We, the undersigned residents and concerned citizens of Bryan County, the City of Richmond Hill, and surrounding areas in Southeast Georgia, submit this communication as formal public comment regarding any federal permitting, authorization, or related zoning actions associated with the proposed Westwin industrial facility

Subject: Public Comment Opposing Federal Environmental Approval and Requesting Enhanced Review for the Proposed Westwin Industrial Facility, Bryan County, Georgia

To Authorities Having Jurisdiction,

We, the undersigned residents and concerned citizens of Bryan County,  the City of Richmond Hill, and surrounding counties in Southeast Georgia, submit this letter as formal public comment regarding any federal environmental review, approval, or concurrence by the U.S. Environmental Protection Agency related to the proposed Westwin industrial facility.

This comment is submitted pursuant to the Clean Water Act (33 U.S.C. §1251 et seq.), the National Environmental Policy Act (42 U.S.C. §4321 et seq.), and other applicable federal environmental statutes and implementing regulations within the Environmental Protection Agency’s oversight and review authority.

While we acknowledge that industrial metal refining plays a role in the national economy, we have substantial concerns regarding the specific processes proposed for this facility—particularly the use of a carbonyl-based system—and the suitability of such operations within a coastal, flood-prone environment.

Clean Water Act Oversight and Water Quality Concerns

The proposed site is located within a coastal region that includes, or is hydrologically connected to, wetlands, marshes, tidal waters, and shallow groundwater systems that are protected under the Clean Water Act. The area is subject to frequent flooding, storm surge, and hurricane impacts, which heighten the risk of pollutant migration into surface waters and connected aquifers.

As the federal agency charged with administering and enforcing the Clean Water Act, including oversight of water quality standards and review of Section 404 permitting actions under Section 404(c), the EPA plays a critical role in evaluating whether a proposed project may result in unacceptable adverse effects on municipal water supplies, shellfish beds, fisheries, wildlife, or recreational areas.

We are concerned that the available information does not adequately demonstrate that:

Discharges of pollutants, stormwater runoff, or accidental releases associated with the facility can be reliably prevented under flood and storm conditions;

Water quality standards will be maintained during both routine operations and emergency scenarios; or

Impacts to wetlands, marshes, and downstream waters have been sufficiently evaluated, avoided, and minimized.

Hazardous Substances and Emergency Risk in a Coastal Setting

The proposed use, storage, and transport of carbonyl compounds and other hazardous substances introduces additional risks in a coastal and environmentally sensitive region. Based on publicly available information, we are not satisfied that adequate consideration has been given to:

The potential for accidental releases during extreme weather events;

The transport of hazardous materials through flood-prone corridors;

Emergency response and containment capabilities near tidal waters, wetlands, and navigable waterways; and

The potential for acute or chronic contamination of surface waters and groundwater in the event of a release.

These concerns are directly relevant to EPA’s responsibilities under the Clean Water Act, the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and related risk management and spill prevention frameworks.

NEPA Review and Interagency Coordination

Given the potential for significant environmental impacts, including impacts to waters of the United States and sensitive coastal ecosystems, we believe the proposed project warrants a comprehensive review under NEPA. Such review should include a full evaluation of cumulative impacts, climate-related and coastal vulnerability risks, and reasonable alternatives to the proposed site.

We respectfully request that EPA exercise its review and coordination role to ensure that any environmental assessment or environmental impact statement fully addresses these issues and that no federal approvals proceed without adequate analysis and public transparency.

Land-Use Compatibility and Precedent

We are also aware that similar industrial facilities in other jurisdictions have required high-intensity industrial zoning classifications—specifically I-4 zoning—prior to permitting, including in Lawton, Oklahoma. This precedent raises further questions regarding land-use compatibility and whether the proposed site is appropriate for the type and scale of industrial activity contemplated.

Request for Agency Action

Based on the environmental sensitivity of the proposed location, the risks associated with the proposed industrial processes, and the absence of sufficient information demonstrating compliance with federal environmental protections, we respectfully request that the U.S. Environmental Protection Agency:

Object to or condition any federal permits or approvals associated with this project as appropriate;

Exercise its oversight authority to ensure full compliance with the Clean Water Act and related statutes; and

Require a thorough and transparent federal environmental review prior to any advancement of the project.

The signatures of supporting constituents are provided in confirmation of this submission.

Thank you for your consideration and for your continued role in protecting water quality, public health, and the environment.

Respectfully submitted,

Concerned Citizens of Bryan County, Richmond Hill, and surrounding counties in Southeast Georgia

By signing this petition, I affirm that I am a resident or stakeholder of Bryan County, the City of Richmond Hill, Georgia, or a nearby surrounding area, and that I support the concerns and requests outlined in the related correspondence submitted to the relevant regulatory agencies.