Monday, March 18, 2013


 If Fillmore County Commissioners do not order an EIS on Rein's Expansion, then that means they could issue a permit immediately (or request more info.).

  Citizens need to speak up now also. Although it is too late to have these comments included as formal responses to the EAW, we can always contact the commissioners, let them know our concerns, and ask them to order an EIS because there is the potential for significant environmental impacts.

  The other three proposals in Fillmore County are going to do an EIS, and Rein should too. If we let Rein slip in while the state is considering a statewide moratorium and Generic Environmental Impact Statement, it would be premature and bad policy.

  This task is important now.  Thank you for spreading the word to anyone you know who might be interested.

  To read the EAW comments you can go to Fillmore County, Minnesota, zoning dept. or here
Some points from those comments you might wish to borrow to ask for the EIS:

  An EIS is required, not only to fill in the blanks of basic information, but in addition, to address the project's environmental impacts and provide a comparative analysis of its economic and sociological effects.  We need an EIS that considers reasonable alternatives, including the "no-build" alternative.  We need information on future stages of the proposed mine to examine cumulative impacts.  Only then will Fillmore County officials be able to make a wise decision on a conditional use permit.

  The cumulative effects of the Rein mine expansion, along with the other silica sand projects known or discussed in our area have potential for significant environmental impacts.  An EIS is needed to study them thoroughly.

  How will we be reimbursed for loss in property values?
  Hauling route -- Misnamed roads:  Hwy 2 east of Eitzen, Minn., is a County Hwy.  The eastern end of Hwy 2 to New Albin, Iowa, becomes Allamakee Hwy A-11, which is also a County Hwy.
  Fillmore County Rd 12 would be unsafe to handle the large number of heavy sand trucks.
  South Fork Root River bridge was expensive to construct.  Proposed excessive number of heavy sand hauling trucks would quickly deteriorate this major asset.
  Intersection of Co Rd 12 bridge over South Fork Root River is prime angling area. This proposed alternative route would be in conflict with recreational use of this area.
  Lawmaker (Iowa) County has 18-month long, and extendable, moratorium on development & operation of both frac sand mines and processing facilities.  There is no processing facility near New Albin, Iowa. Members of Allamakee County Bd of Supervisors have hinted that they will probably prohibit permanently the mining and processing of silica sand in Allamakee County. There would be no legitimate reason to haul mined sand to New Albin, Iowa, area.
  Proposed MnDOT construction projects that may impact the proposed haul routes:
  2013 MN Hwy 44 from US Hwy 52 to east of Spring Grove (replacing 5 box culverts.
  2014 MN Hwy 43 from MN Hwy 16 to Root River bridge in Rushford.
  What happens if routes need maintenance and repair, but necessary funds from other government sources are unavailable to combine with the road use fees to do the job?
  Houston Co. DOT: Houston Co. has moratorium.
  Houston County's road use agreement will require modification with any haul route changes.
  Houston County Hwy 2 was not designed for proposed traffic; anticipated it would need to be upgraded to handle the proposed traffic.  Also, spring load restrictions for roughly 2 months each year, along with Allamakee Co. Hwy A-11.
  Who has liability for damage to trout streams, aquifers, human & animal health, or existing businesses?  What kind and amount of liability insurance is required to be carried to pay for damage by mine operations far into the future?  This should be required to be described in detail.
  Particulate matter -- crystalline silica dust is a Class 1 carcinogen. 
  Specific, high-quality, small-particle monitoring devices need to be around the mine boundary and feed real-time data to a public site.  All cost of the monitoring must be paid by the mine operator and owner.
  Diesel particulates are also a Class 1 carcinogen.
  Information is incomplete with no use figures for mining, processing, and loading equipment. Diesel particulate monitoring must be required with the same stipulations as for silica dust monitoring.
  Proximity of sinkholes and springs.
  Will blasting increase cracks and fissures in the underlying Shakopee karst which could directly affect the feeding of the springs at Nepstad Creek (a designated trout stream)?
  This proposal is incompatible with Fillmore County's Comprehensive Land Use Plan.
  Any modification of the original reclamation plan must be approved by the technical team of reclamation experts, not just by "mutual consent of the operator and zoning administrator," to guard against weakening of the original reclamation plan.
  Complete details for this proposal are needed about all amounts of taxes & fees which are going to be paid to Minn, Fillmore County, and Holt Township annually.  Also needed is information on how many jobs are expected, where the workers will come from , with details on what kinds of jobs will be done and their associated pay rates, and total payroll per year.
  How much total water will be used by the "wet suppression" system?  Does it operated during hours/days/weeks when the mine is not in operation?  How does it function at temperatures below freezing/  If water is trucked in to the site, where will that come from?
  What will be the source of the 6" topsoil over the 50 acres when done?  We need to be sure that its transfer will not deplete the agricultural use of some other parcel of land.  The imported topsoil needs to be tested by a third party at the  mine owner's expense to be sure it doesn't contain heavy metals or other contaminants.
  The Minnesota Dept. of Health recommended:
   more info. regarding backfilling and grading plan for reclamation;
   Monitoring wells with baseline sampling and ongoing monitoring;
   Comprehensive well survey to identify drinking water wells near the site which are not recorded in the CWI.  Collect baseline samples from the nearest wells;
   Record post-reclamation land use options on the property deed to alert future land owners to potential groundwater concerns.
   Identify well being used for dust suppression and erosion control water.
   Include plan to monitor for respirable crystalline silica on a regular basis;
   Develop & sample monitoring well network in OPCJ aquifer, including nearly private wells if monitoring well results indicate this is warranted.
   If negative impacts to groundwater are detected in the monitoring wells, they should be resampled for pesticides.
   Minn. Dept. Natural Resources:
   Recommends an invasive species management plan within the reclamation plan;
   Identify location of off-site wells that will be used as water source, and quantify number of gallons used at the mine by a daily tally of water trucks (with known volume).
   Potential cumulative effects should be considered to the extent necessary as connected or phased actions.
   Mandatory threshold for EIS of 160 acres during the mine's existence...take into consideration future expansion of additional silica sand resources owned by Reins. 
   All phases that can be reasonably anticipated for future permitting must also undergo environmental review at this time.  These phases in total appear to exceed the 160 acre limit in the rules, and therefore, would require preparation of an EIS.