Okefenokee River Gauge Data Letter 20 Feb23

Warnell School of Forestry
and Natural Resources

Forestry, Fisheries and Wildlife,
Natural Resource Management and Sustainability,
Parks, Recreation and Tourism Management
180 E Green Street
Athens, Georgia 30602-2152
TEL 706-542-2686 | FAX 706-542-8356
February 20, 2023
www.warnell.uga.edu
Georgia EPD and Interested Parties

Re: Appropriate streamflow data for assessing how the proposed TPM LLC mine
groundwater withdrawals will affect Okefenokee Swamp Hydrology
We, the undersigned research hydrologists of southeastern universities, find that the
appropriate USGS gage for assessing hydrologic effects on the Okefenokee Swamp of
consumptive groundwater withdrawals by the proposed TPM LLC mineral sands mine is
gage #02228500, North Prong of the St Marys River at Moniac, GA. Further, we find gage
#02231000, St Marys River near Macclenny, FL, chosen by GA EPD, is inappropriate for such
analysis.
The salient hydrologic question about the mine is the degree to which it will alter the
hydrology and associated ecosystem benefits of the southeastern portion of the
Okefenokee Swamp. The North Prong of the St Marys at Moniac exclusively drains the
southeastern portion of the swamp plus its contributing areas from Trail Ridge, and
previous research has demonstrated very high correlations between flows at this gage and
swamp water levels monitored by the USFWS. The geographic position of this gage is ideal
for analyzing potential effects to swamp hydrology of consumptive ground water
withdrawals beneath Trail Ridge.
Conversely, the data from the USGS gage at Macclenny, FL are inappropriate for direct
analysis of how consumptive groundwater withdrawals by the mine will affect the
hydrology of the swamp. The Macclenny gage drains a basin that is 4.4 times larger than the
Moniac gage. Three-quarters of the area draining to this gage is in relative highlands of
north central Florida. The hydrologic inputs to this basin and the hydrologic behavior of this
basin are in no way similar to that of the southeastern portion of the Okefenokee Swamp.
Furthermore, the sheer size of the basin and its flows at this gage will mask the effects a
fixed withdrawal would have where the river exits the swamp.
Conclusions drawn from consumptive flow removal from the Macclenny, FL gage data
cannot be applied to the question of how the Trail Ridge groundwater withdrawals will
affect the swamp. To assess this question, it is necessary to use flow data from the Moniac
gage.
Commit to Georgia | give.uga.edu

An Equal Opportunity, Affirmative Action, Veteran, Disability Institution
We thank you for your attention to this important matter. We know you agree it is critical
to apply the best possible data to this resource management decision affecting Georgia.
Sincerely,
Signing for:
C. Rhett Jackson, John Porter Stevens Distinguished Professor of Water Resources, Warnell
School of Forestry and Natural Resources, University of Georgia
Larry Band, Ernest H. Ern Professor of Environmental Science, School of Engineering,
University of Virginia
Stephen Schoenholtz, Director and Professor, Virginia Water Resources Research Center,
Virginia Tech University
Kevin McGuire, Professor of Hydrology, College of Natural Resources and Environment,
Virginia Tech University
Daniel L. McLaughlin, Associate Professor of Hydrology, Department of Forest Resources &
Environmental Conservation, Virginia Tech University
Diego Riveros-Iregui, Associate Professor of Watershed Hydrology, Department of
Geography, University of North Carolina at Chapel Hill
Ryan Emanuel, Associate Professor of Hydrology, Nicholas School of the Environment, Duke
University
Matt Cohen, Professor of Water Resources, School of Forest, Fisheries and Geomatics
Sciences, University of Florida
Courtney Siegert, Associate Professor of Hydrology, College of Forest Resources, Mississippi
State University
Luke Pangle, Associate Professor of Hydrology, Dept. of Geosciences, Georgia State
University
Todd Rasmussen, Professor of Hydrology, Warnell School of Forestry and Natural
Resources, University of Georgia

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Warnell School of Forestry

and Natural Resources

Georgia EPD and Interested Parties

Commit to Georgia | give.uga.edu

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