The Amy H Remley Foundation  

February 21, 2009

Crystal River Commons Project

The following document is submitted for inclusion in the Public Record, additional information may be seen on this Foundation's website at Crystal River – Hydrogeology.


This document is submitted for inclusion in the Public Record in relation to the proposed development of the Crystal River Commons site, and the hearings pending.

On December 9, 2008, the Board of Citrus County Commissioners, acting under Quasi Judicial Rules, voted unanimously to modify the wording of the Comprehensive Plan, the Land Development Atlas, and a Planned Development Overlay to accommodate the application by the developer, Primerica Group One LLC, and others.

County staff have informed that the developer did not ask their investigating geological consultant, Ardaman and Associates, Inc. to comment upon the risk of pollution to the Outstanding Florida Water of Crystal River/Kings Bay, because this was a matter for the State of Florida, not the County.

Whereas, our own research has revealed that there are direct conduit links from the proposed site to spring outflows in Kings Bay (Figure 1 below). Moreover, those waters are already stressed, such that the ecology there is changing, and the local population of the protected Manatee species is stressed and evidenced by weight losses, and we have to pay attention to existing evidence that the assimilative capacity of the environment may well have been reached.

"We must ensure our continuing economic prosperity, but the price we pay for growth must be carefully evaluated. We must recognize that the destruction of Florida is a price too high. Ecological destruction in Florida is nothing less than economic suicide." Declared Governor Reubin O'Donovan Askew on September 22, 1971, in Miami, Florida. Patently, this careful evaluation with respect to the subject proposed development has not yet occurred as it most surely should.

The Water Resources Act, 1972, declared Florida water a resource of the state, and not owned by any individual landowner. Water Management Districts are commissioned to manage the waters to meet all reasonable and beneficial uses of the people of Florida by a system of permits. Since the Commissioners are elected, and paid in office by tax dollars, and County Staff are similarly remunerated, it is submitted that it is incumbent upon them to ensure that the water resource, which is so economically and socially important to the community, will be adequately safeguarded before proceeding with further decision hearings.

Dr Robert O. Vernon

In the research report of the late Dr. Robert O. Vernon, 1951, is a remarkable map of Florida, not the land, roads, buildings and forests, but showing the pressure of water in the artesian aquifer under the ground. He called lines on the map piezometric contours, (meaning, piezo = pressure, metric = measure, contour = line joining points of equal measure).

A region of high pressure lies to our southeast in Polk county. Another high pressure lies to our northeast between Alachua and Putnam counties. Citrus County, in a lower pressure area, receives flow both from the north and the south as groundwaters flow from high pressure areas to lower ones. This piezometric flow, is a modest rate of flow through a system of holes in the limestone. The origin of Florida's ground water is rain precipitation from the atmosphere. On passing through the atmosphere, the falling rain water becomes charged with carbon dioxide gas that combines with water to form carbonic acid. Humic acids from rotting vegetation are added on contact with the ground to form the natural solvent for limestone. As this acid-charged water soaks into the ground, limestone rock is dissolved to make the holes over eons of time.

For the first time, Dr Vernon also indicated locations of many fracture sets, or sets of fissures, in the aquifer rocks, created some millions of years ago as the land emerged and was formed from marine sedimentation.

Three major parallel fracture sets are indicated by Dr Vernon oriented towards Crystal River/Kings Bay. The fracture sets, although indicated as a single line, usually comprise several parallel fissures in the rock spaced from a few feet up to very many feet apart. Between these major sets, depicted by Dr Vernon, can lie lesser fracture sets. An example of this, is where the fissures can clearly be seen from the banks of Black Spring (Lat. 28° 52’ 38.63”, Long. 82° 35’ 57.20”). Several other vents were served by the same line of fractures in Kings Creek and in the waters and on land, out into Kings Bay, for example, the 'hook' of Hook Island. (Not all vents continue to flow today.)

Ardaman Associates showed one of Dr Vernon's fracture sets which can seen as the source of water delivered by Tarpon Hole, a first magnitude spring (also known as King Spring, Lat. 28° 52’ 54.42”, Long. 82° 35’ 41.01”). Several vents emit water in that same locality. Smaller springs are also fed before and after Tarpon Hole along this general lineament.

Dr Glen L. Faulkner

In 1973, the U.S.GEOLOGICAL SURVEY completed the Water-Resources Investigations Report, I-73, GEOHYDROLOGY OF THE CROSS FLORIDA BARGE CANAL AREA WITH SPECIAL REFERENCE TO THE OCALA VICINITY (Prepared in cooperation with: U.S. DEPARTMENT OF THE ARMY CORPS OF ENGINEERS). Dr Faulkner's report illustrates the importance of understanding the geological influences upon ground water flows in an aquifer system and how to build upon work of other distinguished authors, such as Dr Vernon.

Dr Faulkner affirmed the general southerly direction of the piezometric flows to the north of Citrus County, and the influence of the north east to south west alignment of fracture sets, which serve to concentrate and channel the conduit flows.

Also, when piezometric flows encounter a fracture set the water flows combine to follow a path of least resistance in the direction of the fracture. Moreover, the increased quantities of acidic water flowing faster, increases the size of the fracture conduit over time. Enlarging some areas into huge cavernous complexes along the way.

As these underground "conduit" flows break the surface to air or vent into another water body, a spring is formed. Sometimes the roof of an underground cavern collapses to form a really big spring.

Dr Faulkner shows the same major fracture sets of concern regarding Crystal River as those depicted by Dr Vernon.

The fracture sets and contour lines predate the formation of Lake Rousseau by very many centuries. Dr Faulkner showed that piezometric flow from the high to the north of the Lake Rousseau merges with the flow originating to the east and south of the Rainbow River in the area of northeast Citrus County. This would also appear to strengthen the ground water stream along a fracture set passing through that area leading southwestward towards the Hunter Spring Run/Three Sisters Spring group in Kings Bay.

On page 111, of the USGS I-73 report, Dr Faulkner writes: "Additional geological information should be gathered …. to aid in the delineation of certain stratigraphic and structural characteristics of the area, the knowledge of which may help to further define routes of preferential ground-water flow, and thereby aid in preventing pollution of water in the aquifer. [Foundation's emphasis]"

Kings Bay Fracture Sets

The angular transitions of the general flow line of Crystal River appear to follow the fracture set paths, predicated by Vernon. Flowing NW from its origin with the springs in the south region of Kings Bay, turning more westerly as it is joined by flows from Hunter Spring run, then more

northerly as joined by the fracture set running parallel to and set to the west of the initial path into Kings Bay, and so on out to the Gulf.

The Ardaman report submitted to the Commissioners eliminated from their considerations the red line lineament shown in their Figure 16, transecting the proposed development site, derived by them from Dr Vernon. This was presumably because it was not shown by them to pass through Tarpon Spring nor Shark Sink as it surely does in Kings Bay, and no sinkhole was shown on its track. Also, the blue lineament line transecting the proposed site was truncated some 1000 feet short of Kings Bay and hence not shown to pass through Black Spring and beyond, nor were the three sink holes affirming this lineament shown.

However, fracture sets transecting the proposed site do in fact convey water which is released into Kings Bay from the springs on those paths. The Southwest Water Management District report, 1998, “Origin of Nutrients in Ground Water Discharging from the Kings Bay Springs”, authored by Dr Sam B. Upchurch and others, clearly shows the subject Crystal River Commons site within the Kings Bay Ground-Water Basin Boundary (page 3) and directions of groundwater piezometric flow both from the north and south (Figure 13, Page 30).

Fractures also capture flows according to their depth, in a similar way to a well having a Cone of Influence. Thus, the feed from these fracture sets may accept and convey underground water flows beneath a land surface up to hundreds of feet wide. This emphasizes the imperative, if the Outstanding Florida Waters of Crystal River/Kings Bay are to be preserved for the future and as a source of significant economic wealth for the community, to prevent pollution in the aquifer, (per, Dr Faulkner's document, above, page 111.)

This Foundation has derived the attached computer mapping of these critical flows into Kings Bay. The position of the springs was directly embodied without variance within the mapping from, "The Hydrology and Water Quality of Select Springs in the Southwest Florida Water Management District" -prepared by the Water Quality Monitoring Program, in May, 2001, (pages 51 to 53). The position of sinkholes was also directly embodied without variance into the mapping from State of Florida information.

Managing Development Impacts

The proposed site, without any development, has little if any surface water run off owing to the relatively high soil permeability (Ardaman Report, Page 2) and vegetative transpiration. Precipitation reaching the ground is naturally ameliorated by evapotranspiration, before draining to the aquifer.

Once built upon according to the proposal, however, impervious areas would be expected to develop some 1.6 trillion gallons of surface water run off per year. Of this amount, all but , say, 750 million gallons would likely be returned to the atmosphere. Transpiration areas would be significantly reduced. Retention ponds positioned over fracture set areas connected to Kings Bay should be avoided as they are inherently susceptible to the formation of solution pipes.

It is not yet known how waters would be prevented from conveying accumulated excess nutrients applied to the land surface, together with pollutants of motor vehicular combustion on the site, to the fracture sets and into Kings Bay. Site engineering plans acceptable for Environmental Resource Permitting are necessary. Note that only added pollutant loadings could possibly have caused the wall to wall Lyngbya cover in Kings Bay following the Home Depot build, over the period of years for which it occurred -not the accidental penetration of the aquifer as some have suggested. The magnitude and cost of the task to prepare the site for development and render the Outstanding Florida Water safe from permanent harm, following recommended Best Management Practices, has not yet been determined. It is questionable whether the physical resources of the site could sustain any such a program.

The whole site is a springshed area, where water is the common resource and carrier of pollutants within it, and its protection and management is of primary concern, especially when directly connected to environmentally sensitive springs of an Outstanding Florida Water. (See, Protecting Florida's Springs, Land Use Planning Strategies and Best Management Practices, 2002, authored by the Departments of Community Affairs and Environmental Protection, and 1000 Friends of Florida, page 42ff).

The site is in a Coastal High Hazard area and flooding from a major storm surge could inundate the site disastrously, polluting the Outstanding Florida Water immeasurably, and hazarding a major evacuation route.

Furthermore, announcement was made for the developer, at the December 9, 2008, meeting, of the intention to proceed with the associated dwellings development without delay which will further exacerbate environmental damage and safety.


It is recommended that this document be included in the Public Record and sufficient time be made available for formal presentation to the County Commissioners, so that due consideration is given to the matters raised in any forthcoming hearings.

Figure 1.

Map showing fracture set derived from Robert O. Vernon (red line) and fracture set passing through Black Spring (blue line). Both pass across the CRCP site (to the south of the Crystal River Landing Field) and feed Kings Bay springs. (Squares indicate sinkhole locations).


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