20140356 Ver 1_WRC Comments_20140623

Burdette, Jennifer a
From:
Lynnette Batt [lbatt @uniqueplacesllc.com]
Sent:
Monday, June 23, 2014 12:38 PM
To:
Burdette, Jennifer a
Cc:
Cranford, Chuck; Fox, Tim; Kulz, Eric
Subject:
WRC comments on Pine Mt Mine permit
Attachments:
WRC comments 5.16.14.pdf
Hi Jennifer,
It was good to talk with you Friday. I spoke with Chuck as well. Attached are the comments from WRC. I'm Ic-
ing the group in case others haven't seen them.
Thanks,
Lynnette
unirlueplacesllc.com

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
May 16 "', 2014
Ms. Tasha Alexander
U.S. Army Corps of Engineers, Regulator- Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801 -5006
SUBJECT: WRC Comments on The Quartz Corp, USA — Pine Mountain Mine Individual Permit,
Stream Impacts, Mitchell County
Dear Ms. Alexander:
Representatives of The Quartz Corp (TQC), USA, Pine Mountain Mine requested a permit to impact
1,220 linear feet of streams, replace 60 linear feet of existing culvert, temporarily impact 80 linear feet of
streams, and impact 0.019 acres of Nvetlands at TQC's Pine Mountain Mine, Mitchell County, NC. The
stream relocation is requested in order to divert surface Nvater away from the M3 Mine Waste Dump area.
Comments from the NCWRC on this application are offered for your consideration under provisions of
the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and Fish and Wildlife Coordination Act (48 Stat.
401, as amended; 16 U.S.C. 661- 667d).
Little Bear Creek in the vicinity and dovmstream 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 tributaiv streams may, over time, reduce additional
sediment impacts in the Natershed. We do not object to the proposed project and request that all prudent
measures to reduce, or eliminate to the fullest extent practical, sediment from entering surface Nvaters as a
condition of this permit. We do not request the trout spawning moratorium for this project because Nvild
trout populations are no longer found doN- ,nstream of this project.
Four mitigation options have been offered for this project including a mitigation bank, North Carolina
Ecosystem Enhancement Program (EEP), on -site mitigation, and proposed off -site preservation in the
upper Beaver Creek watershed. Although mitigation banks, EEP credits, and on -site mitigation are
normally the range of mitigation options, Nve feel that consideration by USACE should be given to the
preservation proposal for the upper Beaver Creek Natershed. We feel that on -site mitigation Nvould be
extremely expensive and relatively insignificant given the totality of impacts at the Pine Mountain Mine.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

We feel that total mine reclamation at the time of mine closure is the best technical solution to those
impacts. We do feel strongly, however, that TQC should be held fully responsible for implementing
stringent erosion and sediment control strategies so that conditions with the Little Bear Creek watershed
do not continue to deteriorate.
Staff with the NCWRC sampled the Beaver Creek -,watershed in April 2014 at multiple locations and it
currently supports a population of wild rainbow trout. The headwaters are believed to be fishless
although further sampling is needed. The quality of the aquatic and terrestrial habitat within the
watershed is vein high with unique wetland and hydrologic communities and, in our opinion, represents a
unique opportunity- to mitigate for mine impacts by preserving vein 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.
Thank you for the opportunity to revie'kv and comment on this regulator- action. Please contact me at
(828) 659 -8684 ext. 221 if you have any questions about these comments or need further assistance.
Sincerely,
4, ��4
Doug Besler, Mountain Region Fisher- Supervisor
ec: Ms. Jennifer Robertson, Wetland and Natural Resources Consultants, Inc.
Ms. Lynette Batt, Unique Places
Mr. Chris Wood, NCWRC