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Phosphate Mining Comment Letter
August 9, 2001
Colonel James G. May, District Engineer
Atten: Charles A. Schnepel Charles.A.Schnepel@saj02.usace.army.mil
Atten: John Hall john.r.hall@saj02.usace.army.mil
Department of the Army
Jacksonville District Corps of Engineers
Tampa Regulatory Office
P. O. Box 19247
Tampa, FL 33686-9247
Re: C. F. Industries, Inc.: Rock Mining of 8,558 acres in Hardee County
Permit Application 199301395 (IP-CS) MOD#8
Recommended Denial/Request for Public Hearing
Request for Statewide Environmental Impact Statement (EIS)
Dear Colonel James G. May:
I am writing in response to Permit Application 199301395 (IP-CS) MOD#8 regarding the proposed mining of 8,858 acres of Florida's regional aquifer system for phosphate rock by C. F. Industries, Inc. in Hardee County. The information was included in your Public Notice with an expiration date of August 19, 2001, as posted on your website (http://www.saj.usace.army.mil/permit).
I am directing this letter to your attention because Florida's regional aquifer system is in a state of crisis. It is analogous to a multiple stab-wound victim, hemorrhaging from every artery due to gouging wounds inflicted over its body by the mining industry. As its life blood is pumping out of the countless gaping wounds - gargantuan pits left behind by rock mining, sand mining, peat mining and similar activities - your agency muses over administering an IV in the form of aquifer "storage" and recovery (ASR). The cost to taxpayers for ASR would be billions of dollars, while NO attempt is being made to control the hemorrhaging!
The referenced, proposed permit application would be the fatal blow to the west-central Florida area where the proposed project would occur. That area of the state is teetering on the brink of collapse from massive groundwater withdrawals and excavations of the actual structure of the aquifer system. For a graphic display of only some of the structural damage that has occurred to the aquifer system in that area, please refer to the 1998 USGS report by Lewelling et al. that is cited below. The report should be accessible from the Tampa area USGS office.
That report contains dramatic photographs of catastrophic collapse of the earth's surface due to the massive volumes of ground water being withdrawn to process the mined phosphate. Also contained in that report are seismic-reflection profiles illustrating all of the structural weaknesses in the rock formations of that area. Those fractures and collapse features are exacerbated and magnified by the constant removal of the ground water by mining activities, such as the one proposed for permitting in the referenced public notice.
After reading that report, answer the following question honestly:
"HOW BAD DOES IT HAVE TO GET BEFORE YOUR AGENCY RECOGNIZES THAT THE IMPACTS ASSOCIATED WITH THESE MINING ACTIVITIES ARE UNMITIGATABLE?"
The groundwater impacts are not constrained to the mechanical removal of ground water. Please refer to the 1989 publication by Curtis, listed with the other citations below. The excavation of the mine pits causes the water from the surficial aquifer to pour into the pits. That conversion of ground water into surface water also results in the significant increase in loss of water to the atmosphere, via evaporation. These combined impacts represent two additional forms of "consumptive use" of ground water that have not been identified or accounted for in the referenced application.
So-called "recharge ditches", that have been touted as a means of preventing the drainage of wetlands (by rimming the wetlands with these so-called "recharge ditches"), are the equivalent of a parachute made of concrete. Even if there was some shred of evidence that the so-called "recharge ditches" prevented the drainage of unmined wetlands on the site - DOES YOUR AGENCY HAVE ANY SUCH EVIDENCE? - what would prevent the drainage of offsite wetlands and all of the upland habitats that have no such ditches?
To provide a more in-depth perspective of the magnitude of impact associated ONLY with the water quantity aspect of the proposed mining project, I have enclosed a copy of the 2-page abstract from the 1998 report by Lewelling et al. (referenced above) with the hard copy of this letter that is being mailed to Mr. Schnepel. The abstract describes impacts such as:
1. "a progressive long-term decline in streamflow" that "has occurred since 1931 due to a lowering of the potentiometric surface of the Upper Floridan aquifer by as much as 60 feet because of intensive ground-water withdrawals for phosphate mining and agriculture";
2. "cessation of flow at several springs located near and within the Peace River channel, including Kissengen Spring, that once averaged a flow of about 19 million gallons a day";
3. "flow reversals at locations where streamflow enters sinkholes along the streambed and floodplain"; and,
4. "vertical or enlarged solution conduits.
The "Mitigation" section of the referenced public notice includes "tallies" under categories of "The Pre-Mining Footprint" and "The Reclamation Footprint". Those categories address only the "SURFACE FOOTPRINT" of the proposed mining activity. Because of the conditions referenced above, the actual, or "SUBSURFACE FOOTPRINT" of the proposed activity will be immense.
The public notice indicates that 3,470 acres of wetlands would be "impacted" by the proposed project. If that figure is added to the remaining acreage which is not proposed to be "protected" (4,188 acres?) that total would represent the "SURFACE FOOTPRINT" of the proposed mining activity. Add to that total the 1,200 acres of wetlands on the site that are purported to be "preserved", and the countless acres of wetlands, uplands and streams offsite that would be destroyed by the proposed project, and that huge (but undetermined) amount represents the actual, or "SUBSURFACE FOOTPRINT" of the proposed project. To assist you in visualizing this concept, trying to stretch the proposed mitigation to offset the total acreage of project impacts (assuming there was some evidence it would be successful) would be equivalent to "Big Foot" trying to put on a Barbie doll shoe.
To reiterate, based solely on the water quantity impacts that would result if the proposed permit was issued, all of the wetlands that are proposed to be "preserved" in the referenced application would be destroyed, as well as the wetlands, uplands and streams on surrounding, offsite areas. Examples of specific areas that would experience severe adverse impacts include: Horse Creek, Gum Swamp Branch, Shirttail Branch, Lettis Creek, Doe Branch, Troublesome Creek, Plunder Branch, Brushy Creek and Coon's Bay Branch. There is strong evidence suggesting that coastal habitats also would experience adverse impacts (beyond the existing impacts to those systems) due to reductions in submarine groundwater discharge.
Depressional wetlands in the general vicinity of the proposed mine would be one of the most sensitive and susceptible habitat types to the groundwater impacts described above. These depressional wetlands provide critical nesting and foraging habitat for wood storks, a federally-endangered species. According to the referenced public notice, your agency "made a determination that the proposed work may affect but is not likely to adversely affect wood storks, indigo snakes, Florida scrub jays, red-cockaded woodpeckers, and eagles." Certainly that must have been a typographical error. Based on water quantity impacts alone, the proposed project will, with every degree of scientific certainty, have profound adverse impacts on all of the referenced species, via total destruction of their habitat and sources of food.
Please refer to my sworn Affidavit that was submitted with Case No. 99-286-CIV-J-16B and Case No. 01-11179-B, 11th Circuit Court against your agency for a more detailed description and photographs of the precise type of damage that will occur to wood storks. I also refer you to the examples of relevant published literature listed below, as well as to the comments I submitted previously for the proposed mass mining of the aquifer system (referred to as the "Miami Lake Belt" project) in the Everglades, and the proposed E. R. Jahna Industries, Inc. mining project (Permit Application No. 19964304 (IP-JB)) in the Green Swamp, for a more detailed discussion of those impacts.
The adverse impacts associated with mining will not be confined to water quantity impacts. Severe water quality impacts also are predicted to occur. One example of such impacts include potential phosphorus loading of downstream ecosystems, including areas as far away as Florida Bay and the Florida Reef tract. Apparently your agency has not considered the potential for iron loading to downstream ecosystems, another such impact, although ample evidence exists to suggest this occurring. Additions of iron at the nM levels have been shown to trigger phytoplankton blooms in coastal waters and may be a significant factor in the red-tide outbreaks in the Gulf of Mexico. These red-tide outbreaks have been identified as a causal factor in the death of numerous manatees, another federally-listed species.
The highly publicized acid mine drainage problems associated with other types of mining activities in more northern states pale in comparison to the impacts that have occurred in the vicinity of the rock and related mines in Florida. There is a plethora of scientific support for my statements regarding the myriad adverse environmental and economic impacts that are occurring, and will be magnified to the point of ecosystem (habitat) collapse, if the proposed project is permitted.
Obviously the proposed project could not be considered "not contrary to the public interest", nor could it be considered "in the public interest". Furthermore, there is no evidence that any semblance of an "Alternatives Analysis" has been conducted for the proposed project. For example, the "no mining" alternative was selected for a recently proposed mining operation in the vicinity of the Okefenokee Swamp in Georgia. The impacts from that proposed mining operation was minuscule in comparison to the impacts that are occurring from the phosphate mining in Florida. Numerous environmentally (and economically) sound alternatives to phosphate mining are available, but apparently have not been considered by your agency.
It is apparent that your agency's permit review staff, throughout the entire State of Florida, is unaware of the large-scale impacts to the regional aquifer system inflicted by these types of mining projects. This serious agency deficiency, combined with the fact that federal, state, and local taxpayers are being expected to shell-out BILLIONS of dollars to reverse the damage to the Florida's aquifer system, while your agency simultaneously inflicts more wounds, should be sufficient justification for the initiation of a full Congressional investigation of such gross violations of the Clean Water Act and other federal and state laws. Additionally, your agency immediately should initiate a Statewide Environmental Impact Statement (EIS) to address the impacts of all existing and pending mining activities on Florida's regional aquifer system.
In the interim, the proposed permit application should be denied, or a series of Public Hearings should be scheduled to be held throughout the entire southern half of the state to address the countless adverse impacts that the proposed project would have, if it was implemented. If the permit is not denied, a full Section 7 consultation should be conducted.
For your convenience I have attached rtf files of my referenced letters of comments, and pasted those letters below. I also have forwarded hard copies of those comments, with this letter, to Charles Schnepel of your Tampa office. Also forwarded to Mr. Schnepel are reprints of my articles referenced below (except for the most recent article for which I have not received reprints yet) and the article by Curtis. My letters of comments address only some of the countless environmental and economic problems associated with mining the regional aquifer system in Florida.
Thank you for the opportunity to provide comments. By copy of this letter I am formally requesting an actual copy of any proposed agency action for the proposed project referenced above. I also am formally requesting that all other concerned citizens and groups join me in requesting agency accountability for the demise of our priceless natural resources and economic well-being.
Examples of Relevant Literature:
Bacchus, S. T. 2001. Knowledge of groundwater responses - A critical factor in saving Florida's threatened and endangered species. Part I: Marine ecological disturbances. Endangered Species Update 18(3):79-90.
Bacchus, S. T. 2000. Predicting nearshore environmental impacts from onshore anthropogenic perturbations of ground water in the southeastern Coastal Plain, USA. pp. 609-614 in: Interactive Hydrology: Proceedings of the 3rd International Hydrology and Water Resources Symposium of the Institution of Engineers, Australia, 20-23 November 2000 Perth, Western Australia.
Bacchus, S. T. 2000. Uncalculated impacts of unsustainable aquifer yield including evidence of subsurface interbasin flow. Journal of American Water Resources Association 36(3):457-481.
Bacchus, S. T., T. Hamazaki, K. O. Britton and B. L. Haines. 2000. Soluble sugar composition of pond-cypress: A potential hydroecological indicator of groundwater perturbations. Journal of American Water Resources Association 36(1):1-11.
Curtis, T. G. 1989. Estimating Unsteady Water Table Behavior Using Boundary Integral Approximations. pp. 298-310 in: J. E. Moore, A. A. Zaporozec, S. C. Csallany, and T. C. Varney (eds.). Recent Advances in Ground-water Hydrology. American Institute of Hydrology.
Lewelling, B. R., A. B. Tihansky, and J. L. Kindinger. 1998. Assessment of the Hydraulic Connection Between Ground Water and the Peace River, West-Central Florida. USGS Water-Resources Investigations Report 97-4211. 96 pp.
Enclosures
Sincerely,
Sydney T. Bacchus, Ph. D.
Hydroecologist
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