Request comment deadline extension and public hearings about titanium mine near Okefenokee Swamp –Suwannee Riverkeeper to Army Corps 2020-03-19

We urge everyone else to also send the Army Corps a comment letter asking for an extension of the comment deadline and for public hearings.

For more things you can do to oppose this bad mining application, see How to Comment.

[Map: TPM Mine, Okefenokee Swamp, Suwannee River]
Map: TPM Mine, Okefenokee Swamp, Suwannee River
in the WWALS map of All Public Landings in the Suwannee River Basin.
The TPM mine is marked in the right center by the highlighted crossed hammers,
due north of the line of four Chemours titanium mines in north Florida.

Below is the text of the letter WWALS just sent to the Corps as a PDF.

March 19, 2020

To: 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

Cc: 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 Colonel Hibner,

Regarding permit application SAS-2018-0054 by Twin Pines Minerals, LLC, of Birmingham, Alabama, Suwannee Riverkeeper for WWALS Watershed Coalition (WWALS) asks the U.S. Army Corps of Engineers (USACE) to extend the public comment period and to hold public hearings, as detailed at the end of this letter.

Review of the current 219-page Application and the hundreds of pages of appendices is not practicable in the thirty days currently specified as a comment period. In particular additional time is needed to review several reports that describe simulation modeling of surface and groundwater. We note that to date these modules have not been peer-reviewed.

[Omissions and issues from Application]
Omissions and issues from Application

No doubt the tens of thousands of public comments received on the previous application by the same Applicant for essentially the same mine indicate a very high level of public concern, as does the opposition by the U.S. Environmental Protection Agency (EPA), the U.S. Fish and Wildlife Service (USFWS), and the Georgia Environmental Protection Division (GA-EPD), and the comment letters from Georgia state Senator William R. Ligon and U.S. Congressman from Florida Al Lawson. Review of Applicant’s studies and Application by independent third parties will constitute new information worth holding a public hearing, as will information about relevant mines and watersheds omitted from the Application.

A cursory review of the Application reveals little, if any, mention of the Suwannee River, whose headwaters is the Okefenokee Swamp, nor of the four titanium mines in north Florida for which Twin Pines Minerals along with Chemours is under a Florida Consent Order for a range of violations, nor of the hydrological effects of the phosphate mine in Hamilton County, Florida, downstream on the Suwannee River. The present Application does not appear to include any test wells nor river monitoring for the Suwannee or St. Marys Rivers. The Application also lacks a Reclamation Plan. It seems safe to expect many more issues will be revealed in thorough inspection of the Application. Thus we strongly feel that an extension of the comment period is in the public interest. We and the rest of the public need adequate time to comprehensively review the Application.

We also feel that all of the issues discovered should be discussed in public hearings in south Georgia and north Florida. The Application claims to be for a “reduced mining area” yet the acreage is approximately 86% of that from the previous Application. The Applicant claims that “reduction” is a significant change in scope of the project. Any significant change in scope is grounds for public hearings. Thus the Applicant’s claim of “reduction” is yet another reason to hold public hearings.

[Novel Coronavirus and COVID-19]
Novel Coronavirus and COVID-19

The novel Coronavirus and the COVID-19 disease it causes is also a serious impediment to meaningful comment in such a short thirty-day timeframe. The World Health Organization (WHO) has declared this virus a pandemic. So far this pandemic has resulted in work-at-home requests from the federal and state governments as part of their declarations of a public health emergency. These actions, while no doubt prudent, disrupt and slow work on anything, including comments on this mining application. If the virus in the U.S. expands exponentially like it has in other countries, as seems likely, further disruption seems likely for an unknown extended period, but quite likely beyond thirty days. Many state and federal government offices have suspended operations or had them slowed due to work-at-home, and it seems unlikely USACE will not also have this happen.

Given the local, state, national, and worldwide significance of the Okefenokee Swamp for its boating, birding, fishing, and nearby hunting, for its ecological diversity and services, and for its economic value to both Georgia and Florida, as well because the Okefenokee Swamp is the headwaters of the Suwannee and St. Marys Rivers, all of which sits above the Floridan Aquifer, from which all of south Georgia and north Florida drinks for human, agriculture and industrial use, adequate public comment time is essential for review of this mining application, and public hearings are needed in south Georgia and north Florida to discuss that review.

There needs to be more than one public hearing, at least one in Georgia and one in Florida, because the Okefenokee National Wildlife Refuge (NWR) extends into Baker County, Florida, as well as Charlton, Clinch, and Ware Counties, Georgia, and that NWR provides more economic benefit to each of Florida and Georgia than any other NWR.

Therefore we request USACE regarding permit application SAS-2018-0054:

  • to extend the public comment period for at least another one hundred and twenty (120) days, or no earlier than mid-August 2020, and
  • to hold public hearings in south Georgia and north Florida, for example in Folkston, Waycross, and Fargo, Georgia, and in Maclenny and Starke, Florida.

WWALS reserves the right to submit further comments on this Application, up to and beyond the current nominal comment submission deadline.

For the rivers and the aquifer,
John S. Quarterman
Suwannee RIVERKEEPER®
229-242-0102
contact@suwanneeriverkeeper.org
www.suwanneeriverkeeper.org

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.

For much more about this bad mining idea, see:
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!