Dear Editor:
The Okefenokee Swamp is listed as one of the Seven Natural Wonders of Georgia and is the largest blackwater swamp in North America.
Most of it is under federal protection within the boundaries of the Okefenokee Wildlife Refuge and the Okefenokee Wilderness. It is the largest National Wildlife Refuge east of the Mississippi River and was designated a Wetland of International Importance by the Wetlands Convention in 1986.
The Okefenokee Swamp is also the headwaters of the St.
Mary’s River and the Suwanee River. Given the unique value and vulnerabilities of the Refuge’s complex ecosystem and living resources, any potentially damaging activities in the vicinity are of dubious justification, and the standards for properly evaluating and enforcing needed precautionary protection measures are so rigorous under these circumstances that the costs would far exceed any benefit of the project.
-The hydrology at the proposed project site is complex and sensitive to alterations that may disrupt and/or degrade the Okefenokee National Wildlife Refuge (ONWR).
Although the applicant has alleged a mining methodology that restores the soil substrate, the proposed technique is unproven. Given the importance of protecting the unique conservation and recreational benefits of the ONWR, we believe it is extremely important to thoroughly evaluate the proposal, to include an EIS review that serves the public interest.
-The escalating disruptive effects of climate change in the area could produce extreme drought, extreme precipitation, or both, which further complicate the ability to confidently predict and assess the hydrological risks of mining at the site and how to control them. Thus risks of adverse outcomes are not only great, they are increasing.
-Subsurface conditions altered by the proposed mining operations could significantly alter water flow and water quality entering the ONWR.
Even subtle modifications that appear to be marginal could produce significant and unacceptable cumulative, long-term environmental consequences. It is possible that such impacts would not be perceived or measurable until after significant damage becomes irreversible.
-Our concerns are further justified by the uncertain, unreliable, and untested procedures for monitoring and assessing on-site impacts of the project, which – if the project proceeds – would be crucial to preventing unacceptable disruption and degradation of the hydrology essential to the ONWR’s functions and ecosystem stability.
-Initially proposed location of facilities for equipment storage and refueling indicate the applicant’s poor understanding of environmental risks and how to control them, given the site’s topography in relation to the ONWR. It’s our understanding that such planning decisions by the applicant suggest avoidable and rudimentary site contamination hazards. These planning deficiencies also strongly substantiate apprehensions that justify the preparation of a thorough, well-researched EIS.
-According to the U.S. Fish and Wildlife Service, Trail Ridge is part of a recovery unit for the federally threatened eastern indigo snake (Drymarchon couperi) and “[e] liminating a significant area of habitat from a recovery unit may eliminate the value of the entire unit, and delay species recovery.” A thorough survey of the presence of this species as well as the gopher tortoise (Gopherus polyphemus), recently delisted as endangered but a keystone species, is warranted since it is possible that these species’ habitat will be permanently altered by the disruption caused by surface mining.
Former Secretary of the Interior, Bruce Babbit, who opposed an earlier proposal to strip mine on another Trail Ridge tract abutting the ONWR, summed up our position aptly when he said, “Titanium is a common mineral, while the Okefenokee is a very uncommon swamp.” This project has a large footprint which could be multiplied many times by subsequent projects along the Trail Ridge formation.
Additional authoritative objections to the project include:
• U.S. Interior Secretary Deb Haaland urged the state not to approve the mine last year after visiting it with Senator Ossoff.
• The U.S. Fish and Wildlife Service [USFWS] — which protects and manages the swamp — has said the proposal would have “major negative impacts” to the Okefenokee.
• In his comments, Senator Ossoff cited USFWS and a report by University of Georgia hydrologist, Rhett Jackson, who said the mining plan “fails to address key environmental issues.”
• Our own board member, Dr. Jim Reichard, a respected veteran Geo-Hydrologist on the faculty of Georgia Southern University, advises us that, “ Replacing this complex layered deposit [at Trail Ridge] with homogenized waste material from the mining operation is expected to cause an increase in permeability across Trail Ridge, permanently lowering the water table in the Okefenokee. This will drastically alter the swamp’s delicate ecosystem and also make it more prone to drought and wildfires.
Risking such a national treasure for a small, short-term economic gain hardly seems like a wise choice.”
It would be a grave error to set or prolong a precedent of permitting surface mining at such a uniquely complex, vulnerable and valuable location. To protect the ONWR and honor the public interest that EPD is legally obligated to uphold, this proposed mining activity should be denied.
David Kyler, Center for a Sustainable Coast, St. Simons, Georgia
Editor’s Note: The following letter was submitted last year to the Environmental Protection Division of Georgia DNR on behalf of the Center for a Sustainable Coast by the Center’s co-founder and director, David Kyler. The final Twin Pines permit is now under review, and the deadline for submitting comments to EPD is April 9, 2024.