Redesignating waterways as Recreational –GA-EPD Triennial Review Meeting 2021-02-02

The Georgia Environmental Protection Division (GA-EPD) is being quite thorough about the Triennial Review of Water Quality Standards that is required by federal law. However, several problems were revealed at their online meeting on February 2, 2021. Some of the GA-EPD slides are inline below, and the rest are on the WWALS website:–ga-epd-triennial-review

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[Second-class Recreational, maps, wastewater]
Second-class Recreational, maps, wastewater

They want to create a second class of Recreational designation for boating, with more lax restrictions on contamination and only seasonal application; several waterbodies we requested are missing; and they want to declare that 20 river miles downstream from a wastewater permit cannot be Recreational.

Second-class Recreational designation

Here is the slide defining second-class Recreational for boating:

[Bacteria Criteria: Secondary contact recreation for boating, fishing, etc.*]
Bacteria Criteria: Secondary contact recreation for boating, fishing, etc.*

  • “Primary contact recreation” is full immersion contact with water where there is significant risk of ingestion that includes, but is not limited to, swimming, diving, water skiing, and surfing.
  • “Secondary contact recreation” is incidental contact with the water not involving a significant risk of water ingestion such as canoeing, fishing, kayaking, motor boating, rowing, splashing, wading, and occasional swimming.

I was not the first to point out that people boating in south Georgia often get out and swim along the way. GA-EPD wants lists of specific swimming holes. OK, done: mostly they’re where the access points are for our water trails. But people will swim in the river where-ever they take a mind to, so listing swimming holes misses the point. The entire river is a swimming hole.

Plus just getting into and out of a boat is likely to get you wet, as well as water dripping off paddles as you go. Then there’s the possibility of capsizing. EPD said they had a study that showed you’re four times less likely to ingest water on a capsize than if you deliberately swim. Which still misses the point that people do swim on purpose while boating.

The year-round freshwater primary contact recreation criteria for E. coli are the same as we use all the time: no more than 126 cfu/100 mL for a 30-day geometric mean, and no more than 410 for a single sample.

[Year-round primary recreation criteria: Recreation vs. Fishing/Drinking Water*]
Year-round primary recreation criteria: Recreation vs. Fishing/Drinking Water*

Seasonal considered inappropriate

The problem comes with that second-class Recreational designation. They did lower the previous limits, but the new limits are still higher in November through April: 353 30-day mean or 1148 single-sample.

[Seasonal secondary contact criteria: Recreation vs. Fishing/Drinking Water*]
Seasonal secondary contact criteria: Recreation vs. Fishing/Drinking Water*

That makes no sense in south Georgia, where people boat year-round, and often swim while they boat. As I mentioned in the meeting, it was unlikely anybody was swimming that particular day, because it froze that morning, but it could be 75 degrees the same week any day of the year down here. Two of our members paddled 11 miles on the Alapaha River the other day in 40-degree weather. We have paddled in the Okefenokee Swamp when it was 35 degrees and drizzling rain.

Actually, in the winter there are fewer mosquitoes, so many paddlers prefer paddling in the cooler months.

So seasonal differences in river water quality limits make no sense in central south Georgia. People boat, fish, and yes, swim year-round in our waterways. We do get snow here, about every ten years. Otherwise, our seasons are not north Georgia seasons: we grow Satsuma oranges and bananas in our central South Georgia watersheds.

Thus in south Georgia we need first-class Recreational designations year-round.

Missing waterbodies

For reference, here is what we requested from GA-EPD back in 2019:

See also Cost of reclassifying Georgia rivers from Fishing to Recreational in Triennial Review of Water Quality Standards.

The map of waterbodies for which Recreational designation was requested does include:

[Map: recreation-requested]
Map: recreation-requested

However, it is missing Banks Lake National Wildlife Refuge (NWR), Grand Bay Wildlife Management Area (WMA), and Lake Irma in Lakeland, GA. All three are in the WWALS Alapaha River Water Trail (ARWT).

And all three are on the slide listing Waterbodies Under Consideration for Recreation Use. So I’m guessing the map was for waterway tracks, and did not include lakes and swamps.

[Waterbodies Under Consideration for Recreation Use*]
Waterbodies Under Consideration for Recreation Use*

They are both missing Reed Bingham State Park Lake, but that’s the only waterbody in the Suwannee River Basin that is already designated Recreational, so Reed Bingham SP Lake does not need to be redesignated.

Back on January 19, 2021, I responded for WWALS to questions from GA-EPD about what part of Grand Bay and the Okefenokee Swamp were we proposing to redesignate Recreational. Here are excerpts.

Grand Bay WMA

For Grand Bay let’s use the WMA boundaries…; here is GA-DNR’s own map:,30.904,-83.071,31.025

Here is a screenshot:

[Map: Grand Bay WMA by GA DNR]
Map: Grand Bay WMA by GA DNR

Immersive activities are most likely to occur near the two boat ramps, especially on the canoe trails. Here’s a detail from DNR’s interactive map, showing those boat ramps near the WMA entrance off of Knights Academy Road:

[Grand Bay WMA Boat Ramps]
Grand Bay WMA Boat Ramps

However, anything that affects the water level or quality of Grand Bay anywhere, or that of the closely-interconnected Banks Lake, is likely to affect the area near those boat ramps. So it would be better to reclassify the entire extent of the Grand Bay WMA as Recreational.

Okefenokee NWR

For the Okefenokee Swamp, let’s use the NWR boundaries.

Here is U.S. Fish & Wildlife Service (FWS)’s own map:

This screenshot shows ONWR, and also has Banks Lake NWR on it towards the upper left:

[Map: Okefenokee NWR by U.S. FWS]
Map: Okefenokee NWR by U.S. FWS

Immersive activities are most likely to occur along the numerous canoe trails. Here is ONWR’s own map of the Okefenokee Wilderness Area Canoe Trails:

[Map: Trails in Okefenokee NWR by U.S. FWS]
Map: Trails in Okefenokee NWR by U.S. FWS

Examples of immersive activities include simply getting in and out of boats, which usually involves wading in the water and getting it in the boat, as well as paddling involves water dripping off the paddle into the boat and onto the paddler. In addition, it is not uncommon for people to get out and wade in areas that are only somewhat submerged. Plus there is always the possibility of a boat capsizing.

As you can see, the Okefenokee Wilderness Area Canoe Trails traverse much of the Swamp. People come from all over the world to paddle on them. WWALS alone organizes several paddles a year on them.

People do also boat in areas of the Okefenokee Swamp not on those trails. I know multiple people who have paddled from Okefenokee Swamp Park (OSP) down the Suwannee River. While OSP is not within the ONWR boundaries, reclassifying the ONWR as Recreational would suffice to protect that and other areas outside the ONWR boundaries, as well as areas inside the ONWR that are not on the Canoe Trails.

Given that the Okefenokee is a large, flat, swamp, anything that affects water levels or quality of any of it probably will affect all of it. So it does not seem prudent to limit the Recreational classification to the canoe trails. The entire extent of the ONWR seems a better proxy for the entire Okefenokee Swamp.

I have discussed this reclassification with ONWR personnel, who are amenable to the ONWR boundaries being used for this purpose. They plan to send further information later related to your other items 6-9.

We are also contacting other organizations about these and the other waterbodies of reclassification.

Banks Lake NWR

We did not send GA-EPD additional boundary designations for Banks Lake, because we already said Banks Lake NWR.

WWALS holds Full Moon paddles there every month, to see the sun set, the moon rise, and often birds and bats. Yes, there are alligators. One attendee at the Banks Lake Halloween Blue Moon paddle in 2020 was the Manager of both Banks Lake NWR and Okefenokee NWR.

[The Mad Manatee meets Pirate, witches, wolf, Mad Hatter, and more]
The Mad Manatee meets Pirate, witches, wolf, Mad Hatter, and more

Here is U.S. FWS’s own map of Banks Lake NWR:

[Map: Banks Lake NWR by U.S. FWS]
Map: Banks Lake NWR by U.S. FWS

Suwannee River Basin in Georgia

Here is the WWALS google map of all landings in the Suwannee River Basin.

This screenshot shows the Georgia part of the Basin:

[Map: Suwannee River Basin in Georgia]
Map: Suwannee River Basin in Georgia

The screenshot zooms in on Banks Lake NWR (purple outline) and Grand Bay WMA (yellow outline).

[Map: Grand Bay WMA and Banks Lake NWR by WWALS]
Map: Grand Bay WMA and Banks Lake NWR by WWALS

Notice that the boundary between the two is not quite right, because I added the boundaries from the Tax Assessor maps for Lowndes County and Lanier County, Georgia. The west end of Banks Lake NWR is apparently part of the same land owned by Moody Air Force Base that forms the northmost part of Grand Bay WMA.

Permits, TMDLs, and downstream

GA-EPD is rightly concerned about Total Maximum Daily Load (TMDL) designations for rivers, including the Withlacoochee River.

[Map: Withlacoochee TMDL]
Map: Withlacoochee TMDL

Manure runoff, not sewage, is our big problem

Our problem on the Withlacoochee, Little, and Alapaha Rivers is non-point-source manure runoff from fields after rains, mostly NOT sewage spills from NPDES permitees.

GA-EPD proposes to say that 20 river miles downstream from an NPDES permit outflow cannot be designated Recreational. That is not appropriate for the Withlacoochee River. The only NPDES wastewater permit directly on the Withlacoochee River is for Valdosta’s Withlacoochee Wastewater Treatment Plant (WWTP). The WWTP has not spilled since December 2019. Because of a GA-EPD Consent Order, Valdosta is now testing for E. coli three times a week on forty river miles to the state line. Just across the state line, Madison County, Florida, tests twice a week at the state line and two places downstream into Florida. WWALS fills in the gaps with weekend and other testing. We have DNA marker and chemical tracer data from the Florida Department of Environmental Protection (FDEP) and WWALS also does selected DNA tests. See

All this data shows our big problem is manure runoff after rains. Probably mostly cattle manure, although sometimes pig, and we are looking at horses. Yes, we do still get occasional sewer spills that affect the Withlacoochee River, most recently from Quitman, GA, coming down Okapilco Creek. But that is far less frequent than high river E. coli from manure runoff.

The E. coli most likely from cattle manure goes up fastest at Knights Ferry Boat Ramp, coming down Okapilco Creek from Brooks County. That is less than 20 miles downstream from the WWTP, but unrelated to it. After big rains, we often also get higher than 410 cfu/100 mL upstream of the WWTP.

We track when the Withlacoochee River is clean and when it is not, we announce that, on social media and in the international smartphone app Swim Guide, and people do pay attention. A blanket TMDL does not reflect any of this.

On Saturday, February 27, 2021, the Mayor of Valdosta will help us lead maybe a hundred people paddling directly past the outfall of the WWTP on the Withlacoochee River. Valdosta already approved a resolution supporting our Withlacoochee and Little River Water Trail (WLRWT), and another resolution supporting our Alapaha River Water Trail (ARWT). We will ask Valdosta for an explicit letter of support for these Recreational redesignations.

We are working with the Southern Georgia Regional Commission (SGRC) on a 319 grant proposal about further tracing sources so that we can get funds to assist agricultural operators

This situation is not like any other rivers in Georgia (or Florida), as near as we have been able to discover, because of the masses of E. coli and other testing going on. We are very aware of the TMDLs on the Withlacoochee River, but they don’t reflect our current knowledge of the actual state of the river.

Thanks to GA-EPD

In the meeting, I thanked GA-EPD for their Sewage Spills Report, updated each weekday, posting reports the same day they receive them from wastewater permit holders. GA-EPD listened to the thirty organizations in Georgia and Florida that requested those reports.

I also thanked them for the Consent Order that is the reason why Valdosta now tests forty river miles to the state line three times a week. I mentioned that Valdosta has been quoted recently as saying they realize those tests are so useful that they plan to continue them even after the required four-year period.

And I thanked them for the forthcoming public hearings and review process for the five permit applications from Twin Pines Minerals LLC of Birmingham, Alabama, to strip mine for titanium far too near the Okefenokee Swamp.


Now let’s see if GA-EPD can incorporate into their Triennial Review how south Georgia waterways are different from north Georgia trout streams.

Please: primary recreational designation for all the rivers, lakes, and swamps we have proposed, and year-round (not seasonal) bacterial and other limits. Also no 20-mile limit downstream of wastewater permits.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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