Madison County, FL asks USACE for a SEIS 2016-07-18

This request for a Supplementary Environmental Impact Statement (SEIS), mentioning Madison Blue Spring in particular, was sent July 18th or 19th 2016, one copy to each of the Corps addresses. (PDF). That’s the fourth Florida county to make such a request, after Hamilton, Suwanee, and Marion Counties. The Corps already responded to Madison County.

Board of County Commissioners
Madison County, Florida

to express our concerns

Jacksonville Permits Section
U.S.A.C.E. Regulatory Division
Attn: Mark R. Evans,
  Senior Project Manager,
Post Office Box 4970
Jacksonville, Florida 32232

Commander, U.S.A.C.E.,
Savannah District
Attn: Mr. Terry C. Kobs
1104 N. Westover Boulevard, Unit 9
Albany, GA 31707

Mobile District Reg. Div.
Montgomery Field Office
Attn: Mr. James S. Cherry II
605 Maple Street
Building 1429 Room 105
Maxwell AFB, AL 36112-6017


Norman C. Bay, Chairman
Cheryl A. LaFleur, Commissioner
Tony Clark, Commissioner
Colette D. Honorable, Commissioner
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426

Re: Application Numbers: SAS-2013-00942 (GA), SAJ-2013-03030 (FL), SAM-2014-00655-JSC (AL)

Applicants: Sabal Trail Transmission, LLC, Attn Mr. George McLachlan;
 Florida Southeast Connection, LLC, Attn: Mr. Randall LaBauve
 Transcontinental Gas Pipe Line Company, LLC, Attn: Ms. Karen Olson

FERC Docket Nos.: CP15-17-000, CP14-554-000, CP15-16-000

Dear Mr. Evans, Mr. Kobs, and Mr. Cherry:

The Board of County Commissioners of Madison County writes to express our concerns regarding Sabal Trail Transmission, LLC’s (“Sabal Trail”) proposal to construct a 516-mile-long, 36-inch-diameter natural gas pipeline through Alabama, Georgia, and Florida. If approved, the pipeline would traverse neighboring Hamilton County east of the Withlacoochee River which is the border with Madison County, and only about a mile away, often less.

Geological studies to the north and to the south show that water travels many miles underground in the same fragile karst limestone that contains the Floridan Aquifer in Madison County. In the next county to the north, Lowndes County, Georgia, water travels as much as fifteen miles to Valdosta’s water wells,[1] including from Shadrick Sink on the other side of the Withlacoochee River. In the next county to the south, Suwannee River Water Management District (SRWMD) in 2014 put dye into Falmouth Sink in Suwannee County and some of it came up two days later more than three miles away in Suwannacoochee Spring in Madison County, after travelling under the Suwannee River.[2]

Withlacoochee River, Madison Blue Spring, water wells We are concerned that any sinkholes, cracks, or crevices near Sabal Trail’s pipeline, whether they occur naturally as they often do, or whether they are caused by construction or leakage later, could carry contaminants into or under the Withlacoochee River, into Madison Blue Spring or into water wells in Madison County.

We are especially concerned by Sabal Trail’s June 6th 2016 response[3] to U.S. Rep. Sanford Bishop’s letter of May 31st 2016.[4] Sabal Trail wrote in part:

“The City of Valdosta’s 2014 Water Quality Report states that the travel time of groundwater from a sinkhole on the Withlacoochee River to the City’s wellfield, a distance of 3 miles, is approximately 75 years. This extremely slow travel time combined with the fact that groundwater in the aquifer at the Withlacoochee HDD crossing moves to the west, away from Valdosta, makes it impossible that contaminated water entering the Floridan aquifer as a result of the HDD crossing, could contaminate Valdosta’s wellfield.”

Madison County is to the west and downstream of Sabal Trail’s proposed HDD crossing of the Withlacoochee River in Georgia. In addition, since the Falmouth Dye Trace established water can move underground and under a river three miles in only a few days, it is puzzling how Sabal Trail could use the word “impossible” in this context. Since Madison County will be here in two days or in 75 years, we would like to see a more comprehensive study of the cumulative evidence, especially before the Corps issues any permit.

As Rep. Bishop noted, there are state permits outstanding in Alabama, Georgia, and perhaps in Florida, and the Clean Water Act prohibits the Corps or the Federal Energy Regulatory Commission (FERC) from issuing a permit before all state permits are issued.

formal request for a SEIS Please consider this letter as a formal request for the Army Corps of Engineers to make a site inspection to determine the actual proximity of active sinkholes and other features of the aquifer and cave systems to the proposed pipeline route, and for the U.S. Army Corps of Engineers to open a process for a Supplemental Environmental Impact Statement (SEIS) to take into account further evidence, especially cumulative evidence, before issuing any permit.

Allen Cherry, County Coordinator
Madison County, Florida

[1] "The Connection Between Surface-Water Quality and Ground-Water Quality in a Karst Aquifer," Box E on Page 63 in Sustainability of Ground-water Resources, by William M. Alley Thomas E. Reilly O. Lehn Franke, USGS Survey Circular 1186, 1 January 1999,

[2] "Falmouth dye trace reveals unknown connectivity", by Abby Johnson, Suwannee River Water Management Press Release, December 4, 2014,

[3] “Sabal Trail Transmission, LLC submits its Response to Letter from U.S. Representative Sanford D. Bishop, Jr. under CP15-17.” FERC Accession Number 20160607-5134, June 7, 2016,

[4] "U.S. Representative Sanford D. Bishop submits comments re Sabal Trail Transmission's natural gas pipeline proposal etc. under CP15-17 et al." FERC Accession Number 20160601-0010, May 31st 2016,


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  1. Pingback: USACE refuses Madison County’s request for a Sabal Trail SEIS 2016-07-29 | WWALS Watershed Coalition

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