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Pangea Environmental letter to DNR

October 12, 2021

Kirk Lapham

Director, Mineral Management Section

Michigan Department of Natural Resources

Lansing, MIRE: Mineral Leases at Brighton State Recreation Area, Genoa Twp, Livingston County

Pangea Environmental, LLC has done a cursory review of the site conditions at the two proposed mineral lease locations. The mineral leases are for the mining of sand and gravel.

The review included an investigation of potential environmental concerns and the economic

viability of an aggregate mine. I have years of experience in the extractive industries that include mining and petroleum exploration and production and retired as a Senior Geologist with the Michigan Department of Environmental Quality (DEQ).

I have developed, permitted and managed industrial mineral mines in my career and I am not against mining. I have been a member of the Society of Mining Engineers, American Association of Petroleum Geologists and was an active member of the Michigan Oil and Gas Association, where I served on their environmental committee.

If these leases are granted the leasee will need to comply with the Michigan Zoning Enabling

Act (MZEA) at the local level for a Special Use Permit and/or rezoning. The MZEA requires a

demonstration of the need for the additional aggregate in the market and a demonstration that the deposit can be mined at a profit.

After these are demonstrated, the local government then considers the “Very Serious

Consequences” that could occur. These leases fail on all three. Why lease minerals if the

permitting will be problematic and most likely not be allowed by the local government?

Chilson is an historical location for sand and gravel mining. The parcels offered for lease have been mined, previously.

A 1907 topographic map shows rail sidings into what was at one time H & H Gravel. Field observations appear to confirm extensive mining has occurred on both parcels. How much is left? Much of the relief appears to be the result of this mining and the left over tailings piles.

The larger parcel along Brighton Road was used as a dump for years. Aerial photos from 1967 show the extent of the dump. This will remove a large area from possible mining unless the dump is removed!

Aggregate processing needs water to wash the sand and gravel and control dust during

crushing and sizing. The groundwater beneath the northern parcel is contaminated with sodium and chloride from the Oak Point WWTP effluent.

Both the dump and WWTP effluent are potential sources of PFAS. I do not believe any testing has been done for PFAS. We will be contacting EGLE RRD about sampling select residential wells and any remaining monitoring wells on site. We have discovered PFAS at a very similar location in Holly, MI.

Not only is there a potential problem with the groundwater extracted for use in the mine, but that groundwater has to be returned to the subsurface. (A closed loop system may be employed but fugitive water will be present). This can cause additional contamination and changes in the shallow hydrogeological conditions.

Fugitive silica dust is a serious problem around aggregate mines. Silica causes silicosis and lung cancer. The smallest and most dangerous particles travel the furthest. The leases are surrounded by homes, schools, campgrounds, lakes, wetlands and trails used by the public.

This are not appropriate locations for an industrial operation.

The General Permit issued by EGLE Air Quality Division (AQD) exempts gravel mining and crushing from monitoring for airborne silica leaving the site (fugitive dust). The workers are protected under the Mine Safety and Health Administration (MSHA), but not the residents across the property line! We have convinced the Michigan Department of Health and Human Services (MDHHS) to start a study into the apparent cluster of illnesses around a sand and gravel mine in Jackson Co. That setting is less populated than the area included in the mineral leases.

Property devaluation can be as high as 30% next to a mine. This is another “Very Serious

Consequence” the local government must consider in the local permitting process under the MZEA.

As you can see there are serious hurdles any mine applicant must go through at the local level. From my experience these two locations will not be mined due to Genoa Twp not granting a permit/rezoning due to the conditions of the MZEA not being met.

Why waste time on leases that have questionable reserves due to past mining going back over 100 years and there are so many “Very Serious Consequences” that will have to be overcome.

There are other issues we will be bringing up if the leases are granted that include traffic safety, noise, and more. All allowed under the MZEA. The property devaluation alone should kill these mines.

Removing aggregate prior to development can be a good practice in places. But not near

campgrounds on state land and in residential areas. Fitting into the character of the area is

another “Very Serious Consequence” that can be considered under the MZEA for denial!

Prior to the clear cutting, was a habitat study performed? How about a wetland delineation?

Hydric soils are indicated on EGLE’s Wetland viewer and shallow groundwater is present on the proposed leases.

In summary, the parcels appear to have been mined over 100 years ago and questionable

quantities of usable sand and gravel remain. The permitting process under the MZEA offers

multiple valid reasons for denying any permit. There are serious potential human health

concerns and environmental hazards involved with mining in this area. The DNR should be

setting a better example for the public.

We are all busy, so why waste time and more taxpayers’ dollars on this fiasco?

Thank you.

Pangea Environmental, LLC

Mike Wilczynski

Certified Professional Geologist-Emeritus

Mining and Hydrogeology


Cc: Ron Olson

Pete Rose

Pangea letter to DNR
Download PDF • 102KB

The Department is required to accept public comments on the proposed mineral leasing of these three parcels. Public comments may be submitted in writing, no later than October 27, 2021, to the DNR at: Kim Venne, Minerals Management Section Finance and Operations Division Michigan Department of Natural Resources P.O. Box 30452, Lansing, MI 48909 or

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