Sabal Trail ignored springs and underground connections –TSE Plantation

A Suwannee County, Florida landowner points to newly-discovered connections between springs under rivers and to other well-known springs Sabal Trail ignored, adding:

Note that the undersigned is a lay person attorney and NOT a karst expert. Basic research revealed the information contained herein and the omission of this infonnation by Sabal’s purported karst experts should raise serious questions as to the credibility of Sabal’s filings.

Filed with FERC 29 January 2015 as Accession Number: 20150129-5192, “Supplemental Information / Request of Edwards & Ragatz, P.A. under CP15-17. Supplemental Comments of Proposed Intervener, Thomas S. Edwards, Manager, TSE Plantation, LLC Opposing Portion of Sabal Trail Route and Related Motion to Accept Late Comments”,

UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION

Docket No. CP15-17-000

Sabal Trail Transmission, LLC
SUPPLEMENTAL COMMENTS
OF PROPOSED INTERVENER,
THOMAS S. EDWARDS, JR., MANAGER,
TSE PLANTATION, LLC
OPPOSING A PORTION OF SABAL TRAIL ROUTE
And
REALTED MOTION TO ACCEPT LATE COMMENTS
Ladies and gentlemen,
Undersigned respectfully requests that this body accept these late comments.
These supplemental comments are supplied for two reasons:

To attach a document that was discussed, but accidentally omitted, in the undersigned’s original comments; and
To address comments directed to documents Sabal failed to file until after the deadline for comments had passed.¹ These comments are directed to glaring flaws in Sabal’s representations contained in those late filed documents.

Attached hereto as Exhibit “A” is a press release from the Suwannee River Water Management District that was discussed in the timely filed comments. The press release confirms that testing recently performed in the vicinity of the proposed pipeline route shows that numerous springs are interconnected by large aquifer filled underground karst tunnels. This is also relevant to the supplemental comments below addressing the purported karst study done by Sabal. The studies filed with FERC will prove to be so clearly flawed as to raise questions as to why.

¹ The comment period ended on December 24, 2014 and Sabal supplied new filings on December 30, 2014
The comment period for undersigned was until December 24, 2014. Undersigned timely filed comments on December 22, 2014. On December 30, 2014 Sabal filed extensive new materials, including two documents purporting to address the potential for adverse impact on sensitive karst, springs and the aquifer in the vicinity of the pipeline. These documents are deceptive and contain serious omissions.

I am the owner of the TSE Plantation, LLC d/b/a Echo River Plantation which is a 912 acre plantation with between 2 and 2 1/2 miles of frontage on the Suwannee River. Sabal Trail plans to cross my propeity with their pipeline. The plantation abuts the Suwannee River State Park.² The pipeline will cross the Suwannee River at the location where the Park is on one side of the River and Echo Plantation is on the other.

In support of this crossing (and other crossings) Sabal filed voluminous materials claiming to address all sensitive karst areas in proximity to the proposed path. See Sabal filings on December 30, 2014 entitled:

Characterization of Karst Sensitive Areas Relative to the Proposed Route of the Sabal Trail Natural Gas Transmission Pipeline in Florida; and
KARST MITIGATION PLAN.

Sabal failed to address ANY of the major springs — or sensitive karst—in the area of the Suwannee River crossing in their Karst materials. This is a glaring oversight — their own materials state that they should avoid areas such as this because of the confluence of a number of MAJOR springs A having springs in this immediate area leads to large underground water filled tunnels and caverns in the immediate area of the river crossing where they will do the HDD. These springs make this crossing ill-advised under their own analysis.
² I am also a Life Member of the State Park system.
I am attaching a SRWMD press release (See the attached document entitled “Falmouth Dye Trace” — Exhibit “A”) where the SRWMD, DEP and FGS recently tested these springs and proved they are all interconnected by tunnels and other water conduits 7 the interconnected tunnels are both north and south of the pipeline meaning they will be drilling right through an area with interconnected underground tunnel systems jeopardizing the aquifer, these springs and the karst formations — this is acknowledged in their own documents regarding karst structure — but they failed to even identify or discuss these springs in these documents while representing to FERC that they were addressing all springs in the vicinity of the proposed pipeline. Why would these major — well-documented — springs be omitted?

I’m attaching a document from the Sabal filing entitled “pages from Karst Sensitive Areas” — Exhibit “B”— this has 3 pages of excerpts from Sabal’s completely flawed and misleading document:

a picture supposedly showing the “major springs” in the area where the Suwannee and Withlacoochee come together —

NOT ONE SPRING IS SHOWN NEAR THE “V” where the rivers join — compare that to the SRWMD map showing springs in that immediate area Exhibit “C” — there are two magnitude 1 and four magnitude 2 springs and two magnitude 4 springs all less than 2 miles from the proposed pipeline crossing — these were omitted from Sabal’s materials;
The second page claims to identify all major springs the pipeline will go near — the distance from the springs to the pipeline shown on this page range from 1.1 mile to almost 20 miles —

NONE of the above springs are identified or discussed and all are less than 2 miles from the proposed pipeline and some within 1/2 mile; and
The third page shows “fracture traces” that have been documented at the proposed Suwannee River crossing for the pipeline —

that is because there are identified “fractures” in the earth — knowing the springs are in the area this means there are probably underground aquifer tunnels at this exact location — that is what the fractures are. This is further confirmed by the recent dye trace testing

The proposed crossing of the Suwannee River is approximately 1.71 miles north of where the Withlacoochee and the Suwannee Rivers converge (I’m using a measurement from the Suwannee County Property appraiser GIS map from my property line — where they propose to cross the river to the point where the two rivers meet in a “V”). Thus on any map look for the V of the two rivers and the proposed crossing is a little to the north on the Suwannee.

At the point where the Suwannee and the Withlacoochee meet there are NUMEROUS major springs — see the attached map from the Suwannee River Water Management District Web Site (SRWMD Spring Map — Exhibit “C”) —

NONE of these springs are addressed in the karst study done by Sabal. There are springs both north of the proposed pipeline and springs south of it.

I am attaching a document from the SRWMD with information on all of the springs that are in this area and which they failed to identify for you. See Exhibit “D”.

They are all in the area I circled on the attached maps — they are all less than two miles from the proposed pipeline and the crossing — they are all major springs (and should have been identified and discussed) 7 they are all interconnected as proven by recent testing by state agencies and they fall both north and south of the proposed crossing 7 they could not have picked a worse place to cross. The springs I am identifying are:

Lime Run Spring or Sink (magnitude 1 spring, 173 cubic feet per second) 7 17 miles to the south of the crossing by the V;
Falmouth Spring — magnitude 1— outflow as high as 220 cubic feet per second with recent readings in the range of 160 cubic feet per second) 7 to the southeast of the V;

Stevenson Spring (also known as Lineater Spring and/or SUW923973)—discharge rate of 93 cubic feet per second — magnitude 2 spring— 7 percent shy of magnitude 1 spring 7 this spring is .7 miles to the north of the crossing;

Lime Spring -magnitude 2 spring, 20.3 cubic feet per second — by the V — 1.7 miles to the south of the crossing;

Suwanacoocheee Spring — a magnitude 2 spring, 52 cubic feet of water per second — to the south by the V — 1.5 — 2 miles from the crossing;

SUW923971—magnitude 4 spring, 1 cubic foot per second) 7 to the south by the V; and
Ellaville Spring (also known as Edwards Spring) — magnitude 2 spring, 82 cubic feet per second — to the South by the V
SUW923972 — Magnitude 4 — the only one they address at all (they claim it is irrelevant and don’t acknowledge it as connected to the others) 7 less than 1/2 mile to the nmth of the crossing

The document I attach from SRWMD gives detail on each spring. Most of these springs have also been shown by the National Speleological Society (the Cave divers group) to be interconnected and many of them have been mapped by this organization with miles of tunnels and caverns in the exact area where the HDD crossing is proposed.

I hope this helps explain that I am not just a disgruntled land owner as Sabal claims in their filings (reference their comment about landowners not wanting their pipeline there). The proposed HDD crossing of the Suwannee River cannot be justified based on language in their own Karst analysis e the likely reason they ignored these springs is their own analysis would prohibit this path if they had revealed them.

Note that the undersigned is a lay person attorney and NOT a karst expert. Basic research revealed the information contained herein and the omission of this infonnation by Sabal’s purported karst experts should raise serious questions as to the credibility of Sabal’s filings.

RELIEF REQUESTED

The undersigned respectfully requests FERC consider these comments and materials and that the Sabal Trail route be rejected as it relates to the current route through the Suwannee River State Park and Echo River Plantation and that an alternative route be mandated that does not go through this area of the state, but instead uses alternative existing pathways that are safer from an ecological and conservation standpoint.

Respectfully submitted January 29, 2015.
/s/ Thomas S. Edwards Jr.
THOMAS S. EDWARDS, JR.
State Bar of Florida #395821
For EDWARDS & RAGATZ, P.A.
Attorneys for Intervenor
501 Riverside Avenue, Suite 601
Jacksonville, FL 32202
(904) 399-1609