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HomeMy Public PortalAbout048-2022 - HAYS MEMOShannon Hayes 1432 Clearcreek West Dr Richmond, IN 47374 765-373-8740 November 16, 2022 Ian Vanness Director of Infrastructure & Development Re: Ordinance 48-2022 and the East Aquifer Protection District Dear Mr. Vanness: I’m writing to advocate that the Richmond Unified Development Ordinance Articles 3.07-3.13 Aquifer Protection Overlay (APO) be applied to the proposed over-55 development on Garwood Road. I believe that the close proximity of the parcel to city supply wells and the underlying geology necessitates using the development and management standards in the APO to protect Richmond’s water supply. The proposed over-55 development is located directly on top of the aquifer that is supplying a significant portion of the city’s drinking water. The property is located approximately ½ mile southwest of the Cooper- Kelly wellfield (Figure 1). Indiana Department of Natural Resources public water supply records indicate that the three Cooper-Kelly wells are 15-30 feet deep in the Whitewater River Valley Outwash Aquifer Subsystem. Both the Unconsolidated Aquifer Systems of Wayne County, Indiana (Indiana DNR, 2011) and the USGS study contracted by City of Richmond to assess the vulnerability of this aquifer to contamination (Buszka et al., 2007), show the aquifer extending underneath the property in question (Figures 2 & 3). The aquifer consists of surficial sand and gravel glacial outwash deposits surrounded by less permeable glacial till (Figure 2). The USGS study states that the shallow depth and fast groundwater flow rates make the aquifer highly vulnerable to contamination (Buszka et al., 2007). At this time, we do not know which way groundwater flows under the property. The USGS study shows an overall southwestern flow direction of groundwater in the area north and east of the public supply wells (Figure 3). However, the topographic maps show the ground surface sloping gently eastward. Given the shallow depth to groundwater, there is a good chance that the water under the property also flows east. There is no site-specific data available to predict how a high-density, residential development could impact the city water supply. It seems unlikely that residential land use would add more contaminants to the aquifer than the current agricultural use. However, it's conceivable that putting a significant amount of impermeable concrete and buildings as well as two retention ponds on top of a shallow, unconfined aquifer could change the aquifer recharge rate and possibly even the groundwater flow direction. As a community, we need to be careful when there is development planned on top of one of our best sources of water. The East Aquifer Protection District ends on the east side of Garwood Road, across from the proposed development. However, the aquifer extends further west, under the proposed development roughly to Henley Road (Figure 2). I do not know why the western portion of the aquifer was not included in the APO when it was created, but believe this is an oversite that should be rectified. In the meantime, I encourage the city to require APO code on this new planned development. Sincerely, Shannon K Hayes IN Licensed Professional Geologist 2330 References: Buszka, Paul M., Watson, Lee R., Greeman, Theodore K., 2007. Hydrogeology, ground-water-age dating, water quality, and vulnerability of ground water to contamination in a part of the Whitewater Valley aquifer system near Richmond, Indiana, 2002–2003: U.S. Geological Survey Scientific Investigations Report 2006-5281, 120 p. (https://pubs.usgs.gov/sir/2006/5281/pdf/sir2006-5281.pdf) Maier, Randal, 2011. Unconsolidated Aquifer Systems of Wayne County, Indiana, IDNR, Division of Water, Resource Assessment Section (https://www.in.gov/dnr/water/files/83_Wayne_County_UNC_AQSYS_map.pdf) Attachments: Figure 1. Proposed development and Cooper-Kelly public water supply wells on 2019 Air Photo Figure 2. Unconsolidated Aquifer Systems of Wayne County, Indiana (clipped from Maier, 2011) Figure 3. Groundwater flow direction from USGS study Dec 24, 2002 (developed from Figure 12 in Buszka et al., 2007) 2019 Air Photo from the Wayne County GIS Data Server Proposed development Cooper-Kelly Wellfield Aquifer Protection Overlay District Figure 1. Proposed development and Cooper-Kelly public water supply wells on 2019 Air Photo Whitewater River Valley Outwash Aquifer Subsystem From Maier, Randal, 2011. Unconsolidated Aquifer Systems of Wayne County, Indiana, IDNR, Division of Water, Resource Assessment Section (https://www.in.gov/dnr/water/files/83_Wayne_County_UNC_AQSYS_map.pdf) Proposed development Aquifer Protection Overlay District Cooper-Kelly Wells GLACIAL TILL- very limited waterSAND & GRAVEL SOURCE: https://www.in.gov/dnr/water/files/83_Wayne_County_UNC_AQSYS_map.pdf Figure 2. Proposed development Figure 3. Groundwater flow direction from USGS study Dec 24, 2002 Approximate extent of upper aquifer Aquifer Protection Overlay District Based on Figure 12 in Buszka et al., 2007