Jekyll Island State Park Conservation Plan:
Comments from the Conservation Community

Below is a sampling of the comments submitted by representatives of the conservation, wildlife and environmental communities regarding draft three of the Jekyll Island State Park Conservation Plan. It is our hope that the Conservation Plan Committee will take full advantage of this input along with the nearly 200 other comments it has received from the public regarding how to further improve the Jekyll CP.

The final draft of the CP will be written over the next few weeks. IPJI has requested that the final draft to be posted on the JIA's website for public viewing at least two weeks prior to the date it will be submitted for consideration by the Jekyll Island Authority Board of Directors.





Georgia Ornithological Society

March 28, 2011

RE: Jekyll Island Conservation Plan (March Draft) Comments
Dear Drs. Exum and Norton,

Thank you for the opportunity to review the Jekyll Island Conservation Plan (CP).  The Georgia Ornithological Society (GOS) supports the substance of the CP, with the following exceptions:

1.  You state that "The existing pet ordinance will suffice for issues associated with feral cats and free-ranging housecats at this time."  We respectfully disagree with this assertion.  Jekyll Island's managers are allowing a "Trap-Neuter-Release" (TNR) strategy on the island with respect to the management of cats.  This strategy has been implemented and studied in other communities, and the scientific consensus is that TNR is not effective in eliminating, let alone controlling the growth of, feral cat populations.  On the contrary, TNR-managed cat populations continue to prey on wildlife, often contributing in significant ways to declining populations of rare bird species, some of which are currently found on Jekyll Island.  Effective feral cat management involves catching and relocating cats to a shelter or other protected sanctuary (where cats are not allowed to roam), and mandatory spay/neuter requirements in instances where cat owners persist in allowing their pets to roam.  We urge the Jekyll Island Authority (JIA) to not be influenced by emotion-based arguments from cat advocacy groups, but to instead embrace a science-based policy. 

If you would like to know more about this issue, please see the GOS position statement on feral and free-ranging cats at: http://www.gos.org/orginfo/gos-cats.htm

2.  The lack of a coherent map depicting the 65% of the island that is purportedly maintained in a natural state continues to be a source of confusion and an invitation for contentious debate.  It is unclear to conservation groups and to development entities exactly which areas of the island are protected by law.  At times, decisions authorizing development projects appear to be arbitrary, when they should be assessed with an eye towards preserving fragile habitats and biological diversity.  While we realize that delineating the natural areas was beyond the scope of the CP, we assert that the sound protection of the island’s natural resources will continue to be inadequate without such a delineation.  The CP should include a recommendation to map these areas, and this needs to be a high priority.  

3.  One of the key lessons repeatedly learned by natural resource managers is that the success of management plans cannot be gauged – and adjusted if needed – unless follow-up monitoring protocols are rigorously implemented.  The CP alludes to the importance of monitoring the impacts of management on page 58, but the plan does not provide a clear explanation for conducting such monitoring, including a timeline, nor does it explain who would conduct the monitoring effort and what the qualifications of the monitor(s) might be.  Please include these details in the CP.

4.  Earlier this year, the education subcommittee recommended the acquisition of funds to establish and staff a nature-oriented education program.  This recommendation does not appear to be included in the current draft, but the need for such a program is vital.  Please reinsert this requirement. 

5.  We applaud the plan to appoint two “outside” individuals to the Environmental Assessment Procedure Review Team (EAPRT).  Since these people will apparently be appointed by the Jekyll Island Authority (JIA), it seems only appropriate that they should not be connected in any way to JIA, and that they should be professionally qualified to perform the reviews for which they will be hired.  Please include these requirements in the CP.  Additionally, analysis of the environmental impacts associated with development projects on state and federal lands are made available for review and comment by the law under the stipulations of the National Environmental Policy Act and the Georgia Environmental Policy Act.  We feel that the public should also be afforded the opportunity to review and comment on decisions made by the EAPRT.  This seems only fitting since the island belongs to the citizens of the state of Georgia.

Thank you again for the opportunity to review and provide comments on this plan.  Our 500-member society has an over 40-year tradition of meeting in the fall on Jekyll Island, so we are especially interested in the future of this coastal treasure.  Please contact me if you have questions, or if we can assist with the CP in some manner. 

Sincerely.
Steve Holzman
Conservation Chair, GOS







                                   
                                   Initiative to Protect Jekyll Island

                                                             308 Old Plantation Rd.
                                                  Jekyll Island, GA 31527
                                              www.savejekyllisland.org


To: Dr. Jay Exum and Dr. Terry Norton,

First, we want to thank you and the other members of the CP Committee for amending the CP to reflect some of the suggestions made by members of the public. We also want to compliment you on the format of Friday’s public forum, for it allowed you to make clear the Committee’s thinking about many of the public comments it received and to point out how the March 7th draft was shaped by public input and input from Committee members as well. 

As you turn to the final revision of the CP, we would like you to give full consideration to the following recommendations, many of which were raised at Friday’s meeting, some of which are new.:

1. The delineation of the 65% of Jekyll Island State Park that is required by law to remain in its natural condition was not a task assigned to the CP Committee, but we strongly feel that the CP should at least emphasize the importance of delineating the 65% natural area of Jekyll Island and recommend to the Master Plan review committee that this area not only be mapped but permanently set. Clear delineation of the island’s natural areas is not only necessary for conservation management but would end the practice of flipping acreage between the 65% and 35% zones, which has, in the past, allowed for inappropriate site selection for development projects. Furthermore, the clear delineation of the island’s 65% natural area is a prerequisite for securing the conservation easement recommended by the CP to permanently protect that area.  

2. “Development” and “redevelopment” be included in the list of general ecological threats, stressors and stresses recorded in Section 3.7, pp. 15-16, of the CP. This would make Section 3.7 consistent with other and later sections of the CP in which development is cited among the potential “threats and stresses” to the island’s wildlife habitats and natural resources -- see “Vegetative Communities,” pp. 22, 24, 27 and 29, “Island-Wide Management,” p. 40, for examples.

3. In Section 5.4, p. 58, the CP says that monitoring of the impact of management actions is vital to the achievement of the Plan’s objectives, but the Plan only offers a preliminary outline of monitoring activities and state that, “A more detailed approach should be developed to match staffing and funding levels for implementing the Conservation Plan.” In light of the importance of monitoring, the Plan should include a more comprehensive monitoring program—including specific management controls—and a strong recommendation that the JIA provide the staff and funding to implement it. If the JIA chooses not to act on the CP’s recommendation, so be it, but at least the CP will have done what it can to formulate and promote a comprehensive monitoring program.

4. The January draft of the Education Subcommittee’s report included a recommendation for a full-time staff and proper budgeting to implement and coordinate an island-wide, nature-based education program. That recommendation is not in the March draft but should be. The JIA board may say it cannot afford to fund this program, but the CP should nonetheless recommend that the board do so.

5. Section 7, “Environmental Assessment Procedure, p. 69, says, “New commercial buildings must consider certification through LEED, Green Globe or some other environmental certification program. Proposed development projects that do not include environmental certification must provide an explanation to the EAP review Team as to why certification is not plausible.” Asking developers to simply “consider” adhering to the standards of an environmental certification program is insufficient; certification should be strongly recommended, if not required, for new commercial buildings.  Furthermore, the cost of adhering to “green” standards should not be an acceptable reason for a proposed project to be exempted from environmental certification.

6. The CP should recommend appropriate criteria for the selection of the two outside individuals who will be appointed to the Environmental Assessment Procedure (EAP) Review Team by the JIA Executive Director.  Since this Team will have a voice in deciding if proposed development/redevelopment projects are consistent with conservation objectives or in need of revision, the naming of the two non-JIA members of the Team is clearly a matter of some consequence.

7. The CP should include a recommendation for public and independent professional review of EAP Review Team decisions. Since the Jekyll Island Authority has usually given the public an opportunity to review proposed major development projects, this should also be the case with development projects evaluated by the EAP Team.

8. In Section 8, “Staffing, Partnerships and Funding,” the CP should recommend a time frame for hiring a Director of Natural Resources and should provide a detailed job description for that all-important position.  

9. The CP should recommend that the JIA initiate a professional visitor capacity study, which would include the identification of indicators of quality resource conditions and visitor experiences; establishment of standards that define minimum acceptable conditions, and the formulation of monitoring techniques to determine when management action must be taken to keep conditions within established standards.  Such a study would provide the JIA with a framework for determining how much development and how many visitors the island can handle without unacceptable impacts on wildlife habitats, beach conditions, hydrological functions and the overall quality of the visitor experience.

10. The CP should include a glossary in order to identify and explain key names, terms, phrases, etc. used in the Plan.

11. The CP does not make clear the method used by the Georgia Department of Natural Resources (DNR) for determining the number of acres on Jekyll Island that are classified as “developed.” Also unclear is why the March draft classifies 230 fewer acres as developed than does the January draft.  We know that the CP Committee attributes the changes in acreage calculations to the DNR’s refinement of its mapping of communities and land use types on Jekyll Island, but a change of this size (1,550 acres instead of 1,780) is hard to understand without details on the DNR’s methodology.

12. The January draft CP is not posted on the JIA’s website, which means that people can’t compare that draft to the March 7th version of the CP to determine the extent to which public input regarding the January draft is reflected in the latest version of the CP.  This omission may have discouraged some people from submitting comments about the revised version of the CP. Since the April 1 deadline for public comments is just a few days away, this problem should be resolved immediately. 

13. At the March 25 public forum, the CP Committee presented its responses to some of the public comments submitted regarding the January draft CP. Those responses—some of which reflect favorably on the Committee’s handling of public input— should be integrated into the final draft of the CP. The videotape of that forum should be posted on the JIA’s website.

14. Written comments about the March draft and public forum should be appended to the CP, as was the case with the previous draft.

15. The final draft of the CP should be posted on the JIA’s website at least two weeks before the Plan is submitted for consideration by the JIA board of directors so that members of the public have a chance to review the CP and, if necessary, formulate questions or prepare comments in advance of the board meeting at which the Plan will be discussed.  All 3 drafts of the CP (each dated to separate it from the others) should appear on the Authority’s website

Thank you for giving the above recommendations your full consideration,

Sincerely,

David and Mindy Egan
Co-Directors, Initiative to Protect Jekyll Island State Park
308 Old Plantation Rd.
Jekyll Island, GA 31527
www.savejekyllisland.org







                           Altamaha RIVERKEEPER

P.O. Box 2642
Darien, GA 31305
Phone: 912-437-8164
Fax: 912-437-8765
email: stewards@altamahariverkeeper.org
website: http://www.altamahariverkeeper.org


                                                                                                                  March 30, 2011

Dear Mr. Exum and Dr. Norton,
Altamaha Riverkeeper (ARK) appreciates the opportunity to comment on the draft Jekyll Island Conservation Plan. The Jekyll Island Authority (JIA) is to be commended for moving forward with the creation of the Conservation Plan (CP) at this time, and the Conservation Plan Committee is to be commended for its work on the plan generally and especially for the improvements made to the plan in response to public comments on the January 2011 draft, and for the receptive treatment of public input during the drafting process. Certain matters addressed in the plan still present concerns, however.
Of greatest concern to ARK is the fact that the goals stated in the plan are not practically meaningful without a clear delineation of the 35% of the land area on Jekyll Island that may be developed and the 65% that must be left in a natural state, per Georgia law. Until this delineation is made, meaningful conservation on the island cannot take place. ARK urges the JIA to move the process of this delineation to a conclusion during the process of updating the Master Plan this year. ARK also asserts that the method of calculation for the delineation of acreage should not include any marshland as “upland.”

ARK also urges the JIA to fund and fill the position of Conservation Director as soon as possible to expedite implementation of the CP, as the CP is meaningless without staff to carry out its objectives. The CP should set a definite timeframe for filling the Conservation Director position.

The CP should, but does not, call for a professional visitor capacity study to determine impacts and recommended limitations and management of human use and activity on the island. Such a visitor capacity study should include the identification of indicators of quality resource conditions and visitor experiences; establishment of standards that define minimum acceptable conditions, and the formulation of monitoring techniques to determine when management action must be taken to keep conditions within established standards.  Such a study would provide the JIA with a framework for determining how much development and how many visitors the island could accommodate without unacceptable impacts on wildlife habitats, beach conditions, hydrological functions and the overall quality of the visitor experience.

The list of ecological threats, stressors and stresses in Section 3.7 of the CP should include “development” and “redevelopment.” This would make Section 3.7 consistent with other and later sections of the CP in which development is cited among the potential “threats and stresses” to the island’s wildlife habitats and natural resources.

Lastly, the CP should contain a more comprehensive and detailed program for monitoring of management actions and reporting the results of said monitoring, in Section 5.4.

Thank you again for the opportunity to make these comments on the CP.

Sincerely,

Sonja Cox
Altamaha Riverkeeper






                                                                     
                                                                            Amber L. Pitt, Ph.D. Interdisciplinary Ecology
                                                                            705 Bridgewater Drive
                                                                            Seneca, SC 29678


Jay Exum, AECOM
Terry Norton, Georgia Sea Turtle Center
Jekyll Island Authority
100 James Road
Jekyll Island, GA 31527

Dear Drs. Exum and Norton:

I am submitting these comments in response to the latest version of the Jekyll Island Conservation Plan. It was encouraging to see that the Jekyll Island Conservation Planning Committee integrated so many of the previously solicited public comments into the revised conservation plan. This process indicates a commitment to conservation on Jekyll Island and, as someone who loves Jekyll Island, I certainly appreciate the effort and considerations that are being made for conservation. My list of issues and recommendations for the latest draft of the conservation plan follows:

General issues and comments:
1) The plan does not set many specific measurable goals for conservation nor does it specify timelines for most of the goals that are included. Conservation plans must have measurable goals and a well-defined timeline in order to assess the efficacy of the conservation/management strategies.

2) No mention of determining a human carrying capacity of the island was mentioned. As the water availability for the island is already a concern and issue, further subdivision/(re)development of the island should be carefully considered even in existing footprints, especially since the Master Plan proposes an increased number of hotel and housing units.

Specific issues and comments:
Chapter 1, Page 4:
“The Jekyll Island Conservation Plan recognizes the need for income-yielding, developed portions of the Island respecting the statutory limit of 35% of the Island’s uplands as determined in the Jekyll Island Master Plan, and provides direction for less-restrictive protection of wildlife in these zones, in addition to providing for strong protection of the strictly natural areas of the Island (65% of the Island’s uplands).”

This statement concerns me and sets a negative tone for the conservation plan as a whole. As a reader, this statement suggests that the primary goal is profit generation and the conservation plan that follows is at best secondary and potentially may be disregarded by the Jekyll Island-State Park Authority (JIA). Although a financial strategy for sustaining Jekyll Island (JI) is necessary, the JIA also needs to recognize that conservation can be a financially sound strategy (e.g., natural ecosystems generate ecotourism, water conservation, storm surge protection, etc.) and need not be a secondary goal for JI but part of a comprehensive strategy for financial sustainability.

The phrase, “less-restrictive protection of wildlife in these zones” implies a non-conservation-oriented “anything goes” strategy for developed areas of JI. I am assuming at this point that the conservation plan will alleviate this concern as I continue to read, but again, as this is the opening statement in the conservation plan, it sets a really negative tone for what is to come and the average reader realizes that what happens on developed areas can have far-reaching impacts on wildlife in nearby (and sometimes far away) undeveloped areas.

Chapter 2, Section 2.0, Paragraph 1:
“it provides a vision for a long-term (50+ year) approach”
50 years is not long-term for an island or long-lived species

The Plan is expected to be clarified, refined, and adapted based on further research, improved techniques, and a changing environment.”
This statement concerns me because it is vague and the criteria for refining and adapting the plan are not explicitly listed. Will the plan be revised based on conservation goals or other objectives? Will the “changing environment” include a shifting baseline effect where we allow a certain amount of continued degradation to be accommodated in future revisions of the plan thus allowing for more destructive development and use practices as time goes on, eventually leading to yet another overdeveloped island? If the goal of the plan is conservation (which one would hope since this is the conservation plan for the island), the text should reflect that goal. Otherwise, it allows for creative interpretation of the plan which may undermine the conservation of JI. This may seem like “nit-picking” but the conservation plan is suppose to provide a “50+ year approach to protect, manage, and enhance” JI. Fifty years is longer than the average JIA member’s tenure so the clearer the language is from the start, the more consistently the plan can be implemented. Also, because the proposed (re)development changes to the island are controversial and many people are questioning the legitimacy of JIA’s commitment to conservation (as referenced in many of the comments in Appendix F), clearer language might also ease some of the minds of concerned stakeholders as well as provide clear direction for future JIA members.

Chapter 2, Section 2.1:
The mission and priorities are commendable and in-line with conservation goals and strategies and the tone is positive and leads the reader to believe that the rest of the plan will highlight how the “four primary areas of focus” will be achieved.

“The Committee determined that data compiled under the framework of the NatureServe Ecological System should be used as a baseline for implementing plans for resource protection. The scope of work for the creation of this conservation plan includes:
• compilation of existing data,
• use of NatureServe landcover maps prepared by the Georgia Department of Natural Resources as base maps”
Using the NatureServe Ecological System (NES) for the baseline appears to be a logical choice, but I am wondering if the data will be updated with the availability of higher resolution and more complete data. Based on information available on-line (e.g., http://landscopedemo.natureserve.org/visitLocal/conference/BWB2010/04-28_PCrist-GA.pdf ), it appears that the people involved with the NES realize that there are some areas/species for which information is incomplete. Obviously, future development/non-restorative land use changes that happen should not be considered “baseline”, but as more information becomes available for particular species of concern that have not been adequately assessed for distribution and habitat use, that information should be incorporated into the plan to enhance the plan’s accuracy and conservation effectiveness.





GEC
Glynn Environmental Coalition
P.O. Box 2443
Brunswick, Georgia 31521
www.glynnenvironmental.org


                                                                                                            April 1, 2011

To: Jekyll Island Authority
     100 James Road
     Jekyll Island, Georgia  31527

Jay Exum - Jay.Exum@aecom.com
Dr. Terry Norton - tnorton@jekyllisland.com
Re: Jekyll Island Draft Conservation Plan Comments

Dr. Exum and Dr. Norton,

Enclosed, please find the comments on the March 2011 Draft Conservation Plan (CP) for Jekyll Island.  The most recent CP draft is a vast improvement over the previous draft.  Still, more work is needed to flesh-out the CP.

The Jekyll Island Conservation Plan comments submitted February 9, 2011 are incorporated into the comments below via reference.

The Conservation Plan for Jekyll Island must be competed, and be a document in which the people of Georgia take pride.  The improvements made since the February 2011 draft are a good step in the right direction.

Sincerely,

Daniel Parshley, Project Manager
Glynn Environmental Coalition
www.glynnenvironmental.org
 

Comment 1. – Conservation Plan (CP) Section 3 and 4 has been improved greatly.  The history of how the island came to this point in time will be very helpful in developing the CP.  Identifying the challenges the CP must correct or contend with prepares the CP for the Sections that follow.

Comment 2. – The history, environmental setting, vegetative and wildlife communities, and geology are adequately described.  Appendix E identifies work to be completed under the conservation plan.  When possible the CP should refer to the appropriate section in Appendix E.

Comment 3. – Conservation Plan Evaluation – Appendix E should be used to evaluate the effectiveness of the CP.  An evaluation of the CP should be conducted every five years.  Areas of improvement and degradation should be noted and plans implemented to correct problem areas.

Comment 4. – The delineation of the 35% developed and 65% under conservation must be clearly defined and be part of the Conservation Plan, even if the task is scheduled to be completed during the draft and final Master Plan (MP).  At a minimum, the critical habitat areas should be identified in the CP, and recommendations made to the MP Committee.
The following are suggested recommendations:
A. The standards being used for "the land of Jekyll Island" for the 35% developed and 65% under conservation appear to be incorrect.  The 1996 JI Master Plan (MP), on page 9, there is a map of JI.  On this map is a "4.3 mean high water mark", which is the level where land is considered "useable".  But the state of Georgia claims as the “Waters of Georgia” at 5.6 feet above mean tide level under the Coastal Marshlands Protection Act, (CMPA)  O.C.G.A. 12-5-280, and this standard applies to delineating the uplands on the river side of JI, and another law protects the beach, and another set of standards apply on the beach side. But there is also the 9.5 tree line standard, which should be used as the developed/undeveloped standard to protect the fragile boundaries between the uplands and estuarine areas of Jekyll Island (JI). The area between above the delineated “Waters of the State of Georgia” at 5.6 feet and the “tree line standard” of 9.5 feet should be included in the areas to be conserved and permanently be designated as a buffer between the upland and beach/estuary areas.  The CP Committee should recommend the Master Plan Committee use the above criteria when establishing the 65% undeveloped and 35% developed areas.
B. The 65% of JI to be conserved should be placed under a conservation easement and permanently protected.  Once land is developed, conversion to a natural state is next to impossible due to the disturbance to the underlying soil structure.
C. The Conservation Plan does not specially designate "conservation areas" (the parts of the island that will not be developed) and a plan for these areas, and the developed/recreational areas.  The plan should address how conservation measures will be conducted in each area, and designate the areas on a map.  Once the areas are delineated, plans for public access or viewing can be completed.  The public is currently pulling off the road to view wildlife, and these areas are easily identifiable along the road.  Improvements to the roadsides should be considered.  Furthermore, the Jekyll Island Authority should consider development of a driving and parking point guide for wildlife viewing.  A product like this would be particularly helpful for families with small children.
D. The plan should define conservation measures for the developed and undeveloped areas.  Wildlife will not respect boundaries between the two areas.  Also, areas between forest and meadow are important for many species.  In the case of Jekyll Island, these will often have overlap between conservation and development areas.  The CP Committee is correct in developing a CP for the entire island, irrespective of any anticipated boundaries between developed and undeveloped areas.
E. Since the current conservation plan is a "Conservation and Recreation" plan, critical habitats like bird nesting areas should have a "stand-off" area designed in by routing paths trails, and viewing areas an appropriate distance away.  Each species will have a comfort level for how close people come to their nesting or roosting area.  The minimum distance from these areas should be designated (or at least a recommendation) in the Conservation Plan. The “stand-off” recommendations can be added to Appendix E.   Furthermore, the Conservation Plan should identify these areas as "critical habitat" and be designated as such on a map.  Designating the 35% for development activities and 65% under conservation will be needed before final planning for wildlife in critical habitat areas can be designed into the Jekyll Island Conservation Plan and Master Plan.
F. Paths, trails, and viewing areas should be considered "development".  Since people will frequent these areas, plans should include where bathrooms and trash collection will be located and how they will be accessed. To the extent possible, parking and bathroom facilities should be located near major road routes, be handicapped accessible, and away from critical habitat areas. The plan should keep in mind that bathrooms will be high traffic areas and popular for picnicking and other activities. Design and location of amenities can direct people away from critical areas while still making points of interest for nature viewing accessible.   The vast majority of people will use the designated trails and paths for viewing or photography.  The Conservation Plan should include recommendations for where public viewing and photography areas should be located and where the supporting amenities should be located. 
G. It is important that the Conservation Plan be part of the development plan and Master Plan, and not a standalone document that guides conservation and development.  Completion of the Conservation Plan is needed first in order to be incorporated into the Master Plan.  At some point in the development of the Master Plan, the CP should be incorporated into the Master Plan as a completed document (when the 65%/35% has been designated would be an appropriate time).

Comment 5. – The Jekyll Island Authority, Brunswick Port Authority, Glynn County Government, and the St. Simons business community should meet with the U. S. Army Corps of Engineers (ACE) concerning the sand sharing plan for coastal Georgia in relation to the Brunswick Ship Channel.  An evaluation of the current location and shape of the ship channel should be conducted.  The Brunswick Ship Channel is atypical in shape and location when compared to natural occurring ship channels on the Georgia coast, and could be a major factor in the failure of St. Simons Island to migrate south, and Jekyll Island to accrete sand on the north end beaches.  The economic ramifications of the ship channel maintenance plan can no longer be ignored.  No less than the future economic viability of St. Simons Island and Jekyll Island are hanging in the balances.

Comment 6. - French drains and swales are good tools and recharge the groundwater, which allows for a controlled release to wetlands through seeps and such.  In the final analysis, the water holding structures for any new development need to be designed with realistic capacity goals in mind. Usually, the pervious surface also costs less.  The Request for Proposals (RFP) and the resulting bids for the pervious surface and impervious surface should include performance standards based upon actual rainfall records.  An "impervious" surface can be mitigated with a leach field under the surface or "French Drains" that hold the water and let it percolate into the ground.  The only other option to an impervious surface is a retention pond, which is expensive in land use and construction.  There are many options to achieve the goal of reducing or eliminating excessive runoff.  The Conservation Plan should have a plan for conserving the surface and subsurface hydrology and specify the tools to be used during future development should be identified and incorporated into the CP via an appendix to achieve this goal.

Comment 7. – The incinerator ash disposal area west of the former incinerator location should be designated as a developed area.  Furthermore, the area should be designated for further investigation by sampling and analysis to determine the extent of contamination by combustion byproducts such as dioxin. Elevated dioxin levels found in Jekyll Creek by the National Oceanic and Atmospheric Administration are most likely emanating from the incinerator ash disposal area. The CP should identify the ash disposal area as an area of concern.






Environment GEORGIA
817 West Peachtree St. N.W., Ste. 204 • Atlanta, GA 30308
Phone 404-892-3573 • Fax (404) 892-5201


April 1, 2011
Jekyll Island Authority Conservation Plan Committee
100 James Road
Jekyll Island, GA 31527

To Whom It May Concern:

Thank you for your work as you continue to refine Jekyll Island’s Conservation Plan.
Environment Georgia, a statewide non-profit and non-partisan environmental organization that is funded by citizens around the state, appreciates the opportunity to provide comments and feedback. Please feel free to contact me with any further questions at Jennette@EnvironmentGeorgia.org.

First, we commend you for identifying development as a major threat to the flora and fauna that rely on the unique wild spaces that exist on Jekyll Island State Park and we urge you to strengthen your recommendations by:
• Amending section 7 to:
1. Clarifying the criteria that will be used to approve or deny future development or
redevelopment proposals. The criteria should clearly take into account the impact that
more visitors, vehicles and impervious surfaces will have on the island’s ecosystems as a
whole and should be based on a better understanding of what a 4,000 acre island, of
which 65% is to remain undeveloped, can sustain while still allowing undeveloped areas
to thrive.
2. The language in paragraph 1 of section 7.2 continues to weaken the Conservation Plans
ability to actually impact local and site scale proposed development or redevelopment.
We recommend the following amendment:
“Potential design changes or alternative locations for proposed projects that could cause
significant local/site scale natural resource impacts must be considered, and/or the project
(not) may/ (but) will be deemed inappropriate.”
3. Do more than ask that commercial buildings consider the latest green building and design
techniques. We urge you to require ALL new building to adopt these common sense
standards to help minimize impact of future development or redevelopment.

• Amending Section 8, “Staffing, Partnerships and Funding,” the CP should recommend a time frame for hiring a Director of Natural Resources and should provide a detailed job description for that all-important position.
• Improving monitoring requirements. In light of the importance of monitoring, the Plan
should include a more comprehensive monitoring program—including specific management controls—and a strong recommendation that the JIA provide the staff and funding to implement it.

Finally, the development on the 35% of the island that is not restricted by state law can obviously have an impact on the entire island, at the same time the sincerity with which the remaining 65% is protected is also critical. The Conservation Plan explains that it will leave this decision up to the rewrite of the JIA’s Master Plan. We applaud you for outlining “Special Protection Areas,” in Figure 7 but continue to urge you to go further by expanding your identified ‘special areas’ and clearly recommending these areas included in the 65% in the future.

Please also clarify the method used by the Georgia Department of Natural Resources (DNR) for determining the number of acres on Jekyll Island that are classified as “developed.” As indicated in our previous comment the presentation of the marshland adjoining Jekyll Island State Park as one of the island’s vegetative communities seems to inappropriately communicate the intention of counting the marshland in the 65% of the island that will be protected. While it is appropriate to discuss strategies for protecting the marsh we urge you to clarify this point.

Thank you again for the opportunity to comment on this very important plan, we look
forward to reviewing future drafts and are happy to answer any questions moving forward.

Sincerely,

Jennette Gayer
Environment Georgia
Jennette@EnvironmentGeorgia.org
www.EnvironmentGeorgia.org






Comments on JISP Conservation Plan, 3/31/11
Ken Cordell, Ph.D.
Jackson County, GA

(Acknowledgement of receipt requested)

Following please find my review of the revised Conservation Plan for Jekyll Island State Park. As you may recall, I sent my review of the January CP draft to you and also to both Drs. Bob Manning (U. Vermont) and Glenn Haas (Colorado State University and SU and National Association of Recreational Resource Planners Board). The purpose for sending that review to those individuals was to get their reactions, given that I had used National Association planning principles they helped develop as my organizing framework. Both Drs. Manning and Haas confirmed appropriate and helpful application of those principles, including my reference to the critical need to conduct a visitor capacity analysis. In my view, the Association’s Planning Principles are extremely well done, and they and the professionals who put them together are held in very high regard in professional planning circles.

I further submitted and had that earlier review published in the Association’s Newsletter in order to share with member planners an application of their Principles in critiquing a planning process underway. My comments then, as now, are meant to be constructive by suggesting ways to enhance the JISP conservation plan. I believe that conservation planning is the key to the sustainability of Jekyll Island as a state park and ecological reserve. I find that the plan is still in need of some attention.

I am submitting my review in two parts. First is an abbreviated revisitation of some of my key concerns with the January draft that also now apply to the March draft. Second are some additional observations and concerns by page number that are specific to the March draft.

Key Concerns regarding both the January and March drafts

The italicized sentences below are selected applicable planning principles as published by the National Association.

A Contract with the Public: A … plan is a contract with the … public and affected stakeholders that transcends any one person or administration, and as such should be detailed, unambiguous, and provide for accountability.

Cordell Comment.—The introduction to the earlier as well as the current plan drafts indicate that they are meant to provide a framework for protecting and managing natural resources on Jekyll Island (State Park). However, this framework as it currently stands does not rise to the level of a contract. While this second draft seems to move further toward making a contractual commitment to protection of Jekyll Island’s naturalness, it appears to leave the future open to many contingencies and good intentions. A plan should be a contract with Georgians, but the March draft does not seem to be that level of commitment.

Represent the Public Interest: Resource planning is a collaborative public process that deters the bias of special interests, political intervention, or incremental unplanned decision making.

Cordell Comment.—It has been good to see that in working toward the March draft, more attention seemed to be devoted to listening to the diversity of citizen interests in the conservation plan. However, development of the JISP conservation plan still looks pretty much like “planning by committee”. This planning committee includes JISPA staff and others who in my view likely don’t represent the statewide and citizenwide diversity of JISP interests. Planning by committee usually means drafting a plan that is then, after the fact, distributed for comments. Comments are then considered, but not in any way weighted, nor responded to. Frankly, this is “old school” planning.

Old school planning means you decide what you want to do and write it up without early-on engagement of citizens and key interests as a part of the team. In all public land planning, citizens should have an influential voice at the beginning of the process. As well, an open planning process would welcomed all citizens and groups expressing an interest in being a part of the team. The JISP conservation framework project could have benefited from early citizen engagement and involvement of citizen volunteers. Instead, the JISP conservation project was largely a closed process, and a number of offers of help were rejected or ignored.

“New school” planning engages (in fact, aggressively recruits) citizens and key interests at the beginning, before the first sentence is written. A citizen involvement plan is among the first steps in new-school planning processes. There is a serious effort put forth to hear and understand public opinion, not just friendly opinion. As well, citizens who want to be involved are welcomed into the proceedings. Park management and consultants are there to listen, facilitate, encourage, gather data, analyze, report out (to citizens early and often, not just to a board). As we all learn better ways of planning for stewardship of public lands, we can and should look toward improvement of future planning projects that we know are coming. A prominent example for JISP is the upcoming master planning project. With this project lies an important opportunity for the JISPA to strike a very different chord. This is an opportunity for the conservation plan committee also. This committee has an opportunity to become a strong advocate for improvement of JISP planning proceedings that would feature significantly greater public involvement. Application of modern planning principles applied to master planning would stress that public involvement will be aggressively pursued at the very beginning and that the full scope of public and stakeholder interests are at the table.

Visitor Capacity is an Essential Ingredient of Conservation Planning

Comment: Visitor capacity analysis is one of the most significant pieces of park planning. Jekyll Island State Park is a major destination and favored island environment for nature-based recreation and tourism. Protection of naturalness is paramount to sustaining recreation and tourism. By not conducting a rigorous analysis of recreation visitor capacity, it is not possible to define needed management objectives and strategies to protect the island’s natural systems. What will the interaction be between different levels and kinds of recreation use, commercial development, natural processes (e.g., erosion and sea level rise) and regional influences?


Systems Approach: Resource planners must consider how their resources fit into a larger regional system, how their potential … alternatives might be linked to larger systems.

Comment.—There still is a significant need to analyze how Jekyll Island fits into and what its relationships are to other SE coastal areas, including other islands, estuaries, marshes and human communities. The focus of earlier and of the current conservation plan draft is pretty much solely on resources within the borders of the island itself. Yet, JISP is inextricably linked to river, marsh, ocean, island, and other natural systems, and to Brunswick and surrounding communities. As one example, there was no analysis I could find that projected the impact on JISP natural systems from population growth in nearby communities and up river.

A Process: While the specific terms and steps in a … planning process often vary across institutions, all resource planning in some manner includes:
• …collaborative stakeholder involvement.
• …evaluating and selecting the preferred alternative.
• …best available science and information.
• …Formulation of alternatives….
• …benefits and affects of each proposed alternative.
• …full and reasoned analysis.
• …monitoring.
• …adaptation or revision.

Comment: Four of the 8 plan components listed above explicitly refer to consideration of alternatives. Perhaps I overlooked it, but I could not find in the current conservation plan draft any identification of the alternative management scenarios considered, nor the criteria evaluated leading to selection of what appears to be the preferred alternative described in Chapter 5, especially the desired future conditions in the Introduction. At a minimum, needed is a description of the range of reasonable alternatives considered and an evaluation and comparison of their costs, benefits, effectiveness and effects. In conservation, business or any other planning there must be alternatives to evaluate. If this is not provided, how can the JISPA and its board make rational decisions concerning adoption or rejection of the plan being put before them? What were the alternatives they could have considered?

Comprehensive and Integrated: Planning should consider other significant natural and cultural resources, uses, demands, and values in an integrated and comprehensive fashion. Functional planning, whereby one resource is planned for in a vacuum from other resources, is not appropriate and is contrary to comprehensive and integrated planning.

Comment: Integration of all planning for JISP would greatly benefit decisions and future management. This means integration of conservation planning, development planning (already being implemented of course), recreation site and facility planning, education planning, master planning, fiscal planning, partnership planning and any other planning. Planning could thus better identify and consider a comprehensive range of management alternatives, instead of isolated consideration of objectives and portions of the island resources.

Budgetary Tool: An effective plan should include projected budgetary needs.

Comment: The JISP conservation plan does not include a projection of budgetary needs across a reasonable set of conservation management alternatives. Without a cost and budget needs projection, how will it be possible for the JISP Authority and its board to rationally consider the conservation plan in whatever form it is finally submitted. Without a cost and budget analysis one is left wondering what level of commitment there is or will be to natural resource conservation.

Additional observations and concerns with the March draft

Below you will find review comments specific to the most recent revision of the conservation plan.

P. 5 Why not call the document a framework or strategic framework? See the copied portion of the introduction below. Also, in the Introduction quoted below, reference is made only to natural resources. State parks, including JISP, are established to protect also the cultural resources—physical and social. While the emphasis is on natural resources, it seems to me that protection and stewardship of cultural resources can be acknowledged and the importance of the relationships between natural and cultural given attention.

“The intent of this Plan is to create a framework for protecting and managing the natural resources of Jekyll Island, part of the Georgia State Park system managed by the Jekyll Island – State Park Authority (JIA). It is not the final story for conservation; instead, it provides a vision for a long-term (50+ year) approach to protect, manage, and enhance the sensitive environments of this barrier island.”
P. 7  GADNR work on the island was cited here, but no specific reference nor link was provided. Throughout this framework document specific citations of sources is needed.

P. 8  As a citizen, I ask that we citizens be involved up front in any 5-year revisions of the conservation framework. This step works very well to reduce contentiousness in planning. Clear ownership of planning by the island owners is a solid foundation. By owners I do not mean owners of houses, I mean citizen owners of the state park.

P. 30  The importance of estimated acreages of the JISP “Project” (5,847 acres) and of the marsh cannot be overstated. It is not clear what is meant by “project”, but it is very clear that the upland area of JISP should not include marsh. By cross referencing laws, we know that marsh cannot legally be considered island upland area. I recommend that this be clarified so that it is understood that it is 65% of the island upland area that is to be delineated and protected.

P. 43 and Figure 6   I have worked in public land management and research for a number of years. I have a great deal of experience with research and policy specifically concerning trail systems. In the draft plan you identified four primary areas of focus.
1. preservation of biological communities and species diversity,
2. restoration, maintenance, and management of the Island’s ecological processes,
3.      nature-based tourism and recreation, and
4.      environmental education.

Later on, the conservation plan went further to say that a number of new trails have been identified to be recommended. I am happy to see the emphasis given to recreation trails. However, in looking closely at the plan, at the four focus areas above, and in looking for the decision analytics used, I am a little puzzled. Trail planning, actually any planning, goes through a public process of identifying and prioritizing alternatives. I could not identify where those alternatives for trails were described, nor where a comparative analysis was done. As well, where is the use and use impact analysis from new trails. I can see some possible grounds for a legal challenge of the plan’s emphasis on creation of new trail segments as shown in Figure 6, page 61.

What is proposed are new paved and unpaved trails. In trail policy and design, it is imperative that a thorough ecological impact assessment be conducted, and that public visitor preferences be clearly analyzed. I could not find reference to either of these. How did you decide that new trails are needed from the visitor’s perspective. How did you decide new trails would be used? Perhaps more importantly, how were forest fragmentation, wildlife disturbance, and soil and hydrology impacts at or in areas adjacent to trails considered? These likely impacts should be considered and included in the planning analysis. Habitat fragmentation refers to conversion of large expanses of habitat (such as Jekyll Island forest areas) into multiple smaller patches which become isolated from each other and then interrupted by other types of vegetative or manmade cover (Fahrig 2003 and Lampila et al 2005 are examples of this research). The additional trail segments you identified in the plan need to be seriously reconsidered if a fragmentation and habitat impact analysis has not been done. This actually is needed for any land development from trails to structural development.

In finishing, let me say that agencies charged with managing public lands realize that conserving nature, and even restoring ecosystem functioning is central to nature-based recreation, tourism and environmental education. If this has not been done well, visitor experiences relative to their expectations may fall well short of the mark. This of course underscores the importance of a solid conservation plan built on best science and a clear understanding of public expectations and preferences. There are a number of us who as citizens and experienced professionals will be more than happy to help in further developing plans for the future of Jekyll Island State Park.
 
Ken Cordell, Ph.D.
706-540-0499 (Cell)
706-559-4263 (Office)
1119 Highway 330
Athens GA, 30607






March 29, 2011

To: Drs. Jay Exum and Terry Norton

The committee has worked hard on this Plan and should be commended for it. Your acceptance of and attention to public input are greatly appreciated. Jekyll Island is a unique and wonderful place which
should be preserved as well as possible so that future generations can also discover its magic. The newest version of the Conservation Plan has made many improvements, but could still see a few more.

I was delighted to note that the current version of the CP supports limiting development of the island to 35%, preserving the 65% of the land which must remain undeveloped in accordance with existing laws.
Reviewing the effects of future development on natural resources is a wonderful thing to have included in the CP's mission. However, wildlife within the developed 35% of development must still be cared
for. Visiting, living, and working on such an ecologically unique and important island should put people in mind to respect the wildlife coming into developed areas. Also, future development of the island
would greatly benefit from delineation of that 65% percent to remain undeveloped. The areas designated for preservation should be set up to be as continuous as possible. Having many smaller habitats does not provide as good a quality of life for animals and plants living in those areas as would having a few or one larger habitat, even if the overall land area was the same quantity. During delineation, the CP should not include the adjoining estuarine marshlands. Including the marshlands creates an artificial increase in acres eligible for development.

Thank you for acknowledging the widespread public input and including Appendix F of the over 300 comments.

I am glad that you addressed the lowering levels of ground water and asked for further studies of the reduced hydrological functioning of the island and its causes. The later mention of further research on
the diamondback terrapins on and adjacent to the Causeway and the improving the Causeway's effects on local hydrology follows this idea. Thank you.

The improved island history including the dredging operations and marina complex is greatly appreciated. The added information on the archaeological sites and investigations goes well with the expanded
history.

The Ecological Threats and Stresses (Section 3.7) has forgotten a very important one: development. While I recognize that controlling development is part of the CP's mission, development must still be
included as a stressor. This exclusion is incongruous with development's mention in both 'Vegetative Communities' and 'Island-Wide Management' sections as having "the greatest potential to fragment habitat continuity or result in the loss of natural habitats." How can development be called a stressor throughout the plan, but not actually be included in the list of threats and stresses?

What is the actual acreage of the developed land? In the January draft, 1,780 acres were listed as developed, but in the March CP, it was 1,550. This large of a difference could greatly affect how much land is conserved. How did each draft determine acreage? Obviously, some changes were made regarding what qualified as 'developed'.

New buildings should be required to seek LEED certification. Merely considering it does not benefit the environment. How does one prove consideration? A policy of only requiring consideration leads to
builders thinking about going for LEED but then deciding not to do it. That would not be in line with the mission of the CP.

Thank you for adding Reporting to the section on Monitoring. As an ecologist, I recognize that reporting is a vital part of monitoring. Monitoring an area over time becomes more difficult when there is less
reporting. Having recognized the importance of monitoring, the CP should outline detailed staffing and funding guidelines.

Incorporating more detail regarding the Education Subcommittee's work is good, but it does not make up for eliminating the recommendation for full time staff for nature-based education and providing a funding plan for that staff and those programs.

The commitment to include a Director of Natural Resources is commendable. Putting it in the next fiscal year is understandable and provides time to set up a budget. A time frame and a plan for filling
this position should also be included in the CP along with a more detailed description of duties and obligations of the position, in order to allow proper recruitment and advertising of the postion. Leaving the position open for a long period of time will not help the island.

As always, thank you for your attention and your reviewing of public comments.

Jessica Prescott
Aquatic Ecologist
Meredith College 2010
B.S. Biology






Center for a Sustainable Coast
221 Mallory Street, Suite B
Saint Simons Island, GA 31522
Phone 912.638.3612
Web: www.sustainablecoast.org

"Conserving Coastal Georgia's Natural Heritage
Investing in Our Children's Future"


March 31, 2011

Additional Comments on the Jekyll Island Conservation Plan
                  
~   Recommendations must be made in the CP and they must be specific.

We cannot simply assume that the master plan will consistently make decisions and form positions that are logically based on analysis in the CP.  For example, when I urged a recommendation in the CP that would give priority to ensuring that the definition of the 65% natural area of the island would include all the most valuable ecosystems and critical habitat, Eric Garvey said, of course the CP would be used in making decisions in the MP.  Assuming the rational use of information, and specifically the designation of the natural areas boundary to achieve maximum protection of the island’s most valuable natural assets, is by no means a foregone conclusion.  The CP would be falling short of its potential by failing to make explicit recommendations that will help ensure the MP makes the best possible use of environmental analysis in the CP – including buffers and development evaluation procedures as well as designation of the 65% of the island that will remain undeveloped.

~   Management controls must be provided to achieve management objectives.

If the CP is to achieve its goal of being a true management plan, it is not enough to propose management objectives and management actions unless there are corresponding management controls.  These controls would be a combination of specific obligations related to monitoring, assessment, and corrective actions taken, as needed, by a designated entity having the authority, responsibility and staffing to properly conduct management functions. Procedures for providing management control should be as specific as possible to make certain that the conservation program achieves it full potential.

~   Sea level rise must be thoroughly analyzed in the CP as a management factor, and related recommendations should be made.

Some six weeks ago an important article was published about urgent actions being taken in coastal North Carolina to respond to hazards caused by rising sea level associated with global climate change. [See below.]  It is only a matter of time (probably several years at most) before this issue imposes similar threats in coastal Georgia, yet none of the ongoing planning seems to reflect realistic, practical analysis of such factors.  Surely it would be a tragic mistake to ignore or marginalize rising sea level when making planning decisions involving large expenditures of public funds in support of development in high-risk zones at low elevations that are directly exposed to increasing risks of ocean storm-surge and flooding.

Many fail to grasp that, with the flat topography of the coastal plain, on average there is a 200-foot ingress of water for every one-foot rise in sea level. Even extremely conservative projections made by the Intergovernmental Panel on Climate Change (IPCC) now predict a 1-foot rise in sea level by 2050. Moreover, it is worth noting that every time the IPCC reconsiders new information and updates their previous prediction, sea level rise forecasts become more ominous.  What was predicted for 2100 ten years ago is now projected by 2050, primarily due to well-documented accelerated warming at the poles, which results in global ice masses melting at ever higher rates.  If this higher rate of polar warming continues, as many climate scientists believe it will, the 2050 sea level rise will be well above the most recent IPCC prediction. 
Of course, this means that in intermediate years natural hazards related to sea elevation will be increasing, perhaps drastically, during the lifespan of projects now being built.

Construction already underway lies in the path of these risks, and more to follow will be encouraged by infrastructure being planned by JIA and funded with millions in state bonds – which could ultimately be obligating repayment in tax dollars collected from Georgians.  At the very least, the conservation plan should recommend disciplined, sustained research of this issue with reliably ensured follow-up that will safeguard the public interest.

I urge you to step back and get advice from large organizations with analytical depth on these issues, including the Pew Center on Global Climate Change [see
http://www.pewclimate.org/climate-change-101/local  and
http://www.pewclimate.org/climate-change-101/adaptation ], and see the video at http://www.youtube.com/watch?v=kgCYhU5ISwI&feature=related .

[NOTE: See referenced article below]

Rising waters threaten the coast of North Carolina
Climate change is carving its name into the state's retreating shorelines. Planners are taking official notice as they prepare for a wetter world.

By Bruce Henderson
bhenderson@charlotteobserver.com
Posted: Tuesday, Jan. 18, 2011

MANNS HARBOR The sea that sculpted North Carolina's coast, from its arc of barrier islands to the vast, nurturing sounds, is reshaping it once again.

Water is rising three times faster on the N.C. coast than it did a century ago as warming oceans expand and land ice melts, recent research has found. It's the beginning of what a N.C. science panel expects will be a 1-meter increase by 2100. [At current trends, but could likely accelerate.]

Rising sea level is the clearest signal of climate change in North Carolina. Few places in the United States stand to be more transformed.

About 2,000 square miles of our low, flat coast, an area nearly four times the size of Mecklenburg County, is 1 meter (about 39 inches) or less above water.

At risk are more than 30,500 homes and other buildings, including some of the state's most expensive real estate. Economists say $6.9 billion in property, in just the four counties they studied, will be at risk from rising seas by late this century.

Climate models predict intensifying storms that could add billions of dollars more in losses to tourism, farming and other businesses.

While polls show growing public skepticism of global warming, the people paid to worry about the future - engineers, planners, insurance companies - are already bracing for a wetter world.

"Sea-level rise is happening now. This is not a projection of something that will happen in the future if climate continues to change," said geologist Rob Young of Western Carolina University, who studies developed shorelines.

Nobody knows how high or fast the sea will rise. Water isn't likely to submerge all the state's low coastland because landowners will fight back. But the coast we know, with its fringe of salt marshes, its fluffy beaches and old harbor towns, might look like a different place a few generations from now.

That won't be the work of rising water alone, but of quirks in North Carolina's coastal topography. The flat ground means even a small increase in water level will spread far inland. The coastal plain is also sinking, the geologic legacy of the last Ice Age.

Sea-level rise magnifies two other powerful forces - erosion that gouges the coastline and the pounding of nor'easters and tropical storms.

Storms, Young said, are "the hammer" of rising seas. As storm surges pound ashore on a higher base of water, their damage multiplies.

The Outer Banks, some scientists predict, could disintegrate into a string of high spots - Avon, Buxton, Ocracoke - reachable only by boat.

If storms punch new inlets through the islands, the brackish sounds and wetlands that serve as vital nurseries for Atlantic coast seafood species would turn into open saltwater. Predatory fish would pour into previously protected waters. Marshes would migrate inland or drown.

Dead bald cypress trees already rim the Albemarle-Pamlico Peninsula, graying in the encroaching salty water that engulfed and killed them. Much of the peninsula, which juts toward the northern Banks and is one the state's richest wildlife sanctuaries, could be underwater by century's end.

Human habitats will be forced into momentous decisions - fortify or flee.

A row of beach houses in the old resort town of Nags Head is collapsing into the surf now as the town plans a $36 million project to pump fresh sand onto its eroding strand this spring. Down the coast, in North Topsail Beach, property owners are waffling on helping to pay for a $10 million nourishment project.

As sand moves around, some beaches such as Sunset actually widen. But communities that control about a third of the state's 325 miles of beach face similar sink-or-swim decisions. The average cost of pumping sand onto eroding beaches is nearly $1 million per mile, repeated about every five years as storms wash it away.

One coastal village repeatedly swamped by storms is barricading itself, Dutch-style, behind a 17-mile dike.

State planners are preparing detailed maps of future high-water lines, groundwork for an eventual retreat inland of both people and buildings. [DNR is doing similar work in Georgia.]

"To me, it's the big planning problem for this century," said Scott Shuford, planning director in Onslow County, on the southern coast. "There's an element of urgency about it, but at the same time a recognition that it can't be solved easily."

Drafting sea-level policy

It seems implausible that an almost imperceptible rise in the sea - about the thickness of two nickels a year - could cause such havoc.

But it took only an 8-inch global rise to threaten the iconic Cape Hatteras Lighthouse, which was 1,500 feet from the Atlantic when it was built in 1870. By 1999, when hydraulic jacks gingerly nudged the striped brick tower inland, waves crashed at its foundation.

Long before people were capable of such engineering, the sea and wind were shaping the Carolina coast. After the last Ice Age peaked 11,000 years ago, melting glaciers turned Pamlico Creek into Pamlico Bay, then into Pamlico Sound.

Coastal geologists who reconstructed sea-level changes on the northeastern N.C. coast say levels were stable for 3,000 years. The sea began rising in the 19th century. The rate of climb doubled again in the 20th century, with a further quickening in the past 30 years.

Alonzo Leary gauges the changes over the 74-year span of his life. Raised near Albemarle Sound in a farming community called Alligator, he left as a young man to find work. He returned 20 years later to find old swimming holes flooded and the sound closer to road level.

"I notice that the swamps stay full of water most of the time," Leary said.

Scientists envision more acceleration this century. Some say seas could rise to as much as 6 feet above current levels by 2100 if large ice masses melt in Greenland and Antarctica.

Because the stakes are so high, local and state policy leaders are paying new attention to sea-level rise.

To help plan for building new roads, bridges and other infrastructure, a state panel of engineers and scien

tists recommended estimates last year that the sea will rise 15 to 55 inches by 2100, with 39 inches, or 1 meter, the midpoint.

The N.C. Division of Coastal Management is circulating drafts of what could become the state's first policy on sea-level rise. If adopted, the policy would lay the groundwork for regulations influencing development and how public structures from boat ramps to bridges are built.

When state transportation engineer Ted Devens and his colleagues recently designed a 28-mile widening of U.S. 64 across the Albemarle-Pamlico Peninsula, they raised the roadbed by a foot to allow for rising seas. It was a first for an N.C. Department of Transportation road project.

"What we're trying to do is get away from the hype and just look at the data," said Devens, who works in project development and environmental analysis. "Our data tells us sea level is rising.

"What do you plan for? That's been the big question."

Armed with a $5 million federal grant, state planners are using high-resolution flood-plain maps and geologic data to assess future flood risks from higher seas and storms, and how to respond.

At some tipping point - state officials calculate sea-level rise will cause significant problems by about 2042 - decisions will have to be made. Infrastructure such as water and sewer lines, and industries, will have to be moved inland.

"Do you move those things now or do you wait? It gets to be an interesting chicken-and-egg question," said study leader John Dorman of the state flood-plain mapping program.

Other key questions: where to move both structures and people, and how to pay for it?

In the little town of Plymouth, where the Roanoke River flows into Albemarle Sound, storms regularly submerge the century-old sewage system, once stranding a town employee at the treatment plant. It will only get worse as water in the sound rises.

"Everybody's going to have to start figuring, where do we go from here?" said Mayor Brian Roth. "We know that we're going to have to deal with these issues. These small towns cannot possibly handle the money this is going to take, no way."

Rob Young, the coastal geologist, credits the state's planning efforts. But if the state were serious about adapting to rising seas, he says, it would be smarter in responding to the storms that already hammer the coast.

Beach communities shredded by hurricanes are typically built back, sometimes repeatedly. Taxpayers subsidize federal flood insurance, roads and bridges.

If seas rise by 1 meter, Young said, engineers could fix the holes storms would blow through the rim of barrier islands, as long as the state can afford repairs. The problem of the future is that Charleston, Miami and other East coast cities also would be struggling to keep their heads above water.

"If we have to fix Manhattan," he said, "Hatteras is not going to compete for money real well."


Comments on the Jekyll Island Conservation Plan, February 11, 2011

In December, when I pointed out the obvious need for the CP to address the legally establish split between 65% of the island’s area to be retained in natural condition and limiting development to no more than 35%, Jay Exum said there was simply not enough time to “resolve” the issues related to 65/35 questions.  However, my assertion was not intended to suggest that all such matters should be resolved in the CP, but rather that certain fundamental questions should be identified and at least some recommendations about them relative to conservation resources should be made in the CP, which could then assist in resolving them through the Master Plan process.

For instance:

  • Should ‘natural’ areas in the 65% be restored in cases where they’ve been altered?
  • How should natural areas (the 65% lands) be restricted in their use and/or rate of use (e.g. visitors per day), and protected from risks caused by surrounding developed uses?
  • Should temporary active uses be prohibited from the 65% lands? If not, what criteria should be adopted, or at least considered, if they are to be temporarily used for more intensive activities?
  • How should conservation practices (“management actions”) be enhanced or elevated within the 65% areas?
  • Once dedicated as “natural” within the 65% area, should there be a ban on the practice of “swapping” and reassigning land in the course of future island development?
  • Who will be responsible for administering conservation practices and planning provisions throughout the island and for proposing and implementing needed plan refinements or revisions? What procedures will be used and how should they relate to the Master Plan? (Again, even if these matters aren’t resolved in the CP, at least recommendations should be made for further consideration in the MP.)
  • How does assessment of the value and condition of the island’s natural resources conform with currently delineated areas apportioned between natural and developed?
  • Should some areas be shifted from one designated category to the other so that conservation objectives can be enhanced? Should any such areas be restored as well as protected?

2.      There was repeated reference to the term “management action” in the CP. Based on over thirty years of experience in public policy analysis and planning, it is my opinion that, in general, the term “management” is much abused in programs and plans addressing environmental issues. Far too often actions are given ‘management’ attributes when they are simply recommended steps pursuant to a plan that has little to do with legitimate management.  To be worthy of the management designation, actions must be closely linked to specific planning objectives and – most importantly – they must be accurately and accountably evaluated to determine the extent to which they are achieving intended results.  In orally commenting on December 1, I suggested that the CP should be organized on the basis of all aspects of management – emphasizing management control, not just management action.  Such control can only be achieved if sufficient field data is gathered and if that information is used effectively to produce thorough, timely evaluation of conditions relative to desired outcomes, and to support appropriate corrective actions when needed, which also must be well monitored and controlled. 

3.      Budgeting and organizing for management is therefore a primary challenge. To have credibility as a management device, the CP must make detailed recommendations about the costs, staffing, and organizational structure and procedures required to succeed.  And it must make clear an ongoing commitment to this enterprise that will be needed, year in and year out, to ensure that the public interest is served.  In my view, this means establishing an advisory body of qualified individuals who are independent of the JIA board.  The qualifications and independence of advisors will help ensure that conservation objectives and practices are honored, and that information is used to guide timely management actions that serve the public purpose of conservation planning.

4.      As others have noted, carrying capacity needs to be considered and used as a guiding concept in the CP.  There should be at least two dimensions to the concept as applied on Jekyll Island: (1) the sustainable level and rate of visitation, seasonally adjusted and tailored to respective areas, that will preserve the quality of experience intended, and (2) the types of activity and corresponding intensities of use that are both appropriate to visitation and sustainable within the viable limits of healthy natural communities.

5.      Due to a series of unfortunate missteps historically, the CP remains independent of the island’s master planning process.  Instead of preparing the CP as a separate undertaking, it would be far better to integrate all related research, analysis, and management strategies into comprehensive master planning efforts.  Without obligatory language for implementing the recommendations and findings of the CP, the MP (or future revisions of it) may subvert or compromise conservation measures. Continued fragmentation of these two essential guiding documents deprives the public of the best possible procedures for responsibly managing Jekyll Island State Park
.
6.Reference is made to the Environmental Assessment Procedures on pages 54 and 55 of the draft CP.

  • Rather than assigning assessment responsibilities to “a team from the Jekyll Island Authority,” as recommended by the CP, the proposed environmental impacts review should be conducted by an independent panel of experts.  To be best informed and least vulnerable to conflicting influences, decisions of environmental review must be made by individuals having special credentials relevant to such evaluation and who are not exposed to political pressures.

  • There is insufficient attention to detailed criteria needed to guide the Environment Assessment Procedure Team in reaching decisions regarding what is and is not appropriate development or redevelopment. Objective measures for quantifying and limiting anticipated impacts must be provided, not merely a list of objectionable activities.  Such measures might include: volume and content of non-point source pollution leaving the project site, visual impact on surrounding land uses, and disturbance of natural functions of adjacent areas including wildlife habitat.

  • Findings of the EAP Review Team regarding development proposals must carry more force than the CP now assigns to them. As it currently reads, the CP (p. 55) allows objectionable projects at odds with conservation objectives to proceed, with or without Team approval, despite the EAP assessment: “The EAP review will likely result in specific design recommendations that may be required for project approval.” I strongly advise that the word “may” be revised to “will,” making EAP Review approval essential for any project to proceed.  Conditions established by the Team for controlling or avoiding adverse impacts must be made legally enforceable as part of approval agreements, and then strictly enforced if the CP is to ensure the practical benefits intended.  The full cost of monitoring and assessment should be the responsibility of project proponents, not the public.


David Kyler
Executive Director
Center for a Sustainable Coast
www.sustainablecoast.org