Commentary: Region needs study, review of sand miningAn open letter from the Red Wing Izaak Walton, to communities affected by silica sand mining activities:
By: Ken Moon, The Republican Eagle
An open letter from the Red Wing Izaak Walton, to communities affected by silica sand mining activities:
The Izaak Walton League of America is among the nation’s first conservation groups. Since 1922, we have been working at the local, regional, and national levels to advocate sensible solutions to the most pressing challenges facing America’s natural resources.
Frac-sand mining and its use is clearly one of these challenges.
As a conservation organization, our first recommendation would be to encourage energy conservation and renewable energy investments to avoid gas and oil frac-sand drilling. Both must be part of any policy as we move forward.
Current practices for extraction, storing and processing of crystalline and amorphous forms of silica involve methods that are not well suited for operations of the magnitude being proposed or actively working in the region. Mining operations are being conducted or proposed along river and valley corridors, along bluffs, and other geologic areas where extraction and transportation corridors exits.
These areas also contain 40 percent of the state’s biological diversity of rare and protected plants and animals and need our protection.
Many of these areas have already been shown to not be well suited for storing, processing or mining due in part, to the limited protections provided by state or local permits and ordinances.
Frac sand mining or processing facilities near residences or population centers must ensure that windblown (airborne) forms of silica which can cause health or nuisance conditions should be prevented or minimized. Current state air permits do not adequately cover these silica related releases from mines, storage, or processing facilities.
Concerns with health, noise impacts, visual impacts, and fugitive dust from the mining, processing, or stockpiling operations simply must be better addressed and protections put in place. Stating that the size (4 microns) is difficult to measure, or that monitoring or the body of study of these pollutants is incomplete and therefore not providing protection from an emerging pollutant is simply not an adequate response.
Water resources both ground water and surface water at these facilities from dewatering, washing, processing or transporting should adequately protect our resources. From water withdraw to discharge and from stormwater to waste water all need further regulatory controls.
To date most of these facilities are (or are being proposed) to be regulated under existing sand and gravel regulatory structures. This regulatory structure is typically used for local product and sale, at small scale operations. These regulatory applications are not suited and are not protective of mining, processing operations, or transportation issues of the size and nature of the frac sand sites.
Further protections that will prevent negative groundwater or surface water impacts which can affect the habitat of our natural environment, our landscape, and our natural hydrologic systems need further study and review.
We must seek understanding of these issues in a sustainable, sane and non-combative way.
The IKES support local control and regulations and encourage full environmental review of these facilities as provided by Environmental Quality Board Rules. To ensure both a public review process occurs, adequate comment period is conducted, and adequate regulatory oversight can be applied to these regional facilities.
This should result in health and pollution protections for our natural resources and have sustainable solutions. Success with these efforts would also minimize other impacts; infrastructure (e.g. roads, rails, and barge), land-use compatibility, bluff protection, and community quality of life needs.
Ken Moon is a board member of the Red Wing Izaak Walton League.