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