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Regarding Sargent Sand Company Permit Renewal

  • We would prefer it is not necessary to ask your help in this matter: that is, addressing the permit renewal application which Sargent Sand has filed with the Michigan Department of Environmental Quality, Office of Oil, Gas, and Minerals (DEQ-OOGM). However, Sargent Sand is keeping all their options open by filing this application. And so must we keep all our options open.

  • Furthermore, one of Sargent's arguments regarding the appropriateness of coastal dune mining in the Ludington Dunes, has been this: "No one commented at the last renewal." Comments were certainly made ca. 2006. However, no one foresaw the massive operations Sargent had planned, and which DEQ approved, in 2010-2011. More fool we; but because we have largely been silent in the past, does not mean we give up our rights to speak, now and in the future. 

  • Since the late 1920s, Sargent Sand Company (Sargent) has been mining sand from the coastal dunes referred to as the Ludington Dunes, which are the southern 40% of the Big Sable Dune Complex. This Complex also includes the Nordhouse Dunes Federal Wilderness Area, part of Manistee National Forest; it includes, as well, open coastal dunes administered by Ludington State Park.

  • Prior to 2005, historical uses for sands mined from Sargent's property have included road-building and construction materials (1920s through 1950s), foundry sands (1960s and 1970s), automotive and high-quality glass (1980s), and as proppants for use in the hydraulic fracturing process for extracting oil and natural gas (since 2005).

  • Prior to the 1980s, Sargent mined up to a few thousands of tons of sand per year. In the 1980s, Sargent mined several tens of thousands of tons per year. The 1980s operations resulted in removal of relatively smaller dunes, as well as the creation of a dredge pond. (The dredge pond became known as Lake Ann following its transfer to Ludington State Park around 1987.)

  • Through even the heavier 1980s operations, impacts on neighbors, including Ludington State Park, were relatively minimal.

  • Sargent's operations were largely dormant through the 1990s. However, its permit remained current.

  • Beginning in 2006, Sargent ramped up operations dramatically. By 2010, Sargent was removing around 100,000 tons per year. After deploying new capital equipment in 2012, Sargent's production capability rose to 800,000 tons per year -- roughly 100X the rate of historical production. 

  • This massive increase in production followed closely the dramatic rise in the price of commodity silica sands in the US

  • The massive production increase has impacted local residents negatively and substantively. It has also impacted morphological features of dunes on Ludington State Park property, as well as wild flora and fauna in the dune lands, both forested and open. 

  • The massive production increase also has closed off opportunities for some of the options for future, sustainable development (post-mining).

  • Yet, the permit relies upon an Environmental Impact Statement (EIS) written in the 1970s (when the first Michigan Natural Resources and Environment Impact Act was passed). This EIS is found HERE. It is wholly inadequate for the size and scope of Sargent's operations, as they have emerged over the last ten years, and in particular over the last five years.

  • The State of Michigan, through the Department of Environmental Quality, Office of Oil, Gas, and Minerals, is responsible for issuing operating permits for sand mining in coastal dunes. 

  • Permits are granted according to the specifications of Part 637 of the Michigan Natural Resources and Environmental Protection Act (MNREPA), No. 451 of the Public Acts of 1994, as amended. A copy of Part 637 is located HERE.

  • More information, including a PDF of the permit renewal application, can be found on the DEQ-OOGM website HERE.

  • ACTIONS: Therefore, the Ludington Dunes Conservancy would like you to take the following actions.

  • Be aware that mining of these particular coastal dunes in the present era is, to a large extent, a fluke. DEQ-OOGM was mandated in the 1970s to identify substitutes within Michigan for coastal dune sands. These substitutes were required to meet specifications for industrial uses, particularly as foundry sands. The report can be seen HERE. The report says, in particular, that these coastal dunes can be replaced by sands found in sandstone formations, including formations in Lake County, just east of Mason County. (Note that we made just such a suggestion at the AFFEW-sponsored events in March and May.)

  • In light of this fact, the only reasons Sargent Sand Company still mines these sands: 1) "It's easy." (Quote from Kurt Koella, environmental consultant for Sargent Sand, at Sand Mining Forum in Ludington, May 2016. By 'easy', he meant operationally easy, and therefore very inexpensive relative to conventional, sub-surface mining.) 2) Despite the restrictions of MNREPA, Sargent is legally able to continue to mine, because it kept its permit current for nearly 80 years. 3) Despite a history of environmental awareness, and a proven awareness of the sustainable, natural resource value of their coastal dune lands, Sargent nonetheless made the determination in the early 2000s to ramp up production dramatically, and mine the landscape aggressively. Why? Because, in effect, in 2000 Sargent Sand won the 'commodity minerals lottery': the price of silica sands went from barely level with inflation (for the period 1914-2000), to in some cases 20X above the inflation-adjusted historical value by 2014.

  • Be aware, too: Sargent Sand Company operates within its rights. It treats its employees fairly. It meets or exceeds all requirements, for water quality, for safety, and for other parameters. Its owners and employees are decent people, professional and skilled.

  • Unfortunately, Sargent's historical interest lies at odds with the modern interests of neighbors (including Ludington State Park) and the county and the State. Sustainable practices are the goal of all modern businesses. Indeed, DEQ's web site places a strong emphasis on sustainability. Yet, mining is intrinsically unsustainable: a resource is 'developed', then extracted and removed. The unsustainable nature of the practice is reflected in the very accounting principles applied to mining: government grants to mining companies a 'depletion allowance' -- a practice dating back to the 1800s, when sustainability was not valued by society. This allowance means, we (all of us) pay mining companies to extract mineral wealth -- a practice most of us now see to be both archaic, and counter-productive to society's broader interests.

  • First, in your own words, write a letter to the Michigan Department of Environmental Quality, Office of Oil, Gas, and Minerals. Explain why renewal of the permit is problematic for you. Ideally, refer to specific portions of Part 637, which the present permit fails to fulfill. Address: Jennifer A. Ferrigan, Geologist -- Permit Coordinator, Permits & Bonding Unit, PO Box 30256, Lansing, Michigan 48909. Email addresses: ferriganj2@michigan.gov, or DEQ-OOGMpubliccomments@michigan.gov. Suggested areas to focus on: the inadequacy of the 1976 EIS for post-2010 operations; the lack of a substantive reclamation plan; the absence of any mention, in the permit or the reclamation plan, regarding prevention of silicosis on mined lands, after mining operations are completed; the tangible, detrimental effects on local property owners (including Ludington State Park), especially from noise, hours of operation, morphological changes in landscape, effects on humans, fauna, and flora, and effects from blown sands; the effect on roads of transport of sands; above all, the effect of uncertainty (how long will this operation go on?) upon neighbors, whose enjoyment of their own property has been placed in jeopardy by Sargent's development of its property.

  • You might also ask DEQ, why the 1978 study -- which showed appropriate substitutes for valuable coastal dune lands existed, including in Lake County -- was not followed up, by Sargent and the State, with a land swap. Such an endeavor then would have produced a win-win situation for all: preserving Sargent's rights to the value of their minerals; preserving jobs for local workers; preserving tax revenues for the State and Federal governments; and opening new possibilities for development of the Ludington Dunes, as a sustainable resource.

  • Second, ask your friends, neighbors, and other interested groups to submit their own letters.

  • Third, in your own words, write other letters as you see fit and have time. Suggested people to write: Ludington City Council; Ludington Road Commission; your State representatives; your Federal representatives. (Addresses will be added in the next few days. Today's date: Wednesday, October 19, 2016.)

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