Despite decades of well-founded, science-based warnings, Georgia’s policies have defiantly continued to worsen climate-change impacts.
In defending their reckless decisions, undoubtedly Georgia leaders will claim that Helene’s massive destruction was unrelated to rising temperatures caused by the release of carbon dioxide and methane, epitomized by Georgia Power’s profitable, Public-Service-Commission-sanctioned combustion of fossil-fuels.
Yet, scientific evaluation underscores the tragedy of Georgia’s negligence:
Michael Wehner, a senior scientist … said he and his colleagues conducted a “climate change attribution” analysis of [Helene’s] rainfall, seeking to determine how global warming contributed to the event. Their findings show that rainfall totals observed in parts of Georgia and the Carolinas were … about 20 times more likely because of human-caused global warming. The authors estimate climate change “may have caused as much as 50% more rainfall….” [Drew Kann in Atlanta-Journal-Constitution.]
These findings are especially relevant because a study committee of Georgia’s General Assembly is gathering information needed to prepare legislation addressing disaster mitigation and resilience. As stated in a resolution creating the committee, “[Georgia] will benefit from a coordinated and collaborative effort to develop comprehensive … solutions to protect this state and its citizens, businesses, and natural resources [from the impacts of extreme weather] by accounting for current risks as well as projected future conditions.”
Unquestionably, this legislative study is timely and important. However, it would be foolhardy to limit its focus to devising methods for protecting Georgians from the very events that state energy policies are making more disastrous.
Safeguards protecting the public against extreme weather would greatly improve if officials honored science instead of profits.
[Pubilshed in the Atlanta Journal Constitution, July 5, 2024]
Coastal Georgia is undergoing rapid, unprecedented urbanization, closely tied to the state’s industrial growth and international trade. Just west of Savannah in Bryan County, these trends are being dramatically demonstrated by an enormous Hyundai EV plant, among the world’s largest such facilities, under construction on a ‘mega-site of nearly 3,000 acres near the rural town of Ellabell. A related battery-making facility is also part of the $7.6 billion deal, announced in 2022.
Although those involved in the negotiations to secure the Hyundai project claim they have met ‘due diligence’ requirements, many critical questions remain unanswered, and residents are raising well-founded objections. Similar clashes surround the proliferation of big-box warehousing along the I-16 corridor that is directly linked to the colossal volume of international trade flowing through the Port of Savannah. Georgia Ports Authority documents an increase of nearly 15% over the past year, which gives Savannah its highest ranking ever among U.S. container ports, now comprising 11.2% of the nation’s total.
The Ports Authority describes the Savannah facility as “the fastest-growing container terminal in the nation.” And, unsurprisingly, the Savannah Economic Development Authority portrays their domain as “one of the hottest industrial real-estate markets in the country.” In keeping with these ambitions, the Port of Brunswick registered a whopping increase of 44% in April’s cargo, some 80,600 units of vehicles and heavy equipment, setting a new record.
According to Latrice Williams writing in Savannah Morning News, through a combination of expenditures in acquiring, reviewing and preparing the site, highway expansions and infrastructure, and workforce education, as well as tax breaks, the ‘incentive package’ supporting the Hyundai operation, paid for by public agencies, is reported to be some $1.8 billion. That means that Georgia taxpayers – including many adversely affected – are subsidizing the project without participating in pivotal decisions that result in these projects being implemented, often without adequate planning, assessment, or regulatory enforcement.
A brief 15-day regional review of the Hyundai project was conducted by the Coastal Regional Commission – in compliance with proforma procedures of the Georgia Planning Act – but comments were advisory, lacking mandatory requirements, and the review evidently occurred after the lengthy incentive negotiations had been well underway and were already deeply vested. While local-government master plans are required by the same state legislation, they may be marginalized or expediently amended to accommodate opportunistic projects that can appear appealing when not insightfully scrutinized.
These experiences strongly suggest the need for fundamentally revising procedures used in making such decisions. Economic development must be judiciously evaluated, and when impacts are deemed unacceptable through informed, deliberative, and broad participatory review, projects must be accountably restricted or rejected altogether. As thousands of acres of tree-covered land are cleared and paved-over, and intensified commerce generates thousands of trips on local roads and highways, rural residents express despair about the decline in their quality of life, while also voicing concerns about stormwater contamination, river and aquifer protection, public safety, and air quality.
It is clear that decisions made by various local development authorities, the Georgia Ports Authority, and Georgia’s Department of Economic Development, whose only measure of success seems to be rapid and profitable growth, give little credence to different values held by citizens living within the expansive impact areas of these massive mega-projects.
Aggressive state and local development practices must be tempered by deliberative, mandatory review of both environmental factors and quality-of-life issues through a transparent process of participatory decision-making that justly empowers all Georgians. Our citizens must not be forced to endure the offensive consequences of dubious ventures that are unilaterally rationalized as progress, largely driven by the objectives of politically influential absentee investors.
But to help improve these decisions, the public cannot afford to be complacent. Instead of assuming a passive role that is often rationalized by cynical assertions about the impossibility of defending local interests, Georgia citizens and voters must organize and speak out at every opportunity. In particular, unless coastal Georgians insist on actively participating in these decisions, the unique character of the region will be forfeited to profit-obsessed interests, becoming just another “sacrifice zone” exploited through predatory industrialization.
“The question is whether any civilization canwage relentless war on life without destroying itself, and without losing the right to be called civilized.”
~ Rachel Carson
MEGA hats are available from the Center for a Sustainable Coast, www.sustainablecoast.org
Earth Day 2024
We must fulfill our obligation to serve democracy & the common good
It has been said that human life is driven by a series of decisions, personal and otherwise. That proposition has special significance in a democracy, where we have the opportunity to use our moral authority as citizens to make political choices that can have profound consequences for our collective future. In light of this valuable political opportunity, it should be acknowledged that over the past century, the rapid proliferation of commercialism has come to dominate - and critically restrict - choices that are pivotal to the future of our nation.
Accordingly, our decision-making role has increasingly shifted to becoming consumers, with a proportional decline in well-informed political engagement. Whether that trend has been orchestrated or is simply a result of gradual adaptation to economic circumstances, the implications should be taken seriously – not only by expressing our views in the voting booth, but also by voicing them in many state and local decisions providing procedures for making public comment through agency review processes, as well as in the media.
There can be little doubt that if our era is objectively chronicled, it will be marred by escalating, corrupt opportunism – exploitative practices being rewarded rather than punished. When the growing injustices of abusing the common good repeatedly go uncorrected, victims become cynically disengaged while grifters are emboldened and empowered.
Consider two prominent examples related to Georgia’s Public Service Commission, the agency supposedly responsible for representing the public interest in issues related to the price of electricity, as well as how it’s generated and distributed. Contrary to their legal obligation, PSC members have shifted billions-of-dollars in Plant Vogtle expansion cost-overruns from Georgia Power executives and Southern Company stockholders onto residential energy consumers. Southern Company stock-returns and executive salaries soared during the 15-year project, while its subsidiary, Georgia Power, caused massive financial burdens that the PSC converted to a 30% increase in residential utility costs to compensate for corporate blunders. Apparently, the PSC would rather sustain the ample incomes of company executives and stockholders than protect household energy-users and the common good.
Similarly, after litigation was filed asserting that the method for electing PSC members violated a recent Supreme Court ruling on the federal Voting Rights Act, instead of immediately correcting the problem, Georgia courts delayed the next election, extending the terms-of-office for two members by two years. Moreover, while enjoying their unfairly prolonged PSC authority, these members helped worsen Georgia’s pollution of air and climate for many years ahead by irresponsibly approving expanded fossil-fuel-burning power-generation instead of converting to clean energy. That decision fundamentally contradicted compelling, well-informed public hearing testimony as well as national climate-policy objectives.
Oppression undermines democracy, environmental justice, and the common good when flagrant exploitation by special interests is politically sanctioned instead of being prohibited. As citizens and voters, we must vigilantly strive to fulfill our obligations and use our moral authority to reform political institutions so they consistently serve urgent priorities essential to safeguarding the future.
Our active engagement in these critical decisions as citizens is imperative.
David Kyler, Center for a Sustainable Coast
The above statement is based on a letter-to-editor published in The Brunswick News and The Albany Herald, and The Bryan County News.
Ten Policies to Help Make Earth Great Again
Prohibit environmentally degrading activities, based on balanced, thorough assessment of their consequences for life-support systems and at-risk communities.
Immediately adopt escalating restrictions on the emission of heat-trapping emissions, with the goal of eliminating all such emissions no later than 2050.
Eliminate all government subsidy of activities that threaten or degrade environmental quality, critical species, and social justice.
Issue comprehensive monthly reports based on well-researched scientific evaluation of key ecosystems essential to life-support and food supplies.
Adopt federal procedures requiring mandatory review of all legislative proposals and existing laws to revise them as needed, based on these ecosystem threat-assessments.
Tax all incomes over $10 million annually at a minimum of 20% and provide a 50% carbon-emission-reduction tax-credit for all households earning less than $200,000 a year.
Use at least half the proceeds from high-income-bracket taxes to restore damaged ecosystems, correct environmental injustices, and enforce emission-reduction activities.
Implement a comprehensive international environmental education and internship program, strengthening capabilities for global ecosystem restoration and protection.
Adopt federal requirements applicable to licensed media outlets to eliminate all environmental disinformation, while disseminating weekly updates on ecosystem conditions.
Create federal trade policies that strictly prohibit products, services, and practices that degrade essential ecosystems, consistent with the latest scientific assessments.
Comments on proposed rule changes, CRD/DNR January 19, 2024
Georgia’s marshlands are a key component of the dynamic and complex intertidal zone, where freshwater systems merge with marine waters. Georgia's tidal marshlands, the largest on the U.S. east coast, are extremely important as wildlife habitat and marine fish nurseries, as well as providing invaluable water filtration and flood protection. These marshes are regulated by the Georgia Department of Natural Resources, which is now proposeing ill-conceived revisions in the marsh rules they administer.
Properly protecting the important functions of marshlands is complicated by the movement of tides, river and pipeline outflow, as well as stormwater runoff in the five coastal river watersheds (that can carry contaminants hundreds of miles downstream), the development of upland areas including water access via docks and elevated walkways, and changes in conditions caused by the alteration of topography, vegetation, and land-cover in adjacent upland areas. Despite the growing risk of coastal flooding and the corresponding expense of flood insurance, demand for the development of marsh-front properties continues to escalate, making the protection of marshes increasingly important and controversial, as well as more difficult. (See references listed below.)
Objectives that should be served by effective marsh buffer rules:
Prevent activities causing harm to marsh functions. Those functions include wildlife habitat and fishery nurseries, water filtration & flood protection of adjacent uplands.
Minimize harm to upland areas and marshes caused by rising sea level and storms.
Prevent damage to other [off-site] upland areas caused by permitted activities.
Administer and evaluate permitting to prevent risk of cumulative damages within a watershed or impact zone, augmented by analysis of other information about marsh conditions and threats.
Enhance public awareness of the benefits of marsh protection through state regulation.
DNR’s current and proposed procedures for marsh buffer regulation are flawed by:
Incremental decision-making that lacks systemic assessment and longer-term perspective
Fragmented, weakly coordinated use of state and local authority [under rules based on both Georgia’s Marshlands Protection Act and the Soil Erosion and Sedimentation Act]
Neglect of significant factors that can adversely influence the consequences of permitting decisions – foremost rising sea-level, and
Inadequate public understanding of the permitting process and its relevance to Georgia’s coast.
Critique & Recommendations
Lack of Systemic Analysis
Due to the risk of accumulative adverse effects of many individual permitted activities and rising sea level, incremental permitting cannot provide adequate protection of the tidal marsh ecosystem. Permitting decisions must be augmented with assessment of the consequences of activities previously permitted and changing conditions affecting the ecosystem functions of Georgia’s tidal marshes.
Uncoordinated & Fragmented Use of State Authority
The current split of authority between two separate divisions of Georgia DNR, as well as the option for local governments to assume certain elements of regulation caused inevitable but avoidable lack of uniformity, understanding, and rigor in the use of rules intended to protect tidal marshes. Buffer rules must be adopted under a structure that empowers a single agency unit for applying state authority.
Neglect of Key Assessment Factors
Current rules provide no assurance of credible evaluation of important factors relevant to anticipated impacts of proposed development activities in the tidal marsh buffer. Foremost, there are numerous studies predicting the accelerated risks of coastal flooding caused by rising sea level, which must be a critical factor in regulation of demand for marshfront projects such as seawalls and evaluating their impacts over the life of the project. Buffer rules must include mandatory assessment of such factors, for which there are now many sources of technical support through NOAA and various national NGOs, as well as federal funding for programs providing climate change adaptation. [See references below]
Inadequate Public Involvement & Understanding About Marsh Protection
Reforming rules for marsh buffer regulation provides an important opportunity to upgrade reporting and analysis of permitting activities for public review, which promises to enhance citizen understanding about the relevance of these efforts, support for them, and compliance with regulatory requirements. As I suggested in oral comments at the January 4th hearing, it is strongly advised that DNR/CRD adopt the practice of producing and widely distributing an annual report that describes and maps all permitted activities [Marshlands Protection, Shore Protection, and Buffer Protection], results of any post-permitting assessment of impacts, regulatory violations and related resolutions, and letters of permission affecting the tidal marshes of Georgia. To initiate enhanced public involvement, we enthusiastically support the formation of a stakeholder/public advisory group to work with DNR/CRD in developing a more thorough, consistent, and effective regulatory program for Georgia’s marsh buffers.
. Thanks to prolonged supremacy of the greed ethic over the past four decades, stockholder affluence has soared while the U.S. minimum wage, inflation adjusted, is less than a third of what it was in the 1970s. Concurrently, along with such financial injustices that eroded the working wage and depleted the middle class, environmental negligence has escalated, with severe consequences.
“The point is, ladies and gentlemen, that greed, for lack of a better word, is good. Greed is right, greed works. Greed clarifies, cuts through, and captures the essence of the evolutionary spirit. Greed, in all of its forms — greed for life, for money, for love, knowledge — has marked the upward surge of mankind.”From the 1987 film, Wall Street.
In the 35 years since the fictional character Gordon Gekko proclaimed that greed is good in the movie “Wall Street,” the tycoon’s assertion, further empowered by the 2010 Supreme Court Citizens United decision, has taken a treacherous toll on America and, in various ways, the world beyond. Thanks to prolonged supremacy of the greed ethic over the past four decades, stockholder affluence has soared while the U.S. minimum wage, inflation adjusted, is less than a third of what it was in the 1970s. Concurrently, along with such financial injustices that eroded the working wage and depleted the middle class, environmental negligence has escalated, with severe consequences.
A recent, controversial example is the preventable railroad accident in eastern Ohio, spilling hazardous materials that killed wildlife and will likely cause diverse public health risks for years to come.
According to news coverage, the cost of installing braking devices – that could have stopped hundreds of thousands of gallons of toxic chemicals from contaminating the city of East Palestine and its inhabitants – was deemed unjustified by Norfolk Southern Railway executives. Equally troubling, the railway industry used its political clout to get the federal government to weaken rules so that trains with fewer than 70 cars carrying hazardous material are not required to have electronically controlled pneumatic brakes. Furthermore, they reduced crew size and inspection standards that boosted rail industry profits by taking risky shortcuts.
The biased calculations used in these selfish trade-offs, made to exclusively serve narrow corporate goals, are ubiquitous and increasingly driven by the outsized influence of well-paid professional lobbyists, who too often produce grossly unethical hidden consequences. Corporate profits are boosted by a combination of degraded safety precautions and inadequate accountability when the public, and/or workers, are injured – unfairly shifting private costs and suffering onto unwary third parties.
Similar regressive outcomes have occurred through relaxed environmental enforcement. In June 2022, the US Supreme Court ruled that EPA cannot limit state-level carbon emissions under the 1970 Clean Air Act. This constraining rollback, serving short-term motives of the power industry at the public’s expense, is brazen circumvention of urgently needed policy goals adopted by Congress. Moreover, the ruling defied well-established scientific findings that such emissions are the main cause of climate change, an unparalleled threat to human health and vital life-support systems. In recent decades other threats to the public accumulated in an array of lower-court decisions failing to penalize violations of state and federal regulations, weakening natural-resource safeguards and environmental justice. And in May 2023 the Supreme Court delivered a decision degrading federal Clean Water Act protections over millions of acres of wetlands that are essential to water quality, wildlife habitat, flood prevention, and human health.
By prioritizing short-term property income and investment interests over the common good, bolstered by government funding favoring intertwined fossil-fuel and financial institutions, the injustices of U.S. policies are only outdone by certain states, including Georgia, that reward industry investors at the citizens’ expense, even for mismanaged projects.
As the earth hurdles toward ever-worsening climate hazards and economic injustice, we can no longer tolerate the indiscriminate promotion of all development under “greed-is-good” policy, as if it inherently benefits society. Until more objective and holistic assessment standards are applied in using public resources and regulatory authority to guide business activities, government programs will continue generating inequitable and environmentally harmful outcomes.
For example, while Georgia wins unbridled praise for securing major investments in the manufacture of batteries, solar panels, and electric vehicles, officials remain stubbornly regressive in the state’s energy policy by severely restraining the implementation of rooftop solar infrastructure. Energy experts advise that the widespread use of rooftop solar and on-site battery storage will not only reduce consumer energy costs, but it will help ensure a more stable and resilient power grid as demand grows and extreme weather threats worsen.
Concurrently, Georgia’s energy policymakers have expanded the use of natural gas, a fossil fuel that emits heat-trapping gases when burned and is linked to an array of methane leaks that dangerously compound global overheating. Furthermore, unlike most states, Georgia has failed to adopt a clean-energy transition plan or scheduled targets for reducing carbon emissions.
Likewise, Georgia officials have imposed grossly excessive cost overruns, incurred in Georgia Power’s Vogtle nuclear plant expansion, on residential customers, who have suffered a rate increase near 30 percent since 2010, while industrial rates grew by only 0.3 percent. These Vogtle costs are some $20 billion over budget, and still increasing by millions weekly. In effect, residential energy customers are subsidizing Georgia’s industrial development – and Georgia Power’s profit margin – without public approval, and probably without the understanding of those who are most financially abused because of it.
Meanwhile, economic development proponents have received unqualified support for producing clean-energy equipment, while Georgia markets for it are either stymied by state policies (solar panels) or encumbered by products (electric vehicles) that will be recharged primarily with power produced by burning fossil fuels.
To initiate remedies for these blatant contradictions and inequities, rigorous standards must be adopted and consistently applied, including the following recommended criteria:
Public costs for subsidizing economic development projects, including tax exemptions, low-cost leases, and below-market land/energy, must not be imposed on taxpayers and energy customers without their formal agreement through detailed, specific voter referendums.
Government support for ‘job creation’ in the clean-energy sector must require both enhanced working conditions and employee benefits as well as energy policies that are consistent with the goal of reducing heat-trapping gases that cause disruptive climate damages. States like Georgia, without such policies, should not be eligible for federal support, including grants and/or tax credits provided through the Infrastructure Act and the Inflation Reduction Act.
Any state receiving clean-energy development incentives must be required to adopt a transition plan and routinely report corresponding implementation efforts. States without such plans or sufficient progress in implementing them, must not be eligible for receiving federal support.
The environmental impacts of clean-energy projects must be thoroughly analyzed, publicly reviewed, and reliably evaluated, consistent with applicable state and federal laws. The potential benefits of clean-energy projects do not justify regulatory exemptions or lax enforcement. Impacts of these projects on water, air quality, surrounding land uses, and other factors must be responsibly assessed and all reasonable alternatives must be rigorously but expediently evaluated.
Unless we can rapidly surmount powerful political interests fixated on short-term profitmaking, humanity's prospects will grow increasingly dire as our life-support systems further degenerate. The common good, essential to our future, can only be realized by responsibly controlling greed.
It would be a grave error to set or support 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.
Statement filed with Georgia Department of Natural Resources by Center for a Sustainable Coast, March 20, 2023
The Proposed Activity
In March 2020, Twin Pines, LLC, an Alabama-based mining company, submitted a revised application to the U.S. Army Corps of Engineers (USACE) seeking issuance of a permit to “construct a demonstration mining project on 1,042 acres that will mine heavy mineral sands on 898 acres over 6 years” from Trail Ridge near the southeastern edge of the Okefenokee Swamp. The application was later reduced to 556 acres for a ‘Phase 1’ mining project.
From the U.S. Fish & Wildlife Service: “Trail Ridge forms a rim or geomorphological “dam” on the east side of the swamp maintaining the hydrology of the swamp. The soil of Trail Ridge has a profile of distinct layers. This gives it water holding and water movement characteristics.”
Mining project proponents seek to strip-mine heavy minerals (titanium and zirconium) to a depth of 50 feet below the ground surface, which is below the level of the Okefenokee Swamp depression and essential to maintaining surface water and groundwater hydrology in this region of southeast Georgia.
Unprecedented & Tenuous Permitting Procedures
Since the adoption of federal environmental laws in the early 1970, no project of this magnitude and significance has failed to require an individual federal permitting review process. Due to the unique timing and circumstances of this ill-advised mining proposal, the State of Georgia is now exclusively authorized to administer the permitting process, and Georgia EPD is in the highly controversial, politically vulnerable position of evaluating anticipated impacts that the project will impose on the Okefenokee National Wildlife Refuge [ONWR].
Resources at Risk & Reasons for Opposing the Project Permit
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 required for properly evaluating and enforcing precautionary protection measures would be 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, which is not being required.
- 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 unacceptably adverse outcomes are not only great, they are worsening.
- 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.
- 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) - classified as threatened by both Georgia and the US Fish & Wildlife Service as well as being considered a keystone species - is warranted since it is likely that their habitat will be permanently degraded by surface mining disruptions.
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.”
Although engineering solutions to these hazards are claimed, such methods remain unproven and are prone to unanticipated flaws. Considering the disastrous downside consequences, the Trail Ridge site is an unacceptably irresponsible place to experiment with engineering techniques.
It would be a grave error to set or support 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.
Respectfully,
David C. Kyler, Co-Founder & Director Center for a Sustainable Coast
Understanding limitations and how to deal with them responsibly is at the heart of achieving an enlightened, judicious, and sustainable society that adapts well to ever-changing circumstances.
Those of us who promote sustainability in public policy are continually reminded of limits – regulatory funding, environmental health and capacity, political support for clean energy, etc. But due to widely reported constraints for recovering from our brutal economic slump, it is only recently that the general public has recognized the need to confront the reality of limitations.
America’s history has been marked by pride in our optimism and self-sufficiency, often verging on reckless bravado, largely based on promoting boundless economic growth. Rising expectations have been cultivated among the young, who were assured that better-paying jobs, improved technology, and the competitive entrepreneurial spirit of capitalism would generate evermore wealth and economic opportunities – despite the biological and physical limitations of “spaceship earth.”
These themes became the rhetorical dogma of political speeches for so long that many Americans came to believe our nation was invincible, able to defy all constraints that hamstrung progress in other countries. Any U.S. candidate openly daring to question such beliefs was unelectable. Legislation intended to correct problems caused by implicit vulnerabilities was often defeated, weakly implemented, or veiled in the guise of more acceptable purposes.
Now we face the ominous plausibility of irreversible national decline brought by prolonged wars and tax-cuts that we could not afford, global trade agreements and tax policies that placed corporate profits above the welfare of our citizens, and willful negligence of under-regulated financial institutions that viewed rampant speculation as a legitimate means of wealth creation. As a result, the U.S. presently staggers under the burden of a reality we are forced to reckon with, made even worse by our belated recognition of it.
As part of this delusion, blame is too often placed where it doesn’t belong. Immigration policy is attacked while unprecedented corporate profits are taxed at record-low rates (if at all), and bailed-out banks are flush with tax-payer enhanced capital, as small businesses and homeowners plummet into bankruptcy at rates not seen since the Great Depression.
Major industries that are among the largest profit-makers include irresponsible polluters and market manipulators, such as pharmaceuticals, chemicals, coal and oil, which are doggedly defended against justifiable regulation and elimination of government subsidies, while worthy competitors are dismissed as impractical and starved for funding.
Above all, government is often treated with contempt, especially in areas of activity where public programs are most vitally needed. Evidently, many Americans would rather suffer inferior infrastructure, healthcare, and education programs than see government provide needed improvements.
A false and deeply misguiding pride in a perverse sense of “liberty” motivates many of our citizens to oppose the imperative to divert a small share of private wealth, gained at public expense of one kind or another, toward repairing our threadbare social fabric.
Evidence contradicting foolhardy devotion to American “self-reliance” is quite clear: Concentration of wealth among the very rich does not create equitable opportunities for all, just as surely as public expenditures are indispensable to economic stability and quality of life as the private sector fails to serve the common good. Likewise, deregulation doesn’t improve society, because irresponsible business practices invariably result, imposing hardships on the public – whether through unhealthy air and water, fraudulent pension programs and mortgages, or substandard, sometimes dangerous, products and working conditions.
National recovery depends on achieving mature recognition of our mutual inter-dependence as fellow Americans. We must overcome the dismissive rejection of government’s pivotal role in shaping our shared future – ironically, a dogmatic position often taken by those who have benefitted from public programs but deviously deny their advantages to others.
Under conditions of greater limitations – whether environmental, social, or economic – the need for well-managed governmental programs in taxing, subsidizing, regulating, and providing social services is more vital than ever.
Ongoing efforts to defeat a robust and accountable federal role in resolving our nation’s most profound challenges will only make the future more precarious.
David Kyler, Co-Founder & Director
Center for a Sustainable Coast, Saint Simons Island, Georgia
Small-Scale Clean Energy Must Be Georgia's Priority
Submitted to the Georgia Public Service Commission, July 19, 2022
by Center for a Sustainable Coast
We share the concern of many others that despite the alleged financial advantages of energy efficiency, these claims are not well-founded because Georgia Power’s proposed Integrated Resource Plan (IRP) maintains the status quo that has hidden costs and risks jeopardizing the public. If this Georgia Power plan is approved, more fossil fuels and higher utility costs will be unjustifiably imposed on its customers who have already suffered the financial burdens of the company’s past mismanagement of energy projects. Moreover, the plan does not ensure sufficient reliable reduction of greenhouse gas emissions, which is essential to curbing the most destructive impacts of climate change.
Decentralized Facilities Serve the Public Far Better Than Costly Corporate Projects That Are Vulnerable to System Failures
The most fundamental issue, effectively masked by preconceptions assumed in preparing the plan now under review, is the crucial distinction between a corporate-dominated, capital-intensive approach in contrast with a decentralized, “distributed-system” strategy, wherein the energy-generating and storage capacity is primarily owned by energy consumers, not stockholders.
States that have been most successful in achieving clean energy goals are those that have incentivized residential and small-scale commercial solar installations. In these cases, rates paid for all energy are uniform, so that when combined with tax credits, revenues from the sale of excess power at market rates enable these small-scale systems to recover their total acquisition costs in less than five years.
Contrast those installations and their benefits to energy customers with the capital-intensive model being advanced by this plan, which advocates massive ‘solar farms’ that occupy vast areas of land and are implemented as an industrial-scale investment returning income to stockholders, not consumers. These projects cost millions of dollars, which once invested under routine PSC approval are guaranteed a handsome return, yet the vast majority of energy users will remain under the yoke of their substantially greater monthly billing obligation, including repayment of the corporate utility’s capital project costs, plus profits to stockholders.
Moreover, beyond the injustices and inefficiencies caused by abandoning a more equitable, cost-effective policy remedy offered by decentralized facilities (demonstrably proven in other states) the capital-intensive corporate model is also more vulnerable to blackouts and brownouts because there are fewer (and more distant) installations providing power to the energy network (grid). When one or another of the few major power-generating facilities in existence is compromised, the whole system may be jeopardized, and service becomes unreliable.
Similar conclusions can be drawn when comparing centralized energy-storage facilities with those that are distributed among millions of households. As the conversion from fossil fuels to clean energy progresses under a decentralized strategy, the availability of small-scale storage devices will flourish – as both site-based installations at homes and small businesses as well as the cumulatively substantial mobile storage capacity provided by plug-in, interconnectable batteries of tens-of-thousands of electric vehicles integrated into a “smart grid”.
This diverse and decentralized power-storage network would ensure a far more reliable, resilient, and stable energy supply than the capital-intensive system now being proposed. If any single large energy-storage facility became inoperable or disconnected from the grid, without a robust, decentralized (owner-based) array of facilities with comparable cumulative capacity, the whole system would suffer, especially during periods of peak demand.
Natural Gas Leakage & Mandatory Monitoring
Overdue attention must also be given to resolving the methane-leak problem inherent in the use of natural gas. These leaks are not acknowledged in unconditional claims that natural gas is a clean substitute for coal. Yet, energy analysts consistently assert that leaks of more than 2% of natural gas during extraction, processing, distribution, and/or end-use will completely negate any benefits gained by burning natural gas instead of coal, because the leaked gas will produce the equivalent heat-trapping effects in the atmosphere. (Methane has far greater heat-trapping effects than carbon dioxide, making relatively small natural gas leaks costly and counterproductive.)
Studies have shown that many gas-based systems exceed the two-percent leakage limit when they are evaluated throughout the entire cycle, from extraction to end-use. Until and unless the natural-gas systems being advocated and used under this plan are evaluated and continuously monitored to ensure they do not exceed the leak-limit, such systems should not be approved or sanctioned as part of Georgia’s energy-production portfolio. Without rigorous, mandatory use of leak monitoring and assessment safeguards applied to natural-gas energy generation, the state cannot reliably achieve greenhouse gas reductions that are essential to curbing the destructive effects of climate change.
By David Kyler, Center for a Sustainable Coast, Saint Simons Island, Georgia
We have become vulnerable to entrenched assumptions and practices that are not only failing to serve humanity’s interests, but which are, collectively, an escalating threat to our future on Earth. As one of hundreds of factual analyses and reports substantiating this assertion, consider the recently issued National Climate Assessment, the fifth in a series of such evaluations mandated by Congress.
The report documents numerous threats to property, health, and environment. Among them are the increasing extreme-weather events caused by human activities emitting heat-trapping gases – primarily carbon dioxide and methane from using fossil fuels – costing U.S. citizens over $150 billion annually in recent years. These destructive effects include:
Wildfires – Destroying carbon-storing capacity while amplifying heat-trapping gas emissions.
Drought – Killing crops, destroying communities and habitats, endangering millions of people.
Extreme heat – Causing premature deaths and a range of degenerative heat-related diseases.
Extinctions – Entire species are being lost at about a thousand times the historical average.
Cumulatively, these costly worldwide effects are accelerating, and aside from the tragically inequitable financial penalties, they’re creating worsening living conditions that will become intolerable unless pivotal changes are quickly made in how humans use the Earth to support quality of life. This will mean finding viable means to curtail the destructive assaults of our reckless industrialized economy and correct deeply flawed understanding of self-interest.
The implications of these findings are not new, only more alarming due to woefully deficient efforts to appropriately respond to four prior climate assessments, beginning over 20 years ago. The reasons for failing to properly restructure our social and economic institutions despite factual analysis of crucial problems are complex and disputed, but one thing is certain: due to unprecedented environmental damage to life-support systems caused by overriding human activities, the measures for guiding these activities must be judiciously restructured.
The following three factors must be well-integrated into these new institutional guidelines.
Honoring Environmental Limits
Fifty years ago, a landmark book, The Limits to Growth, presented the inevitably destructive effects on the condition of vital world resources caused by irresponsible industrialization and population growth. By foolishly isolating decisions guiding human activities from impacts on the natural systems upon which all life depends, over the five decades since these dire predictions were made, they have become conclusively exhibited. To prevent environmental collapse and an uninhabitable planet, future economic choices must be based upon reliable evaluation of their consequences on life-support systems. Among other things, this will require a well-developed ‘circular economy’ that maximizes the reuse of resources, applying methods that minimize harm and conform with environmental limits.
Merging Individual and Common Interest
Western values now dominating the global economy, epitomized by the American culture, have emphasized self-reliance and individual ambitions that have all too often neglected the common good, with disastrous results. These contrasting outcomes were memorably described as “private affluence amid public squalor” by the well-respected economist John Kenneth Galbraith. Similar negligence has been manifested in U.S. policies adopted over recent decades, as corporate influences have overpowered political and economic agendas, exacerbated and sanctioned by the 2010 Supreme Court decision, Citizens United. That disruptive landmark ruling granted Constitutional protections for corporate political spending as a form of free speech. Yet, human prospects on Planet Earth cannot be served if corporate motives and methods continue to prevail, because individual liberty, economic justice, and environmental viability will increasingly suffer the dire impacts of insatiable profit-and-growth mega-business agendas. Any durable emerging civilization must be based on institutions that transparently reconcile – and accountably integrate – individual rights and the common good to prevent exploitation of the many by the opportunistic few.
Time Horizon
Directly related to the above dominance of profitmaking constructs are the devious effects of short-term thinking that impede the forethought needed to ensure that consequential decisions are properly evaluated, and unwise choices are prevented. But negligent myopic perspective is rewarded by the rigid aims of quarterly and annual profit-maximizing, which routinely forfeit unexamined future well-being for near-term opportunities. The responsible accountability required to prevent continued destruction of life-support systems demands that both individual and collective decisions are guided by longer-term viewpoints. Rather than guaranteeing stock dividends for the next quarter or prolonging annual growth, key decisions must combine the goals of meeting near-term human needs with the rigorous, well-informed long-term conservation of world resource systems. To achieve enlightened economic and social objectives, our ever-advancing information-gathering and analytical capabilities must be dedicated to serving the complex demands of a ‘mixed scanning’ approach that continually surveys and justly reevaluates the dynamic landscape of our socio-geo-political biosphere.
Electronic waste, material recovery, and the clean energy transition
Based on reports by Environmental Resources Management [ERM], consultants. See www.erm.com
The use of and demand for electronics has reached unprecedented levels, propelled by new technologies, intensified reliance on communication infrastructure, and the pressing need for clean energy sources, including upgrades in energy storage and grid transmission. It has been estimated that growth in demand for strategic materials needed to meet these needs will require a production increase of some 400% within a decade, especially critical due to the urgency of rapidly transitioning to clean energy as a means of curbing heat-trapping fossil-fuel emissions.
With accelerating reliance on electronic equipment, there’s been an enormous growth in electronic waste (“e-waste”). In the past e-waste has included computers, servers, monitors, tablets, printers, and cell phones. But with the spreading use of computer chips and electronic devices, this term now encompasses many more household and business products—appliances, toys, tools, audio-video gear, cars, etc. When the performance of these items are surpassed by newer technology, or when they fail, their useful life ends, converting them to e-waste.
“According to the 2020 UN Global E-waste Monitor, e-waste is the world’s largest waste stream globally, often contains materials that are toxic to human health and the environment, yet very little is being recycled. E-waste also contains extremely valuable materials, such as cobalt, lithium, palladium, copper, and gold,” with a lost value in many billions of dollars when not recovered through recycling.
“The world generated 53.6 million metric tons of e-waste in 2019. Only 17.4% of that was recycled. The fraction not recycled (82.6%) represents $47 billion in lost value from materials that could have been recovered, including cobalt, palladium, copper, and other conflict minerals.” [ERM, 2022.] Sources: 2020 UN Global E-waste Monitor, GESP 2020 How E-waste Management Market Became a Highly Profitable Industry 2020: Revenue Analysis and Growth Opportunity, AP Newswire 2020
To the greatest extent possible, the demand for these critical materials must be extracted from the e-waste-stream rather than mining and processing them from deposits scattered around the world. Deriving such materials from e-waste will greatly reduce both environmental and financial costs by avoiding the disruptive, energy-intensive processes required to mine, refine and distribute them from new sources. Risky geo-political disputes may also be avoided.
Coastal Georgia is already encountering a unique opportunity in the emerging e-waste recovery industry with the recently announced location of Igneo Technologies, a New York-based e-waste recycling company, which will be opening its first U.S. electronics recycling facility in Savannah next year. This makes the assessment and control of e-waste recycling even more pertinent in our region, offering potential alignment between environmental and business interests.
Significant risks of e-waste
ERM warns that E-waste contains many toxic and hazardous materials, such as lead, mercury, per- and polyfluoroalkyl substances (PFAS), brominated flame retardants (BFR), chlorofluorocarbons (CFC), hydrochlorofluorocarbons (HCFC), and persistent organic pollutants. When e-waste is not recycled, these chemicals contaminate landfills, creating risks to water quality through leachate when disposal-linings leak, exposing land and wildlife to relate harms. Communities located near landfills are particularly susceptible to chemical exposures resulting from improper e-waste disposal. Environmental contamination from recycling operations is common, endangering human health in neighboring communities, often compounding long-suffered environmental injustices.
When recovering valuable materials from e-waste, the disassembly process presents the potential for worker exposure to airborne contaminants such as lead, mercury, and combustible dust, causing significant health risks. Following disassembly, the treatment of e-waste for recovering precious metals entails hazardous chemicals and high-risk methods, such as acid processing and smelting, creating risky working conditions.
Most e-waste treatment occurs in developing countries, which often lack the regulatory controls, safety infrastructure, and culture to keep their workers safe. Research by the World Health Organization identified associations between e-waste exposure and thyroid dysfunction, adverse birth outcomes, behavioral changes, decreased lung function, and adverse changes at the cellular level in children. For these reasons, it is critically important that science-based safeguards are reliably implemented and conditions are monitored to protect waste-recovery workers – in the U.S. and globally.
According to ERM, consumers and governments are increasing demands for business programs that accommodate product takeback and resource recovery. Some regions are seeing regulatory action on e-waste, such as the European Union’s recast of the Waste from Electrical and Electronic Equipment (WEEE) Directive. Many European businesses are committing to climate and zero-waste goals in response to shareholder and customer pressures, to enhance their corporate profile in achieving sustainable business outcomes. E-waste processing business is especially sensitive to factors such as regulation of working conditions and the environment, shifting market incentives, consumer preferences, and carbon-emission reduction goals, all of which are increasingly critical to profitability.
Achieving sustainability through responsible resource recovery
As the world transitions from a linear economy to a circular one, mining prime materials needed for electronics is unsustainable for business and intolerable for our already overburdened ecosystems. While the technology for efficiently recovering and recycling key components is still developing, more companies are investing in recovery and recycling technologies, because doing so contributes to their emerging bottom line. Capturing the value from existing e-waste will save billions in material costs and significantly reduce adverse environmental impacts. Companies need to discuss how to ensure that resource recovery from e-waste is applied as a strategic business advantage in the transition to a circular economy.
Those business that succeed in resource recovery methods will not only become major leaders in sustainability, but they will also have the potential to realize cost savings by tapping into the growing e-waste market, predicted to reach $102.62 billion by 2027, according to AP Newswire (2020).
ERM advises that the approach must be two-pronged: (1) understand and mitigate the risks associated with current e-waste processing methods, and (2) harness the value of the circular economy transition through product redesign and reuse of valuable materials.
By diligently adopting these goals and also making the important commitment to implementing a clean-energy transition, Georgia can become a leader in advancing a sustainable future.
Forum Addressed Climate-Change, Clean Energy and Federal Support for Needed Improvements
Congressional candidate Wade Herring attended and commented. Representative Buddy Carter was invited but did not attend.
On October 13th the Center for a Sustainable Coast [CSC] hosted a public forum focusing on the climate crisis and new federal funding support for expanding the use of clean energy to help curb heat-trapping fossil-fuel emissions. The event, featuring both live and virtual speakers, was held at the Savannah Cultural Arts Center.
Welcoming participants and providing background on the climate issue, CSC’s co-founder and director, David Kyler told the audience, “It is revealing that a recent survey by the Yale Climate Communications Center reported that although well over two-thirds of Americans believe climate change is either important or urgent, more than 60% of those who prioritize the issue say they seldom if ever talk about it. That is a major reason why we are here this evening—to ensure that the public talks about the climate crisis and, equally important, supports political actions required to make a rapid transition to the clean-energy economy.”
Headlining the forum program was Kate Cell, Senior Climate Campaign Manager at the Union of Concerned Scientists. Referencing a number of statistics and graphs, Cell provided an eye-opening view of alarming climate impacts predicted for the next 30 years, based on the latest scientific research.
According to Cell, “The impacts of climate change are already being felt across the Southeast and in particular in its coastal communities. But there is time to decarbonize our economy and avoid the worst impacts of climate change. Based on modeling done by the Union of Concerned Scientists, flooding and temperature increases will cause billions of dollars in damage along Georgia’s coast by mid-century. Tens of thousands of homes will be uninhabitable due to frequent flooding, and unbearable heat will occur as much as six weeks a year—seven times more often than now—which could be cut by a third or more if quick actions are taken to curb heat-trapping emissions. Unless these emissions are reduced, by 2100 temperatures will be life-threatening for about three months a year in coastal Georgia.”
When Congress passed the Inflation Reduction Act in August and President Biden signed it into law, some $370 billion in federal funds became available to speed the urgently needed conversion to clean power sources and energy-efficiency upgrades.
The Center’s Savannah event was scheduled in view of the mid-term election approaching, as this unprecedented injection of funding provides urgently needed opportunities for taking climate action. Timely efforts to reduce fossil fuel emissions will help restrict the destructive effects of flooding, drought, and extreme heat that threaten humanity here on the coast and elsewhere.
Also speaking was Brionte McCorkle, director of Georgia Conservation Voters, who is working to secure a more just and sustainable future by electing pro-environment candidates and holding elected officials accountable for their actions and voting record. McCorkle’s comments focused on the diverse array of federal supports offered under the Inflation Reduction Act. She elaborated on funding and tax-credits available for individuals, small business, and communities interested in improving energy efficiency, the production and storage of clean energy, and other upgrades and clean-energy technologies that will employ thousands of people in the years ahead.
“For Georgians to secure the greatest benefits from the Inflation Reduction Act, state legislators and local elected officials will need to take notice and take action to revise policies that impede the used of these federal supports,” McCorkle emphasized.
Continuing, she added, “The Inflation Reduction Act is the most significant legislation in U.S. history to tackle the climate crisis. Georgia communities and households that want to address climate change often lack the resources and support to do so. The IRA is a significant catalyst for action that will provide Georgians jobs, savings, and other benefits. The funding provided by this act will help lower energy costs for households and businesses all across Georgia and create manufacturing jobs for American workers. The old way of doing business in Georgia doesn't have to be the only way. The IRA is a catalyst for the clean, secure, and healthy future we all want for our children and grandchildren.”
Panelist Dr. Jim Reichard, a full faculty member at Georgia Southern University’s Department of Geology, gave a quick but comprehensive overview of the science behind climate change, including what is causing it and why commonly heard denials about theses causes are unfounded.
Afterwards Dr. Reichard said, “Science has shown that modern global warming and climate change are being driven by human activity, principally the burning of fossil fuels. This has led to more intense droughts and heat waves and extreme weather events. For coastal Georgia, we will also have to face accelerated sea level rise and the risk of more powerful hurricanes, all of which will have serious economic impacts. At this point our best course of action to avoid the worst impacts of global warming and climate change is to reduce global carbon emissions by quickly transitioning to low-carbon economies.
Center board president Steve Willis provided the audience with a broad perspective on the historical significance of our predicament and decisions that must be made to prevent the worst impacts of climate change. After the event, Willis said:
“Although the self-inflicted global warming crisis is probably the greatest threat humanity has ever encountered (including nuclear weapons), the harnessing of the inexhaustible power sources of wind, sun, and tides--which is the necessary solution to global warming--may be the greatest and most desirable opportunity we have ever had. Let’s do the smart thing before it’s too late.”
During the question-and-answer period, Democratic candidate for Congress, Wade Herring made some comments, and later he shared this statement: “I was grateful to attend the forum hosted by the Center for a Sustainable Coast on the evening of October 13, 2022, to learn more about the imminent threat posed to coastal Georgia by climate change, but also to discuss the positive actions that we can take to prevent damage to this beautiful place where we live. When I am elected to Congress, I will work hard to make sure that the First District gets its fair share of infrastructure funds, as well as the sustainable energy investments from the Inflation Reduction Act. These investments mean jobs for Georgians, a thriving economy, and protection for coastal Georgia that we are grateful to call home. I do not understand why Buddy Carter voted against both of these important bills which are so important to the First District. Carter continues to demonstrate that he is out of step with what matters to the people of this District.
From 2018 through mid-October 2022, a listing of Center letters and opinion columns published in Georgia media outlets features over 150 items explaining timely CSC positions on issues related to climate and clean energy. A complete, updated list of these items is available by contacting the Center at susdev@gate.net.
The October 13th forum was the fifth Savannah event Sustainable Coast has organized in the past decade to build support for effective action on these issues by cultivating well-informed, open public discussion.
A video recording of the event will be available. Please contact the Center at susdev@gte.net .
