makes up about 50% of the Town's water supply. The
Town was required to dredge the reservoir several years ago at a very high cost and effort due to
natural erosion in the steep watershed. The costs of maintaining the reservoir with continuing
erosion, and the limitations associated with expansion of the reservoir as outlined in the covenants,
May drive the Town to seek an alternative water supply in the future, which would leave the tract
unprotected.
During a recent site visit to Beaver Creek it was determined that the property could have an
economic quartz deposit based on the surface outcroppings and a grab sample tested at The Quartz.
Corp, laboratory. The testing of the. sample showed an impurity level for iron, sodium and potassium
that are within the current process method for glass tubing requirements. The Titanium level was
above the current process method cutoffs which would mean further work would be needed 'to be
done to develop ,a process that could lower the Titanium. However what makes the potential deposit
interesting for more development work is the lack of detectable calcium. Having an economic quartz
deposit with extreme low values in calcium would really drive future product develop plans.
In summay, the legal rights of the landowner and Town to extract resources in the watershed,
combined with the economic incentive to do so, constitutes.an on -going threat. While the landowner
currently prefers to maintain the land in conservation, the property is owned fee simple and could be
sold at any point, making it subject to the Interest of subsequent landowners.
As noted above and in SELC's comment letter, the 2008 federal rule states that preservation may be
used when several conditions are met, including when "the resources are under threat of destruction
or adverse modification." While the word "threat" is not defined in the Code of Federal Regulations
as, relates to compensatory mitigation, the legal rights of the landowner and Town, combined with
the economic incentive from the timber and mineral resources on the site, constitute an on -going
threat to the resource.
Asheville, Office
775 Haywood Road, Suite D
Asheville, NC 28806
828 -712 -9205 mobile

The word � "preservation" is, defined in the Code, of Federal Regulations as it relates to compensatory
mitigation. CFR §332.2 ("definitions" section) states, "Preservation means ,the removal of a threat to,
or preventing the decline of, aquatic resources ,by, an action in or near those aquatic resources. This
term includes activities commonly associated with the protection ,and maintenance, of aquatic
resources through'the implementation of`appropriate legal and' physical mechanisms." The proposed,
Beaver Creek preservation project would remove the threat -associated, with potential timber and
mineral extraction, and by doings so, prevent the decline of aquatic resources, thereby meeting the,
definition of preservation as described_ in the 2008 Federal Rule and associated Code of Federal
Regulations.
Western North Carolina Alliance ,(WNCA)
According to discussions in the meeting held between The Quartz Corp, Unique Places, WNR, SELC,
and WNCA ,on June 25, 2014, the primary concern stated by WNCA with regard to the project and
proposed mitigation 'was related to erosion and sedimentation control's �at the mining site. 'WNCA
asked whether additional sediment controls could',be proposed for mitigation. The Quartz Corp
explained 'that, sediment and erosion control plans for the site ,already exceeded requirements, so this
would not be an, appropriate form of mitigation. 'The applicant has included the erosion control plans
for Pine Mountain, Mine sand a sutnrnary spreadsheet in` Attachment 4.
Of ;note, WNCA did not state concern with -the preservation proposed at Beaver Creek in the meeting.
They in fact noted the value of high quality preservation such as Beaver Creek ,as a form of'
mitigation.
United States Fish and Wildlife, Service (FWS
No,comments,were received during the public notice from FWS. Mr. Bryan Tompkins did participate
in the agency site, visit to Pine Mountain Mine and, the, Beaver .Creek Preservation project on May '12,
2014. Correspondence with Bryan has occurred since our last meeting in your office on June, 25,
2014. Per Bryan Section 7 consultation is complete.
United ;States Environmental Pr®tection Agency (EPA)
No comments were received during the public notice from, EPA. However, Mr. Todd Bowers did
participate in the agency site visit to Pine Mountain Mine 'and the Beaver Creek Preservation project,
on, May 12, 2014.
Summary
To summarize,, we have provided feedback from all .of`the comment letters and emails received
during the public notice. This package includes­a rev_,ised broadened purpose, 'alternatives analysis;
and analysis of impacts for the'project: An, expansion of the potential cumulative'and, second ary
impacts has been included.
Asheville <Ofrlce
775' HaywoodAoadaSuite D
Asheville, NC ",28806
828 -712 -9205 mobile

1080 linear feet (88.5 %) of the proposed stream impacts occur on poor quality streams which are
lacking function and habitat. The proposed work and structures at these locations will very likely
improve downstream water quality over time. A very minimal amount, 140 linear feet (11.,,5 %), of
the stream impacts are necessary for two road crossings to access a mine waste area. Habitat will
be improved at one of these road crossings due to improved culvert design, and should 'be
minimally affected at the other road crossing given the design and method of installation during
construction. Removing a portion of the preservation to allow for a restoration component will
diminish ,the exceeding high value of the preservation mitigation plan. The preservation plan is
offering higher mitigation ratios than are required.
The Beaver Creek preservation project is the most appropriate and ecologically significant form of
mitigation available for this project. There are no available banks in the HUC. Multiple benefits of'
the Beaver Creek preservation project outweigh EEP, on -site restoration, and off -site restoration.
Beaver Creek is a very unique and high priority opportunity for a mitigation site, which will not'
likely be duplicated. The NC IRT 2012 Preservation Guidance and'2008 Federal Rule are being met
by the proposed mitigation plan at Beaver Creek.
TQC did not account for mitigation for the stream relocation because your office concurred that no
mitigation would be required during pre - application meetings. Stream assessment forms and
detailed construction plans have been included. The monitoring commitment has been expanded
to include the upper confluence.
Threats of logging, water bottling, additional ponds, mining, and potential future development are
a real possibility at Beaver Creek. The Town of Spruce Pine could allow logging within the Beaver
Creek watershed up to within 50' of the streams. The'level of protection under a conservation
easement will be much greater than the current protection within the watershed under the
restrictive covenant, and will add additional areas not currently protected.
With the application and all supporting data we have established that the average impact areas are
low quality streams and that the entirety of the preservation area is of the highest ecological
value. We submit that the preservation of Beaver Creek replaces the historic uses that were lost
within Little Bear Creek basin and its tributaries during the life of the mine. The impacted streams
likely supported brook trout (specifically in Little Bear Creek) and pollution intolerant small stream
aquatic life prior to the mining operations which commenced in 1937. The aquatic life that once
thrived and propagated within these streams is present at the Beaver Creek Site which is an
immediate and viable replacement. Strengthening the environmental protections will insure that
these systems remain in perpetuity. The existing uses are limited to the propagation and survival of
sediment tolerant species. The remaining reaches of streams at Pine Mountain Mine will see a
functional uplift with the implementation of the sediment controls and ;storm water controls
associated with the new mining permit. Essentially the implementation of erosion control practices
will provide a level of restoration within the Little Bear Creek basin and that the Beaver Creek
preservation site will provide additional immediate replacement of existing and lost functions.
While the all preservation mitigation plan at Beaver Creek may not be justified for all projects, it is
overwhelmingly justified for the impacts at Pine Mountain Mine. Beaver Creek and its tributaries is
the most ecologically viable site because it most closely replaces the functions and values that have
Asheville Office
775 Haywood Road, Suite D
Asheville, NC'28806
828 =712 -9205 mobile

been lost at the ,mine site and that are not available, to be restored elsewhere. Historically speaking,
the smaller streams'in high mountain valleys were left undisturbed by agriculture;and therefore there
are no identified opportunities to replace these functions through restoration.
What makes Beaver Creek a viable option is that'the preserved areas are high quality areas that have
benefited from a limited amount of protection as a water supply watershed. The high value of these
streams is found on no other preservation site because most preservation is, incidental to preserving
on site streams that cannot be impacted. Unlike the EEP sites, the Beaver Creek site protects
upstream waters and better ensures the survival of pollution intolerant species. The valley type
restoration conducted' by the EEP serves different specific functions and values; none of the EEP sites
support just brook trout or protect intact headwaters stream and seep systems. The patchwork
restoration conducted by, the EEP does not control pollutant inputs from upstream waters' nor does it
replace the lost functions of the streams at, the impact areas and therefore we find it less ecologically
viable of replacing the lost functions and values.
Section 7 consultation with FWS has concluded. No comments were received from EPA. For
clarification purposes the Pine Mountain Mine permit boundary is 577.10 acres as opposed to 755
acres. Please correspond if we need to provide any additional assistance or information necessary
for your review and, if possible, expedite the issuance of this permit authorization request. Please
feel free to call with any questions or comments.
Best regards,
� a-? z,,
Jennifer L Robertson
Asheville Office
775 Haywood Road, Suite D
Asheville, NC 28806
828 =712 -9205 mobile

Attachment 1
THPO Site History, Slope Analysis Summary, and Maps

Pine Mountain Mine
The Quartz Corp
Eastern Band of Cherokee Indians, THP®
Phase 1 Request Additional Information
History of Pine Mountain Mine
The Quartz Corp was formed in 2011 as a joint venture between Imerys and Norsk
Mineral AS.
The Pine Mountain Mine currently consists of a mining processing plant and associated
facilities, multiple sedimentation and settling ponds, maintenance buildings and
associated facilities, an extensive infrastructure of roads, existing mined areas, existing
mine waste dump, areas, existing tailings management areas, logged areas, young
forested areas, disturbed forested areas, streams, and wetlands. Elevations on site
range from approximately 3,520 feet on the Northern 'boundary of the property to
approximately 2,500 feet on'the Southern boundary along North Toe River. The Little
Bear Creek drainage on site ranges in elevation from 2,640 feet to 3,460 feet.
This property began being mined in 1937 for mica, quartz, and feldspar. The property
has also been logged as recently as 1994. There has been extensive disturbance in the
mined areas. Many of the logged areas are greater than 15% slope.
All, economic resources are located beneath the'surface and we presume that all readily
minable surface (shallow) resources were depleted many years ago.
Summary of Slope Analysis Maps
The total land area at Pine Mountain Mine is 577.10 acres. The slope analysis has been
sectioned into property within the mine that includes mining areas (459.00 acres),
tailings areas (81.00 acres), and plant areas (37.10 acres). There is 190.10 acres that
,are less than or equal to 1.5% slope; and '387.00 acres that are greater than or equal to
15% slope at Pine Mountain Mine. Within the 190.10 acres there is 137.58 acres that
are highly disturbed. The areas within Pine Mountain Mine that are less than 15%
slope that are not disturbed include some mining, tailing, and plant areas as well as the
Little Bear Creek stream corridor within the mine area total 52.52 acres (9.1 %) and
42.72 acres (7.4 %) not including the Little Bear Creek stream corridor. Based on
conversations with Mr. Tyler Howe 7.4% - 9.1% of Pine Mountain Mine would be
eligible for conducting a Phase 1. However, some of these areas are not proposed for
disturbance such as the Little Bear Creek stream corridor.

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Pine Mountain Permit Boundary
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Attachment 2
Glenda Hollifeld Maps

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Attachment 3
Stream Relocation Data Forms and Plans

USACE AID#_ 00t3- 013'1(a DWQ,# I +- 035Ra Site #T 4indtcate onptgSkl d rtjapl�
rMS STREAM QUALITY ASSESSMENT WORKSHEET
Provide the following'information for the stream reach under assessment:
1. Applicant's name. "rh2 OuiNckZ
3. Date of evaluation*- `l 15ZQQ13
5. Name of stream: JT Av U A) JL, far
7. Approximate drainage area-- D, t SQe, wt " -_��e..
9. Length of reach evaluated: 10c),
11. Site,coordinates (if known). prefer en'decimal degrees
2. Evaluator's name- c ,Q-
4. Time of evaluation �}' = P M
6. River basin: (ND< ��_�,�- .1, iky
8. Stream order. 1
10. County._ INN "C -VA e- /
12. Subdivision v
name (if any) N16L
Latitude (ex 34 872312). 36-
-M3 - Longitude (ex —77 556611). —Q , 0913ncri-29oa %' 5
Method location detemuned,(circle). Ph((note� T,opo Sheet Ortho,(Aerial PFsairnidDattach Other GIS Other
13: Location of reach under evaluanearby r oads and landma map identifying stream(s) location).
S Q_Caxv� rtA o [a.34 n✓t K"2t rat
14. Proposed channel work (if any)-_ CRAQC�a-�2,
15. Recent weather conditions k, Vi PrVLA v-ta ► vv
16. Site conditions at time of visit
17. Identify any special waterway classifications known _Section 10 Nal Waters _Essential Fisheries Habitat
Trout Waters _Outstanding Resource Waters — Nutrient Sensitive Waters _Water Supply Watershed (I -IV)
18. Is there a pond or lake located upstream of the evaluation pomt9 YES 0 If yes, estimate the water,surface area. A/0
19. Does channel appear on USGS'quad map? YES CNO'
20. Does channel appear on USDA Soil Survey9 YES NO
21. Estimated'watershed land use: _% Residential _% Commercial _ %,Industrial _% Agricultural
r)al Forested _% Cleared / Logged �% Other * k vk )
22. Bankfull width I 23. Bank height (from bed to top of bank): t ri
24. Channel slope down center of stream _Flat (0 to 2 %) _Gentle (2 to 4 %) X_Moderate (4 to 10 %) =Steep ( >10 %)
25. Channel" 'sinuosity Y—Straight _Occasional, bends _Frequent meander Very sinuous _Braided channel
Instructions for completion of worksheet (located on page 2): Begin by determining the most ,appropriate ecoregion based on
location, terram, vegetation, stream classification, etc Every characteristic must be scored using the same ecoregion Assign points
,to each charactenstic within the range shown for the ecoregion Page 3 provides a 'brief description of how to review the
characteristics identified in the worksheet Scores should reflect an overall assessment of the stream reach under evaluation. If a
characteristic cannot be evaluated due to site or weather conditions, enter 0 in the scoring box and provide an explanation in the
comment section. Where'there are obvious changes in the character of a stream under review (e.g., the stream flows from a pasture
into a forest), the stream may be divided into smaller reaches that display more continuity, and a,separate form used to evaluate each
reach The total score assigned to a stream reach must range between 0 and 100,, with a score of 100 representing a stream ,of the
highest quality
Evaluator's Signature, Date /g /o�0 i 3
This channel evaluation form J�the ntended to be used only as a ide to assist landowners and' environmental professionals in
gathering the data required United States Army Corps of Engineers to make a preliminary assessment of stream
quality. The total score resulting from the completion of this form is subject to USACE approval and does not' imply a
particular mitigation ratio or requirement. Form,sublect to change - version 06/03. To�Comment, please call 919- 876 =8441 x 26.

STREAM QUALITY ASSESSMENT WORKSHEET
I11UNC ka141dGle11Sl1GS ale nol assessed in coastal streams.
#
CHARACTERISTICS
ECOREGION POINT
RANGE
SCORE
Coastal
Piedmont
Mountain
1
Presence of flow / persistent pools in stream
0-5
0 - 4
0-5
(no flow or saturation = 0; strong flow = max points)
1 1
2
Evidence of past human alteration
0-6
0-5
0-5
extensive alteration = 0• no alteration = max points
3
Riparian zone
0-6
0-4
0-5
I
no buffer = 0; conti ous, wide buffer = max points)
4
Evidence of nutrient or chemical discharges
0-5
0-4
0-4
3
extensive discharges = 0; no dischar es = max points)
ra
5
Groundwater discharge
0-3
0-4
0-4
3
U
no discharge = 0; springs, seeps, wetlands, etc. = max points)
r•,
6
Presence of adjacent floodplain
0-4
0 - 4
0-2
no floodplain = 0• extensive floodplain = max points)
a"
Entrenchment / floodplain access
0-5
0 — 4
0-2
0
(deeply entrenched = 0; frequent flooding = max points)
8
Presence of adjacent wetlands
0-6
0-4
0-2
0
no wetlands = 0; large adjacent wetlands = max points)
9
Channel sinuosity
(extensive channelization = 0; natural meander = max points)
0-5
0 — 4
0-3
10
Sediment input
0-5
0-4
0-4
extensive deposition= 0; little or no sediment = max points)
11
Size & diversity of channel bed substrate
fine, homogenous = 0; large, diverse sizes = max points)
NA*
0-4
0 - 5
12
Evidence of channel incision or widening
F
deep) incised = 0• stable bed & banks = max points
0-5
0 - 4
0-5
a 4
13
Presence of major bank failures
0-5
0 — 5
0-5
0
(severe erosion = 0; no erosion stable banks = max points)
02
14
Root depth and density on banks
no visible roots = 0; dense roots throughout = max points
0-3
0 — 4
0-5
15
Impact by agriculture, livestock, or timber production
�
substantial impact • no evidence = max points
0 — 5
0 — 4
0 — 5
16
Presence of riffle- poot/ripple -pool complexes
0-3
0-5
0-6
3
F
(no riffles/Tipples or pools = 0; well - developed = max oints)
F
17
Habitat complexity
(little or no habitat = 0• frequent, varied habitats =
0-6
0-6
0-6
a
max points)
18
Canopy coverage over streambed
l
(no shading vegetation = 0; continuous canopy = max points)
0-5
0 - 5
0-5
I
19
Substrate embeddedness
NA*
0-4
0-4
a
(deeply embedded = 0; loose structure = max
20
Presence of stream invertebrates (see page 4)
no evidence = 0• common, numerous es = max points
0-4
0 — 5
0-5
'J
21
Presence of amphibians
0-4
0-4
0-4
a
O
(no evidence = 0• common, numerous es = max points)
22
Presence of fish
(no evidence = 0; common numerous types =
0 — 4
0-4
0 — 4
�l
lJ
max points)
23
Evidence of wildlife use
0
0
3
(no evidence = 0; abundant evidence =max points)
-6
-5
0 -5
Total Points Possible
100
100
100
TOTAL SCORE (also enter on first page)
k TI_
3�P
I11UNC ka141dGle11Sl1GS ale nol assessed in coastal streams.

USACE AID# QUO - QJ3!J(0 DWQ ##_ par; (e Site # (indicate on attached (qap)
;,o,; STREAM 'QUALITY ASSESSMENT 'WORKSHEET r
Provide.the followingInformation for the stream reach under assessment:
1. Applicant's name. QOQ(tZ COrp. 2. Evaluator's name Z[O-Rak S� Cie to
3. Date-of evaluation. —/ y oi013 _ l_ 4. Time of evaluation 411-50
� n�
5. Name of stream )T -0j A +1 EQQjC 6. River basin, N D 6� ' p - N^ Vi c,�I y c"
S 1
7. Approximate drainage area. D. t w � Mv— ee. 8. Stream order. i {
9. Length of reach evaluated. — I OO, 10. County a 4-C)A PA l
11. Site coordinates (if known)• prefer in decimal degrees_ 12. Subdivision name (if any) o n,�
Latitudc,(ex 34 872312): 35.,a4S 3I I291 � Longitude (cx -77 556611): p a� ���?) 043 29 09'g 157
Method location determined`(cifele) GPS Topo Sheet Ortho (Aenal) hoto /GI Other GIS Other
13. Location of reach under evaluation (note-nearby roads andlandmarks and attach map identifying stream(s) location):
Lak- " s4f Irv► r l0GAA� no
14. Proposed channel work (if any): �(o� (Zr_a,e-
15. Recent weather conditions- P,>�o VV. aA. . A o /IV a I ,r-^ I W-%
16. Site conditions at time,of visit,
17. Identify any special waterway classifications know
,Trout Waters Outstanding Resource Waters
_Section 10 _Tidal Waters
Fisheries Habitat
Nutrient Sensitive Waters _Water Supply Watershed (I -IV)
18. Is there,a pond or lake located upstream of the evaluation point? YES NO If yes, estimate the water surface area,
19. Does channel appear on USGS quad map9 YES 20.,Dges channel appear,on USDA Soil Survey9 YES' O
21. Estimated watershed land use % Residential
% Forested
22. Bankfull width.
24. Channel slope down center of stream: _Flat (0 to 2 %)
_% Commercial _% Industrial _% Agncultural
_% Cleared / Logged 2,Q% Other ( )
23 Bank height (from bed to top of bank)- i
Gentle (2 to 4 %) Moderate (4 to 10 %) _Steep ( >10 %)
25. Channel sinuosity Straight KOccasional bends _ _Frequent meander _Very sinuous _Braided channel
Instructions for completion of worksheet (located on page 2): Begin by determining the most appropriate ecoregion based on
location, terrain, vegetation, stream classification, etc Every characteristic must;be scored using the same ecoregion Assign points
to each characteristic within the range shown for the ecoregion Page 3 provides a brief description of how to review the
characteristics identified in the worksheet Scores should reflect an overall assessment of 'the stream reach under evaluation. If a
characteristic cannot be evaluated due to ,site or weather conditions, enter 0 in the scoring box and provide an explanation 'in the
comment section Where there are obvious changes in the character of a stream under review (e.g, the stream flows from as pasture
into a forest), the stream may be divided into smaller reaches that display more continuity, and a separate form used to evaluate, each
reach. The total score assigned to a stream reach must range between 0 and 100, with' a score of 100, r_epresenting a stream of the
highest quality.
Evaluator's Signature \ ' A,% Date
This channel evaluation fo is intended to ,be used only Wa guide to assist landowners and environmental professionals in
gathering the data requiredby the United States Army Corps of Engineers to make a preliminary assessment of stream
quality. The total score resulting from the completion of this form is subject to USACE approval and does not imply a
particular mitigation ratio or requirement. Form subject,to change- version 06/03 To Comment, please call 919- 876 -8441 x 26
lt

STREAM QUALITY ASSESSMENT WORKSHEET
.I1CJG 1-11414cLC►isucs are not assessed in coastal streams.
#
CHARACTERISTICS
ECOREGION POINT
RANGE
SCORE
Coastal
Piedmont
Mountain
1
Presence of flow / persistent pools in stream
0-5
0 — 4
0-5
no flow or saturation = 0• strong flow = max points)
2
Evidence of past human alteration
0-6
0 - 5
0 — 5
O
(extensive alteration = 0; no alteration = max oints)
3
Riparian zone
0-6
0-4
0-5
O
no buffer = 0• contiguous, wide buffer = max points
4
Evidence of nutrient or chemical discharges
extensive discharges = 0; no discharges = max points)
0-5
0-4
0-4
t
5
Groundwater discharge
0-3
0-4
0-4
3
(no discharge = 0• springs, sees wetlands etc. = max points)
U
6
Presence of adjacent floodplain
(no floodplain = 0; extensive floodplain = max points)
0-4
0 - 4
0-2
O
aEntrenchment
/ floodplain access
0— 5
0— 4
0— 2
(,
(deeply entrenched = 0; frequent flooding = max points)
8
Presence of adjacent wetlands
0-6
0-4
0-2
0
no wetlands = 0; large adjacent wetlands = max points)
9
Channel sinuosity
0-5
0 — 4
0-3
(extensive channelization = 0; natural meander = max points)
10
Sediment input
extensive deposition= 0; little or no sediment = max points)
0-5
0-4
0-4
Q
11
Size & diversity of channel bed substrate
fine, homogenous = 0• large diverse sizes = max points
NA*
0-4
0 - 5
12
Evidence of channel incision or widening
0-5
0 4
a
(deeply incised = 0; stable bed & banks = max points)
-
0-5
13
Presence of major bank failures
severe erosion = 0• no erosion, stable banks = max p oints
0-5
0 - 5
0-5
l
14
Root depth and density on banks
0-3
0 - 4
0-5
Ono
visible roots = 0; dense roots throughout =max points
15
Impact by agriculture, livestock, or timber production
substantial impact =0; no evidence = max points
0-5
0 - 4
0-5
3
16
Presence of riffle- pool/ripple -pool complexes
H
(no riffles/ripples or pools = 0• well- develo ed = max points)
0-3
0 — 5
0-6
1
17
Habitat complexity
(little or no habitat = 0; frequent, varied habitats = max points)
0-6
0-6
0-6
18
Canopy coverage over streambed
0-5
0 — 5
0-5
(�
no shading vegetation = 0; continuous cano = max points)
19
Substrate embeddedness
NA*
0-4
0 - 4
(deeply embedded = 0; loose structure = max)
01
20
Presence of stream invertebrates (see page 4)
no evidence = 0; common, numerous types = max points)
0-4
0 - 5
0-5
21
Presence of amphibians
O
no evidence = 0• common, numerous types =max points)
0 -4
0 -4
0 -4
t
l
22
Presence of fish
0-4
0 — 4
0 — 4
O
(no evidence = 0• common, numerous es = max points)
23
Evidence of wildlife use
0 — 6
0 — 5
0-5
no evidence = 0; abundant evidence = max points)
Total Points Possible
100
100
100
TOTAL SCORE (also enter on first page)
T�
a.
.I1CJG 1-11414cLC►isucs are not assessed in coastal streams.

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Attachment 4
Erosion Control Plan and Spreadsheet

Pine Mountain Mine
The Quartz Coop
Southern Environmental Law Center, SELC
and
Western North Carolina Alliance, WNCA
Erosion and Sedimentation Control Request Additional Information
Summary
Attachment,4- has been included for SELC and, WNCA. According to discussions in the
meeting held between The Quartz Corp, Unique Places, WNR, SELC, and WNCA on June
25, 2014, the primary concern stated by WNCA with regard to the project and proposed
mitigation was related to erosion and sedimentation controls at the mining site. WNCA
asked whether additional sediment controls could be proposed for mitigation. The
Quartz Corp explained that sediment and erosion control plans for the site already
exceeded requirements, so this would not bean appropriate form of mitigation. The
applicant further explained that DENR is currently reviewing the mining permit which
includes erosion and sedimentation control plans. 'In summary, there are over 75
sediment and /or water- quality basins proposed on the plan within the Mine Mountain
Mine permit boundary. There are 6.77 miles of rip rap ditches proposed and 121 miles
of grassed swales proposed which accumulate to 9.99 miles of ditches and swales.
Of note, WNCA did not state concern with the preservation proposed at Beaver Creek in
the meeting. They in fact noted the value of high quality preservation such as Beaver
Creek as a form of mitigation.
The maps .included within this attachment include the ditches and swales that will be
incorporated at Pine Mountain Mine. Please note that the scale on these maps has
been revised from the maps submitted in the mining permit to account for a different
paper size. These maps are scaled for printing on it x 17 paper.

Pine Mountain,Sedimerit Control
RIP
GRASS
Total
Fe_ e_ t
feet
feet
MP2
2;696
1,,212
3,908
,MP3
3,358
4,041
7,399
MP4
1,393
762
2,155
MP5
803
199
902
MP6,
3,498
.869
4,367
MP7
5,667
5,667
MP7A
107
2,506,
2,613
MP8
10,468
10,468
MP9
4,849
4,849
MP10
1,830
2;444
4,274
MP11
768
2;047
2,815
MP12
50
1,555
1,605
MP13
264
1„437
1,701
total
35,751
16,972
52,723
677
321
:9 99 Miles

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