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Open letter on sewage plant plan
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This is an open letter to Allen Davis, president of the Coastal Estuary Protection Association, Inc.
Dear Allen,

It has been almost two years since we began our protest over the proposed construction of a waste water treatment plant designed to annually dump over one billion gallons of treated sewage directly into the upper reaches of the Medway River salt water estuary. There was first just a few of us that grew into a membership of now countless numbers of coastal residents under the banner of the newly formed and incorporated CEPA.
Our only request was that Georgia law be conformed to. We wanted a proper scientific study, conducted by competent personnel, to be conducted to determine the presence or absence of what we feel is the potential for severe and permanent damage to the salt marsh eco-system.
Even as this process goes forward there is legislation being introduced to prevent challenges to bad decisions by the EPD. This legislation is suspiciously timed along with the advent of the proposed plant in Liberty County.
From a political standpoint I am sure the pressure to continue with the Liberty County project regardless of its threat to the marshes is increased by the knowledge that the Liberty County Development Authority (LCDA) has already spent over $7 million of the Liberty County tax payer’s money on a project that did not have final approval from the EPD.

Aside from purely environmental concerns, there still remains the question of the need for such a plant in the first place. There still remains the question of the continuously evolving position of the promoters of the plant as to how they intend to disperse the 3.2 MGD of treated waste water as objections are raised.
There is the statement that they intend to use spray field application when there does not appear to be a location for spray fields. There is the statement that they intend to reuse large portions of the water when all indications are that there is no place to reuse it. As I understand it, their claim that the reuse water will go to firefighting has been rejected by the firefighters. Even were they to agree to such a usage, the area is rural. The plant would have to be downtown NYC to have enough fires to utilize the effluent at the rate the plant is designed to produce it. All of these arguments are obviously based on their realization that dumping 3.2 million gallons per day of treated sewage into the marsh is not a good idea. If the proponents of the plant do not think such a discharge is potentially hazardous then why do they argue for alternate solutions, particularly ones that do not appear to exist.
The EPD, for whatever reason, has apparently chosen to ignore the very best advice from the most reliable scientific sources. They continue on their path of using inadequate data and improper modeling techniques.
I fully expect that an announcement will be made at the second so called “stakeholder’s" meeting that the EPD fully intends to grant the permit. I am referring to the meeting scheduled for March 31 at 1 p.m. at the Savannah office of the EPD, Jeff Larson presiding. If there is not full permission given to proceed with the project then enough leeway will be given for the project to go forward under “further consideration.” It is my opinion that this second “stakeholder’s” meeting is an end run to avoid further public outcry against such a blind venture.
The results of the so called study conducted by the EPD on the upper reaches of the Medway should be discussed in a public forum with full participation by SkIO scientists. The only decision that can be made now is to actually do an environmental impact study that has merit. Perhaps the argument revolving around EPD methods should be brought to the floor of the Georgia Legislature so that lawmakers can have the facts and the benefit of third party professional expert testimony.
Skidaway Institute of Oceanography (SkIO) scientists suggested that the study could take a year or more of intensive work for accumulation of scientific data. The time involved is necessary to accommodate the complexity and ever changing dynamics of a tidal system. These scientists speak from decades of hands on experience with the very same subject matter and questions involved in this situation. They are world renowned and published in their knowledge of the process to find the answers, the right answers. The EPD claims to have accomplished this task in a matter of hours on the water!
The SkIO group, and also Federal EPA scientists, have stated unequivocally that a three dimensional model must be used to process data involving tidal waters.
EPD chose to use a one dimensional model. This model was provided to them by the EPA for use on single directional flow rivers. The description of this model provided by its designers was that it was designed so that an "inexperienced person” could use it! Is this the respect we give our very vital and very sensitive salt marsh estuaries?!
We cannot expect the scientists from SkIO to fight the political pressure behind the EPD decision. They have already given us their best advice and it has been categorically ignored. I will be surprised and grateful if they again donate their valuable time to the second stakeholders meeting when they have been systematically ignored at every turn of events.
CEPA and the residents of the coast have not had the question that was the basis for our original argument answered. No proper analysis has been done where the LCDA plant is involved. The data to be presented at the so called “stakeholders meeting" is totally inadequate in depth and volume. If the EPD announces its intent to issue the permit to build the Liberty County Plant based on their actions since the last public meeting, it is my opinion that the residents of coastal Georgia and essentially the residents of the entire State of Georgia have become victims of unsurpassed political elitism. It must not be allowed. Where is our voice?

Roy Hubbard

Hubbard is a member of CEPA and has long been pushing for a more thorough study of the plant's potential impact on the Georgia coast. 

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