Marilyn Baumer, Professional in Conservation
February 6, 2018
Re: NPDES Permit Application of Enon Sand & Gravel LLC
Dear EPA Permit Reviewers,
My name is Marilyn Baumer and I am a professional in conservation working for B-‐W Greenway Community Land Trust.
B‐W Greenway safeguards land with high conservation value, including wetlands and land along waterways, in the Fairborn and southern Clark County, Ohio area. B-‐W Greenway holds conservation easements protecting land along the Mud Run and the Mad River. I am requesting that you deny the Enon Sand & Gravel permit.
My work with B-‐W Greenway provides a very special appreciation of the uniqueness of the area in question. The geology and hydrology of this area results in a rare and beautiful ecosystem that is intrinsically at very high risk of pollution and destruction from human actions. There is a strong connection between the ground water and the aquifer in this region. As others testified at the hearing on February 1, 2018, the area in question is blessed with numerous springs, seeps and very high quality fen wetlands. Fen wetlands are among the rarest type of wetlands and deserve the highest protection. Fens contain a unique set of plants and animals, many of which are specialists to the ecosystem and not found in other areas. The U.S. Fish and Wildlife Service lists the Mitchell’s satyr butterfly (Neonympha mitchellii mitchellii) as an endangered species. This butterfly is restricted to fen wetlands and has an historical range in Ohio.
The permit would allow both dewatering and discharge of water into a short tributary prior to flowing into the Mud Run. It is well documented that wetlands depend upon a narrow range of water to continue to exist. Dewatering will undoubtedly permanently change or destroy the hydrology of adjacent wetlands, causing what may be a slow but permanent decline and destruction.
In addition to the need to protect the wetlands in the area, the discharge of water into the Mud Run will also permanently change the stream. Currently the stream is of high quality as suggested by informal fish surveys that have been done during the monitoring of the easement held by B-‐W Greenway. The discharge will increase the suspended solids in the stream and increase flooding. Due to
the very porous geology of the area, all flooding greatly increases the risk of contamination to the underlying aquifer. The aquifer provides drinking water to the greater Miami Valley region. Protection of this incredible asset demands that decisions favor protection over any potential use that could permanently damage this valuable resource.
Please consider the protection of the unique fen wetlands and the high risk to water quality and deny the Enon Sand & Gravel permit.
Independent Professional in Conservation