Comments: 20,338 on titanium mining near Okefenokee Swamp –USACE 2019-09-12

If this and the 27 news articles on radio, TV, and newspapers in Georgia and Florida, several of them carried by Associated Press across the country, plus the ten op-eds and three editorials, is not enough to establish controversy, I wonder what is. Maybe still more comments and news articles and social media?

[Public Notice: 20,338 comments]
Public Notice: 20,338 comments
PDF

Nedra Rhone, Atlanta Journal-Constitution, 13 September 2019, Mining proposal near Okefenokee draws more than 20K comments from public

The Suwannee Riverkeeper, on Thursday, sent 22 pages of questions to the Corps and the Georgia Department of Environmental Protection asking the agency to deny the permit. The Riverkeeper joined the SELC and other organizations and individuals in asking the Corps to prepare an Environmental Impact Statement, the highest level of analysis available when a proposed federal action may significantly affect the quality of the human environment.

Also in that AJC story:

Commenters expressed concerns ranging from the acres of wetlands that would be lost to what they considered inadequate studies conducted to determine the potential impact of the mine.

In a letter to the Corps, the Southern Environmental Law Center said Twin Pines has misrepresented the scale and severity of the project impacts throughout the applications process and most recently at a public meeting.

Controversy is one of the indicators that an Environmental Impact Statement (EIS) is needed, but about that and about public hearings all yesterdays’s notice says is:

Once we reach a decision on the appropriate level of NEPA analysis and additional forums for public information and comment, we will provide notice.

You may wonder when you will get an acknowledgement that your comment was received. I asked that of Billy Birdwell, Senior Public Affairs Specialist, Corporate Comm Office at Savannah District, US Army Corps of Engineers, Savannah, Georgia. He checked and said they are working through the comments in the order they are received. So far they are up to those received September 3rd. They expect to finish acknowledgments probably some time next week.

He, like this notice, was quite clear that comments are closed. However, when asked directly whether comments received after the nominal deadline would be read by the Corps, he said he would not commit to that, but he would not say they wouldn’t.

So I recommend that if you have something new to say, or a different perspective, especially if it is a question you think nobody else might have asked, send it in anyway.

Even better, also send it as a letter to your local newspaper, publish it on your website, or post it on social media.

This isn’t over until the Corps or GA-EPD denies the permit, or at the least starts an EIS. Contact your state Senator and Representative, and your U.S. Senator and Congress member, and ask them to ask for denial or an EIS.

How to Comment

The comment deadline was May 28, 2020, according to SAS-2018-00554 Twin Pines Minerals, Published April 13, 2020, Expiration date: 5/28/2020.

“The Savannah District will hold a virtual Public Meeting for the Twin Pines project on May 13, 2020 from 2:00 PM to 5:00 PM EDT. The meeting will consist of a formal presentation followed by a question and answer session. The meeting will be recorded and published to the Savannah District public website. To allow time for the public to submit questions and RSVP to the public meeting, as well as comment on any information presented at the meeting, additional public comments will be accepted and the original public notice will remain open until May 28, 2020, 15 days after the virtual public meeting.”

However, you can write to your elected officials. And the Corps apparently actually continues to read comments after the deadline, right up until they make a decision. While you are at home because of the novel Coronavirus (COVID-19), you have a great opportunity to write a comment, and to You can also post your comments on social media, as op-eds, etc.

You can ask the Corps and other elected and appointed officials to deny the application, or to require an Environmental Impact Statement (EIS) to consider wider areas the mine may affect, especially the entire Okefenokee Swamp, the Suwannee and St Marys Rivers, and the rest of Trail Ridge in Georgia. You can ask for the EIS to include other mines relevant to this one, especially the four Chemours titanium strip mines in north Florida for which TPM, along with Chemours, is under a Florida Consent Order for a range of violations. You may want to ask for inclusion of the existing phosphate mine in Hamilton County, Florida, next to the Suwannee River, as well as the one proposed in Union and Bradford Counties, Florida, next to the New and Santa Fe Rivers, tributaries of the Suwannee. All those mines affect the Floridan Aquifer, which is the main source of water for drinking, agriculture, and industry for everyone in south Georgia and north Florida.

To comment, or to request a public hearing, you can write to
Commander, U.S. Army Corps of Engineers, Savannah District,
Attention: Ms. Holly Ross, 1104 North Westover Boulevard, Suite 9, Albany, Georgia, 31707,
or by email to CESAS-SpecialProjects@usace.army.mil or holly.a.ross@usace.army.mil.
In your comments please refer to:
Applicant: Twin Pines Minerals, LLC, Application Number: SAS-2018-00554.

For the requested state permit regarding Section 401 of the Clean Water Act, you can send a comment or request for public hearing to
Stephen Wiedl, Wetlands Unit, stephen.wiedl@dnr.ga.gov
Georgia Department of Natural Resources, Environmental Protection Division, Water Protection Branch, 7 Martin Luther King, Jr. Drive, Atlanta, Georgia 30334.

For the Georgia Coastal Management Program certification, you can send a comment to
Federal Consistency Coordinator, Ecological Services Section, Coastal Resources Division,
Georgia Department of Natural Resources, One Conservation Way, Brunswick, Georgia 31523-9600
Telephone 912-264-7218.

The public announcement says: “The applicant may also require assent from the State of Georgia, which may be in the form of a license, easement, lease, permit, or other appropriate instrument.”

You can write to your Georgia state representative or senator or governor or lieutenant governor and ask them to refuse any such instrument.
To find your legislator you can type in your ZIP code here: http://openstates.org/find_your_legislator/

You can also write to your U.S. Representative or Senator and ask them to urge the Corps to reject this mine or at least require an EIS, like Rep. Al Lawson (FL-05) already did.

You can also write to the Georgia DNR board, asking them to refuse any such instrument.
Georgia Board of Natural Resources
2 Martin Luther King Jr. Drive, SE, Suite 1252, Atlanta, GA 30334

You can write to the U.S. Environmental Protection Agency (EPA) asking them to ask the state of Florida to comment.

To: Mary S. Walker, Regional Administrator, walker.mary@epa.gov
Jeaneanne Gettle, Director, Water Division, gettle.jeaneanne@epa.gov
Blake Ashbee, Chief of Staff, ashbee.blake@epa.gov,
Carol Kemker, Director, Enforcement & Compliance Assurance Division, kemker.carol@epa.gov
Region 4, U.S. Environmental Protection Agency (EPA)

Cc: Gregory J. Strong, Director, Northeast Division, Greg.Strong@dep.state.fl.us
Noah Valenstein, Director, Noah.Valenstein@dep.state.fl.us
Florida Department of Environmental Protection (FDEP)
 
Col. Daniel Hibner, Commander, U.S. Army Corps of Engineers,Savannah District
Attention: Ms. Holly Ross, holly.a.ross@usace.army.mil,
CESAS-SpecialProjects@usace.army.mil
1104 North Westover Boulevard, Suite 9, Albany, Georgia 31707
 
Stephen Wiedl, Wetlands Unit, stephen.wiedl@dnr.ga.gov
Georgia Department of Natural Resources, Environmental Protection Division,
Water Protection Branch, 7 Martin Luther King, Jr. Drive, Atlanta, GA 30334

Re: Applicant: Twin Pines Minerals, LLC, Application Number: SAS-2018-00554

Dear Administrator Walker and Director Gettle,

Here is the pithy request sent by Waterkeepers Florida:

We request EPA to determine, according to 33 CFR § 325.2(b), whether the mining activities of the applicant may affect the quality of the waters of the state of Florida and to notify the state of Florida, the district engineer, and the applicant that Florida therefore “has 60 days from receipt of EPA's notice to determine if the proposed discharge will affect the quality of its waters so as to violate any water quality requirement in such state, to notify EPA and the district engineer in writing of its objection to permit issuance, and to request a public hearing.”

To submit a letter to the editor of the Charlton County Herald, you can email editor@charltonherald.com.
Or write to your local newspaper.
You can also contact radio, TV, and of course post on social media.

DEPARTMENT OF THE ARMY
U.S. ARMY CORPS OF ENGINEERS, SAVANNAH DISTRICT
100 WEST OGLETHORPE AVENUE
SAVANNAH, GEORGIA 31401-3604

September 12, 2019

Regulatory Branch
SAS-2018-00554

PUBLIC NOTICE
Savannah District

The Savannah District has received an application for a Department of the Army permit, pursuant to Section 404 of the Clean Water Act (33 U.S.C § 1344), as follows:

Application Number: SAS-2018-00554

Applicant: Steven R. Ingle, Twin Pines Minerals, LLC, 2100 Southbridge Parkway, Birmingham, Alabama 35209

The Public Comment Period for the Twin Pines project closes today. To date, we have received 20,338 comments regarding this project, including comments from the Cherokee of Georgia Tribal Council, the U.S. Environmental Protection Agency Region 4, and 14 Non-Governmental Organizations. Many commenters have requested an extension to the comment period. At this time, the Corps is not going to extend the public comment period. Currently we are reviewing the comments we have received and evaluating our path forward under the National Environmental Policy Act (NEPA). Once we reach a decision on the appropriate level of NEPA analysis and additional forums for public information and comment, we will provide notice. We are still awaiting the submittal of additional project studies from the applicant, including hydrology studies. Once received, we will provide notice and this information will be available through our website or through a Freedom of Information Act request.

If you have any further questions concerning this matter, please contact Ms. Holly Ross, Project Manager, Albany Field Office at 648-422-2727 or via email at holly.a.ross@usace.army.mil.

Much more is on the WWALS website here:
http://www.wwals.net/pictures/2019-07-12–tpm-usace/

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

You can join this fun and work by becoming a WWALS member today!