We thanked the Atkinson County Commission for this letter, and later got a copy of it. The letter probably helped with GA-EPD deciding to redesignate Recreational an upper segment of the Alapaha River Water Trail, one containing Willacoochee Landing in Atkinson County. More redesignations are possible later. There’s a GA-EPD Update Meeting next week.
![[Letter, Commission, Willacoochee Landing]](https://www.wwals.net/pictures/2021-06-23--atkinson-county-epd-recreational/many.jpg)
Letter, Commission, Willacoochee Landing
There are a couple of new things in what I sent on the deadline day, yesterday. (PDF)
For what this is all about, see Calling for pictures of swimming, diving, rapids, tubing, water skiing, or surfing, Suwannee River Basin, Georgia.
June 30, 2021
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
Re: Georgia Triennial Review of Water Quality Standards
Dear Ms. Booth,
Once again I would like to commend you and all the GA-EPD staff for your diligence in this Triennial Review process. I thank you for your consideration of the request by WWALS Watershed Coalition, Inc. (WWALS) to upgrade GA EPD’s designated use of the Little, Withlacoochee, Alapaha, and Suwannee Rivers, as well as Grand Bay WMA, Banks Lake NWR, and the Okefenokee NWR, from Fishing to Recreational, to set higher water quality standards for these bodies of water.
In the interests of saving you and me time, I will try to merely summarize the arguments I have already made, while adding some material you may not have previously seen.
As you know WWALS would prefer that redesignation applied uniformly, year-round. As you mentioned in the recent EPD zoom meeting on this subject, perhaps one reason Florida has all its rivers as Recreational by default is its climate. South Georgia, like north Florida (and unlike north Georgia) has a subtropical climate in which we are not surprised by 80-degree weather in January. People swim, dive, fish, and boat on our rivers year-round. Some people even prefer to be on and in the water in the winter because there are fewer insects. I have recently been reminded that local churches also use them for immersion baptisms, which can happen in any season of the year.
Per request of EPD, please find attached a Recreational Data
Spreadsheet, which is also online here:
https://drive.google.com/file/d/1g9gLcNnbRx4H9djZAlKd1ZaB7zrlmDbz/view?usp=sharing
In that spreadsheet are examples of swimming and diving locations, including almost every boat ramp or landing, plus selected sandbars, beaches, and springs. Also included are a few examples of rapids. None of them are Class III, but at least two are Class II+, and as Gwyneth Moody pointed out on the recent zoom, people frequently capsize in those.
Included for every location in that spreadsheet is a link to further information, mostly to one of our three river trails (“blue trails”):
Continue reading
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:
https://wwals.net/pictures/2021-02-02–ga-epd-triennial-review
You can help:
https://wwals.net/?p=50127#help
![[Second-class Recreational, maps, wastewater]](https://www.wwals.net/pictures/2021-02-02--ga-epd-triennial-review/many.jpg)
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.
Here is the slide defining second-class Recreational for boating: Continue reading
Update 2020-01-25: Florida advisory lifted, but WWALS warning signs stay up, and keep testing rivers, creeks and wells.
Okapilco Creek is down from 2419.6 cfu/100 mL E. coli last Thursday to 365 yesterday, Wednesday, January 22, 2020, according to data from Lowndes County received during the Florida Rivers Task Force meeting in Lake City.
![[Okapilco Creek in Brooks County]](https://www.wwals.net/pictures/2020-01-18--fdoh-lowndes-wwals-wq/okapilco-brooks.jpg)
Okapilco Creek in Brooks County in
Brooks County Tax Appraiser map.
That’s still higher than we’d like to see, but not way up in don’t touch the water range like before.
![[Lowndes County 2020-01-22]](https://www.wwals.net/pictures/2020-01-18--fdoh-lowndes-wwals-wq/2020-01-22--lowndes-county-data.jpg)
Lowndes County 2020-01-22
Thanks to Lowndes County Chairman Bill Slaughter for sending these results,
which are
on the WWALS website
along with the entire
entire updated WWALS composite spreadsheet
of all results from all sources.
Where did that contamination go? Did it show up on Continue reading
2019-12-28: High E. coli at state line in Florida DOH water quality data 2019-12-24.
At Nankin Thursday: 533 cfu/100 mL E. coli, well above the state limit of 200, and up from 33 on December 15, and zero on December 11 and 8 and November 23.
Florida already saw elevated bacterial counts at the state line on Tuesday, so the Withlacoochee River is apparently contaminated with Valdosta sewage all the way from Sugar Creek down to the Florida line. Yet Valdosta still hasn’t put up any warning signs on the Withlacoochee River downstream from Sugar Creek.
That December 26th reading by Suzy Hall at Nankin Boat Ramp isn’t as high as her recent numbers at Knights Ferry: 6,767 on December 24 and 4,966 on December 21st (with 100 on December 15th and zero on December 11th). Nonetheless, it looks like Valdosta’s sewage has spread downstream from Knights Ferry to Nankin.
At 533 cfu/100 ml, you probably don’t want to get that river water on you. Georgia standards indicate Continue reading
Florida provides Get Out of Jail Free cards for fertilizer, sewage, and manure (FSM), wrote Waterkeepers Florida in this letter sent Friday to the Florida Department of Environmental Protection (FDEP) in its Triennial Review of Water Quality Standards:
If actual substantial harm is eventually found, the only result is a planning processes that lead to Basin Management Action Plans (BMAPs). BMAPs are largely collaborations of the operators of FSM pollution sources, and the only consequence of the failure of the plan to actually curb FSM pollution is a requirement to report the failure. Where BMAPs were hoped to be practical mechanisms to reduce FSM pollution, they have in fact functioned as a “Get Out of Jail Free” card for agriculture industries and other sources of as FSM pollution, while our waters continue to be degraded. The FSM rules have been implemented over the past seven years, during which time, widespread massive algae outbreaks have taken place on the St. Johns River, and in other rivers and lakes throughout Florida.
![[Turbidity Criteria]](https://www.wwals.net/pictures/2019-11-22--wkfl-triennial-review-comments/WKFL-Final-Triennial-Review-Comments-0001.jpg)
Much of this letter from most of the members of Waterkeepers Florida, including Suwannee Riverkeeper, is about cyanotoxins, which fortunately we do not yet have in the Suwannee River Basin, and coral reefs, which are a southern Florida regional matter. Yet every regional matter affects the whole state of Florida, the southeast, the nation, and the world. For example, about II. Routes of Ingestion:
This calculation only takes ingestion while swimming into account. Exposure to cyanotoxins can also occur dermally and through inhalation of aerosolized particles. These routes are not taken into consideration, as EPA states, because adequate effects data are not available. The relative source contribution that was a part of the 2016 recommendations has been removed, to focus on the ingestion.
Plus people all over Florida and beyond eat fish caught in the red tide areas: how much exposure to ingested cyanotoxins do we all have?
Recently I was asked if there would be water monitoring costs to cities or counties because of upgrading our main Suwannee River Basin waters in Georgia from Fishing to Recreational, as we have requested in Georgia’s Triennial Review of Water Quality Standards. Here’s the answer, as best I could determine. And how you can help. For those who wonder why upgrade from Fishing to Recreational, please see the previous blog post.
![[Satellite Map]](https://www.wwals.net/pictures/2019-04-21--wwals-suw-basin-landings/basin-ga-sat.jpg)
WWALS Satellite Map of landing in the Suwannee River Basin in Georgia
Specifically the question was: would reclassifying rivers or swamp from Fishing to Recreational cause cities or counties to have to spend more money on water quality monitoring, specifically if a wastewater treatment plant had a spill, more money on water quality sampling afterwards?
The brief answer is: probably not.
Recently, I asked James A. Capp, Chief, Watershed Protection Branch, EPD. He said that for that case, there should be no change, because sampling after a spill is determined mostly by the number of gallons spilled.
Let me use some NPDES permits I have on hand to illustrate.
Here is the language in NPDES Permit No. GA0020222 for Valdosta’s Withlacoochee Wastewater Treatment Plant, first about number of gallons, then about the required sampling. Continue reading
Dear FDEP, please raise no pollutant limits, do more water quality monitoring, and publish all testing results in days, not months.
Continue readingWaterkeepers Florida yesterday voted to send a letter to FDEP about cyanobacteria as comment in the Triennial Review of Florida Water Quality Standards.
![[The cyanobacteria problem in Florida]](https://www.wwals.net/pictures/2019-05-31--wkfl-triennial-review/WKFL-Triennial-Review-Comments-re-Cyanotoxins-0001.jpg)
The cyanobacteria problem in Florida
You may recall Continue reading
Update 2021-02-09: Redesignating waterways as Recreational –GA-EPD Triennial Review Meeting 2021-02-02.
We asked the state of Georgia to upgrade our main Suwannee River Basin rivers (and some lakes and swamps) from their current lowest water quality classification as Fishing to what they really are: Recreational Use. You can help!
![[Georgia landings in Suwannee River Basin]](https://www.wwals.net/pictures/2019-03-03--wwals-suw-basin-landings-ga/all-ga-landings-suw-river-basin.jpg)
Every three years, federal law requires each state to review its water quality standards. 2019 is such a year for Georgia, so the Georgia Environmental Protection Division (GA-EPD) is conducting a Triennial Review. The request WWALS sent to GA-EPD, background, and their response are all on the WWALS website. Our request was rather long, with 23 pages asking for reclassification of the Suwannee River, the Okefenokee Swamp, the Alapaha River, Lake Irma, Banks Lake, Grand Bay, the Withlacoochee River, the Little River, and Reed Bingham State Park Lake, all from Fishing to Recreational Use. The WWALS cover letter is included at the end of this blog post. For the rest, see the WWALS website.
The response thus far from GA-EPD has some good news: Continue reading
![[Rivers, Letter]](https://www.wwals.net/pictures/2021-06-30--recreational/many.jpg)
![[Across]](https://www.wwals.net/pictures/2019-12-26--nankin-wq/20191226_163637_resized.jpg)
![[More water quality monitoring]](https://www.wwals.net/pictures/2019-05-31--wwals-fdep-triennial-review/2019-05-30--WWALS-FDEP-Triennial-Review-0001.jpg)