Kentucky Department of Natural Resources
Non-Coal Mining Division
300 Sower Boulevard, 2nd Floor
Frankfort, KY 40601
COMMENTS IN RE: Permit No. 099-9404, Red River Materials, LLC, December 13, 2016
These comments are submitted by the Kentucky Environmental Foundation regarding the application of Red River Materials, LLC, a Kentucky Limited Liability Company with its principal office in Lexington, Kentucky, for a non-coal mining permit. The application seeks permission to conduct non-coal surface mining using the contour and pit method on approximately 86.4 acres
IMPACT ON PUBLIC HEALTH
The introduction of a quarry into the community could present a range of concerns regarding impacts to public health.
IMPACT ON WATERSHED(S)
Since the Red River, which borders the proposed mine site, is Powell County’s only source of public water, in order to assure that the proposed mining will not adversely affect the hydrology of the area and the watershed into which the property drains, a hydrogeologic investigation of the property and relationship to Red River, various branches, creeks, streams, aquifers, springs, and to any private groundwater users in the area is appropriate.
In addition The Wild and Scenic designation also applies to the stretch of river that passes through the gorge, but it does not protect the entire Red River watershed from human impacts. Recently members of the Kentucky Waterways Alliance, an environmental nonprofit, collaborated with the state’s Division of Water and the U.S. Forest Service to create the Red River Gorge Restoration and Watershed Plan, which addresses potential threats to the water quality of four creeks that flow into the iconic river. These threats include high levels of sediment resulting from road construction, and contaminated runoff from residential areas. Because portions of these tributaries are located on private property, the watershed plan recommends “best management practices” that property owners can implement in order to reduce the amount of polluted runoff. Maintaining a riparian buffer of stream side vegetation, which prevents bank erosion, is just one solution that private landowners can choose to implement.
The nonprofit organization has also secured an implementation grant from the Kentucky Division of Water, which they hope to use to create financial incentive programs for homeowners. The grant money will fund other stream restoration projects as well, such as the removal of two culverts on Indian Creek that are currently impeding the passage of fish. This proposed mining would likely heavily impact this plan and the community in a negative way.
IMPACT ON TOURISM/LOCAL ECONOMY
Tourism is the top industry/revenue producing “industry” within the area of and nearby the proposed mine site. Researchers estimate that approximate 7,500 climbers visit the Red River Gorge each year and spend an estimate $3.6 million in the six counties surrounding the Red River Gorge. In addition thousands visit to simply hike, paddle, camp and enjoy the natural beauty of this area. The proposed mine site would not only be in close proximity to many of the natural tourist destinations in the Red River Gorge/Daniel Boone National Forest area, but would be visible from the Bert T. Combs Mountain Parkway, Eastbound lane as tourists traveled to the Slade Exit towards Natural Bridge. Runoff, dust, and other debris (as well as potential noise pollution) from the proposed mine site would adversely alter the view-shed of the area and thus negatively impact tourism, a staple industry of this area.
IMPACT ON TERRESTRIAL SPECIES
The placement of a proposed quarry is in close proximity to known roosting sites for several species of federally endangered bats.
Federally Endangered Bat Species Documented or Likely Present Within one (1) Mile of Proposed Quarry:
The Virginia big-eared bat (documented) and the Indiana bat (likely) are Federally Listed as Endangered under the Endangered Species Act. The Northern long-eared bat is Federally Listed as Threatened under the Endangered Species Act. The Eastern Small-footed Myotis and Rafinesque big-eared bat are on the Kentucky Nature Preserves Rare Species List.
The Virginia big-eared bat, one of the rarest mammals in North America, is known to use sandstone rock shelters less than one (1) mile of the proposed limestone quarry. The largest known population occurs in the Daniel Boone National Forest in limestone caves and sandstone rock shelters in this area. Indiana bats and Northern long-eared bat likely use forested areas within the proposed limestone quarry for roosting.
“Range: Virginia big-eared bats occur in isolated populations in eastern Kentucky, eastern West Virginia, southwestern Virginia, and northwestern North Carolina.
Causes of Decline: Human disturbance is probably the biggest factor contributing to the decline of these bats. Disturbance during hibernation causes bats to lose stored fat reserves, and repeated disturbance can cause the bats to die before spring (when insect prey are again available). If female bats are disturbed during the maternity season, they may drop their young to their deaths or the whole colony may abandon a roost for a less suitable location.” Taken from: (http://fw.ky.gov/Wildlife/Pages/Virginia-Big-Eared-Bat.aspx)
Blasting from the quarry could damage karst/cave systems and rock features that harbor these critically endangered bats. Sonic disturbance caused from blasting could gravely impact and interfere with the bats’ natural echolocation processes. It should be noted that ALL bat species are under duress due to the often fatal disease, white-nosed syndrome that has wiped out as much as 90% of certain species of bats once considered common.
AQUATIC LIFE IMPACTS
Kentucky Arrow Darter (fish), known from the Red River Drainage, proposed for federal listing. Limestone sediments from the quarry can increase watershed damage, affecting numerous endangered fish and mussels. (see attached County Report of Endangered, Threatened, and Special Concern Plants, Animals, and Natural Communities of Kentucky
Kentucky State Nature Preserves Commission, December 2015 EXHIBIT “D” ). The resulting limestone enriched runoff would also create a disturbance in the balance of the Red River ecosystem by allowing for unfettered growth of algae and other invasive species that thrive on limestone-enriched waters.
Consultation with the Kentucky Department of Fish and Wildlife Resources and the U.S. Fish and Wildlife Service, as well as Environmental Impact Assessment (EIA) conducted by independent biological consultants should be required in order to assure no jeopardy, hazard, or physical damage to protected species, and to comply with both state and federally mandated laws concerning endangered/threatened flora and fauna.
The Cabinet has been made aware through public comments that there exists a number of karst features, including sinkholes and caves, on and near the property proposed to be mined. The presence of such features raises several concerns regarding the potential for environmental damage and hazard to public safety.
The presence of mature karst features may allow any blasting conducted in association with the quarry to adversely impact those properties and structures, since such features could provide a pathway for transmitting both air-blast and ground vibrations in a manner that is not readily controlled, and may concentrate the force of such blasts. The applicant should be required to retain a consultant qualified in the investigation and mapping of karst features, in order to develop and provide a thorough mapping of sinkholes, caves, and other karst features. Additionally, a blasting plan should be required that specifically addresses the potential for transmittal of blast vibrations through karst features, in order to protect the integrity of nearby residential structures and properties.
The presence of mature karst features presents a second concern that warrants investigation, which is whether there are cave resources in the vicinity that could, directly through quarrying or indirectly through changes in hydrology or through blast vibrations, be adversely affected in a manner that would violate the Kentucky Cave Protection Act.
Thank you in advance for your consideration of these concerns.
Kentucky Environmental Foundation
128 Main St, Berea, KY 40403
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