Resources Worth Millions of Dollars Annually Are at Risk

1. In November 1997, a workshop was held by fisheries experts on the issue of fisheries research as it relates to the flow and quality of fresh water from coastal rivers into the intertidal areas of Georgia.

2. The overwhelming conclusion, for many reasons, was that the scientific understanding about these relationships is insufficient and that some of these resources are already at risk.

3. Even without considering other ecological implications, the productivity of commercial and recreational fisheries (valued at more than $600 million a year in regional business activity and employment) may be threatened by further withdrawal, contamination, and flow disruption of surface water in the five river systems on the coast.

4. The quality of water in coastal rivers is also not completely known. A recent EPA report on watersheds indicates that critical information is lacking about water quality in all coastal Georgia rivers. However, from limited sampling, we know that 60% of state waters fail to meet federal standards.

5. More than half of the state's 85 fish-consumption advisories apply to coastal Georgia, most due to mercury contamination. This presents a serious risk to human health and to the businesses that depend on natural resources.

6. Marine research specialists and members of the fishing industry are increasingly concerned about permitting of water withdrawal and discharge activities affecting these rivers until further research is completed.

7. Indications of threats to water resources include:
  • Loss of wetlands resulting in greater extremes in flow conditions, high and low.
  • Increasing salinity and reduced habitat areas.
  • Increasing watershed development producing more nonpoint source pollution.
  • Insufficient monitoring of water quality.

BLUESQUAREIn the Absence of Adequate Scientific Information
In the Absence of Adequate Scientific Information Under Current Permitting Practices, the "Burden of Proof" in Permitting Decisions Rests on Those Who Believe They Will Be Adversely Affected, Usually Local Residents and Businesses

1. The situation with fisheries is not unique. In many instances when environmental permits are applied for, the effects of proposed activities (e.g., water withdrawal) on existing public interests cannot be reliably predicted, yet risks to the public interest are significant.

2. In such cases, the practice has been for EPD to evaluate only the most immediate, direct, and short-term effects resulting from the proposed activity, often based on intuitive judgment.

3. Long-term, cumulative, and indirect or interactive effects of proposed actions are complex and usually ignored, exposing the public to unjustifiable risk to benefit a single permit applicant.

4. If any segments of the public believe that these effects are significant and adverse to the public interest, they must carry the cost of analyzing consequences and presenting their case to EPD.

5. At present, when permits involve coastal resources, EPD may ask staff of the Coastal Resources Division (CRD) of DNR for an opinion, but they are not required to do so. Moreover, EPD has great discretion in the interpretation and use of the CRD opinion in making permitting decisions. In at least one important case of permit review, EPD minimized the implications of significant CRD continents, issuing a "letter of concurrence" to the applicant despite CRD's concerns to the contrary.

BLUESQUAREInterrelationships Between Surface Water and Groundwater
There Are Important Yet Poorly Understood Interrelationships Between Surface Water (Rivers & Streams) and Groundwater.

1. One reason why fisheries resources are at risk is likely to be the significant loss of freshwater upwelling from groundwater sources into coastal rivers and estuaries. Excessive withdrawal from the principal aquifer is believed to have gradually produced increasing salinity in intertidal fisheries habitats over the past several decades, reducing their capacity to support a variety of species. Research about these critical interrelated effects must be conducted and results must be consistently applied in permit-review decisions as soon as possible.

2. In 1998, a legislative study committee made recommendations for groundwater research and related water supply issues in the coastal region of Georgia. Of the $14.5 million in research that is recommended, only about 1% ($158,000) of the work is related to surface water. This amount is grossly inadequate to provide the answers to vitally important questions affecting the productivity and diversity of coastal ecosystems, including commercial and recreational fisheries.

3. The interactive influences of surface water and groundwater must be determined to enable responsible, accountable permitting decisions. The use and protection of our coastal resources depend on the study and research of these relationships.

BLUESQUAREWhat Can Be Done to Resolve These Issues?
The Center suggests that concerned citizens urge coastal legislators and the Board of Natural Resources to form a comprehensive study committee on water resources. This is vital to determining research and regulatory measures needed in support of comprehensive, accountable watershed-level management of Georgia's surface and groundwater resources.
Note: A Stakeholder Committee was created by the General Assembly this year. (SEE: Legislative Update in Spring 2001 Newsletter)

State Water Plan Study Committee was formed in 2001 after this position was taken by the Center in 1998; committee will report later this year.

1. Elected officials must recognize the urgency of supporting critically needed environmental research. Due to the lack of sufficient information available to support key decisions, failure to understand the consequences of issuing water withdrawal and discharge permits could cost Georgia millions of dollars a year and thousands of local jobs in tourism, fishing, and the seafood business.

2. Moreover, water supply and public health are at significant risk. The state must take action to support this research in order to protect our citizens and their quality of life.

3. Action is also needed to strengthen water permitting laws and regulations. Legal requirements for permitting should be amended to include:
  • Prohibition from issuing permits when information about impacts is inconclusive (proof of no significant impact must be based on sound science and risk evaluation at the watershed level).
  • A procedure for independent, objective evaluation of science used in permit review to improve reliability and accountability of permitting decisions A PEER REVIEW PROCESS.
  • Legislative language that is as specific as possible to minimize the use of administrative discretion and to prevent subjective, erratic, and preferential enforcement of environmental safeguards.
  • Mandatory evaluation of existing economic and social benefits of natural resource(s) potentially affected by proposed activities and the level of impact
  • Permit review based on systemic level of analysis (aquifer, watershed, ecosystem, etc.).
4. Please give these issues the attention they deserve by urging your elected officials and the Board of Natural Resources to create a study committee and to strengthen review requirements for water permitting decisions.

5. We appreciate being kept informed about your opinions on these issues. If you would like to receive updates, please inquire about becoming a Center member.
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