Tag Archives: swamp

Twin Pines: no keys to the Okefenokee –Christian Hunt 2019-10-23

Excellent letter in the Charlton County Herald, October 23, 2019. You can send your own letter to the editor or comment to the Army Corps or GA-EPD.

Twin Pines should not be given the keys to the Okefenokee

Dear Editor,

Since announcing plans to strip mine along the Trail Ridge adjacent to Okefenokee National Wildlife Refuge, Twin Pines Minerals has held multiple hearings and meetings with political figures and the people of Charlton County to make their case and ostensibly calm fears about the miners environmental impact. Unfortunately, the company continues to display a lack of transparency and misrepresent both the nature and scale of the proposed mine, as well the costs of mining next to the swamp.

To truly understand what is at stake, here are the facts.

[Hunt]

First, Twin Pines has repeatedly claimed that operations will only Continue reading →

Floridan Aquifer withdrawals affect the Okefenokee Swamp, so how could TPM’s withdrawals not? 1995-04-11

Water withdrawals from the Floridan Aquifer affect water levels and quality in the Okefenokee Swamp, a pair of researchers concluded 24 years before Twin Pines Minerals of Alabama proposed to withdraw 2.4 4.32 million gallons per day from the Aquifer for a titanium mine within a few miles of the Swamp:

Abstract. A rapid response is observed between water level fluctuations in the Okefenokee Swamp and water levels in the underlying Floridan Aquifer. A lag of approximately one month is common, and a hydraulic diffusivity of 3.83 x 10-3 m2 s-1 best matches the calculated aquifer response to the swamp water level perturbations. The magnitude of leakage between the swamp and the aquifer is uncertain because of a lack of knowledge about the specific storage coefficient in the aquitard separating the swamp and the aquifer which has not been explicitly measured. An intermediate value of specific storage within the likely range of values results in a down- ward vertical flow of 1.2 meters of water per year. This induced recharge can significantly alter the natural water balance within the swamp. Such a large loss of water from the swamp may be responsible for observed pH and water level changes, and increased beavy metal accumulations in aquatic organisms in the swamp.

We cited that study[5] on page 4 of the Suwannee Riverkeeper comments to USACE about TPM, just after noting Twin Pines application to withdraw 4.32 million gallons per day (mgd) of Floridan Aquifer water much closer to the Swamp than any other permitted withdrawal. TPM’s own hydrology study in that withdrawal application shows a cone of depression in the Floridan Aquifer extending under the Swamp:

[Figure 8. Drawdown 2930 days]
Figure 8. Drawdown 2930 days

How could that not affect Swamp water levels and content?

As pointed out to the Corps by Okefenokee Swamp Park (OSP), any change to the water level in the Swamp would Continue reading →

Rights to Clean Water, Air, and Land

Update 2021-06-15: Right to Clean Water, and four more Florida ballot initiatives 2021-05-20.

Update 2021-02: New York State Environmental Rights Amendment for November 2021 ballot: “Each person shall have a right to clean air and water, and a healthful environment.”

See also the 1972 Montana precedent.

Update 2021-02-24: The regulatory trap at SRWMD: 30 speakers, yet unanimous Nestlé permit 2021-02-23.

Update 2021-01-31: Green Amendment Passes in the New York State Legislature.

Update 2021-01-22: Orange County, Florida (home of Orlando) passed a Bill of Rights for Nature, becoming the most populous local government area in the U.S. to do so; see below.

Does it seem most of the agencies, laws, and rules are rigged for big corporations and against local private property rights, against local fishing, swimming, boating, and hunting, and against organizations like Riverkeepers and Waterkeepers?

[Sabal Trail fracked methane pipeline, titanium mine too near Okefenokee Swamp, Suwannee River Basin]
Sabal Trail fracked methane pipeline, titanium mine too near Okefenokee Swamp, Suwannee River Basin.
See also WWALS map of all public landings in the Suwannee River Basin.

One approach to change that is a Bill of Rights for Nature (BOR), to change the legal structure so rivers, swamps, aquifers, lakes, etc. presumptively have rights that corporations have to prove they are not violating. There are at least three ways to do this: personhood for a waterbody, a Bill of Rights for Nature spelling out specific rights such as to exist and to flow unpolluted, or human rights to clean air and water, commonly known as a Green Amendment.

Examples

First, here are some examples of why rights of nature would be useful.

Example: a titanium strip mine proposed too near the Okefenokee Swamp

For example, Suwannee Riverkeeper is helping oppose a company that wants to mine titanium within three miles of the Okefenokee Swamp, which is the headwaters of the Suwannee and St. Mary’s Rivers, and above the Floridan Aquifer, from which all of south Georgia and north Florida drinks.

[Tribal Grounds west along GA 94 to TPM equipment, 12:38:38, 30.5257540, -82.0411100]
Tribal Grounds west along GA 94 to TPM equipment, 12:38:38.
Photo: John S. Quarterman for WWALS, on Southwings flight, pilot Allen Nodorft, 2019-10-05.

We shouldn’t have to get more than 20,000 60,000 comments sent to the U.S. Army Corps of Engineers pointing out that the Okefenokee National Wildlife Refuge contributes far more jobs (700+) and other economic benefits (more than $60 million/year) to the region and to Florida and Georgia than even the wildest promises of the miners (150-200 as in the application? 300? 350, as they told some reporters?), and the mine would risk all that, including boating, fishing, and birding in the Swamp and hunting around it. We should be able to point to the rights of the Swamp, Rivers, and Aquifer, and the miners should have to prove beyond a shadow a doubt that they would not violate them.

Update 2021-01-22: And then the Army Corps abdicated oversight in late 2020, leaving only the State of Georgia standing between the miners and Swamp with their five permit applications to the Georgia Department of Environmental Protection.

[Twin Pines Minerals mine land, maps, Cherokee of Georgia Tribal Grounds]
Twin Pines Minerals mine land, maps, Cherokee of Georgia Tribal Grounds, photographs by Southwings pilot Chris Carmel on a flight for Suwannee Riverkeeper, 2021-01-10.

You can help, by asking the Georgia Governor and other elected and appointed officials to reject or at least thoroughly review those permit applications.

Example: the Sabal Trail fracked methane pipeline

When the Georgia House of Representatives overwhelmingly refused to grant easements for the Sabal Trail fracked methane pipeline to drill under Georgia rivers, Continue reading →

Heavy equipment on TPM titanium mining site near Okefenokee Swamp 2019-10-05

Update 2019-10-10: Looking west from the Cherokee of Georgia Tribal Grounds along GA 94 past sawmill to equipment on mine site, with Okefenokee Swamp beyond. And a Bill of Rights for Nature.

[Tribal Grounds west along GA 94 to TPM equipment, 12:38:38, 30.5257540, -82.0411100]
Tribal Grounds west along GA 94 to TPM equipment, 12:38:38.
Photo: John S. Quarterman for WWALS, on Southwings flight, pilot Allen Nodorft, 2019-10-05.

This time it’s true: there is heavy equipment on site Twin Pines Minerals proposes for titanium mining near the Okefenokee Swamp, as of yesterday. It looks like dredging equipment similar to what we saw a few minutes earlier at the Chemours North Maxville Mine in Baker County, Florida. People more familiar with mining equipment, what do you think?

[Closeup: equipment]
Photo: John S. Quarterman for WWALS, on Southwings flight, pilot Allen Nodorft, Closeup: equipment, 12:41 PM, Saturday, October 5, 2019.

For context, this picture is looking east along GA 94 towards St. George: Continue reading →

Full page ad by titanium miners in Charlton County Herald 2019-09-25

Update 2019-11-07: This blog post published as an op-ed in the Charlton County Herald, October 9, 2019, as Convenience of private profit is no excuse to risk Okefenokee.

[Convenience of private profit is no excuse to risk Okefenokee --Suwannee Riverkeeper]
Convenience of private profit is no excuse to risk Okefenokee –Suwannee Riverkeeper

It’s the miners who are proposing to risk the Okefenokee Swamp for their private profit, so it’s their job to provide proof, despite what the Twin Pines full page ad in the Charlton County Herald says. Alex Kearns has already made this point for St. Marys Earthkeepers in a letter to the editor. You can comment on the newspaper’s website on that one, or you can send one, too, to: editor@charltonherald.com.

[CharltonCounty-Herald 25Sept2019-0001]
CharltonCounty-Herald 25Sept2019-0001
PDF

Yet in our Suwannee Riverkeeper comments to the Corps, we have provided quite a few studies that indicate the risk, including a Florida Consent Order against the same company for similar mines in Florida.

Where are these studies Twin Pines touts in the ad? They were not in Twin Pines’ mining application, as we and many others, including U.S. EPA and GA-EPD have pointed out. When will these miners’ studies be published?

The one Twin Pines hydrogeological study I have been able to find is in a different application that this miners’ ad doesn’t mention: for groundwater withdrawal and use. That study shows the 4.32 million gallons per day the miners’ want (more than twice all the current permitted water withdrawals in Charlton County) would lower the level of the Floridan Aquifer under the Swamp.

[Figure 8. Drawdown 2930 days]
Figure 8. Drawdown 2930 days

At the August 13, 2019 miners’ meeting in Folkston, GA, Steve Ingle claimed the mine would not affect the Floridan Aquifer, and the miners’ hydrologist Mark Tanner claimed there would be no cone of depression under the Swamp, both on video. This was two weeks after the same company had filed its withdrawal application with a hydrology report that clearly depicts a cone of depression extending under the Swamp. A report authored by the same two hydrologists who were at the August 13th meeting: Robert M. Holt and J. Mark Tanner.

The same miners’ hydrologists also repeatedly refused to guarantee there would be no effect on the Suwannee River, despite the ad’s claims of “100% certainty.”

Pretty much every other point in that ad is similarly easily rebuttable.

It’s curious they didn’t mention their biggest selling point: Continue reading →

TTM groundwater withdrawal and use permit application to GA-EPD 2019-07-24

At 4.32 million gallons per day (mgd) monthly average, Twin Pines proposes to withdraw more Floridan Aquifer water than almost anything in the surrounding six southeast Georgia counties: 4.32 times the City of Folkston, and almost four times the notorious Nestlé withdrawal request for Ginnie Springs on the Santa Fe River in Florida. You can still comment to the U.S. Army Corps of Engineers about the TPM mining application. Or to GA-EPD about this water withdrawal permit.

[4.32 mgd, 1.44 mgd from each of three wells]
4.32 mgd, 1.44 mgd from each of three wells

The only things bigger nearby are the City of St. Marys (6 mgd) and the Rayonier paper mill at Jesup (74 mgd).

For comparison, Kingsland 4, Waycross-Ware County Industrial Park 3.4, Waycross 3.16, Jesup 3, Kings Bay Submarine Base 2.9 + 1 for irrigation, Satilla Regional Water and Sewer Authority 2.2, Folkston 1.0. Even Chemours in Wayne County only wants 0.605 and Southern Ionics only 0.504 in Charlton County and another 0.504 in Pierce County.

All the permitted withdrawals in Charlton County add up to less than half what TPM wants for its titanium mine near the Okefenokee Swamp: 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 →

Deadline: today to comment to USACE against titanium mine near Okefenokee Swamp 2019-09-12

Please send your comments today to the Army Corps and GA-EPD against the proposed titanium mine far too near the Okefenokee Swamp, which is the headwaters of the Suwannee River.

How to Comment

Help Suwannee Riverkeeper save the Okefenokee Swamp
You can object to a titanium strip mine proposed far too near the Swamp.

Help Suwannee Riverkeeper Save the Okefenokee Swamp

GA-EPD had a public comment period open until March 20, 2023 on the Twin Pines Minerals Mining Land Use Plan.

You can still send a comment to the addreseses below, even though the comment period is over. You can comment from anywhere: not limited to Georgia.

Here is the Public Notice and the documents on which you need to comment.

You can email or paper mail your comments, or join one of two zoom webinars.

You can write to your Georgia state representative or senator or governor or lieutenant governor and ask them to refuse any such instrument.

Here's a convenient comment form by Georgia Water Coalition:
https://protectgeorgia.org/okefenokee/#/320/

Or to find your legislator you can type in your ZIP code here: http://openstates.org/find_your_legislator/

These are the Georgia state Senators with districts most involved with the Okefenokee Swamp:

  • GA Sen. Mike Hodges, District 3 District 003 Senator Mike Hodges (R-Brunswick), (404) 463-1309, (912) 464-1989, mike.hodges@senate.ga.gov (Charlton, Brantley, and east half of Ware Counties).
  • GA Sen. Russ Goodman, District 8 District 008, Senator Russ Goodman (R-Homerville), (404) 463-1318, 912-218-0447, russ.goodman@senate.ga.gov, rustingoodman@gmail.com, (Lowndes, Lanier, Echols, Clinch, Atkinson, and west half of Ware Counties).

These are the Georgia state Representatives with districts most involved:

  • John Corbett, House District 174 174, John Corbett, R - Lake Park, (404) 656-5105, john.corbett@house.ga.gov, Charlton, Brantley, south half of Ware, Clinch, Echols, east third of Lowndes Counties.
  • Steven Sainz, House District 180 180, Steven Sainz, R - Woodbine, (404) 657-1803, steven.sainz@house.ga.gov, Camden and part of Glynn Counties: no Suwannee River Basin Counties after recent redistricting.
  • James Burchett, House District 176 176, James Burchett, R - Waycross, 404-656-5105, Suite 1318, james.burchett@house.ga.gov, southwest Coffee, Atkinson, Lanier, and northeast Lowndes Counties
  • Dexter Sharper, House District 177 177, Dexter Sharper, D - Valdosta, 404.656.0126, dexter.sharper@house.ga.gov, Lowndes County

You can also write to your U.S. Representative or Senator and ask them to urge the Corps to take back up its oversight of the mine site. See former letter from former Rep. Al Lawson (FL-05).

For the requested Georgia state permit regarding Section 401 of the Clean Water Act, you can send a comment or request for public hearing to
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, Georgia 30334.
Be sure to mention Applicant: Twin Pines Minerals, LLC, Application Number: SAS-2018-00554.

For the Georgia Coastal Management Program certification, you can send a comment to
Federal Consistency Coordinator, Ecological Services Section, Coastal Resources Division,
Georgia Department of Natural Resources, One Conservation Way, Brunswick, Georgia 31523-9600
Telephone 912-264-7218.

You can also write to the Georgia DNR board, asking them to refuse any such instrument.
Georgia Board of Natural Resources
2 Martin Luther King Jr. Drive, SE, Suite 1252, Atlanta, GA 30334

To submit a letter to the editor of the Charlton County Herald, you can email editor@charltonherald.com.
Or write to your local newspaper.
You can also contact radio, TV, and of course post on social media.

More than 12,000 people have already commented. You can, too.

[Signs]
Photo: John S. Quarterman, before 2019-08-13 TPM meeting. L-r: Mark Lyons of Citizens Against Phosphate Mining, Alice Keyes of One Hundred Miles, Hilda Gilchrist of Our Santa Fe River (OSFR), Jim Tatum of OSFR and WWALS, Rena Peck Stricker of Georgia River Network, Mike Roth and Kristin Rubin of OSFR and WWALS, John S. Quarterman, Suwannee Riverkeeper, Merillee Malwitz-Jipson of OSFR and WWALS

Here’s why.

Julia Widmann, Waterkeeper Alliance, 23 August 2019, Suwannee Riverkeeper Fights to Protect Okefenokee Swamp from Titanium Strip Mine,

Twin Pines Minerals, LLC (TPM), an Alabama-based mining company, applied for permits from the U.S. Army Corps of Engineers and the Georgia Department of Environmental Protection to mine for titanium near the Okefenokee National Wildlife Refuge, which is the headwaters of the Suwannee and St. Marys Rivers in Southern Georgia. The Suwannee flows south through Florida to the Gulf of Mexico, and the St. Marys becomes the border between Georgia and Florida on its way to the Atlantic.

John was quoted in the first news story about the mine, by Emily Jones of Georgia Public Broadcasting on July 15, “The most obvious thing that we really need is a real environmental impact statement. All we have so far is, ‘this is what the applicant said.’”

Both Suwannee Riverkeeper and Southern Environmental Law Center have prepared comments which will go in went in today. If your organization wants to sign on, please contact me ASAP, at contact@suwanneeriverkeeper.org send in your own comments saying you support the Suwannee Riverkeeper comments.

Or you can just send in your own comments directly. Doesn’t have to be long. A sentence will do.

Much more about the proposed mine is here:
wwals.net/issues/titanium-mining/

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

You can join this fun and work by becoming a WWALS member today!