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:
- 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
- Site
1 would impact approximately 59 acres within the 100-year floodplain of a
river crossing the site.
- 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.
- 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:
creation (making a
wetland where there never had been one before);
restoration
(restoring a wetland, for instance by taking out old dikes or levees);
enhancement (making
an existing wetland "better"); or
preservation
(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.
