Posted by Mary O'Brien on February 19, 2002 at 10:24:17:
Apologies for the FOUR attachments - they are charts that will help
"daylight" the science the County Commission staff has not summarized for
the Commissioners, and which some Commissioners would like to ignore. I'll
be delivering copies of the cover letter (see below) and the four charts to
the Commissioners' mailboxes today.
Hopefully this citizens' guide will prevent the Commissioners on
Wednesday, February 20, from ignoring the science that says a gravel mine
out on River Road WILL destroy surrounding farm operations. (Yup - the
Commissioners meet on this during the same day of the evening planning
commissions' West Eugene Parkway public hearing.) State land use law
basically says the mine can't be permitted if it will harm the operations
or costs of surrounding family farms.
Here is the cover letter for the charts:
A CITIZEN'S GUIDE TO KEY DISAGREEMENTS BETWEEN
EUGENE SAND AND GRAVEL'S CONSULTANTS
AND OTHER SCIENTISTS
REGARDING POTENTIAL HARM BY PROPOSED GRAVEL MINING
TO SURROUNDING FARMING OPERATIONS
On January 30, 2002 the Lane County Commissioners voted that Eugene Sand
and Gravel (ESG) had shown by representative sampling that the River Road
site on which ESG wishes to excavate and operate a gravel mine has a layer
of road-grade gravel that is more than 60 feet thick beneath the
overburden of soil. In other words, they voted that there is a
"significant" source of gravel on the site.
On Wednesday, February 20, 2002, at 9 a.m., the Lane County Commissioners
will again meet as a panel of "judges" in a quasi-judicial decisionmaking
process to "vote" on the next step in the decisionmaking process that could
prohibit or permit the gravel mine. This step is to vote on whether the
gravel mine and mining operations proposed by ESG can be run without
forcing significant changes in the farming practices or costs of
Several potential harms will be considered. If any one of them appears to
pose the likelihood of forcing significant changes to the costs and
practices of the surrounding farms, the gravel mine cannot be permitted
directly, according to state land use law. Likewise, if the accumulation
of smaller stresses from individual harms appear to pose a cumulative
likelihood of forcing significant changes in farming practices or costs,
the gravel mine cannot be permitted.
These questions include:
1. Will dust from the gravel mining operations be of such minor amount that
the growing and marketing of fruits and vegetables or the raising of horses
, won't be significantly harmed?
2. Will ESG be able to maintain groundwater levels for farmers' access to
water when the mine pit draws the water level down?
3. Will farming operations be unharmed when flood levels are raised on
their land because of berms surrounding the gravel pit?
4. Will the amount of added truck traffic in front of the farm stands at
Thistledown and Lone Pine make no significant difference to these farmers'
ability to market their produce?
If the answer is NO to ANY ONE of these questions, or if significant
changes to costs or practices will be caused by the SUM of any of these
stresses, then the mine cannot be permitted outright. A number of
scientists and experts disagree with ESG's consultants on the answers to
each one of these; collectively, these scientists believe the answer is NO
to all four questions.
ESG's consultants predict minimal dust; that ESG can restore water to
surrounding farms; that no harm will result from the increased flooding,
and that traffic will have no significant effect.
Other scientists say more dust will land on the farms than ESG's
consultants predict and that it will harm fruit and berry-growing. They say
that experience elsewhere shows that ESG's proposed water restoration
scheme will not work.. They say there is evidence the flooding could be
greater than ESG predicts and that flooding increases of just a few inches
will harm the agricultural operations. They say that traffic will be worse
than ESG predicts.
So, like all judges, the County Commissioners have to look at the evidence
on both sides and decide which "experts" have provided more credible
evidence. The burden of proof is on ESG that they will NOT force
significant changes to the farming practices or costs of surrounding farms.
Until now, the County Staff has not provided you, the public, or the
County Commissioners with any explanation of the major points of contention
in this debate.
The following charts help show some of the major points of contention
between ESG's consultants and other scientists and experts.
A reminder to you about numbers. Some numbers are ESTIMATES, and other
numbers are MEASUREMENTS.
The scientists and experts on both sides are PREDICTING (a fancy term for
"guessing") what will happen in the future. They are using numbers to make
these predictions, but some of the numbers are only ESTIMATES, while other
numbers are MEASUREMENTS. Both of those kinds of numbers LOOK alike, but
ESTIMATING that there are 15 cookies left in a cookie jar is different than
COUNTING (i.e., measuring) that there are really only 12 cookies left.
So sometimes the scientists and experts are using MEASUREMENTS to predict
(as when Camille Sears says that measurements show that only about 50-70%
of road dust gets controlled) and sometimes they are using ESTIMATES to
predict (as when ESG says they estimate they'll be able to control 99.5% of
the road dust, so they can meet LRAPA dust standards).
Likewise, sometimes the MEASUREMENTS one side uses are ON-SITE and
sometimes they are OFF-SITE. For instance, Joel Massman uses pumping test
measurements of water flow that were taken ON the proposed mining site to
predict that ESG would have to pump much more water back into surrounding
aquifer each day than ESG predicts. For its prediction, ESG uses
measurements from sites several miles away with different ground water
conditions to predict that they won't have to pump so much water.
Finally, each side is using MODELS into which they plug these estimated
and/or measured numbers. They choose what model they will use and that
influences what numbers they come out with. For instance, ESG predicted
dust deposition on nearby farms by using a model that assumes the ground is
smooth and that dust will be carried farther away because there is little
to stop its flow. Camille Sears predicted more dust will be deposited on
nearby farms by using a model that recognizes that there is a filbert
orchard directly downwind of the dust, i.e., the ground is NOT smooth in
all the areas, and so more dust will be "captured" by the trees.
As you watch Lane County Commissioners act as "judges" on February 20, the
enclosed guide will help you see whether the Commissioners are:
1. UNDERSTANDING the conflicting evidence that experts have given them
on two sides of the questions of harm;
2. DISCUSSING the implications of the conflicting evidence; and
3.. DECIDING on the basis of the best scientific evidence and most
Prepared by: Mary O'Brien
February 19, 2002
P.O. Box 12056
Eugene, OR 97440