September 12, 2019
Ms. Holly Ross
U.S. Army Corps of Engineers
1104 North Westover Boulevard, Suite 9
Albany, Georgia, 31707
RE: Comment Letter, Georgia Wildlife Federation
Permit Application No. SAS-2018-00554
Twin Pines Site, Charlton County, Georgia
Dear Ms. Ross,
The Georgia Wildlife Federation submits this letter of comment to the U.S. Army Corps of Engineers (USACE) for Twin Pines Minerals, LLC heavy minerals, mine permit application number SAS-2018-00554, located on Trail Ridge in Charlton County, Georgia.
Georgia Wildlife Federation (GWF) is Georgia’s oldest member-supported statewide conservation organization, established in 1936. GWF provides leadership, services and advocacy on behalf of conservation issues across Georgia. GWF is a proponent for the professional, science-based management of our wildlife and natural resources. GWF was a commenter and activist organization in the previous initiative to mine titanium near the Okefenokee National Wildlife Refuge (ONWR). We were a party to the ultimate agreement that ended the previous mining attempt and we hold interest in the agreement associated with the cessation of that initiative.
The Okefenokee Swamp is, in human terms, a permanent component of Georgia’s landscape. Its designation as a wildlife refuge in 1937 has ensured its protected status has been a component of GWF’s history from our beginning. The Okefenokee Swamp’s subsequent recognition as a national and international treasure is a source of pride for Georgians. Many Georgians are concerned when potentially irreversible harm could ensue from activities such as the strip mining proposed so close to this place of beauty. ONWR, in its natural state, provides jobs and economic benefits in a community that needs both.
Given significant information/study gaps in the application submitted by Twin Pines Minerals, LLC, including a lack of their promised hydrologic studies, GWF recommends three broad points:
- Extension of the comment period by US Army Corps of Engineers for another 90 days from the date when Twin Pines Minerals, LLC provides the promised peer-reviewed hydrologic studies of their proposed mining operation, impacts on surface and groundwater quality and quality and impacts on protected species of both terrestrial and aquatic flora and fauna.
- Denial of the permit by US Army Corps of Engineers should those promised studies not be produced; or should there be insufficient opportunity for interested/affected parties to review, assess and comment on those studies in context of the overall permit application.
- Require a full Environmental Impact Statement (EIS), paid for by Twin Pines Minerals, LLC, due to the sensitive nature of the riverways, wetlands and groundwaters. The permit application doesn’t adequately address concerns regarding the overall hydrology of the sight as well as the potential impact on threatened and endangered species. Risks to this international treasure, a landscape that has played a unique role in all of human history and pre-history in the area, entail additional consideration for required assessment of impacts on social, cultural, and economic resources, as well as natural resources – as required by NEPA.
GWF’s comments are amplified below in much more detail. These comments were developed in concert with our partners at The Georgia Conservancy. The concerns and issues expressed in this letter center on three vital landscape features that are susceptible to project impacts:
- Okefenokee National Wildlife Refuge: One-third of the mining site drains to streams that discharge to the Okefenokee, one of Georgia’s most precious ecological sites and an internationally-recognized treasure. The Okefenokee’s 438,000-acre biodiverse ecosystem is home to the headwaters of two notable rivers, the Suwannee and the St. Marys, and contains nearly 353,981 acres of federally-designated wilderness. Stephen C. Foster State Park, located within the Okefenokee National Wildlife Refuge, was recently designated a Gold-tier International Dark Sky Park.
- Marys River: Much of the site drains to this southernmost river on Georgia’s coast. This river is a blackwater stream ecosystem home to several threatened and endangered species that could be impacted by changes in surface water brought by mining, including – but not limited to – alterations to the pH and turbidity.
- Trail Ridge: Trail Ridge plays a significant role in the hydrogeology of this area of Georgia; this saturated, low sand ridge is often described as a sill for the eastern side of the vast Okefenokee Swamp. Trail Ridge is also a critical element of Georgia’s State Wildlife Action Plan (SWAP), as it provides a vital ecological link northward from Florida to the Altamaha River.
The mining plan shows the stream and wetland impacts are aggressive and on a scale never before seen in this section of Georgia. On the project site, 1,201 acres of 2,414 acres are wetlands (Figure 4.1a). Impacts affect roughly half the site, including temporary impacts to 522 acres of wetlands and 2,454 linear feet of tributaries, and permanent impacts of 65 acres of wetlands and 4,658 linear feet of tributaries.
Georgia Wildlife Federation seeks to have the following issues addressed in the US Army Corps of Engineers wetland impact permitting (and forthcoming Georgia Environmental Protection Division’s Open Pit Mining Permit) process for this first phase of a proposed multi-stage mine.
Stream and Wetland Impacts: the permit application is for the first phase, comprising of 2,414 acres, on an overall tract of 12,000 acres. The applicant has made it clear that this permit area is part of a larger project. How will the cumulative effects of the mining in the remaining tract be included in the environmental assessment (EA) or environmental impact statement (EIS)?
The limited detail provided in the mining plan shows the draglines moving back and forth (east-west) in the active mining area, requiring reconstruction of impacted streams and wetlands. The permit application lacks the stream and wetlands reconstruction details which explain the means and methods employed for streams and wetlands reconstruction (biotic and abiotic). Will credits be purchased to offset the temporary impacts of reconstruction on the reclaimed land?
Groundwater Issues: GWF has concerns regarding the probable/possible impacts on-site and in the adjoining landscape. The application outlines a plan to excavate an average of 50 feet below the land surface, sort the material with a wet mill, and backfill in a 24-hour per day operation. The process exposes approximately 25-40 acres per month of ground.
The site has shallow groundwater with much of the area, having groundwater within two feet of the ground surface. It is vital to understand potential impacts of mining operations and soil homogenization on the water level of the Okefenokee. Changes in groundwater flow from mining operations, which lower the area water table, could also have an impact on the adjacent (Trail Ridge) isolated wetlands.
On page 559 of the US Army Corps of Engineers application, Twin Pines indicates a series of four reports are forthcoming. These reports provide critical information needed to analyze the merits of the project. Without this information available during the comment period we have limited ability to review two of the most critical aspects of the project; 1) the hydrogeology of the area and 2) the methodology and feasibility for stream and wetland construction after mining. The four anticipated reports focus on the following:
- “Pumping Tests Conducted in the Twin Pines Project Area” – The activities associated with and interpretation of two pumping tests conducted in the study area is the subject of this report.
- “Subsurface Hydrogeology of the Twin Pines Project Area, Trail Ridge, Georgia” –This report will summarize the regional geology and hydrology of the Trail Ridge area, document drilling efforts (including boring logs), identify subsurface hydrogeologic units, present cross-sections and subsurface maps of hydrogeologic units, define the potentiometric surface of the surficial aquifer system, and develop a conceptual hydrogeological model of the study area.
- “Hydraulic Properties of Subsurface Soils in the Twin Pines Project Area, Trail Ridge, Georgia” – Measured hydraulic and other properties of the subsurface soils are the subject of this report.
- “Groundwater Models of the Twin Pines Project Area, Trail Ridge, Georgia” – This report will document the groundwater models produced to evaluate the pre-mining conditions, the impact of mining activities on groundwater flow, and the post-mining groundwater conditions.
In the landscape scale and scope of the Twin Pines Minerals, LLC proposal, Georgia Wildlife Federation foresees habitat reduction and fragmentation on the unique Trail Ridge structure. GWF is concerned that the proposed mining operations along Trail Ridge may adversely impact wildlife habitat within and near the site. These potential impacts include:
- The cumulative loss of habitat for the gopher tortoise, a keystone species listed as threatened by the State of Georgia, along with other notable species that depend on the tortoise (Gopherus polyphemus), including the endangered eastern indigo snake (Drymarchon couperi) and gopher frog (Lithobates capito).
- Changes in fire frequency and intensity as a result of groundwater alternations. During the last ten years, there have been two major fires in the area of this site. Thus, there is significant concern related to fire management in and around the Okefenokee.
- Diminishing of water quality and quantity necessary to sustain fish populations in the St. Marys River. Both the Shortnose sturgeon (Acipenser brevirostrum) and Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus) are present in the St. Marys River. Sturgeon use freshwater rivers such as the St. Marys to spawn and as juvenile habitat. Under the Endangered Species Act, both species are “Endangered throughout its range.” The St. Marys River is designated a Critical Habitat for the Atlantic Sturgeon. The SWAP has also identified the St. Marys as a high priority watershed.
More than 600,000 visitors per year visit the Okefenokee National Wildlife Refuge and its surrounding State and local parks. The combination of noise, light, and other impacts for wildlife and visitors to the area from mining on this site is of significant concern. The Okefenokee is essential to the economy of Charlton and nearby counties. The citizens of the area should have a chance to learn more and discuss the impacts of this proposal.
Thank you for extending the comment period for this application. However, the application still lacks essential information from the applicant. The Okefenokee Swamp is a unique ecosystem, and Trail Ridge is an integral element. Given that nearby mining could impose significant impacts on this ecological treasure, Georgia Wildlife Federation respectfully requests the development of a full Environmental Impact Statement for cumulative impacts over the entire Twin Pines tract (12,000 acres).
President and CEO
Georgia Wildlife Federation