2/8/2024
TO:
Park County Planning Department
856 Castello Ave
Fairplay, CO. 80440
(719) 836-4292
[email protected]
I am writing on behalf of the more than 1000 members of the Pikes Peak Chapter of Trout Unlimited. We are voicing our concern over the application for an asphalt plant on the Middle Fork of the South Platte River. Locating an asphalt plant on a river will threaten the immediate riparian habitat for all living biota, including human beings.
Asphalt is a proven source of Polycyclic aromatic hydrocarbons (PAHs), which are carcinogenic pollutants that are especially toxic in riparian habitat systems due to being bio-accumulated, meaning, the PHA content is concentrated up the food chain. An asphalt plant will also require large storage areas for fuel. These conditions add up to a highly precarious situation:
1. RIVER
2. PHAs
3. FLOODING
The Conditional Use Permit written by Lewiki &Associates did not address or even mention PHAs. In particular, Lewiki’s evaluation of the site location’s propensity for flooding and catastrophic consequences of a 100 year flood is greatly underestimated.
For comparison, we urge Park County Planning Commission to review the findings on hydrology and flooding as recorded by SRK in their site assessment of the Middle Fork the South Platte River in this exact same location for due diligence study in support of the US Highway 285 / CO 9 intersection project.
FOUR ASPECTS TO CONSIDER REGARDING APPLICATION FOR ASPHALT PLANT PERMIT
1. THE MIDDLE FORK OF THE SOUTH PLATTE RIVER: A RECOVERING RIVER
SYSTEM
• Freestone waters
The Middle Fork of the S Platte River is a unique unimpeded natural river classified as a Freestone Stream, meaning the water is derived from runoff. The engineered outlet at Fairplay Beach ponds the river to a FEMA specified level and allows continued flow through the aperture of the outlet. The health of the Middle Fork of the South Platte River in Fairplay, as a Freestone Stream, is completely dependent on the health of the headwaters upstream. By inference, the health of the South Platte River downstream of Fairplay is directly dependent on the health of the Middle Fork upstream in Fairplay.
• Healthy river system
A healthy river is a connected system of multiple interacting communities of organisms living in balance within fluctuating conditions of chemical and physical properties, such as, pH, dissolved oxygen, temperature, clarity, and salinity (affects the Specific conductivity. or the water’s capability to pass electricity and enable the chemical reactions that occur within the aquatic community.) The whole system includes the river bottom (substrate) of sediments (cobbles, granules, sand, and pebbles), hydraulic flow, structure, and depth. Disruption of any of these balanced elements results in a degraded health status, possibly a sterile river.
• Recuperation from 100+ years of dredge mining
The Middle Fork of the S Platte is in a state of recuperating from 100 years of hydraulic mining – a total removal of the substrate and interruption of a balanced freestone stream. Without the substrate, the river had no underwater flora, microscopic communities, macro- invertebrates, no plants, and no fish.
This condition may have also impacted historic bird life as well.
Modern mining technology has evolved to operate within strict environmental standards. The costs of hiring environmental scientists and performing due diligence of environment impact studies, including depositing money into Escrow to cover the costs of future reclamation is the only means by which a modern mining company can operate.
Small-time mining operations do not usually have the resources to address the environmental impact of their operations. Those mining permits must be scrutinized and supervised by governing agencies at the cost to taxpayers to ensure the protection of natural resources.
Aggregate quarries are even further removed from having to adhere to the scrutiny of environmental assessment that larger mining operations are subjected to. As a result – the smaller mining operations, especially quarries, commonly cause unanticipated environmental impacts. This can be seen along the Colorado Mineral Belt where open pits and tunnels of small independent mining operations and their tailings and drainage have never been mitigated. Aggregate operations disturb the natural habitat, impacting local ecosystems. The quarry runoff carries sediment and pollutants into nearby aquatic ecosystems with adverse effects on both plant and marine life. Quarries have airborne issues with pollutants and dust as well to mitigate.
IN SUMMARY, the Middle Fork of the South Platte is a fragile and unique ecosystem that is currently recuperating from historic mining and is now in the path of additional disturbance that is highly likely to destroy the aquatic community in the vicinity of Fairplay.
2. PHA CONTAMINATION
• Chemistry: Polycyclic aromatic hydrocarbons (PAHs) are carcinogenic pollutants associated with mutagenic (aberrant cellular growth) effects. Asphalt production (and use of asphalt products, such as paved parking lots), is a major source of Polycyclic Aromatic Hydrocarbons (PAHs) creation. This is not speculation, this is a factual, well- documented type of contamination associated with asphalt. The most serious impact of an asphalt plant on the Middle Fork of the South Platte River will be contamination of the river and lake sediments from deposition of PAHs, which are microscopic on a molecular level.
Remediation of these compounds is difficult and expensive. PAH’s are highly mobile and lock onto silt particles like glue. The dissolved contaminants become absorbed into the living biota of the hydrologic community by means of ingestion.
PHA contamination of a body of water will render the fish toxic to human consumption.
• Runoff
PHAs dissolve and are mobile in solution. PHA’s (carbon and hydrogen) adhere to the surface of dust particles and are suspended in the atmosphere until being deposited by rain or dry settling in distal places. PHA’s settle on the surface of water bodies and are dispersed by streams to eventually become integrated with the sediment of river and lake bottoms. Runoff water flowing over asphalt-based sources – even from automotive exhaust on adjacent high-use roadways - will contaminate nearby water bodies.
PHA particles derived from an asphalt plant upstream of the Fairplay Beach would be transported via atmosphere and runoff by the river and settle out in the mud of the Fairplay Beach, where it would be concentrated and absorbed into the biota – microscopic organisms, macro-invertebrates and fish – and HUMANS if the fish are eaten.
• Catastrophic toxicity – inedible fish
PAHs are bio-accumulated, which means the concentrations of PAHs found in fish will be much more concentrated (higher counts) than in the environment from which they were taken. The fish become more toxic than the sediment because the fish are eating numerous other organisms and retaining all the PHAs. PAHs have moderate to highly acute toxicity to aquatic life (and birds). When people eat these animals, they are ingesting concentrated levels of PHAs.
• Breckenridge story (20 years later) BIOREMEDIATION
In 1989, the town of Silverthorn (on the Blue River) began developing the corridor along State Highway 9 directly aligned with the Blue River. At that time the Blue River was one of 13 rivers and three lakes in Colorado with a State designated status of GOLD MEDAL WATER, meaning the Blue River was one of Colorado’s highest quality waters for fishing. (This special designation allows the state to spend money on protecting and improving stream quality and access. The result is improved reactional use and revenue for communities and services near a Gold Medal Water.)
In the 90’s, Recreation in the Summit County was growing at an amazing pace not only due to the booming ski industry but also for any mountain-related outdoors recreation.
Fly Fishing guiding / outfitting was a natural commercial investment in Summit County – specifically along the Blue River and that meant specifically: Breckenridge.
In less than 20 years, the Blue River fishery began to decline. In 2016, the Blue River officially lost this designated status. The elements that contributed to this decline were sparse aquatic invertebrate populations, low nutrition content and degraded habitat.
The river looked the same as it had always been, but the ecological system had been disturbed. These adverse conditions were directly related to commercial developments along the river corridor, meaning parking lots, runoff, and mismanagement of flows.
Today, there is a 1.8 million dollar project in addition to public grants and funds to attempt to remediate the Blue River and restore its quality to previous standards.
Of interest, Breckenridge Outfitters and other Summit County outfitters come over Hoosier Pass to guide in Park County - especially at Fairplay Beach on the Middle Fork - because of the quality of our fishery on this side of the Continental Divide!
3. FEMA / FLOODING: (QUOTED DIRECTLY FROM LEWIKI & ASSOCIATES
CONDITIONAL USE PERMIT STORM WATER MANAGEMENT PLAN
“During mine operations runoff is contained within the site using berms and site grading. All water runoff within the disturbed area will be contained with a perimeter berm, which routes the runoff to sediment ponds. It will be stored in this area to evaporate and INFILTRATE into the ground” (NEXT TO A RIVER???)
“The use of various Best Management Practices (BMPs), such as erosion control and silt fencing, will ensure all water discharge from the site is clean and sediment free” (??WATER DISHARGED FROM THE SITE?? This report does not address soluble particles suspended as dissolved components of contaminated water).
“This plan accounts for both storm water AND PROCESS WATER. The only acceptable methods of managing on-site stormwater runoff are to contain it for Use in Operations, for INFILTRATION into the ground, or for EVAPORATION into the air.”
LEWIKI & ASSOCIATES CLEARY DO NOT UNDERSTAND THE NATURE OF PHAS AND THE SOLUBILITY / MOBILIZATION OF THIS CARCINOGENIC CHEMICAL THROUGH INFILTRATION OF GROUND WATER AND SUBSEQUENT CONTAMINATION OF THE RIVER.
Many aspects of the Lewiki Report are highly skeptical – the 100 year flood analysis (image here from the report) offers zero supporting data or cited sources for their summary.
Running a statistical analysis for the Middle Fork of the South Platte at the Ellie Belle Mine site using the streamstats app (https://streamstats.usgs.gov/ss/) yields the following:
The Maximum 24-hour precipitation that occurs on average once in 100 years: 3.42 inches (not 2.87)
Total area drained by the stream: 62.6 square Miles
The 1-percent AEP flood model shows a flow rate of: 1260 cu. ft./sec (cfs)
The mean annual flow for the channel is: 64.7 cu. ft./sec
A Bieger_USA_channel_cross_sectional_area of: 160 sq. ft.
As for the available on-site water storage of 5.8 acre-ft. The storage must contain a lot more volume than simply the rain that falls on the property (45 acres) since the property is located at the bottom of a river valley. Just considering the amount of rainfall on the property for a 100 yr. event yields: 3.42 inches/12 inches/ft. * 45 acres = 12.825 acre-ft.. more than 2 times the on-site storage capacity!
Due to the proximity of the stream, the stream flooding must also be considered. For a 1% flood scenario (100 year) the max flow rate of 1260 cfs (almost 20 times the mean annual flow) will overwhelm the 160 sq. ft. channel and potentially overrun the plant site causing any material on-site to contaminate the stream.
4. FUEL STORAGE: THE LEWIKI REPORT DOES NOT ADDRESS ONSITE
STORAGE FOR LARGE QUANTITIES OF FUEL THAT IS AN INTEGRAL PART OF ASPHALT PRODUCTION
An additional adverse element of location an asphalt plant on a river system, is the potential hazard that comes with storage of large amounts of fuel, which is integral in the production of asphalt. Yes, there are appropriate ways to secure / store fuel but NEVER ON A RIVER.
Any leaks of spills of fuel infiltrate into the ground an contaminate the soils. These contaminants are mobilized under high runoff as occurs with snow melt and intermittent flooding. The reason there is a river there is because the drainage of all the headwaters upstream find this to be the lowest point in water migration – this river IS THE FOCAL POINT DURING FLOODING.
WE STRONGLY URGE PARK COUNTY TO ACQUIRE THE MOST RECENT FEMA – FLOODING REPORTING STUDY PERFORMED FOR THE US HIGHWAY 285 / C0 9 BRIDGE DOWNSTREAM OF THE PROPOSED ASPHALT SITE AS OPPOSED TO ACCEPTING THE LEWIKI REPORT.
Sincerely,
Don Logelin
President
Pikes Peak Chapter of Trout Unlimited
TO:
Park County Planning Department
856 Castello Ave
Fairplay, CO. 80440
(719) 836-4292
[email protected]
I am writing on behalf of the more than 1000 members of the Pikes Peak Chapter of Trout Unlimited. We are voicing our concern over the application for an asphalt plant on the Middle Fork of the South Platte River. Locating an asphalt plant on a river will threaten the immediate riparian habitat for all living biota, including human beings.
Asphalt is a proven source of Polycyclic aromatic hydrocarbons (PAHs), which are carcinogenic pollutants that are especially toxic in riparian habitat systems due to being bio-accumulated, meaning, the PHA content is concentrated up the food chain. An asphalt plant will also require large storage areas for fuel. These conditions add up to a highly precarious situation:
1. RIVER
2. PHAs
3. FLOODING
- FUEL STORAGE
The Conditional Use Permit written by Lewiki &Associates did not address or even mention PHAs. In particular, Lewiki’s evaluation of the site location’s propensity for flooding and catastrophic consequences of a 100 year flood is greatly underestimated.
For comparison, we urge Park County Planning Commission to review the findings on hydrology and flooding as recorded by SRK in their site assessment of the Middle Fork the South Platte River in this exact same location for due diligence study in support of the US Highway 285 / CO 9 intersection project.
FOUR ASPECTS TO CONSIDER REGARDING APPLICATION FOR ASPHALT PLANT PERMIT
1. THE MIDDLE FORK OF THE SOUTH PLATTE RIVER: A RECOVERING RIVER
SYSTEM
• Freestone waters
The Middle Fork of the S Platte River is a unique unimpeded natural river classified as a Freestone Stream, meaning the water is derived from runoff. The engineered outlet at Fairplay Beach ponds the river to a FEMA specified level and allows continued flow through the aperture of the outlet. The health of the Middle Fork of the South Platte River in Fairplay, as a Freestone Stream, is completely dependent on the health of the headwaters upstream. By inference, the health of the South Platte River downstream of Fairplay is directly dependent on the health of the Middle Fork upstream in Fairplay.
• Healthy river system
A healthy river is a connected system of multiple interacting communities of organisms living in balance within fluctuating conditions of chemical and physical properties, such as, pH, dissolved oxygen, temperature, clarity, and salinity (affects the Specific conductivity. or the water’s capability to pass electricity and enable the chemical reactions that occur within the aquatic community.) The whole system includes the river bottom (substrate) of sediments (cobbles, granules, sand, and pebbles), hydraulic flow, structure, and depth. Disruption of any of these balanced elements results in a degraded health status, possibly a sterile river.
• Recuperation from 100+ years of dredge mining
The Middle Fork of the S Platte is in a state of recuperating from 100 years of hydraulic mining – a total removal of the substrate and interruption of a balanced freestone stream. Without the substrate, the river had no underwater flora, microscopic communities, macro- invertebrates, no plants, and no fish.
This condition may have also impacted historic bird life as well.
Modern mining technology has evolved to operate within strict environmental standards. The costs of hiring environmental scientists and performing due diligence of environment impact studies, including depositing money into Escrow to cover the costs of future reclamation is the only means by which a modern mining company can operate.
Small-time mining operations do not usually have the resources to address the environmental impact of their operations. Those mining permits must be scrutinized and supervised by governing agencies at the cost to taxpayers to ensure the protection of natural resources.
Aggregate quarries are even further removed from having to adhere to the scrutiny of environmental assessment that larger mining operations are subjected to. As a result – the smaller mining operations, especially quarries, commonly cause unanticipated environmental impacts. This can be seen along the Colorado Mineral Belt where open pits and tunnels of small independent mining operations and their tailings and drainage have never been mitigated. Aggregate operations disturb the natural habitat, impacting local ecosystems. The quarry runoff carries sediment and pollutants into nearby aquatic ecosystems with adverse effects on both plant and marine life. Quarries have airborne issues with pollutants and dust as well to mitigate.
IN SUMMARY, the Middle Fork of the South Platte is a fragile and unique ecosystem that is currently recuperating from historic mining and is now in the path of additional disturbance that is highly likely to destroy the aquatic community in the vicinity of Fairplay.
2. PHA CONTAMINATION
• Chemistry: Polycyclic aromatic hydrocarbons (PAHs) are carcinogenic pollutants associated with mutagenic (aberrant cellular growth) effects. Asphalt production (and use of asphalt products, such as paved parking lots), is a major source of Polycyclic Aromatic Hydrocarbons (PAHs) creation. This is not speculation, this is a factual, well- documented type of contamination associated with asphalt. The most serious impact of an asphalt plant on the Middle Fork of the South Platte River will be contamination of the river and lake sediments from deposition of PAHs, which are microscopic on a molecular level.
Remediation of these compounds is difficult and expensive. PAH’s are highly mobile and lock onto silt particles like glue. The dissolved contaminants become absorbed into the living biota of the hydrologic community by means of ingestion.
PHA contamination of a body of water will render the fish toxic to human consumption.
• Runoff
PHAs dissolve and are mobile in solution. PHA’s (carbon and hydrogen) adhere to the surface of dust particles and are suspended in the atmosphere until being deposited by rain or dry settling in distal places. PHA’s settle on the surface of water bodies and are dispersed by streams to eventually become integrated with the sediment of river and lake bottoms. Runoff water flowing over asphalt-based sources – even from automotive exhaust on adjacent high-use roadways - will contaminate nearby water bodies.
PHA particles derived from an asphalt plant upstream of the Fairplay Beach would be transported via atmosphere and runoff by the river and settle out in the mud of the Fairplay Beach, where it would be concentrated and absorbed into the biota – microscopic organisms, macro-invertebrates and fish – and HUMANS if the fish are eaten.
• Catastrophic toxicity – inedible fish
PAHs are bio-accumulated, which means the concentrations of PAHs found in fish will be much more concentrated (higher counts) than in the environment from which they were taken. The fish become more toxic than the sediment because the fish are eating numerous other organisms and retaining all the PHAs. PAHs have moderate to highly acute toxicity to aquatic life (and birds). When people eat these animals, they are ingesting concentrated levels of PHAs.
• Breckenridge story (20 years later) BIOREMEDIATION
In 1989, the town of Silverthorn (on the Blue River) began developing the corridor along State Highway 9 directly aligned with the Blue River. At that time the Blue River was one of 13 rivers and three lakes in Colorado with a State designated status of GOLD MEDAL WATER, meaning the Blue River was one of Colorado’s highest quality waters for fishing. (This special designation allows the state to spend money on protecting and improving stream quality and access. The result is improved reactional use and revenue for communities and services near a Gold Medal Water.)
In the 90’s, Recreation in the Summit County was growing at an amazing pace not only due to the booming ski industry but also for any mountain-related outdoors recreation.
Fly Fishing guiding / outfitting was a natural commercial investment in Summit County – specifically along the Blue River and that meant specifically: Breckenridge.
In less than 20 years, the Blue River fishery began to decline. In 2016, the Blue River officially lost this designated status. The elements that contributed to this decline were sparse aquatic invertebrate populations, low nutrition content and degraded habitat.
The river looked the same as it had always been, but the ecological system had been disturbed. These adverse conditions were directly related to commercial developments along the river corridor, meaning parking lots, runoff, and mismanagement of flows.
Today, there is a 1.8 million dollar project in addition to public grants and funds to attempt to remediate the Blue River and restore its quality to previous standards.
Of interest, Breckenridge Outfitters and other Summit County outfitters come over Hoosier Pass to guide in Park County - especially at Fairplay Beach on the Middle Fork - because of the quality of our fishery on this side of the Continental Divide!
3. FEMA / FLOODING: (QUOTED DIRECTLY FROM LEWIKI & ASSOCIATES
CONDITIONAL USE PERMIT STORM WATER MANAGEMENT PLAN
“During mine operations runoff is contained within the site using berms and site grading. All water runoff within the disturbed area will be contained with a perimeter berm, which routes the runoff to sediment ponds. It will be stored in this area to evaporate and INFILTRATE into the ground” (NEXT TO A RIVER???)
“The use of various Best Management Practices (BMPs), such as erosion control and silt fencing, will ensure all water discharge from the site is clean and sediment free” (??WATER DISHARGED FROM THE SITE?? This report does not address soluble particles suspended as dissolved components of contaminated water).
“This plan accounts for both storm water AND PROCESS WATER. The only acceptable methods of managing on-site stormwater runoff are to contain it for Use in Operations, for INFILTRATION into the ground, or for EVAPORATION into the air.”
LEWIKI & ASSOCIATES CLEARY DO NOT UNDERSTAND THE NATURE OF PHAS AND THE SOLUBILITY / MOBILIZATION OF THIS CARCINOGENIC CHEMICAL THROUGH INFILTRATION OF GROUND WATER AND SUBSEQUENT CONTAMINATION OF THE RIVER.
Many aspects of the Lewiki Report are highly skeptical – the 100 year flood analysis (image here from the report) offers zero supporting data or cited sources for their summary.
Running a statistical analysis for the Middle Fork of the South Platte at the Ellie Belle Mine site using the streamstats app (https://streamstats.usgs.gov/ss/) yields the following:
The Maximum 24-hour precipitation that occurs on average once in 100 years: 3.42 inches (not 2.87)
Total area drained by the stream: 62.6 square Miles
The 1-percent AEP flood model shows a flow rate of: 1260 cu. ft./sec (cfs)
The mean annual flow for the channel is: 64.7 cu. ft./sec
A Bieger_USA_channel_cross_sectional_area of: 160 sq. ft.
As for the available on-site water storage of 5.8 acre-ft. The storage must contain a lot more volume than simply the rain that falls on the property (45 acres) since the property is located at the bottom of a river valley. Just considering the amount of rainfall on the property for a 100 yr. event yields: 3.42 inches/12 inches/ft. * 45 acres = 12.825 acre-ft.. more than 2 times the on-site storage capacity!
Due to the proximity of the stream, the stream flooding must also be considered. For a 1% flood scenario (100 year) the max flow rate of 1260 cfs (almost 20 times the mean annual flow) will overwhelm the 160 sq. ft. channel and potentially overrun the plant site causing any material on-site to contaminate the stream.
4. FUEL STORAGE: THE LEWIKI REPORT DOES NOT ADDRESS ONSITE
STORAGE FOR LARGE QUANTITIES OF FUEL THAT IS AN INTEGRAL PART OF ASPHALT PRODUCTION
An additional adverse element of location an asphalt plant on a river system, is the potential hazard that comes with storage of large amounts of fuel, which is integral in the production of asphalt. Yes, there are appropriate ways to secure / store fuel but NEVER ON A RIVER.
Any leaks of spills of fuel infiltrate into the ground an contaminate the soils. These contaminants are mobilized under high runoff as occurs with snow melt and intermittent flooding. The reason there is a river there is because the drainage of all the headwaters upstream find this to be the lowest point in water migration – this river IS THE FOCAL POINT DURING FLOODING.
WE STRONGLY URGE PARK COUNTY TO ACQUIRE THE MOST RECENT FEMA – FLOODING REPORTING STUDY PERFORMED FOR THE US HIGHWAY 285 / C0 9 BRIDGE DOWNSTREAM OF THE PROPOSED ASPHALT SITE AS OPPOSED TO ACCEPTING THE LEWIKI REPORT.
Sincerely,
Don Logelin
President
Pikes Peak Chapter of Trout Unlimited
Michele White, VP of Financial Development and Don Logelin, President are also both testifying before the Park County Planning Commission during their meeting of Feb. 14th.