Cheatham County, Tennessee

US Army Corps of Engineers ® Nashville District

ENVIRONMENTAL ASSESSMENT Land Disposal for Construction of A.O. Smith Levee Project, Cheatham Lake and Dam Project, Cheatham County, Tennessee

July 11, 2019

For Further Information Contact:

David Adams, Biologist U.S. Army Corps of Engineers Nashville District Project Planning Branch Telephone: (615) 736-7850 Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Table of Contents

1.0 PURPOSE AND NEED FOR ACTION ...... 1 1.1 Introduction and Authorization ...... 1 1.2 Purpose and Need ...... 1 2.0 ALTERNATIVES CONSIDERED...... 3 2.1 Alternative 1 - No Action ...... 3 2.2 Alternative 2 – Limited flood protection measures ...... 4 2.3 Alternative 3 - Construct a flood levee on AOS property ...... 4 2.4 Alternative 4 - Construct a wall to reduce flood risk to the AOS buildings and equipment ...... 4 2.5 Alternative 5 - Raise SR-455 (Tennessee Waltz Parkway) above the 100 year flood level between SR-49 and the AOS plant entrances ...... 5 2.6 Alternative 6 - Disposal of USAGE tracts E-514-1 , E- 514-2, E-518-1 , E-518-2, E- 519-1, E-537-1 and E-538 to AOS and construction of a flood levee ...... 5 2.7 Alternative 7 - Disposal of USAGE tracts E-514-1 , E- 514-2, E-518-1 , E-518-2, E- 519-1 , . E-537-1 and E-538 to AOS for construction of levee on three sides of the plant...... 6 2.8 Alternative 8 - Proceed with disposal of USAGE tracts E-514-1 , E- 514-2, E-518- 1, E-. 518-2, E-519-1 , E-537-1 and E-538 to AOS for construction of a flood levee (Preferred Alternative) …………………………………………………………………..7 2.9 Alternatives Evaluated in Detail in EA ...... 8 3.0 AFFECTED ENVIRONMENT & ENVIRONMENTAL CONSEQUENCES ...... 9 3.1 Introduction ...... 9 3.2 Physiography and Topography ...... 10 3.3 Aquatic Resources (Streams) ...... 13 3.4 Water Quality ...... 16 3.5 Wetlands ...... 17 3.6 Floodplain ...... 19 3.7 Terrestrial Resources ...... 21 3.7.1 Soils ...... 21 3.7.2 Vegetation ...... 22

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

3.7.3 Wildlife ...... 23 3.8 Archeological and Historic Resources ...... 24 3.9 Threatened and Endangered Species ...... 24 3.10 Hazardous, Toxic, and Radioactive Waste (HTRW)...... 25 3.11 Health and Safety ...... 26 3.12 Recreation and Scenic Resources ...... 26 3.13 Socioeconomics ...... 27 3.14 Air Quality ...... 28 3.15 Navigation ...... 29 4.0 CUMULATIVE IMPACTS ...... 29 4.1 Past and Present Actions ...... 29 4.2 Reasonably Foreseeable Future Actions ...... 29 4.3 Combined Cumulative Effects ...... 30 5.0 ENVIRONMENTAL COMMITMENTS, PERMITS, AND APPROVALS ...... 30 6.0 ENVIRONMENTAL COMPLIANCE ...... 31 6.1 Executive Order 11990-Wetlands ...... 31 6.2 Farmland Policy Protection Act ...... 31 6.3 Executive Order 11988-Floodplain Management ...... 31 6.4 Clean Water Act ...... 31 6.5 Endangered Species Act ...... 32 6.6 Fish and Wildlife Coordination Act...... 32 6.7 National Historic Preservation Act ...... 32 6.8 Executive Order 13514 – Environmental Justice ...... 33 6.9 Clean Air Act ...... 33 6.10 Comprehensive Environmental Response, Compensation, and Liability Act ... 33 6.11 Resource Conservation and Recovery Act ...... 33 6.12 Executive Order 13653 (Preparing the United States for the Impacts of Climate Change ...... 34 7.0 PUBLIC AND AGENCY COORDINATION ...... 34 7.1 Public and Agency Involvement ...... 34 7.1.1 Scoping Process ...... 34

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

8.0 CONCLUSION ...... 35 REFERENCES ...... 36 LIST OF PREPARERS ...... 38

Figures Figure 1. General Vicinity Map ...... 2 Figure 2. Location Map of AOS Project Area and USACE Real Estate Tracts ...... 3 Figure 3. Conceptual Levee Footprint ...... 9 Figure 4. Ecoregions Surrounding Cheatham Lake ...... 11 Figure 5. NLCD Land Use in the Cheatham Lake Watershed ...... 12 Figure 6. Streams in the Project Area ...... 15 Figure 7. Wetlands in the Project Area ...... 18 Figure 8. Floodplain Map ...... 20 Figure 9. USDA Soils Map of Proposed Project Area ...... 22

Tables Table 1. Land Uses in Cheatham Lake Watershed ...... 13 Table 2. Stream Impacts ...... 15 Table 3. Wetland Impacts ...... 19 Table 4. Map Legend for USDA Soils Map ...... 21 Table 5. Population Statistics for Cheatham County & Tennessee ...... 27 Table 6. Industry Statistics for Cheatham County & Tennessee ...... 27

APPENDIX A- Project Scoping and Comments

APPENDIX B- Cultural Resources and the National Historic Preservation Act

APPENDIX C- Project Plans

iii

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

1.0 PURPOSE AND NEED FOR ACTION The U.S. Army Corps of Engineers, Nashville District (USACE) is evaluating the impacts of a proposed land disposal needed to construct a flood risk reduction levee at the A.O. Smith (AOS) Plant, Ashland City, Cheatham County, Tennessee.

1.1 Introduction and Authorization

Cheatham Lock and Dam was authorized by the River and Harbor Act approved 24 July 1946 (House Document No. 761, 79th Congress, 2nd Session) to provide a navigable river channel on the Cumberland River. The project is part of a comprehensive plan for the development of the Cumberland River and its tributaries in Kentucky and Tennessee. Additional authorization on 19 June 1952 (Public Law 396, 82nd Congress, 2nd Session) provided for the production of hydroelectric power as a project function. The Federal Water Project Recreation Act of 1965 (PL 89-72) established development of the recreational potential of Federal water resource projects as a full project purpose. Other authorized project purposes include fish and wildlife management and water quality. During droughts, consideration is given to water supply pipe intakes.

This Environmental Assessment (EA) is being conducted under Operation and Maintenance authority for Cheatham Lake, which was authorized by the River and Harbor Act of July 24, 1946 (Public Law 396, 82nd Congress, 2nd Session). This EA is being prepared pursuant to the National Environmental Policy Act (NEPA), Council for Environmental Quality (CEQ) regulations (40 CFR 1500-1508), and the USACE Regulation ER 200-2-2, titled Policies and Procedures for Implementing NEPA. The real estate tracts E-514-1, E- 514-2, E-518-1, E-518-2, E-519-1, E-537-1 and E-538 would be conveyed in accordance with section 1331(a) of the Water Resources Development Act of 2018.

In addition to the EA, the USACE’s Regulatory Division is separately evaluating the proposed project and discharges of fill material into waters of the United States which requires a Department of the Army (DA) permit pursuant to Section 404 of the Clean Water Act (CWA) (33 U.S.C. 1344).

1.2 Purpose and Need

AOS is the largest employer in Cheatham County (NACC, 2019). The Ashland City Plant has experienced multiple flood events in the past, and AOS wishes to construct a levee to manage risk from future flood events. The land acquisition policy for Cheatham Lake was conservative in nature and limited land acquisition to an ascending line commencing on the 390 contour at the dam and extending to the Cheatham-Davidson county line. This limited acquisition created an irregular USACE property line with finger-like projections at the project area. Upon initial construction of the AOS Plant,

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake portions of the facility were inadvertently built on USACE property. A land disposal from USACE would also be needed for sufficient contiguous property for the construction of a flood levee.

A vicinity and location map is included for project orientation and location (Figures 1 and 2). The proposed project consists of disposal of seven tracts of USACE land totaling approximately 9.19 acres and will address both the initial encroachment of current facilities and the disposal of additional lands for the levee project.

Figure 1. General Vicinity Map

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

C] Tracts ---- Govemment Boundary Line

- Encumbered Area (3.11 ac) Approx. Aro.i Raquostod f« Lovec Construction (6.08 ac}

Figure 2. Location Map of AOS Project Area and USACE Real Estate Tracts

2.0 ALTERNATIVES CONSIDERED A No Action Alternative and several versions of a levee/flood wall were considered during initial project planning by AOS and this information was considered by USACE.

2.1 Alternative 1- No Action

Under the No Action alternative, disposal of the tracts of land by USACE to AOS and flood levee construction would not occur. This option would result in no impacts to aquatic resources and would not result in other environmental concerns such as siltation. The No Action Alternative would not require any mitigation for wetland and

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake stream impacts. Although this alternative would result in no environmental impacts, it would not offer any flood risk reduction for AOS and nearby facilities.

2.2 Alternative 2 – Limited flood protection measures

AOS first evaluated limiting flood protection measures to “flood proofing” manufacturing buildings. The initial approach was to evaluate the feasibility of removing 4 feet of the metal building walls above slabs and replacing them with concrete walls sealed to the existing foundation. Under this approach, stackable planks would have been used to seal all building openings when a flood event occurred. Engineering analysis determined the interior slabs would implode during a flood event due to hydraulic pressure as part of the flood management system. Additionally, the problem of access to the plant during flood events would not be resolved with this approach. Ingress and egress routes would still be blocked during flooding. This approach was not carried forward for consideration.

2.3 Alternative 3- Construct a flood levee on AOS property

Engineers from AOS evaluated constructing a flood protection wall or berm completely around the facility and entirely on AOS lands. Geotechnical exploration (drilling) was performed in 2012 to quantify the seepage rate and bearing capacity of underlying soils for structural design of a wall or berm. Depth of wall foundations and limit of required undercut of earth for a berm were determined from the results. Based on this data, costs were developed for both wall and earthen berm options, which indicated that while a wall was much more expensive than a berm, it required a smaller footprint. Using this data, engineers then estimated project costs for a combination of wall and berm to be built entirely on AOS property. The wall would have been constructed where space was limited and an earthen berm used where possible to help control costs. Analysis was performed for both 100-year and 500-year flood events and conceptual designs were prepared. It was determined that while the conceptual plan protected the asset, it did not allow for access to the facility for production to continue during a flood event since all entrance roadways would be under water. Additionally, the required roadway ramps over the berm into and out of the plant site took critical parking and product storage area out of use. This alternative was eliminated from consideration.

2.4 Alternative 4- Construct a wall to reduce flood risk to the AOS buildings and equipment

The fourth alternative considered was to provide 100-year flood risk management to the press building, which is the lowest building on the site and the only building below the 100-year flood level. Under this approach, an I-wall would have been installed around

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake the press building with stackable flood planks used to seal the openings required for normal operation. This alternative would only provide 100-year flood risk management for the facility with no access for production during a flood. After detailed analysis, it was determined that the level of management provided was not sufficient to allow the AOS corporate management team to confidently invest in future plant expansions since the facility would remain at risk of severe damage resulting from any flood over the 100- year level such as the catastrophic event which occurred in 2010. Therefore, Alternative 4 was eliminated from further consideration.

2.5 Alternative 5- Raise SR-455 (Tennessee Waltz Parkway) above the 100 year flood level between SR-49 and the AOS plant entrances

The fifth alternative considered was to raise the elevation of Tennessee Waltz Parkway with earthen fill, construct a combination of I-wall and earthen berm along Puzzlefool Creek between Tennessee Waltz Parkway and the Railroad. This would reduce flood risk to the plant and provide access to and from the plant during flood events so that production would not be interrupted unless loss of power occurred. The loss of power is a possibility since this alternative would not protect the Cumberland Electric Membership Corporation (CEMC) electrical substation. Under this alternative, earthen fill would be placed along the east slope of the railroad embankment to seal it and allow it to function as a flood levee. The Tennessee Department of Transportation (TDOT) rejected this alternative due to risks associated with having a roadway on top of a flood management structure. With rejection from TDOT, this alternative was not carried forward for consideration.

2.6 Alternative 6- Disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E-518-2, E- 519-1, E-537-1 and E-538 to AOS and construction of a flood levee

Under this alternative, an earthen levee would be built surrounding the entire AOS facility except for a small portion on the north side of the plant between Tennessee Waltz Parkway and the Railroad. This smaller portion would consist of a concrete wall due to space limitations. The earthen levee would be built on the west and south sides of Tennessee Waltz Parkway reducing risk to the roadway access during flood events, the CEMC substation on the south side of the plant, and the Ashland City Wastewater Treatment Plant (WWTP). TDOT would modify the section of Tennessee Waltz Parkway between Highway 49 and the plant entrance to pass over the levee. A large borrow area would be built on City property to supply needed material for levee construction eliminating the need for trucking material from offsite. The borrow area would be constructed in a manner to allow it to be converted to a fishing lake for a future park planned by the City once levee construction was complete.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Ingress and egress would be maintained during flood events, and electrical and sewer service would also be protected. However, the concerns remained relative to the necessity to divert the flow from eastern tributaries north to Puzzlefool Creek, impact on neighboring properties, and encroachment upon ball fields and school property to the east.

AOS contracted Civil & Environmental Consultants, Inc. (CEC) to evaluate and refine the preliminary design and to perform flood studies to determine what the effect of diverting flows from the east, north to Puzzlefool Creek would be upon neighboring properties. CEC was also tasked with performing wetland and stream determinations at the site so that resource impacts could be determined. During this analysis, CEC discovered that the topography on the east side of the plant presented a severe impediment to the conceptual design. There was so little elevation drop between the point where the eastern drainages would have to be intercepted to direct them north to Puzzlefool Creek and the creek discharge point that any channel would have to be much wider than previously envisioned and would encroach much more onto adjacent school properties than previously believed. Additionally, its design would most likely have to consist of a concrete bottomed, trapezoidal ditch that would significantly increase required stream mitigation expense assuming permits for such a structure could be obtained.

Based on this new information, AOS determined the impacts to adjacent property were too significant to proceed with Alternative 6 as initially envisioned and CEC was requested to evaluate potential design modifications. Higher ground to the south completely prevented any consideration of diverting flow in that direction. Constructing a new combined culvert for all stream storm flows under the plant with its inlet and outlet set outside the flood levee perimeter proved feasible based on modeling but extremely expensive not only from a construction standpoint but also due to lost production time at the facility while construction was underway. Additionally, it was considered very likely that removing streams from their existing culverts and placing them into a single new culvert would result in thousands of feet of additional stream mitigation requirements. Based on these cost prohibitive developments, Alternative 6 was dropped from further consideration.

2.7 Alternative 7- Disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E-518-2, E- 519-1, E-537-1 and E-538 to AOS for construction of levee on three sides of the plant

Under Alternative 7, the levee would surround three sides of the plant with the east side left open and all drainages currently flowing from the east would be allowed to continue to do so following their existing routes. Modeling performed in association with

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Alternative 6 had conclusively shown that flood flows in these drainages would peak long before the Cumberland River. This fact would allow the levee system to be designed such that flood flows from the eastern drainages could be allowed to flow through open gates in the earthen levee on the west side of the plant. As the flow in the smaller tributaries diminished and the Cumberland River began to rise, gates in the levee would be closed protecting the plant from flood flows from the Cumberland River. Eastern tributary waters would be pumped over the levee while gates were closed.

Alternative 7 had significant advantages over other alternatives considered up to that point. Flow to downstream wetlands would be maintained addressing earlier concerns relative to the potential for altering wetland hydrology by diverting tributary flow North to Puzzlefool Creek. Flood modeling confirmed the design would result in a no-rise situation for that portion of Puzzlefool Creek upstream of Tennessee Waltz Parkway and for the Cumberland River and thus neighboring properties would not be impacted. Wetland and stream impacts were reduced to an estimated 1,760 feet of stream encapsulation and impoundment and 4.05 acres of wetland fill due to elimination of portions of the flood control structure previously proposed east of the plant and a change to 2.5:1 levee side slopes over the originally proposed 3:1. However, due to a lack of adequate stream mitigation, this alternative was not carried forward for consideration.

2.8 Alternative 8- Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518- 1, E-518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee (Preferred Alternative)

Under Alternative 8, all facets of Alternative 7 would remain the same except for elimination of impact to Streams 10 and 11 and the earthen levee and culvert crossing at Stream 9. This section of the earthen levee would be replaced with a concrete floodwall, significantly reducing stream and wetland impacts. The levee would encompass the Ashland City WWTP to the north and the CEMC electrical substation to the south (Figure 3). Under this alternative, an earthen levee would cross Streams 3 and 4, and culverts in the levee at each of these crossing locations would result in encapsulation of 130 feet of Stream 3 and 138 feet of Stream 4. The earthen levee would be replaced with a concrete floodwall at the Stream 9 crossing resulting in encapsulation impacts of about 2.5 feet. Total encapsulation impacts would be 270.5 feet. Stream 8 would be placed in a new channel of the same length mimicking its existing pattern and profile and redirected to a confluence with Steam 9 upstream of the floodwall. A concrete floodwall would also be constructed within the portion of the levee extending along the north side of the plant between Puzzlefool Creek and the WWTP resulting in no impact to Puzzlefool Creek as a result of the levee. Wetland fill resulting from the project would be 3.67 acres.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

With the Preferred Alternative, the proposed structure would consist of a combination of earthen levee and concrete floodwalls. The earthen portion of the levee would be about 5,850 feet in length and range from 75-150 feet in width and from 13-27 feet in height. Side slopes would be 2.5:1. Concrete floodwalls would make up about 1,200 feet of the structure’s length and would range in height between 8 and 25 feet. Average thickness of the wall would be 18 inches with the portion of wall at the Stream 9 crossing potentially being up to 30 inches in width pending the completion of design. On the south side, the levee would tie into existing grade above the 500-year flood level at Tennessee Waltz Parkway west of the railroad. On the north side, the wall would cross the railroad tracks and tie into natural grade to the east. 2.9 Alternatives Evaluated in Detail in EA

After a consideration of the alternative actions, only the No Action Alternative and Alternative 8 (Preferred Alternative) were carried forward throughout this EA as a basis of comparison for potential impacts. The Preferred Alternative provided flood risk reduction while reducing wetland and stream impacts and associated mitigation costs as much as possible. Alternatives eliminated from detailed discussion in the EA were because of either the functionality during floods, impacts to AOS operations, including ingress and egress and storage/parking area, greater stream mitigation costs, or the degree of flood risk reduction provided in comparison to Alternative 8. Therefore only the No Action and the Preferred Alternative are carried forward.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Figure 3. Conceptual Levee Footprint

3.0 AFFECTED ENVIRONMENT & ENVIRONMENTAL CONSEQUENCES 3.1 Introduction

The proposed project area is located adjacent to Cumberland River Mile 185.4R, Cheatham Lake, Ashland City, Cheatham County, Tennessee (Latitude 36.266621°, Longitude - 87.067433°). It lies on the southwest side of Ashland City, south of Cumberland Street/SR-49 and mainly west of Tennessee Waltz Parkway. Portions of

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake the proposed project area are currently developed by AOS to include buildings, parking area, and storage yards. Some of the land is forested or in scrub/shrub thickets. Small drainages and low wetland areas are scattered across the project area.

The climate of the Cheatham Lake area is moderate. Temperatures range from typical summer highs (July and August) of 89°F to winter lows of 27°F in January (U.S. Climate Data, 2017). The average growing season is approximately 225 days, extending from April to October. Annual rainfall for the basin averages 48 inches (Tennessee Climatological Service, 2015). Relative humidity for the area ranges from 47% to 90% with a 69% average across the year (National Weather Service, 2017). 3.2 Physiography and Topography The Cheatham Lake watershed boundary lies within two Level IV ecoregions of the Interior Plateau as defined by the Environmental Protection Agency: the Western Highland Rim (71f) and Outer Nashville Basin (71h). The project area lies within the Western Highland Rim (Figure 4). The Western Highland Rim is characterized by dissected, rolling terrain of open hills with elevations of 400-1000 feet (EPA, 2015). The geologic base of Mississippian-age limestone, chert and shale is covered by soils that tend to be cherty and acidic with low to moderate fertility. Streams are relatively clear with a moderate gradient. Substrates are coarse chert, gravel and sand with areas of bedrock. The native oak-hickory forests were removed over broad areas in the mid-to late 1800's in conjunction with the iron-ore related mining and smelting of the mineral limonite, however today the region is again heavily forested. Some agriculture occurs on the flatter interfluves and in the stream and river valleys.

According to National Land Coverage Data (NLCD) in 2016, the majority of the Cheatham Lake watershed has a mixture of land coverages, mainly comprised of forest, cattle pasture/hay fields, and residential/commercial development (Figure 5). Table 1 shows the breakdown of land coverage types within the Cheatham Lake watershed. This breakdown includes the much urbanized areas of Davidson and Williamson Counties.

Cheatham Lake contains 320 shoreline miles. Most of the shoreline area of Cheatham Lake is relatively flat, having slopes of 12 percent or less. This is particularly true in the upper reaches of Cheatham Lake. The slope in the lower reaches, the reservoir area, though relatively flat along the shoreline, varies from slight (0 to 12 percent slope) as one gets away from the shoreline area. There are, however, areas along the shoreline, characterized by moderate to steep wooded slopes.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

t Vie

Kingston 1

71i Ecoregions Surrounding Cheatham Lake Ecoregion 71 -Interior Plateau D 71e Western Pennyroyal Karst Plain -- D 71f Western Highland Rim D 71h Outer Nashville Basin D 71i Inner Nashville Basin

Figure 4. Ecoregions Surrounding Cheatham Lake (EPA, 2015)

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

D Cheatham Lake Watershed NLCD_Land

- Emergent Herbaceuous Wetlands D Developed, Open Space - Developed, Medium Intensity H - Developed, Lo w Intensity - Developed, High Intensity - Deciduous Forest

- Cultivated Crops

- Barren Land I Figure 5. NLCD Land Use in the Cheatham Lake Watershed

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Table 1. Land Uses in Cheatham Lake Watershed Cheatham Lake (acres) Percent Total

Open Water 5,507 1.33%

Developed, Open Space 60,978 14.73%

Developed, Low Intensity 39,374 9.51%

Developed, Medium Intensity 18,577 4.49%

Developed, High Intensity 10,500 2.54%

Barren Land 620 0.15%

Deciduous Forest 172,130 41.58%

Evergreen Forest 6,193 1.50%

Mixed Forest 34,596 8.36%

Scrub/Shrub 1,104 0.27%

Grassland/Herbaceous 2,312 0.56%

Pasture/Hay 54,229 13.10%

Cultivated Crops 5,587 1.35%

Woody Wetlands 1,223 0.30%

Emergent Herbaceous Wetlands 1,034 0.25%

Total Acres 413,962 100%

3.3 Aquatic Resources (Streams)

The current project area contains eight (8) perennial streams, three (3) intermittent streams, and two (2) ephemeral streams totaling approximately 8,157 linear feet (Figure 6). There is 1,768 linear feet of streams currently encapsulated. All the features documented are hydrologically connected to the Cumberland River to the west. Historically, streams 3 and 4 were impacted during the construction of the AOS facility in the early 1960’s by being placed in culverts that are located below the AOS facility. Stream 7 was impacted with the placement of a crossing along Tennessee Waltz Parkway, a closed access road crossing from Highway 49, and an existing bridge constructed for access to the Ashland City WWTP. See Section 3.5 for discussion regarding wetlands.

Alternative 1 (No Action Alternative): The No Action alternative would have no effect to aquatic resources within the proposed project area. 13

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): Navigable waters, their tributaries and adjacent wetlands are waters of the U.S. subject to the provisions of Section 404 of the Clean Water Act (Section 404). For purposes of Section 404, the lateral limits of jurisdiction over non-tidal water bodies extend to the ordinary high water mark in the absence of adjacent wetlands. USACE defines the term “ordinary high water mark” for purposes of the CWA lateral jurisdiction at 33 CFR 328.3(e). For managed reservoirs such as Cheatham Lake, normal summer pool is considered the ordinary high water mark. AOS submitted a project application indicating the project would result in the impact of approximately 294.5 linear feet of stream channel. Of the impacted streams, 270.5 linear feet would be encapsulated and 24 feet would be relocated (Table 2).

Streams 3 and 4 currently flow through culverts under the AOS facility and streams 8 and 9 begin at the western toe of Tennessee Waltz Parkway on the west side of the facility. These streams would be crossed by the levee. Streams 3 and 4 would pass through gated culverts in the earthen portion of the levee. A new channel (Stream 8) would be constructed relocating flow to Stream 9 upstream of the concrete levee wall and then the combined Stream 8/9 base flow would likewise pass through a gate in the concrete floodwall.

The project was designed to maintain channel lengths and employ natural channel design techniques for the channel relocation (i.e., Stream 8 tying to Stream 9). The combined flows would pass through the levee at a single gate and rejoin the existing stream channel downstream. Other minimization measures include reducing the levee footprint at crossing points by installation of an open channel through the levee rather than encapsulation. Other measures would be employed including installation of erosion control measures, revegetation and stabilization of disturbed areas, and other best management practices (BMPs) as necessary.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

P. STR-4 t ·•· ,f -y . I 'i-.. ~. ~- P. STR-3 -:-i (

□ Areao Elfec Pere-nniaf Stream P. STR-11 lntermitt·ent Stream Encapsulated I. STR-11 Stream Ephemeral Stream P. STR-10 REFERENCE TOOT AERIAL IMAGERY 00 TOARCGIS ON 'lNMAP.TN.OOWBASEMAPS/IMAGERY ACCESSED lll23.i2017 Figure 6. Streams in the Project Area

Table 2. Stream Impacts ID Feet Acres Impact Type STR-3 130 0.01 Encapsulation STR-4 138 0.02 Encapsulation STR-8 24 0.002 Relocation STR-9 2.5 0.00005 Encapsulation

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

The applicant proposed mitigation for the stream impacts by onsite, permittee responsible measures. Streams 3 and 4 (proposed encapsulation) are characterized as Cumberland River backwater/open water slough (lentic) areas. The total area of lentic habitat to be impacted is 0.03 acre (total of 268 linear feet). For these impacts, the applicant proposes onsite, in-kind lentic mitigation by the creation of a 7.81- acre (fishing) lake. It would be constructed at the site of the soil borrow area post-excavation with a variety of depths, substrates, and habitats for fish, reptiles, amphibians, and benthic macroinvertebrates. For stream mitigation of impacts to Streams 8 and 9, total of 26.5 linear feet, the applicant proposes to relocate 24 linear feet of STR-8, remove two existing bridges and provide restoration activities including bank stabilization on approximately 100 linear feet of Stream 7 (Puzzelfool Creek).

3.4 Water Quality

Unregulated, local tributaries, many of which drain highly developed areas, influence water quality of Cheatham Lake but their total inputs are usually small relative to the main stem Cumberland River. Water quality in Cheatham Lake is closely tied to the flow regime which is governed by dam releases at Old Hickory Reservoir and J. Percy Priest Reservoir. In turn, the quality of these upstream releases is determined by factors such as nutrient enrichment, hydraulic retention time, and effects of temperature stratification.

Local inflows contribute pollutants in varying quantity to the pool. Approximately 994 acres of Cheatham Lake, the reach between Bordeaux Bridge and Woodland Street Bridge, within Davidson County, is listed under the 2014 Tennessee Department of Environment and Conservation (TDEC) 303 (d) list for E. Coli impairment from discharges from municipal separate storm sewer systems (MS4s) and combined sewer overflows (TDEC, 2014b). However no fish consumption advisories are posted for the Cumberland River/Cheatham pool or any of its tributaries. In addition, no significant contaminants in reservoir bottom sediments have been observed in Cheatham sample collections since routine USACE monitoring began in 1999. There are approximately 58 reaches of impaired streams, totaling 246.4 miles, within the Cheatham Lake watershed. The most common impairments are E. coli, sedimentation, alteration of streamside or littoral zone, and other anthropogenic habitat alterations. Major pollutant sources include discharges from municipal separate storm sewer systems (MS4s), urbanized high density areas, and land development (TDEC, 2014b).

Alternative 1 (No Action Alternative): This alternative would have no direct effect on water quality within the proposed project area. No construction disturbances would occur.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): The project would have permanent, minor adverse impacts to water quality within the proposed project area due to the encapsulation and relocation of streams and loss of wetlands described in Sections 3.3 and 3.5. These impacts could limit flood attenuation and cause increased turbidity. Also, construction within the project area would produce short-term, localized turbidity in streams, but with the implementation of BMPs, there would be little effect to the reservoir. All construction activities would be required to be in accordance with all federal, state and local laws.

3.5 Wetlands

The project area consists of 13.04 acres of existing wetlands onsite (Figure 7). The primary contributing factor to the wetland hydrology currently present at the site is a natural groundwater connection to an elevated water table and backwater from the Cumberland River. High rainfall events cause water levels to rise and backwater floods the surrounding wetlands. Open water wetland (POW) areas occupy approximately 23% of the current wetland composition and are permanently inundated by Cumberland River backwater. Bottomland hardwood forests (PFO), scrub-shrub (PSS), and emergent wetland (PEM) areas are seasonally and intermittently inundated and saturated in various areas.

Alternative 1 (No Action Alternative): The No Action Alternative would have no effect on wetlands.

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): Approval of the project would result in the permanent fill of 3.67 acres of wetlands (Table 3). Additional temporary wetland impacts totaling up to 2.68 acres may occur during construction, but these areas would be restored to their original contours immediately after construction.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Areao CJ Etl'ec Palustrine - OpenWate<'S Palustrine Open Waters D (O\Jlside JD Boondary) - Wedand

Isolated Pond

REFERENCE TOOT AERIAL IMAGERY GO TOARCGIS ON AAP.TN..GOVIBASEMAPSIIMAGERY ACCESSED 6.'23/20 17 Figure 7. Wetlands in the Project Area

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Table 3. Wetland Impacts ID Acres Impact Type Wetland Type WTL-1 0.41 Permanent Fill PEM WTL-2 0.08 Permanent Fill PFO WTL-3 0.01 Permanent Fill PSS WTL-9 1.35 Permanent Fill PFO WTL-11 1.78 Permanent Fill PFO WTL-12 0.04 Permanent Fill PFO Total 3.67 Permanent Fill

3.6 Floodplain

Portions of the AOS facility, as well as a waste water treatment plant and electrical substation, are located in the 100-year floodplain (Figure 8). Fill activities that reduce the lake’s flowage easement capacity are of concern and must be offset by excavation at a corresponding elevation.

Alternative 1 (No Action Alternative): The No Action Alternative would have no effect on the floodplain.

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): The land disposal would facilitate the construction of the flood levee around the AOS facility and two other structures. USACE would retain a flowage easement on the disposed land in order to ensure the Cheatham Dam and Reservoir project could continue to fulfill its authorized purposes of providing the Nation with navigation and hydropower. Therefore, the AOS planned levee facility would be subject to the Nashville District’s 2002 policy regulating the placement of fill within its reservoirs. Such fill is generally prohibited but exceptions can be made under certain circumstances, one being when excavation is done to offset the storage lost. This excavation shall be done in a manner and location so as to fully offset the volume of reservoir storage lost. The material needed for the levee facility would be obtained from a borrow site riverward of the levee which would be at or below the elevation of the fill to be placed. Although the lower portion of this borrow site would maintain a constant pool of water, a portion above this pool is being designed to connect to the Cumberland River such that it replaces the storage lost below the top of flowage easement due to construction of the levee. Specific quantities are not available at this time but will be added once provided by the

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake levee design team. Local storm water ordinances reflect FEMA minimum standards which restrict fill in a Zone AE floodplain to that which will cause no more than a one foot increase in the 100-year flood. The portion of the Zone AE floodplain where fill isn’t allowed unless additional conditions are met is designated as a floodway. The proposed project lies nearly entirely within the Zone AE floodplain but outside of the floodway.

SPECIAi. Fl.000 I HAZARD AR£AS ©- - - TlaMeCI _.,_ 8Hd flcad D<\ellclol U..•(Bffl -...ct Floadtlop Bouocb,y --- lll"11CIS4..,., 0,2, M•oalCliil..,.AoooHUlrO.Ar .. __ ,.1154....,,11oomary ~om• bit cf 1" IMuM Cbanct flOOd wfUt 41"61. t !IO ce

Figure 8. Floodplain Map (FEMA, 2019)

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

3.7 Terrestrial Resources

3.7.1 Soils The soils present at the proposed project area have been mapped using the United State Department of Agriculture (USDA) website, https://websoilsurvey.nrcs.usda.gov. Figure 9 below is the soils map taken from that website. The seven (7) soil types present in the soils map are listed in Table 4. According to the USDA mapping, the proposed project area is primarily underlain by Beason Silty Clay Loam (Be) and Wolfever Silty Clay Loam (WfA).

Neither alternative would affect soils or geology.

Table 4. Map Legend for USDA Soils Map Percent of Map Unit Symbol Map Unit Name Acres Area Arrington silt loam, 0 to 2 percent slopes, ArA 1.4 0.8% occasionally flooded

Be Beason silty clay loam, occasionally flooded 79.6 44.2%

Byler silt loam, 2 to 5 percent slopes, ByB2 0.9 0.5% eroded Ennis gravelly silt loam, occasionally En 0.9 0.5% flooded Hawthorne gravelly silt loam, 5 to 12 HaC 2.2 1.2% percent slopes

TrC2 Tarklin gravelly silt loam, 5 to 12 percent 0.2 0.1% slopes, eroded

Wolftever silty clay loam, 0 to 2 percent WfA 94.8 52.7% slopes, occasionally flooded

Totals 179.9 100%

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Figure 9. USDA Soils Map of Proposed Project Area

3.7.2 Vegetation The proposed project area is between the Tennessee Waltz Parkway and the Cumberland River. The adjacent lands are a mixture of agricultural fields, scrub/shrub thickets, early successional forest, and residential/commercial properties. Most of the land within the project area has been previously disturbed. Plant communities found in the area are characteristic of communities formed over limestone and siltstone. The western portion of the area is most heavily forested. The forested plant community includes hackberry (Celtis occidentalis), green ash (Fraxinus pennsylvanica), box elder (Acer negundo), black willow (Salix nigra), sycamore (Platanus occidentalis), eastern red cedar (Juniperus virginiana), American elm (Ulmus Americana), and cottonwood

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

(Populus deltoids). The upland field plant community includes little bluestem (Schizachyrium scoparium), winged elm (Ulmus alata), and broom sedge (Andropogon virginicus).

Alternative 1 (No Action Alternative): The No Action Alternative would have no impact on the existing vegetation within the proposed project area since no project would be implemented.

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): Approval of the proposed action would have minor, permanent impacts to vegetation through the construction of a flood control levee. Soil used to construct the berm would be obtained from the adjacent AOS properties to the west and from Ashland City property to the southwest of the facility. In coordination with the local government agencies, AOS would borrow soil from 7.81-acres of Ashland City property to the southwest of the project area. The soil would be excavated to an average depth of 20 feet below ground surface. The excavated soil would be used in the construction of the levee. Borrow pits on AOS property would be converted to wetlands. Deciduous, woody vegetation would be permanently cleared, especially in the western portion of the project area. Based on correspondence between USACE and USFWS, implementation of the project would result in the clearing of approximately 17 acres of suitable summer habitat for the Indiana bat (Myotis sodalis) and the Northern long-eared bat (Myotis septentrionalis). Correspondence regarding the removal of habitat for forest-dwelling bats is further described in Section 3.8 (Threatened & Endangered Species).

3.7.3 Wildlife An extensive list of species occurring on project lands can be found in the vicinity of Cheatham Lake. Major game mammals found in the project area include: white-tailed deer (Odocoileus virginianus), opossum (Didelphis virginiana), raccoon (Procyon lotor), muskrat (Ondatra zibethicus), eastern gray squirrel (Sciurus carolinensis), fox squirrel (Sciurus niger), and eastern cottontail rabbit (Sylvilagus floridanus). The major game birds in the area include the bobwhite quail (Colinus virginianus), mourning dove (Zenaida macroura), Canada goose (Branta canadensis), wood duck (Branta canadensis), and mallard duck (Anas platyrhynchos). Cheatham Lake also provides a suitable environment for a variety of reptiles, amphibians, and non-game mammals and birds.

Alternative 1 (No Action Alternative): This alternative would have no effect on aquatic wildlife in waters of the U.S. or terrestrial species in the upland areas within the project corridor.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): The project would have a minor, permanent detrimental effect to wildlife. Approximately 17 acres of forested habitat loss would occur as described in Section 3.6.1. The levee would be maintained as grass, without the presence of trees.

3.8 Archeological and Historic Resources

The Cumberland River has served as a transportation corridor for at least 12,000 years. The continued occupation of the area from the Paleoindian period (c. 12,000 – 10,000 years ago) through the pre-contact (10,000 years ago to c. A.D. 1650) and historic periods (c. A.D. 1650 – present) creates dense concentration of archaeological resources. USACE records over 200 sites on the land immediately surrounding Cheatham Lake. It is common for pre-contact and historic sites to be present along the Cumberland River. In some cases, sites are buried deep, below centuries of alluvial deposition.

Cultural resource inventories of the proposed project area and immediate surroundings identified two archaeological sites (CEC 2016, 2017b, 2017c, 2019; DWE 2018). The proposed plans avoid impacts to an archaeological site that is eligible for listing in the National Register of Historic Places. The second archaeological site is a small lithic scatter that lacks contextual information that would provide information about the past. No historic buildings or structures are present in the proposed project area nor immediate viewshed.

Alternative 1 (No Action Alternative): This alternative would have no effect on significant archaeological sites or historic buildings or structures.

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): The proposed project avoids impacts to known significant archaeological sites. The proposed action would impact one small open air lithic scatter. Investigations of this site indicate that the site lacks the potential to provide additional data about the past. Therefore, impacts to the site do not affect a resource of significance. Appendix B documents the National Historic Preservation Act consultation. A review may be needed pending survey of relocated borrow area.

3.9 Threatened and Endangered Species

No endangered species are believed to be present within the boundary of the project area. While known endangered mussels, bats and plants are located in the general region, no critical habitat is located within the site boundary.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Alternative 1 (No Action Alternative): The No Action Alternative would not result in any new disturbances to aquatic or terrestrial resources, and therefore, would not affect any federally listed threatened or endangered species.

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): Implementation of the project would result in the loss of approximately 17 forested acres of suitable summer habitat for the federally endangered Indiana bat (Myotis sodalis) and federally threatened northern long-eared bat (Myotis septentrionalis). A mist net survey for listed bat species was conducted in the summer of 2016 and no listed bats were documented. Based on these results and a habitat assessment, CEC submitted a preliminary “not likely to adversely affect” determination.

On May 13, 2019, USFWS provided a letter to USACE, in response to the Public Notice, concurring with the CEC preliminary determination that “the proposed action is not likely to adversely affect the Indiana bat and Northern long-eared bat”. The letter stated USFWS is not “aware of any other federally protected species that would likely be affected by the proposed action” and further concluded that Section 7 of the Endangered Species Act had been satisfied. Correspondence regarding the Endangered Species Act is included with this document in Appendix A.

3.10 Hazardous, Toxic, and Radioactive Waste (HTRW)

Currently, nine (9) tracts of USACE land are located on and adjacent to the active area of the AOS facility. Five (5) USACE tracts are covered in asphalt and concrete parking or warehouse space. Manufacturing equipment such as propane cylinder storage, used oil storage and miscellaneous parts and scrap metal storage was observed on or in close proximity to the eastern most USACE tracts. The remaining four USACE tracts are located to the west of Tennessee Waltz Parkway are primarily forested wetlands. No structures or improvements are present on the 16.37- acre AOS tracts to the west of Tennessee Waltz Parkway. A Phase I Environmental Site Assessment (ESA) was conducted by CEC in December 2016. No sampling or testing of materials, soil, water, air, or other environmental media was performed. Reviews of State agency record, site reconnaissance and owner and city official interviews were conducted and indicate little risk of an HTRW condition. The 2016 Phase 1 has since expired, and USACE will be conducting a new Phase 1 ESA.

Alternative 1 (No Action Alternative): Under the No Action Alternative, land disposal and flood levee construction would not occur. AOS would continue to use, store, and dispose of hazardous materials needed for their routine operations as they do now.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): Construction of the flood levee could result in potential for fuel or similar spills associated with manufacturing activities or equipment used in the construction process. This would be covered by the site specific spill plan under the construction general permit. The project would ultimately help mitigate potential HTRW issues by reducing the risk of flood waters (up to a 500 year event) entering the facility. Based on previous information/observations, no HTRW issues are anticipated. This will be verified after the current Phase 1 ESA is completed (before concluding EA).

3.11 Health and Safety

Alternative 1 (No Action Alternative): The No Action Alternative would have a long-term, negative effect on health and safety by failing to offer flood mitigation measures which would increase safety risks such as pollution of waters.

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): The project is expected to have a beneficial effect to public safety by limiting pollution of waters near the Cumberland River by reducing risk of flood waters from entering the AOS facility. The project would also offer flood risk mitigation for a CEMC substation and the Ashland City WWTP and reduce flooding of Tennessee Waltz Parkway to traveling vehicles.

3.12 Recreation and Scenic Resources

The proposed project is along Tennessee Waltz Parkway and the Cumberland River. There is no active recreation within the current project area. The nearby City soccer fields, to the north, would not be affected. Portions of the project area are currently developed by AOS to include buildings, parking area, and storage yards. The adjacent lands are a mixture of agricultural fields, scrub/shrub thickets, early successional forest growth, and residential/commercial properties.

Alternative 1 (No Action Alternative): The No Action Alternative would result in no construction of a flood control levee. No earth disturbance would occur and this alternative would not affect project aesthetics.

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): The proposed project could affect the aesthetics of the existing landscape. The project would result in minor modifications of the existing terrain and landforms within the flowage easement of Cheatham Lake to include construction of a flood levee. The levee would be maintained as grass. A mitigating factor to the aesthetics of the project would 26

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake be the planting of native vegetation. The borrow area developed to obtain material needed to construct the levee would be utilized as a public fishing lake in the future. This is part of a long-range plan to offer more recreational opportunities to the citizens of Ashland City. There would be minimal effects to the nearby soccer fields and park during construction.

3.13 Socioeconomics

The area of interest (AOI) is limited to Cheatham County. Nashville, TN is the largest city in the project’s vicinity, however, the Lake is less than 200 miles from other large metropolitan areas—Memphis, TN; Louisville, KY; Birmingham, AL. Population statistics for Cheatham County, as well as overall state data, are provided in Table 5.

Table 5. Population statistics for Cheatham County & Tennessee Cheatham TN County, TN Population 6,770,010 40,439 2018 estimate

% Population Change +6.7% +3.4% 2010-2018

% Population below 15.0% 12.7% poverty level

Median Household Income $48,708 $56,150 2013-2017

As shown in Table 6 below, the primary industries for employment for Cheatham County are education/healthcare and social assistance; manufacturing; retail trade; scientific, management and administrative; arts, entertainment, recreation, food services, and accommodation; transportation, warehousing, and utilities; and construction (US Census Bureau, 2017).

Table 6. Industry Statistics for Cheatham County & Tennessee Statistics are % of employment per Cheatham industry; not all industries represented; TN County, TN totals will not equal 100% Educational Services, Health Care, 22.6 19.6 Social Assistance

Manufacturing 13.1 12.3

Retail Trade 12.1 10.4

Professional (scientific, management, 9.6 9.4 administrative)

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Statistics are % of employment per Cheatham industry; not all industries represented; TN County, TN totals will not equal 100% Arts, Entertainment, Recreation, Food 9.6 6.8 Services, Accommodation

Transportation, Warehousing, Utilities 6.4 7.5

Construction 6.3 11.3

Alternative 1 (No Action Alternative): Socioeconomic benefits to the community could substantially decrease under the No Action Alternative. AOS is the largest employer in Cheatham County and plant production has been significantly impacted due to past flood events. If no flood risk mitigation is provided, additional investment in the Plant is unlikely and Plant closure is a possibility.

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): Approval of the proposed action would have a beneficial effect to local socioeconomics. The project would be expected to offer long-term benefits to the AOS Plant and future investment in the community as well as temporary employment to construction workers. The project would also have positive, long-term effects for traffic utilizing Tennessee Waltz Parkway.

3.14 Air Quality

Currently the proposed project area is in an attainment area with regard to the National Ambient Air Quality Standard (NAAQS).

Alternative 1 (No Action Alternative): No work would be performed under this alternative and levee construction would not occur. There would be no effect to air quality.

Alternative 8 (Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E- 518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee): Under Alternative 8, there would be temporary, minor air quality impacts (dust, vehicle exhaust) from vehicle, equipment, and construction activities. However, these temporary impacts would be minimal, and would have no long-term effects on air quality levels. Therefore, the proposed project meets the Conformity Rule under the Clean Air Act and poses no risk to NAAQS.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

3.15 Navigation

Cheatham Lake is part of the Cumberland River commercial navigation system (Barkley Lock & Dam to Cordell Hull Lock & Dam). Neither of the alternatives described in this document would impact navigation.

4.0 CUMULATIVE IMPACTS Cumulative impacts are defined as “the impact on the environment which results from the incremental impact of the (proposed) action when added to other past, present, and reasonably foreseeable future actions regardless of what agency or person undertakes such other actions (40 CFR 1508.7).” Past, present and reasonably foreseeable future activities contributing with the proposed action for cumulative impacts in the area include aquatic resources, floodplains, and socioeconomics. The geographical boundary considered for this discussion of cumulative impacts is Cheatham Lake and Cheatham County. The temporal boundary established spans from construction of the reservoir in 1950 to fifty years future projection. 4.1 Past and Present Actions Cheatham Lock and Dam was authorized to provide a navigable river channel on the Cumberland River. Subsequent, additional authorization provided for the production of hydroelectric power, water quality, recreation, fish and wildlife management, and provision of a water supply for surrounding areas. As documented in Section 3.6, approximately 31% of Cheatham Lake watershed consists of lands that are developed (open space, low density, medium density, or high density) opposed to approximately 52% of the watershed in combined forest and scrub/shrub habitat. Commercial and residential development around the reservoir has increased, prompted in part by the proximity to Nashville and easy access to Interstates 24 and 40. Impacts to aquatic resources and the floodplain are expected to increase as development also increases. Although development often has a detrimental impact on aquatic resources and floodplains, it provides economic opportunities for local citizens. 4.2 Reasonably Foreseeable Future Actions Urbanization and economic growth in Nashville and the surrounding areas are expected to continue. Reasonably foreseeable future development will continue to stress the floodplains and aquatic resources while also providing employment. Impacts to aquatic resources and floodplains include habitat alteration and land development. The relationship between industrial, commercial and economic development, and natural resources in the watershed is clear in Section 3.4. The Corps of Engineers Regulatory Branch and TDEC promote avoidance, minimization and compensatory mitigation of aquatic resources, while allowing sustainable development through implementation of the Clean Water Act. Climate change is also expected to have an impact on the Cheatham Lake watershed. The area is projected to receive more intense rainstorms

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake resulting in extreme flooding. The lands will need to be managed to protect natural resources and human safety. 4.3 Combined Cumulative Effects Several alternatives have been considered to achieve the desired flood risk mitigation purpose but were eliminated from further consideration due to cost, inadequate mitigation or greater environmental impacts (Section 2.0). The preferred plan resulted in flood risk mitigation while avoiding impacts to Puzzlefool Creek and reducing overall wetland and stream impacts. Impacts were reduced to an estimated 3.67 acres of wetlands and 294.5 linear feet of streams by modifying the project footprint (Section 3.3 and Section 3.5). The flood risk mitigation would have a beneficial effect to the local economy as the Plant provides 1,922 jobs (NACC, 2019) and has a substantial socioeconomic effect on Cheatham County.

In summary, when combined with other past, present, and foreseeable future actions associated with the reservoir and Cheatham County, the incremental impacts of the present action on the cumulative effects issues of aquatic resources, floodplains and socioeconomics are considered minor or positive. Compensatory mitigation would occur onsite for impacted aquatic resources. The project would cause “no rise” to the base flood elevation on the Cumberland River but protects the local facility along with a waste water treatment plant and electrical substation. Protection of the AOS facility is vital to the socioeconomics of the local community. No construction would occur other than in a designated area, managed according to strict agreements with USACE, and therefore cumulative impacts would be controlled and are not considered significant. Any cumulative effects to the environmental condition in the Cheatham Lake watershed would likely be caused by other activities in the watershed, which would be subject to regulations and preventative measures of other programs such as Clean Water Act, Food Securities Act (agriculture), etc.

5.0 ENVIRONMENTAL COMMITMENTS, PERMITS, AND APPROVALS The following commitments, permits, and approvals are made regarding implementation of the action alternatives:

1) An Individual Water Quality Certification from TDEC is required for the project. 2) An Individual DA Permit from the USACE Regulatory Division is required for the proposed work under authority of Section 404 of the Clean Water Act. 3) A General Permit for stormwater discharges from construction sites is required for the project. 4) Examples of general construction BMPs are listed below.  Minimize Disturbance – minimize disturbed areas within the project area to those being actively worked.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

 Sediment Control Devices – sediment control devices such as silt fences, fiber rolls, geotextile filter fabric, and rock filters would be used as temporary erosion control barriers to capture stormwater runoff from project area.

6.0 ENVIRONMENTAL COMPLIANCE 6.1 Executive Order 11990-Wetlands

The project would result in the permanent fill of 3.67 acre of wetlands. However, these impacts would be mitigated through onsite compensatory mitigation to include the creation of 14.44 acres of new wetlands. An additional 1.68 acres of wetland preservation is proposed along with 4.42 acres of upland buffer preservation.

6.2 Farmland Policy Protection Act

The Natural Resources Conservation Service provided feedback stating the project “will convert areas of prime farmland as defined by the Farmland Policy Protection Act”. Prime farmland soils in the project area (Figure 9) include Arrington silt loam (ArA), Beason silty clay loam (Be), Byler silt loam (ByB2), Ennis gravelly silt loam (En), and Wolftever silty clay loam (WfA). Consultation with NRCS for the draft EA will continue during public review.

6.3 Executive Order 11988-Floodplain Management

Executive Order 11988, Floodplain Management, requires federal agencies to evaluate and minimize impact to the floodplain. USACE controls flowage easement for flood control in the Cheatham Lake reservoir to elevation 385 feet above mean sea level. There would be a “no rise” to the base flood elevation. Upon completion, potential negative effects associated with flooding of the AOS facility would be prevented up to a 500 year event. Based on the given information, the proposed land disposal and levee construction complies with Executive Order 11998, Floodplain Management.

6.4 Clean Water Act

Waters of the U.S. are present within the proposed project footprint. Therefore, coordination with State and Federal Agencies regarding Clean Water Act compliance is required. Permits from both TDEC (Section 401) and the USACE Regulatory Division (Section 404) would be required for the proposed project.

The applicant submitted an Individual Aquatic Resources Alteration Permit (ARAP) application (Permit NRS17.220) on July 3, 2017. The project was reactivated on April 17, 2019 and is currently pending. The project is being evaluated as an Individual

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Permit (LRN-2012-00124) by the USACE Regulatory Division. A Public Notice for the project was issued May 6, 2019 and the application is still pending.

6.5 Endangered Species Act

The lead federal agency for a project is required to consult with USFWS for potential effects to federally listed threatened and endangered species under Section 7 of the Endangered Species Act. Consultation for potential impacts to threatened and endangered species within the project area was completed on May 13, 2019. Section 7 of the Endangered Species Act compliance has been completed for this project.

6.6 Fish and Wildlife Coordination Act

USACE is required to coordinate with the USFWS and State Agency under the Fish and Wildlife Coordination Act (FWCA) (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.). Coordination with USFWS and Tennessee Wildlife Resources Agency was initiated by scoping in conjunction with Public Notice No. 19-14 posted by USACE Regulatory Office (Appendix A) on May 6, 2019. A draft EA will be provided to these agencies for coordination under the FWCS and any responses will be considered before finalizing the EA.

6.7 National Historic Preservation Act

Section 106 of the National Historic Preservation Act (54 U.S.C. 306108) requires Federal agencies to consider the effects of their undertakings on historic properties and afford the Advisory Council on Historic Preservation and opportunity to comment. 36 CFR 800 promulgates the process for Federal agencies to meet their obligations under Section 106.

Cultural resource investigations are ongoing. To date, CEC (2016, 2017b, 2017c) completed cultural resource surveys of the majority of the proposed action. The investigations identified two archaeological sites. One site is eligible for the National Register of Historic Places and plans avoid the site. The second site lack the potential to provide data about the past; therefore, it is determined not eligible for listing in the NRHP. Additional cultural resource surveys are being conducted in the location of the proposed borrow area. When this information is available, USACE will continue consultation.

Appendix B presents a summary of the correspondence with the State Historic Preservation Office and tribes.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

6.8 Executive Order 13514 – Environmental Justice

The 1994 Executive Order 12898: “Federal Actions to address Environmental Justice in Minority Populations and Low Income Populations” was signed by President Clinton on February 11, 1994, to focus Federal attention on the environmental and human health conditions of minority and low-income populations, with the goal of achieving environmental protection for all communities. As defined by the “Draft Guidance for Addressing Environmental Justice under NEPA” (CEQ, 1996), a minority population exists where the percentage of minorities in an affected area either exceeds 50% or is significantly greater than in the general population. Data from the 2010 Census (US Census Bureau, 2017) indicate that the population of Ashland City, Tennessee was 90.3% white and 3.5% was black, with the remainder divided into several other categories. Hispanics or Latinos made up 5.2% of the City's population, while non- Hispanics and non-Latinos made up 94.8%. Within Cheatham County, 95.6% of the population was white, and 1.4% was black, with the remainder divided into several other categories. Hispanics or Latinos made up 2.3% of the County's population, while non- Hispanics or non-Latinos made up 97.9%. The final step in the environmental justice evaluation process is to evaluate the impact of the project on the population and to ascertain whether target populations are affected more adversely than other residents. The conclusion for this proposed project is that low-income or minority populations would not be disproportionately affected by the proposed activity. Neither of the alternatives described in this environmental assessment would disproportionately place any adverse environmental, economic, social, or health impacts on minority and low- income populations.

6.9 Clean Air Act

Neither of the alternatives described in this document would impact long-term ambient air quality standards.

6.10 Comprehensive Environmental Response, Compensation, and Liability Act

No Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites were identified within the proposed project boundaries.

6.11 Resource Conservation and Recovery Act

All alternatives would be in compliance with the Resource Conservation and Recovery Act (RCRA).

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

6.12 Executive Order 13653 (Preparing the United States for the Impacts of Climate Change)

Climate change is a topic to be considered into discussions for potential impacts and consequences. Lands identified as vulnerable to extreme climate impact (flood and drought) would need to be managed to protect natural resources and human safety. Although information available for review specific to climate change varies, most acknowledge similar expected trends. Noted generally for the Southeast section of the United States, thus applicable for the Cheatham Lake project area, temperatures are expected to increase over the next century. Regional average summer temperature increases (assuming a scenario with steadily rising emissions of greenhouse gasses) are expected between 4.90 by 2055 and 8.50 F by 2085 (NCA, 2014). Trends evaluated more directly to the Ohio River Basin estimate average temperature increases to be 5- 70F looking outward through 2055 (USACE, 2015).

Views on changes in precipitation are less aligned among scientists than temperature changes (NCA, 2014). Most agree with projections of decreased amounts of precipitation and increased storm frequencies (USACE, 2015; NCA, 2014). Thus, the rainfall that is received within the Cheatham Lake watershed would be in more intense rainstorms, resulting in sudden and more extreme flooding. There is not enough data to determine whether or not this would increase the risk to the AOS project, however, construction of the flood levee would provide a level of resiliency against possible flood impacts, up to a 500 year event, due to climate change. The project is not expected to affect climate change.

7.0 PUBLIC AND AGENCY COORDINATION 7.1 Public and Agency Involvement

NEPA is a Federal law that requires federal agencies to consider the potential environmental, including social, impacts of their proposed project and to allow for comments from interested groups about the work plan before any action is taken.

7.1.1 Scoping Process

Through the NEPA process, a Scoping Letter, in conjunction with the Public Notice for an Individual DA Permit from Regulatory Division (Appendix A), was sent to other governmental agencies and officials, Indian Tribes, the public, private individuals, and other interested parties on May 6, 2019. The Notice states the need for action and provides general information on the scope of work and the area of land and/or water that would potentially be affected by the agency project. The Notice attempts to identify environmental concerns by requesting comments on alternatives and a list of environmental resources to consider. Two comments, along with a letter of support,

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake were received during the scoping period (Appendix A). This EA will be sent for public review, along with a Notice of Availability (NOA) letter. Comments received from the NOA process will be incorporated into the Final EA.

8.0 CONCLUSION

Two alternatives were evaluated in detail throughout this EA; Alternative 1- No Action Alternative and Alternative 8- Proceed with disposal of USACE tracts E-514-1, E- 514-2, E-518-1, E-518-2, E-519-1, E-537-1 and E-538 to AOS for construction of a flood levee.

Alternative 1 would not allow the proposed land disposal and flood levee construction to occur. No environmental impacts would occur along the proposed project area. However, no improvements would be made to the existing lack of flood risk management.

Alternative 8 would allow the proposed land disposal and construction of a flood levee to occur. The levee construction project would have minor, detrimental impacts to water quality and aquatic and terrestrial resources. The minor, localized impacts to water quality in Cheatham Lake would be due to the encapsulation or relocation of 294.5 linear feet of stream and permanent loss of approximately 3.67 acres of wetlands. The project would also cause minor, temporary increases to turbidity to local streams during construction, which would be minimized through the sequential approach to road construction and implementation of BMPs. Minor impacts to aquatic resources would be offset by compensatory mitigation. Impacts to terrestrial resources would include the loss of approximately 17 acres of suitable summer habitat for the federally endangered Indiana bat (Myotis sodalis) and federally threatened northern long-eared bat (Myotis septentrionalis). However, a “not likely to adversely affect” determination was concurred by USFWS. The proposed project would provide serious flood risk reduction, up to a 500 year event, at the AOS facility and provide long-term benefits to the health/safety and socioeconomics of the local area. Temporary direct, indirect and cumulative impacts to the Cheatham Lake watershed, associated with Alternative 8, would be minimal. All work would be performed in accordance with federal, state and local regulations.

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

REFERENCES Civil & Environmental Consultants, Inc. (CEC), 2016 Phase I Archaeological Survey for the A.O. Smith Flood Control Levee Construction and USACE Land Exchange, Ashland City, Cheatham County, Tennessee

Civil & Environmental Consultants, Inc. (CEC), 2017a. Draft Environmental Assessment Land Exchange Between The U.S. Army Corps of Engineers and Cheatham County, Tennessee and Construction of Proposed Flood Control Levee to Protect A.O. Smith, Inc. Facility in Ashland City, Tennessee

Civil & Environmental Consultants, Inc. (CEC), 2017b. Phase I Additional Archaeological Survey of 5.7 HA (14 AC) Addendum to: Phase I Archaeological Survey for the A.O. Smith Flood Control Levee Construction and USACE Land Exchange, Ashland City, Cheatham County, Tennessee

Civil & Environmental Consultants, Inc. (CEC), 2017c. Phase I Second Additional Archaeological Survey of 4.1 HA (10.1 AC) Addendum to: Phase I Archaeological Survey for the A.O. Smith Flood Control Levee Construction and USACE Land Exchange, Ashland City, Cheatham county, Tennessee

Council for Environmental Quality. Draft Guidance for Addressing Environmental Justice under NEPA. 1996.

Federal Emergency Management Agency (FEMA). Flood Map Service Center. Accessed 6/28/2019. https://msc.fema.gov/portal/search?AddressQuery=500%20tennessee%20waltz%20parkway% 2C%20ashland%20city%2C%20tn#searchresultsanchor

National Ambient Air Quality Standards (NAAQS). Clean Air Act. Accessed 6/27/2019. https://www3.epa.gov/airquality/greenbook/popexp.html

Nashville Area Chamber of Commerce (NACC). 2019. Cheatham County Economic Development. Accessed 6/28/2019. https://www.nashvillechamber.com/economic- development/our-region/cheatham

National Climate Assessment (NCA). 2014. US Global Change Research Program. Accessed 6/28/2019. www.globalchange.gov

National Weather Service (NWS). 2017. Accessed April, 2017. http://www.weather.gov/

Tennessee Climatological Service. 2015. Retrieved from University of Tennessee Institute of Agriculture: www.climate.tennessee.edu

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Tennessee Department of Environment and Conservation (TDEC). 2014a. 2014 305(b) Report-- The Status of Water Quality in Tennessee. Planning and Standards Section, Nashville, TN.

Tennessee Department of Environment and Conservation (TDEC). 2014b. Final Version Year 2014 303(d) List.

US Army Corps of Engineers (USACE). 2018, Cheatham Lake Master Plan Draft.

US Army Corps of Engineers (USACE). 2015. Recent US Climate Change and Hydrology Literature Applicable to US Army Corps of Engineers Missions-Ohio Region 5. Civil Works Technical Report, CWTS 2015-05, USACE, Washington, DC.

US Army Corps of Engineers (USACE). 1996a. Engineering Regulation (ER) 1130-2- 550, Recreation Operations and Maintenance Policies. Chapter 3: Project Master Plans and Operational Management Plans. Washington, DC.

US Army Corps of Engineers (USACE). 1996b. Engineering Pamphlet (EP) 1130-2-550, Recreation Operations and Maintenance Policies. Chapter 3: Project Master Plans and Operational Management Plans. Washington, DC.

US Army Corps of Engineers (USACE), Nashville District. 2018. Master Plan, Cheatham Lake, Tennessee.

US Census Bureau. 2017. QuickFacts. http://www.census.gov/quickfacts

US Climate Data. 2017. Accessed April, 2019. www.usclimatedata.com

US Department of Agriculture, National Resource Conservation Service (NRCS). 2019. Accessed on July 1, 2019. https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx

US Environmental Protection Agency (EPA). 2015. Ecoregions of Tennessee. ftp://ftp.epa.gov/wed/ecoregions/tn/tn_eco_lg.pdf

US Geological Survey, National Land Cover Database (NLCD). 2016. Retrieved from Multi-Resolution Land Characteristics Consortium. https://www.mrlc.gov/data?f%5B0%5D=category%3Aland%20cover&f%5B1%5D=category%3A urban%20imperviousness&f%5B2%5D=region%3Aconus&f%5B3%5D=category%3Aland%20c over&f%5B4%5D=category%3Aurban%20imperviousness&f%5B5%5D=region%3Aconus

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

LIST OF PREPARERS David A. Adams, Biologist, Environmental Section, Project Planning Branch, Primary EA Preparation

Travis Wiley, Biologist, Environmental Section, Project Planning Branch, Environmental Discussion

Valerie McCormack, Archaeologist, Environmental Section, Project Planning Branch, EA Preparation – Cultural and Historic Resources

Timothy Higgs, Chief, Environmental Section, Project Planning Branch, EA Review

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Appendix A

Project Scoping and Comments

Page 1 of 7

US Army Corps of Engmeers Public Notices Public Notice No. 19-14 ; File No. LRN-2012- 00124

Published May 6, 2019

Public Notice No. 19-14 Nashville District Application No. LRN-2012-00124 Date: May 7, 2019 ; Expires: June 6, 2019

Please address all comments to: Nashville District Corps of Engineers Regulatory Division (Attn: Amy Robinson), 3701 Bell Road, Nashville, TN 37214

SUBJECT: Proposed discharge of fill material into streams and wetlands associated with conveyance of approximately 9.19 acres of U.S. Army Corps of Engineers (USACE) Cheatham Lock and Dam Project lands for construction of a flood control levee to protect A.O. Smith Facility, in Ashland City, Cheatham County, Tennessee (Adjacent to Cumberland River Mile 185.4)

TO ALL CONCERNED: The application described below has been submitted for a Department of the Army (DA) Permit pursuant to Section 404 of the Clean Water Act (CWA) (33 U.S.C. 1344). In addition, a joint National Environmental Policy Act (NEPA) document will be prepared for the DA Permit and USACE real estate conveyance action for tracts E-514-1, E- 514-2, E-518-1, E-518-2, E-519-1, E-537-1 and E-538.

APPLICANT: A. O. Smith Corporation 500 Tennessee Waltz Parkway Ashland City, Tennessee 37015

LOCATION: Tributaries and wetlands adjacent to Cumberland River Mile 185.4, right descending bank, Cheatham Lake, By Pass Road and Tennessee Waltz Parkway, in Ashland City, Cheatham County, TN (Latitude 36.266621°, Longitude - 87.067433°)

DESCRIPTION OF PROPOSED WORK: The applicant proposes to construct a 500-year flood protection levee around the north, west, and south sides of its facility in Ashland City, TN.

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The levee would be constructed partially on property they own and partially on government lands. The soil used as fill for the earthen levee would be obtained partially from property they own and partially from City land. The levee would fill approximately 3.67 acres of wetlands (consisting of 0.91-acre of forested wetland and 2.76-acres of emergent wetlands) and impact 986 linear feet of stream channel. Of the impacted streams, 270.5 linear feet would be encapsulated, 24 feet would be relocated, and 692 feet would be excavated (within the borrow area of soil for the levee) as shown in table below:

Impact Table Streams Wetlands Impact Impact ID Impact Type Impact Type Feet Acres ID Acres STR-3 130 0.01 Encapsulation WTL-1 0.41 Permanent Fill STR -4 138 0.02 Encapsulation WTL-2 0.08 Permanent Fill STR -8 24 0.002 Relocation WTL-3 0.01 Permanent Fill STR -9 2.5 0.00005 Encapsulation WTL-9 1.35 Permanent Fill STR-10 137 0.03 Excavation WTL-11 1.78 Permanent Fill P STR-11 228 0.05 Excavation WTL-12 0.04 Permanent Fill I STR-11 327 0.08 Excavation

Totals 986.5 0.19 3.67

The dimensions of the earthen segments of levee would range from 75 feet to 150 feet wide and 13 feet to 27 feet tall. Portions of the levee will consist of 8 foot to 25-foot high concrete floodwalls up to 30 inches thick. Streams flowing from east to west from under t he A O Smith facilit y would follow their existing course through gates in the floodwall and culverts in t h e levee during normal flow conditions. When the Cumberland River reaches flood stage these gates would be closed and stream and storm flow will be pumped over the levee. On the south side, the levee would tie into existing grade above the 500-year flood level at Tennessee Waltz Parkway west of the railroad. On the north side, the wall would cross the railroad tracks and tie into natural grade to the east.

The levee would also surround and protect a Cumberland Electric Membership Cooperative substation located to the south of the plant and the Ashland City Waste Water Treatment Plant (WWTP) to the north. Concrete walls were selected for the section between the WWTP and Puzzlefool Creek on the north side and at the Stream 9 crossing on the west side to minimize stream impacts.

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Construction of the levee would require the permanent filling of 3.67 acres of wetland located within the proposed levee footprint. Additional temporary wetland impacts totaling up to 2.68 acres may occur during construction but these areas would be restored to their original contours immediately after construction. Streams 3 and 4 currently flow through culverts under the A.O. Smith facility and streams 8 and 9 begin at the western toe of Tennessee Waltz Parkway on the west side of the facility. These streams would be crossed by the levee. Streams 3 and 4 would pass through gated culverts in the earthen portion of the levee. A new channel (Stream 8) would be constructed relocating flow to Stream 9 upstream of the concrete levee wall and then the combined Stream 8/9 base flow would likewise pass through a gate in the concrete floodwall. Approximately 692 feet of streams (Streams 10 and 11) would be excavated along their length crossing a borrow area for the earthen levee. The entire borrow area excavation would be remain and would be converted to a public access fishing pond owned by the City after borrow is complete.

Plans and location maps of the proposed project are provided in this notice.

If you received this notice by mail and wish to view all of the diagrams, visit our web site at: http://www.lrn.usace.army.mil/Media/PublicNotices.aspx.

PURPOSE AND NEED: A.O. Smith is the largest employer in Cheatham County. The purpose of the levee is to protect the A.O. Smith Plant from future flood events. Since its construction, the Ashland City A.O. Smith Plant has experienced multiple flood events. In 2010, the 500- year flood elevation of 407 was exceeded at the site. Plant production was significantly impacted and total cost of lost production and repairs from the 2010 flood event was in excess of 66 million dollars. Flooding of the plant parking lot during a flood event in February of 2016 resulted in damage to employee vehicles. Additional investment in the Plant is unlikely without the levee. Work to complete the levee is expected to take approximately 1.5 years.

AVOIDANCE AND MINIMIZATION OF IMPACTS TO WATERS OF THE U.S.: Several alternatives have been considered to achieve the desired flood control purpose, but were eliminated from further consideration due to inadequate protection or greater environmental impacts. According to the application, every effort has been made to minimize impacts to streams and wetlands and the currently proposed alternative represents the best possible approach to protect the A.O. Smith Plant and allow for future investment and growth of the facility. In addition, the applicant states every effort has been made to keep the construction footprint as small as possible. The project was designed to maintain channel lengths and employ natural channel design techniques for the channel relocation (i.e., Stream 8 tying to Stream 9).

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The combined flows will pass through the levee at a single gate and rejoin the existing stream channel downstream. Other minimization measures include reducing the levee footprint at crossing points by installation of an open channel through the levee rather than encapsulation (originally proposed as 270 linear feet). Other measures would be employed including installation of erosion control measures, revegetation and stabilization of disturbed areas, and other best management practices as necessary. Unavoidable temporary wetland impacts would be held to the absolute minimum necessary and restored in as timely as manner as possible to minimize temporal impacts. Stream crossings would be constructed in the dry and work would be timed during dry weather periods to the extent possible.

COMPENSATORY MITIGATION: The applicant proposes compensatory mitigation for the proposed 3.67-acres of wetland impacts. The mitigation plan includes creation of 14.44 acres of new wetlands onsite, on applicant owned property (4:1 ratio to compensate for 3.67 acres of filled wetlands). The applicant proposes to excavate higher areas of the Cumberland River floodplain adjacent to existing wetlands to a similar bottom elevation. This proposal would link the existing wetland areas into a larger wetland system resulting in the enhancement of habitat of onsite existing wetlands. An additional 1.68 acres of wetland preservation is proposed (10:1 ratio for 0.17 acre of impacted wetland) and 4.42 acres of upland buffer preservation. According to the applicant, the proposed mitigation plan would generate compensation equivalent to the loss of 4.07 acres of wetlands at the site, create a larger, connected wetland system within the floodplain area, and increase existing wetland functions.

The applicant proposed mitigation for the stream impacts by onsite, permittee-responsible measures. Streams 3 and 4 (proposed encapsulation) and Streams 10 and 11 (proposed borrow excavation impact) are characterized as Cumberland River backwater/open water slough (lentic) areas. The total area of lentic habitat to be impacted is 0.11 acre (total of 960 linear feet). For these impacts, the applicant proposes onsite, in-kind lentic mitigation by the creation of a 7.81- acre (fishing) lake with fringe wetlands (approximate ratio of 41:1). It would be constructed at the site of the soil borrow area post-excavation with 3:1 sloping banks and a variety of depths, substrates, and habitats for fish, reptiles, amphibians, and benthic macroinvertebrates.

For stream mitigation of impacts to Streams 8 and 9, total of 26.5 linear feet, the applicant proposes to relocate 24 linear feet of STR-8, remove two existing bridges and provide restoration activities including bank stabilization on approximately 100 linear feet of Stream 7 (Puzzelfool Creek).

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The proposed permittee-responsible mitigation plan for this project is on file in the Regulatory Division office.

PUBLIC INTEREST REVIEW/CUMULATIVE EFFECTS: The decision whether to issue a DA permit will be based on an evaluation of the probable impacts including cumulative impacts of the activity on the public interest. That decision will reflect the national concern for both protection and utilization of important resources. The benefit, which reasonably may be expected to accrue from the proposal, must be balanced against its reasonably foreseeable detriments. All factors which may be relevant to the proposal will be considered including the cumulative effects thereof; among those are conservation, economics, aesthetics, general environmental concerns, wetlands, historic properties, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shoreline erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, considerations of property ownership and, in general, the needs and welfare of the people.

SOLICITATION OF COMMENTS: The Corps is soliciting comments from the public; federal, state, and local agencies and officials; Indian Tribes; and other interested parties in order to consider and evaluate the impacts of this proposed activity. USACE is soliciting comments from the public; federal, state, and local agencies and officials; Indian Tribes; and other interested parties in order to consider and evaluate the impacts of this proposed activity. Any comments received will be considered by USACE to determine whether to issue, modify, condition, or deny a permit for this proposal. To make this decision, comments are used to assess impacts on endangered species, historical properties, water quality, general environmental effects, and the other public interest factors listed above. Comments are used in the preparation of an Environmental Assessment (EA), supplemental EA, and/or an Environmental Impact Statement pursuant to the National Environmental policy Act (NEPA). Comments are also used to determine the need for a public hearing and to determine the overall public interest of the proposed activity.

HISTORIC AND CULTURAL RESOURCES: The applicant conducted archaeological surveys of the proposed flood control levee and associated work in 2016 and 2017. These surveys were submitted for Corps review with the application package. Identified sites would be avoided by the levee alignment. No archaeological sites listed on or eligible for the National Register of Historic Places would be impacted by the proposed project. Assessment of indirect effects on historic buildings and structures is forthcoming.

A copy of this notice is being sent to Tennessee Historical Commission, the State Historic Preservation Office (SHPO), and Federally recognized tribes for their comments and consultation under Section 106 of the National Historic Preservation Act. The Corps invites

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responses from American Indian Tribes or tribal governments; Federal, State, and local agencies; historical and archeological societies; parties likely to have knowledge of or concerns regarding historic properties and cultural significance at or near the project area, and the public. Under separate cover, the Corps will provide copies of the reports to the SHPO and Tribes in association with Section 106 consultation.

ENDANGERED/THREATENED SPECIES REVIEW: The Endangered Species Act (ESA) requires federal agencies to consult with the U.S. Fish and Wildlife Service (USFWS) pursuant to Section 7 of ESA on all actions that may affect a species listed under the ESA as threatened or endangered (T&E) or any designated critical habitat. The applicant submitted results of a mist net survey and a habitat assessment report conducted in October 2016. According to the report, habitat for the endangered Indiana bat (Myotis sodalis) and threatened northern long- eared bat (Myotis septentrionalis) are present at the site. The affected permit area contains approximately 17 acres of secondary growth forest, which could be considered potential summer habitat for the Indiana bat due the size, and characteristics of the trees. The land to the west of the project area is riparian, secondary growth forest, and contains bottomland habitat that is ideal for the Indiana bat. This area contains flyways for bats, protected foraging areas, multiple roost locations, and access to drinkable water. While potential bat habitat was identified across the permit area; the report concludes that the location with the best habitat is well outside the location proposed for the levee. No significant adverse effects to fish and wildlife, their habitats and human uses are expected to result from the proposed work.

This public notice serves as coordination with the USFWS pursuant to Section 7 of the ESA of 1972 (as amended) and Fish and Wildlife Coordination Act. Per this notification, we request comments from the USFWS concerning potential impacts to T&E species. After receipt of comments, USACE will evaluate potential effects on proposed and/or listed species and their designated critical habitat and initiate consultation with USFWS, if required.

OTHER APPROVALS: In addition to the DA permit, other federal, state, and/or local approvals may be required for the proposed work, including:

1. Before a permit can be issued, water quality certification must be provided by the State of Tennessee Department of the Environment and Conservation, pursuant to Section 401(a)(1) of the CWA (33 U.S.C. 1341), that applicable water quality standards will not be violated.

2. The project requires Corps Real Estate Division approval for work on U.S. Government land. Therefore, prior to construction, the Corps Real Estate Division must approval for the project to impact lands and waters upon which the government has real estate interests.

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3. Other federal, state, and/or local approvals that may be required for the proposed work.

PUBLIC HEARING REQUESTS: Any person may request, in writing, within the comment period specified in this notice, that a public hearing be held to consider this application.

Requests for public hearings shall state, with particularity, the reasons for holding a hearing.

COMMENT PERIOD: Written statements received by June 6, 2019, will become a part of the record and considered in the determination. Any response to this notice should reference Corps Application No. LRN-2012-00124, and be directed to the Regulatory Division, Attn: Amy Robinson, at the above address or email: [email protected].

/s/

Timothy C. Wilder Chief, West Branch Regulatory Division U.S. Army Corps of Engineers

Related Story: Plans for 19-14 /Portals/49/docs/Regulatory/PLANS FOR PN 19-14.pdf? ver=2019-05-06-142534-967

https://www.lrn.usace.army.mil/DesktopModules/ArticleCS/Print.aspx?PortalId=49&Modul... 5/7/2019 DEPARTMENT OF THE ARMY NASHVILLE DISTRICT, CORPS OF ENGINEERS REGULATORY DIVISION 3701 BELL ROAD NASHVILt E, TENNESSEE 37214 ~.-E· 1r·· ., ~, J~N ~ -.,- ~ ~l . SUBJECT: File No. LRN-2012-00124; PN 19-14;Proposed Flood Control Levee Construction along Tennessee Waltz Parkway, Cumberland River Mile 185.4R, Cheatham Lake, in Ashland City, Cheatham County, Tennessee (latitude 36.266621; longitude-87.067433)

Mr. Keith Auville A.O. Smith Corporation 500 Tennessee Waltz Parkway Ashland City, TN 37015

Dear ML Auville:

The U.S. Army Corps of Engineers (USACE) issued Public Notice PN 19-14, dated May 7, 2019, concerning your application requesting Department of the Atmy (DA) authorization to construct a flood control levee along a p01iion of Tennessee Waltz Parkway, in Ashland City, Cheatham County, TN. Enclosed are copies of comments and/or objections we received in response to the public notice. Please refer to File LRN-2012-00124 regarding this project in any future correspondence.

It is our policy to refer all comments and/or objections to the applicant to afford you an oppo1iunity to resolve the objections or respond to the stated concerns. While no objections were received in response to the public notice, the Environmental Protection Agency (EPA) requested consideration of impacts associated with the construction of the levee such as Section 106 of the National Historic Preservation Act, wildlife species, water quality and migration of · terrestrial and aquatic species.

As discussed during a June 5, 2019 meeting with A.O. Smith representatives and USACE offices, the project plans could potentially be revised pending Ashland City's approval. The revision would be to avoid and minimize stream impacts in the vicinity of the proposed borrow site/fishing lake. Prior to land conveyance and/or issuance of a DA permit, a determination regarding potential archaeological/historical impacts pursu;mt to Section 106 of the National Historical Preservation Act (NHP A) must be made for any land not originally investigated. If necessary, provide any surveys, rep01is, and/or info1mation for the additional property.

Please provide a response to these comments no later than 30 days from the date of this letter. - 2 -

If you have any questions concerning this matter, please contact the Staff Archaeologist, Valerie McCormack at (615) 736-7847 or e-mail: [email protected], or Regulatory Project Manager, Amy Robinson at the above address, phone (615) 369-7506, or email: [email protected].

Sincerely,

imothy C. 1lder Chief, West Branch Regulatory Division U.S. Army Corps of Engineers

Enclosures

Electronic copy furnished: LRN-OP (Church and Fanning) LRN-OPN-CHR (Henninger and Thomas) LRN-PMP (Higgs, Adams, and McCormack) LRN-RE (Norals) CEC, Inc. (Catron) AO Smith (Head) Robinson, Amy M CIV USARMV CELRN (US)

From: Long, Larry < [email protected]> Sent: Wednesday, May 8, 2019 9:44 AM To: Robinson, Amy M CIV USARMY CELRN {US) Cc: Militscher, Chris Subject: [Non-DoD Source] NEPA Scoping Comments -A.O. Corporation, Cheatham Lock and Dam;

Amy Robinson U.S. Army Corps of Engineers Nashville District Regulatory Branch 3701 Bell Road . Nashville, Tennessee 37214

Re: NEPA Scoping Comments -A.O. Corporation, Cheatham Lock and Dam; LRN-2012-00124

The U.S. Environmental Protection Agency (EPA) has reviewed the Public Notice (PN) 19-14 provided by the U.S. Almy Corps of Engineers (USACE) Nashville District for the construction of a flood control levee, Ashland City, in Cheatham County, Tennessee. This project as proposed would include the deposition of fill material into streams and wetlands identified as Waters of the United States (WOTUS) for the construction of a 500-year flood protection levee located at the Cumberland River Mile 185.4. The EPA provides the following specific comments and recommendations for your consideration.

The USACE may wish to consider relevant impacts associated with the construction of the 500-year flood levee, including Section 106 of the National Historic Preservation Act, wildlife species, and water quality. USACE may also want to consider how the control structures could impact the migration of terrestrial and aquatic species. We recommend that the USACE consult with the Tennessee Wildlife Resource Agency (TWRA) to dete1mine any potential impacts to dete1mine the hydraulic and hydrological design impacts associated with placement of control structures that might result in potential impacts to terrestrial and aquatic species.

The USACE Nashville Regulatory Division may wish to provide the CWA 404(b)(l) documents for this project in the appendix to the final NEPA document(s) in support of any wetland and stream mitigation decisions. This information could help aid the Tennessee Department of Environmental Conservation (TDEC) to evaluate stream impact requirements for the TDEC Section 401 Water Quality pe1mit. The 404(b)(l) documents can also help to streamline the final environmental review and permitting processes.

Thank you for the opportunity to provide comments for your proposed project. The EPA Region 4 requests one hardcopy of the draft NEPA documents with one electronic version (e.g., CD). Please forward copies to:

U.S. Environmental Protection Agency - Region 4 Attn: NEPA Section Strategic Programs Office 61 Forsyth Street, SW Atlanta, Georgia 30303

1 If you have any questions or comments concerning our recommendations, feel free to contact me via the information provided below.

Larry Long Regional Mining Expert Physical Scientist/Sr. Principle Reviewer Strategic Programs Office Office of the Regional Administrator EPA Region 4 NEPA Program Office 61 Forsyth Street, SW Atlanta, GA 30303 404-562-9460 404-562-9598(F AX) long. [email protected]

Intelligence does not always define wisdom, but adaptability to change does

CONFIDENTIALITY NOTICE: This message is being sent by or on behalf of the Environmental Protection Agency. It is intended exclusively for the individual(s) or entity(s) to whom or to which it is addressed. This communication may contain infmmation that is proprietary, privileged or confidential, or otherwise legally exempted from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy, or disseminate this message, or any part of it. If you have received this message in error, please notify the sender immediately by email and delete all copies of the message.

2 United States Department of the Interior

FISH AND WILDLIFE SERVICE Tennessee ES Office 446 Neal Street Cookeville, Tennessee 38501

May 13,2019

Amy Robinson Regulatory Specialist U.S. Anny Corps of Engineers, Nashville DistTict 3701 Bell Road Nashville, Tennessee 37214

Subject: FWS# 2019-CPA-0452. U.S. Army Corps of Engineers -LRN-2012-00124, PN 19-14, Conveyance of 9 .19 acres of Cheatham Lock and Dam Project Lands for Construction of a Flood Control Levee Project to Protect the A.O. Smith Facility in Ashland City, Cheatham County, Tennessee.

Dear Ms. Robinson:

U.S. Fish and Wildlife Service (Service) personnel have reviewed your correspondence dated May 6, 2019, in regards to the proposed conveyance of9.19 acres of Cheatham Lock and Dam project lands for construction of a flood control levee project to protect the A.O. Smith facility in Ashland City, Cheatham County, Tennessee. The levee would be constructed partially on the applicant's property and partially on lands currently owned by the U.S. Army Corps of Engineers. The following constitute the comments of the U.S. Department of Interior, provided in accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.) and the Endangered Species Act of 1973 (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.) (ESA).

Project implementation would result in the loss of approximately 17 forested acres of suitable summer habitat for the federally endangered Indiana bat (Myotis soda/is) and federally threatened northern long-eared bat (Myotisseptentrionalis). In support of the proposed action, Civil & Environmental Consultants, Inc. conducted a presence/probable absence mist-netting survey during the 2016 survey period. Although six (6) bats were captured during this survey, none were identified as federally protected species. This finding suggest probable absence of the [ndiana bat and northern long-eared bat within the action area. Also, the site occurs outside of any known occurrence buffers for these species and we are unaware of any other information suggesting presence.

Upon consideration of this information, the Service concurs with your determination that the proposed action is not likely to adversely affect the Indiana bat and northern long-eared bat. We are unaware of any other federally protected species that would likely be affected by the proposed action. Therefore, based on the best information available to the Service, we believe that the requirements of the Fish and Wildlife Coordination Act and section 7 of the ESA, are fulfilled. Obligations under section 7 of the ESA must be reconsidered if (l) new information reveals impacts of the action that may affect listed species or critical habitat in a manner not previously considered, (2) the action is subsequently modified to include activities not previously considered, or (3) new species are listed or critical habitat designated that might be affected by the action.

Thank you for the opportunity to comment on this proposed action. If you have any questions regarding the information which we have provided, please contact Dustin Boles at 931/525-4984, or by email at dustin_ [email protected].

Sincerely, f:1/F. 51- Robert E. Sykes Acting Field Supervisor CHEATHAM County Mayor COUNTY Kerry R. McCarver [email protected] A~#a<,e Phone: (615) 792-4316 touiidea~ Fax: (615) 792-200 I June 27, 2019

Amy Robinson, Project Manager West Branch Regulatory Division U.S. Army Corps of Engineers [email protected]

Cc: [email protected]

Re: Cheatham County Land Disposal and Ashland City Levee Project

Dear Ms. Robinson,

On behalf of Cheatham County, I write in total support of the Cheatham County Land Disposal project as it will allow for the construction of a levee by the A. 0 . Smith Corporation in Ashland City, Tennessee, which in turn will protect our largest industry and employer.

The catastrophic flooding of the Cumberland River in 2010 impacted our county causing millions of dollars in damages. The flood interrupted electric power as well as water and sewer plants near the A. 0 . Smith plant. The proposed project not only protects the A. 0. Smith property and plant, but also would protect the CEMC electric substation to keep power on to thousands of Cheatham County homes and businesses.

The local economic impact of A. 0. Smith down during and following the flood as well as weeks to bring all the jobs back on line dealt a blow to the local economy and was felt in sales tax revenues down for the county that took months to recover. All county sales tax collected go to local schools, so schools had to adjust to sustain the drop in sales tax revenue having an adverse effect on our schools. We learned what an impact A. 0 . Smith has on our local economy. Should the levee not be approved and lead to the eventual closing of the local plant, it would devastate our local economy that would ripple throughout all county services especia lly our education system.

The levee would not only protect A. 0 . Smith, but all Cheatham County would benefit from the construction and our best bet to reduce the impact of future flooding from the Cumberland River. I request the Corp of Engineers move swiftly to issue the necessary permits and permission for A. 0. Smith to move forward without further delay. The Cheatham County Commission one year ago, unanimously passed resolutions of support as well as needed construction and permanent right-of-way acquisition to A. 0 . Smith to keep this project moving.

If there is any way I can help with questions or information, please do not hesitate to let me

100 Public Square• Suite 105 • A hland City, TN 37015 Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Appendix B

Cultural Resources and the National Historic Preservation Act

B. 1 INTRODUCTION

Section 106 of the National Historic Preservation Act (54 USC 306108) requires federal agencies to consider the effects of their undertakings on historic properties and notify the Advisory Council on Historic Preservation. Historic properties are buildings, structures, sites, objects, districts or landscapes that meet specific criteria, have significance, and maintain integrity. 36 C.F.R. 800 directs a four-step process for federal agencies to follow to meet the intent of Section 106 process. Step 1 – Establish the Undertaking, identify appropriate State Historic Preservation Officer and other consulting parties, Step 2 – Determine the Scope of the Efforts, Identify Historic properties, Evaluate significance. If area of potential effects lacks historic properties, and consulting parties agree, then the Section 106 process is complete. Step 3 - if historic properties are present, then the federal agency evaluates the effects of the undertaking on the historic properties. If after consultation, all agree that there is no adverse effect to the historic properties, then the Section 106 process is complete Step 4 - If evaluation of the historic property concludes with an adverse effect to historic properties, then the federal agency must notify and invite the Advisory Council on Historic Preservation to consultation, and resolve the adverse effects through a Memorandum of Agreement.

B.2. SECTION 106 INITIATION

On May 6, 2019, the Corps provided a Public Notice (PN) the State Historic Preservation Officer (SHPO) and tribes with an interest in Cheatham County. The PN noted that additional information on historic property identification would be provided to the SHPO and Tribes when it is received. The Public Notice also invited comments from organizations and individuals with knowledge or concerns of historic properties to comment. In a letter dated June 14, 2019, the Corps provided a letter defining the Area of Potential Effects (APE) to the SHPO. In a letter dated June 25, 2019, the SHPO concurred with the APE and stated that they will continue to review the undertaking as expeditiously as possible with the submittal of additional information. As of 3 July 2019, the Corps awaits additional information from the applicant. B. 1. Summary of Section 106 initiation consultation.

Consulting Party Section 106 Comments letter Tennessee State Historic Preservation Officer Absentee-Shawnee Tribe of Oklahoma Alabama-Quassarte Tribal Town Cherokee Nation Chickasaw Nation Eastern Band of Cherokee Indians Eastern Shawnee Tribe of Oklahoma Muscogee (Creek) Nation, Oklahoma Shawnee Tribe United Keetoowah Band of Oklahoma

HISTORIC PROPERTY IDENTIFICATION A.O. Smith contracted with Civil Environmental Consultants, Inc. (CEC) to complete an archaeological survey of the proposed project area. To date one report and two addenda are complete. In addition, The Tennessee Department of Transportation investigated a portion of the APE for investigations related to an associated project. Changes to the project footprint require additional cultural resource surveys. The reports completed to date are:

Phase I Archaeological Survey for the A.O. Smith Flood Control Levee Construction and USACE Land Exchange, Ashland City, Cheatham County, Tennessee (CEC: 2016)

Phase I Additional Archaeological Survey of 5.7 HA (14 AC) Addendum to: Phase I Archaeological Survey for the A.O. Smith Flood Control Levee Construction and USACE Land Exchange, Ashland City, Cheatham County, Tennessee (CEC: 2017)

Phase I Second Additional Archaeological Survey of 4.1 HA (10.1 AC) Addendum to: Phase I Archaeological Survey for the A.O. Smith Flood Control Levee Construction and USACE Land Exchange, Ashland City, Cheatham county, Tennessee (CEC 2017)

Phase I Archaeological Assessment of SR-455, From 1,500 Feet South of SR-49 to SR-49 Ashland City, Cheatham County, Tennessee (Desert West 2018)

Two new archaeological sites have been identified through these investigations 40CH206 and 40CH209. CEC initiated a Phase II investigation of 40CH206 to determine whether the site is eligible for inclusion in the National Register of Historic Places. During the Phase II field investigations, A.O. Smith redesigned the levee to avoid 40CH206. CEC is completing a report on the Phase II investigations. TDOT through consultation with your office determined that 40CH209 is not eligible for inclusion in the National Register of Historic Places. The Corps concurs and recommends no further consideration of 40CH209.

CEC is completing surveys on previously uninvestigated areas. When the Corps receives the additional information, then the Corps will continue Section 106 consultation RECOMENDATION AND COMMITMENTS To be determined upon the completion of Section 106 consultation.

REFERENCES

Phase I Archaeological Survey for the A.O. Smith Flood Control Levee Construction and USACE Land Exchange, Ashland City, Cheatham County, Tennessee (CEC: 2016)

Phase I Archaeological Assessment of SR-455, From 1,500 Feet South of SR-49 to SR-49 Ashland City, Cheatham County, Tennessee (Desert West 2018)

Environmental Assessment U.S. Army Corps of Engineers Land Disposal and Construction of Levee Project Cheatham Lake

Appendix C

Project Plans

Public Notice 19-14 Attachment 4 of 6 File No. LRN-2012-00124

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HORIZONTAL SCALE SCALE IN FEET 0------30 60 A.O. SMITH VERTICAL SCALE FLOOD CONTROL PROJECT ASHLAND CITY SCALE IN FEET Civil & Environmental Consultants, Inc. CHEATHAM COUNTY, TN 325 Seaboard lane · Suite 170 · Franklin, TN 37067 0------6 12 615-333-7797 · 800-763-2326 PROPOSED LEVEE NOTES: www.cecinc.com CROSS SECTIONS 1. PLANS FOR PERMITTING PURPOSES DRAWN BY: BRO CHECKED BY: DRAFT APPROVED BY: DRAFT FIGURE NO.: ONLY, NOT FOR CONSTRUCTION. 1-D-AT_E_: ----J-UN-E-20_1_7t-D-W-G-SC-A-LE-:__ A_S_S_H_O_W_N-t-P-RO-J-EC-T-N0- ,----15-4--2-03--t EX-8 Public Notice 19-14 Attachment 5 of 6 File No. LRN-2012-00124

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HORIZONTAL SCALE SCALE IN FEET 0------30 60 A.O. SMITH VERTICAL SCALE FLOOD CONTROL PROJECT ASHLAND CITY SCALE IN FEET Civil & Environmental Consultants, Inc. CHEATHAM COUNTY, TN 325 Seaboard Lane • Suite 170 · Franklin, TN 37067 0------6 12 615-333-7797 · 800-763-2326 PROPOSED LEVEE NOTES: www.cecinc.com CROSS SECTION 8 1. PLANS FOR PERMITTING PURPOSES DRAWN BY: BRO CHECKED BY: DRAFT APPROVED BY: DRAFT FIGURE NO.: ONLY, NOT FOR CONSTRUCTION. I-D-AT_E_: ____J_U_N_E_2_0-17-+-DW_G_S_C_A_LE_ : ___A_S_S_H_O_W_N+P-R-0-JE_C_T_N0_: ____15-4--2-0--13 EX-C Public Notice 19-14 Attachment 6 of 6 File No. LRN-2012-00124

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0------30----- 60 VERTICAL SCALE A.O. SMITH FLOOD CONTROL PROJECT SCALE IN FEEf Civil & Environmental Consultants, Inc. ASHLAND CITY CHEATHAM COUNTY, TN 0------6 12 325 Seaboard Lane · Suite 170 · Franklin, TN 37087 815-333-7797 · 800-783-2328 PROPOSED LEVEE NOTES: www.cecinc.com CROSS SECTION C 1. PLANS FOR PERMITTlNG PURPOSES DRAWN BY: BRO CHECKED BY: DRAFT APPROVED BY: DRAFT FIGURE NO.: ONLY, NOT FOR CONSTRUCTION. --□-A-TE-: ____J_U_N_E_2_0-17-+- □-W-G-SC-A-LE_: ___A_S_S_H_O_W_N-+P-R-O-JE_C_T-N0_: ____15....;4..;;.-2..;;.0-'-13 EX-D