Sam’s Club (Canal Crossing) Report

Read my full report on this site in the following attached documents.


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Dunbar Creek Sewage Treatment Plant (St. Simons Island)

There has been much discussion here lately about development, land swaps and too much raw sewage for the Dunbar Creek  sewage plant to properly treat and discharge into Dunbar Creek as clean treated waste water.

This discussion reached an almost peak at the last Island Planning Commission (IPC) meeting when a Representative from the Glynn Brunswick Joint Water & Sewage Commission declared that a new development in the North Harrington/Frederica Road area that this development would not be able to hook up to the sewage treatment system on St. Simons.  The reason given that this development would not be able to hook up to the Island waste water treatment system was the fact that Lift Station #2032 in this area was already at peak capacity.

At this time I was already in the process to obtain the Discharge Monitoring Reports (DMR’S) for September which are the records that reflect how well the sewage plant functions on a daily basis.  I had already approached EPD to obtain a copy of the DMR’S for other months at this plant and I was given what is called a netDMR which is a condensed version of the total DMR’S for the plant.  Attached is one page of a netDMR that the EPD is requiring all waste water treatment plants in Georgia to turn in on a monthly basis rather than the old way of turning in the full DMR sheets for any given month at these plants.

I reviewed this netDMR and to say as an advocate for clean water saying I was unhappy with what I was seeing isn’t what I was thinking, even the font was so small I could not read it with my glasses on. I am in no way an expert on sewage plants but I know enough to read parts that are critical to the public’s interest like dissolved oxygen content, the ph levels and fecal coliform bacteria.  There was no way on this netDMR that you, me, EPD or anyone else could tell what happened on a given day in this sewage treatment plant.  From that point I started working towards getting the DMR’S which are called spread sheets by the plant managers.

Through no fault of the management I did not receive the spread sheet DMR’S until yesterday afternoon.  When I opened the DMR for the month of September 2015 I just about went in shock and I am not jesting.  As a clean water advocate I consider the functions of the entire sewage system on St. Simons as being a disaster in September 2015.  Like I said, I am no way an expert on sewage plants but the problems on St. Simons are such that it isn’t just one lift station causing these major problems.  It also appears to me that we are still having major concerns with storm water infiltrating into the sewage system out beyond the plant its self.  Not knowing for certain these high tides may have also caused some difficulty by infiltration into the sewage lines over various areas of St. Simons.

One way to tell how well a sewage plant is functioning is to watch how much influent (raw sewage) is entering the plant each day.  All sewage treatment facilities are designed to treat a maximum capacity of influent each day.  My belief for the Dunbar Creek sewage treatment plant is between 4-5 million gallons per day of influent being maximum.  The Dunbar Creek influent exceeded the 5 million gallons per day (MGPD) 6 days in the month of September 2015.  Of these 6 days one day was over 6 MGPD.

This plant went over 4 MPGD 18 times.  I think it stands to reason that if you have a sewage plant pushing capacity that often there should be some planning and funding to start coming in to head off future problems as well as the present concerns.

Fecal coliform bacteria are what many or most people get concerned about if their sewage treatment plant does not stay within legal guide lines for fecal coliform bacteria.  The EPD considers safe levels for human contact and fecal coliform bacteria is 200 colonies or less per 100ml water.  The Dunbar Sewage Treatment Plant violated this parameter nine (9) times in the month of September 2015.

The Dunbar Creek plant treats fecal coliform bacteria with ultra violet light in which in my opinion is the foremost way to treat fecal bacteria and other pathogens that come in cyst form.  Most plants use Chlorine to treat waste water for bacteria and it does a pretty good job on fecal bacteria but chlorine has a problem penetrating pathogens in the form of cysts.  Ultra violet light penetrates most cysts and sterilizes them so they can not multiply into millions after they reach the receiving stream (Dunbar Creek).

Attached are two DMR sheets with graphics showing what occurred in the plant on a monthly basis in September for influent and fecal coliform bacteria.

There are also two aerial photos of the Dunbar Creek Sewage Plant area.  One photo shows that the treated waste water is discharged mighty close to human dwellings.

The other photo shows the wetlands that are being considered in a land swap deal with Glynn County and the Sea Island Acquisition (SIA).  I am a proponent of the idea that this land swap deal is not a deal that our county should be involved in.  Just look at what I have pointed out in my writing and attachments.  We need these wetlands in the event of a massive sewage spill (God Forbid) at the waste water treatment facility.  Some may not agree with me, but I believe it best for a sewage spill to be diverted into that wetland rather than to the marsh and Dunbar Creek its self.

In conclusion, I believe the Represesentative from BGJWSC made the right decision to disallow the development in the vicinity of North Harrington to hook into the sewage lines until this problem of too much sewage gets fixed.  As a matter of fact, given the fact that there is more and more development on St. Simons and Sea Island that I believe our elected officials should take a hard look at what we have going on right now.

Further more, it can no longer be denied that we have a sewage problem on the island so our officials need to right now start coming up with the funding to do whatever is necessary to end this problem.  If you want to stunt growth, just let this keep going by doing nothing like we have in the past.

Respectfully Submitted,

James Holland

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The Solar Farm on Harry Driggers BLVD. (Classic Major Wetland Fill Project)

This site is in Glynn County and apparently is being condoned by our County Commissioners.  I do not know if these people are permitted or not and from what I am hearing this is also Glynn County public Property that may not have deeded this property over to the Solar Farm Company yet.    James Holland

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8th Street Beach Entrance

From E-mail:

Good Afternoon Karl,

Recently, I was told that someone had cut down a large amount of tree’s on the 8th Street Beach Entrance at East Beach on St. Simons.  Upon reviewing some of my most recent images (Photos) (10-14-15) and one image from 2-23-15 it does appear that someone has removed a large number of tree’s including vegetation on the dunes.  I can not tell when the tree cutting activity took place other than it appears that it did occur according to my photos after 2-23-15.

Attached, you will find a Google Image of the 8th Street Beach Entrance area that I used to locate 8th Street and the site where the damage occurred.  I also created combination images so a comparison view of the site could be easily made.

I am sending this to you with the Glynn County authorities also copied because some of the removed tree’s may have been on Glynn County Property (Accreted Area).  It is particularly disturbing that people would do this to improve on their view of the ocean front and the dune.

If you and the County authorities were not already aware of this area please assign someone to investigate it and please penalize the people that did this. The one area that is all brown appears to have possibly had chemicals used on it.

Thank You in advance for your assistance in this very important matter.    James Holland

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TRACT IX, Cloister Residences East (The Spit)

From E-mail:

Good Evening Mr. Andrews,

I am filing this complaint with you as the Glynn County Local Issuing Authority (LIA).  In my attached photos you will see land disturbing activity, bulkhead on the marsh side construction and bridge building that eventually will be Dune Avenue Extension out to the proposed 8 lot development on the spit.

Also visible in my photos you can see where the silt fence has been torn down and in other areas you can see where the construction crew bored holes for the bulkhead pilings outside the silt fence.  In these areas there is still dirt scattered around the marsh edge with nothing to keep the dirt out of the marsh in a rain event or a high tide from carrying it off site into the marsh.

Also attached is a combination image where I submitted two Georgia Open Record Act (GORA) requests seeking information from the county about this site having the particular permits to authorize any of the building activities I mentioned above.

The Director of the Glynn County Development Authority (Mr. David Hainley) responded to both GORA Requests.  The first GORA Request for information I received back on 10-7-15 and I filed a second GORA Request for the same information because on 10-14-15 I observed the Land disturbing, bulkhead construction and the bridge building had been going on for some time.  I received the GORA Request from the second GORA on 10-19-15.  The reason for the second GORA Request was because I needed to know if Glynn County had issued the Sea Island Acquisition (SIA) any permits for all this activity since receiving the first GORA Response on 10-7-15.  Both GORA Request responses are attached and according to the Open Records Act Response the SIA did not have any permits issued to them from Glynn County to perform the work seen in my attached photos.

Having said and shown you this no permits information I am requesting that you as the LIA either go to this site yourself or assign staff to do the site visit and issue a “STOP WORK ORDER” until permits have been issued by Glynn County to bring the entire SIA site into compliance with all county ordinances including the Dune Avenue Bridge Extension.

Where are the setbacks required by Glynn County ordinance when building near the salt marsh and wetlands (see attached Photos with the bridge built in wetlands and no 15 feet set back)?

Mr. Andrews, I have copied all the Glynn County Commissioners on this complaint because I attended the County Commissioners Work Shop this afternoon where the Sea Island Acquisition was lauded for always obtaining their permits when working these sites and environmentally sensitive areas.  I hope this dispels the myth that the SIA is a good developer and always obtain their permits before starting construction.

Thank you in advance for your assistance in this very important matter.

James R. Holland, Environmental Advocate for Clean Water and Healthy Marshes.



Mr. Andrews, a written response to this complaint is requested.

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Yellow Bluff Creek

From E-mail:

Yellow Bluff Photos attached.  The Altamaha Canal from where it merges with Yellow Bluff Creek northward is in name only.  My photos indicate that it gets its main flush of tidal water from the Turtle River and Yellow Bluff Creek.  In other words, in reality the old Canal is now a fully functioning body of tidal waters and marshes of Yellow Bluff Creek.  This section of Yellow Bluff Creek should now be called Yellow Bluff Creek.     James Holland

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Sea Island Acquisition (SIA) – The Spit

From E-mail:

Dear Mr. Garvey,

I am writing to report and request assistance regarding the above corporation for building what appears to be a bulkhead along the marsh on the lower part of Sea Island.  Recently (9-29-15 photo dated attached) tidal waters came up on several of the lots that the SIA plans to develop and sell.  

On my most recent photo flight (10-14-15) I observed and documented construction activity in the vicinity of the 8 lots to be developed and sold.  It turned out that it appears the SIA may be bulkheading the entire length of the site on the marsh side of the development where the tide waters came in.  Pilings are already in the ground most of the length of the marsh area(s).  I have attached 12 exhibits to better explain what I am writing about below;

#1- Tract IX Cloister Residences East site plan showing the lot numbers and the proposed route out to the 8 lots called Dune Avenue Extension. Lot #8 is highlighted for a reason that will be revealed in my attached photos.

#2- Is a document I received from Glynn Cpounty via a Georgia Open Records Act (GORA) Request telling me that Glynn County has no permits on file regarding roads, land disturbing, etc. on this 8 lot development.

#3- Is a photo of a new bulkhead blocking tidal flows at the end of their bridge at the near by condo’s.

#4- Is a photo that due to the lighting conditions darker than normal, however, it shows the tidal water up on the lots.

#4A- Is a combination photo indicating where part of what appears to be a bulkhead is being constructed and it is located at one of the spots the tide came up onto the site.

#5- Is a photo showing tidal water up on several of the lots including lot #8 that is completely surrounded by tide water.

#6- Shows lot #8 totally surrounded by tide water and on this day it is an island/hammock that should be difficult to develop without special permitting from the State and the USACOE.

#7- Shows lot #8 again surrounded by tide water with the tide up inside the lot.

#8- Another photo show tidal waters up on the lots.

#9- Shows what appears to be ongoing bulkhead construction.

#10- This is another photo image of what appears to be bulkhead construction.

#11- Another angle showing what appears to be on going bulkhead construction.

Mr. Garvey, you already have one complaint regarding the permitting of the bridge on this site being constructed in waters of the State and United States.

I am requesting that you investigate this site to determine if a Clean Water Act (CWA) Section “404” Permit is required for what I have shown you in my exhibits.  If a permit is required and the SIA does not have a permit for this construction please request a stop work order until they become compliant with the laws of the United States.

I would like to thank you in advance for your assistance in this very important matter.

James R. Holland, Environmental Advocate

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July – September Photos!

Here are the photos taken between July and September 2015!

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E-Mail Response (Cannon’s Point)

From E-mail:

Mr. Burgess,

This e-mail is a response to an e-mail you sent Mr. Woodward on 5-5-15 regarding some of my complaints about the Cannon’s Point Site.  I obtained this e-mail from the many files I received when I placed a GORA Request for the CRD files on Cannon’s Point.  In particular, this e-mail is responding to what I believe is Coastal Resources Division (CRD) allowing just about anything anyone wants to work from while working on projects in our public resources (Marshes and Estuaries).

Fortunately for me I only have records from the Glynn County area and there are five other coastal counties that I do not monitor the marshes in very often.

If our local legislators are wondering why I always copy them, this is my answer; As our representatives I believe it is very important for them to see how the tax payers money is used to protect our natural resources.

In your e-mail to Mr. Woodward, “In Mr Holland’s (name spelled incorrectly) photos you will see such temporary placement of the marsh mats.  These are similar to the types of mats used by GEORGIA POWER and other entities that obtain authorizations to conduct projects in the marsh”.  Yes they do and the results are almost the same, the marsh underneath this matting gets destroyed because the matting was not properly sized for the soil types to be worked in.

My photos also demonstrate the Lance Toland site where he worked in the marsh from poles using heavy equipment.  Unfortunately, that site is like the Cannon’s Point site, CRD inspectors could find nothing wrong with it either.

On the GEORGIA POWER site in my photos I e-mailed you and requested if you would please go out there and ask them to restore the marshes they destroyed.  You know what, “YOU DID NOT EVEN BOTHER TO RESPOND TO MY REQUEST” and all I asked of you was to ask them to restore the area because they are exempt from the marsh Act.  No, the marsh along Sea Island road does not appear to have been repaired either.

I would like to make a suggestion at this point; when someone is going to actually work in the marsh, please ensure that the proper equipment is used.  

Yes, I know that CRD is going to say that the marsh may restore its self over time.  Yes, maybe it will but it does not have to be this way, all the CRD staff are paid to be protector’s of this public resources and until it grows back the way it was we (the public) lose the daily benefits of that section of marsh.  The marsh does not belong to CRD, even though there are times that CRD staff acts like it does. Well, it is not and we expect CRD to do what it is paid for and protect the property of the people.

I have not received all the Georgia Open Records Act (GORA) requests from other sources and when I get the rest of them I am expecting to file more complaints about this Cannon’s Point site.

Respectfully Submitted,  James R. Holland

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“The Spit” Erosion Concerns

From E-mail:

I put together the attachments to this e-mail for a good reason.  These images do not indicate but show that erosion on the spit is taking place at an alarming rate.  These images starting on 11-29-13 show the erosion from the spit in just 21 months with no major weather systems.  This erosion starts at the southern groin and works its way all the way down to the tip end of the spit.

I try to raise this issue every now and then because I feel like East Beach and the northeastern side of St. Simons will bear the brunt of the damage if this erosion continues at this rate.  The erosion is moving south and westward towards the north end of St. Simons where Sea Island Road is connecting with Frederica Road.  I have gotten some evidence already that the eroded sands are entering the marshes on the western bank of Black Banks River.

I do not understand people, everyone that lives along and near the shoreline and marshes of the east side of St. Simons should be watching all the activities that are occurring on the spit and the SIA.  It is my understanding (hear say) that the SIA has already gone to Thomas and Hutton for an estimated cost to put in a groin along the spit shore line some place.  The SIA has already shown us that they will do almost anything to protect their own interests and care less about who it may hurt.  Under those conditions the politicians and the people of St. Simons better wake up and soon.      James H

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