The Amy H Remley Foundation  

Fracture Sets Example


The Crystal River Commons project (CRCP) is an interesting example of the application of knowledge of fracture sets to protect aquifer water quality, as proposed by Dr Glen L. Faulkner (1972). In this instance the aquifer water is conveyed underground to issue from springs into an Outstanding Florida Water.

Prior to taking decisions on December 9, 2008, the Citrus County Board of Commissioners (BOCC) were not apprised of any risk to the Outstanding Florida Water (OFW) of Crystal River Kings Bay. Simply, the consultant retained to examine the geological considerations was not asked by the developer to report on that possibility. The CRCP site is wholly within the designated springshed of the OFW, and any degradation of water quality of the OFW is prohibited by law.

The consultant's report includes reference to photo lineaments and correctly positioned one, first identified by Dr Robert O. Vernon in 1951, as passing under the CRCP site. However, the county commissioners remained unaware of any risk to the OFW, it was excluded by the consultants from consideration in their narrative. In fact, at the hearing on December 9, 2008, the developer's legal representative asserted that the proposed development on the site would have no impact upon the OFW.

Incorporating latitude and longitude coordinates of the Kings Bay spring vents into Google Earth, together with the entire FDEP database of sinkhole latitude and longitude positions, has allowed the position of fracture set conduits connecting the CRCP site with spring vents in OFW to be identified. The criteria used conform to those used by the United States Army Corps of Engineers.

Three such conduits, and spring groups of the OFW served by them, are shown on the above view derived from Google Earth to pass under the CRCP development site south of the Crystal River Airport runway.


Much of the environmental discussion before the BOCC involved the wetlands and not the aquifer groundwater flows. [USGS Water-Resources report 01-4230 page 5, "The Coastal Springs Ground-Water Basin is bounded by ground-water divides rather than topographic divides because the principal drainage is by ground water flow in the Upper Floridian aquifer." ]

In that context, wetland mitigation, such as that proposed in 2000 regarding Realticorp' previous submission for this site, has no relevance, especially considering federal law and its requirements for "equivalent value function". -[ The April, 2006, Congressional Research Issue Brief for Congress IB97014. The map - HOMOSASSA QUADRANGLE FLORIDA-CITRUS CO. 7.5 MINUTE SERIES (TOPOGRAPHIC) – sent to me by the United Sates Army Corps of Engineers, shows substantial wetland areas to the east of the CRCP site, scheduled for development as extension of that currently under consideration.] Any evaluation of potential impact upon the OFW must include the impact of disturbing these wetland areas also, since they help to cleanse naturally draining westward flows .

The entire CRCP property is within the designated ground-water divide of Crystal River/ Kings Bay, but is not mentioned in the proceedings. [SWFWMD, Crystal River SWIM Plan July10, 2000, p38. Fig. 8. Also, Jones and Upchurch, 1988, "Origin of Nutrients Discharging from King's Bay Springs", p3, Fig. 2].

Primerica Group One failed to instruct their consultant, Ardaman and Associates to consider possible impact upon the Crystal River/ Kings Bay, an Outstanding Florida Water (OFW). [Classified and protected under F.A.C. Chapter 62-302, and, The SWIM Plan, mentioned above, p38., effective Feb 1, 1982, with water quality not to be downgraded from that existing March 1, 1979. (Chapter 62-302. 700(8) FAC). ]

The Citrus County BOCC were never apprised of any such risk, as the existence of fracture set conduits was not considered before them. Moreover, as soon as the building of roadways, walkways, parking areas, and structures takes place considerable run off from created impervious surfaces ensues. (Storm run off was negligible, prior to the building of impervious surfaces on the site.) The Ardaman report did not portray any need to treat storm run off on site to the more stringent requirements of the state of Florida, having regard to the protection of the OFW. [Personal discussion with SWFWMD.]

Instead of considering the impact of fracture sets shown to run under the CRCP site on Fig 16, of the Ardaman Report, they were erroneously eliminated and not considered at all as to their direct linkage to springs of Kings Bay. [Ardaman Associates Report File Number 07-9849 to Primerica Group One, attn: Steve Facione.]

It should be noted that ground-truthing shows the Black and Tarpon Spring conduits to each have a lateral distance cover of more than 800 feet, and the third conduit similarly. Almost the entire CRCP site would be situated above active fracture set conduits.

Costs to cleanse run off on site to avoid polluting the OFW do not appear in the documentation.
University of Florida scientific studies indicate that the OFW is already suffering progressive eutrophic stress. Dead zones in the Kings Bay restrict fodder for the protected resident winter manatee population, to the extent of causing examples of weight loss, and causing manatees to venture for fodder elsewhere. The springs affected exhibit increased levels of saltiness which is causing ecologic changes in the OFW.


The omission not only compromises the decision processes of the BOCC, but also compromises any due diligence process of any corporation interested in erecting or trading from any building on the CRCP site. It has also been observed at a meeting of the Coastal Rivers Basin Board, that the greater likelihood of sinkholes forming over the fracture sets may well cause liability insurers to quote higher rates, should they be interested to underwrite the exposure.

Significant risk of degradation of the OFW waters is created by development of the CRCP site, which under the OFW law and the Environmental Review Permitting law must be avoided.

Development costs are understated without due consideration of the fracture set conduits and treating run off on site.

The adverse ecologic changes observed to be taking place will accelerate from the affects of any CRCP development, as has been observed from adjacent past development activity.

The annual economic benefit to the community of the OFW, estimated to be in the region of $10million, would be put in jeopardy.

News and Views
News Items

November 30, 2013
On environment, shortsightedness costs Florida big.
Scott Maxwell, Taking Names.
read more

October 9, 2013
Fuel Cell Today analysis.
The Fuel Cell Industry Review 2013.
read more

September 25, 2013
Fuel Cell Today analysis.
The Potential for Fuel Cell Prime Power in Japan.
read more

August 1, 2013
Duke Energy to cancel proposed Levy County nuclear plant.
read more

May 22, 2013
Fuel Cell Today analysis.
Electrolysers for Renewable Energy Efficiency.
read more

March 13, 2013
Beyond Electricity: Using Renewables Effectively.
read more

September 24, 2012
Sewer Systems Legal Filing.
read more

February 1, 2012
Fuel Cell Today update.
read more

January 13, 2012
Sewer Agenda.
read more

December 23, 2011
Scientist: Water account overdrawn.
read more

Novemver 14, 2011
Submission to the Citrus County Commissioner, 14 November, 2011.
read more