Life is getting in the way of my blogging again. The lazy days of Paddle Georgia are behind me and the realities of work and my other obligations are setting in. I continue to research the Rayonier discharge issue. There is a deadline looming for public comment on a request by Rayonier to amend the current consent order relating to the discharge. This got me to thinking about how the public would be aware of the issue and even know that there was an opportunity to comment.
What I found is disturbing and illustrates one of the reasons we need to support our Riverkeepers. One of the first things I looked at on the EPD website was a section entitled “what’s new at EPD“. Presumably this would give me a snapshot of current issues. The first and most current entry was on the “Ogeechee River Fish Kill-May 2012“ which was posted June 6, 2012. I found this somewhat encouraging as the Ogeechee River and the discharge of King America Finishing top the Georgia
Dirty Dozen list. I plan to tackle the Ogeechee issue in future posts but do not want to divert from fully exploring the Rayonier issue. The what’s new section appears to cover about the last year and I could find no reference to any requested changes to the Rayonier consent order here. I decided to look under the “Rules and Laws” Section and came across”391-1-3 Public Participation in Enforcement of
I ask that my readers bear with me as I will now be analyzing what I call “reguspeak”. Reguspeak is that language that is used to document the laws of our land on a federal, state and local level. I deal with this language extensively in my day job as an Import Director for CEVA Logistics while trying to decipher the laws and regulations impacting the import and export of goods to/and from the United States. The opening paragraph states “1) The Environmental Protection Division shall issue notices of proposed or final administrative orders and proposed or final administrative consent orders as required in applicable statutes and rules of this State.”. My interpretation of this tells me that a proposed amendment to a consent order may not even require public notification. I read on. When something does require public notice under thus statute, the notice is to be made as follows: ” The notices specified in (1), (2) and (3) above shall consist of posting on the Environmental Protection Division’s Internet Web Site and, for orders pertaining to facilities located in counties with populations of less than 10,000 persons, written notice provided to local newspapers and radio stations. Notices shall be mailed to persons requesting such for an annual fee of fifty ($50) dollars.” This solidifies that the web site is probably the best resource for this information. I find the second part rather humorous, ” for orders pertaining to facilities located in counties with populations of less than 10,000 persons, written notice provided to local newspapers and radio stations.”. I checked, of the 159 counties in Georgia only 20% have a population of under 10,000 people. I welcome opposing views but I doubt a radio spot has ever been devoted to the issuance of an EPD consent order and invitation to public comment. Local and even regional newspapers struggle for their very existence in the internet age. In the case of Rayonier which is located in Wayne County (population 30,099 according to the 2010 Census) a consent order would not have to be published in the local paper. Undaunted I continued to search for any reference to Rayonier’s request for an amendment to the existing consent order. I found a section entitled “Events, Notices and Announcements” and according to the EPD we can “Use this section to learn about public events and to find information on various
topics including proposed rule making and permitting. This includes notices of
public hearings, public meetings and the collection of public comments.”. Great, I am getting closer. I did eventually find the listing which read as follows:
Facility: Rayonier Performance Fibers, LLC/Jesup Location: Wayne County Order Number: AMENDMENT # 3 TO
EPD-WQ-4837 Cause of Order: Revision to original order from March 6,
2008 to remove requirements for installation of O2 delingnification bleaching
system on C-Mill Requirement(s) of Order: Alternative
technologies for color reduction for production of ultra high-purity cellulose
specialty fibers are being substituted and Rayonier shall install appropriate
equipment in C-Mill screening o Settlement Amount: None Date
Notice Posted: June 20, 2011 Comment Period Closes: July 20, 2011
You have to search for the information you cannot browse and if you put “Rayonier” in any of the facility searches nothing comes up. I had to look at all listings for Wayne County to find what I was looking for. Even if you find this there is no detail on what Rayonier is proposing so anyone wanting to comment with any amount of credibility would have to still do further research and possibly request documents publicly available from the EPD.
I know this post has been a bit “in the weeds” but there is a point here. How on earth is the layperson supposed to know about what the EPD in working on and what those who seek to discharge effluent into our rivers are up to? This is one of the core reasons that we must continue to support our Riverkeepers and the Georgia River Network. Without their vigilance and “getting down in the weeds” public awareness to many of the issues effecting our rivers would be nonexistent. Public notifications by the EPD are an abysmal failure based on my findings and do not support the very foundations of the unalienable rights we celebrate on the day I post this entry.
We explored the Rayonier discharge into the Altamaha a bit and discussed manufacturing in the US in previous posts. The Altamaha Riverkeeper and Georgia River Network have provided me with some great source material. I have read through some of the documents and have learned a lot over the last week. The very first thing I would like each of my readers to do is go to the Rayonier website. Watch the video at the top of the page in its entirety. There have been very few actual comments posted so before I go any further with this discussion please take a moment to watch the video, read my previous posts and review the material related to the Rayonier discharge on the Altamaha Riverkeepers site.
I would next ask that you compare the video from Rayonier website and what is said to what is actually happening at the Jesup plant and to this news video. If you were a Paddle Georgia participant this year please comment on your impressions while paddling through this area. I have more to share but I would like some dialog to be generated by this entry before continuing the discussion. My hope is that this discussion will lead us to raised awareness and result in a focused, informed letter writing campaign to EPD, Rayonier and others to clean up the discharge.
I have been researching the Rayonier discharge issue since my return from Paddle Georgia. Deborah Sheppard of the Altamaha Riverkeeper and Chris Manganiello at The Georgia River Network have been awesome in answering my numerous questions. I now have a copy of the discharge permit issued to Rayonier back in 2001 to peruse. The issue is complex in my view. One option to eliminate the discharge into the Altamaha River would be to close the plant. The discharge would stop immediately and presumably the ecosystem would start to heal downriver. Of course approximately 800 people would be out of a job and the City of Jesup would lose it’s largest employer. The ripple through the local economy would no doubt be harsh and Jesup would suffer beyond already tough economic conditions. I don’t consider this an option even for a moment, people were great to us in Wayne County, they deserve the opportunity to prosper and I don’t think anyone on either side of the argument wants this to happen or really sees it as a viable solution. In one way this creates common ground for opposing points of view.
The reality in our country is that many companies have decided to move production offshore. Rayonier has been in Jesup since 1954 and I am sure that the availability of their primary raw material (wood) from local land holdings is one big reason. From an environmental perspective moving the factory to another country may conveniently solve the issue locally but from what I have read the environmental issues don’t go away they just impact someone else. I have ordered a copy of “The River Runs Black: The Environmental Challenge to China’s Future” to further explore the impact of economic growth with little or no consideration of the long term environmental impact. It comes as no surprise that a great percentage of the goods we purchase are now made in China. The goods we use everyday have to be made somewhere and we know that rarely is that somewhere within the confines of the United States of America. Even the ball caps we proudly wear announcing our participation in Paddle Georgia are made somewhere else (Vietnam this year, Banlgladesh in 2011). China’s economic growth has come at a great environmental cost. I bring this up here because I heard several people talking about boycotting products produced by the Rayonier plant. Looking at what the plant produces this would probably be very difficult to nail down since it does not appear that the material produced is what goes directly to the consumer. You can go here to get more info from the Rayonier website specific to the Jesup mill.
It also is not the answer in my opinion because if the Rayonier facility did not exist in Jesup Georgia or somewhere else in the US it would exist in some other country with environmental laws inferior to our own. The river discharge problem would still impact someone.
This is why we must “think globally and act locally” as we struggle to balance economic stability with care and respect for the environment. Rayonier’s discharge is a problem, a big problem but my other experience with the Altamaha was a river that was pristine and remarkably free of the trash we are so used to seeing on many other rivers in Georgia. My journey to understand continues.