An Analysis of the Bleakly Advisory Group’s Report
on the Long-Term Impacts of Commercial Development of Jekyll Island State Park
At the February 9, 2009 Jekyll Island Authority board meeting, the Bleakly Advisory Group presented a report entitled “A Comparison of Jekyll Island to Comparable Southeastern U.S. Coastal Destinations,” the purpose of which is to provide insights into the potential impact of future development by comparing the built-up Jekyll Island of the future to other coastal vacation sites. See section V for this part of Bleakly's analysis. Senator Jeff Chapman (R – Brunswick), acting in response to complaints from his constituents about the accuracy of the Bleakly study, commissioned Dr. Ken Cordell, a nationally known authority on public land planning, to review the Bleakly report. Dr. Cordell’s report appears below.
Beware the Ides of March are Upon Georgia’s Jewel:
Review of a Poorly Done, Misleading Analysis of the Impacts of Commercial Development of Jekyll Island State Park
March 15, 2009
Conclusion: “Wildly understating the development and population densities projected for Jekyll Island State Park has resulted in misreporting that Jekyll Island is and will be in the future one of the least developed eastern coastal islands. In fact, the opposite is the case.”
In responding to a request from a Georgia legislator to professionally review an analysis contracted by an agency of the state of Georgia, a number of serious and fatal analytical flaws were discovered. The impact analysis in question was contracted by the Jekyll Island Authority (JIA) to justify a commercial development contract with Linger Longer corporation. The impact analysis was performed by the Bleakly Advisory Group (BAG) and reported to the JIA and its Board on February 9, 2009. It is interesting that the results of this impact analysis were reported to the Jekyll Island Authority nearly two months after signing the development contract. Typically, impacts from management decisions are analyzed and considered before a contractual decision is made.
The level of seriousness of the analytical flaws discovered prompted the reviewer (1) to conduct a re-analysis of the data behind the BAG analysis. Results of that review and subsequent re-analysis are presented below. Conducting a proper impact analysis is especially important to the State of Georgia and its citizens because it pertains to planned large-scale commercial development of public land, Jekyll Island State Park, and involves tens of millions of dollars of taxpayer funds.
The review was undertaken applying the same rigor and standards one would expect to use in reviewing an article submitted to a professional journal, such as the Journal of Park and Recreation Administration, or in reviewing any report submitted as an official decision document. Carrying through the development and financial arrangements in the contract between the JIA and Linger Longer will result in change in perpetuity of the character visitors have sought for decades at Jekyll Island State Park. It will result in reduction of access to average Georgians and a transfer of that access to wealthy patrons. Thus, it seems appropriate to hold the BAG impact analysis to the same professional standards as other park and recreation administration research reports.
The primary method for the BAG analysis reviewed herein was to compare development and population densities in Jekyll Island State Park, before and after commercial development, with density on other east coast islands. Such a comparative approach is fraught with theoretical, standard, and assumptive errors. The conclusion from this review of the Bleakly Advisory Group impact analysis is that it is not based on widely known, published and accepted park planning principles and theory, and the data and analysis are fatally flawed leading to wrong conclusions. It is this reviewer’s recommendation that the analysis be rejected and withdrawn from further consideration.
(1) The reviewer is H. Ken Cordell, PhD, Athens GA. He is nationally and internationally respected as an authority on public park planning. He has published 5 books and over 325 scholarly articles and reports in the area of planning, recreation demand assessments, park trends and economics. He is the principal scientist for the National Survey on Recreation and the Environment.
As stated, on February 9, 2009, the Bleakly Advisory Group (BAG) reported on an analysis the Jekyll Island Authority (JIA) had contracted with the group to look at the development and population density impacts of the commercial development being planned on public beach property at the Jekyll Island State Park. While it is standard professional park practice (globally) to analyze park management decisions on the basis of how those decisions impact quality of visitor experiences and the integrity and sustainability of park environments, the Jekyll Island Authority decided to take a different approach. That approach was to look only at revenues that could be generated for use by the Authority and at densities of development that could be achieved to further support generation of revenues. Development densities and maximized revenues are not appropriate criteria for evaluating and choosing public park management and development alternatives. In fact, this impact analysis occurred after the decision to proceed with development, as is evidenced by the signing of a contract with Linger Longer development corporation in December 2008.
Results of an earlier BAG impact analysis focusing on revenue generation potentials of commercial development of Jekyll Island State Park was presented to the JIA and its Board on September 15, 2008. A review by this author of that September 2008 analysis found it too to be seriously flawed as a basis for public park planning (Cordell 2008). Assumptions and forecasts of future visitation and revenues were not seen as clearly explained in that earlier report, nor were the methods defensible. Appropriate and widely known methods and data in the park planning profession were not acknowledged nor used.
The second phase of impact analysis, as reported February 9, 2009, focused on development. However, that analysis used obviously incorrect estimates of the land area of the State Park and inappropriately continued to rely upon earlier flawed and unjustified forecasts of visitation and revenue generation.
The error of over-stating the area of Jekyll Island and using that over-estimate to compute development and population densities per acre and per square mile led to incorrect conclusions. The island area used in that impact analysis was more than double recent LIDAR-based estimates of the actual State Park’s land area, and more than double the land area reported in the 1996 JIA Master Plan. In that the principle thrust of the BAG analysis was to compare the density of other east coast islands with development and population densities before and after Jekyll Island development, it was crucial to carefully identify and use the correct island area estimate in density calculations. By selecting a wildly incorrect island area as the base number, the calculated relative density of development and population reported for Jekyll Island State Park was seriously understated to be only about ½ of the densities existent and that would occur if the BAG total development and population estimates were correct. Understating the development and population density to such an extent resulted in reporting that Jekyll Island is and will be in the future one of the least developed coastal islands. In fact, the opposite is the case. Details of the review are as follows.
Findings or the Review and Re-Analysis
Figure 1 (below) shows the land area for Jekyll Island as used by the Bleakly Advisory Group (hereafter referred to as the “Bleakly pseudo-area”, i.e., false area). The black bar in Figure 1 shows the acreage reported by Bleakly, i.e., the pseudo-area. The green bar is island area as determined by NOAA LIDAR as reported by the Jekyll Island Authority, and the red bar is area of the JIA reports can be developed (1,453, 35% of total) (A. Brzank, C. Heipke. 2006. Classification of lidar data into water and land points in coastal areas. Institute of Photogrammetry and GeoInformation, University of Hanover). It is clear that the BAG analysis seriously inflated the Jekyll Island land area, and thus seriously understated density from planned development. The range of LIDAR estimates available for Jekyll Island is 4,094 to 4,152. In this review, the more liberal and development friendly estimate of 4,152 total acres is used to avoid the appearance of bias. However, the acreage of 4,094 is the more credible estimate from the University of Georgia and is also based on LIDAR. Whether 4,094 or 4,152 is used does not change this re-analysis result and conclusion.
Figure 2 (below) shows number of commercial lodging units currently on Jekyll Island at 1,208, a little over half the number on Captiva/Sanibel Island (CSI). For all figures shown here, counts or projections of housing, lodging and population were adopted directly from the BAG analysis. Total number of commercial units after development in 2023 is projected at 3,370, 65 percent greater than the much larger CSI. Figure 2 also shows lodging units per acre, which for CSI (an already heavily developed island) is 0.2 units per acre. After adjusting Jekyll Island to its correct land area, a little over 4,000 acres, not 9,232 acres, we find that Jekyll Island now already has greater density than Captiva/Sanibel at 0.3 units per acre. After development by 2023, commercial lodging density would be over 4 times greater on Jekyll than on CSI at 0.84 units per acre. Thus, density of lodging per acre on Jekyll Island is planned to be far above one of the most heavily developed southeastern coastal islands selected by BAG and the Authority for comparison.
Figure 3 (below) shows units per acre of resident housing added to number of units of commercial lodging for Captiva/Sanibel Island and for Jekyll Island State Park, now and as targeted by the JIA after commercial development by 2023. Units of resident housing per acre for Jekyll Island (now 0.5 per acre) is below that of Captiva/Sanibel (0.79 units per acre), but by 2023 it would be substantially above CSI housing and lodging density (Jekyll Island in 2023 at 1.0 units per acre). This density would exceed development of any other coastal island selected by BAG and JIA as comparisons. This includes exceeding Pawley’s and Santa Rosa Islands. The projected density for Jekyll Island would be nearly 4 times the density at St. Simons Island, the neighboring island just north of Jekyll Island. Most Georgians think of St. Simons Island as being heavily developed.
Figure 4 (below) shows estimated peak seasonal overnight population per square mile for Captiva/Sanibel and for Jekyll Island now, and after development in 2023. Currently Jekyll Island has an estimated peak population that is about ½ that of Captiva Sanibel Island (CSI). After planned new commercial development by 2023, peak population density (persons per square mile) on Jekyll Island State Park would be as high as CSI. It would be three times the population density of St. Simons Island. Only Pawley’s Island would exceed Jekyll Island. The Bureau of Census definition for an urban area is 500 or more persons per square mile. Population density projected after development by 2023 would be more than twice the Bureau of Census definition of an urban area.
Figure 5 (below) shows persons overnighting per square mile for 10 coastal islands, including Jekyll Island in 2008 and in 2023. Persons per square mile on Jekyll Island State Park was reported by BAG as 254 in 2008 and at 546 for 2023. After correcting the land area within these computations, the corrected population density for Jekyll Island in 2008 is computed at 565. The corrected population density for Jekyll in 2023 is 1,213. The density reported by BAG for 2023 was 546, less than ½ the correct calculation. Jekyll Island currently is close to Fripp Island, a heavily developed island. For 2023, Jekyll Island State Park would be third from the top of the list in terms of population density. This population density is three times the density on St. Simons Island. It is above Fripp, Kiawah, Santa Rosa, and Ocean Isle. It is nearly as dense as Captiva Sanibel and Pawely’s Islands.
Figure 1.—Pseudo-area used by Bleakly Advisory Group, LIDAR estimated actual area range, and estimated developable area of Jekyll Island State Park (35%)
Figure 2.—Total units of lodging and units per acre for Captiva/Sanibel Island, Jekyll Island State Park 2008 and Jekyll Island 2023 with planned development.
Figure 3.—Units per acre of resident housing plus commercial lodging for Captiva/Sanibel Island, Jekyll Island State Park 2008 and Jekyll Island State Park 2023 when planned new commercial development is scheduled to be completed.
Figure 4.—Estimated peak seasonal overnight population in persons per square mile on Captiva/Sanibel Island, Jekyll Island State Park 2008, and Jekyll Island State Park 2023 after planned development.
Figure 5.—Comparison of peak overnight population per square mile occupying dwelling units and commercial lodging for 10 southeastern coastal islands including Jekyll Island State Park in 2008 and in 2023, after commercial development.
What the Analysis Focus Should Have Been
It is a stated goal of state parks in Georgia, and typically of all park systems globally, that meaningful visitor experiences and sustaining the integrity and health of a park’s natural and cultural resources are the primary goals of park management. Literature and guidelines for park planning abound and they all focus on visitors and park resources.
One of the better published systems for park planning is the Visitor Experience and Resource Protection (VERP) model used by the National Park Service. VERP requires identification of indicators to explicitly measure the effects of management options and different levels of visitation on the quality of visitor experiences and on park resources (USDI National Park Service, 1997). As stated in the VERP Handbook, this system for park planning emphasizes clear identification of complementary and compatible visitor experience opportunities and resource conditions. It is only after desired visitor experiences and resource conditions are identified that type and level of access, development and management are determined. This logical ordering allows managers to recognize that unrestricted access, while a valid goal, is not one which can always be accommodated in light of the more important goals of meeting experience expectations of visitors and needs for resource protection. (The Visitor Experience and Resource Protection (VERP) Framework: A Handbook for Planners and Managers, September 1997. U.S. Department of the Interior, National Park Service, Denver Service Center.)
As referenced in the VERP process, all parks have a carrying capacity. Carrying capacity accounts for the quality both of the park resources and of the visitor experience. Park resources as referenced in the VERP Handbook encompass all biophysical, aesthetic, and cultural elements and features. Visitor experience refers to meeting visitor expectations, and the attendant perceptions, feelings, and reactions visitors have while visiting a park. As it applies to national and state parks, visitor carrying capacity is defined as “the type and level of visitor use that can be accommodated while sustaining acceptable resource and social conditions that complement the purpose of a park.”
While JIA planning documents and the development impact analysis refer often to maintenance of quality visitor experiences as a primary goal of JISP management, no experience impact analysis has been done, reported, nor considered in development decisions. Consideration of visitor experiences can only be undertaken by surveying visitors, surveying other users of the island, identifying general public preferences, systematically monitoring visitor satisfactions, and using the findings to guide management decision making. Understanding what visitors and Georgians want for Jekyll Island is the key to publicly responsive park planning. While a few surveys have been conducted within the decision-making time frame, none seem to have been considered in decision making.
The BAG reports and analyses done over the last year or more should be subjected to further rigorous peer review, especially in light of the fact that Jekyll Island is a state park and not private property. Accounting only for revenue, development, structural and population densities as criteria for managing a public property is very inappropriate and inconsistent with widely known and professionally endorsed park and public land planning standards. This approach also is not consistent with State of Georgia planning principles, with the Georgia Statewide Comprehensive Outdoor Recreation Plan, nor with the Department of Natural Resources and the Georgia State Park strategic plans. Literature and research abound that has laid out and rigorously tested appropriate park planning approaches and criteria.
In general, the objectives and therefore criteria for park planning are quality visitor experiences and sustained integrity of park resources. The BAG analysis is incomplete in that it provides no accounting for current visitor experience expectations, no accounting for change in experiences that would result from much greater development and population densities, and no accounting for park resource impacts. The Jekyll Island State Park Authority seems to have considered only one option for determining the future of this state park. That option is commercial development that moves the island toward being one of the most developed barrier islands on the Southeast coast, one whose peak seasonal population per square mile would be more than three times the Bureau of Census definition of an urban area.