Skip to content

Category: Uncategorized

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.
Published on

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

Published on

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.

The central question in confronting this harsh reality is whether we as a people are capable of determining our true self-interest and taking timely, strategic steps to act upon it effectively. Recent political trends suggest a contrary shift to even more reckless delusion, creating disruptive barriers to consensus at a time when we can least afford them.  

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

Published on

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 .

Published on

Of the multiple challenges America now faces, one is most fundamental: achieving a responsible balance between individual freedom and urgently needed pursuit of the common good.

Our nation’s future has been repeatedly threatened by self-destructive periods of neglecting the public interest – intentionally or not – when our sense of liberty is degraded by divisive antagonisms, especially when fueled and exploited by callous, power-hungry leadership, in both the private sector and public.

In part, this unhealthy pattern stems from a misunderstanding of the country’s legacy, founded in rebellion against abusive authority, which established sanctified status of the individual. It has been further distorted by excesses in the American character derived from rhetoric praising self-sufficiency, famously captured in Emerson’s “Self-Reliance.” This preoccupation with individual pursuits has weakened social cohesion as well as respect for the crucial role of government in advancing justice and equality.

Compounding these interwoven disruptive influences is the historical record of harsh injustices imposed on African Americans, Hispanics, Native Americans, and other ethnic minorities – both here and abroad – too often shamefully condoned and implicitly sanctioned by institutions professing devotion to the dignity of human life.

As a nation, our struggle with these protracted hypocrisies now culminates while we confront other profound challenges that must be overcome. Any path forward requires that America finally cast off this chronic tribalism, now being propagated anew through self-destructive acts of partisan delusion that threaten our democracy.

These circumstances demand us to question how we apply our individual abilities – whether to fabricate and defend unfounded assertions that victimize scapegoats unfairly blamed for alleged deprivations, or to insightfully reexamine and revitalize our commitment to the unifying ideal of collective strength through diversity and equality.

Despite the sacred bonds of society being frayed by the reckless turmoil of selfish agendas that thwart humanitarian principles, we can – and must – resolve to advance America’s founding aspirations – extinguishing the malignant perils of exploitation, distrust, and violence – by healing our nation through the disciplined practice of respect for our common humanity.

Many now wonder if it is still possible to restore America’s aspiration to cultivate a durable, equitable future. The answer largely depends on our collective ability to honor the life-enriching interconnections and interdependencies among humans – not only fellow Americans, but all who share the blessings, and limitations, of Earth’s prolific but vulnerable abundance.

We must now thoughtfully dedicate our liberties to prescribing and diligently serving the common good.

Published on

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.

~ David Kyler, Center for a Sustainable Coast

Published on

In observance of Independence Day, we are posting this letter to the editor by Center Co-Director, David Kyler. It was originally published in the Savannah Morning News in July 2020.

Photo by Fabian Fauth on Unsplash

In the barrage of recent events, Independence Day invites self-reflection on the history and values associated with this hallowed holiday.

Diverse expressions of dissent related to COVID-19, racial issues, and national interest have exposed contentious rifts in America’s identity. Ironically, these conflicting viewpoints are commonly derived from aspirations embedded in the nation’s origins – foremost, individual liberty and the pursuit of happiness.

Americans are renowned for independent thinking, articulated in the landmark 1841 essay by Ralph Waldo Emerson, "Self-Reliance.” Resisting conformity and following one’s instincts as perceived in an “every-man-for-himself” world have been espoused for much of our history.

Related residual views still predominate among various divisive groups, serving as a vaguely understood basis of self-respect. Yet, intertwined social, economic, and technological changes that have occurred since these tenets of American identity were formulated require that we adapt them to new circumstances.

Personal liberty in the 21st century depends on a respectful society that requires tempering the excesses of a “frontier ethic” whose practitioners are often skeptical of science and hostile toward others – including racial minorities and migrants.

Abandoning fantasized freedoms is essential if we hope to restrain COVID and other diseases, restore our ravaged global environment, and establish lasting social justice.

Achieving an equitable, interdependent society with mutually beneficial opportunities requires that past prejudices and antagonisms be cast aside. A revitalized sense of the common good must inspire our vision.

To honor America’s ideals, we must struggle for independence from the oppressive dogmatism that degrades our country’s worthy prospects.