Questions concerning the Teichert Shifler Mining and Reclamation Project

We are a group of Yolo County citizens concerned about the potential adverse impacts of the Teichert Shifler Mining and Reclamation Project. We would like the Yolo Planning Commission and Board of Supervisors to PRESS PAUSE, because there are TOO MANY QUESTIONS unanswered or not fully addressed in the materials hitherto provided by Teichert.

Our main concerns regarding the Teichert Shifler Project have to do with Water, Prime Farmland, and Liability. Given the size and complexity of the Draft Environmental Impact Report (dEIR) and the Final Environmental Impact Report (fEIR), we would like the Yolo County Natural Resources department to answer some questions that we have had trouble finding answers to in the documentation.

1) WATER. Where in the dEIR and fEIR can we see that the needed and appropriate scientific expertise—geochemistry and groundwater modeling—is being brought to bear on the Teichert Shifler Mining Project AND on the state of Cache Creek?

A)     Cache Creek is contaminated with mercury which primarily comes from Sulphur Bank Mercury Mine, a US EPA Superfund site located at the east end of Clear Lake.  

B)     It has been estimated that mining activities released 220,000 pounds of mercury into the Clear Lake ecosystem (Suchanek et al., 2008).

C)     The Cache Creek watershed is the largest contributing source of mercury to the San Francisco Bay Delta (Weeks, 2018).

D)      The transport pathways and environmental cycling of mercury are complex and even now are incompletely understood (Marvin-DiPasquale et al., 2019). Chemical and biological transformation of mercury generates methyl mercury, which is highly toxic and bio-concentrates in wildlife (Suchanek et al., 2008). Other environmental by-products are also very toxic. 

E)     It is likely that mercury is lodged in downstream sediments. Aggregate mining can disturb long-dormant streambed sediments and re-release mercury back into the water. Insufficient attention has been paid to the status of mercury in the side channels. 

F)   In addition, insufficient attention has been paid to the enormous amount of water required for mining. Groundwater pumping rate cannot exceed 3,500 gallons/minute (gpm); annual use cannot exceed 1,910 acre-feet/year. You would meet that maximum if you pumped 1,184 gpm for 24 hours/day, 365 days/year. Where in the dEIR or fEIR is this discrepancy explained? How does this enormous use of water compare with the amount used to irrigate crops? 

G)    Moreover, insufficient attention has been paid to the “fines” or sediment that Teichert intends to return to the pit, since this is where chemical reactions are likely to happen. This could also lead to Liability issues in future (see #3 below).

H)    Chemical transformation and movement of mercury from its original source to downstream locations needs to be thoroughly investigated. If groundwater ever becomes contaminated, it is extremely difficult – if not impossible – to clean up.

I)    The Cache Creek Technical Advisory Committee consists of three scientists whose focus appears to be the ecology of the creek. Given the potential for aggregate mining to adversely affect groundwater, the Committee needs the addition of scientists with expertise in geochemistry and groundwater modeling.

 

2) PRIME FARMLAND. Where in the dEIR and fEIR can we find legal and scientific proof that reclamation of 113 acres to agriculture—just over one third of the acres involved in the full Teichert Shifler Mining Project—will return the soil and fields to pre-mining quality and yield?

A)    In the updated Cache Creek Area Plan materials it is acknowledged that mining-induced loss of farmland will be “SU,” significant and unavoidable. But if there is to be meaningful reclamation, then the soil or “overburden” as it is called, needs to be returned to the productivity it knew before the mining project. Teichert’s video at the November Planning Commission meeting did nothing to allay our concerns on this issue.

B)    We depend on the earth's topsoil for 95% of our food; yet it is being rapidly degraded at a rate where the world can run out of topsoil in about 60 years, according to M. Semedo of the UN's Food and Agriculture Organization (2019). Research shows that topsoil removal disturbs organisms in soil communities and affects physical and chemical soil properties and processes.

C)    Indeed, removing and leaving soil bare for any amount of time reduces organic carbon content and degrades the soil. If crop residue is not returned to the soil frequently, the soil organisms will starve and the soil will eventually die. It will no longer contain enough living organisms to carry on the biogeochemical and biogeophysical processes needed for healthy plant growth. The concentration of organic carbon in the soil should remain approximately 2% in the top 8 to 12 inches. This is essential for water retention, controlling soil erosion, leaching, nutrient cycling and improved soil structure (Lal, 2020).

D)    Compaction from heavy machinery and scraping away topsoil—as with the reclamation proposed by Teichert—decreases the porosity of the soil and its ability to hold water. Moved soil loses organic matter and nutrients. Once soil is returned, it is costly, slow, and labor intensive to heal the soil. To make the soil productive again organically, it requires much water, labor, and investment to grow, irrigate, and rotate Nitrogen-fixing cover crops, and mow and dice plant material to add organics to the soil. Choosing to use synthetic fertilizers might speed the process at first but in the end, it would degrade the soil even more and grow less healthy produce (Woodward, 1996). 

E)     Soil analyses need to be completed over a long term—before soil is removed, after it is returned, and through several growing cycles. It is critical to track amounts of essential plant nutrients, the ability of soil to hold onto them (called Cation Exchange Capacity, CEC), and bioindicators, i.e. soil nematodes and plants. It is also important to know the amount of carbon loss happening from the soil so a sufficient amount of biomass carbon can be added back to the soil (Lal, 2020). All this would help to quantify the success of topsoil removal and restoration in comparison with alternative measures. Tracking amounts of contaminants that may appear in latent stages is also essential for transparency, remediation, and best practices.

F)    We cannot afford to degrade precious natural resources that have taken thousands of years to develop and then depend on short term remedies. Structural breakdown of soil is easier to prevent than to cure, so maintaining or improving soil structure is one of the most important aspects of soil management. Choosing to preserve Class 1 agricultural farmland would be a wiser and more climate-friendly approach to use the natural resources we are blessed to have in Yolo County.

 

3) LIABILITY. Where in the dEIR and fEIR can we find legal guarantees that, during and at the completion of mining, Teichert will be held responsible to repair any contaminated groundwater and soil and to reverse any adverse impacts of air and noise pollution?

A)    Impacts of trucking and machinery pollution. Conversion to green technology would need to happen at the beginning of any excavation. Where can we find discussion of Teichert’s responsibility to respect the County’s climate neutrality goals? Where in the dEIR and fEIR can we find out how noise and air pollution levels will be monitored on a daily basis and how these will affect residents, visitors, and workers? Where in the dEIR and/or fEIR is it explained what fuel will be used by the converted vehicles? Exactly how many trips will there be and what will the emissions be? Who will be monitoring the traffic and emission levels? Rubberized asphalt has been proposed by Teichert as a way of reducing noise pollution; what will be the level of this rubberized asphalt particulate matter, released as the result of heavy mining loads and as the road ages, cracks and degrades?

B)    Woodland Plant. What does it mean that Teichert will dedicate the Woodland Plant to the county at the end of their use? What will be the county liability in receiving the plant?

C)    Confused presentation of the timeframe. Where in the dEIR and fEIR can we find legal guarantees about the timeframe, especially concerning completion dates for mining and reclamation? For example, recent visitors to the proposed mining area could see no visible reclamation work done on the neighboring Storz mining project, completed 4 years ago, even though the suggestion at the November Planning Commission meeting was that it would become part of a larger Parkway reclamation. Given this, what are the legal guarantees that the promised Teichert reclamation would be ongoing during a Teichert Shifler project—ensuring top soil and land would not further degrade before the final reclamation and restoration take place after thirty years? Has a timeframe for such reclamation/restoration been considered, to hold Teichert responsible to a particular schedule over the next years, something that is especially pressing in the current context of climate change conditions and impacts on the county?

D)    The Maintenance and Remediation Fee. This 4.44% fee is in an interest-bearing account. What is the actual balance today of the account and the projected balance in 2027 when the first funds are available for mercury management (if needed), environmental monitoring beyond what is already required, and the monitoring and maintenance of pits? Whose liability is it if funds are needed for these purposes before 2027? Which pits are to be monitored; does monitoring only begin when the funds are available? Are the funds adequate? If funds for habitat restoration, recreation, and creek stabilization are only available in 2047, when exactly is the restoration, creation of recreation areas, and creek stabilization scheduled to occur? What if the funds have already been used for mercury management, etc.? What happens in the extreme case of subsidence of land or depletion of water sources for residences and agriculture? Off-channel mining has its problems, too.

In sum, we urge you to PRESS PAUSE. There are TOO MANY QUESTIONS to be answered before we commit to a project of such magnitude at this time of climate emergency.

Yours sincerely, 

Concerned Yolo County Citizens

Hannah Adamy*

Lizabeth Albanez*

Jacki Amos

Frances Andrews

Harriette Andrews

Mark Aulman*

Lucas Baillargeon**

Cidney Barcellos

Steve Barzo

Juliette Beck

Laurel Beckett

Frankie Brandemeyer

Nick Buxton

Helen Campbell

Brian Chamberlain*

Carolyn Chamberlain

Elizabeth Coolbrith*

Robin Datel*

Judy Davis*

Mike Davis*

Pamela Dolan

Greg Dryfoos*

Renee Dryfoos*

Diane J Emmrich*

Jorge Espinoza

Candice Foster

Rolf Frankenbach*

Peggy Froelich

Andrea Garza

Ayush Garg*

Ryan Gault*

Peter Gee

Vern Goehring*

Michael Goos

Liza Grandia

Pamela S. Gunnell**

Abby Hanus

Wendy Heller*

Charlene S. Henwood*

Carole Hom*

Blake Hurzeler

Jon Ingenthron

Mary Anne  Ingenthron

Alan Jackman*

Jean Jackman*

Jamie Jensen

Alessa Johns

Roy Kaplan

Vernice Karbe*

Elise Keddie*

Deborah Khaw**

Cecilia Kwan**

Maya Krishnan

Adam Lea*

Trudie Lerner*

Janet E Levers*

Stanley W Levers*

Ann Liu

John Liu

Susan Lugo

Jacob Lynch

Johnny Lynch

Ryan McBride

Tobias Menely

Robert Milbrodt*

Elizabeth Carolyn Miller

Roberta Millstein*

Michael Mlekoday

Kali Mulligan*

Sookeun Neaverth*

Pamela Nieberg*

Lynne Nittler

Mackenzie Nye

JoyAnne Noll

Ron Oertel*

Sally Oliver*

Camila Ortiz

Pablo Ortiz**

Jessie Ann Owens*

Nikita Tignesh Patel

Ana Peluffo**

Isa Perez

Rebecca Petrik*

Sedona Patterson-Smith

Alison Pease

Steven Pierce**

Don Price

Nancy Price

Alan Pryor

Chris Reynolds

Gabriel Reynolds

Joyce Reynolds**

Ranse Reynolds**

Rodney Robinson*

Joseph Robson

Nan Rowan**

Charles Salocks

Susan Knadle Salocks

Eileen Samitz*

Eddie Sanchez*

Johanna Schmitt *

Bill Schwarz*

Sharon Schwarz*

Anett Szczepanek

Olivia Sinclair

Karen Slinkard*

Steve Slinkard*

Scott Steward

Kathleen Stock**

Matthew Stratton

Sharon Strauss*

Obin Sturm

Beth Tanke*

Brenden Tull

Anuj Vaidya*

Pam Van Brocklin**

Katy Vigil-McClanahan**

Colin Walsh*

Emma Ware

Sam Warren*

Claire Waters

Robert Weidenfeld*

Jessica Weng*

Gina Werfel

Brendan White**

Meg Whitman

Changruo Wu**

Angelina Crans Yoon**

James Yoon**

*  Name added after 2 December 2021

** Name added after 9 December 2021

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