Here's Why the National Park Service Should
Stop Dynegy's Riverbank Project
Click to read EJC's letter to the National Park Service
Dynegy, recently submitted a permit application to the U.S. Army Corps of Engineers for approval to install over a third of a mile of rip rap along bank of the Middle Fork, immediately upstream from Kickapoo State Park. This massive project is the first step in Dynegy’s plan to cover and permanently leave 3.3 million cubic yards of toxic coal in unlined, leaking pits along the river. River advocates believe that Dynegy should move their ash to an upland, properly lined facility. By doing so, only short-term, interim and targeted bank reinforcement would be necessary to protect the river from the coal ash.
This massive project is the first step in Dynegy's plan to cap and leave 3.3 million cubic yards of toxic coal ash in the floodplain of Illinois' only National Scenic River. Tell the National Park Service they should follow requirements of the Wild and Scenic Rivers Act and withhold their approval. Click here to send your letter.
Because the Middle Fork is a designated National Scenic River, Dynegy’s proposal must receive approval from the National Park Service (NPS). The NPS, along with the the Illinois Department of Natural Resources (IDNR) as the state administrator, are bound by Sections 7(a) and 10(a) of the National Wild and Scenic Rivers Act to protect and enhance the river’s free-flowing condition, water quality, and outstanding remarkable values for which the river gained its designation. These values include scenic, recreational, ecological, geologic and historic resources.
But the project does none of these things. Instead, it would:
- Artificially constrain the river’s free flowing condition. As planned, 11,500 cubic yards of rip-rap and stone toe protection, and an additional 2,000 cubic yards of soil would be placed below the ordinary high water mark for a distance of 2,000 linear feet.
- Degrade water quality in the river. The proposal would require extensive excavation of soils and sediments within the bed and bank of the river. These materials are known to be contaminated with heavy metals and would be conveyed downstream.
- Harm recreational use of the river. Construction of the project would take place from the river during prime recreational months when the water levels are low. While plans to construct a portage are under consideration, it is unlikely that most using the river will be willing to carry canoes, kayaks and gear for over 1/3 of a mile to avoid construction. And those who do may choose never to return to the Middle Fork.
- Degrade the scenic value of the river. Adding 2,000 feet of white, limestone rip rap along the west bank of the river next to the coal ash pits disrupts the natural character of the river, which is one of the reasons it received its designation.
Make a Difference. Write the National Park Service Today!
The National Park Service has already gone on record expressing concerns over riverbank stabilization ultimately installed by Dynegy in 2017. In June of 2016, they wrote in their FINAL SECTION 7(a) EVALUATION AND DETERMINATION prepared for Dynegy's 485-foot long project along the New East Ash Pit:
“The location of the fly ash disposal ponds is not consistent with the purpose of the River and the removal of the ash ponds, as well as associated embankments, streamside pump house, and non-operational infrastructure that remains within the river corridor would protect and enhance the River and its values.”
In that same letter, the NPS concluded that Dynegy's 485-foot long project was not fully consistent with Section 10(a) of The Wild and Scenic Rivers Act and recommended the following actions be taken (see page 10):
- Remove the coal ash pits.
- Remove the rock protection installed for stabilization, when the ash pits are relocated to restore the riverbank to a more natural condition.
- Remove the pump house, downstream of the New East Ash Pit, which no longer is functional.
- Remove the coal plant stack.
- Continue coordination between stakeholders and agencies regarding the long-term restoration potential at the Dynegy site and the need for a comprehensive approach to riverbank management.
We agree with this assessment, and hope you do, too.
Dynegy's most recent plan to build another 2,000 feet of wall means there would be rock wall along the west bank of this National Scenic River that is nearly 1/2 mile long. The plan also would provide tacit endorsement for leaving 3.3 million cubic yards of coal ash within the floodplain of the river, a condition that is unnecessary and antithetical to the Middle Fork’s National Scenic River status. The National Park Service cannot determine that this project, with its attendant impacts, is consistent with the Wild and Scenic Rivers Act.
We need you to give the NPS the support it needs to withhold its approval. Please use this form to send a letter to the National Park Service today. While you can send the form letter, it will have far greater impact if you use these talking points to personalize your letter.