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07/04/12
Notification Nonsense
Filed under: Paddle Georgia, Rayonier
Posted by: @ 9:22 am

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
Water Coalition’s
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
Environmental Statutes”.

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.

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