April 2, 2009

Crystal River Commons Project Application.

This letter and the presentation were submitted for the attention of the Citrus County Board of County Commissioners on 2 April, 2009. Based upon the Crystal River Hydrogeology page (Education Section - Coastal Rivers - Crystal River - Hydrogeology).

Crystal River/ Kings Bay is classified as an Outstanding Florida Water (OFW), and has been so designated for more than twenty five years. Furthermore,

• The proposed Crystal River Commons project site (CRCP) is within the designated springshed of that OFW.

• Primerica Group One failed to instruct their geological consultant, Ardaman and Associates, to consider possible impacts of the proposed development of the site upon the OFW. (The case put years earlier to the Governing Board of the Southwest Florida Water Management District, by local environmental groups, included argument that the wetlands of the site were contiguous with a larger wetland area critical to sustaining the water quality of the OFW).

• At the December 9th, 2008, hearing before the BOCC the Primerica legal representative had cause to assert that no run off would affect the OFW, that the site area was not karst, and water would flow to the east if anywhere.

The consequences of this omission by Primerica Group One are several and serious.

• The Citrus County Board of County Commissioners (BOCC) were never apprised of any risk to the OFW in the Primerica Group One submissions made before it.

• Had the consultants, on being properly instructed with respect to the OFW, and considered the red line lineament. correctly placed by them on Figure 16 of their report in that context, it would have become clear that it passed through Tarpon Hole springs and Shark Sink spring as a high risk conduit.

• Moreover, the blue line lineament passing through the SW corner of the site would similarly have been identified as passing through Black Spring and three sink holes. Ground-truthing would have shown that that fracture set occupies a lateral distance of more than 800 feet across Kings Creek — a distance consistent with literature of the United States Army Corps of Engineers. The area of influence of the two fracture sets across the area of the CRCP site would be commensurately larger than any lines on a map may suggest.

• Questioning of the consultant's report would have highlighted the fact that, prior to any construction activity, run off of surface water is minimal as it mostly permeates directly into the aquifer. It is only as impervious surfaces for roadways, parking and buildings are created that run off becomes an issue, and then mostly as contaminated underground flows.

• Also, the BOCC would have had cause to question the efficacy of the statements made to it on December 9th, 2008.

• The absence of any note of the potential threat to the OFW in the proceedings, would be tantamount to concealing an inherent risk of the site from by any big box corporations' conduct of due diligence.

• For information, Rule of Law, F.A.C. 62 — 302.700 Special Protection, Outstanding Florida Waters, Outstanding National Resource Waters, reads: "It shall be the Department policy to afford the highest protection to Outstanding Florida Waters and Outstanding National Resource Waters. No degradation of water quality, other than that allowed in subsections 62-4.242(2) and (3), F.A.C., is to be permitted in Outstanding Florida Waters and Outstanding National Resource Waters, respectively, notwithstanding any other Department rules that allow water quality lowering"

• Recent research indicates that the annual economic worth of the OFW to the local community has a value exceeding $10million.

• To proceed to negotiate a Development Permit with Primerica Group One is therefore not in the best interests of any of the parties involved.

Norman Hopkins. Director.