Serious Allegations Against Sabal Trail

This post by WWALS  poses some serious allegations that Sabal Trail knowlingly withheld information from FERC that seems to be critical and which seems might be detrimental to their efforts to obtain a permit for their controversial  pipeline.

Although this post is much longer than ordinary, it contains a great deal of information that is pertinent to the Santa Fe River basin.

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On January 31, 2015 at 07:28PM, jsq at WWALS Watershed Coalition published the following article:

300x388 Sabal Trail proposes to go through an area riddled with these conduits, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015
A Suwannee County, Florida landowner points to
newly-discovered connections between springs under rivers

and to other well-known springs
Sabal Trail ignored, adding:

Note that the undersigned is a lay person attorney and NOT a karst expert. Basic research revealed the information contained herein and the omission of this infonnation by Sabal’s purported karst experts
should raise serious questions as to the credibility of Sabal’s filings.

Filed with FERC 29 January 2015 as
Accession Number: 20150129-5192
,
“Supplemental Information / Request of Edwards & Ragatz, P.A. under CP15-17. Supplemental Comments of Proposed Intervener, Thomas S. Edwards, Manager, TSE Plantation,
LLC Opposing Portion of Sabal Trail Route and Related Motion to Accept Late Comments”,

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Docket No. CP15-17-000

Sabal Trail Transmission, LLC

SUPPLEMENTAL COMMENTS

OF PROPOSED INTERVENER,

THOMAS S. EDWARDS, JR., MANAGER,

TSE PLANTATION, LLC

OPPOSING A PORTION OF SABAL TRAIL ROUTE

And

REALTED MOTION TO ACCEPT LATE COMMENTS


300x388 Two Reasons, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

Ladies and gentlemen,

Undersigned respectfully requests that this body accept these late comments.

These supplemental comments are supplied for two reasons:

  1. To attach a document that was discussed, but accidentally  omitted, in the undersigned’s original comments; and
  2. To address comments directed to documents Sabal failed to file until after the deadline for comments had passed.These comments
    are directed to glaring flaws in Sabal’s representations contained
    in those late filed documents.

Attached hereto as Exhibit “A” is

a press release from
the Suwannee River Water Management District

that was discussed in
the timely filed comments. The press release confirms that testing
recently performed in the vicinity of the proposed pipeline route
shows that numerous springs are interconnected by large aquifer
filled underground karst tunnels. This is also relevant to the
supplemental comments below addressing the purported karst study
done by Sabal. The studies filed with FERC will prove to be so
clearly flawed as to raise questions as to why.

1 The comment period ended on December 24, 2014 and Sabal supplied new filings on December 30, 2014


300x388 Sabal failed to address ANY of the major springs, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

The comment period for undersigned was until December 24, 2014.
Undersigned timely filed comments on December 22, 2014. On December  30, 2014 Sabal filed extensive new materials, including two documents purporting to address the potential for adverse impact on sensitive karst, springs and the aquifer in the vicinity of the pipeline. These documents are deceptive and contain serious omissions.

I am the owner of the TSE Plantation, LLC d/b/a Echo River  Plantation which is a 912 acre plantation with between 2 and 2 1/2 miles of frontage on the Suwannee River. Sabal Trail plans to cross my propeity with their pipeline. The plantation abuts the Suwannee  River State Park.2
The pipeline will cross the Suwannee River at the
location where the Park is on one side of the River and Echo
Plantation is on the other.

In support of this crossing (and other crossings) Sabal filed
voluminous materials claiming  to address  all sensitive karst areas
in proximity to the proposed path. See Sabal filings on December 30,
2014 entitled:

  1. Characterization of Karst Sensitive Areas Relative to the
    Proposed Route of the Sabal Trail Natural Gas Transmission Pipeline
    in Florida; and
  2. KARST MITIGATION PLAN.

Sabal failed to address ANY of the major springs — or
sensitive karst—in the area of the Suwannee River crossing in
their Karst materials. This is a glaring oversight — their own
materials state that they should avoid areas such as this because of
the confluence of a number of MAJOR springs A having springs in
this immediate area leads to large underground water filled tunnels
and caverns in the immediate area of the river crossing where they
will do the HDD. These springs make this
crossing ill-advised under their own analysis.

2 I am also a Life Member of the State Park system.

300x388 Falmouth dye trace reveals unknown connectivity, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015I am attaching a SRWMD press release (See the attached document entitled

“Falmouth Dye Trace”
— Exhibit
“A”) where the SRWMD, DEP and FGS recently tested these  springs and proved they are all interconnected by tunnels and other water conduits 7 the interconnected tunnels are both north and south of the pipeline meaning they will be drilling right through an area with interconnected underground tunnel systems jeopardizing the aquifer, these springs and the karst formations — this is acknowledged in their own documents regarding karst structure
— but they failed to even identify or discuss these springs in these documents while representing to FERC that they were addressing all springs in the vicinity of the proposed pipeline. Why would
these major — well-documented — springs be omitted?

300x388 NUMEROUS major springs at Suwannee and Withlacoochee Rivers, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015
I’m attaching a document from the Sabal filing entitled “pages from Karst Sensitive Areas” — Exhibit “B”— this has 3 pages of excerpts from Sabal’s completely flawed and misleading document:

  1. a picture supposedly showing the “major springs” in
    the area where the Suwannee and Withlacoochee come together —


    600x776 No springs identified by Sabal Trail at confluence of the Suwannee and the Withlacoochee, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

    NOT ONE SPRING IS SHOWN NEAR THE “V” where the rivers
    join — compare that to the SRWMD map showing springs in that
    immediate area Exhibit “C”


    there are two magnitude 1
    and four magnitude 2 springs and two magnitude 4 springs all less
    than 2 miles from the proposed pipeline crossing

    — these were
    omitted from Sabal’s materials;

  2. The second page claims to identify all major springs the
    pipeline will go near — the distance from the springs to the
    pipeline shown on this page range from 1.1 mile to almost 20 miles


    600x776 Distance from each Major Spring, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

    NONE of the above springs are identified or discussed and
    all are less than 2 miles from the proposed pipeline and some within
    1/2 mile; and

  3. The third page shows “fracture traces” that have
    been documented at the proposed Suwannee River crossing for the
    pipeline —


    600x776 Fracture Trace Analysis Figure 3, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

    that is because there are identified
    “fractures” in the earth — knowing the springs are
    in the area this means there are probably underground aquifer
    tunnels at this exact location — that is what the fractures
    are. This is further confirmed by the recent dye trace testing

The proposed crossing of the Suwannee River is approximately 1.71
miles north of where the Withlacoochee and the Suwannee Rivers
converge (I’m using a measurement from the Suwannee County Property
appraiser GIS map from my property line — where they propose to
cross the river to the point where the two rivers meet in a
“V”). Thus on any map look for the V of the two rivers
and the proposed crossing is a little to the north on the Suwannee.

At the point where the Suwannee and the Withlacoochee meet there are
NUMEROUS major springs — see the attached map from the
Suwannee River Water Management District Web Site (SRWMD Spring Map
— Exhibit “C”) —


600x395 NUMEROUS springs, NONE IDENTIFIED, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

NONE of these springs are addressed in
the karst study done by Sabal. There are springs both north of the
proposed pipeline and springs south of it.

300x388 All the springs, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015
I am attaching a document from the SRWMD with information on all of
the springs that are in this area and which they failed to identify
for you. See Exhibit “D”.


600x776 Springs of the Suwannee River Basin in Florida, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

They are all in the area I circled on the attached maps — they are all less than two
miles from the proposed pipeline and the crossing — they are
all major springs (and should have been identified and discussed) 7
they are all interconnected as proven by recent testing by state
agencies and they fall both north and south of the proposed crossing
7 they could not have picked a worse place to cross. The springs I
am identifying are:

  1. Lime Run Spring or
    Sink (magnitude 1 spring, 173 cubic feet per
    second) 7 17 miles to the south of the crossing by the V;
  2. Falmouth Spring — magnitude 1—

    outflow as high as 220 cubic feet per second with recent readings in the range of 160
    cubic feet per second) 7 to the southeast of the V;


    600x776 Lime Run Sink, Falmouth, Ellavile, Lime, and SUW923973 Springs, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

  3. Stevenson Spring

    (also known as Lineater Spring and/or
    SUW923973)—discharge rate of 93 cubic feet per second —

    magnitude 2 spring—

    7 percent shy of magnitude 1 spring 7 this
    spring is .7 miles to the north of the crossing;


    600x776 Picture of SUW923973 Spring on Echo River Plantation, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

  4. Lime Spring -magnitude 2 spring,
    20.3 cubic feet per second — by
    the V — 1.7 miles to the south of the crossing;


    600x776 Pictures of Ellaville and Lime Springs, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

  5. Suwanacoocheee Spring

    — a

    magnitude 2 spring
    , 52 cubic feet of
    water per second — to the south by the V — 1.5 — 2
    miles from the crossing;


    600x776 Suwanacoochee Spring, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

  6. SUW923971—magnitude 4 spring,
    1 cubic foot per second) 7 to the south by the V; and
  7. Ellaville Spring
    (also known as Edwards Spring) —

    magnitude 2 spring
    ,
    82 cubic feet per second — to the South by the V
  8. SUW923972 — Magnitude 4

    the only one they address at all (they claim it is irrelevant and don’t acknowledge it as
    connected to the others) 7 less than 1/2 mile to the nmth of the
    crossing


    600x776 SUW923971 and SUW923972 Springs, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


300x388 Figure 1. Surveyed Reaches of the Suwannee River Basin, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

The

document I attach from SRWMD
gives detail on each spring. Most  of these springs have also been shown by the National Speleological Society (the Cave divers group) to be interconnected and many of them have been mapped by this organization with miles of tunnels and caverns in the exact area where the HDD crossing is proposed.


300x388 The proposed HDD crossing of the Suwannee River cannot be justified, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

I hope this helps explain that I am not just a disgruntled land owner as Sabal claims in their filings (reference their comment about
landowners not wanting their pipeline there). The proposed HDD
crossing of the Suwannee River cannot be justified based on language
in their own Karst analysis e the likely reason they ignored these
springs is their own analysis would prohibit this path if they had
revealed them.

Note that the undersigned is a lay person attorney and NOT a karst
expert. Basic research revealed the information contained herein and
the omission of this infonnation by Sabal’s purported karst experts
should raise serious questions as to the credibility of Sabal’s
filings.

RELIEF REQUESTED

The undersigned respectfully requests FERC consider these comments
and materials and that the Sabal Trail route be rejected as it
relates to the current route through the Suwannee River State Park
and Echo River Plantation and that an alternative route be mandated
that does not go through this area of the state, but instead uses
alternative existing pathways that are safer from an ecological and
conservation standpoint.


Tom Edwards In: Serious Allegations Against Sabal Trail | Our Santa Fe River, Inc. | Protecting the Santa Fe River in North Florida

Respectfully submitted January 29, 2015.

/s/ Thomas S. Edwards Jr.”
THOMAS S. EDWARDS, JR.
State Bar of Florida #395821
For EDWARDS & RAGATZ, P.A
.Attorneys for Intervenor
501 Riverside Avenue, Suite 601
Jacksonville, FL 32202
(904) 399-1609

Some more extracts below from SRWMD’s springs document via

What is a Spring?

with commentary in yellow and red by Thomas S. Edwards, Jr.


600x776 Table 1. First Magnitude Springs in the Suwannee River Basin, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


600x776 Floridan Aquifer is source for all springs and for drinking water, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


600x776 Sabal Trail proposes to go through an area riddled with these conduits, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


600x776 52 Springs in Suwannee County, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


600x776 Sabal Trail did not address multiple Magnitude 1 and 2 springs, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


600x776 Sabal Trail failed to address springs both north and south of the proposed pipeline, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


600x776 Lime Run Sink, Falmouth, Ellavile, Lime, and SUW923973 Springs, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


600x776 SUW923971 and SUW923972 Springs, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


600x776 Withlacoochee River Springs, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015


600x776 Suwanacoochee Spring, in TSE Plantation against Sabal Trail pipeline, by Thomas S. Edwards, Jr., for WWALS.net, 29 January 2015

-jsq

The post Sabal Trail ignored springs and underground connections –TSE Plantation appeared first on WWALS Watershed Coalition.

Read this article at WWALS Watershed Coalition at http://www.wwals.net/2015/01/31/sabal-trail-ignored-springs-ignored-underground-connections-tse-plantation/.
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