Public comments desired for saving a critical piece of habitat

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jonathan
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Public comments desired for saving a critical piece of habitat

Post by jonathan »

This is the most personal conservation effort I have ever engaged in.

The most herpetologically unique piece of land in my home county is slated to be destroyed by gravel mining. The area is of enormous botanical significance as well, preserving an ecosystem (Willamette Valley camas prairie) that otherwise has been eliminated almost everywhere within a 50km radius and for which less than 2% of the historic coverage exists in the Pacific Northwest.

I would greatly appreciate anyone who was willing to submit a public comment to the US Army Corps of Engineers and the Department of Environmental Quality explaining why it is foolhardy to destroy the last remaining habitat of this type in the entire county. Feel free to PM me if you want information on the herpetological uniqueness of the site.

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Here is the statement from Friends of Liberty Hill on how to submit a comment:

USACE (United States Corps of Engineers) has unexpectedly accepted the mining application "as is" and moved to public comment period (this is an acceptance of the permit as complete - NOT the actual approval of mining plans).

The public comment period has now begun for both USACE and DEQ. Comments regarding the mining plans can now be submitted until March 3rd, 2021. In order to have standing in contesting the permit, public comment MUST be submitted by the March 3rd deadline.

* It is still very important to comment at ALL three agencies who are reviewing the permit - USACE, DEQ and Department of State Lands. As noted above, DSL public comment period will come later this Spring or Summer.



Here is the link which will take you to the USACE public notice page with an summary of the mining plan application and instructions for submitting your comments to both USACE as well as DEQ. Please read the overview. Please also note that the the actual project name on the permit is "Watters Quarry Expansion". In commenting, please use the actual project name of "Watters Quarry Expansion" and the permit number, NWP-2020-065.

We encourage comments submitted to BOTH agencies (USACE and DEQ) at this time, though some comments may apply to more to one agency.

Not sure what to write?? Below are some permit facts and "talking points" that may help assist in advocacy for Liberty Hill. In order for your comments to have the greatest impact, we highly suggest you not submit comments word-for-word as written below. Unique and individualized comments will have more meaningful impact. We realize that there are A LOT of talking points here, but while it would be of value to cover as many points possible, you do not have to cover EVERY talking point, but encourage you to review the below facts and suggested talking points first and decide on either a condensed version in each category or an area that is particularly meaningful to you.



LIBERTY HILL FACTS and FOLH SUGGESTED PUBLIC RESPONSES

FACT: Approximately 94 acres will be directly impacted by mining for basalt. Over 12 acres of wetland and seasonal steams will be impacted (completely removed) in addition to those designated "indirect impact" that will eventually go dry from the natural water source being cut off.

The proposed mining expansion will gravely impact one of the region's last, largest, and unusually intact and ecologically diverse native habitats of this type - indeed, one of the best remaining in the state of Oregon. These include specialized "wet meadows" that are extremely difficult if not impossible to replace in mitigation efforts. Considering the value of this site remaining intact and the fact that basalt is plentiful and easily obtained elsewhere in the region - even very close to the proposed site - Liberty Hill should be preserved.

​As sited in 2013 by Dr. Kenton Chambers, herbarium at OSU and John Christy, wetlands ecologist and botanist with OSU, this site of proposed mining expansion is considered as "one of the best examples of intact camas meadow and oak/ash mixed woodland in the Pacific Northwest." It needs to be preserved. Basalt is not rare. Sites like this are.

​It is estimated that only 2% of this type of ecologically diverse oak and camas plant community still exists in Oregon where historically it covered much of the Willamette Valley and Lower Columbia Gorge up into Washington State and B.C. In these other areas mentioned it is nearly gone as well. Because of this drastic loss, most people in the Pacific Northwest don't even realize these "ghost landscapes" of prairies dotted with oak and wildflowers existed, believing instead that our Iconic Douglas fir forests were what once grew all around. Not only were the plant communities incredibly diverse, but so were the bird, fish, insect and animal population that they sustained. This site is a remnant. A survivor of 150+ years of development, agriculture, industrial degradation and mining. Now this expansion is looking to erase this beautiful and now rare landscape even more - FOR ROCK.



FACT: Liberty Hill has over 20 acres of almost continuous camas meadow.*

* please note that USACE has jurisdiction on cultural resources . The following talking points should be directed to them and not DEQ.

Though there are a multitude of other wildflowers and native plants at this site, it is the camas bloom that occurs every April that is a delight to both local and regional people who marvel at the sea of blue blossoms. A soft blue "glow" from the mass flowering can even be viewed from a distance by passersby on highway 30 . In the past, while this site was not the specific blooming camas meadow that Meriwether Lewis noted in his journal as resembling "lakes of fine clear water", given the proximity to the route of the Corps of the Discovery explorers, these meadows could well have garnered the same response. These camas meadows, however, are far older than the time of Lewis and Clark. Prized for their camas bulbs and tended and harvested by the tribes of the region, there is little doubt that they have been present for hundreds if not thousands of years. Where does this mining company have the right to destroy such a place of significant history, beauty and rarity that is cherished by the community and the region's native people? Basalt can be found many other places instead of beneath these meadows, which are a living legacy of Pacific Northwest history.



FACT: The application to date, and pending revision, is planning 44 acres of mitigation area in an effort to replace lost wetland. This site is proposed for the West side of the expansion plan and includes both preserving as well as “enhancing” existing wetlands that will involve removal of invasive plants already present. Hydrology may be supplied by redirecting water from sources in the lower SW portion of the mitigation area. A “stream” will be created just beyond and parallel the Urban Growth Boundary to connect hydrology from the uplands to the the east side of the site.

​The "indirect impact" areas (where water flow is cut off) seems underestimated given the complex hydrology of the area. The footprint of the expansion is so large and impacts some critical large wetlands downstream of the site. The mitigation plan either needs to be larger for additional loss of wetland meadows to the south of the expansion area, or the footprint needs to avoid the largest sources of hydrology. An alternative site should be STRONGLY considered.

​Overall, ANY mitigation to try to replace these specialized habitats that have formed naturally over thousands of years will be woefully inadequate with a high degree of failure in recreating them. The ecosystem of this area is uniquely adapted to its geology. When the rock beneath these areas is removed, they are never coming back. Alternate sites NEED to be thoroughly explored and encouraged.



FACT: The following paragraph is a direct excerpt from the permit application regarding “project purpose and need". Please note that this specific information is not provided on the USACE public notice page overview of the project. The full permit application can be found HERE
High-quality aggregate is essential for the construction of public infrastructure projects including roads, railroads, bridges, buildings and airports as well as private residential, commercial and industrial developments. Aggregate is required for nearly all construction projects as the primary component of concrete and asphalt paving material and as structural fill. The project would assure a long-term local source of high-quality aggregate in the County and nearby Portland metropolitan area market for the next 50 years, depending on market conditions. The project would benefit the local and regional community by providing jobs and an affordable source of high-quality aggregate products for public and private construction projects.
​If this project is “depending on market conditions” as it states in the actual permit (not in the USACE summary) then why is this extraction plan so huge?

Why does the entire 50 years of rock need to come from this one site? Especially when there are other existing quarries nearby as well as other potential sites for basalt extraction.

​Basalt is one of the most plentiful rocks on earth and is widespread both locally (Knife River has several other quarries in the area) and regionally outside the proposed site. There are also plenty of other mining companies in the region who could provide basalt aggregate from other sites - some nearby. Some of these companies are local. Knife River’s parent company is a huge company, MDU Resources and it is in Bismarck ND. They have several quarries around the Western US. The depletion fee for rock is very low, so direct benefit to the local community is minimal. This project mostly “takes” and does not give back.

​How will it create jobs when the current Watters Quarry (before proposed expansion) employs fewer than 10 people from the nearest community? Mining is largely automated and expansion will not require many additional opportunities for employment. This site is beautiful and has been known to and enjoyed by the community for decades. Basalt is everywhere and Knife River is not hurting. They should quarry elsewhere.

Knife River parent company is MDU Resources headquartered out of Bismark, North Dakota. Only a handful of their employees live locally. Historically, mining was an important local industry to the Saint Helens area that provided many good paying jobs as well as meaningful involvement with the community. Now Knife River puts a banner up at the Columbia County Fair and calls it good. This is no longer a "local industry". It's a giant, out-of-state corporation that is lining it's executives pockets from selling off Oregon basalt aggregate without even a decent depletion fee to give back.

​The depletion fee on rock extraction is very low in Columbia County. The local community will benefit MINIMALLY from this mining expansion with a much greater risk of loss of an important and exceedingly rare ecosystem and natural resource for future generations.

​BASALT CAN BE FOUND EVERYWHERE.

​​

FACT: Two "alternative sites" were studied for mining - one directly to the North and one a few miles West. Also, "alternative analysis" was provided for levels of degradation and appropriate mitigation response for wetland losses in the preferred site.

The "alternative analysis" sites for other possible basalt extraction has not been thoroughly explored. Of note, is a large basalt shelf which is RIGHT THERE on the North side of the existing quarry that is also owned by the lessor (Weyerhaeuser) and could easily and relatively inexpensively be extracted without a need for such a huge expensive mitigation project for that will be required for the preferred expansion to the South. The immediate North site does not have anywhere near the significant ecological value as the preferred site with it's huge camas meadow, streams and wetlands. There appears to be a decent amount of rock to quarry in that direction, so why not expand that way? It should provide at least 20-30 years of rock. Seems more than adequate.



The following talking points are specifically directed to DEQ regarding holding ponds and stormwater management

This site, with its water volume and complex pattern of wetlands and streams would seem to have a very high likelihood of many problems with storm water discharge and turbidity from this scale of disruption from the expansion. Knife River, the applicant who also operates Angell Quarry in Multnomah county was fined by DEQ for turbid discharge into the Multnomah Channel in 2017 (see "Notice of Civil Penalty Assessment and Order Case No. WQ/SW-NWR-2017-080"). The fine was $46,512, which from the amount, sounds pretty serious. It looks so too. Anyone who drives frequently on highway 30 and can see that muddy stream coming down off the hillside near Angell quarry has to wonder what they have done to address that problem in 4 years. Most days it's STILL looks horrible. Even on days where the water looks sort of clear there is an ever present orange color to the rocks. Nothing really grows close in around this stream. The many other streams nearby coming down the hillside have moss and ferns. From what I read in the 2017 citation , it looks like Angell Quarry has just this ONE STREAM. Now with this huge expansion on this site, they'll be looking to have to constantly manage not one stream but 12 acres of wetlands and interconnecting steams. If they can't manage the storm water from the Angell Quarry site, how are they going to do any better with managing all the storm water at this site? I don’t think this permit should be approved without a hard look at an alternative place to quarry.

Where are the holding ponds for all the water that will be pouring through this site? There is no map showing them. There is little meaningful info as well as to how they are going to effectively manage muddy water pouring into the tributaries that are connected to the water flowing from the site. Some of these tributaries flow to the Columbia and salmon habitat. Considering the times we are in with unprecedented losses to salmon runs, stormwater management from huge quarry projects such as this should be top priority.

There is an existing mitigation area on private land below the mining expansion area (this mitigation area is in the SE corner adjacent the project area and currently owned by NSA property holdings) it was established many years ago but is currently in good standing with many plantings that rely on hydrology from the proposed expansion area by way of a large seasonal stream that cascades down the Eastern edge in a waterfall. From this mitigation area, the water flows from this site on to Dalton Lake and eventually the Columbia. I can't find any mention of this existing mitigation site in this public notice or on the maps and yet it could be gravely impacted by either having the water supply cut off or turbidity from the expansion degrading it, not to mention the potential negative effects on fish habitat since the water eventually enters the Columbia. This site, as well as other drainages from the impact area need to be accounted for.
https://www.oregoncamas.com/pending-rem ... ing-permit

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Ameron
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Re: Public comments desired for saving a critical piece of habitat

Post by Ameron »

I go to the link provided, all it does load a very BUSY page with numerous email contacts. There is no intuitive link for Submit Comments Here.
Where is the actual link for submitting comments?

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jonathan
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Re: Public comments desired for saving a critical piece of habitat

Post by jonathan »

Ameron wrote:
February 20th, 2021, 8:23 am
I go to the link provided, all it does load a very BUSY page with numerous email contacts. There is no intuitive link for Submit Comments Here.
Where is the actual link for submitting comments?
Thanks for highlighting that, the Corps did not make it easy to follow.

Comments are submitted via email or snail mail. The follow section had the instructions:
Submitting Comments: Interested parties are invited to provide comments on the proposed project. Comments may be submitted by conventional mail or email. All comments received will be considered in determining whether authorizing the work would be contrary to the public interest.

Either conventional mail or e-mail comments must include the Corps reference number as shown on page 1 and include the commenter’s name and address. In order to be accepted, e-mail comments must originate from the author’s e-mail account and must include on the subject line of the e-mail message the Corps reference number. All comments received will become part of the administrative record and are subject to public release under the Freedom of Information Act including any personally identifiable information such as names, phone numbers, and addresses.


Comments should be submitted to the following mailing address or email address:

U.S. Army Corps of Engineers
Regulatory Branch
Caila Heintz
P.O. Box 2946
Portland, Oregon 97208-2946
Email: [email protected]
Telephone: (503) 808-5113
The reference # mentioned several times is NWP-2020-065

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zeevng
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Re: Public comments desired for saving a critical piece of habitat

Post by zeevng »

Thank you for bringing this to our attention, and I will definitely be sending in a comment. Have you posted it to some of the herp FB pages, too? (California Field Herping, North American Field Herping Association, Wild Snakes: Education and Discussion, etc,) and many other great groups filled with passionate herpers and conservationists that may not visit the forum?
I think the greater number of comments sent in, the better, right? It would be great to get it in front of as many eyes as possible.

Thanks for fighting the good fight on this!

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Kelly Mc
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Re: Public comments desired for saving a critical piece of habitat

Post by Kelly Mc »

Thanks Jonathan for bringing this to our attention.

My partner and I will be working on our comments letters starting tonight.

Lets try to keep this up here. Its so important. What a treasure in our country.

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Porter
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Re: Public comments desired for saving a critical piece of habitat

Post by Porter »

I live in Roseville now and fairly close to the open and seemingly endless foothill habitat I use to explore in my childhood. The most fruitful area of that habitat is now no more than the circumference of a strip mall. There were horned lizards in those hills at one time... I'll submit a comment.

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jonathan
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Re: Public comments desired for saving a critical piece of habitat

Post by jonathan »

Thank you zeevng, Kelly Mc, and Porter for your support.

Yes, more comments can help as they show the volume of public interest/outcry regarding the project. However, what is more specifically helpful are informed comments. Anything you can share regarding the rarity of the ecosystem, its uniqueness in the region, the need to maintain intact native habitats that have otherwise almost disappeared, and the extreme unlikelihood that supposed "mitigation" will actually rectify the issue is very helpful. Use either cited sources or your own personal experience for any of those points. I'm happy to help via PM if you have questions.

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jonathan
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Re: Public comments desired for saving a critical piece of habitat

Post by jonathan »

Ameron wrote:
February 20th, 2021, 8:23 am
I go to the link provided, all it does load a very BUSY page with numerous email contacts. There is no intuitive link for Submit Comments Here.
Where is the actual link for submitting comments?
Also, if your comment is relevant to water quality, you should send to this email as well (though I was under the impression the would cross-reference comments anyway, better not to risk it):


Written comments: Written comments on project elements related to water quality must be received at the Oregon Department of Environmental Quality by 5 p.m. on the date specified in the upper right section on page one of this notice. Written comments may be emailed or mailed as described below:

Email - [email protected]

Mail - Oregon Department of Environmental Quality, Northwest Region
700 NE Multnomah Street, Suite 600
Portland, Oregon 97232
Attn: 401 Water Quality Permit Coordinator

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