Case 2:14-cv-00044-LGW-JEG Document 1 Filed 03/26/14 Page 1 of 31

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA BRUNSWICK DIVISION

CIVIL ACTION NO. Plaintiff,

JURY TRIAL DEMANDED

COMPLAINT FOR CIVIL PENALTIES, INJUNCTIVE RELIEF, ATTORNEYS' FEES, AND EXPENSES OF LITIGATION ALTAMAITA RIVERKEEPER, INC., (hereinafter "Plaintiff" or "the Riverkeeper") submits the following Complaint for Damages and Injunctive Relief showing the Court as follows: JURISDICTION, VENUE, AND NOTICE
1. This action is brought pursuant to the Clean Water Act, 33 U.S.C. 125 1 et seq. Plaintiff challenges the Defendants' ongoing and continuous pollutant

discharges into the Altamaha River in violation of the Clean Water Act, which

have had and continue to have a drastic impact upon the water quality of these waters of the United States. Thus, this Court has subject matter jurisdiction over

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this action under the provisions of 505 of the Federal Water Pollution Control Act Amendment of 1972 (hereinafter the "Clean Water Act" or "CWA"), 33 U.S.C. 1365(a)(1), and pursuant to 28 U.S.C. 1331 (federal question). 2. This Court also has subject matter jurisdiction over pendant state statutory and common law claims pursuant to 28 U.S.C. 1367 (supplemental jurisdiction). 3. The CWA claims in this action are brought by Plaintiff as a private attorney general for past and ongoing violations of the CWA. Under the CWA, Plaintiff seeks civil penalties, injunctive relief, attorneys' fees, and costs and expenses of litigation. Plaintiff also asserts pendant state law and common law claims arising from the same actions and/or omissions giving rise to the federal claims seeking compensatory damages, special damages, punitive damages, injunctive relief, attorneys' fees, and costs and expenses of litigation as well as any other relief this Court deems just and equitable. 4. There are no pending actions that defeat this Court's subject matter jurisdiction.

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5. A substantial part of the alleged events or omissions giving rise to Plaintiff's claims occurred and continue to occur in Wayne County, Georgia within the Southern District of Georgia - Brunswick Division. Venue lies in this District because the claims arose in this district, as provided by 28 U.S.C. 1391, and because the discharges occurred and continue to occur in this district pursuant to the CWA, 33 U.S.C. 1365(c)(1).

ru
Pursuant to Section 505 of the CWA, 33 U.S.C. 1365(b), Plaintiff has provided Defendants with the requisite pre-complaint notification. Specifically, on or about November 26, 2013, Plaintiff mailed to Defendants the required Notice of Intent to Sue letter ("Notice Letter"), pursuant to CWA Section 505, 33 U.S.C. 1365(b), and provided a copy of the Notice Letter to the Administrator and the Regional Administrator of the Environmental Protection Agency ("EPA"), and the Director of the Georgia Environmental Protection Division ("EM"). Defendants received the Notice Letter as evidenced by the return postage receipt. True and correct copies of the Notice Letter and return receipt are attached hereto and incorporated herein in their entirety by reference. See Exhibit A. The purpose of

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providing Defendants with notice of Plaintiff's intent to file suit is to provide Defendants an opportunity to come into compliance without the need for litigation. 7. To date, Defendants have refused and failed to cease the CWA violations and remedy the damage describe herein as well as to abate the nuisances and trespasses or otherwise correct the problems within the sixty-day period.

In compliance with Local Rule 7.1.1, Plaintiff attaches a Disclosure Statement as Exhibit B. PARTIES

Plaintiff is a Georgia non-profit corporation with its principal office located in Darien, Georgia. The Riverkeeper's members recreate in/on and derive aesthetic enjoyment from the Altamaha River. 10. From its establishment in 1999, the Riverkeeper's mission has been to protect and restore the Altamaha River. The Riverkeeper's approximate 1,200 members use, enjoy, recreate, work and reside near, as well as derive aesthetic enjoyment from, the waters, adjacent habitat, and dependent aquatic life and

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wildlife in and along the Altamaha River, which have been and are continuing to be damaged by the Defendants' discharge of pollutants complained of herein. The Riverkeeper and its members have recreational, aesthetic, and economic interests in the Altamaha River and its fish and other wildlife, which are and continue to be directly and irreparably injured by the degradation of these areas. Numerous individuals who are members of the Riverkeeper reside on or very near the River such that the River is an everyday part of their personal lives. 11. The Riverkeeper brings this action on behalf of itself and its members who have been and continue to be injured by Defendants' failure to comply with federal and state laws as well as local ordinances governing the discharge of pollutants into a water of the United States in violation of the Defendants' pollutant discharge permit. The Riverkeeper is a "citizen" pursuant to the Clean Water Act, capable of bringing a citizen suit under the citizen suit provisions of the Clean Water Act, 33 U. S.C. 1365. Plaintiff and its members have suffered damage and continue to suffer damage as a result of Defendants' actions and/or omissions described in this Complaint.

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12. Defendant Rayonier Inc. is a foreign corporation with its principal place of business in Jacksonville, Florida, which conducts and transacts business in Wayne County, Georgia. Defendant Rayonier Performance Fibers LLC is a Delaware limited liability corporation located at 4474 Savannah Highway in Jesup, Georgia. Defendants Rayonier Inc. and Rayonier Performance Fibers LLC are collectively referred to herein as Defendants or "Rayonier." Defendants at times relevant to this Complaint are an owner and/or operator of a facility located on the Altamaha River which is a source of pollutants flowing into jurisdictional waters, including the Altamaha River. Defendants are responsible for the activities at the Jesup Mill facility (hereinafter the "Facility") which have and continue to result

in violations

of federal and state law governing the discharge of pollutants into waters of the United States. FEDERAL STATUTORY AND REGULATORY FRAMEWORK 13. In 1972, Congress passed the Clean Water Act "to restore and maintain the chemical, physical, and biological integrity of the Nation's waters." 33 U.S.C. 1251(a). To achieve this objective, Section 301 of the CWA, 33 U.S.C.

1311(a), prohibits the discharge of any "pollutant" into "waters of the United

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States" except in accordance with water quality standards promulgated and permits issued under other sections of the CWA. Generally, the CWA prohibits the discharge of pollutants into jurisdictional waters without a properly issued and valid permit or in violation of the terms and conditions of a properly issued and valid permit. See CWA 301, 402, and 404; 33 U.S.C. 1311, 1342, and 1344. 14. Section 402 of the CWA establishes the National Pollutant Discharge Elimination System ("NPDES") permit program, which prohibits the discharge of pollutants from a point source into waters of the United States without an NPDES permit or in violation of an NPDES permit. 33 U.S.C. 1342. CWA Section 502(14) defines "point source" to include, inter alia, "any pipe. -from . .from which pollutants are or may be discharged." 33 U.S.C. 13 62(14). 15. The Administrator of the EPA has initial authority to issue permits, but the Clean Water Act likewise provides for the delegation of permitting to the States. 33 U.S.C. 1342(a), (b). Accordingly, each state may establish and administer its own permitting program. See id. Georgia has a delegated program and

administers the NPDES permitting program through the Georgia Water Quality Control Act ("GWQCA"). O.C.G.A. 12-5-20 et seq.

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16. Pursuant to delegated authority, the Georgia EPD issued NPDES Permit No. GA 003620 ("Permit") to Rayonier allowing for the discharge of specific pollutants in regulated concentrations into the Altamaha River at Outfalls 001 and 11111 17. Rayonier' s permission to discharge under the Permit is contingent upon its compliance with the federal water quality standards at CWA Section 307(a), 33 U.S.C. 1317(a), and state water quality standards at Ga. Comp. R. & Regs. r.
391-3-6-.03(5).

113
The Permit contains technology-based limitations, water quality-based effluent limitations, monitoring requirements, and reporting requirements. 19. Water quality-based effluent limitations are incorporated into NPDES permits if technology-based limitations alone are not sufficient to ensure compliance with applicable water quality standards. 33 U.S.C. 131 1(b)(1)(C), 1312(a), 1313(e)(3)(A) 40 C.F.R. 122.44(d). Each permit must include

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requirements necessary to achieve water quality standards under the CWA, including state narrative criteria for water quality. 40 C .F.R. 122.44(d)(1).

The purpose of a water quality standard, as defmed in the Clean Water Act, is to ensure that, wherever attainable, water quality provides for the protection and propagation of fish, shellfish, and wildlife, and provides for recreation in and on the water. 33U.S.C. 1251(a)(2). 21. Water quality standards are established for waters taking into consideration their use and value for public water supplies, propagation of fish and wildlife, and recreational purposes, among other uses. 33 U.S.C. 1313(c)(2)(A). 22. Georgia water quality standards require that "[a]ll waters shall be free from material related to municipal, industrial, or other discharges which produce turbidity, color, odor or other objectionable conditions which interfere with legitimate water uses." Ga. Comp. R. & Regs. r. 391-3-6-.03(5)(c). Additionally, "[a]11 waters shall be free from turbidity which results in a substantial visual contrast in a water body due to a man-made activity." Ga. Comp. R. & Regs. r.
391-3-6-.03(5)(d).

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23. The Altamaha River has been designated a "fishing" river by the State of Georgia, which affords it certain additional protections under the law. Ga. Comp. R. & Regs. r. 391-3-6-.03(6)(c)(14). The Defendants' discharge of pollutants into the Altamaha River has substantially interfered with this designated use.
STATEMENT OF FACTS

24. The Altamaha Riverkeeper is a grassroots organization dedicated to the protection, defense and restoration of Georgia's biggest river - the Altamaha. The Altamaha Riverkeeper's members live, work, and recreate in the Altamaha River watershed.
25.

The Altamaha Riverkeeper monitors pollution and polluters throughout the watershed through a program of water sampling and analysis. The Altamaha Riverkeeper also monitors land-based activities that impact the health of the river. In addition to the watershed-monitoring program, the Altamaha Riverkeeper responds to citizen complaints about pollution.

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M
The Facility is located at 4470 Savannah Highway, Jesup, Wayne County, Georgia. 27. The Facility discharges wastewater into the Altamaha River and has done so since the Facility opened more than fifty years ago.

On May 25, 2001, EPD issued the Permit to Rayonier. PA On April 30, 2006, the Permit expired. However, the Director has administratively extended the Permit at least through the time of the filing of the Complaint. 30. The Facility discharges 50 million to 60 million gallons of polluted effluent per day into the Altamaha River. This effluent is comprised of complex organic compounds that make the effluent dark and odorous. 31. The Facility has discharged and continues to discharge color in its effluent in violation of Georgia water quality standards for color and turbidity and the Permit

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with documented high color discharges on numerous dates including, but not limited to, those dates listed in Exhibit A, which are continuing and ongoing. 32. The Facility has discharged and continues to discharge offensive odor in its effluent in violation of Georgia water quality standards and the Permit, with documented high odor discharges on dates including, but not limited to those dates listed in Exhibit A, which are continuing and ongoing. GENERAL ALLEGATIONS 33. Rayonier presently owns and operates the Facility in Jesup, Wayne County, Georgia. 34. The Facility discharges into the Altamaha River through two distinct permitted outfalls. 35. The Facility is subject to, among other GWQCA regulations, the Ga. Comp. R. & Regs. r. 391-3-6-.03(5), General Criteria for All Waters.

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36. The General Criteria for All Waters requires that "all waters shall be free from material related to municipal, industrial, or other discharges which produce turbidity, color, odor, or other objectionable conditions which interfere with legitimate water quality uses." Ga. Comp. R. & Regs. r. 391-3-6-.03(5)(c). 37. The General Criteria for All Waters also requires that "all waters shall be free from turbidity which results in a substantial visual contrast in a water body due to man-made activity." Ga. Comp. R. & Regs. r. 391-3-6-.03(5)(d.

93
EPD has concluded that the aesthetic impact of the Facility's discharge has the reasonable potential to violate the Narrative Water Quality Standards because it has the reasonable potential to produce turbidity or other objectionable conditions that interfere with the legitimate water quality uses of the Altamaha River and because it has the reasonable potential to cause turbidity that results in a substantial visual contrast in the Altamaha River due to man-made activity. 39. Prior to filing this lawsuit, Plaintiff complained to Defendants that the discharges of pollutants are illegal and interfere with its rights.

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DJ Defendants failed or refused to conform their behavior and abate the discharges of pollutants described herein. 41. The pollutants discharged from Defendants' facility cause significant violations of Georgia's narrative water quality standards for color and odor which substantially impair the Riverkeeper's and its members' use and enjoyment of the Altamaha River and interfere with their legitimate uses of the River. 42. The Riverkeeper has incurred substantial cost and has spent a considerable amount of time performing investigations into the facts of the discharge of pollutants into the Altamaha River, testing the effluent and the downstream water quality, responding to public and member outcry and conducting other related research and outreach efforts as a direct result of Defendants' illegal discharges. The Defendants' continuing violations of Georgia's narrative water quality standards for color and odor substantially impair the Riverkeeper's organizational mission of protecting the Altamaha River.

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43. Defendants have failed or refused to abate Plaintiffs and its members' losses, damage, and injury caused by the discharges of pollutants into the Altamaha River.

At all times relevant hereto, Defendants were and are responsible for complying with all applicable federal, state, and local legal requirements concerning the discharge of pollutants into the Altamaha River.

45.
At all times relevant hereto, it was foreseeable to Defendants that their discharges of pollutants into the Altamaha River could harm the river, Plaintiff, and Plaintiffs members. 46. The Plaintiffs and its members' interests continue to be damaged by Defendants' discharges of pollutants which are ongoing at the time of the filing of this Complaint.

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47. Plaintiffs remedies at law are inadequate to stop the continuing discharges by Defendants.

Plaintiff and its members continue to suffer irreparable injury as a result of the discharges of Defendants' pollutants into the Altamaha River. COUNT ONE - VIOLATION OF THE CWA 49. Paragraphs 1 through 48 are hereby incorporated by reference as if rewritten in their entirety. IJ Section 301 of the Clean Water Act prohibits the discharge of pollutants into waters of the United States, except as otherwise expressly authorized by the Act. 33 U.S.C. 1311(a). 51. Section 505(a)( 1) of the Clean Water Act authorizes citizens to commence a civil action against entities who are alleged to be in violation of a CWA effluent standard or limitation. 33 U.S.C. 1365(a)(1).

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52. Effluent standard or limitation includes a permit or condition thereof issued under Section 402 of the CWA. 33 U.S.C. 1365(f)(6). 53. Section 402 of the Clean Water Act prohibits the discharge of pollutants from a point source into waters of the United States without an NPDE.S permit or in violation of an NPDES penmt. 33 U.S.C. 1342. 54. Georgia's narrative water quality standards for color/turbidity and odor are incorporated by reference into Rayomer' s NPDES permit so that violations of these standards are violations of the Permit and the CWA. 55. Upon information and belief, Rayonier has violated Georgia's standards for odor and color/turbidity on at least the days listed in Exhibit A. Each daily violation of the color and odor/turbidity standards constitutes an individual illegal discharge subjecting Rayonier to civil penalties of $ 37,500 per discharge per day.

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COUNT TWO - VIOLATIONS OF THE CLEAN WATER ACT AND GEORGIA WATER QUALITY STANDARDS

Paragraphs I through 55 above are herein incorporated by reference as if rewritten in their entirety. 57. Georgia's water quality standards require that "[a]ll waters shall be free from material related to municipal, industrial or other discharges which produce turbidity, color, odor or other objectionable conditions which interfere with legitimate water uses." Ga. Comp. R. & Regs. r. 391 -3-6-.03(5)(c). Additionally, Georgia's water quality standards require that "[a]ll waters shall be free from turbidity which results in a substantial visual contrast in a water body due to a man-made activity." Ga. Comp. R. & Regs. r. 391 -3-6-.03(5)(d).

Defendants' ongoing discharges of colored effluent from its facility interfere with fish propagation and with the health and viability of other wildlife, in violation of the Georgia water quality standards. Defendants' ongoing discharges produce objectionable color/turbidity and odor that interfere with legitimate uses of the Altamaha River.

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59.

Defendants have failed or refused to utilize available technologies to adequately treat the discharge effluent so that it does not discolor the Altamaha River and cause an offensive odor. iJ Defendants' violations of Georgia's water quality standards for odor and color/turbidity constitute violations of the NPDES permit under the Clean Water Act. 61. Defendants' continuing violations of Georgia's water quality standards for color/turbidity and odor are illegal, are harmful to humans, animals, and aquatic life. 62. Said violations have had and continue to have significant detrimental effects on the quality of waters of the United States into which they flow.

The aforementioned Defendants' complete and knowing disregard for the requirements of the CWA indicates that it derives economic benefit from violating the law.

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Defendants will continue these violations until it is no longer economically advantageous for it to do so.
65.

In light of the foregoing, the CWA entitles the Plaintiff to injunctive relief by an Order of this Court that requires Defendants to remove or otherwise remedy the discharges and damage to waters of the United States by, inter alia: (A) enjoining any further violations of the CWA by the Defendants, including the illegal discharge of pollutants into waters of the United States; (B) ordering Defendants to change practices and conditions at its facility so as to cease violations of the CWA and all applicable state laws; (C) ordering Defendants to restore the physical, biological, and ecological integrity of the impacted jurisdictional waters; (D) ordering that all impacted jurisdictional waters be restored and/or remediated; and (E) ordering any further relief this Court finds just and equitable.

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za
In light of the foregoing, the CWA also entitles Plaintiff to judgment against the Defendants requiring Defendants to pay civil penalties for the CWA violations, in an amount not to exceed thirty-seven thousand five hundred dollars ($37,500) per day per violation, injunctive relief as specified herein, and payment of Plaintiffs litigation costs, including Plaintiffs reasonable attorneys' fees, expert witness fees, and expenses. COUNT THREE - NEGLIGENCE 67. Paragraphs 1 through 66 are hereby incorporated by reference as if rewritten in their entirety.

Defendants have acted negligently by allowing pollutants to flow from its discharge pipes and into the Altamaha River in violation of state and federal laws, and in violation of its NPDES permit. 69. As owner and/or operator of the Rayonier facility, Defendants have a duty not to cause damage or injury to Plaintiff and Plaintiff's members who recreate in and around the Altamaha River, whose livelihoods are based upon use and/or

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access to a fishable and swimmable Altamaha River, who eat the fish they catch in the Altamaha River, and who otherwise use and enjoy the Altamaha River. 70. Defendants have breached this duty by operating the Facility in disregard of applicable state and federal laws and in violation of its pen -nit for effluent discharge. 71. Defendants' actions and omissions that have caused and/or contributed to the discharge of pollutants into the Altamaha River in violation of state and federal laws and in violation of the NPDES permit are the proximate cause and cause in fact of the injury and damages to Plaintiff and its members. 72. As a result of Defendants' actions, Plaintiff and its members have suffered damages for the injury to and loss of the use and enjoyment of the Altamaha River. 73. Plaintiff and its members have suffered damages as a result of Defendants' actions and/or omissions and should be compensated in an amount and manner to be proven at trial.

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COUNT FOUR - NEGLIGENCE PER SE 74. Paragraphs 1 through 73 are hereby incorporated by reference as if rewritten in their entirety.

75.
Defendants were and are required to conform their conduct to applicable federal and state legal requirements, including without limitation the Clean Water Act and the Georgia Water Quality Control Act and the regulations promulgated pursuant to these statutes. 76. Plaintiff and its members are members of the class of persons for whom the legal requirements applicable to Defendants' conduct were designed to protect.

77.
Plaintiffs damage and injury are the types of damage and injury that legal requirements applicable to Defendants' conduct were designed to guard against. '1:' Defendants' acts and/or omissions in the discharge of pollutants into the Altamaha River violate state and federal laws as well as Defendants' NPDES permit.

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79. Defendants' conduct as described herein is the actual and proximate cause of Plaintiff's damage and injury. IiJ Defendants' violation of these applicable laws is negligence per Se.
81. Because of the Defendants' negligence per Se, Plaintiff and its members have suffered and continue to suffer damages and should be compensated in an amount and manner to be determined at trial. [0[11Ikl 0 W LTA - iJ 1.1 N [.IS] F[i}

Paragraphs 1 through 81 are hereby incorporated by reference as if rewritten in their entirety. M . Defendants have and continue to cause a nuisance by interfering with the public's use and enjoyment of the Altamaha River and surrounding natural area. 84. Under Georgia law, a public nuisance is "one which damages all persons who come within the sphere of its operation, though it may vary in its effects on

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individuals." O.C.G.A. 41-1-2. A "public nuisance exists if the act complained of affects rights which are common to all within a particular area." Atlanta
Processing Co. v. Brown, 227 Ga. 203, 211 (1971)

The right to use and enjoy the Altamaha River is a right common to all the public. The odor and discoloration of the River caused by Defendants' illegal discharges negatively and significantly affect the rights common to all people who use the water and the surrounding natural areas.

Defendants' illegal discharges have caused a special injury to Plaintiff by harming and impairing Plaintiff's ability to conduct its organizational business and meet its organizational objectives. Plaintiff has and continues to divert a substantial amount of organizational resourcesincluding but not limited to monitoring and submitting complaintsto address the Defendant's illegal discharges. 87. Plaintiff has suffered damages as a result of Defendants' actions and/or omissions and should be compensated in an amount and manner to be proven at trial.

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COUNT FIVE - INJUNCTIVE RELIEF

Paragraphs 1 through 87 are hereby incorporated by reference as if rewritten in their entirety. E:J Plaintiff seeks a preliminary injunction seeking immediate injunctive relief necessary to prevent further irreparable harm.

Plaintiff is entitled, under this Court's powers of equity and the CWA, to a preliminary injunction requiring that Defendants cease their illegal discharge of pollutants, including odor and color, into the Altamaha River. 91. In addition, Plaintiff seeks permanent injunctive relief requiring Defendants to restore and remediate the Altamaha River and to implement changes to its facility's manufacturing or wastewater processing practices which are necessary to prevent further harm to the Altamaha River, Plaintiff, and Plaintiffs members. 92. Plaintiff is entitled, under this Court's powers of equity, and the CWA, to a permanent injunction:

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(A)

enjoining any further violations of the CWA by the Defendants, including the illegal discharge of pollutants into waters of the United States in violation of federal and state laws and regulations;

(B)

ordering Defendants to change practices and conditions at its facility so as to cease violations of the CWA, all applicable state laws, and its NPDES permit;

(C)

ordering Defendants to restore the physical, biological and ecological integrity of the impacted Altamaha River;

(D)

ordering that all future production in the Facility be carried out in strict compliance with all applicable laws; and

(E)

ordering any further relief this Court finds just and equitable.

COUNT SIX - ATTORNEYS' FEES UNDER O.C.G.A. 13-6-11 93. Paragraphs 1 through 92 are hereby incorporated by reference as if rewritten in their entirety. OZA 1, Defendants have acted in bad faith, have been stubbornly litigious, and/or have caused Plaintiff unnecessary trouble and expense.

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95. Accordingly, Plaintiff is entitled to recover their attorneys' fees and costs of litigation under O.C.G.A. 13 -6-11. 96. Plaintiff has incurred attorneys' fees and costs of litigation and will incur additional attorneys' fees and costs of litigation as a result of Defendants' actions and/or omissions which forced Plaintiff to bring this lawsuit and should be compensated for its reasonable attorneys' fees and costs of litigation. COUNT SEVEN - ATTORNEYS' FEES AND EXPENSES UNDER THE CWA 97. Paragraphs 1 through 96 are hereby incorporated by reference as if rewritten in their entirety. 93 Pursuant to 33 U.S.C. 1365(d), this Court, in issuing any final order in this action, may order an award of litigation costs, including reasonable attorneys' fees and expert witness fees, to Plaintiff.

MNM

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Kel

Plaintiff is therefore entitled to an award of litigation costs, including reasonable attorneys' fees and expert witness fees, in an amount to be determined upon completion of this litigation. rsIIJ WHEREFORE, Plaintiff requests that: (A) (B) service of process issue as authorized by law; this Court temporarily and permanently enjoin the Defendants from committing any further violations of the CWA or other applicable laws; (C) this Court order Defendants to immediately change facility practices and conditions so as to cease all violations of the CWA, the Georgia Water Quality Control Act, and all applicable regulations; (D) this Court order the Defendants to restore the physical, biological and ecological integrity of the Altamaha River; (E) this Court require the design and installation of adequate control technology to abate the continuing discharges of pollutants; (F) this Court award Plaintiff actual damages from the Defendants, as determined at trial;

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(G)

this Court, in issuing any final order in this action, order an award of litigation costs, including reasonable attorneys' fees and expert witness fees, to Plaintiff pursuant to 33 U.S.C. 1365(d) and/or O.C.G.A. 13-6-11,

(H) (I)

that Plaintiff be afforded its right to trial by jury; and that Plaintiff have such other and further relief as this Court deems just and equitable.

Respectfully submitted this 26th day of March, 2014.

/s/ R. Hutton Brown R. Hutton Brown - Ga. Bar No. 089280 GreeriLaw 104 Marietta Street Suite 430 Atlanta, Georgia 30303 Tel. 404-659-3122 Fax 404-522-5290 [email protected]

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Is! Donald D.J. Stack Donald D. J. Stack - Ga. Bar No. 673735 Jenny R. Culler - Ga. Bar No. 200456 Stack & Associates, P.C. 260 Peachtree Street, NW, Ste 1200 Atlanta, Georgia 30303 Tel. 404-525-9205 Fax 404-522-0275 [email protected] [email protected] Is! Nathaniel H. Hunt Nathaniel H. Hunt - (ha. Bar NC). 157402 Nathaniel H. Hunt Staff Attorney Southern Environmental Law Center 127 Peachtree St., Suite 605 Atlanta, Georgia 30303 Tel. 404-521-9900 Fax 404-521-9909 nhuntselcga.org
Counsel for Plain tiffAltamaha Riverkeeper, Inc.

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