Letter to the Community
Dear Community Members:
In the past few weeks, several individuals have been outspoken in opposing Georgia-Pacific’s Foley Cellulose mill and our efforts to meet state and federal water quality standards. Unfortunately, much of this opposition has included inaccuracies and misrepresentations about our company and the work our mill has done to comply with state and federal regulations and improve the Fenholloway River system.
First, it’s important to know that we have more than 500 employees at Foley who live, work, and enjoy the natural beauty of north Florida. We all are committed to balancing the ability to operate our facility while protecting our rivers and streams. We have worked cooperatively for many years with the Florida Department of Environmental Protection (FDEP), the U.S. EPA and community groups to achieve that balance.
During the past decades, we have spent significant effort, time, and money to improve the environmental performance of our mill, all to meet applicable water quality standards for the Fenholloway River. Close to $120 million in mill process investments have resulted in improved water quality in the river. Since the river flows directly into the Gulf of Mexico, these improvements have a direct and positive effect on the water quality of both bodies of water. The improvements were implemented voluntarily until 2014 when the state issued an Administrative Order defining the remaining projects required for our permit.
Notable improvements include:
- 14 percent reduction in water use and effluent volume
- 26 percent reduction in phosphorous
- 25 percent reduction in nitrogen
- 54 percent reduction in water color
- 28 percent reduction in biological oxygen demand
- 49 percent decrease in total suspended solids.
Our mill will complete additional improvements required by the Administrative Order at a cost of $70 million to $100 million during the next five years that will further benefit the Fenholloway and the Gulf.
Despite the claim from some that our mill does not need to change the location where our effluent is discharged, the need for an effluent pipeline was initially determined by the state in 1994 and confirmed by two subsequent studies involving the mill, FDEP, EPA and community groups. Combined with manufacturing changes, treatment technologies and Fenholloway headwater restoration, the pipeline is required to enable the river, estuary, and nearshore Gulf of Mexico to meet Class III recreational water quality criteria. It is just one part of many efforts needed to meet water quality standards.
The mill currently discharges into the Fenholloway River, which flows into the Gulf. As required by FDEP, the discharge will be moved to the tidal portion of the river, closer to the mouth and the Gulf of Mexico. The primary reason to relocate the discharge point to the tidal portion of the river is to address the salt content of the treated effluent. Salinity will not pose a concern at the relocation point because the salt content of the treated effluent is less than that of the brackish water in the lower reaches of the river. At project completion, the entire Fenholloway River system will meet Class III standards, supporting recreational use.
Another inaccuracy pertains to the sea grass beds at the mouth of the Fenholloway River, a focus of our restoration efforts during the past decade. Independent monitoring confirms that conditions necessary to support sea grass in the Gulf along the mouth of the river have been reestablished.
Some continue to state that we have not considered alternative technologies that could allow us to meet water quality standards. However, no specific technologies that have the ability to meet the standards required have been presented to either Georgia-Pacific or FDEP. The finding of facts within the Administrative Order clearly demonstrates there are no other alternatives available for us to meet Class III water quality standards in the river.
Finally, it has been mentioned that we are waiting for a permit from the Army Corps of Engineers to begin building the pipeline. Our existing Army Corps of Engineers permit for pipeline construction is currently being updated and its term extended to match the timeline in the Administrative Order. The Corps completed its public comment period for the permit extension conditions on May 15, 2015.
For more than 60 years, our company and employees have been committed to operating with integrity and in compliance with all laws and regulations, and we are committed to being a responsible member of our community and region. On behalf of the company and our employees, my commitment is that our actions will continue to demonstrate this dedication.
Vice President and General Manager, Foley Cellulose