Tag Archives: USACE

GA-EPD: Twin Pines massive submittals short on analysis, incomplete, not sufficient, and wetland impacts not temporary 2019-12-05

“We reiterate our concern and position that an appropriate project review for 401 water quality certification is not yet possible since complete substantive and important information about the proposed hydrogeologic effects of this project relative to the surrounding landscape has not yet been submitted by the applicant. …So substantial, so massive, so transformative is the effect to wetlands contemplated at the Twin Pines site that you no longer have in place the original wetland to be impacted.” The Georgia Environmental Protection Division (GA-EPD) wrote that to the U.S. Army Corps of Engineers (USACE) in response to the thousands of pages of low-level data but only a few pages of analysis that Twin Pines Minerals (TPM) has sent those agencies.

Twin Pines Minerals is still failing to hoist its burden of proof that its propsosed titanium strip mine would not jeopardize this national treasure, the Okefenokee Swamp, the headwaters of the Suwannee and St. Marys Rivers.

[Tribal Grounds west along GA 94 to TPM equipment, 12:38:38, 30.5257540, -82.0411100]
Photo: John S. Quarterman for WWALS, of Tribal Grounds west along GA 94 to TPM equipment, 12:38:38, 30.5257540, -82.0411100, on Southwings flight, pilot Allen Nodorft, 2019-10-05.
See also pictures from that flight by Wayne Morgan.

Maybe the City of Folkston and Charlton County Development Authority (CCDA) might want to rethink its assertion in the Charlton County Herald that “We would not support anything that would jeopardize this national treasure.” GA-EPD’s opinion is much like what U.S. EPA said, that the mine would have “substantial and unacceptable impact”.

CCDA wrote, Continue reading

U.S. EPA still says mine would have substantial and unacceptable impact –Suwannee Riverkeeper 2019-12-31

In the Charlton County Herald, December 31, 2019:


Dear Editor,

The burden of proof is still on the miners to show their mine would not damage the Swamp or the Rivers, and they have not met that burden.

U.S. EPA still finds that “the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.”

[Distant 2019-11-23]
Anonymous drone aerial of heavy equipment on the mining site 2019-11-23.
River Styx is in the background, Okefenokee Swamp is on the horizon.
St. Marys River flows out top left horizon. Suwannee River flows out far side of Swamp.

That’s about “the permit application submitted by Twin Pines Minerals, LLC” for a titanium strip mine. “The proposed 2,414-acre mine area lies in proximity to the Okefenokee National Wildlife Refuge (NWR), and the potential secondary effects of the mine on the NWR have not been demonstrated by the permit applicant.”

This is the second letter EPA has sent to the U.S. Army Corps of Engineers saying the mining application is deficient. We obtained a copy through a Freedom of Information Act (FOIA) request. The entire letter is here: http://wwals.net/?p=50931.

You, too, can still comment to the USACE, and all comments they receive before the Corps announces a decision can be used in any potential lawsuits. The addresses are: Continue reading

U.S. EPA still finds Twin Pines mine will have a substantial and unacceptable impact 2019-10-03

U.S. EPA still finds that “the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.”

That’s about “the permit application submitted by Twin Pines Minerals, LLC” for a titanium strip mine. “The proposed 2,414-acre mine area lies in proximity to the Okefenokee National Wildlife Refuge (NWR), and the potential secondary effects of the mine on the NWR have not been demonstrated by the permit applicant.”

You, too, can still comment to the USACE, and all comments they receive before the Corps announces a decision can be used in any potential lawsuits.

[the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.]
the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.

The previous letter from EPA to USACE, of Continue reading

Thanks to organizations for the Okefenokee Swamp, against the Titanium Mine

Thanks to the more than two dozen organizations, local, regional, statewide in Florida and Georgia, national, and international, that oppose the titanium mine that would be far too close to the Okefenokee Swamp. The Okefenokee National Wildlife Refuge (ONWR) provides boating, birding, fishing, and hunting nearby to the tune of more than $60 million a year and more than 700 jobs, making it the NWR of most economic benefit to each of Georgia and Florida. The Okefenokee Swamp is a unique ecological treasure, and is the headwaters of the Suwannee and St. Marys Rivers. The burden of proof is on the miners, and they have not met it.

[Organizations For Okefenokee Swamp, Against Titanium Mine]
Organizations For Okefenokee Swamp, Against Titanium Mine
PDF
Add your organization here: https://forms.gle/Dyqc77EBsjXBsz93A

You can still file a comment with the U.S. Army Corps of Engineers. If the Corps actually issues a permit, which they may in the next few weeks, anything filed can be used in any ensuing lawsuit.

Exactly how many organizations oppose that strip mine is hard to say, since Continue reading

Drone aerials of titanium mine site near Okefenokee Swamp 2019-11-23

Yesterday someone sent me drone pictures of the titanium mine site near the Okefenokee Swamp. They were taken from above GA 94, looking northwest.

You can still can comment against the proposed mine to the U.S. Army Corps of Engineers.

[Closeup 2019-11-23]
Closeup 2019-11-23

For comparison, here is an aerial Wayne Morgan took for WWALS on October 5, 2019, on a Southwings flight Continue reading

Waterkeepers Florida passes resolution against titanium mine application near Okefenokee Swamp

Waterkeepers Florida asks the Army Corps to require Twin Pines Minerals to supply all the information missing from its application for a titanium mine near the Okefenokee Swamp, to prepare a full Environmental Impact Statement (EIS), to hold Public Hearings, including in Florida, and “to answer how the Corps has or will determine that the Applicant’s proposed mine would not adversely affect the Okefenokee Swamp, the St. Marys River, the Suwannee River, the Floridan Aquifer, or the State of Florida.”

You can also still comment to the Army Corps.

[TPM Equipment closeup, Wayne Morgan]
TPM Equipment closeup Photo: Wayne Morgan for Suwannee Riverkeeper on Southwings flight, pilot Allen Nodorft, 2019-10-05.

Continue reading

GA-EPD cites Suwannee Riverkeeper and US EPA against TPM titanium mine near Okefenokee Swamp 2019-09-12

GA-EPD told USACE the mining application is incomplete, asked for comments to be reopened, and cited Suwannee Riverkeeper and Georgia River Network:

“Understanding that groundwater hydrologic effects associated with the Twin Pines project have been a central concern expressed by federal resource/regulatory agencies, NGOs (e.g. the Suwannee Riverkeeper and Georgia River Network), and the public at large, we respectfully submit that the 404/401 permit application as submitted thus far is not complete since it lacks full information and findings regarding hydrogeologic factors on site and post-project effects to hydrogeology/groundwater. We feel that it is inappropriate and premature to close the project comment window when such notable elements of the environmental documentation for this project have not yet been made available. documentation which we at GaEPD judge to be important to our review of this project.”

[the 404/401 permit application as submitted thus far is not complete]
the 404/401 permit application as submitted thus far is not complete

This was revealed by USACE in a Public Notice of September 17, 2019. So far, this is the only update posted by the Corps since it closed comments on September 12, 2019.

It also includes comments by U.S. EPA, also saying the application is incomplete, and also cited by GA-EPD. EPA cites cumulative effects and notes numerous lacking documents and studies. EPA concludes:

“Due to the potential for the proposed Twin Pines Minerals mine to adversely affect the hydrology of the Okefenokee NWR, the EPA believes that there is the potential for this project as proposed to cause adverse effects to water quality and the life stages of aquatic life or other wildlife dependent on aquatic systems. The EPA finds that this project, as proposed, may result in substantial and unacceptable impacts to aquatic resources of national importance, as covered in Part IV. paragraph 3(a) of the August 1992 Memorandum of Agreement between the EPA and the Department of the Army regarding CWA Section 404(q).”

Apparently USACE is at least listening to the public and the public and NGOs such as Suwannee Riverkeeper.

You can still send in comments. The Corps won’t say they will read them, but they explicitly won’t say they won’t read them, so keep sending them in, and publish them on social media, as op-eds, etc. Continue reading

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 Continue reading

Deny or EIS, titanium mining near Okefenokee Swamp –Suwannee Riverkeeper for WWALS 2019-09-12

Sent just now as PDF. You can still send in your comments today.

[Who wants to boat, fish, bird, or hunt next to a strip mine?]
Who wants to boat, fish, bird, or hunt next to a strip mine? PDF


September 12, 2019

To: Col. Daniel Hibner, Commander, U.S. Army Corps of Engineers, Savannah District
       Attention: Ms. Holly Ross,  holly.a.ross@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,

Suwannee Riverkeeper for WWALS Watershed Coalition (WWALS) asks USACE:

  • to reject the subject Application from Twin Pines Minerals (TPM), given the inappropriate location which would over the years move ever closer to the Okefenokee Swamp, which is the headwaters of the Suwannee and St. Mary’s Rivers, combined with the numerous omissions from the Application regarding the wide hydrogeologic, water quality, ecologic, and economic ramifications of the proposed mining, and the numerous other mines relevant to the proposal.

If USACE continues to process the Application, WWALS requests USACE:

  • to require a complete hydrogeological assessment and report, a full Environmental Impact Statement (EIS), and an economic analysis, with all three covering all the relevant features, mines, and applications in south Georgia and north Florida, including at least those outlined in this letter.
  • to accept comments until at least ninety days after all these documents are submitted to USACE and distributed to the public, preferably on USACE’s website, without requiring site visits to Albany to get them.
  • to hold public hearings in Georgia and Florida for further independent input and review after sufficient time (months or years) for independent third-party review.

The proposed Charlton County, Georgia, TPM mine site is hydraulically upgradient from the Okefenokee Swamp and within close proximity to the boundary of the Okefenokee National Wildlife Refuge (ONWR), with its 600,000 visits per year for boating, birding, and fishing, with more than $60 million annual economic effects including hundreds of jobs supported directly or indirectly, plus hunt clubs surrounding the Swamp. The Swamp provides ecosystem services of great economic values, including storm protection, water quality provisioning, support for nursery and habitat for commercial fishing species; and carbon storage, plus those hunt clubs depend on the Swamp. Any pollution of the Swamp or change in surface or groundwater levels could adversely affect not only ONWR and nearby areas, but also the Okefenokee Swamp Park (OSP) near Waycross, in Ware County, GA, and Stephen C. Foster State Park (SCFSP) in Charlton County, via Fargo in Clinch County. Visitors come from Jacksonville, Florida, Brunswick and Valdosta, Georgia, and from much farther away to visit the Okefenokee Swamp. The Swamp is a treasure to the entire nation and the world.

The stigma of a strip mine next to the swamp could cause people to turn away, taking their dollars with them. Who wants to boat, fish, bird, or hunt next to a strip mine?

Continue reading

PCS Phosphate Mine dragline access permit application SAJ-1984-04652 2019-10-15

It may be useful to keep tabs on last year’s USACE expansion application of the PCS (now Nutrien) phosphate mine in Hamilton County, FL.

Jacksonville District, U.S. Army Corps of Engineers, SAJ-1984-04652 (MOD-JPF), Published Oct. 15, 2018, Expiration date: 11/14/2018

[Location Map]
Location Map
PDF

Here are the rest of the maps from that document. Continue reading