IPJI COMMENTARY

THE JEKYLL ISLAND CONSERVATION PLAN:
JANUARY 2011 DRAFT

In 2004, the Jekyll Island Master Plan Update recommended the creation of a conservation plan to manage, conserve and protect Jekyll Island’s natural resources and help guide development decisions.  After years of delay, the Jekyll Island Authority (JIA) has released a draft of the recommended Conservation Plan and is accepting public input on it until February 11.   Following citizen input, the Conservation Plan will be redrafted and will then be discussed at a JIA-sponsored public meeting to be held on February 23.


CITIZEN INVOLVEMENT NEEDED NOW

The Initiative to Protect Jekyll Island (IPJI) is urging its members to take the time to read the draft Jekyll Island Conservation Plan, particularly sections 6, 7 and 8, which deal with how the Plan will be implemented and administered. 

The importance of creating a first-rate Conservation Plan (CP) for Jekyll Island State Park cannot be overstated, as that document will be the primary means of protecting the island’s natural resources against a wide range of threats and stresses, including those associated with real estate development.   For this reason, IPJI is encouraging concerned citizens to share their impressions of the CP—brief or detailed—with the JIA’s Conservation Plan Committee.

A copy of the CP is available at: http://www.savejekyllisland.org/ConsPlanJan2011.html.

Comments about the CP may be sent to the Jekyll Island Authority at: Jay.Exum@aecom.com and tnorton@jekyllisland.com.

It is important to note that professional conservation planning typically provides a viable framework for:
  • actively involving concerned citizens in the conservation plan process 
  • identifying and managing natural communities
  • accomplishing plan objectives
  • monitoring plan implementation
  • evaluating and resolving potential threats—both man-made and natural—to  the long-term conservation of natural resources
  • adapting the plan to changing conditions and needs
  • staffing and funding to implement the plan’s strategies and achieve its objectives

With an eye on the above framework, IPJI has identified a number of components of the draft CP and planning process that could stand improvement, an outline of which appears below.

IPJI’s constructive critique is not intended to diminish the positive features of the CP, which include an extensive inventory of Jekyll’s natural resources; a comprehensive outline of the threats to the island’s wildlife and vegetative communities; a range of natural resource management prescriptions; and a commitment to enhancing environmental education and recreational opportunities. IPJI also recognizes and appreciates the dedication shown by the CP Committee members—most of whom are volunteering their time—in working toward a Jekyll Conservation Plan of which we can all be proud.

It is our hope that the CP Committee will view IPJI’s observations and constructive criticisms as an attempt to help the Jekyll Conservation Plan reach its full potential and that the Committee will give our recommendations serious consideration in refining the draft CP.




THE PLANNING PROCESS

1. An independent, highly qualified planning reviewer or review team should have been asked by the JIA to analyze the CP Committee’s approach to doing a plan so that any problems and/or omissions in the plan process could have been identified and remedied before work on the plan commenced.  Such a review most likely would have revealed a key weakness in the planning process, namely the failure to aggressively seek public involvement—beyond Jekyll Island— in the conception, development and refinement of the CP.

2. A statewide public survey should have been done as a first step in the CP process to determine what Georgia’s citizens value most about their state park and how they want its natural resources managed. Surveying of this type is widely practiced by professional land planners, as it provides them with a means of establishing citizen preferences as a first step in the planning process and fully engaging the public in their work. Dr. H. Ken Cordell, a nationally known planning professional with extensive experience in survey design and implementation, volunteered to assist in crafting and administering a survey for the Jekyll CP Committee, but the JIA did not take him up on his offer, with the result that the Committee undertook its work without a robust plan for reaching out to citizens across the state to involve them in the CP process from beginning to end.

3. The first draft of the CP should have been available for viewing prior to the December JIA-sponsored public input session. In the absence of details about the draft CP, public commentary at that meeting was unnecessarily limited and the CP Committee was denied an opportunity to receive potentially valuable input from the general public and the conservation community.

4. The public should have access to the next draft of the CP prior to the February 23rd public input session being held by the JIA to discuss the refined draft.  Informed and detailed public commentary demands that this be so.

5. The CP Committee should respond in writing to organizations and citizens who submit comments about the draft CP so they know that their recommendations have actually been read and may have a chance of shaping the CP. Responses beyond a “thank you” are typically provided by public agencies that have requested citizen review of a public document as part of the planning process. This should hold true for the Jekyll Conservation Plan Committee as well.

6. All written public comments submitted to the JIA should be appended to the CP as a means of gauging the extent to which public input has impacted the CP. 

7. A thorough review of the final draft of the CP should be conducted by an independent team of professionals representing a wide spectrum of relevant science disciplines. Employees of the JIA (including paid consultants) or other state agencies should not be part of this review team.


THE CONSERVATION PLAN

1. The CP’s stated intent is “to create a framework for protecting and managing natural resources on JI…. The Plan is expected to be clarified, refined, and adapted based on further research, improved techniques and a changing environment.” Obviously, the CP cannot resolve all issues now and must follow an adaptive approach for natural resource management. However, the CP leaves hanging a number of important conservation concerns by failing to provide adequate details/guidelines on how objectives may be realized and by deferring action on the CP until staffing and funding issues have been resolved by the JIA.

2. The CP recognizes that some areas of Jekyll Island are far more environmentally sensitive than others but fails to clarify the boundaries of the 65% of Jekyll’s land area that is required by law to remain in its natural condition, saying instead (p. 33) that it is up to the Jekyll Island Master Plan “to delineate and identify the parcels most appropriate for development or redevelopment.” It seem clear, however, that the delineation of natural areas in need of protection—whether from natural or man-made threats and stresses—is fundamentally a conservation objective, a point evidenced by the fact that the highly regarded definition of conservation planning developed by the Conservation Planning Institute has at its core the delineation of natural areas that must be protected. (Source: Margules, C. R., and R. L. Pressey. 2000. “Systematic Conservation Planning.” Nature 405:243-253.)  At the very least, the CP should recommend that the land area of the entire island be classified hierarchically based upon environmental sensitivity, with the 65% of the island that is required to remain in its natural condition comprising Jekyll’s most environmentally sensitive areas.

3. The CP does not address the critical question of demarcation of the boundary between upland Jekyll Island and the salt marsh which is one of Georgia’s most sensitive and precious natural resources. Currently, sizable areas of estuarine marshland adjoining Jekyll Island State Park are being counted as part of the island’s total land area, which results in an artificial increase in the number of acres that are eligible for development under the state law limiting development to 35% of the land area of Jekyll Island. Areas making up the protected 65% of the land area of Jekyll Island should be surveyed and hard boundaries thus established as an essential step in conservation management. Science-based conservation standards note that protected area demarcation is an essential element of conservation planning and management. If conservation planning does not directly account for requirements of the 65-35 law, a fundamental island conservation management principle will have been violated.

4. The CP states that "all proposed projects that have the potential to affect natural systems must undergo a review to determine whether the project is appropriate for Jekyll Island."  This is a fine concept, but the CP goes on to say that the review is to be “conducted by a team from the Jekyll Island Authority facilitated by the Director of Natural Resources once this position is filled.” There are several significant problems with this approach:
  • There are no criteria or indicators specified to help guide decisions about what is and is not appropriate development or redevelopment. The draft conservation plan that was submitted to the Authority back in February of 2007 included clear steps for evaluating the appropriateness of development proposals [click here to view that section of the 2007 CP]. Unfortunately, the JIA board chose to remove those steps from the 2007 plan. Instead of clearly outlined evaluative steps, the current "Environment Assessment Procedure" lists impacts that should be avoided or minimized along with general impacts upon which the assessment of development proposals may be based. The examples of an inappropriate project proposal cited in Section 7.1 of the CP—such as a biomass combustion facility or a new regional airport on Jekyll Island—have little meaning, as they are so outrageous that they would be deemed totally inappropriate by virtually all observers and stakeholders. 
  • The environmental assessment review should be conducted by an independent panel of experts, not be “by a team from the Jekyll Island Authority,” as specified in the CP. An environmental impacts review conducted by people dependent on the JIA or the state of Georgia for their livelihood poses the clear risk of JIA development priorities taking precedence over ecological, wildlife, natural scenery, and threatened species concerns, as was the case with the ill-fated Linger Longer town center project. Furthermore, if the EAP review is to have teeth, it should be conducted by neutral parties who have critical expertise and the  authority to revise/stop a project that is deemed to be fundamentally at odds with conservation priorities. 
  • Even if a proposed development project is found to be at odds with conservation objectives, the draft CP still allows it to proceed: “The EAP review will likely (not will) result in specific design recommendations that may (not will) be required for project approval.” [Section 7.2 - “Local/Site Scale Impacts, p. 55]. Action on EAP Review Team recommendations must carry more force than this.
  • Last but not least, the CP fails to include a provision for public and peer expert review of EAP Team and JIA decisions. In the absence of such a provision, development interests may be allowed to take precedence over conservation concerns and objectives.

5. The implementation of the CP will require a professional staff dedicated expressly to conservation management, yet the CP—while recommending that a Conservation Director be hired at some point in the future—does not include adequate recommendations for additional and necessary staffing but simply states that, “some additional staff will likely be required.” The CP does recommend the use of existing “JIA staff, graduate students, interns and volunteers” along with “other natural resource agencies” to implement the CP, but the fact is that the JIA executive staff is already stretched thin, as is the staff of other natural resource agencies the CP hopes to enlist. Clearly, a substantial professional staff—including such positions as an environmental education coordinator, a wildlife biologist, and a volunteer coordinator—dedicated solely to conservation management is absolutely essential to the success of the CP.

6. The CP’s section on funding is inadequate.  No timeframe is specified for hiring a Director of Conservation, whose job will include “the preparation of a staff and budget to implement the Conservation Plan.” In the absence of a conservation budget, the CP says that some of the initial conservation management actions can be implemented by existing staff or by focusing on the efforts of existing partners. Conservation funding should be a high priority and fully integrated into the JIA’s overall budget. Reliance on the fund-raising ability of a yet to be named Conservation Director and on the possibility of funding from the Jekyll Island Foundation and groups that use the convention center—as recommended by the CP—seems inconsistent with the professed importance of conservation as a JIA priority. 

7. The CP has delegated the important task of coordinating and expanding environmental education on Jekyll Island to an eight-person subcommittee chaired by Dr. Terry Norton, the Director of the Georgia Turtle Center. That committee has already come up with an ambitious vision for the island’s nature based education programs, but it remains unclear as to how the committee’s recommendations relate to the CP itself and what its responsibilities—if any—are over the long haul. What is clear is that a full time staff and designated funding for the coordination and enhancement of nature based education programs will be essential to the achievement of the committee’s goals, yet—as pointed out above—neither of these two requisites is addressed forcefully by the CP.

8. The environmental and ecological impacts of development and redevelopment projects fall within the purview of a comprehensive conservation plan, yet the CP is silent on the question of how best to determine the ideal carrying capacity for Jekyll Island State Park. Carrying capacity is a management concept applied by professional land planners for the purpose of establishing the amount of activity/development an area can absorb before unacceptable impacts occur. In a public land setting, carrying capacity typically forms the basis of all management decisions and actions as well as for the development of project scenarios and alternatives.

The Jekyll capacity study done for the JIA by the Bleakly Advisory Group some two year ago was woefully inadequate and widely criticized, having failed to even consider the environmental impacts of the future development it sanctioned. The CP should include a comprehensive carrying capacity study done by an agency independent of both the JIA and any entities—individuals, companies or organizations—with ties to the Authority. Carrying capacity study results should serve as a primary guide for conservation and recreation use decisions. A number of planning and management frameworks have been developed to measure carrying capacity, including the widely used Limits of Acceptable Change (LAC) model, which is geared toward promoting a compromise between the absolute protection of environmental conditions and the visitor experience, on the one hand, and the unrestricted access to resources for recreation or other purposes, on the other. The principles and methods for park planning—including carrying capacity analysis—recently published by the National Association of Recreation Resource Planners would also be of value for the CP Committee.

9. The CP’s section on recreation is incomplete. Lacking, in particular, is a comprehensive, qualitative inventory of recreation settings and resources along with a visitor survey and analysis of visitor preferences regarding existing and potential recreational facilities/opportunities. Planning for recreation management and development is difficult in the absence of a full understanding of the recreation interests and values of the state park’s citizen owners. Furthermore, recreation planning for parks and other public lands is a well developed professional field which the CP team has not taken advantage of to date. A highly regarded professional in the field of recreation planning, who has worked closely with the National Association of Recreation Resource Planners, volunteered to assist the JIA and CP team in this area, but, unfortunately, this offer was rejected.




BACKGROUND AND TIMELINE

2004: The Jekyll Island Master Plan Update recommended that a conservation plan be created to manage, conserve and protect the island’s natural resources and to help guide development and redevelopment decisions.

2007: Three years later, a draft conservation plan was finally completed but was tabled by the Jekyll Island Authority board when questions arose about the plan’s viability, particularly with respect to how best to manage the island’s resources and how development interests would be squared with conservation objectives. For over two years, that plan sat at the State Attorney General’s office, where it was sent by the Jekyll Island Authority board of directors for ‘legal review’ following public protests over the board’s deletion of those parts of the plan that offered specific criteria for determining the appropriateness of development and redevelopment proposals.

2009: In September 2009, the Jekyll Island Authority announced that it was resurrecting the conservation plan and would form a committee consisting of JIA staff members and representatives from the Georgia Department of Natural Resources and the local environmental community to update the plan. 

2010: In March 2010, the JIA selected AECOM, an Orlando-based firm and a development partner of the JIA, to help develop and write the Jekyll Conservation Plan.

2010: On December 1, 2010, the Jekyll Island Authority hosted a public input session at which a draft of the Jekyll Island Conservation Plan was presented by AECOM consultant Jay Exum. A copy of the draft CP was not made available for public viewing prior to the meeting, with the result that public commentary at the meeting was unnecessarily limited due to lack of details about the CP.

2011: On January 6, 2011, a revised draft of the CP was released by the JIA. Public input the January draft will be accepted by the JIA until February 11. The draft will then be revised and will be the subject of a JIA-sponsored public meeting scheduled for February 23. Hopefully, the public will have an opportunity to see the refined version of the CP prior to the February 23rd meeting so as to avoid a situation in which citizens are asked to comment on a draft CP they have not had a chance to read, which was the case at the December 1 public input session.