Our Suwannee Riverkeeper Southwings flight of October 5, 2019, caused the U.S. Army Corps of Engineers to demand Twin Pines Minerals explain their equipment site on pain of civil or criminal penalties.
![[Dragline Yard Location Map]](https://www.wwals.net/pictures/2019-10-18--tpm-dragline-yard/2019.10.18-TPM-Response-to-Intend-to-Ltr-0003.jpg)
Dragline Yard Location Map
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The Corps’ Holly Ross wrote on October 9, 2019 (see also PDF): :
We received a tip that Twin Pines had started work on the project site. The WWALS has aerial imagery posted on their site of mining equipment staged. Continue reading
Mark Lyons, Charlton County Herald, January 14, 2020, Letter to the Editor: Response to City of Folkston, Development Authority,
Dear Editor,
I read with curiosity the Letter to the Editor from the City Council of Folkston and the Charlton County Development Commission giving their endorsement and support of the Twin Pines mining proposal. That letter raises so many questions. Where did these two boards obtain their scientific data that the mining would not affect the swamp and the environment? Much of the information offered in their letter appears to have been spoon fed to them directly from Twin Pines. There was no mention of where they obtained the scientific data that rendered such a strong endorsement that the mining will not harm the swamp or the environment. The letter did not mention any consultants or scientist who were hired by either of these two entities to inform them there wouldn’t be any environmental damage from the mining. How many scientist sit on the city board or the development council? Did the boards hire or consult any scientist at all? What was the name of the consulting firm either the city or the development board hired to supply them the scientific data that the mining would not harm the swamp and environment? Where did the boards get their scientific data that gave them proof the mining would not harm the swamp and environment? Please, I would ask you to share such valuable data with the public.
Photo: Wayne Morgan for WWALS of Chemours mines in north Florida, looking west across Bradford County, on Southwings flight for Suwannee Riverkeeper, pilot Allen Nodorft, 2019-10-05.How can anyone determine and say the mining will not affect the environment when Continue reading
“We reiterate our concern and position that an appropriate project review for 401 water quality certification is not yet possible since complete substantive and important information about the proposed hydrogeologic effects of this project relative to the surrounding landscape has not yet been submitted by the applicant. …So substantial, so massive, so transformative is the effect to wetlands contemplated at the Twin Pines site that you no longer have in place the original wetland to be impacted.” The Georgia Environmental Protection Division (GA-EPD) wrote that to the U.S. Army Corps of Engineers (USACE) in response to the thousands of pages of low-level data but only a few pages of analysis that Twin Pines Minerals (TPM) has sent those agencies.
Twin Pines Minerals is still failing to hoist its burden of proof that its propsosed titanium strip mine would not jeopardize this national treasure, the Okefenokee Swamp, the headwaters of the Suwannee and St. Marys Rivers.
![[Tribal Grounds west along GA 94 to TPM equipment, 12:38:38, 30.5257540, -82.0411100]](https://www.wwals.net/pictures/2019-10-05--equipment-tpm/triba-grounds-to-TPM-equipment.jpg)
Photo: John S. Quarterman for WWALS, of Tribal Grounds west along GA 94 to TPM equipment, 12:38:38, 30.5257540, -82.0411100, on Southwings flight, pilot Allen Nodorft, 2019-10-05.
See also
pictures from that flight by Wayne Morgan.
Maybe the City of Folkston and Charlton County Development Authority (CCDA) might want to rethink its assertion in the Charlton County Herald that “We would not support anything that would jeopardize this national treasure.” GA-EPD’s opinion is much like what U.S. EPA said, that the mine would have “substantial and unacceptable impact”.
CCDA wrote, Continue reading
In the Charlton County Herald, December 31, 2019:
Dear Editor,
The burden of proof is still on the miners to show their mine would not damage the Swamp or the Rivers, and they have not met that burden.
U.S. EPA still finds that “the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.”
![[Distant 2019-11-23]](https://www.wwals.net/pictures/2019-11-23--drone-tpm/74335863_496999617569694_628442505263710208_n.jpg)
Anonymous drone aerial of heavy equipment on the mining site 2019-11-23.
River Styx is in the background, Okefenokee Swamp is on the horizon.
St. Marys River flows out top left horizon. Suwannee River flows out far side of Swamp.
That’s about “the permit application submitted by Twin Pines Minerals, LLC” for a titanium strip mine. “The proposed 2,414-acre mine area lies in proximity to the Okefenokee National Wildlife Refuge (NWR), and the potential secondary effects of the mine on the NWR have not been demonstrated by the permit applicant.”
This is the second letter EPA has sent to the U.S. Army Corps of Engineers saying the mining application is deficient. We obtained a copy through a Freedom of Information Act (FOIA) request. The entire letter is here: https://wwals.net/?p=50931.
You, too, can still comment to the USACE, and all comments they receive before the Corps announces a decision can be used in any potential lawsuits. The addresses are: Continue reading
U.S. EPA still finds that “the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.”
That’s about “the permit application submitted by Twin Pines Minerals, LLC” for a titanium strip mine. “The proposed 2,414-acre mine area lies in proximity to the Okefenokee National Wildlife Refuge (NWR), and the potential secondary effects of the mine on the NWR have not been demonstrated by the permit applicant.”
You, too, can still comment to the USACE, and all comments they receive before the Corps announces a decision can be used in any potential lawsuits.
Thanks to the more than two dozen organizations, local, regional, statewide in Florida and Georgia, national, and international, that oppose the titanium mine that would be far too close to the Okefenokee Swamp. The Okefenokee National Wildlife Refuge (ONWR) provides boating, birding, fishing, and hunting nearby to the tune of more than $60 million a year and more than 700 jobs, making it the NWR of most economic benefit to each of Georgia and Florida. The Okefenokee Swamp is a unique ecological treasure, and is the headwaters of the Suwannee and St. Marys Rivers. The burden of proof is on the miners, and they have not met it.
![[Organizations For Okefenokee Swamp, Against Titanium Mine]](https://www.wwals.net/pictures/2019-07-12--tpm-usace/For-Okefenokee-Swamp-Against-Titanium-Mine-0001.jpg)
Organizations For Okefenokee Swamp, Against Titanium Mine
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Add your organization here: https://forms.gle/Dyqc77EBsjXBsz93A
You can still file a comment with the U.S. Army Corps of Engineers. If the Corps actually issues a permit, which they may in the next few weeks, anything filed can be used in any ensuing lawsuit.
Exactly how many organizations oppose that strip mine is hard to say, since Continue reading
Yesterday someone sent me drone pictures of the titanium mine site near the Okefenokee Swamp. They were taken from above GA 94, looking northwest.
You can still can comment against the proposed mine to the U.S. Army Corps of Engineers.
For comparison, here is an aerial Wayne Morgan took for WWALS on October 5, 2019, on a Southwings flight Continue reading
Waterkeepers Florida asks the Army Corps to require Twin Pines Minerals to supply all the information missing from its application for a titanium mine near the Okefenokee Swamp, to prepare a full Environmental Impact Statement (EIS), to hold Public Hearings, including in Florida, and “to answer how the Corps has or will determine that the Applicant’s proposed mine would not adversely affect the Okefenokee Swamp, the St. Marys River, the Suwannee River, the Floridan Aquifer, or the State of Florida.”
You can also still comment to the Army Corps.
![[TPM Equipment closeup, Wayne Morgan]](https://www.wwals.net/pictures/2019-10-05--equipment-tpm/WAM_0876.jpg)
TPM Equipment closeup Photo: Wayne Morgan for Suwannee Riverkeeper on Southwings flight, pilot Allen Nodorft, 2019-10-05.
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]](https://www.wwals.net/pictures/2019-09-12--epa-ga-epd-usace-tpm/SAS-2018-00554-Charlton-0917-SP-HAR-0005.jpg)
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
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]](https://www.wwals.net/pictures/2019-09-12--wwals-usace-tpm/SAS-2018-00554-Charlton-0912-SP-HAR-0001.jpg)
Public Notice: 20,338 comments
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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
![[the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.]](https://www.wwals.net/pictures/2019-10-03--epa-usace-tpm/SCAN0007-0001.jpg)
![[Closeup 2019-11-23]](https://www.wwals.net/pictures/2019-11-23--drone-tpm/78427724_559623768155531_3842015341974650880_n.jpg)