20230657 Ver 1_More Info Received_20230705

Moore, Andrew W
From:
Greg Jennings <[e-mail]>
Sent:
Wednesday, July 5, 2023 8:23 AM
To:
Leslie, Andrea J
Cc:
Moore, Andrew W; David Brown; Zan Price
Subject:
[External] Re: Platt et al project - a few notes
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Thanks Andrea,
We will remove the riffle work as suggested.
Thank you, Greg
GREG JENNINGS, PhD PE
President I Jennings Environmental, PLLC
o: 919.600.4790
Asheville, NCI lenningsenv.com
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On Fri, Jun 30, 2023 at 2:08 PM Leslie, Andrea J <[e-mail]> wrote:
Hey Greg -
Good to talk with you today. I appreciate the modifications to the design that David has
noted below. The remaining point that hasn't been addressed is the work at approximately
4+00 to 6+00 (see my comments, attached). I don't see any reason to work in that section
of channel - there is good instream and edge habitat and there are only some small spots
of bank instability. I didn't spy tires except for a few in a pile within the channel itself (not
the bank). Take a look and let me know what you think.
Thank you,
Andrea
i

Andrea Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Commission
645 Fish Hatchery Rd., Building B
Marion, NC 28752
828-803-6054 (office)
828-400-4223 (cell)
www.ncwildlife.
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From: David Brown <[e-mail]>
Sent: Thursday, June 29, 2023 2:41 PM
To: Moore, Andrew W <[e-mail]>
Cc: Leslie, Andrea J <[e-mail]>; Zan Price <[e-mail]>; Greg Jennings
<[e-mail]>; Shannon Healy <[e-mail]>; Barker, Don - NRCS, Raleigh, NC
<[e-mail]>; Laura Fogo <laura [e-mail]>; Woody Platt <[e-mail]>
Subject: [External] Re: Request for Additional Information, Platt et al. East Fork French Broad River Restoration,
Transylvania County (DWR Project #20230657)
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Andrew,

The following is provided to address your June 20 request for additional information.
A previous property owner extensively used old tires to stabilize the left stream bank. An environmental impact
of the tires is they can become a source of chemical compounds and heavy metals which left in place could
degrade the soil and surface water at the site. Studies have shown that tires exposed to surface water can be
toxic to aquatic life. An objective of this project is to remove this potential source of contaminants. These tires
will be removed during the grading and benching of the left stream bank. The property owner has arranged for
the tires to be removed from the site and be disposed of properly. Further information can be found in the
following references:
• Abernethy, S.G., Montemayor, B.P., & Penders, J.V. 1996. The aquatic toxicity of scrap automobile
tires. Report ISBN 0-7778-4835-X. Aquatic Toxicology Section -Standards Development Branch,
Ontario Ministry of the Environment and Energy, Toronto.
• Cunningham, B., Harper, B., Brander, S., & Harper, S., 2022. Toxicity of micro and nano tire particles
and leachate for model freshwater organisms. Journal of Hazardous Materials, Volume 429, May
2022.
• Evans, J. J. 1997. Rubber Tire Leachates in the Aquatic Environment. Reviews of Environmental
Contamination and Toxicology. Volume 151, Pp 67-115.
• Lerner, A., Naugle, A., LaForest, J., & Loomis, W. 1993. Study of waste tire leachability in potential
disposal and usage environments. Amended Volume 1: Final Report. Department of Environmental
Engineering & Sciences. College of Engineering, University of Florida, Gainesville, Florida.
• Magni, S., et al. 2022. Ecological Impact of End -of -Life -Tire (ELT) -Derived Rubbers: Acute and
Chronic Effects at Organism and Population Levels. Toxics 2022, Vol. 10, Issue 5.
• Tatlisoz, N., Edil, T., Benson, C., Park, J., & Kim, J. 1996. Review of environmental suitability of scrap
tires. Environmental Geotechnics Report No: 96-7. Department of Civil and Environmental
Engineering. University of Wisconsin, Madison, Wisconsin.
2. It is noted that grading along the existing right stream bank from stations 3+00 to 13+42 will vary. Where the
bank is stable and well vegetated, the grading will be minimal. Heavier grading will be needed at outside bend
toe -wood locations, J-hook vane structures, and the benching/fill from stations 5+75 to 8+75.
3. The brush toe at station 12+00 and constructed native riffles at stations 10+00 and 13+00 have been removed
from the design (see attached revised plan set).
4. During field construction efforts will be made to preserve the large sycamores and pool on the left bank near
station 20+00.
5. Channel realignment from station 14+00 to 18+00 improves river conditions and functions in the following ways:

• By reducing the potential for soil erosion on the right side of the valley where the channel is currently
cutting into the hillslope;
• By establishing a floodplain bench on the right side of channel to support enhanced forested riparian buffer
and overbank floodwater storage;
• By restoring the natural meander pool morphology with a meander bend matching reference geometry for
this valley slope (radius of curvature ratio = 2.5).
• By increasing in -stream habitat values of natural riffles, pools, glides, and undercut banks.
If you have any questions or need to discuss this further, please contact me.
Thank you,
David
David Brown, PG
Sr. Scientist / Geologist I Jennings Environmental, PLLC
828 384 1890
david(a)Oenningsenv.com
Asheville, NC I jenningsenv.com
This information is confidential and is intended solely for use by the recipient and others authorized to receive it. Any disclosure, copying, distribution or taking
action in relation to this information is strictly prohibited and may be unlawful.
From: Moore, Andrew W <[e-mail]>
Date: Tuesday, June 20, 2023 at 10:26 AM
To: David Brown <[e-mail]>
Cc: Leslie, Andrea J <andrea.leslie@ncwildlife.o
Subject: Request for Additional Information, Platt et al. East Fork French Broad River Restoration,
Transylvania County (DWR Project #20230657)
David,
On May 4, 2023, the Division of Water Resources (Division) received your application requesting a 401 Water Quality
Certification from the Division for the subject project. The Division has determined that your application is incomplete
and cannot be processed. The application is on -hold until all of the following information is received:

On June 12, 2023, 1 visited the site with you and Andrea Leslie from the North Carolina Wildlife Resources
Commission (NCWRC). Based on observations made during that site visit, including good in -stream habitat, a
mature riparian buffer, and a lack of visibly eroding streambanks in much of the Phase I area, as well as the
presence of North Carolina species of special concern and North Carolina significantly rare species within the
project reach, the Division is concerned about the extensive in -stream work and removal of the mature buffer
in much of the Phase I reach. Please provide additional information that demonstrates that the proposed
impacts cannot be avoided or minimized in the following areas:
a. The Phase 1 areas noted in the NCWRC June 14, 2023 comment letter; and
b. The offline channel from approximate station 14+00 to 18+00. It's not clear why this new channel is
necessary and why the project objectives (stabilize stream banks, establish buffer, reconnect the
stream with the floodplain) cannot be met by adjusting the channel dimension in its current location.
Please further explain why the impact cannot be minimized in this location and why the new channel is
necessary to meet the project objectives.
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested information for the
proper consideration of the application. Please provide your response by July 20, 2023. If all of the requested
information is not received, the Division will be unable to approve the application and it will be denied as incomplete.
The denial of this project will necessitate reapplication to the Division for approval, including a complete application
package and appropriate fee.
Feel free to contact me if you have any questions.
Andrew W Moore, P.G.
Environmental Specialist ll, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone]
[e-mail]

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