The Georgia Department of Natural Resources, Chapter 391-5-4 of the
Georgia Administrative Code, requires that every licensed commercial-
recreation-float operator in the state file, annually, within ten
calendar days of the close of its "operational dormancy period," a
Winter-Closure Report documenting, per the rule's enumeration:
(a) all float-trip commencements within the reporting period;
(b) all float-trip terminations within the reporting period;
(c) all customer-facing transactions;
(d) all equipment-in-service logs;
(e) all safety incidents (and their dispositions);
(f) all water-condition observations (daily);
(g) the operator's statement of continued fitness.
The stated legislative purpose of the rule, per the General Assembly's
1994 recreation-safety bill that established it, was to ensure that
commercial-float operators maintained continuous engagement with their
regulatory environment, even during the months they were, in fact,
legally prohibited from operating.
Cool River Tubing LLC, the larger of Helen's two commercial float
operators, is legally prohibited from operating between the first
Monday in November and the second Monday in May, per Chapter 391-5-4
and, redundantly, per the White County commercial-recreation ordinance
at WCCO § 12-5-1(b).
Cool River Tubing has, nevertheless, filed its Winter-Closure Report
every year since it began operations in 2009. The report for the
December 2025 period runs to 138 pages. It is the seventeenth
consecutive January in which it has done so.
The content
Section 1 of the report (pp. 1-22) documents, per the regulation's
(a) item, the count of float-trip commencements during the reporting
period. The number, shown in bold 18-point font on p. 3, is zero.
The remaining 19 pages of Section 1 consist of supporting material:
a month-view calendar of each day of December 2025 (31 pages
compressed onto 19 pages for efficiency), each day bearing the
notation "NO COMMENCEMENTS."
Section 2 (pp. 23-38) documents float-trip terminations. The count is
zero. The balance of the section consists of the same month-view
calendar.
Section 3 (pp. 39-64), customer-facing transactions, reports zero.
The supporting material includes a certified auditor's statement, on
letterhead, from the firm Ballard & Associates, Cleveland, GA: "We
have performed no substantive procedures because there were no
transactions to audit."
Section 4 (pp. 65-92), equipment-in-service logs, lists each of Cool
River's 2,400 inner tubes (by serial number) and confirms that each is,
as of December 31, 2025, in storage at the company's Robertstown Road
warehouse. Each tube is individually listed. The section does not, per
the regulation's requirement, summarize.
Section 5 (pp. 93-108), safety incidents, is one line: "NONE."
Followed by 15 pages of blank form templates, unfilled.
Section 6 (pp. 109-130), water-condition observations, reports daily
readings from the U.S. Geological Survey's Chattahoochee-at-Helen gage
(water temperature, flow rate, stage height, turbidity). These
readings are taken automatically by USGS equipment, are publicly
available, and are reproduced in the report without alteration. The
section acknowledges, on page 129, that Cool River made no independent
observations.
Section 7 (pp. 131-138), the operator's statement of continued fitness,
reads, in full: "Cool River Tubing LLC remains commercially fit to
resume commercial operations on the second Monday in May 2026, at
which time it intends to do so."
The statement is signed by CEO Amos Redwine, notarized by a White
County notary public, and dated January 8, 2026.
Commentary
Mr. Redwine, interviewed Friday afternoon at Cool River's Robertstown
Road office, was asked why the company continues to produce a 138-page
report when the regulation's minimum compliance could be satisfied by,
effectively, a single-page statement of non-activity.
"The absence of activity is itself an activity," Mr. Redwine said. "We
maintain our documentation standard. Our customers expect thoroughness.
Our regulators expect thoroughness. Our lawyers expect thoroughness.
I am not the person to introduce a break in the tradition."
Asked who, specifically, reads the report, Mr. Redwine said: "I
submitted it to White County Commercial Recreation on Friday. White
County Commercial Recreation has not, to my knowledge, read it. I
have not read it. I have read Section 7."
Cool River's cost of producing the December 2025 Winter-Closure
Report, per Mr. Redwine's estimate, was approximately $840 — $220 in
the certified audit, $45 for the vinyl binder, $32 in printing, $120
in notarization and legal review, and approximately eight hours of
Mr. Redwine's office manager's time at $55 an hour. This is the
seventeenth such annual expenditure.
Mr. Redwine was asked, finally, whether he had considered filing a
one-page report. He said he had not.
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