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Is EPD study on Laurel View flawed?
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On Wednesday, March 31, Jeff Larson of the Georgia Environmental Protection Division (EPD) held the second “stakeholders” meeting to discuss the progress, or lack thereof, of the EPD in accumulating and processing data to answer the questions about the potential for damage to the salt marsh should the wastewater treatment plant in Liberty County be allowed.
It has been over a year since the project was stopped by public resistance to it. The embarrassment of public disclosure of a very faulty Environmental Impact Study (EIS) along with a chorus of concerns being publicly voiced was enough to cause the EPD to re-visit the situation.
Shortly after the first well-attended public meeting, an attempt was made by the Coastal Estuary Protection Association (CEPA) to bring EPD personnel and scientists from the Skidaway Institute of Oceanography (SkIO) together. We felt this step would be welcomed by the EPD considering the fact that their performance seemed to indicate that they were not equipped to do a proper study.
Unfortunately it did not seem that the meeting with SkIO scientists was considered by EPD as a positive step but rather a hindrance. To be exact, after a lot of planning and scheduling and the graciousness of the SkIO folks in accepting the invitation to attend, the EPD scientist in charge of the project, Dr. Elizabeth Booth, by her own admission, attended the meeting via a cell phone from a swimming pool in Florida and had no idea who was even attending. As the process continued Dr. Booth demonstrated her disdain for the advice of the SkIO group at every turn.
In a recent memorandum from Dr. Booth, dated March 29, she referred to the tremendous public outcry demonstrated last year as simply “local interest.” Referring to the few hours spent on site which she passed as their collection of scientific data, Dr. Booth stated that “GA EPD staff conducted an “intensive field study.”
 The advice of learned scientists, who are published regarding this specific subject, was that because of the dynamics and complexities of the tidal system, the research required to accumulate sufficient data to process could take as long as a year. Dr. Booth managed to accomplish the task in a few hours!!!
Dr. Booth indicated in her memorandum that the field study had taken place during the periods of Sept. 15-18, 2009 to coincide with the highest tidal range that month “8.2-9.0 feet.” Obviously the highest tidal range would be the most favorable to prove dispersion. If they had remained for a couple more days, I believe that there was an occurrence of what is called a ‘SYZYGY’ on Sept. 22, 2009...when the conditions are perfect for an extremely high tide, around 11 feet. I personally steered a boat across the top of marsh grass that is normally two to three feet above the high water mark at high tide without touching the grass. It seems this would have an effect on the “dynamics of the tidal system”.
Then there is the rain factor. In 2008, through August, the coast experienced 9 inches of rain for the year. In 2009, through August, the coast had 27 inches of rain for the year. It seems this might have an effect on the “dynamics” as well. Obviously more than a “few hours” would be needed to accurately gather data.
The SkIO scientists stated that a “three dimensional” model was necessary to process such data. This statement was made because the previous defunct EIS indicated that a “two dimensional” model was used to process non-related data. Dr. Booth took opposition and proceeded to use a “one dimensional” model to process this latest data. I believe the model she used was provided to the State EPD by the Federal EPA. It is described as a model that an “inexperienced” person can use when modeling data involving river flow. “River flow” does not apply to coastal tidal waters. Our “rivers” are nothing more than indentations in the mud with no head water, no body, no mouth and water constantly changing its direction and speed. Without reference to the Liberty County situation, I asked the Federal EPA what model should be used when dealing with tidal waters. They were specific: “A three dimensional model is used and it extends out to sea”. By Dr. Booth’s own admission, she extended the Laurel View project “further out the river…almost to Sunbury”. Measuring tidal rage with yardsticks haphazardly nailed to dock pilings is comparable to a high school science project.
With the insufficient data and the wrong model in play, seventeen pages of memorandum from Dr. Booth were generated containing all sorts of impressive-looking pictures and data of questionable value. This is perhaps the forerunner to another useless, time consuming, computer-generated Environmental Impact Document (EID)?
The DNR Directory has thirty pages listing their department, divisions, etc. This reflects the tremendous task the DNR faces on a daily basis. It escapes me why the EPD, a division of DNR, would insist on going against every caution and persist in doing, what from every measure appears to be, the wrong thing. The actions of the EPD are expensive and wasteful. The law suits which will follow these actions will also be expensive. Unfortunately this seems to be the only way to stop EPDs perpetual motion in the wrong direction with the inadequate mapping of our tidal waters.

Hubbard and his wife Peach are active in environmental causes. They live in Richmond Hill.

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