Update: I just received notice (1/19/12) that Whatcom County withdrew the SEPA determination of non significance (DNS) for the mining area designation for the quarry.
Nice chat with Joe Teeham on the radio this noon. The challenge of weighing need for aggregate and the fact that Whatcom County has tipped towards the remaining aggregate sources being located in either socially sensitive areas (near too many people), or in environmentally sensitive areas (next to the water and a natural resource conservation area), or in a site designated as forest resource land or agricultural resource land or too far from demand locations. Well done show that got the essence of the issues of aggregate mining.
The current hot mine issue is the proposal to expand a rock quarry on Lummi Island. This proposal will be located near people as there is a community immediately to the north. What is more this mine will require blasting and rock crushing and sorting. Lots of noise. The site also is immediately adjacent to the water. An advantage for shipping but the mine has already had a very hard time with stormwater. Most gravel mines are able to readily infiltrate stormwater. But in a quarry that is not so easily done. Another nagging issue is the mine apparently never got a permit to buid the pier it uses for loading barges. This proposal is also located in an environmentally sensitive area. And there are very legitimate concerns regarding long term stability of the rock cut slopes if the mine is allowed to expand.
Designation of this area as a mining area should come up for a vote by the Whatcom County Council sometime this next year. It is currently undergoing an environmental review under the State Environmental Policy Act (SEPA). However, the county has taken the position that detailed analysis of specific mine issues will be done during mine permitting versus designating the area as a mine area and has issued a determination of non significance. My comments submitted to the County:
Please accept these comments regarding the SEPA determination for the Lummi Island Quarry MRL expansion proposal. The SEPA analysis should an assessment of the entire MRL proposal area as though the area will be mined. The County Council is being asked to determine if the area adjacent to the mine should be protected as a future mining site and is being asked to make a determination of how mining in this area will impact other resource lands such as forestry, habitat and shorelines as well as nearby residences. The council can not do this with such a limited SEPA.
The dip slope of the bedrock in this area is oriented such that by mining to depth the dip slope of the bedrock will likely be undermined causing slopes above the mined area to be negatively impacted. This is a classic bedrock stability problem that if allowed to proceed will leave a long lasting slope stability problem that would render a large up slope areas much less stable than it currently is. It has been my experience assessing slope stability of Lummi Formation (the formation at the site) that the dip slopes are very uniform over large distances and thus subject to sliding when undercut because joint sets are perpendicular to the dip slope creating unstable blocks of bedrock if the dip slopes are cut.
There is no way to assess this possibility with the information provided in the SEPA checklist. And hence there will be no way that the council can determine if the source of rock is a viable source for designating. Designation of MRLs requires specific information about the quality of the material. Designations should also include specific information about the impacts of mining that material and the issue ought not to be deferred to some unspecific future date leaving parties including the County uncertain about the MRL.
Lest one think that I am opposed to mining, I have assisted in permitting a number of aggregate mines in other counties. None of those mines had anywhere near the impacts the Lummi Quarry will have and all were substantially larger.
Nice chat with Joe Teeham on the radio this noon. The challenge of weighing need for aggregate and the fact that Whatcom County has tipped towards the remaining aggregate sources being located in either socially sensitive areas (near too many people), or in environmentally sensitive areas (next to the water and a natural resource conservation area), or in a site designated as forest resource land or agricultural resource land or too far from demand locations. Well done show that got the essence of the issues of aggregate mining.
The current hot mine issue is the proposal to expand a rock quarry on Lummi Island. This proposal will be located near people as there is a community immediately to the north. What is more this mine will require blasting and rock crushing and sorting. Lots of noise. The site also is immediately adjacent to the water. An advantage for shipping but the mine has already had a very hard time with stormwater. Most gravel mines are able to readily infiltrate stormwater. But in a quarry that is not so easily done. Another nagging issue is the mine apparently never got a permit to buid the pier it uses for loading barges. This proposal is also located in an environmentally sensitive area. And there are very legitimate concerns regarding long term stability of the rock cut slopes if the mine is allowed to expand.
Designation of this area as a mining area should come up for a vote by the Whatcom County Council sometime this next year. It is currently undergoing an environmental review under the State Environmental Policy Act (SEPA). However, the county has taken the position that detailed analysis of specific mine issues will be done during mine permitting versus designating the area as a mine area and has issued a determination of non significance. My comments submitted to the County:
Please accept these comments regarding the SEPA determination for the Lummi Island Quarry MRL expansion proposal. The SEPA analysis should an assessment of the entire MRL proposal area as though the area will be mined. The County Council is being asked to determine if the area adjacent to the mine should be protected as a future mining site and is being asked to make a determination of how mining in this area will impact other resource lands such as forestry, habitat and shorelines as well as nearby residences. The council can not do this with such a limited SEPA.
The dip slope of the bedrock in this area is oriented such that by mining to depth the dip slope of the bedrock will likely be undermined causing slopes above the mined area to be negatively impacted. This is a classic bedrock stability problem that if allowed to proceed will leave a long lasting slope stability problem that would render a large up slope areas much less stable than it currently is. It has been my experience assessing slope stability of Lummi Formation (the formation at the site) that the dip slopes are very uniform over large distances and thus subject to sliding when undercut because joint sets are perpendicular to the dip slope creating unstable blocks of bedrock if the dip slopes are cut.
There is no way to assess this possibility with the information provided in the SEPA checklist. And hence there will be no way that the council can determine if the source of rock is a viable source for designating. Designation of MRLs requires specific information about the quality of the material. Designations should also include specific information about the impacts of mining that material and the issue ought not to be deferred to some unspecific future date leaving parties including the County uncertain about the MRL.
Lest one think that I am opposed to mining, I have assisted in permitting a number of aggregate mines in other counties. None of those mines had anywhere near the impacts the Lummi Quarry will have and all were substantially larger.
I don't understand how a SEPA checklist used to evaluate rock quarry mining can NOT HAVE questions about the dip slope and rock material. Just because they're crushing it into gravel, doesn't mean they're mining unconsolidated material.
ReplyDeleteAlso, it's a major shortcoming of our system that this operation is allowed to start with unpermitted practices, the pier, and continues constantly with unpermitted practices, expanding before they had permission then applying afterward, and yet they are still allowed to operate. Makes no sense. Why would any mining operation follow the rules?
Niki - good points. The SEPA determination for this project was withdrawn by the county as of 1/19/12.
ReplyDeleteMartha G said>>>
ReplyDeleteI can understand that this could be a problem in a densley populated area however I have been to the Island and I really don't think that this is much of an inconvenience to the neighbors as you would have us believe. It should also be noted that this company that is doing the mining has not given the industry a bad name. They also operate in other areas and are well respected in those areas. Mr. McShane i gather that you live on the Island therefore you do not want the quarry however the quarry does provide jobs and yes it is true that the resources of gravel are limited.
It all goes back to the same old thing not in my back yard. Well whose yard would you suggest that a gravel quarry be in????? We need gravel.
PS> there are other gravel companies that have had citations so I take offense to the idea of this mining company giving a bad name to the industry
Martha: I do not live on the island or anywhere near the proposed mine expansion.
ReplyDelete