Scoping Comments - Jasper Ocean Terminal Environmental Impact Statement
The following are our official scoping comments submitted to U.S. Army Corp of Engineers -Charleston District for the Environmental Impact Statement for the Jasper Ocean Terminal on the Savannah River.
The Georgia Conservancy is pleased to provide scoping comments for the Jasper Ocean Terminal (JOT) Environmental Impact Statement (EIS), on the Savannah River in Jasper County, South Carolina.
Founded in 1967, The Georgia Conservancy is one of Georgia’s oldest nonprofit conservation organizations. Working to protect our coast for 50 years now, the Georgia Conservancy is a statewide organization whose goal is to develop practical conservation solutions for protecting Georgia’s environment. We reach policy decisions with a vision statement centered on a Georgia where people and the environment thrive.
The magnitude of the proposed terminal, at this critical location, opposite Elba Island and immediately northeast of downtown Savannah, Georgia, is of significant concern. The comments and questions in this letter are derived from our Coastal Policy and are based on the development and operation data prepared by the Corps of Engineers (COE) for JOT and the Savannah Harbor Expansion Project (SHEP). The issues presented in this comment letter center on the project’s operational and cumulative impacts. The JOT is a very large project that must be thought of as being at the interface of several functioning ecosystems. The riverine and saltmarsh ecosystems, where the JOT is located, provide a nursery for commercially and recreationally valued species of fish, shellfish, and other wildlife. This area is a valuable ecological and recreation resource.
The States of Georgia and South Carolina have stewardship roles with respect to coastal marshlands, waterbottoms, and estuarine systems that are critical to preserving the integrity of the tidal freshwater wetland and salt marsh ecosystem and the public’s enjoyment of our common coastal treasures.
These coastal land and water resources provide habitat for more threatened and endangered species than any other region of the state. The sum of these resources is a highly integrated, interdependent ecosystem that is vitally linked to Georgia’s economy and quality of life. It is essential to promote a healthy, resilient, and diverse coastal ecosystem that can endure natural and human disturbances, continue to perform its functions, and support self-sustaining populations of native fish, birds, wildlife and plants.
- How will dock and construction and channel alterations affect the spawning habitat of fishes, and will it force utilization of less desirable spawning habitats for fish such as the shortnose sturgeon (Acipenser brevirostrum)?
- The project includes dredging of 439 acres of navigable waters and has potential impacts to 54 acres of open water. In addition to these direct impacts, will there be changes in flow patterns that alter hydrologic function? How are impacted buffers, cleared areas and wetland impacts to be offset with mitigation? Will mitigation be made in the project area (e.g. within seven ) miles)? How will floral species of concern be mitigated?
- This project has more than seven miles of access roadway that traverses the southern edge of the Savannah National Wildlife Refuge complex (SNWR). The SNWR serves as a stopover for thousands of migratory birds annually. Many of these birds are already on the threatened or endangered species list, such as the bald eagle (Haliaeetus leucocephalus). Other birds that utilize the Savannah Wildlife Refuge include the swallow-tailed kite (Elanoides forficatus), purple gallinules (Porphyrio martinica), anhingas (Anhinga anhinga), and more. How will this project impact the critical habitat located along the rail and roadway corridors that access the main terminal site, and adjoining lands held in conservation easements?
- How will rail and roadway access (culverts, bridges, and detention) maintain natural water flow patterns in the SNWR? How will operations related to wildlife management be altered by this project? Will and adaptive management and monitoring plan be developed related to species of concern at SNWR?
- Will a comprehensive stormwater management system that addresses water quality and quantity be developed for JOT? How will stormwater management at the JOT supplement the freshwater areas of the former rice impoundments?
Responsible planning for growth and conservation of sensitive coastal lands is essential to preserving the integrity of natural coastal systems and, in turn, the health and welfare of coastal residents.
- In what ways will the project benefit the local economy? In what ways will it have economic costs (public, private and ecosystem services)? How will the Jasper County Comprehensive Land Use Plan (CLUP) be updated to reflect the conservation, residential, recreational and industrial uses planned around this project? Will a local planning study guide the project related industrial development so it provides more focused economic benefits to Jasper County? Will consideration be given to terminal workforce housing and transport?
- Has consideration been given to creative use of conservation resources (easements, transfer of density rights, development boundaries, etc.) in the preservation of sensitive habitat and buffering of the site? Compatible use buffers at nearby Fort Stewart and Townsend Bombing Range have served conservation efforts well.
- What lessons from the Savannah Harbor Expansion (SHEP) project adaptive management process will be used to mitigate environmental impacts on this project?
- What specific traffic, light, and sound mitigation and operational measures will be taken to protect surrounding properties and wildlife?
- How will the terminal operations (e.g. noise, lighting, etc.) address migration patterns, foraging and local nesting areas for threatened and endangered bird species?
- Every water body has a carrying capacity in terms of point and nonpoint degradation, bank erosion and safe navigation. How will this this project and SHEP impact nearby tidally- influenced freshwater wetlands and marshes? Will salinity levels increase or remain constant with the models used in the SHEP EIS? If upstream salinity increases, what will be the effect on fish assemblages and wetland distribution?
- This project is across the river from Elba Island facility. Will there be a projection of ship traffic flow for this project and the other operations in the Savannah Harbor? How will water and air pollution and accidental spill contingencies be planned for at the JOT?
- Will dissolved oxygen monitoring for SHEP be extended beyond the 10-year period, or modified to account for the JOT construction and operational impacts? Will this project require implementing of additional Speece Cone bubblers to sustain appropriate dissolved oxygen levels?
- How will the data from the SHEP EIS and adaptive management monitoring process be used in the JOT EIS analysis? How will the information be updated and incorporated into the dissolved oxygen mitigation, effects on tidally influenced wetlands, and species of concern such as the native striped bass (Morone savartilis)?
- What will aquifer and groundwater resources be impacts be for this for this project, when considered with SHEP?
- How will sea level rise considerations be incorporated into the site design?
- Potential harm to marine mammals from terminal operations is a critical limiting factor that must be respected. How will the operational and contingency plans for the JOT address fisheries and marine mammal (right whale and manatee) impacts?
Coastal Georgia’s rivers and estuaries have historically served as highways for maritime transportation and trade. Future improvements to navigation channels to support port infrastructure and operations must not come at the further expense of estuarine habitat.
Rigorous application and coordination of existing laws and regulations are critical to preserving the coast’s ecological integrity as human activity expands.
We look forward to working with federal, state, and local agencies to address the issues in this
letter and the other findings of the Draft EIS.
For any questions regarding our official comments, please contact Georgia Conservancy Coastal Director Charles McMillan at firstname.lastname@example.org