Amazon Web Services (AWS), a subsidiary of Amazon, filed for permits earlier this year to approve impacts to federally protected wetlands and ditches associated with the historical Grand Kankakee Marsh. The specific impacts include:
- Permanent loss of 4.51 acres of wetlands,
- Permanent loss of 3,986 feet of streams,
- Temporary impacts to 387.5 feet of stream for dewatering purposes,
- Authorization of roughly one acre of unpermitted, permanent wetland impacts.
The wetland impacts are proposed so that AWS can complete their third hyperscale AI data center campus in New Carlisle—also known as the SBN 210 site. In total, AWS plans to transform nearly 820 acres of floodplain, forest, wetland, and farmland into a sprawling industrial development
Due to fragmented permitting, staged projects, and lack of policy addressing comprehensive environmental impacts in Indiana, these data center campuses have largely evaded comprehensive environmental reviews.
The AWS SBN 210 site: Rich history, prolonged saturation
The Grand Kankakee Marsh was a massive wetland complex that once encompassed over 500,000 acres and was the largest wetland in the contiguous United States at its prime. Nicknamed the “Everglades of the North,” the history of the Grand Kankakee Marsh is a testament to the wet and marshy nature that used to exist in northwest Indiana, but is now largely gone through extensive draining.
The AWS SBN 210 site is located on 300 acres of farmland that encompasses the historical floodplain of the Grand Kankakee Marsh. Portions of that farmland are currently used to cultivate mint (a wetland plant) due to its wet nature.
Location on the historical floodplain of the Grand Kankakee Marsh: A closer analysis
To determine if wetlands existed on the site, a wetland delineation was completed, and a waters report was prepared that summarized the findings.
The report identified four ditches and a 9.7-acre wetland connected to one of the ditches. All the ditches and the wetland drain into the Niespodziany Ditch, which flows into the Kankakee River. Because there was a direct hydrological connection to a Waters of the United States (WOTUS), which in this case is the Kankakee River, all waterways on the project site were determined to be federally protected.
The presence of several on site ditches is a strong indication that drainage activities have historically occurred on site, not atypical of farmland across Indiana and the United States.
A floodplain is any area adjacent to a river or stream. In this case, with the presence of 4 channelized streams, or “ditches,” it becomes clear that the area is a floodplain. The question is: to what extent?
While historical efforts attempted to convey water away from the property and drain the land via tiles and ditches, the presence of a large wetland, predominantly hydric (wetland) soils, and history of mint farming demonstrates that efforts weren’t completely successful in eliminating the history of the floodplain.
To add more evidence to the area being a floodplain, and thus in essence a large wetland, the mitigation plan concluded that the area “historically supported wet meadow and wet-prairie plant communities,” which are wetland communities reminiscent of the Grand Kankakee Marsh. If this area was never drained, these ecosystems may still be standing today. If they were, they would be considered Class III wetlands in Indiana – indicating both rare and high-quality wetland ecosystems.
What we don’t have to speculate is the fact that a mapped Federal Emergency Management Agency (FEMA) floodplain exists on the SBN 210 site, encompassing nearly a third of the property. The flood zone is associated with the Niespodziany Ditch and is designated as “Zone A,” which has a 1% chance of flooding. And according to FEMA, any place with a 1% chance or higher is considered to have a high flood risk.
The floodplain that remains is a living testament to the history of the Grand Kankakee Marsh, and now that history will be smothered in data.
Though local officials and project proponents may argue that they are avoiding portions of wetlands and ditches and that impacts are overblown, this approach fails to see the site as a whole for what it is: the historical floodplain of the Grand Kankakee Marsh—an area that has and continues to experience prolonged saturation.
What happens next, and what is HEC doing?
In the face of federal protection, historical significance, and prolonged saturation, AWS still determined that this area was the most feasible site for their sprawling data center campus, garnering support from local officials in the area who designated these sensitive floodplain regions as prime industrial real estate.
The completion of the AWS SBN 210 data center campus hinges on the approval of two permits to approve impacts to the wetlands and streams, including unauthorized impacts that occurred over a year ago.
HEC submitted comments on both permits, which included a 404 Dredge and Fill Permit issued the US Army Corps of Engineers (USACE), as well as a Section 401 Water Quality Certificate which is issued by the Indiana Department of Environmental Management (IDEM), encouraging both agencies to carefully weigh the evidence, which favors wetland and stream protection, and deny the current permits.
HEC had a representative present to testify at the last public hearing, highlighting key concerns such as Indiana’s wetland mitigation programs’ inability to replace wetlands, the loss of substantial floodplain storage, and the need to protect wetlands.
HEC has also held meetings and calls with IDEM and USACE to express concerns related to the permit applications, as well as meeting with concerned community members and regional organizations such as Just Transition Northwest Indiana.
A decision has yet to be issued on the permits, but HEC remains committed to keeping you informed on the process.
Review the documents
Public Notice for 404 Permit
HEC Comments on 404 Permit
HEC Comments on 401 Permit
Learn more about the Grand Kankakee Marsh
Are you interested in learning more about the Grand Kankakee Marsh, the Everglades of the North? Check out this amazing documentary produced by lakeshore public media: https://www.lakeshorepublicmedia.org/evergladesofthenorth.
Categories: Public Comments, Public Notices, Water & Wilderness Protection, Wetlands