20070645 Ver 1_Application_20070412

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CLEARWATER ENVIRONMENTAL CONSULTANTS, INC.
March 20, 2007
Ms. Linda Wiggs
NC Division of Water Quality
2090 US Highway 70
Swannanoa, NC 28778-8211
Ms. Lori Beckwith
US Army Corps of Engineers
151 Patton Ave, Room 208
Asheville, NC 28801-5006
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Re: After-the-Fact Permit Application
Duncan Creek Restoration
Henderson County, NC
Dear Ms. Wiggs and Ms. Beckwith,
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The enclosed after-the-fact permit application is in response to work performed on Duncan Creek in
Henderson County, NC. This application addresses the comments of the Notice of Violation (NOV-
2007-SS-0002) issued by the NC Division of Water Quality on January 23, 2007. A total of 315 l.f.
of stream channel are proposed to be filled where the abandoned channel is located. The new,
restored channel consists of 225 l.f. of stream length. A net loss of 90 l.f. occurred during the
restoration process. The abandoned stream channel was unstable while the new channel more
adequately matches the pattern and dimension of the upstream reference area. Based on
measurements of the new channel and an upstream reference reach section, the dimension and pattern
of the new channel seem relatively well sized and designed. While there is an overall reduction in
stream length, the increase in aquatic resources and functions should compensate for this loss. A 25-
foot riparian buffer will be planted on either side of the restored channel for a total of 0.28E acres of
riparian buffer restoration. Native trees/shrubs will be planted on 10-foot centers to achieve a target
density of 320 trees/acre at maturity.
On behalf of the applicant, we are requesting that this project be authorized under Water Quality
Certification #3626 and Nationwide Permit No. 27. Thank you for your assistance in this matter. If
you have any questions, please do not hesitate to call me at [phone].
Sincerely,
R. Clement Riddle, P.W.S.
President
718 Oakland Street
Hendersonville, North Carolina 28791
Phone: [phone] Fax: [phone]
www.cwenv.com

~ ~
Processing
.~ .[ -
Office Use Only: Form Version March OS
USACE Action ID No. DWQ No.
(If any particular item is not applicable to this project, please enter "Not Applicable" or "N/A".)
I.
II.
1. Check all of the approval(s) requested for this project:
® Section 404 Permit ^ Riparian or Watershed Buffer Rules
^ Section 10 Permit ^ Isolated Wetland Permit from DWQ
® 401 Water Quality Certification ^ Express 401 Water Quality Certification
2. Nationwide, Regional or General Permit Number(s) Requested: NWP# 27
3. If this notification is solely a courtesy copy because written approval for the 401 Certification
is not required, check here: ^
4. If payment into the North Carolina Ecosystem Enhancement Program (NCEEP) is proposed
for mitigation of impacts, attach the acceptance letter from NCEEP, complete section VIII,
and check here: ^
5. If your project is located in any of North Carolina's twenty coastal counties (listed on page
4), and the project is within a North Carolina Division of Coastal Management Area of
Environmental Concern (see the top of page 2 for further details), check here: ^
Applicant Information
1. Owner/Applicant Information
Name: Jim
2Q070645
nwK 1 ~ Zfl~(
Mailing Address: PO Box 523 8 N~ ~1~ t'1' Ra,~,~t~~ r~
Asheville NC 28813
Telephone Number: 828-230-7702 Fax Number:
E-mail Address:
2. Agent/Consultant Information (A signed and dated copy of the Agent Authorization letter
must be attached if the Agent has signatory authority for the owner/applicant.)
Name: Clement Riddle
Company Affiliation: C1earWater Environmental Consultants, Inc.
Mailing Address: 718 Oakland St
Hendersonville NC 28791
Telephone Number: 828-698-9800 Fax Number: 828-698-9003
E-mail Address: clement(a,cwenv.com
Page 1 of 9

III. Project Information
Attach a vicinity map clearly showing the location of the property with respect to local
landmarks such as towns, rivers, and roads. Also provide a detailed site plan showing property
boundaries and development plans in relation to surrounding properties. Both the vicinity map
and site plan must include a scale and north arrow. The specific footprints of all buildings,
impervious surfaces, or other facilities must be included. If possible, the maps and plans should
include the appropriate USGS Topographic Quad Map and NRCS Soil Survey with the property
boundaries outlined. Plan drawings, or other maps may be included at the applicant's discretion,
so long as the property is clearly defined. For administrative and distribution purposes, the
USACE requires information to be submitted on sheets no larger than 11 by 17-inch format;
however, DWQ may accept paperwork of any size. DWQ prefers full-size construction
drawings rather than a sequential sheet version of the full-size plans. If full-size plans are
reduced to a small scale such that the final version is illegible, the applicant. will be informed that
the project has been placed on hold until decipherable maps are provided.
1. Name ofproject: Duncan Creek Restoration
2. T.I.P. Project Number or State Project Number (NCDOT Only): N/A
3. Property Identification Number (Tax PIN): 9672186357
4. Location
County: Henderson Nearest Town: Fletcher
Subdivision name (include phase/lot number):
Directions to site (include road numbers/names, landmarks, etc.):_ Take Hwy 25 south from
Asheville. Turn left onto Howard Gap Rd Turn left onto Jackson Rd Turn ri t onto
Souther Rd. Bear right onto Livingston Rd The site is located on the left where Duncan
Creek crosses under the road.
5. Site coordinates (For linear projects, such as a road or utility line, attach a sheet that
separately lists the coordinates for each crossing of a distinct waterbody.)
Decimal Degrees (6 digits minimum): 35.42763 °N 82.45493 °W
6. Property size (acres): 6.0~
7. Name of nearest receiving body of water: Duncan Creek
8. River Basin: French Broad
(Note -this must be one of North Carolina's seventeen designated major river basins. The
River Basin map is available at httn://h2o.enr.state.nc.us/admin/maps/.)
9. Describe the existing conditions on the site and general land use in the vicinity of the project
at the time of this application: The site is mostly cleared pasture with a few remaining
large trees. The surrounding areas are a mix of single-family residential and agriculture
Page 2 of 9

10. Describe the overall project in detail, including the type of equipment to be used: The
project involved the restoration through relocation of approximately 315 l.f of Duncan
1 1. Explain the purpose of the proposed work: Duncan Creek had become higlily unstable and
was experiencing severe lateral migration. A portion of the stream was impacting a driveway
right-of-way through bank erosion processes.
IV. Prior Project history
If jurisdictional determinations and/or permits have been zequested and/or obtained for this
project (including all prior phases of the same subdivision) in the past, please explain. Include
the USACE Action ID Number, DWQ Project Number, application date, and date permits and
certifications were issued or withdrawn. Provide photocopies of previously issued permits,
certifications or other useful information. Describe previously approved wetland, stream and
buffer impacts, along with associated mitigation (where applicable). If this is a NCDOT project,
list and describe permits issued for prior segments of the same T.I.P. project, along with
construction schedules. A Notice of Violation (NOV-2007-SS-0002) was received by the
annlicant and dated January 23.2007.
V. Future Project Plans
Are any future permit requests anticipated for this project? If so, describe the anticipated work,
and provide justification for the exclusion of this work from the current application.
No future plans are anticipated at this time.
VI. Proposed Impacts to Waters of the United States/Waters of the State
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
wetlands, open water, and stream channels associated with the project. Each impact must be
listed separately in the tables below (e.g., culvert installation should be listed separately from
riprap dissipater pads). Be sure to indicate if an impact is temporary. All proposed impacts,
permanent and temporary, must be listed, and must be labeled and clearly identifiable on an
accompanying site plan. All wetlands and waters, and all streams (intermittent and perennial)
should be shown on a delineation map, whether or not impacts are proposed to these systems.
Wetland and stream evaluation and delineation forms should be included as appropriate.
Photographs may be included at the applicant's discretion. If this proposed impact is strictly for
wetland or stream mitigation, list and describe the impact in Section VIII below. If additional
space is needed for listing or description, please attach a separate sheet.
Provide a written description of the proposed impacts: See attached sheet.
Page 3 of 9

1. Individually list wetland impacts. Types of impacts include, but are not limited to
mechanized clearing, grading, fill, excavation, flooding, ditching/drainage, etc. For dams,
separately list impacts due to both structure and fl~cdina_
Wetland Impact

Site Number
(indicate on map)

Type of Impact Type of Wetland

(e.g., forested, marsh,
herbaceous, bog, etc.) Located within
100-year
Floodplain
(yes/no) Distance to
Nearest
Stream
(linear feet) Area of
Impact
(acres)
N/A

Total Wetland Impact (acres) N/A
2
List the total acreage (estimated) of all existing wetlands on the property: 0.0
3. Individually list all intermittent and perennial stream impacts. Be sure to identify temporary
impacts. Stream impacts include, but are not limited to placement of fill or culverts, dam
construction, flooding, relocation, stabilization activities (e.g., cement walls, rip-rap, crib
walls, gabions, etc.), excavation, ditching/straightening, etc. If stream relocation is proposed,
plans and profiles showing the linear footprint for both the original and relocated streams
must be included. To calculate acrea~e_ multiply length X w;rlth then ~hv;rlP by d~ sin
Stream Impact
Number
(indicate on map)
Stream Name
Type of Impact Perennial or
Intermittent? Average
Stream Width
Before Impact Impact
Length
(linear feet) Area of
Impact
(acres)
1 Duncan Creek Restoration Perennial 10 ft. 315 0.07

Total Stream Impact (by length and acreage) 315 0.07
4. Individually list all open water impacts (including lakes, ponds, estuaries, sounds, Atlantic
Ocean and any other water of the U.S.}. Open water impacts include, but are not limited to
fill. excavation. dred~in~_ floodin~_ drainage_ hnikhearls etc
Open Water Impact

Site Number
mdicate on ma
( P)
Name of Waterbody

(if applicable)

Type of Impact Type of Waterbody

(lake, pond, estuary, sound, bay,
ocean etc.
) Area of

Impact

(acres)
N/A

Total Open Water Impact (acres) N/A
Page 4 of 9

S. List the cumulative impact to all Waters of the U.S. resulting from the nroiect:
Stream Impact (acres): 0,07 J
Wetland Impact (acres): 0.0
Open Water Impact (acres): 0.0
Total Impact to Waters of the U.S. (acres) 0.07
Total Stream Impact (linear feet): 31 S
6. Isolated Waters
Do any isolated waters exist on the property? ^ Yes ®No
Describe all impacts to isolated waters, and include the type of water (wetland or stream) and
the size of the proposed impact (acres or linear feet). Please note that this section only
applies to waters that have specifically been determined to be isolated by the USACE.
N/A
7. Pond Creation
If construction of a pond is proposed, associated wetland and stream impacts should be
included above in the wetland and stream impact sections. Also, the proposed pond should
be described here and illustrated on any maps included with this application.
Pond to be created in (check all that apply): ^ uplands ^ stream ^ wetlands
Describe the method of construction (e.g., dam embankment, excavation, installation of
draw-down valve or spillway, etc.): N/A
Proposed use or purpose of pond (e.g., livestock watering, irrigation, aesthetic, trout pond,
local stormwater requirement, etc.): N/A
Current land use in the vicinity of the pond: N/A
Size of watershed draining to pond: N/A
VII. Impact Justification (Avoidance and Minimization)
Expected pond surface area: N/A
Specifically describe measures taken to avoid the proposed impacts. It may be useful to provide
information related to site constraints such as topography, building ordinances, accessibility, and
financial viability of the project. The applicant may attach drawings of alternative, lower-impact
site layouts, and explain why these design options were not feasible. Also discuss how impacts
were minimized once the desired site plan was developed. If applicable, discuss construction
techniques to be followed during construction to reduce impacts. The length of stream restored
was limited to only the area that exhibited serious instability Furtherrnore the applicant made
and will continue to make every effort to create and maintain a stable healthy stream and
riparian buffer for an overall increase in aquatic resources and functions While there is an
overall reduction in stream length, these improvements should adequately compensate for this
loss.
VIII. Mitigation
DWQ - In accordance with 15A NCAC 2H .OS00, mitigation may be required by the NC
Division of Water Quality for projects involving greater than or equal to one acre of impacts to
Page S of 9

freshwater wetlands or greater than or equal to 150 linear feet of total impacts to perennial
streams.
USACE - In accordance with the Final Notice of Issuance and Modification of Nationwide
Permits, published in the Federal Register on January 15, 2002, mitigation will be required when
necessary to ensure that adverse effects to the aquatic environment are minimal. Factors
including size and type of proposed impact and function and relative value of the impacted
aquatic resource will be considered in determining acceptability of appropriate and practicable
mitigation as proposed. Examples of mitigation that may be appropriate and practicable include,
but are not limited to: reducing the size of the project; establishing and maintaining wetland
and/or upland vegetated buffers to protect open waters such as streams; and replacing losses of
aquatic resource functions and values by creating, restoring, enhancing, or preserving similar
functions and values, preferable in the same watershed.
If mitigation is required for this project, a copy of the mitigation plan must be attached in order
for USACE or DWQ to consider the application complete for processing. Any application
lacking a required mitigation plan or NCEEP concurrence shall be placed on hold as incomplete.
An applicant may also choose to review the current guidelines for stream restoration in DWQ's
Draft Technical Guide for Stream Work in North Carolina, available at
http://h2o.enr.state.nc.us/ncwetlands/strmgide html.
1. Provide a brief description of the proposed mitigation plan. The description should provide
as much information as possible, including, but not limited to: site location (attach directions
and/or map, if offsite), affected stream and river basin, type and amount (acreage/linear feet)
of mitigation proposed (restoration, enhancement, creation, or preservation), a plan view,
preservation mechanism (e.g., deed restrictions, conservation easement, etc.), and a
description of the current site conditions and proposed method of construction. Please attach
a separate sheet if more space is needed.
No mitigation is proposed as this is considered a restoration project The reduction in
stream length by 90 l.f. is adeguatel mitigated for by improvements in aquatic resources and
functions. A 25-foot riparian buffer will be planted on either side of the restored channel for
a total of 0.28E acres of riparian buffer restoration
2. Mitigation may also be made by payment into the North Carolina Ecosystem Enhancement
Program (NCEEP). Please note it is the applicant's responsibility to contact the NCEEP at
[phone] to determine availability, and written approval from the NCEEP indicating
that they are will to accept payment for the mitigation must be attached to this form. For
additional information regarding the application process for the NCEEP, check the NCEEP
website at http://h2o.enr.state.nc.us/wrp/index htm. If use of the NCEEP is proposed, please
check the appropriate box on page five and provide the following information:
Amount of stream mitigation requested (linear feet): N/A
Amount of buffer mitigation requested (square feet): N/A
Amount of Riparian wetland mitigation requested (acres): N/A
Amount ofNon-riparian wetland mitigation requested (acres): N/A
Amount of Coastal wetland mitigation requested (acres): N/A
Page 6 of 9

IX.
X.
Environmental Documentation (required by DWQ)
1. Does the project involve an expenditure of public (federal/state/local) funds or the use of
public (federal/state) land? Yes ^ No
2. If yes, does the project require preparation of an environmental document pursuant to the
requirements of the National or North Carolina Environmental Policy Act (NEPA/SEPA)?
Note: If you are not sure whether a NEPA/SEPA document is required, call the SEPA
coordinator at [phone] to review current thresholds for environmental documentation.
Yes ^ No ^
3. If yes, has the document review been fmalized by the State Clearinghouse? If so, please
attach a copy of the NEPA or SEPA final approval letter. Yes ^ No ^
Proposed Impacts on Riparian and Watershed Buffers (required by DWQ)
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
required state and local buffers associated with the project. The applicant must also provide
justification for these impacts in Section VII above. All proposed impacts must be listed herein,
and must be clearly identifiable on the accompanying site plan. All buffers must be shown on a
map, whether or not impacts are proposed to the buffers. Correspondence from the DWQ
Regional Office may be included as appropriate. Photographs may also be included at the
applicant's discretion.
1. Will the project impact protected riparian buffers identified within 15A NCAC 2B .0233
(Meuse), 15A NCAC 2B .0259 (Tar-Pamlico), 15A NCAC 02B .0243 (Catawba) 15A NCAC
2B .0250 (Randleman Rules and Water Supply Buffer Requirements), or other (please
identify )? Yes ^ No
2. If "yes", identify the square feet and acreage of impact to each zone of the riparian buffers.
If buffer mitigation is required calculate the required amount of mitigation by applying the
buffer multipliers.

Zone* Im act
s uare feet
(q )
Multiplier
Required
Mitigation
1 N/A 3 (2 for Catawba) N/A
2 N/A 1.5 N/A
Total N/A N/A
* Zone 1 extends out 30 feet perpendicular from the top of the near bank of channel; Zone 2 extends an
additional 20 feet from the edge of Zone 1.
3. If buffer mitigation is required, please discuss what type of mitigation is proposed (i.e.,
Donation of Property, Riparian Buffer Restoration /Enhancement, or Payment into the
Riparian Buffer Restoration Fund). Please attach all appropriate information as identified
within 15A NCAC 2B .0242 or .0244, or .0260. N/A
Page 7 of 9

XI. Stormwater (required by DWQ)
Describe impervious acreage (existing and proposed) versus total acreage on the site. Discuss
Stormwater controls proposed in order to protect surface waters and wetlands downstream from
the property. If percent impervious surface exceeds 20%, please provide calculations
demonstrating total proposed impervious level. The protect does not result in any_ increase in
impervious surface.
XII. Sewage Disposal (required by DWQ)
Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of
wastewater generated from the proposed project, or available capacity of the subject facility.
No wastewater is generated as a result of this project
XIII. Violations (required by DWQ)
Is this site in violation of DWQ Wetland Rules (1 SA NCAC 2H .0500) or any Buffer Rules?
Yes ® No ^
Is .this an a$er-the-fact permit application? Yes ® No ^
XIV. Cumulative Impacts (required by DWQ)
Will this project (based on past and reasonably anticipated future impacts) result in additional
development, which could impact nearby downstream water quality? Yes ^ No
If yes, please submit a qualitative or quantitative cumulative impact analysis in accordance with
the most recent North Carolina Division of Water Quality policy posted on our website at
http://h2o.enr.state.nc.us/ncwetlands. If no, please provide a short narrative description:
No cumulative impacts are anticipated as a result of this project
XV. Other Circumstances (Optional):
It is the applicant's responsibility to submit the application sufficiently in advance of desired
construction dates to allow processing time for these permits. However, an applicant may
choose to list constraints associated with construction or sequencing that may impose limits on
work schedules (e.g., draw-down schedules for lakes, dates associated with Endangered and
Threatened Species, accessibility problems, or other issues outside of the applicant's control).
The work has already been performed by the applicant The current stream channel is adequate
for increasing aquatic resources and functions and needs only minimal additional measures
3~~0~-
Applicant/Agent's Signature Date
(Agent's signature is valid only if an authorization letter from the applicant is provided.)
Page 8 of 9

XI. Proposed Impacts to Waters of the United States/Waters of the State
1. Provide a written description of the proposed impacts:
Duncan Creek had become unstable in the section just upstream from Livingston Rd, most likely
due to removal of riparian vegetation. Excessive lateral migration of the stream had led to
multiple instances of bank failure. One such location was impacting the applicant's driveway
right-of--way. The stream demonstrated little consistency of morphology throughout the reach,
especially in regards to channel width. Deposition of silt and other fine sediments was apparent.
In an effort to create a more stable stream, the applicant constructed a new channel and diverted
all flow through it. The new channel's location was based primarily on historic photos, plats,
and personal conversations between the applicant and past and present landowners. The restored
stream was placed as close to it's historical location as practicable.
A total of 315 l.f. of stream channel are proposed to be filled where the abandoned channel is
located. The new, restored channel consists of 225 l.f. of stream length. A net loss of 90 l.f.
occurred during the restoration process. Based on measurements of the new channel and an
upstream reference reach section, the dimension and pattern of the new channel seem relatively
well sized and designed. Further disturbance of the stream channel would result in a greater
detriment to aquatic resources and functions than the benefits that would be gained. While there
is an overall reduction in stream length, these improvements should adequately compensate for
this loss.
To further enhance the restoration efforts and provide for more stability of the new channel, the
applicant is also proposing additional measures. Currently, the banks are stabilized with
biodegradable erosion control matting and grassed with winter-rye. When the winter rye dies
back, over seeding with a native riparian grass seed mix will take place. Live stakes will be
installed to provide a more long term root mass and will be composed of native species. A 25-
foot riparian buffer, measured from the top of the bank, will be established on either side of the
new channel for a total of 0.28 acres of buffer restoration. Containerized and/or bare-root trees
and shrubs (as found in the NCEEP Guidelines for Riparian Buffer Restoration) will be planted
on 10-foot centers to obtain the optimal plant density of 320 trees/acre at maturity. A total of
approximately 125 trees/shrubs will be planted with individual species counts based on
availability.
To provide an adequate transition from the new channel back into the existing stream, the
applicant is proposing to install a rock cross vane as a grade control structure. This will provide
energy dissipation between the differing elevations of the stream channels and should prevent the
formation of a head cut and possible entrenchment of the new channel. The rock vane will be
based on typical design specifications with in-field sizing and final design during installation.
To ensure that the stream remains stable and that the riparian vegetation is surviving, the
applicant will monitor the stream and plantings one year after final completion of construction.
Cross sections, vegetation counts, and representative photos will be submitted to the USACE and
NCDWQ for final approval.
Page 9 of 9

authorization/agency on Duncan Creek project
Subject: authorization/agency on Duncan Creek project
From: [e-mail]
Date: Thu, 22 Mar 2007 07:55:44 -0400
To: [e-mail]
To whom it may concern...
I,James Andrews,authorize Clearwater Environmental Consultants,Inc. to act on my behalf and as my
agent pertaining to the Duncan Creek Restoration project in Henderson County,NC!
This authorization is for any wetlands permitting on above named project!
Sincerely...James Andrews
828-230-7702
AOL now offers free email to everyone. Find out more about what's free from AOL at AOL.com.
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SEVERE BANK EROSION
BANK UNDERCUTTING AND COLLAPSE
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EXCESSIVE SEDIMENTATION ~ ,.~
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mean depth (ft) OF FINE PARTICULATES
3.5 max depth (ft)
28.6 wetted parimeter (ft)
2.0 hyd radi (ft) ~~..
12.7 width-depth ratio
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9.6 width (ft)
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TYPICAL LIVE STAKE
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io-roo, cexre•. srwccewe°wows ~ RIPARIAN TREES & SHRUBS ~
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LIVE STAKES ~+
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25-FEET FROM TOP OF BANK
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STREAM eeD - 25-FEET FROM OF BANK V m
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CROSS SECTION VIEW >
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NOTES:
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I. LIVE STAKES SHOULD BE PLANTED > LIVE STAKES Z
EVERY 2' IN STAGGERED ROWS )
• •

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eoor <ex.ee sreceewe° Wows 2. LIVE STAKES SMOUID BE DRIVEN
RIPARIAN TREES & SHRUBS WITH AT LEAST ~ OF TOTAL LENGTH
BELOW GROUND )
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3. SPLIT STAKES SHOULD NOT BE
USED )
> RIPARIAN TREES & SHRUBS a
m
• • • . • • . • • . • • •

4. LEAF BUDS SHOIl D POINT UPWARD
LIVE STAKES

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• • • • • • • • . • . • . 5. STAKES SHOULD RE INSTALLED

PERPENDICULAR TO STREAM BANK )

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• • • • • • • • • • • 6. RIPARIAN PLANTINGS SHOULD BE 1
TO 3-GALLON PLANTS PLACED ON ) j Z N
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10'KIO' CENTERS STAGGERED ROWS PLAN VIEW a ~ C°
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7. SPECIES COMPOSITION FOR m w = a
PLANTINGS SHOULD COME FROM NCEEP n Z a U_
PROFILE VIEW RIPARIAN BUFFER GUIDELINES

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BANKFULL x
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ON TOP OF TYPE I I n . ' `~ ~ ~ : ~ scouR root ~ Q
FILTER FABRIC ,I ~ \.~i.ow \ ;. ,
PROFILE VIEW: VANE ARM ~ f-
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ROCK SILL rE~.t ~ ~FLDw ~°~9`; ~"'y ~C~ ~ i
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SCOUR POOL ~' scoua root '~ -
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\ \ ROCK .. F... (~,~y a
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PLAN VIEW CROSS VANE ~ „
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CROSS SECTION
VIEW
o
w

0 7. 0 6 4 5
Photo 1: Old channel looking downstream
Photo 2: Old channel looking upstream

~T ~~s45
Photo 3: Old channel at cross section showing bank collapse and severe erosion
Photo 4: Old channel showing bank collapse and severe erosion

Photo 5: Restored channel looking upstream
Photo 6: Restored channel looking downstream

Photo 7: Restored channel at cross section location
Photo 8: Proposed cross vane location in middle left of view

Photo 9: Reference cross section location
Photo 10: Reference cross section location