Resources At Risk

Farms and natural areas are precious assets that benefit all county residents. Well managed, they protect soil fertility, water quality, and biodiversity. They provide a beautiful, healthful setting for outdoor recreation and make durable contributions to the local economy. They are also irreplaceable: once a farm or natural area is turned into an industrial site, a residential neighborhood, or a strip mall, it can never be restored to its former condition. Land use has a much wider context of responsibility than the creation of employment opportunities. 

Permanent Loss of Agricultural Land

As of January 2020, 70.8% of land in the proposed Core Development Area of the proposed IEC (the 7,200 acres main portion) was zoned as agricultural. One of the strongest impacts and costs of the proposed IEC would be to rezone this area for industrial use. While the county may be able to restrict the amount of heavy industry allowed even within an area rezoned for industrial use, in general, changing the zoning implies permanently changing the nature of the land itself. It is also unclear what mechanisms the county has to ensure that limits placed on heavy industrial use are enforced or obeyed. Permanent land change in this area has occurred before—in drastic fashion. The land in this area of St. Joseph County had been drained and engineered by 1917 to reduce the Kankakee Wetlands areas (covering over 400,000 acres) and to offer new opportunities for farming production and development.

We must respect the high-water tables and current drainage patterns of the area for the health and continuance of the area, and we should identify and increase natural wetlands. Wetlands are havens for biodiversity and provide invaluable services to human communities. Wetlands’ capacity for absorption and filtration of water prevents floods and purifies water. The 2002 Comprehensive Plan indicates that the soil types and hydrology present in the area are not suitable for industrial development. However, the current proposed IEC plan seeks to increase industrial development of the area in ways that work against the character and nature of the land.

This fact was recently acknowledged by the St. Joseph County Area Plan Commission in comments regarding a petition to rezone farmland in another part of the county. The planning staff wrote, “In 1979, St. Joseph County rezoned 300 square miles [nearly 200,000 acres] of the county to a new intensive Agricultural Zoning District. The intent of this new district was to strongly enforce the preservation of agricultural land in St. Joseph County. Agricultural land is a natural resource that must be protected to meet the food needs of not only Indiana, but the entire Country.”

Loss of agricultural land to urban or industrial development, by and large, is irreversible. The inflexibility of much urban or industrial land use makes it impractical, if not impossible, to bring such land back into agricultural production. This is not the case when cropland is diverted to forestry, forage production, or recreation uses. Such acreage can be returned to intensive agricultural production, if needed. 

Environmental Concerns 

There are many additional environmental concerns with the costly industrial use of this land, such as the risk of water, air, soil, light, and noise pollution. These issues will linger even after the industrial use of the land has ended. 

The water-use issues associated with development in this area are paramount, and the county must spend much more time assessing the surface water and groundwater issues at the proposed site. The areas selected for the proposed IEC have a rare, unconfined aquifer; that is, the aquifer is fed through the soil that is directly above it. Industrial wastewater often contains traces of heavy metals and hazardous pollutants. Even if all internal industrial wastewater is sent to municipal treatment plants, there is a lot of run-off from storage areas, parking lots, and along roads, which also often contains traces of heavy metals and hazardous pollutants.

Retention ponds do not always capture all of this run-off and all retention ponds have an overflow provision that dumps overflow water straight into the county drainage facilities. The county should not wait until a series of industrial groundwater users overwhelm and pollute one of the largest freshwater aquifers in the country. Instead, the county should do a thorough groundwater study before rezoning any parcel of agricultural land and the county should develop criteria for retention ponds that are over unconfined aquifers to have requirements that are more stringent that just getting an IDEM approval. Creating wetland areas to offset building and hard-surface footprints should also be a requirement for any new development to replace the water infiltration area lost to the aquifer from the development and mitigate pollutants. 

Water basin studies performed, or released, from the county to date seem to be related to a previously defined Core Development Area of the proposed IEC that included 22,000 acres. It does not appear that more detailed or updated studies relating to the newly redefined 7,200 acres Core Development Area of the proposed IEC have been publicly released, if they have been performed. 

In current planning efforts, little consideration has been made of the negative effects that such large-scale industrial development and the future influence of climate change have on pollution in the area. Noise and light pollution, air and water pollution, soil degradation, and traffic congestion are all major potential costs. 

Finally, to be in consideration for the future, corporations with a national or global reach have been known to abandon facilities as soon as greener pastures become available or if corporate raider takeovers, mergers, or consolidations put pressure on the company to concentrate on short-term profits in lieu of long-term well-being of the area. 

Sources.

• Infrastructure, Planning & Growth, Division of Economic Development, “Indiana Enterprise Center Area Management Plan.” St. Joseph County Website. Chapter Three, page 34, January 2020. http://sjcindiana.com/1798/IEC-Area-Management-Plan-Draft  

• “Agricultural'' Zoning goes beyond Agricultural/Production use and classifies the character of the zoned area, to preserve open space, limit building development, and use of property. (St. Joseph County Zoning Code, Ch. 154) “The A: Agricultural Districts are established to allow Agricultural Uses in accordance with the Comprehensive Plan, to preserve prime agricultural land, to conserve the desirable characteristics of the land, and to protect rural/agricultural areas from the encroachment of scatter urban-type uses and the detrimental economic impacts of urban sprawl. Areas zoned to the A: Agricultural District are those areas being used for agricultural activities, flood plain, natural areas and other rural uses, located beyond the periphery of the incorporated municipalities where intensive urban or suburban uses are not anticipated.”

• Surface Water Hydrology, Historical Perspective, pp. 61-77, accessed January 9, 2021, https://www.in.gov/dnr/water/files/kk_surf_water_hydro_part1.pdf  

• The 2002 Comprehensive Plan is a policy document that sets the vision for the county for 2002-2022. The plan was developed with high levels of community participation. Chapter 3, “Natural Environment,” points out that, “The floodplain and wet soil conditions in the western part of the county preclude heavy development.” HNTB Corporation and the St. Joseph County Area Plan Commission, “Comprehensive Plan for South Bend and St. Joseph County, Indiana, April 2002,” page 3-9, https://www.sjcindiana.com/DocumentCenter/View/1172/Comprehensive-Plan-for-South-Bend-and-St-Joseph-County-2002?bidId= , accessed January 24, 2021 

• Statement by Ryan Fellows, APC Staff report on proposed ordinance to re-zone 54280 Bittersweet Road from A; Agricultural District to R: Single Family District, “The Area Plan Commission of St. Joseph County, Indiana Minutes, June 16, 2020,” page 43, from the Area Plan Commission Agenda from Tuesday, August 18, 2020, http://www.sjcindiana.com/AgendaCenter/ViewFile/Agenda/_08182020-1014  

• Legislators in Indiana have recently proposed legislation because of the concerns of PFAS chemicals or “forever chemicals” that are largely unregulated in Indiana. London Gibson, “South Bend legislators push state bills to regulate toxic ‘forever chemicals’ in drinking water,” South Bend Tribune, February 15, 2021