Dear Mr. Green,
This letter from the Altamaha Riverkeeper®, Inc. (ARK®)
is requesting your assistance in what we believe to be unauthorized
timber harvesting activities in Kings Swamp in McIntosh County.
According to the McIntosh County Property Records we believe
the ownership of this site is as follows; RTOC Limited Partnership C/O
William Tan, P.O. Box 728, Fernandina Beach, Florida
32034. In our attachments for your convenience you will
find a copy of this firm’s property parcel information.
On 3-24-2010 I did a photo flight along Glynn and McIntosh
County areas with a private aircraft and pilot. On this
date I observed a timber harvesting operation in a swamp in
McIntosh County. Attached you will see photo #1573 indicating
the harvesting of timber on that particular day.
On 4-3-2010 I returned to this site via a flight provided
by South Wings, Inc. which is a non profit organization located
in Asheville, North Carolina (www.southwings.org). South
Wings provides watershed groups like ARK® with flights
to better observe and document their watersheds at no cost
to us.
Following this is the list of photos with explanations I am
sending along with this word document complaint;
#2076 is the photo showing the logging site lined up with
a bridge on I-95;
#2097 indicates the harvesting of timber in extremely wet
conditions causing possible unauthorized rutting. The
skidder trail (road) appears to be in slushy mud;
#2106 indicates what appears to be an unauthorized stream
crossing. This photo also appears to indicate a skidder
trail (road) dredged out in an extremely wet area;
#2112 indicates that this site is an active logging site with
skidder trails (roads) dredged out of the mud on site;
#2127 appears to be a near duplicate photo of #2112 with the
exceptions of it being a closer up view of this area;
#2137 indicates the heavy equipment activity in the skidder
trails (roads) caused rutting and ponding of water;
#3151 indicates the heavy equipment activity in the skidder
trails (roads) may have caused movement of mud (sediment),
ponding and rutting in this area;
#3157 indicates what we believe to be the beginning of a very
bad stream crossing with negative impacts to the SMZ;
#3160 appears to show some form of fuel or oil spill in the
skidder trail (road). There are other photos in this
group that show tree pollen on the water and there is a very
distinct color difference;
#3161 is an extension of photo #3157 indicating what we believe
to be a very bad and unauthorized stream crossing and skidder
trail (road).
#3163 is part of photo #3151 indicating the movement of mud
(sediment) along with possible deep rutting in the skidder
trail (road);
#3172 indicates two skidder trails (roads) side by side in
a stream crossing that indicate no protection for the stream
crossing We also believe this photo indicates the
BMP violation of too many skidder trails (roads). In
other words, it appears that the timber harvesting crew made
no effort(s) at this spot to minimize the number of skidder
trails (roads).
Photo #3172 also shows what we believe to be tree pollen on
the water with a very distinct color variation from photo #3160
(the believed oil spill photo).
Photo #3172 also indicates extremely turbid water leaving
this site;
#3174 is an extension of photo #3172 showing what appear to
be deep skidder trails (roads) on this timber harvesting site;
#3176 indicates another badly designed and implemented stream
crossing. There appear to be deep ruts in the heart of
the stream crossing;
#3178 is an extension/improvement of photo #3176. The
green arrow in this photo appears to point out sand or muddy
water stirred up/caused by the invasion of what appear to be
improper skidder trails (roads). This photo also gives
a better view of this stream crossing that does not appear
to be designed or properly implemented;
#3185 indicates deep ruts and improperly managed skidder trails
(roads)
#3186 is an extension of photo 3185 indicating deep rutting
and a badly managed skidder trails (roads);
The Google Earth Image indicates the location of this site
and I-95.
Mr. Green, I have tried to illustrate through aerial photography
that this site appears to be a most egregious site. The
only site that even comes close to be a comparison site of
badly used BMP’s, roads and stream crossings was the
Thompson Hardwood site in Wilkinson County several years ago. If
I could have seen this site at ground level I believe it would
more than likely be worse than the Wilkinson County site.
As the Altamaha Riverkeeper® and representing my organization
in this matter, I need to let you know that we are deeply concerned
about several things at this site but the two that stand out
the most are; We have great concerns with the alteration of
the natural hydrology of this site due to what we believe to
be the absolute ignoring of all BMP’s in the logging
area. King Swamp is one of the major swamps in McIntosh
County and along Georgia’s coastal zone. We already
have serious inflows concerns into the estuarine area(s) from
these wetland areas and we do not need for this situation to
be exacerbated by improper forestry practices.
Further, I am not any kind of expert at forestry regeneration,
but from what my photos indicate show the remaining stumps
cut at all levels from ground level upward. Page 13 of
The Best Management Practices for Harvesting Timber in Georgia
explicitly talks about regeneration in these sensitive areas.
The ARK® is requesting that the GFC investigate this site
for its timber harvesting practices in Georgia. We explicitly
request that this site get a thorough review utilizing the
15 federally mandated BMP’s as outlined in the forestry
manual.
Under those mandated BMP’s we believe that skidder trails
are forestry roads and this would include stream crossings. We
believe the skidder trails (roads) and stream crossings have
severely altered the natural hydrology of this site and Kings
Swamp. The ARK further requests that if you agree with
us on our assumptions we strongly urge the GFC to start the
process of restoring the natural hydrology back to its natural
state prior to this harvesting event.
As always, I would like to thank you and your staff in advance
for your assistance in this very important matter.
James Holland, Altamaha Riverkeeper® |
