PHOTO courtesy of George & Joyce Chase "Kings Highway" "reservoir" mine pit dewatered depressional wetland is in the right foreground. The scale is shown by the ant-like construction vehicles near the top and bottom of the retaining wall around the "reservoir" mine pit |
Mining Impacts to the Human and Natural Environments A compilation of resources and issues
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PHOTO courtesy of George & Joyce Chase "Kings Highway" "reservoir" mine pit drained depressional wetlands in the background |
Tom Warnke
comment letter to the Corps (June 28, 2010):
Hello Dan,
Florida's precious fresh water and watershed system includes above-ground
water and also the water in our aquifer systems. As Geologists and
Hydrologists know, the amount of water in our above-ground watershed is
dwarfed by the amount of water in our aquifers.
The 5.5 mile addition to the Tamiami Trail bridge plan will include an
enormous amount of concrete, utilizing aggregate rock mined in South
Florida. The cumulative impact of rock mining to our aquifer system here in
South Florida is just now being realized, and such mining is very harmful to
protected habitat. These external costs of such aquifer rock mining are not
included in the cost per truckload.
The harmful impacts to the Biscayne Aquifer and Floridan Aquifer systems
include a substantial net loss of water by way of dewatering from increased
evaporation, resulting hydroperiod alterations which directly harm wetlands
and upland forests. As you know, these areas are "Critical Habitat" for many
species included in the Endangered Species Act and the National
Environmental Policy Act. Our aquifer system cannot provide water for these
areas if that water is severely depleted by rock mining.
As an example of how significant a consideration this is, The Army Corps
decided this month to conduct a complete assessment of the entire Peace
River Watershed to determine the cumulative impacts to Florida's Aquifer
system from mining in that watershed. Please refer to the article at the
following link, and include it as part of my comments for additional reference:
http://www.sunnewspapers.net/articles/pnnews.aspx?NewsID=459068&a=newsarchiv
e2/062510/ch1.htm&pnpg=0
My comment is that the Corps must include the alternative of using only
recycled concrete and/or asphalt material in the construction of the 5.5
mile bridge extension to the Tamiami Trail.
Here are some of the steps to take:
1. Estimate the amount of aggregate material to be used in the entire
project, including the bridges and re-paving; and publish this amount in
cubic yards of material so the public will know the size of the aquifer
exposure.
2. Include the list of probable/possible source mine locations in published
reports/EIS pertaining to the project so the public will have notice about
the locations of the inevitable harmful impacts to Florida's aquifer system
being created by the project.
3. Estimate the economic cost of using recycled aggregate for the entire
project, vs the cost of using virgin mined aggregate from the aquifer and
publish those cost comparisons of both sources in documents related to the
project. This relates directly to federal requirements which require
alternatives to be considered for such a project.
4. Weigh the economic costs against the harm to the environment -
Identifying who will benefit from, and who will pay the costs of the proposed
project, as well as where the harm would occur, and publish all of that
information in reports pertaining to the proposed project.
5. Provide information regarding securing and allocating funding from
appropriate sources to utilize recycled aggregate for the entire project,
including providing cash incentives for public and private entities to receive
cash incentives for providing materials from existing paved, impervious surfaces
(especially if those surfaces are converted to pervious surfaces) to be used for
this project. As an example, a source very close in proximity to the proposed
project is the Everglades Jetport, which includes a significant source of
material which could be utilized as recycled aggregate for the Tamiami Trail
bridge extension, including a two-mile runway and extensive taxiways. Here is a
quote from 2004 about the Jetport facility:
"However, with the advent of high fidelity Level C & Level D flight simulators,
airline pilots can now be trained exclusively in simulators,
without resorting to much more expensive training flights in actual aircraft.
Therefore, this use of Dade Collier Training & Transition Airport has largely
gone away, leaving the field once again almost completely unused."
The 2003 Airport Facility Directory listed an average of 40 flight operations
per day, but that is almost definitely an exaggerated figure.
The 2003 Airport Facility Directory included the remark, "Airport closed to
public except by arrangement with Dade County Aviation Department Miami."
In June 2010 Miami Dade County announced plans to attempt to generate income
from "non-aviation" types of uses at the site.
6. Designate the Tamiami Trail bridge extension as a model/pilot project
utilizing recycled aggregate materials, so other projects across the United
States will be able to allocate the funds necessary to avoid the harmful
environmental impacts of aquifer rock mining.
Utilizing recycled aggregate material will require allocation of additional
funds in order to balance the significant "external costs" of using virgin of
funds, however this funding will provide significant direct benefits to the same
environment the bridges are designed to help. As a result, the cost/benefit
analysis will show that utilization of recycled materials provides significant
benefits which justify any additional expenditure for the use of virgin
aggregate materials, based on a cost that does not include the cost of
environmental harm.
Thank you for your consideration, and please acknowledge receipt and
inclusion of this comment letter in the record for the project.
Tom Warnke
trwarnke@hotmail.com
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Last updated June 29, 2010
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