Text of Feb. 3 letter by Bryan County Commissioners to the EPD
Dear Dr. Couch:
The Bryan County Board of Commissioners has followed the LCDA'S request for an NPDES permit very closely. Concern has been expressed by residents of Bryan County that no formal notification took place in our county. The proposed release of 3MGD of treated affluent into a salt water river and estuary seemed radical to our residents and since their properties were part of the estuary; they obviously felt as though formal notice should have taken place for them too. Many of our residents think that other alternatives are available but those alternatives were put aside for an easier way out (release in the river vs. reuse or site holding ponds).
Although some data presented by CH2MHILL via the EID (Environmental Information Document), indicates little or no change to the river or estuary, their recommendation seems to be based on limited background research/data. In addition, the EID is developed by a firm designing and building the facility. It seems that an independent, arms length firm should be required to make such an assessment - a firm that will not stand to lose money, if a negative assessment is made.
Representatives from Bryan County met with EPD staff members several days prior to the meeting on January 27th. They suggested that scientific data and analysis be presented by EPD that would justify the NPDES permit, if they recommendation for approval seemed imminent. Although some limited data was presented, it did not seem overwhelming to the point of justifying the release of treated affluent into a salt water river or estuary. The format of the meeting might also be changed. We suggest that the permit seeker present their data; the EPD present their data and analysis, then conduct break out sessions for questions and answers. This process would allow people to gather information and formulate potentially better questions for your staff.
Capsulizing the data present in this letter: 1.) Independent analysis, either by EPD or an arms length firm should be required; someone with no vested interest. 2.) Sound science and the preservation of the rivers and estuaries should be the main concern, what works in middle and upper Georgia does not necessarily work in the coastal region of Georgia. 3.) Technology is great and we should treat affluent to the highest standards possible, but treated affluent should be disposed of in a method that will preclude the withdrawal of additional waters from the aquifer, a release into the river is not reuse. 4.) Notification process should include an adjacent county when disposal takes place on or near the boundary. 5) Request EPD extend the review period an additional thirty (30) days.
EPD is or should be Georgia’s environmental experts; your department should work diligently with Georgia’s residents to protect and defend what brings people to our state. We support your efforts to make Georgia a better place to live and with just a few changes in the permitting process, Georgians will feels as though they are an integral part of the process. Please consider this letter to be a comment from the Bryan County Board of Commissioners to be included in the official records to this NPDES permit request. We ask that the EPD respond to this comment pursuant to 40 CFR 124.17, and value all other relevant rules and policies.
During Tuesday's meeting, Bryan County Commissioners unanimously agreed to send a written complaint to the Environmental Protection Department regarding the proposed plant. The letter, written on commission letterhead and signed by Chairman Jimmy Burnsed, was faxed to the EPD minutes before the deadline for written comment.
The letter is requesting the EPD extend the review period another 30 days and is also asking for an independent scientific analysis of the plant's impact on the saltwater marsh.
Burnsed said they were essentially telling the EPD fresh water shouldn't be released into the Laurel River. He also said the letter was "being done at the request of Bryan County residents, but we can all agree it's something that is needed."
The two-page letter requested "independent analysis" of the fresh water impact by someone without a "vested interest" in the outcome, and that sound science and the preservation of the rivers be the main concerns. It also stated Bryan County residents with property on the river should have been notified about the plant in the beginning.
Carmen Cole, Director of Administration and Finance for the LCDA, said she is "disappointed that Bryan County has taken that approach. We feel comfortable with the studies that have already been conducted that show there will be no impact on the environment."
Cole said she understands where the Bryan County Commission is coming from, but the EPD has validated the authority's opinion that the proposed facility will not negatively affect the environment.
David Bullard with the Atlanta EPD office said he has yet to see the letter, but all of the letters and public hearing comments will be reviewed and considered. He estimated that the EPD may render a decision as early as two weeks from now, but no timetable has been set.
Bullard said about a dozen letters have come in to the EPD since the public hearing. Prior to the hearing, over 200 letters were received from residents voicing their opinion on the project. Written comments in consideration of whether or not to issue the permit were accepted up until Feb. 3.
"We're going to take some time and look at this closely," Scott Southwick with the Savannah office of the EPD said about all the comments received concerning this pending permit. "I was at the public hearing, and we all thought there were a lot of really good comments worth considering. We're not going to rush into anything without exploring the facts here."
Richmond Hill environmentalist and Coastal Estuary Protection Association member Roy Hubbard said he commends the Bryan County Commission for standing up for their community and the opinions of its people.
"The Bryan County Commission looked at the facts and took a cautious and careful approach to a very complicated issue, and they should be applauded for that," Hubbard said. "It's a very defined position and that's what we need right now. We need all the politicians representing this coastline and even at the state level to take a defined position with this issue."
Hubbard said he is hopeful this letter will have an impact on the EPD's rendering, but he is fearful that the EPD has already made up its mind to issue the permit.
-- BCN staff writer Gina Sutherland contributed to this article.