The Environmental Confederation of Southwest Florida (ECOSWF), a Florida Corporation, is an umbrella organization of over three dozen civic and environmental groups who are concerned about impacts of phosphate mining in South West Florida. The Areawide Environmental Impact Study (AEIS) Scoping sessions asked for input on various issues regarding potential direct,, indirect and cumulative effects of continued phosphate mining in the Central Florida Phosphate District (CFPD).
The Corps should study the cumulative environmental impacts past, current and future of all phosphate lands in the Central Florida Phosphate District (CFPD) as well as the cumulative environmental impacts on associated lands outside the CFPD. More precisely, Charlotte County and all of Sarasota County should be included when accessing cumulative environmental impacts from past, current and future mining activities. Charlotte County is down stream and down wind of mining occurring and potential mining in the CFPD. Sarasota County is both hydrologically down gradient and is often a recipient of winds from the east.
The environmental impacts should not be limited to those areas within the CFPD, which are economically feasible to mine. Economical feasibility changes from day to day. The Environmental Confederation of Southwest Florida along with other groups, governments and individuals requested the Army Corps of Engineers conduct an area wide EIS twenty-one years ago when IMC wanted to begin mining Pine Level (now know as the DeSoto mine). It is unlikely another EIS will be undertaken any time in the near future. It would be a disservice to all parties to not take advantage of this opportunity to access cumulative phosphate impacts on the region.
The following recommendations are based on two assumptions:
1. The geographic boundaries of the Areawide Environmental Impact Statement will be all phosphate lands in the CFP and all of Sarasota and Charlotte Counties.
2. The cumulative impacts are those from past, current and all remaining land identified with phosphate deposits.
HEALTH RISK METHODOLOGY:
The Corps' health risk assessment methodology should be designed to develop and present the key determinants of risk. Risk is a function of (1) the physical and chemical characteristics of phosphate mining (e.g. particle sizes, chemical concentrations), (2) the manner in which phosphate mining is managed, and (3) site specific environmental conditions (e.g. recharge area, upstream of Charlotte Harbor, Southern Water Use Caution Area) and proximity to potential receptors (e.g. surface water, drinking water wells wetlands).
Screening criteria can be divided into two main categories: (1) criteria to compare to constituent concentrations measured in solid samples and (2) criteria to compare to constituents measured in liquid and leachate samples, or in extract samples from solids. The screening criteria compared in solid samples include criteria that reflect the potential hazards to human health via inhalation, soil ingestion, and multiple radiation exposure pathways as well as a criterion that reflects the potential for air quality degradation.
The Corps should include climatologically changes from turning vegetated lands into moonscape and slime ponds. Consideration should be given, but not limited, to changes in rain patterns, quantity and quality; what are the economic repercussions if there is a change in rain patterns, quality and/or quantity; what are the environmental consequences of changes and what are health consequences (more respiratory diseases)? Will these changes increase or decrease daily and nightly temperatures; what impact will temperature changes have on agricultural productivity; what impact will these changes have on ecological systems; what impact will these changes have any negative consequences on the carbon footprint in the area of the Areawide EIS (the area identified by ECOSWF for inclusion in the study)?
SURFACE WATER QUALITY
The Environmental Protection Agency (EPA) just set pollution control standards for Florida. The Myakka/Peace River exceeds the control standards. The Corps needs to identify what the control standards are for all listed rivers, canals and streams in the study area; the Corps needs to identify those segments that do not meet the control standards set; the Corps needs to ascertain how the past and present phosphate mining activities contribute to the Phosphorus amounts in the identified rivers, canals and streams; the Corps needs to determine if proposed mining activities will contribute to Phosphorus amounts exceeding the standards; the Corps needs to discover what past and present phosphate mines are doing to meet the EPA standards; the Corps needs to discover what mining practices future phosphate mining will utilize to ensure Phosphorus standards (limits) are not exceeded .
EPA also set nitrogen control standards for Florida's streams, rivers, lakes and canals. Overloading of nutrients cause algal bloom and weed mats that block the waterways and cause low oxygen "dead zones" in water bodies resulting in declines in wildlife and their habitats. "Dead zones" limit recreational use by fishermen, kayakers and boaters.
The Corps needs to determine if the captured water at a phosphate mine contain algae and/or weed mats. How does the phosphate mine ensure the algae and/or weeds mats will not get into the area's surface water? When the capacity of the water storage structure is reached, where is the excess water released; what are the health risks if the polluted water enters into the public drinking water stream; what are the environmental consequences to wildlife and their habitats; what are the economic impacts from inundation by the polluted water? The Corps needs to quantify the nutrient loading of all water bodies on phosphate land. How will the nutrient loading be affected during and after mining? In the past, how did the nutrient loading from phosphate mining effect public and private water bodies?
Sheet flow contributes to the health of ecosystems. What is the impact on ecosystems when the sheet flow is altered; what criteria is utilized to determine an impact occurred; how long does it take to determine an impact; are the impacts permanent or temporary; what criteria is utilized to determine permanent or temporary impacts; what is the time line for "temporary"?
What are the cumulative impacts to small creeks and wetlands from phosphate mining hydrologically, vegetative and wildlife?
The Southwest Florida Water Management (SWFWMD) defines the southern West-Central Florida Ground-water Basin (SWCFGWB) as an area that consists of clastic sediments underlain by carbonate rocks. There are three recognized aquifer systems. At the surface and extending up to several tens of feet thick is the unconfined surficial aquifer system (SAS). It is generally comprised of unconsolidated quartz sand, silt, and clayed sand. Underlying the SAS is the confined intermediate aquifer system (IAS), which consists of a series of thin interbedded limestone, sand. sandstone, shell and phosphatic clays of typically low permeability. The third aquifer system, which underlies the IAS, is the confined Florida Aquifer System (FAS). It is composed of a series of limestone and dolomite formations.
What are the cumulative impacts from mining on the water quality and water quantity to the SAS, IAS and FAS?
Roughly, two-thirds of IAS groundwater withdrawals occur in Charlotte, DeSoto, and Sarasota counties. The Corp needs to locate and identify all domestic supply and public supply wells. How will phosphate mining impact existing domestic well users? A review of county comprehensive plans to determine future land uses that would require domestic supply wells is necessary to ascertain how phosphate mining will affect the ability to provide water for those adopted land use designations.
Determination of changes in the recharge and discharge capabilities of the SAS, IAS, FAS and the impacts of those changes needs to be determined.
The Corps needs to quantify the number of phosphate extraction years based on all phosphate deposits in the CFPD using worst and best case scenarios. The Corps needs to quantify the past, current and future opportunities for phosphate and phosphate by products. Using the number of years or volume of phosphate and the demand for phosphate related products when will phosphate from the CFPD be mined out? What are the economic impacts on Florida and America when there is no more phosphate?
What technology is currently available or on the horizon to replace phosphate? What impact do practices like sustainable farming and fertilizer ordinances that restrict fertilizer use have on the need for phosphate?
City and county Comphrensive plans include population projections for the state of Florida. Even with the current economic situation, people will continue to move to Florida. Comphrensive plans identify Future Urban Lands for future population growth on maps. How close will phosphate mined lands come to the identified future urban lands? Does the value of those lands decrease as mining moves ever closer?
What is the average life of a phosphate mine? How much revenue is generated by the mine in property taxes? If the land were used for housing, how much revenue would be generated in property taxes?
How long does it take for the moonscape/slime ponds to be reclaimed? What is the amount of revenue generated from reclaimed phosphate land in property taxes?
The Corps needs to determine the current land uses of unmined, phosphate owned land. If the land is currently used for agriculture production, an assessment of the value the crops and livestock inject into the economy of Florida needs to be determined. The value needs to take in consideration the ancillary jobs (grocery stores, restaurants, food processing facilities, transportation, container manufacturers, leather products, and etcetera) that will be lost when agricultural lands are mined.
What revenue generating activities have and will occur on reclaimed phosphate land; how long does it take before the land generates income? Are any previous land use activities precluded from using reclaimed land (too radioactive, soil strata has changed and will not support certain/all vegetation)? What are the economic and environmental costs to maintain reclaimed land either annually or while under phosphate control?
HEALTH AND SAFETY
The AEIS should contain a list of all chemical, chemical by products and radioactive materials used during the phosphate mining/processing activities. The list will contain all know health risks associated with the chemicals, by products and radioactive material. A dollar amount will be assigned for the medical costs of those risks if they are realized. The list will identify any ecologic costs should the chemicals, by products and radioactive material is released into the environment.