Comments Opposing Draft Permits for Twin Pines Mine

Left photo shows Fall Stopover Hotspots for Bird Migration in relation to proposed Twin Pines Mine (in yellow); Right photo shows Spring Stopover Hotspots.

Via Electronic Mail
 
Director Jeff Cown
Georgia Department of Natural Resources
Environmental Protection Division
2 Martin Luther King Jr. Drive SE
Suite 1456, East Tower
Atlanta, GA 30334
[email protected]
 
Re:      Comments Opposing Draft Permits for Twin Pines Mine
                                                                                                         
Dear Director Cown:

On behalf of Birds Georgia members across the state, we are writing today to ask you to protect the Okefenokee National Wildlife Refuge and the St. Marys River by denying Twin Pines Minerals’ (TPM) application to strip mine for heavy mineral sands at the doorstep of the Okefenokee Swamp.
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Birds Georgia’s mission is to build places where birds and people thrive. We fulfill our mission through education, conservation, and community engagement. With more than 2,500 members and more than 5,000 National Audubon Society members from across the state, Birds Georgia represents a broad constituency united by a desire to protect birds and other wildlife. Our constituents include Georgia residents, frequent visitors, and concerned citizens who understand both the significance and beauty of the Okefenokee Swamp for birds and other wildlife.

At 438,000 acres, the Okefenokee Swamp is one of the most wild, pristine, and ecologically intact places in America, sheltering more than one thousand animal and plant species within its vast labyrinth of cypress forests, pine islands, and blackwater channels. In addition to providing refuge to wildlife, the Okefenokee offers an escape to hundreds of thousands of people who fish, hunt, paddle, birdwatch, and camp in its wilderness each year. As the U.S. Fish and Wildlife Service put it, “The Okefenokee is like no other place on earth.”

Twin Pine’s proposed strip mine endangers this world-class resource. Not only is the proposed mine dangerous in its own right, it would effectively open Trail Ridge to mining for decades to come, jeopardizing the long-term viability of the swamp. Georgia EPD, as the state agency charged with protecting and restoring Georgia’s environment, has both a statutory and moral obligation to say no. The stakes are too high, and the risks are too great.

Twin Pines' proposal to mine deep into Trail Ridge adjacent to the national wildlife refuge will likely have lasting and irreversible impacts, eliminating roughly 300 acres of valuable wetlands, excavating up to 50 feet deep, withdrawing millions of gallons of groundwater, releasing air and light pollutants into the International Dark Sky Park, and discharging wastewater into the St. Marys River basin. Twin Pines has offered NO defensible assurances that; 1) their mining operations will protect the Okefenokee Swamp from permanent damage; 2) that they will protect threatened and endangered species, including Red-cockaded Woodpeckers, Wood Storks, gopher tortoises, and many other species that nest and raise young in the Okefenokee Swamp; and 3) that they will safeguard the long-term interest of the birdwatchers, kayakers, hikers, and other nature enthusiasts who visit the Okefenokee Swamp each year. 

The Okefenokee Swamp is a diverse ecosystem that provides critical habitat for more than 200 species of resident and migratory bird populations, as well as many other plant and animal species. Below, please find a list of the specific species that Birds Georgia is concerned will be negatively impacted by the Twin Pines Mine.

• The federally-threatened Wood Stork is the only stork Native to North America. As tactile feeders, wood storks wade in water with their beaks open and partially submerged. When a prey item is touched, the Wood Stork snaps its mandible shut and throws back its head to swallow the prey whole. This feeding technique allows storks to forage at all hours. Feeding success is largely dependent upon prey abundance and availability. Historically, water levels in the Southeast fluctuated with the seasons. Wet seasons would provide increased prey and dry seasons would concentrate that prey in easily accessible locations for Wood Storks. Because much of the Southeast has been diked, canalized, and drained, however, the natural cycle that Wood Storks depend upon has been altered and their historical populations severely diminished. The species is now listed as Threatened under the Endangered Species Act. Because the Okefenokee remains functionally whole and largely intact, Wood Storks utilize the Refuge for foraging and nesting purposes. Unfortunately, the proposed mine potentially stands to alter the hydrological regime upon which the species relies. The Service “expect[s] impacts to groundwater characteristics including water table elevation, and rate and direction of flow as the soil profile is permanently homogenized” within the refuge. Should these impacts be realized, they “may not be able to be reversed,” and could potentially have a major impact upon the ability of Wood Storks to locate prey. It is well established that “storks are especially sensitive to any manipulation of a wetland site that results in either reduced amounts or changes in the timing of food availability.” A drop in the water table, furthermore, would not only affect prey availability, but it could prove fatal to breeding storks, which avoid predation by creating nests in flooded environments.

 

• The Red-cockaded Woodpecker is a federally-listed Endangered Species and is among the coastal plain’s most charismatic, visible, and imperiled species. Though Red-cockaded Woodpeckers were once found throughout the greater Southeast, from New Jersey to Florida and west to Texas, historical logging operations resulted in the loss of nearly 90 million acres of longleaf pine. Because the species uniquely depends upon mature pine forest—trees that are at least 60–80 years old—as few as 7,800 active clusters exist today across the species’ range, down from a historical, pre-European settlement estimate of 1 to 1.6 million family groups. The species remains listed as Endangered under the Endangered Species Act. The larger 8,000-acre project is adjacent to the Refuge, where several active Red-cockaded Woodpecker clusters are known to reside. Currently, the Refuge is home to 97 clusters, 46 of which are active. These “are most likely the remains of a much larger population that once depended on the pine stands surrounding the refuge,,” such as that within the proposed project site.

 

• Prothonotary Warblers breed in the Okefenokee Swamp. These birds are extremely vulnerable to the loss and alteration of forested wetlands on their breeding grounds. Removal of standing dead trees and channeling of streams has been shown to negatively affect nesting success. Prothonotary Warblers could be negatively impacted by declining water levels and forest fragmentation caused by the Twin Pines Mines.

 

• Little Blue Heron populations have been in decline since the mid-twentieth century and are currently being considered as an addition to the State Wildlife Action Plan, on which Birds Georgia’s Director of Conservation, Adam Betuel Serves. Like Wood Storks, Little Blue Herons nest in the Okefenokee Swamp. These birds are extremely sensitive to water diversions and even a small reduction in the water beneath this species’ nesting trees could lead to nest failure.

• Swallow-tailed Kite have lost much of their historic U.S. range —they used to occur along the Mississippi River as far as Minnesota—due to habitat loss and fragmentation from agriculture, urban development, logging, and other landscape alterations. Roosting kites are also vulnerable to disturbances like light and noise pollution.

 

• Chuck-will’s-widows are Birds Georgia’s current “Species of Concern.” Their populations have declined by about 1.6% per year for a cumulative decline of approximately 58% between 1966 and 2019, according to the the North American Breeding Bird Survey (https://www.pwrc.usgs.gov/bbs/about/). Chuck-will's-widow is included in the list of Partners in Flight Common Birds in Steep Decline for species that are still too numerous or widely distributed to warrant Watch-List status but have been experiencing troubling long-term declines. Chuck-Will’s-Widow nest in the Okefenokee Swamp and are extremely sensitive to disturbance at their nesting sites. They are also vulnerable to pesticide use since they have such an insectivorous diet.

 

• The Georgia state-listed Bachman’s Sparrow has been documented on this site. Populations of these birds have declined by 76% between 1970 and 2014, according to Partners in Flights. Partners in Flight estimates that the global breeding population is 190,000 and if current rates of decline continue, Bachman's Sparrows will lose another half of their remaining population by 2040. The Bachman’s sparrow has experienced significant range contractions, as a result of habitat conversion and commercial development. The species depends upon open, mature pinelands, regenerating clear cuts, and utility rights-of-way. Mining disturbances are likely to result in the localized disappearance of Bachman’s sparrows from the site and affect the behavioral patterns of the larger population found within the Refuge.

 

• Bald Eagles are known to utilize Okefenokee National Wildlife Refuge. Because Trail Ridge is an inseparable component of the larger refuge ecosystem, any mining disturbances stand to potentially affect the nesting and hunting success of the Bald Eagles that depend upon the waters of the Swamp.

 

• The Okefenokee Swamp is one of the only known breeding sites in Georgia for the Florida subspecies (Grus canadensis pratensis) of Sandhill Cranes. These birds are listed as threatened in the state of Florida. Degradation or direct loss of habitat due to wetland drainage or conversion of prairie for development or agricultural use are the primary threats facing Florida sandhill cranes.  The range of the Florida sandhill crane diminished in the southeastern United States during the 20th century, with breeding populations disappearing from coastal Texas, Alabama, and southern Louisiana due to degradation, habitat loss, and overhunting.  (Meine and Archibald 1996). Sandhill Crane populations recover slowly, partly because each breeding pair usually has only one chick per year that survives to fledging. The future of Sandhill Cranes is mainly tied to the fate of their habitat.

 
Hydrology Concerns:
Birds Georgia does not believe that Twin Pines has adequately proven that the proposed mine will not harm the water levels in the Okefenokee Swamp and surrounding Trail Ridge. The proposed mining project would dig pits up to 50 feet deep into Trail Ridge, a feature integral to maintaining surface water and groundwater hydrology in the Okefenokee, St. Marys River, and surrounding areas. More than 85 scientists, including UGA hydrologist Rhett Jackson, have concluded that the mine poses a significant risk to the swamp. Even a small reduction in the amount of water in the swamp could have far reaching impacts for the wading birds and other species that live there. As indicated above, many bird species are extremely vulnerable to reduction in water levels beneath nesting trees and many more rely on the Okefenokee for feeding and shelter.
Twin Pines proposed is expected to (1) lower water levels in the Okefenokee Swamp and the St. Marys River by removing more than one million gallons of groundwater per day; (2) destroy the distinct geological layers of Trail Ridge, making it difficult to reestablish wetlands and potentially reducing long-term flows to the swamp; (3) increase wildfire risk in the vicinity of the swamp by exposing peat and by increasing the duration and severity of drought in the Okefenokee Swamp and St. Marys River; (4) contaminate ground and surface water in the vicinity of the mine by liberating heavy metals, radionuclides, and other contaminants that are currently stored in Trail Ridge soils; (5) degrade habitat and harm wildlife, including endangered sturgeon and migratory birds.,

Question: What steps will Georgia EPD take to ensure that the water level in the swamp is not negatively impacted by the Twin Pines Mine?

Stopover Habitat for Migratory Birds:
Along with other partners and researchers, Birds Georgia has been working with the Cornell Lab of Ornithology and Colorado State University to use radar and satellite imagery to develop BirdCast, a bird migration forecasting tool. In addition to providing multi-day forecasts of bird migration patterns over the continental U.S., BirdCast also provides real-time data on the population density and direction of migratory birds flying over the country. An analysis of BirdCast data from 2000 to 2020 revealed that the Okefenokee Swamp and surrounding environment is a critically important stopover area for vast and diverse populations of migratory birds, both during spring and fall migrations. Particularly notable, portions of Trail Ridge which include and surround the proposed mining site are hotspots for spring migration stopovers. These areas provide migratory birds with needed shelter and key food sources as they travel to and from breeding and wintering grounds. The Okefenokee Swamp could be the first landfall for many of these Neotropical migrants that just crossed the Gulf of Mexico or arrived from the Caribbean Islands.


The proposed mine would disrupt these critical stopover areas in a variety of ways, by destroying vegetation and soil structure, removing groundwater, generating light and noise, exacerbating wildfires, and releasing toxic contaminants. All of these disruptions are likely to negatively impact migratory birds and their habitat in and around the mining site, as well as the broader Okefenokee ecosystem. This is especially worrisome as our long-distance migrants are the species, in general, experiencing the steepest declines and encountering the higher amount of threats.
Lighting Concerns:
Birds Georgia remains concerned about excess nighttime lighting associated with the Twin Pines Mine. The Okefenokee Swamp is well known for its dark nighttime skies, and nearby Stephen C. Foster State Park is designated as a Dark Sky Park. Migrating birds are extremely sensitive to nighttime lighting which can act as a magnet pulling them off course and into brightly lit areas where they face threats ranging from building collisions to predation. 
 
Question: How will the Georgia Environmental Protection Division ensure that birds are not negatively impacted by nighttime lighting from the Twin Pines Mine?
 
Birding and Outdoor Recreation:
In addition to the many bird and animal species that rely on this diverse ecosystem, the Okefenokee Swamp is a popular tourist destination. Each year, more than 650,000 people visit the Okefenokee National Wildlife Refuge to watch birds, camp, canoe, kayak, hike, and enjoy this unique natural area, generating roughly $88 million in economic impact in Charlton, Clinch, and Ware counties. In fact, the Okefenokee National Wildlife Refuge (NWR) provides more economic benefit to Georgia and Florida than any other NWR.
Question: How will the Georgia Environmental Protection Division ensure that Twin Pines does not cause irreparable harm to this ecosystem and negatively impact recreational opportunities and tourism-related economic benefits from Okefenokee Swamp-related tourism?
Overwhelming Opposition to Mine:
 
Finally, no permit application in Georgia history has drawn as much opposition as this one. Since Twin Pines proposed mining Trail Ridge in 2018, public opposition has been overwhelming and unwavering, with more than 200,000 individual comments at the state and federal level as of April 1, 2024. Birds Georgia submitted comments during the March 5 Public Meeting and listened to the 3+ hours of testimony. Not a single person spoke in favor of the mine.  In addition, people from across Georgia  have written letters and called their legislators in unprecedented numbers, and at least nineteen local governments have passed resolutions calling for the protection of the Okefenokee Swamp. It is clear that Georgians DO NOT WANT the Twin Pines Mine near the Okefenokee Swamp.
 
In closing, Birds Georgia feels strongly that the Okefenokee Swamp is a unique ecosystem that should be protected from activities that could disrupt bird life. We continue to encourage the Georgia EPD to deny these permits for surface mining along the Okefenokee Trail Ridge.

Thank you for your consideration.

Sincerely,

Jared Teutsch
Executive Director