Midwest Environmental Advocates began a review of a draft Industrial Sand Mining Strategic Analysis released by the Wisconsin Department of Natural Resources this week.

The DNR’s draft Strategic Analysis is the first glimpse into a long-awaited, comprehensive look into the impacts of frac sand mining on the health, environment, economies and way of life of many Wisconsin communities.

Upon initial review, however, the draft Industrial Sand Mining Strategic Analysis will need a deeper analysis, more data and more input from experts and the public in order to be a meaningful resource for local and state policy makers and agency staff for decision making.

The air quality section has the same fundamental flaw as the agency’s recent actions regarding fine particulate matter, or PM2.5. While the DNR asserts that mechanical processes, such as those at industrial sand mines, do not produce or emit PM2.5 (only larger particles), the agency does not have evidence to support this conclusion.

The Strategic Analysis also relies on studies based on voluntary monitoring and industry-funded studies at industrial sand facilities. The report also only makes passing reference to independent research such as that of UW Eau Claire’s Dr. Crispin Pierce’s PM2.5 study that shows that industrial sand facilities may be causing or contributing to unsafe levels of fine particulate matter around mining facilities. This reliance on industry-funded research shares the same limitations as the Health Impact Assessment of Industrial Sand Mining in Western Wisconsin published by the Institute for Wisconsin’s Health, Inc. earlier this year.

However, the Strategic Analysis does acknowledge the threat of acid mine drainage from industrial sand facilities and supports further study of the potential for frac sand mining to allow metals to leave bedrock and enter surface and groundwater. DNR has known for some time that some wastewater holding ponds at industrial sand mines have had high levels of metals, which present a risk to groundwater quality and the health of rural residents who rely on private wells for drinking water.

But in the meantime, DNR should require monitoring at industrial sand facilities to ensure that these discharges are not going unnoticed. DNR recently revised its industrial sand stormwater and wastewater general permit and should have, but did not, account for uncertainty about the potential for metals in these discharges.

Public comment welcomed

The DNR is accepting public comment between now and Aug. 22. The DNR will host a public informational meeting July 26 at 4:00 p.m. at the Chippewa Valley Technical College, Business Education Center, Casper Conference Center , Room 103A/B, at 620 W. Clairemont Avenue, Eau Claire.

Robust public comment will improve the final Strategic Analysis, if the DNR will hear the public’s concerns, accept more air quality studies, and address the legal and environmental concerns with fine particulate matter associated with frac sand mining.

The True Cost of Sand Petition

On October 29, 2014, petitioner Ken Schmitt presented the True Cost of Sand Petition to the Wisconsin Natural Resources Board and shared his experience as a grass-fed beef farmer in western Chippewa County whose community is increasingly dealing with the negative impacts of frac sand mining. The True Cost of Sand petition was a summary of concerns local citizens have voiced over the last few years.

These concerns about hazardous dust, polluted runoff into streams, truck and train traffic, shrinking natural habitats, and negative impacts on the quality of life in Wisconsin’s Driftless Area have been the root of many of the calls to Midwest Environmental Advocates’ law center’s legal helpline since the initial boom of frac sand mining in our state. Many people who signed the petition expressed shock that the DNR had never done any meaningful, big-picture study of the frac sand industry’s impacts on our water, air and land.

The petition, signed by over 1,100 Wisconsin residents asked for a simple request: The state Natural Resources Board should direct the Department of Natural Resources to conduct a strategic analysis of the impacts of frac sand mining and processing. Then NRB Chairman Preston Cole directed the DNR to review the petition and submit their recommendations for action, and the DNR issued an outline of what the analysis would include in March of 2015.

An unbiased, comprehensive look at the impacts of frac sand mining on the health, environment, economies and way of life of Wisconsin communities can be an invaluable resource for local and state policy makers and agency staff to use for making decisions on zoning, laws and rules, public health policy and land reclamation planning.

For more on the True Cost of Sand Petition and the DNR’s Industrial Sand Mining Strategic Analysis, visit midwestadvocates.org/truecostofsand.

Midwest Environmental Advocates is a public interest organization that uses the power of the law to support communities fighting for environmental accountability. Learn more about the Midwest Environmental Advocates on the web atmidwestadvocates.org, like MEA on Facebook or follow @MidwestAdvocate on Twitter.