Thursday, November 15, 2012

St. Marys Airport


The plan to “relocate” St. Marys Airport to Sea Island-donated land (Site 1, Billyville Rd.)  continues to divide the community, absorb taxpayer’s funds and divert attention from far more pressing matters. In 2010, The St. Marys EarthKeepers published a resolution against the “relocation” of the St. Marys Airport to Site 1. We stand by this resolution.

Consider the following:

An airport must not be built on Site 1, (the City’s preferred location due to its donation by the Sea Island Co.) for several compelling reasons including acres of wetlands, the Satilla River, the Rose Basin, threatened species and a 100 Year Floodplain (the FAA prohibits the construction of any airport in a floodplain): http://www.faa.gov/airports/environmental/environmental_desk_ref/media/desk_ref_chap12.pdf


Perhaps one of the most telling reports is that of the Department of the Interior (dated Dec. 11th, 2006 and available at City Hall). It states:

"While we understand the cost savings associated with the donation of the land at Site 1, we recommend that another site be selected for the location of the St. Marys Airport for several reasons:

  1. Construction at this site would lead to greater wetlands impacts than at the other sites. More impacts at this site would be to high quality wetlands, with less impact to low quality wetlands than at the other sites. Also, the selection of Site 1 would lead to a higher level of secondary impacts as described in the draft EA (the topping and/or removal of trees and other obstructions).
Site 1 - total impacts: 228
Site 3 - total impacts: 148
Site 9 - total impacts: 115

Impact to high quality wetlands:

Site 1 - 173
Site 3 - 56
Site 9 - 11

  1. Site 1 would impact approximately 59 acres within the 100-year floodplain of a river crossing the site.
  2. A set of Georgia Power Company Utility lines would have to be relocated at an estimated cost of $7 million. This relocation would lead to additional impacts to natural resources.
  3. Site 1 has the highest estimated construction costs as compared to Site 3 and Site 9."- (approximately $4 million more)."

This is but one of dozens of documents detailing the negative environmental costs (and financial ones) of relocation to Site 1. All are available through the City of St. Marys website http://www.ci.st-marys.ga.us/ and extensive on-line searches.

Given all of these prohibitive factors - plus the massive (? million) environmental mitigation costs required by the EPA and the USACE – why is the City is still speaking of this matter? This issue has been monitored very closely by several agencies throughout the years and they had thought it "dead" due to the overwhelming negative effects involved with Site 1. Logic would dictate that the current airport be enhanced (if needs be) and used as an asset for St. Marys (as per The Department of Industry, Trade and Tourism).

According to the Dept. of the Interior, EPA and initial USACE reports, the chance of being granted a 404 are slim to nil - and if, for some reason, it slides through it will most likely be legally challenged. Wetlands, 100 Year flood-plain, the Rose Basin, one of the most fragile points of the Satilla River, 10 threatened species (listed by the Dept of the Interior, (Dec. 11, 2006), no plans for mitigation (see below CIP report), "no cost to the citizens" as per the non-binding referendum, a multitude of "practicable alternatives" - the only thing that remains a mystery is why and how the City plans to do this. (Additionally, the FAA acknowledges concerns regarding the fact that an airport could not expand on Site 1 and that there are serious public safety issues due to the parallel lines of I-95 and U.S. 17).

U.S. Army Corps of Engineers:
The law places the burden of proof squarely on a permit applicant to demonstrate that the destruction of any portion of a wetland is necessary. If the proposed activity does not absolutely have to be conducted in or near the water, the permitting agency is to begin with the assumption that practicable alternatives do exist. However, in practice, it is not this burden of proof that most often deters potential applicants from pursuing a 404 permit. More often, it is the cost of mitigating environmental damage that provides the greatest disincentive to filling a wetland or altering a waterway.

Mitigation in the 404 context means to minimize the loss of an aquatic site. Mitigation can include:
bulletcreation (making a wetland where there never had been one before);
bulletrestoration (restoring a wetland, for instance by taking out old dikes or levees);
bulletenhancement (making an existing wetland "better"); or
bulletpreservation (purchasing or otherwise protecting an existing high-quality wetland).

The EPA shares the duty of enforcing Section 404. It develops and interprets environmental criteria used in evaluating permit applications, oversees state actions, identifies activities that are exempt from regulation, and reviews and makes comments on individual permit applications. Section 404( c) of the Clean Water Act also authorizes the EPA to override a Corps decision based on "unacceptable adverse effect" on the aquatic environment.

The granting of a permit (including a general permit) is a "federal action" for purposes of the Endangered Species Act. Thus, if a listed species may be affected, a 404 permit request triggers the need for a consultation with the relevant agency (either National Marine Fisheries Service or U. S. Fish and Wildlife Service) under Section 7 of the Endangered Species Act, even on private land.

Processing time for individual permits can range from 6 to 24 months. The time frame is dependant on the complexity of the impacts on aquatic resources, endangered species, archaeological or tribal concerns, and on workload. Processing time may be extended due to endangered species. Applicants requiring an environmental impact statement (far less than one percent) average about 3 years to process.”

The Draft Airport CIP Report (10/30/2009) lists no funds for mitigation efforts/costs.

Further:

According to the report submitted to the City by R,S&H (Reynolds, Smith and Hills, Inc., 10748 Deerwood Park Blvd. South, Jacksonville, FL 32256-0597)

Site 1:
"Drainage of the Site flows southeastward to the Rose Creek Swamp, which ultimately discharges to the Satilla River. There is a sizable floodplain that crosses the northern and southern portions of the Site, as well as a significant amount of wetlands that are dominated by a seasonally flooded, forested system associated with the drainageways.

...potential disadvantages associated with the selection of this Site as the preferred alternative. Those disadvantages include:
. A large portion of the Site has been identified as being within the 100-year Floodplain.
. The Site contains a large amount of wetland areas that would potentially be impacted by construction."

"Wetlands at the Site (1) as the preferred alternative: numerous runway airfield configurations were developed in an attempt to minimize and avoid unnecessary impacts to the wetlands system. Approximately 40 acres of high quality wetlands, 19 acres of medium quality wetlands and 14 acres of low quality wetlands will need to be filled for development. In addition, secondary impacts will occur as a result of disturbance to wetlands not being filled due to the topping and or removal of trees and other obstructions to meet FAA obstruction clearance requirements. Of the disturbed wetlands (not filled) wetlands, approximately 133 acres will be of high quality, approximately 15 acres will be medium quality, and approximately seven acres will be of low quality."

The Department of the Interior has stated that further studies must be undertaken regarding the presence of the Flatwoods Salamander, the Eastern Indigo Snake, the Wood Stork, migratory birds, the rare swallow-tailed kite, Bald Eagles and other fragile species in Site 1; and recommends that another site be selected due to "greater wetlands impact than at the other sites."
Additional statement/reports:

United States Environmental Protection Agency (Oct. 20, 2006):
”Because of predicted wetlands impacts, wetlands should be further assessed to minimize and avoid additional wetland acreage. If unsuccessful, the selection of Site 1 should be re-considered for the FEA or the mitigation must be fully acceptable to the U.A. Army Corps of Engineers (COE), EPA, U.S. Fish and Wildlife Service (FWS) and the State of Georgia.”

Georgia Department of Natural Resources (Feb. 20, 2006):
“Examination of the Flood Insurance Rate Map indicates that sites #1 and #3 encroach on federally designated Special Flood Hazard Areas.”

Regarding Department of the Navy concerns: from Capt. W. E. Stevens, May 5, 2008,
“Although the Navy supports the relocation of the airport, no funding is available for such an initiative and I am advised that the prospects of the Navy supporting a legislative initiative for relocation are remote.”

From the Department of the Interior, Feb 27, 2006
“U.S. Department of Transportation, FAA Advisory Circular No: 150/5200-33A, Hazardous Wildlife Attractants On or Near Airports,” Land use practices that attract or sustain hazardous wildlife populations on or near airports can significantly increase the potential for wildlife-aircraft collisions.”
“Of the three sites being evaluated, two are within two miles of the proposed Broadfield Mitigation Bank. Based on this information, the Service recommends that the proposed airport sites #1 and #3 be reevaluated.”

Also see: http://www.ecy.wa.gov/programs/sea/wetlands/mitigation/banking/

"Under current regulatory programs, parties seeking permits for activities that affect wetlands must first avoid and then minimize those effects. Any remaining damage must be compensated. Historically, the regulatory preference for compensation has been on-site creation, restoration, or enhancement of a wetland. These mitigation efforts have resulted in several smaller, "postage stamp" wetlands that have had limited success in reaching full function potential.
The sequencing of avoidance, minimization, and compensation still applies prior to using credits from any mitigation bank. However, in contrast to traditional mitigation activities, mitigation banking requires that compensation--restoration, creation, enhancement, and/or preservation--occurs before a site is affected by a project. Bank projects are put in place prior to allowing unavoidable impacts by a project. Credits are generated by this up-front activity. Those credits can then be used by the bank sponsor or sold to another party to offset impacts to wetlands that occur in other locations. Again, only impacts that cannot be avoided or minimized are available for compensation through credits from a mitigation bank."

From Reynolds, Smith and Hills, Inc. Final Site Selection Report, April 2005 

“9.4.2.1 Wetlands
Probably the most significant environmental constraint to be encountered in selecting a replacement site for the St. Marys Airport involves potential impacts to wetland areas.
Wetlands have been defined by the FAA in FAA Order 5050.4A, Airport Environmental Handbook, as those areas that are “inundated by surface or ground water with a frequency sufficient to support and under normal circumstances would support a prevalence of vegetative or aquatic life that requires saturated or seasonally saturated soil conditions for growth and reproduction.” As further stated in the Airport Environmental Handbook, Department of Transportation Order 5660.1A, Preservation of the Nation’s Wetlands, provides that Federal agencies:

1. Avoid to the extent possible the long and short-term adverse impacts associated with the destruction or modification of wetlands and to avoid direct or indirect support of new construction in wetlands wherever there is a practicable alternative; 2. Avoid undertaking or providing assistance for new construction located in wetlands unless the head of the agency finds that:
a. There is no practicable alternative to such construction, and
b. That the proposed action includes all practicable measures to minimize harm to wetlands that may result from such use.

There are, however, potential disadvantages associated with the selection of this Site (1) as the preferred alternative. Those disadvantages include:
• A large portion of the Site has been identified as being within the 100-year Floodplain.
• The Site contains a large amount of wetland areas that would potentially be impacted by construction. Prior to construction, coordination would need to occur with the various state and federal agencies to determine the applicable environmental mitigation requirements.
• The Georgia Power Line that run north-south on the Site may need to be relocated.
• The towers located both north and south of the site would need further detailed airspace analysis to determine the extent of their impacts, and may require relocation.”

See also Guidelines on the Establishment & Operation of Wetland Mitigation Banks in Georgia (http://www.sas.usace.army.mil/bankguid.htm) for USACE mitigation bank information.


From Scott Serrit (Manager, Atlanta Airports District Office) via email Wednesday, April 01, 2009 2:13 PM to Mike McKinnon
Cc: ccomer@dot.ga.gov; Larry.Clark@faa.gov; bill.shanahan@tds.net

When speaking of his action regarding the Paulding County Airport:

“We wound up "expediting" an environmental finding (by bending a few rules, damaging relationships with our counterparts in other state and federal agencies, and rendering a finding that might not have stood the test of a court challenge) so that we could honor that earmark 4 months sooner than we had promised to otherwise.” 

These are but a very few of the reports concerning the “potential environmental disaster” that would ensue should the airport be constructed on Site 1.
This proposal would result in the loss of millions of taxpayers’ dollars, bring down the censure of national organizations (and departments that exist to protect fragile environments) and profoundly tarnish the reputation of St. Marys/Camden County.










Thursday, November 1, 2012

St. Marys Binational Peace Garden



On Thursday, November 1, members of City Council, City staff, the St. Marys Tree Board, the St. Marys EarthKeepers and the public held a tree-planting service at the St. Marys Binational Peace Garden. A live oak and a Red Maple (the symbol of Canada) were placed near the American and Canadian flags.
Dedicated on July 4th, 2012, The Peace Garden is the southernmost location on the Binational Heritage Peace Garden Trail that extends from Ontario, Canada, to St. Marys, Georgia. 
Through this initiative, St. Marys has been the focus of international media outlets and plans are being formulated to create Binational Peace Gardens in such locations as St. Simons Island, Savannah and northward along the eastern seaboard. With the opening of each Peace Garden, both in the United States and Canada, St. Marys is profiled. Further programs and events are planned for 2013.
Mayor DeLoughy spoke of the ongoing benefits of the "wonderful media exposure" in terms of tourism and economic development. His remarks were followed by messages of gratitude and congratulations from Canadian Consul (Atlanta) Robert Pengelly and Arlene White, the Executive Director of the Binational Alliance.