March 8, 2019 PDF and Context

To: EPD.Comments@dnr.ga.gov

      Elizabeth Booth, Environmental Protection Division

      Watershed Protection Branch,

      Watershed Planning & Monitoring Program,

      Suite 1152 East, 2 Martin Luther King, Jr., Dr., Atlanta, GA 30334

Cc: Victoria Adams <Victoria.Adams@dnr.ga.gov>, 404-463-4955

Re: Water Quality Standards 2019 Triennial Review

       https://epd.georgia.gov/triennial-review-water-quality-standards#_TR_2019

Dear EPD,

I write to request three changes in the 2019 Triennial Review:

  1. All rivers and many lakes and swamps in the Suwannee River Basin should be designated Recreational, not Fishing.
  2. Boating, especially in paddle craft such as canoes, kayaks, and paddleboards, should be considered primary recreation, not secondary.
  3. Water quality standards should be the same year-round, not lower in winter.

Point 1: Recreational designation for the Suwannee River Basin.

Point 2: Boating should be considered primary contact recreation.

Your slide 5, DESIGNATED USES, for the February 2019 Public Hearing, lists:

From our south Georgia perspective, this seems a very strange ordering. All our streams are warm water, which is why people fish in them year-round for catfish, bass, and bream.

People also boat on our waters year-round, largely because they are warm water.

In our Suwannee River Basin rivers, and in many others in the state of Georgia, boating, especially paddle boating, involves direct contact with the water.

  1. Water drips from the paddle.
  2. Getting in or out of the boat often involves wading.
  3. Every WWALS outing is also a cleanup, involving retrieving trash into the boat, along with some water.
  4. In warm weather, boaters often swim during a paddle.
  5. Because of overhanging branches, deadfalls, shoals, and other reasons, falling in is so common in every season of the year that WWALS even has a Fallers Award. Pictured are two such award winners, from our 2018 BIG Little River Paddle Race.

Thus warm water should be considered a reason for listing streams, lakes, and swamps as “Recreation – Primary Contact” and all our streams and waterbodies in the Suwannee River Basin should be so listed.

Point 3: year-round water quality standards

Thank you for this listing in your presentation slides from the February 2019 Public Hearing:

Indeed, the southeast side of the Okefenokee Swamp is in the Satilla and St Marys River Basins, while the rest is in the Suwannee River Basin. This distinction is common knowledge among those of us who live in south Georgia.

As Suwannee Riverkeeper, I report that people boat in the Okefenokee Swamp and the Suwannee River every month of the year, as well as on the Alapaha, Little, and Withlacoochee Rivers, and on Banks Lake and Reed Bingham State Park Lake. They also fish, swim, and dive in November through April, when the current Georgia Bacterial Standards are lower. https://adoptastream.georgia.gov/sites/adoptastream.georgia.gov/files/related_files/document/B_Ch_1.pdf.

For seven years, we have held our BIG Little River Paddle Race in April, and last year we held a new WWALS Boomerang Paddle Race in November on the Withlacoochee River.

Boating, swimming, fishing, and diving are economic advantages

In addition to the environmental benefits of clean waters. The WWALS water trails have letters of support from tourism authorities, chambers of commerce, city councils, and county commissions, attesting to the economic advantages of water trails. Several county Comprehensive Plans, including those for Lowndes and Brooks Counties, also attest to the economic value of our waters and water trails. http://wwals.net/blog/water-trails/

There are not many cleaner economic benefits, and few requiring less public investment. The entire Suwannee River Basin is above the porous coastal plain limestone that contains the Floridan Aquifer, which is the source of all our drinking water, irrigation for agriculture, water for industry. River water interchanges with groundwater, so river water quality is essential for everything here, from boating to brewing beer. Please reclassify our rivers as Recreational, and update the Georgia Bacterial Standards to be the same year-round.

Sincerely,

John S. Quarterman,

 Suwannee Riverkeeper,

 WWALS Watershed Coalition

 850-290-2350, 229-242-0102

 contact@suwanneriverkeeper.org

Attachments: Map of Landings on all Suwannee River Basin Rivers in Georgia

    Criteria for Changing Recreational Use for:

Suwannee River, Okefenokee Swamp

Alapaha River, Lake Irma, Banks Lake, Grand Bay

Withlacoochee River

Little River, Reed Bingham State Park Lake

Map of Landings on all Suwannee River Basin Rivers in Georgia (PDF)

This map shows most of the landings on the largest rivers in the Suwannee River Basin in Georgia, with their sub-basins color-coded, from east to west: Suwannee, Alapaha, Withlacoochee, and Little. Not all landings can be depicted at this scale; see the maps for the individual rivers, swamps, and lakes. https://www.google.com/maps/d/u/0/viewer?mid=1dnRr3ATEwReknyLZq26-316FfydbER2K

The rest of the attachments each address each of the required criteria for changing a use classification:

  1. Name and length of the waterbody.
  2. Location of the reach, shown on a map.
  3. Any 305(b)/303(d) impairment(s) &/or TMDL(s).
  4. Current users of the waterbody, including but not limited to
  1. Letters of support from:
  1. Investments, both completed and pending, for improved use of the waterbody such as boat ramps, parks, trails, or drinking water systems. Include the amount of the investment, as well as who funded the project(s) and for what purpose.d

Suwannee River, changing its Designated Use to Recreational (PDF)

Suwannee River. Of its 250 miles, about 35 miles are in Georgia, plus its three branches in the Okefenokee Swamp.

See also http://wwals.net/maps/suwannee-river-wilderness-trail/

See next bullet point (stakeholders) for Fargo, Clinch County, Waycross, Echols County, and Valdosta.

There are boat ramps on the Suwannee River in Georgia at GA DNR’s Stephen C. Foster State Park in Charlton County and at Fargo in Clinch County at US 441. There is riverbank access at the Suwannee River Sill and at Griffis Fish Camp, both off of GA 177 between Fargo and the Park. See next section, on Okefenokee Park, for extensive investments.

Okefenokee Swamp, changing its Designated Use to Recreational (PDF)

Okefenokee Swamp. About half of its 438,000 acres are in the Suwannee River Basin, and almost all of that is in Georgia.

See also http://wwals.net/blog/maps/basin/

See next bullet point (stakeholders) for Fargo, Clinch County, Ware County, and Lowndes County.

GA DNR’s Stephen C. Foster State Park has a boat ramp, boat rental, boat tours, 9 cottages, 99 campsites, 1 primitive campground, 3 picnic shelters, a playground, and other outbuildings, https://gastateparks.org/StephenCFoster as well as the Suwannee River Eco-Lodge off of GA 441 north of Fargo. https://gastateparks.org/SuwanneeRiverEcoLodge

Okefenokee National Wildlife Refuge has numerous sleeping platforms on boating trails in the park, as well as a boardwalk and landing on Billy’s Island. https://www.fws.gov/refuge/okefenokee/

Alapaha River, changing its Designated Use to Recreational (PDF)

Alapaha River. Of its 202 miles, 179 are in Georgia. Of the 129 miles on the WWALS Alapaha River Water Trail, 106 miles are in Georgia. At least the 106 miles from Sheboggy Boat Ramp (on US 82 east of Alapaha, GA) to the state line should be reclassified as Recreational. Reclassifying the entire 179 miles of the Alapaha River in Georgia would be better.

See also http://wwals.net/maps/alapaha-water-trail/

The WWALS Alapaha River Water Trail has eleven river landings in Georgia. http://wwals.net/maps/alapaha-water-trail/

See next bullet item (stakeholders) for Valdosta, Lowndes County, Berrien County, Lanier County, Atkinson County, and Echols County.

There are four public boat ramps on the Alapaha River in Georgia, and another being constructed: http://wwals.net/maps/alapaha-water-trail/

In addition there are six public riverbank landings:

* WWALS paid approximately $3,000 for water trail signs at these nine locations on the Alapaha River. At each location, there is a pair of signs (one for each direction of approach). Each pair of signs has three parts on the same pole: a sign saying Alapaha River Water Trail and with appropriate icons, a sign naming the landing and the county, and a directional arrow.

Lowndes County has promised to make and plant road signs at Naylor Boat Ramp when it is completed.

Lake Irma, changing its Designated Use to Recreational (PDF)

Lake Irma, about 12 acres in Lakeland, Georgia.

Apparently none.

The Lanier-Lakeland Chamber of Commerce advertises Lake Irma as an attraction. http://www.lakelandchamber.org/parks-trails.htm

WWALS participated in the 2nd Annual Flatlander Canoe and Kayak Race, 5 October 2014. http://wwals.net/?p=3764

Lake Irma and the land around it is a Lakeland city park, along with the nearby Robert Simpson Nature Trail, advertised on the Chamber of Commerce website. http://www.lakelandchamber.org/parks-trails.htm

The WWALS Alapaha River Water Trail includes Lake Irma. http://wwals.net/maps/alapaha-water-trail/

See next bullet item (stakeholders) for Lanier County.

All those who endorsed the Alapaha River Water Trail, especially Lanier County. See Alapaha River.

Banks Lake, changing its Designated Use to Recreational (PDF)

Banks Lake. 4,049 acres in Banks Lake National Wildlife Refuge.

MERCURY AND FISH CONSUMPTION GUIDELINES DUE TO MERCURY TMDL http://epd.georgia.gov/sites/epd.georgia.gov/files/tmdl/TMDL_Implementation_Plans/SouthGA4_ProgramPlans/TMDLIP_SouthGA4_FCG_Hg_Y2002.pdf

“Night fishing is allowed. Fishing tournaments require a special use permit and privately-sponsored bass tournaments are held frequently year-round. Largemouth bass is the most popular sport fish, and ten-pounders are occasionally caught. Other favorites are speckled perch (crappie), bream (bluegill), and catfish.”

Banks Lake National Wildlife Refuge is managed as part of the Okefenokee Complex by the U.S. Fish and Wildlife Service, along with Okefenokee National Wildlife Refuge. https://www.fws.gov/refuge/Okefenokee/About_the_Complex.html

The WWALS Alapaha River Water Trail includes Banks Lake. http://wwals.net/maps/alapaha-water-trail/

See next bullet item (stakeholders) for Lanier County.

All those who endorsed the Alapaha River Water Trail, especially Lanier County. See Alapaha River.

Georgia Tourism: https://www.exploregeorgia.org/lakeland/outdoors-nature/bird-watching/banks-lake-national-wildlife-refuge

“Facilities at Banks Lake NWR include restrooms, boat ramp, short walking trail, boardwalk and platform, and accessible fishing dock. Night fishing is permitted, and there is no launch fee.  The concession operation, Banks Lake Outdoors, has canoe and kayak rentals and a place to buy your bait before you launch your boat!”

https://www.fws.gov/refuge/Banks_Lake/visit/visitor_activities.html

Grand Bay, changing its Designated Use to Recreational (PDF)

Grand Bay. “The Grand Bay Wildlife Management Area (WMA) encompasses 2,623 acres of state-owned property and 5,874 acres of land under license from the U.S. Air Force.”

See also http://wwals.net/maps/alapaha-water-trail/

None known. However, Moody Air Force Base leaked toxic firefighting foams (per- and polyfluorinated alkyl substances  or PFASs),) at numerous locations upstream of Grand Bay. http://wwals.net/?p=48001

The WWALS Alapaha River Water Trail includes Grand Bay. http://wwals.net/maps/alapaha-water-trail/

All those who endorsed the Alapaha River Water Trail, especially Lowndes County and Lanier County. See Withlacoochee River.

The 2016 Greater Lowndes Comprehensive Plan lists Grand Bay Wildlife Management Area and Wetland Education Center among “Important parts of the local economy which should be better promoted and utilized”. https://www.lowndescounty.com/DocumentCenter/View/1512/2016-Greater-Lowndes-Comprehensive-Plan-PDF

GA DNR’s Grand Bay Wildlife Management Area has two boat ramps, primitive camping, extensive boardwalk, observation tower, hiking trails, and educational center. It lists canoeing first among activities, along with lake fishing. https://georgiawildlife.com/grand-bay-wma

Withlacoochee River, changing its Designated Use to Recreational (PDF)

Withlacoochee River. Of its 115 miles from Berrien County to the Suwannee River in Florida, 87 miles are in Georgia. Of the 97.7 miles of this river in the Withlacoochee and Little River Water Trail (WLRWT), 70 miles are in Georgia, from GA 37 between Adel and Ray City past Valdosta, Quitman, and Clyattville to the state line. At least those 70 miles of the Withlacoochee River on the WLRWT in Georgia should be reclassified as Recreational. Reclassifying the entire Withlacoochee River in Georgia would be better.

See also http://wwals.net/maps/withlacoochee-river-water-trail/

The WWALS Withlacoochee and Little River Water Trail has nineteen landings on those rivers in Georgia, of which ten are on the Withlacoochee River. http://wwals.net/maps/withlacoochee-river-water-trail/

See next bullet item (stakeholders) for Brooks County, Adel, Hahira, and Valdosta.

In Georgia on the Withlacoochee River there are Youngs Mill Creek Landing on GA 37, with paved access by Cook County, and Ray City Landing at GA 37, which Berrien County agreed to name that and to authorize WWALS to plant signs.

Lowndes County has promised to make and plant road signs at all river landings in Lowndes County, which on the Withlacoochee River include Hagans Bridge Landing at GA 122, Franklinville Landing, Staten Road Landing, Langdale Park Boat Ramp (VLPRA) off of US 41, Sugar Creek Landing on Gornto Road, Knights Ferry Boat Ramp (VLPRA), Nankin Boat Ramp (VLPRA), and State Line Boat Ramp (GA DNR & VLPRA).

VLPRA: Valdosta-Lowndes County Parks & Recreational Authority.

Little River, changing its Designated Use to Recreational (PDF)

The Little River runs 105 miles, all in Georgia, from its source near Ashburn to its confluence with the Little River just west of Valdosta. At least the 59 miles on the Withlacoochee and Little River Water Trail (WLRWT), from Kinard Bridge Landing west of Lenox to the Little River Confluence with the Withlacoochee River just downstream from Troupville Boat Ramp west of Valdosta, should be reclassified as Recreational. Better would be to reclassify the whole river.

See also http://wwals.net/maps/withlacoochee-river-water-trail/

The WWALS Withlacoochee and Little River Water Trail has nineteen landings in Georgia (see Withlacoochee River), of which nine are on the Little River, including two on Reed Bingham State Park Lake. http://wwals.net/maps/withlacoochee-river-water-trail/

The Sixth Annual BIG Little River Paddle Race in 2018 drew 49 paddlers in 43 boats, 29 male, 20 female, from 4 to 69 years old, from 10 watersheds, 15 counties, and two states (Georgia and Florida).  http://wwals.net/?p=43850

See next bullet item (stakeholders) for Adel, Cook County, Tifton, Hahira, Valdosta, Lowndes County, and others.

GA DNR has four boat ramps on the Little River: Reed Bingham State Park Boat Ramp (West in Colquitt County and East in Cook County), Cook County Boat Ramp, and Troupville Boat Ramp in Lowndes County. Cook County also has Kinard Bridge Landing near Lenox, upstream from RBSP, and Antioch Road Landing between RBSP and Cook County Boat Ramp. Colquitt County also has Adel-Moultrie Landing on GA 37 just downstream from the RBSP Lake Dam.

Lowndes County has promised to make and plant road signs at all river landings in Lowndes County, which on the Little River are Folsom Bridge Landing at GA 122 and Troupville Boat Ramp (GA DNR & VLPRA). Valdosta through VLPRA funded significant improvements to the access road to Troupville Boat Ramp.

VLPRA: Valdosta-Lowndes County Parks & Recreational Authority.

Reed Bingham State Park Lake, changing its Designated Use to Recreational (PDF)

Reed Bingham State Park Lake. According to GA DNR: http://explore.gastateparks.org/info/94

“A 375-acre lake is popular with boaters and skiers, and fishing for bass, crappie, catfish and bream is excellent. Paddlers can rent canoes and kayaks to explore this beautiful lake lined with fragrant water lilies and tupelo trees. Guided pontoon boat tours are sometimes offered during events. The beachside pavilion, picnic shelters and group shelters are scenic spots for parties, reunions and other celebrations. Reed Bingham is less than six miles from I-75, making it a relaxing stop for travelers. It was named for Amos Reed Bingham who was instrumental in having the park established.

“Visitors to this pretty park usually see abundant wildlife, including species such as gopher tortoises, yellow bellied sliders and indigo snakes. Nesting bald eagles are often seen in winter. American alligators are often seen sunning along the lake’s edge. During winter, thousands of “buzzards,” actually black vultures and turkey vultures, roost in the trees and soar overhead. Nearly 80 percent of the Coastal Plain’s plant community can be found along the park’s Coastal Plain Nature Trail, making this park’s habitat some of the most diverse in the country.”

https://gastateparks.org/sites/default/files/parks/pdf/reedbingham/ReedBingham_OrienteeringMap.pdf

Reed Bingham State Park.  http://explore.gastateparks.org/info/94

The WWALS Withlacoochee and Little River Water Trail includes the two GA DNR boat ramps on Reed Bingham State Park Lake and Red Roberts Landing, upstream on the Little River from that Lake, and still within the Park. http://wwals.net/maps/withlacoochee-river-water-trail/

The WWALS and FORB Sixth Annual BIG Little River Paddle Race in 2018 drew 49 paddlers in 43 boats, 29 male, 20 female, from 4 to 69 years old, from 10 watersheds, 15 counties, and two states (Georgia and Florida).  http://wwals.net/?p=43850

See next bullet item (stakeholders) for Adel and Cook County.

GA DNR has two boat ramps on Reed Bingham State Park Lake and Red Roberts Landing upstream on the Little River, as well as the rest of the state park itself, with all its buildings, roads, and staff.

wwalswatershed@gmail.com               PO Box 88, Hahira, GA 31632           Page  of              850-290-2350                            www.wwals.net