U.S. EPA still finds Twin Pines mine will have a substantial and unacceptable impact 2019-10-03

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.

[the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.]
the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.

The previous letter from EPA to USACE, of Sep 12 2019, was signed by “Director, Water Division” with the name redacted. Looking up online who that is, I called EPA Water Division Director Jeaneanne Gettle, who told me a second letter had gone out, but it did not say much beyond the first letter. Finally received after a FOIA request, here is the second letter, and indeed it just reiterates the first letter, because: “To date, the EPA has received no additional information from the Corps to address these concerns.”

WWALS maintains that the U.S. Army Corps of Engineers should reject the application, or, at the very least, require an Environmental Impact Statement (EIS) broad enough to cover the entire swamp and all the related mines in Georgia and Florida.

The EPA letter

Scans of the letter and the FOIA response cover letter are on the LAKE website, as well as a composite PDF of this letter.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
FORSYTH STREET
ATLANTA, GEORGIA 30303-8960

OCT – 3 2019

Colonel Daniel H. Hibner, District Engineer
ATTN: Ms. Holly Ross
U.S. Army Corps of Engincers
Savannah District
100 W. Oglethorpe Avenue
Savannah, Georgia 31401-3640

Subject: SAS-2018-00554, Twin Pines Minerals, LLC heavy mineral sands mine in Charlton County, Georgia

Dear Colonel Hibner:

This letter is in reference to Public Notice (PN) SAS-2018-00554, for the permit application submitted by Twin Pines Minerals, LLC to directly impact 587 acres of wetlands and 7,112 linear feet of streams during the mining of heavy mineral sands in southern Charlton County, Georgia, 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. The US. Environmental Protection Agency sent the Savannah District of the U.S. Army Corps of Engineers (Corps) a letter regarding this PN on September 12, 2019, identifying concerns with respect to compliance with the Clean Water Act Section 404(b)(1) Guidelines set forth at 40 CFR Part 230. The letter outlined the EPA’s concerns and recommendations about the project’s potential impacts on freshwater wetlands located in the project area and potential secondary impacts to the adjacent Okefenokee NWR (sce enclosed letter).

To date, the EPA has received no additional information from the Corps to address these concerns. Based on the limited information made available, pursuant to Part IV, paragraph (3)(b) of the 1992 Clean Water Act Section 404(q) Memorandum of Agreement between the EPA and the Department of the Army, the EPA finds that the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.

The EPA appreciates the opportunity to comment on this proposed project and looks forward to working collaboratively to address identified concerns. Should you have any questions, please do not hesitate to contact me or have one of your technical staff contact Mr. Eric Somerville of my staff at (706) 355-8514 or somerville.eric@epa.gov. Thank you for the opportunity to review this project.

Sincerely,
[signed]
Mary S. Walker
Regional Administrator

Enclosure

cc: Mr. Mark Williams, Georgia Department of Natural Resources
Dr. Donald Imm, U.S. Fish and Wildlife Service

Far more information on this bad titanium mine application is here:
wwals.net/issues/titanium-mining/

How to Comment

The current comment deadline is Tuesday, April 14, 2020, according to the Public Notice of March 13, 2020.

That thirty day deadline is grossly inadequate, especially considering that everyone is advised to stay home for eight weeks or 56 days because of the novel Coronavirus (COVID-19). Plus the entire Twin Pines Minerals (TPM) application is hundreds of pages, and nobody can adequately absorb and analyze all that in thirty days.

While you are at home, you have a great opportunity to write a comment, and to write to your elected officials. You can also post your comments on social media, as op-eds, etc.

In your comment, perhaps you would like to ask for a deadline extension of 120 days, and a public hearing.

You can ask the Corps and other elected and appointed officials to deny the application, or to require an Environmental Impact Statement (EIS) to consider wider areas the mine may affect, especially the entire Okefenokee Swamp, the Suwannee and St Marys Rivers, and the rest of Trail Ridge in Georgia. You can ask for the EIS to include other mines relevant to this one, especially the four Chemours titanium strip mines in north Florida for which TPM, along with Chemours, is under a Florida Consent Order for a range of violations. You may want to ask for inclusion of the existing phosphate mine in Hamilton County, Florida, next to the Suwannee River, as well as the one proposed in Union and Bradford Counties, Florida, next to the New and Santa Fe Rivers, tributaries of the Suwannee. All those mines affect the Floridan Aquifer, which is the main source of water for drinking, agriculture, and industry for everyone in south Georgia and north Florida.

To comment, or to request a public hearing, you can write to
Commander, U.S. Army Corps of Engineers, Savannah District,
Attention: Ms. Holly Ross, 1104 North Westover Boulevard, Suite 9, Albany, Georgia, 31707,
or by email to CESAS-SpecialProjects@usace.army.mil or holly.a.ross@usace.army.mil.
In your comments please refer to:
Applicant: Twin Pines Minerals, LLC, Application Number: SAS-2018-00554.

For the requested 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.

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.

The public announcement says: “The applicant may also require assent from the State of Georgia, which may be in the form of a license, easement, lease, permit, or other appropriate instrument.”

You can write to your Georgia state representative or senator or governor or lieutenant governor and ask them to refuse any such instrument.
To find your legislator you can type in your ZIP code here: http://openstates.org/find_your_legislator/
You can also write to your U.S. Representative or Senator and ask them to urge the Corps to reject this mine or at least require an EIS, like Rep. Al Lawson (FL-05) already did.

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.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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

1 thought on “U.S. EPA still finds Twin Pines mine will have a substantial and unacceptable impact 2019-10-03

  1. Michael Moody

    There is no way this project can ignore the geology and the ground water that is the ‘key’ to the NWR existence. There are NO streams or watershed feeding the swamp.

    There are some places that just need to be left alone. The similar project in North Florida mining the ancient dunes are a great example of what can go wrong and will go wrong.

    Don’t waste anyone time trying to justify the need for this business over the future of a national and natural
    treasure.

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