January 18th, 2010 

To: Town of Preston Board

Re: Winn Bay Sand Limited Partnership’s “Larkin Valley Project”

First, we would like to thank you for your time and consideration of both sides of the proposed “Larkin Valley Project.” Although there is no official proposal by Winn Bay Sand, many residents have questions and concerns regarding the mine/processing plant and how it may affect our community.

On behalf of residents in the township, the Larkin Valley No Winn Project (LVNWP) members are willing to provide research information at your request. The goal of LVNWP is education so an informed decision can be made on what is best for the future of our community. We are anticipating an official proposal, and have gathered questions from area residents. We hope these questions will be a helpful guide in better understanding the project and how it could impact our community. Enclosed you will find a list of questions for Winn Bay, questions for board members, and supporting articles.

Again, thank you for your careful consideration of this proposed project.


LVNWP Members


Questions for Winn Bay Sand Limited Partnership:

Does Winn Bay have their “Larkin Valley Project” proposal completed?

2.  Is the proposal similar to what was outlined at the November 18th township meeting, or are there changes?

3.  Does Winn Bay have all of the applicable permits for this proposed project? If not, where are they at in the permit process?

4.  Would Winn Bay be doing business in the
U.S. under Winn Bay Sand Limited Partnership, or do they plan to apply for or utilize a different name?

5.  Will Winn Bay provide a list of all of their investors?

6.  Who are the owners of
Winn Bay, and at what percentage?

7.  Will Winn Bay provide a list of their board of directors?

8.  What other names has/is the company operating under?

9.  What does "Limited Partnership" mean? Is it comparable to a Limited Liability Company here in the

10.  Does Winn Bay have any connection to Canadian Sand and Proppants?

11.  Does Winn Bay have any connection to Halliburton?

12.  Does Winn Bay have any connection to Exxon?

13.  Have any of the companies
Winn Bay has/is operating under broken environmental regulations? If so, please explain.

14.  Does Winn Bay currently have any other proposals in the

15.  What is
Winn Bay’s mission statement?

16.  What date are the contracts with property owners due? Does
Winn Bay intend to extend these contracts if terms are not met by that date?

17.  Can landowner’s legally back out of the contract after the due date?

18.  Where is the 60 acre option that was discussed at the November township meeting?

19.  Has Winn Bay investigated
Dubbert Road as a potential site? Square Bluff? Fly Creek? Rat Coulee? Peterson Coulee? Lone Star? What other sites have been investigated?

20.  Does Winn Bay plan on purchasing additional adjacent properties to establish a buffer zone?

21.  Does Winn Bay plan on purchasing other sites to mine and truck the materials in to the processing plant?

22.  How much growth and what does
Winn Bay project their operations in Trempealeau County to look like in 10 years? 20 years? 40 years?

23.  Does Winn Bay plan on utilizing Badger Mining’s (Atlas Resin Proppants) resin plant? If not, what plant are they planning to send the sand to for resin coating?

24.  Does Winn Bay ever plan on building a resin plant on the properties they have current contracts with?

25.  Does Winn Bay ever plan on building a resin plant in
Trempealeau County?

26.  How many tons per year does the company expect to process?

27.  How will shipments of processed materials to offsite locations be made? 

28.  Would there be any shipments from other sites or mines railroaded or trucked to the processing plant?

29.  Would fuel or chemicals be brought to the site via railroad?

30.  Property owners adjacent to property that
Winn Bay has contracts to purchase are projected to have their property values decrease by 30%-50% (the 30% projection is based on documented studies, and 50% was projected by a local realtor). In November, Winn Bay’s representative stated that this would be a win-win situation, how is it a “win” for these property owners?

31.  One of the Town of
Preston’s goals (Comprehensive Plan 2009-2029) is to support small businesses. During a cursory survey of small business owners located at the base of the proposed operation, 7 out of 9 will either shut-down, relocate or seriously consider relocating if the mine were operational. How is Winn Bay’s proposed project a “win” for these business owners and the employees they support?

32.  Documented research has shown that an increase in fine particulate matter leads to health problems such as asthma, COPD, cardiovascular disease, heart attack, increased blood thickness, formation of blood clots, increase in bad cholesterol levels, and premature death.
Winn Bay would contribute to the particulate matter level and increase susceptibility to disease for residents. How is this a “win” for area residents, in particular for those that already have compromised immune systems?

33.  Currently the EPA and DNR do not have standards pertaining specifically to silica dust. Inhaled crystalline silica is a group 1 human carcinogen as well as a catalyst for silicosis and a host of other health issues. Many residents feel that they cannot rely on the EPA or DNR to protect their health as standards are not currently in place. What written guarantees would
Winn Bay give to residents in regard to particulate matter- in particular, silica dust? How much particulate matter is expected to come from each step of the mining and processing operations?

34.  How many air quality monitors is
Winn Bay prepared to install and where? Will these monitors measure respirable crystalline silica, PM2.5 and PM10?

35.  How often does
Winn Bay require silicosis or related screenings for employees?

36.  How often would blasting take place?

37.  What are the procedures for notification of residential owners prior to blasting?

38.  Would roads be posted when blasting occurs?

39.  What roads would be closed, and for how long? Would the roads be able to be opened in case of an emergency?

40.  What noise control measures is the company prepared to take?

41.  How far out from the perimeter of the blasting area will a pre-blasting inspection of buildings occur?

42.  How far from the perimeter of property boundaries would blasting and extraction occur?

43.  Blasting has affected the operation of mobile/ wireless/ emergency communication systems.  What measures would
Winn Bay take to prevent this?

44.  Would Winn Bay guarantee in writing that no foundations, windows, tiling, etc. will ever break or crack due to the mining operations?

45.  What written guarantees would
Winn Bay commit to in regard to potential groundwater contamination and well water quality?

46.  Has Winn Bay identified which blasting contractor will be used?

47.  What type of insurance coverage does that contractor provide?

48.  Recently, many insurance companies have placed a silica exposure exclusion in their policy stating that silicosis and silica related health problems will not be covered. What type of insurance does/will
Winn Bay carry? Do they cover silica exposure? Will this insurance cover residents?

49.  How far from the blasting site will ground and air vibrations be detectable?

50.  It is our understanding that processing for frac sand requires huge quantities of water. What is
Winn Bay’s expected daily budget for water use?

51.  Will high capacity wells be installed? How many?

52.  How large will retaining ponds be? How many?

53.  In the case of a dam breach or break, how would residents be notified?

54.  Where is water expected to flow from the site?

55.  What remediation efforts is
Winn Bay prepared to take should the quality or quantity of private and/or municipal well water supplies be negatively affected?

56.  There is a stream and river in close proximity to the proposed site. Will they dry up?

57.  Would Winn Bay provide a written guarantee that ground water will not be affected in any way (including sediment in water after blasting)?

58.  Would Winn Bay guarantee in writing that no wells will ever go dry, collapse, crack or become unusable?

59.  What does the company plan to use as a flocculent in the slurry?

60.  Will Winn Bay be setting up any monitoring wells to monitor water quality? If so, how many and where?

61.  Is the company prepared to pay for third party testing of all adjacent resident wells on a regular basis for monitoring purposes, or is that burden on the landowner?

62.  Research has shown that silica dust can inhibit the growth and productivity of plants. How much of a loss (quantity and quality) should nearby farmers expect in their crop yield?

63.  How will silica exposure and particulate matter affect the “organic” label?

64.  Will silica dust and particulate matter cause garden vegetables to be unsafe to eat?

65.  What are the effects of silica dust and particulate matter on the milk output of cows? Quality of chicken? Deer? Wildlife?

66.  How much electricity does
Winn Bay plan to use in total? Where will this electricity come from?

67.  How does
Winn Bay plan to control dust while loading boxcars?

68.  Where will the railroad spur be located?

69.  Will there be an additional spur as the operation moves toward the city?

70.  Will there be railcar activity at night?

71.  Will the railroad need to replace, expand or improve upon existing tracks between the proposed site on through the Blair city limits?

72.  Where are road accesses planned? Will they be paved?

73.  Will there be silica/ frac sand piles in the winter?

74.  What does
Winn Bay plan to use as a de-icer in the winter?  

75.  How will fugitive dust from stock piles be controlled? If unable to use water due to freezing, how will it be controlled in the winter?

76.  Will there be a storm water containment area? How frequently will it have to be cleaned? Where will all the sludge go?

77.  What chemical hazards may be present in the sludge and how will that be contained?

78.  What protection from exposure to spills of fuel will be used?  Where will fueling occur and on what type of surface?

79.  Is Winn Bay planning to have any lighted areas at night?

80.  Will there be staff monitoring the mine at night?

81.  How would
Winn Bay alert residents of a plant disaster?

82.  What are the expected highest, average, and lowest salaries (
U.S.) at this operation? Benefits?

83.  Would Winn Bay put in writing they would hire only within the
Township of Preston or City of Blair?

84.  Will Carpenter Bridge be used to haul the heavy machinery to the site? If not, what route?

85.  In a letter to the editor, someone wrote that he is hopeful that the mine would attract people to the Blair area. Can
Winn Bay provide documentation that this “hope” would become a reality?

85.  What independent consultants did
Winn Bay provide the landowners to educate them about mining issues before they committed to their contracts?

86.  A mine representative stated that
Winn Bay would not pursue the mine and plant if residents opposed it. What measure will Winn Bay use to determine opposition?

87.  Has a “lifecycle analysis” been done on the amount of energy it takes to extract and utilize silica sand verses the amount of energy obtained?

88.  Many area residents are concerned for the health of all who may be negatively impacted across the
U.S. by the gas and oil industry. Would Winn Bay agree to put in writing that their silica sand will never be sold to a company that mixes the silica with chemicals for hydraulic fracturing?  


Concerned citizen questions for the Town of Preston Board in regard to the proposed “Larkin Valley Project”:

1.  Will the Town Board do a thorough cost/benefit analysis of the fiscal impacts of this proposed mine before making a decision?

2.  Will the Town Board do a thorough cost/benefit analysis of the quality of life impacts of this proposed mine before making a decision?

3.  At the
November Township meeting, Winn Bay estimated it could bring in 20-25 jobs.  Would there be a net benefit that results from the addition of these jobs if small businesses at the base of the proposed site close or relocate due to the mine? In doing a cursory survey at the base of the proposed operation, 7 out of 9 small business owners stated they will shut-down, relocate or seriously consider relocating if the mine were operational. This could result in a net loss of jobs for the township.

4.  If this project is approved, what remediation is the township prepared to provide to displaced businesses and employees?

5.  A benefit
Winn Bay identified was an increase in tax revenue. However, there are significant costs associated with a reduction in residential property values (and therefore a reduction in tax revenues). What is the anticipated property tax reduction (per $100,000) for a township resident, if the mine were to be approved?

6.  If properties near the mine are revalued and have a lower property tax, would properties in the township that are beyond the 3 mile devaluation range need to pay higher taxes?

7.   What financial impact would additional road maintenance and repair, water monitoring, and remediation efforts have on the Township? On the City?

8.  Would a third party hydro-geologist be required to establish a pre-mining data baseline for normal water levels and to establish a "base" flow of nearby streams?

9.  Would performance and impact data be collected by a third party?

10.  How frequently would
Winn Bay
’s permit need to be renewed?

11.  How would “oversight” be conducted?

12.  Would an "oversight" committee be created to examine performance data, help monitor compliance, review resident complaints, and make recommendations for remedial action?

13.  Would residents living adjacent to the mine be invited to join the “oversight” committee?

14.  To our knowledge, only about 20% of extractions in existing upper Cambrian silica/frac mines are marketable. Many residents are concerned about where the 80% waste will go and how it will be managed.

15.  How would the mine impact other types of economic development?

16.  How would the mine affect retention of residents?

17.  How would the mine affect recruitment of new businesses? 

18.  Would there be any written requirement that the 20-25 jobs would be filled by Township or City residents?

19.  How would the repairs on bridges, roads (city, county, state) as well as railroad infrastructure improvements be funded?

20.  What safety issues would need to be dealt with and how?

21.  There may be a significant increase in rail traffic.  How would the dust, dirt, noise, and congestion at crossings be handled?

22.  When blasting, would citizens have to go alternate routes?

23.  Would school buses, emergency vehicles on certain routes have to be delayed or rerouted due to either blasting or rail activity?

24.  What are the future implications of the township endorsing heavy industrial zones?

25.  If citizens become ill, what remediation would the Township be prepared to offer?

26.  Depending upon whether Winn Bay Limited Partnership utilizes their Canadian name, or applies for a new name in the
, will they be required to pay all local, state and federal taxes? Under either scenario?

27.  There have been several air quality alerts issued by the DNR in the past couple of years (including
Trempealeau County).  When there are air quality alerts, would Winn Bay
be required to close down? Who would monitor their compliance?

28.  Studies show that an increase in air pollution has a direct negative effect on the health of citizens. What is the township doing to reduce air pollution?

29.  We understand that the processing of sandstone requires the removal of fines and larger sizes that are not marketable. Mines normally redeposit the non-marketable materials on the excavated site using a slurry. To remove the fines which tend to suspend in the water rather than settle out, companies use a "flocculent."  Sandstone particles have an electrical charge and they need some chemical or other substance put into the water slurry that will also be electrically charged. This flocculent attracts the fines to each other to form "cakes" which then have enough weight to settle out. Many standard flocculants (such as polyacrylamide) release toxic elements into the groundwater and pollute it.  Polyacrylamide, for example, contains some residual monomers of acrylamide that do not get chemically bonded in the polymerizing process. Acrylamide is a neuro-toxin and leaches from soil cakes into groundwater. We are concerned about what
Winn Bay
may use as a flocculent.

30.  Would Winn Bay be required to set up monitoring wells to monitor water quality? If so, how many and where?

31.  Because water freezes in the winter, some mining companies use calcium chloride, a de-icer. Would
Winn Bay
be allowed to use this?

32.  Many mines are so brightly lit at night that some nearby residents never get to see the night sky. This can have significant health impacts on biorhythms and affect deep sleep and sleep-wake cycles unless the windows in adjacent houses are so heavily curtained or shielded by some means to create dark interior rooms to sleep in. Will the company be allowed to have any lighted areas at night?

33.  What are the potential impacts on the City of
and residents of Blair? Will the city be involved in the decision-making process since the proposed mine is so close to the city limits?

34.  There was an article in the Whitehall Times recently that discussed tourism in
Trempealeau County. Tourism brought $42.5 million to the county last year. Our area is nationally recognized (New York Times, Chicago Sun Times) for it’s scenic beauty and rural charm.  Loop 10, which encompasses Schansberg Road, Larkin Valley Road, and Snake Coulee Road is known as Amish Country. Tourists bus, bike, run, motorcycle, moped, and walk through this scenic area. What impact would a large-scale silica/ frac mine have on tourism- Loop
10 in particular?

35.  By what means will the board decide the fate of the project?

We thank you for the opportunity to voice our concerns, and hope that the board members seriously consider the future ramifications of allowing a large-scale, foreign silica/ frac sand mining operation in our township so close to the City of Blair. Our goal in providing these questions is to get concerns addressed before any decisions are made. We would like to see the township comply with the Town of
Preston’s Comprehensive Plan, and continue to foster opportunities for small businesses. Furthermore, we agree with the Comprehensive Plan that it is important to protect our natural resources and the health and well-being of residents while maintaining the rural atmosphere of our community. Many residents strongly believe that this project would put them at risk for health problems, or cause exacerbation of conditions they already have.  Ultimately, considering displacement, decreased property values, and the potential lack of future growth, we believe the mine would not be healthy or economically advantageous for the Township.

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