Okefenokee mine would be an environmental disaster

Twin Pines’ “Demonstration” Mine will destroy more than 475 acres of wetlands and 412 linear feet of streams on Trail Ridge, and represents an existential threat to the Okefenokee Swamp. If the 773-acre mine is permitted, Twin Pines will likely seek to conduct further mining on more than 6,000 adjacent acres that the company currently owns.

Furthermore, adjacent property owners have expressed their interest in exploring mining opportunities on their land. The Saunders Mine merely represents the proverbial “camel’s nose under the tent.” Activity at this site, dubbed a “demonstration” may not reflect impacts from mines at other locations along Trail Ridge. The cumulative impact of multiple mines should be taken into consideration.

If permitted, the mine will lower water levels in the Okefenokee Swamp, setting off a series of problems that will impact wildlife habitat and human use and enjoyment of the Okefenokee National Wildlife Refuge. The lowered water levels will also impact climate change by exposing and drying the naturally water-logged carbon-rich peat for which the Okefenokee Swamp is known. 

Mining activity on Trail Ridge, now a largely undeveloped and wild stretch of land bordering the east side of the Okefenokee National Wildlife Refuge, will disrupt a wildlife corridor stretching from Central Florida to the Altamaha River and Fort Stewart Military Reservation, a 285,000-acre wildlife haven.

Impacts to cultural resources should also be considered. Consultants for Twin Pines concluded that “no significant cultural resources will be adversely affected by the proposed mining project,” but previous archeological surveys of the area show that there are five sites within the Saunders Mine permit area. These sites contain pre-contact lithic tools, debitage, and ceramic artifacts as well as post-contact historical material, suggesting that the area was inhabited and/or used by Native Americans. Additional study of the mining site may reveal more archaeological discoveries.

Indeed, studies conducted on portions of Trail Ridge north of the Saunders Mine site revealed artifacts dating back some 4,000 years. Given the presence of nearby significant archaeological sites, further study of the Saunders Mine site and Twin Pines other properties should be conducted prior to the approval of this permit application. Additionally, applicants should consult with the Muscogee Nation and other tribes.

Saunders Mine Does Not Demonstrate True Impacts to Okefenokee 

According to the Mining Land Use Plan Summary, the purpose of the mine is to demonstrate “the ability of mining to be conducted within proximity to sensitive environmental resources.” The permit should be denied because the chosen location for the Saunders Mine will not demonstrate the true impacts to these sensitive resources. Of the 6,000 acres that Twin Pines Minerals owns adjacent to the swamp, this location is the furthest from the National Wildlife refuge boundary (2.9 miles) and sits at Trail Ridge’s highest elevation (170-175 feet above sea level). Twin Pines’ property reaches within 400 feet of the refuge boundary and most of Trail Ridge does not rise above 150 feet in elevation. Moving northward from the Saunders site, the desired mineral deposits are narrower and closer to the Okefenokee Swamp with exponentially greater consequences. 

This map shows that the Twin Pines mining site cuts across the top of Trail Ridge (120’-175’).  Trail Ridge is largely at 150’ elevation amsl and the swamp water level is at approximately 120’ amsl — digging 50’ deep would take the pits below the water level of the swamp. The southern end of Twin Pines property where the demo site is located is the highest part of the ridge at 170’ with small areas at 175’  amsl. As Twin Pines moves the mining northward as intended, the elevation as well as the distance away from the swamp decreases making the initial mining site less of a “demo” site of what is to come. 

If Twin Pines wants to determine the “ability of mining to be conducted within proximity to sensitive environmental resources,” the company should have chosen a location that more accurately reflects the conditions on the remainder of its property. 

Surface Mining Rules Not Followed; Fail to Consider Groundwater Impacts 

EPD’s draft permit for the Saunders Mine is flawed because the underlying rules governing Surface mining Permits have not been fully followed and the rules themselves are flawed. Rule 391-3-3-.09 states: 

“Where a mining site is to be located on lands or adjacent to lands containing natural or other resources which may be adversely affected by the mining operation, the mining operator shall include as an attachment to the Mining Land Use Plan, a plan to alleviate and/or mitigate adverse effects of such impacts.” 

Furthermore, Rule 391-3-3-.09 appears to apply only to surface water “contiguous” to the mining site and is specifically silent on impacts to groundwater. The Okefenokee Swamp is not contiguous to the mining site, but nevertheless, independent hydrologists have warned that the mine will disrupt the flow of groundwater, resulting in impacts to the Okefenokee Swamp. The draft permit includes no plan to “alleviate and/or mitigate adverse effects of such impacts.” 

The Saunders Mine will destroy 475 acres of wetlands and 412 linear feet of streams on Trail Ridge. Unfortunately, due to changing federal wetlands regulations during the past eight years, federal permitting authorities no longer have jurisdiction over these natural resources, which, indeed, will be adversely impacted by the mining operation. Twin Pines Minerals has not presented a plan to alleviate or mitigate impacts to these wetlands and streams. 

To my knowledge, Twin Pines has not made any good faith attempts to protect the swamp since they have not conducted any monitoring within the swamp in the four years they have been in the area  or proposed any monitoring in the swamp to detect any changes.  Even with monitoring equipment in place, most likely the consequences will be delayed meaning it will be impossible to identify and correct a problem before it does more harm.  The consequence most likely would be irreversible. 

Finally, the necessity of this mine at this location must be called into question. The minerals to be extracted are common minerals and can be found in abundance elsewhere. The Okefenokee Swamp, a natural feature of worldwide significance, should not be risked for minerals that can be obtained more safely elsewhere.