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SUBMIT PUBLIC COMMENT ON TWO PERMITS
In-river dredging in Shawnee County, Off-river pit mine near Eudora

DEADLINE: March 9, 2011


River dredging endangers water quality, erodes the river channel and banks, and puts key infrastructure at risk. Through 2012, all in-river dredging permits on the Kaw will come up for review before the Army Corps of Engineers. Several permits for off-river sand pit mines are also expected to get underway. This moment represents a historic opportunity for the Kaw's supporters to:
  • STOP in-river dredging on the Kaw - dredging is a bad idea for a long list of environmental, economic, and scientific reasons. Download our fact sheet.
  • STAND UP for the appropriate siting of pit mines - sand can be mined sustainably and economically with respect for the river ecosystem
MAKE YOUR VOICE HEARD:

Public comment on each of the following two permits is due by March 9, 2011. Comments should be submitted separately for each permit, and each comment should refer to the official permit number listed below. (See our press release.)

Permit requesting to re-open in-river sand dredging site in Shawnee County
Permit No. 2003-1759
For a copy of the permit and Friends of the Kaw's analysis, click here.
For a sample public comment, click here.

Permit for proposal to construct commercial sand pit mine west of Eudora in river flood plain
Permit No. 2009-1688
(Note: Comments on this permit must be submitted to both KDHE and USACE - KDHE only accepts comments in writing)
For a copy of the permit and Friends of the Kaw's Analysis, click here.
For a sample public comment, click here.


For the USACE, comments on both permits may be emailed by or on March 9 to Kale.E.Horton@usace.army.mil. (Please feel free to cc the Riverkeeper your comments as well, at riverkeeper@kansasriver.org.) Comments may also be submitted in writing with a postmark date of March 9, and should be addressed to the attention of Kale Horton, U.S. Army Corps of Engineers, Kansas City Regulatory Office, 635 Federal Building, 601 East 12th St., Kansas City MO, 64106. For questions or additional information from the Corps, please call (816) 389-3656.

For the pit mine permit, comments must also be sent in writing to the Kansas Department of Health and Environment, Bureau of Water - Watershed Management Section, 1000 SW Jackson St, Ste 240, Topeka KS 66612-1367.

Check the FOK website for extensive research about dredging and pit mines - especially the environmental and economic impacts, and the current scientific research now underway. Also download our fact sheet.

Friends of the Kaw has been fighting this battle since 1991, and we welcome your support.



PUBLIC COMMENT IS DUE MARCH 9
For the U.S. Army Corps of engineers, comments may be emailed by or on March 9 to Kale.E.Horton@usace.army.mil. (Please feel free to cc the Riverkeeper your comments as well, at riverkeeper@kansasriver.org.) Comments may also be submitted in writing with a postmark date of March 9, and should be addressed to the attention of Kale Horton, U.S. Army Corps of Engineers, Kansas City Regulatory Office, 635 Federal Building, 601 East 12th St., Kansas City MO, 64106. For questions or additional information from the Corps, please call (816) 389-3656.

Comments must also be sent in writing to the Kansas Department of Health and Environment, Bureau of Water - Watershed Management Section, 1000 SW Jackson St, Ste 240, Topeka KS 66612-1367.

GENERAL

Friends of the Kaw supports appropriately sited pit mines as an alternative to in-river dredging (download our fact sheet). Off-river mining can reduce the negative environmental impacts of river sand dredging and provide an economically feasible source of sand for road building and construction. We limit our analysis to the environmental impacts, and recognize that communities and regulatory agencies must also consider issues such as land use practices and traffic flow.  For more information about the permitting process click here

From the consumer's point of view:
  • Sand from pit mines in the river valley is identical to sand obtained from the river
  • Our survey has shown that there is no difference in price to the consumer
  • In-river dredging is vulnerable to periods of high water and floods, while pit mines are a more reliable source
To reduce the impact of pit mines on the river:
  • Avoid placing pit mines in the 100 year flood plain, so they are not captured by the river during high water events and do not release excess pollution back into the river
  • Preserve the riparian ecosystem and avoid destabilizing river bends - do not remove trees in the riparian zone
  • Consider the history of the river channel at that site - pit mines should not be sited in locations that are historically unstable
  • If fill is used it must be clean fill so that it does not cause groundwater contamination, and regular monitoring should take place
  • A quality, practical restoration plan should be in place for when the pit mine ends production
DOUGLAS COUNTY/ EUDORA - PERMIT #2009-1688 OFF-RIVER PIT MINE
Kaw Valley Companies has applied jointly to the Army Corps of Engineers and the Kansas Department of Health and Environment (KDHE) for a permit to develop a 197 acre site with an off-river sand pit mine near 2102 North 1500 Road in Eudora. Public comment on the project is due March 9. A conditional use permit will also be required from Douglas County to develop the property into a sand mining operation. At the end of the thirty year operation, reclamation of the site will be administered by the State Conservation Commission in accordance with the Surface-Mining Land Conservation and Reclamation Act.
  • The proposed project will require the construction of a sand processing plant, an open dredge pit for the excavation of sand, access roads, settling basins, stockpile areas, and buildings
  • The open dredge pit will encompass approximately 114 acres
  • Process water will be drawn from the Kansas River through an intake structure and discharged to settling basins before being returned to the river.  A National Pollution Discharge Elimination System (NPDES) permit should be required for this discharge because process water will be used to wash sand from the pit.  The site was previously used as a golf course and possibly used fertilizers, herbicides and other chemicals on the grounds.
  • A 300-foot setback from the Kansas River is proposed and will be maintained along the entire project boundary
  • The water intake structure will be constructed adjacent to an existing jetty within the river
ANALYSIS

While Friends of the Kaw supports appropriately sited off-river pit mines as an alternative to in-river mining, we believe that care must be taken to minimize harm to the river. Our concerns with this proposed site focus exclusively on its potential impacts to the river; city and county commissions and the community will determine the appropriateness of the site with regards to traffic and other factors affecting local residents.
  • The site is on a bend that is actively eroding, and a great deal of money has been spent to stabilize it with wing dikes to protect the Eudora bridge
  • The recently added wing dikes deflect the river over towards the western bank-- exactly where they are proposing to pit mine
  • The western bank is currently stabilized by a wide band of riparian forest
  • The proposed excavation site will remove all but a 300 foot band of trees
Bottom line: Given the highly dynamic nature of the river in this reach, the fact that we don't yet know how the new wing dikes will affect the western bank, and the fact that the pit is located at a low elevation that makes it vulnerable to flooding, we believe that a 300 foot set back is not enough to protect the bank and prevent the river from potentially altering its channel during high water events.

click on photo icons to enlarge





PUBLIC COMMENT IS DUE MARCH 9
For the U.S. Army Corps of engineers, comments may be emailed by or on March 9 to Kale.E.Horton@usace.army.mil. (Please feel free to cc the Riverkeeper your comments as well, at riverkeeper@kansasriver.org.) Comments may also be submitted in writing with a postmark date of March 9, and should be addressed to the attention of Kale Horton, U.S. Army Corps of Engineers, Kansas City Regulatory Office, 635 Federal Building, 601 East 12th St., Kansas City MO, 64106. For questions or additional information from the Corps, please call (816) 389-3656.

GENERAL
Friends of the Kaw strongly objects to in-river sand dredging for a variety of economic and environmental reasons.
The Army Corps of Engineers must deny permits to continue this damaging, high-impact practice. Dredging companies can affordably mine equal or higher-quality sand off-river at appropriately sited pit mines. (Download our fact sheet.)

IN-RIVER DREDGING COSTS KANSANS BY….
  • Endangering water quality. Dredging stirs up silt that kills mussels and other aquatic life and is expensive to remove from drinking water.
  • Increasing pollution. Dredging churns up old industrial pollutants - like PCBs and heavy metals - that have settled to the river bottom, adding to the river’s contamination levels.
  • Threatening key infrastructure. Dredging damages and destabilizes the river channel and endangers expensive, valuable infrastructure such as bridges, flood control structures, intake pipes for public water supplies, power plants, manufacturing, etc.
  • Jeopardizing riparian property rights. The river automatically seeks to fill the holes that dredging creates – and it does so by carving soil away from the riverbanks, leading to the loss of some of our nation’s most valuable farmland.
  • Causing hazardous conditions for recreational boaters. Dredging cables that attach the rigs to the banks are often hidden underwater, and are dangerous for recreational river users.
ANALYSIS: RIVER MILES 90.1-91.6 IN-RIVER DREDGE PERMIT, SHAWNEE COUNTY

Meier's Ready Mix has applied for a permit to reopen a dredging site in Topeka that was closed because the river bottom had lowered too far to continue dredging.
The dredge was closed down after the 2005 survey because the Army Corps found that the average river bottom elevation lowered by 2.2 feet compared to 1992 baseline data. When it drops by 2 feet below the baseline in a five mile reach over a period of five years it triggers an automatic closure.

Then in 2009 the river bottom rose back up from 2.2 to 1.4 feet below the baseline. That's good, because it means that sand was being added to the bottom. But then in 2010 it went back down again, from 1.4 to 1.79 feet below baseline. That's bad, because it means that even without dredging the river bottom is going down-- it's losing sand.

The bottom line for the Army Corps is that in 2009 and 2010 the river bottom was above the "red line" (-2 feet below baseline) and they can now open it for dredging.

The bottom line for Friends of the Kaw is that from 2009 to 2010 the river bottom lowered and is fast approaching the "red line," making it foolish to prematurely open a previously degraded reach before it has recovered.

If issued, this permit would be valid until December 31, 2012 and will then be re-evaluated in the next permit cycle with all Kansas River dredging proposals. So why the rush? Why not get one more year of measurements to see if the downward trend will continue before fully evaluating this permit along with all the others?


Click here to see the graphs and maps of the dredge site
Click here to see the permit request

Comments are due by March 9, 2011




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