Holland Complaint Re: Hog Crawl Creek

Let me just preface this by observing that that’s how our legal system works. It relies on complaints. Our agents of law enforcement, including our environmental watch dogs, are not supposed to get involved until there is evidence that violations have occurred. And who’s supposed to serve as the trigger? The citizenry at large.

So, it isn’t really a matter of “getting the government we deserve.” It’s a matter of getting the services we demand from our agents of government. Which is why Citizen James Holland has sent a demand letter to the Georgia EPD.

Good Morning Alice*,
I have been monitoring some work Glynn County has been doing in Hog Crawl Creek out near the FLETC turn off on U.S. 17 North. Attached is a google image with coordinates showing the site location. At least about half the work at this site is on or very near a named designated creek (Hog Crawl Creek) a tidal water body.

I first observed this site on 2-11-15 and most of the work appeared to have been completed at least on one segment of the site (see attached photos). On this site visit Glynn County did not have any BMP’S installed to prevent sediment from getting in the creek during the period while they were working in there. The county appeared to have hauled some dirt in to do something to the bank of the creek, however, they installed nothing to keep the transported material(s) from getting in the creek while they were working and it did as my photos will bear out.

One thing I strongly object to is the county did some dredging in the site and just simply dumped the dredge spoil material on the stream bank and in some cases leveled it out using the excavator bucket.

Unfortunately part of this system is a drainage system from west of HiWay U.S. 17 from a long time housing development and it also is close enough to a golf course to possibly receive run off water from the golf course. Over the years all the pollution from those areas appears to have entered Hog Crawl Creek that is tidal in this area. These settled out pollutants in the dredge spoil materials were just dumped out on the stream bank and will run right back into this stream (in rain events) allowing the water flows to carry these pollutants further down stream and into our salt marshes.

Recently, the Coastal Resources Division (CRD) issued Glynn County a Letter of Permission (LOP) to remove materials that are blocking the tidal flows in Hog Crawl Creek just south of the Bell Point Parkway. The LOP stipulates that “All material removed must be disposed of at an appropriate upland disposal site”.

The materials authorized by the LOP for removal are part of the same polluted materials Glynn County dredged from the creek and dumped on the bank beside the creek. It stands to reason that common sense ruled the day when CRD issued this LOP to Glynn County, yet, Glynn County left to its own accord failed to use this same common sense and just dumped these polluted materials right out on the stream bank. To top that off some of this dredged material on the creek bank was dumped about 15-20 yards north of the culverts running under Bell Point Parkway maybe 50 yards from the CRD site authorized by the LOP to be removed and disposed of at a proper upland disposal site.

#1- Why wouldn’t the same conditions in the LOP not be required in a permit that I doubt Glynn County has for doing this work in the beginning. According to my interpretation of the Manual For Erosion and Sediment Control in Georgia (6th edition) Glynn County is not exempted from the Erosion and Sedimentation Act (ESA). Even if Glynn County were exempt, they would not be exempt from the Georgia Water Quality Control Act (GWCQA) where it appears a number of violations of the GWQCA have occurred at this site in this tidal body of water.

#2- The ESA requires that on construction sites (this is one) that BMP’S will be installed either prior to the beginning of construction or in conjunction with the land disturbing activity (LDA). My photos taken on 2-11-15 on my initial site visit show that neither of those rules were used on this site.

#3- I returned to the site later in the day and the county had thrown out some straw that was sparse in many areas, not like the manual calls for (2-4 inches in depth). Hate to say it but the county did not even come close to doing as good a job with their BMP’S at this site as did the contractor at the Brailsford Plantation on St. Simons did when the county paid that place a site visit. I think Glynn County is one of these entities that says “do as I say do, not what I do”/????

The County excavator machine operator used an unauthorized stream crossing on this site by laying down logs and limb debris and used it for a stream crossing. I could not find that type temporary stream crossing in the “Green Book” so it must be considered as an unauthorized stream crossing. I know the Best Management Practices for harvesting timber forbids the use of this type stream crossing. Once the machine operator was finished crossing the stream he simply lined the logs a top each other that makes it appear that a bulkhead is in place. However, under closer scrutiny it appears that he hid the damage caused by the treads and heavy weight of the machine with those logs, Now, is there any other reason for doing this, eventually when it starts raining a lot it will dislodge these logs and cause another stream blockage some place down stream.

Also, when using this crossing damage was done to the bank on Hog Crawl Creek as seen in my attached photos.

My photos will also show where one tree was uprooted and left laying on the stream bank with another tree near by damaged with its roots exposed.

I am requesting that the EPD investigate this site to determine if my allegations are correct as I believe they are. If the EPD agree’s with me regarding my belief’s that Glynn County committed several violations of the ESA, would you please cause Glynn County to come into compliance with all our erosion and sedimentation Laws including getting a LDA Permit for this site. I am also requesting that the EPD do a stream buffer determination at this site due to the disturbed earth on this site and my observations of wrested vegetation along this stream.

Alice, just because Glynn County went into Hog Crawl Creek many years ago and altered the stream hydrology by doing what humans do (Make streams have straight banks) does not make Hog Crawl Creek any less of a stream. I would think all rules and regulations would apply to Hog Crawl Creek as a “LIVE STREAM” with aquatic species living in it.

The photos and documents attached to this are from my initial site visit. I will send the photos from my second site visit (later the same day) and the third site visit on 2-12-15 in a second e-mail.

Thank you very much for your assistance in this very important matter. James Holland, Concerned Citizen.

* Alice Vick is in charge of the local Georgia EPD program office.