Review of the 11/22/10 draft of the Jekyll Island
State Park Authority Conservation Plan

Steven Y. Newell, Public Liaison to the Conservation Plan Committee and Representative of Park Residents

The following remarks are some of those that I submitted as suggestions for revision of the draft Conservation Plan now being prepared by the Conservation Plan Committee.  Each preceding statement in brackets explains the need for each remark.

>> [The draft Plan nowhere refers to the State Park nature of Jekyll Island.]  Jekyll Island is a State Park, as established by Georgia law.  This is relevant to any conservation activities in the Park.  The fact that Jekyll is a State Park means that it belongs to all the people of Georgia.  For this reason, conservation efforts in the Park are especially important, to citizens all across the State.  Also, the State Park nature of the island provides a discouragement to overdevelopment.  The State Park nature of the island should be recognized throughout the Conservation Plan, including (and perhaps especially) on the cover page.

>> [There is no mention in the Plan of the Marshlands Protection Act or the Shore Protection Act, or of the Federal Endangered Species Act.]  Two Georgia environmental laws are pertinent to any conservation activities in Jekyll Island State Park.  They are the Marshlands Protection Act and the Shore Protection Act.  These two laws should be acknowledged, and the goal of adherence to the laws should be specifically stated.  Another law that should be cited in this Plan is the Federal Endangered Species Act.  It should be stated that the requirements of this law will be carefully observed.  This applies especially to loggerhead turtles, wood storks, and piping plovers.

>> [There is no discussion in the Plan of the law that protects 65% of the State Park from development.] Georgia law requires that 65% of the upland territory of Jekyll Island State Park remain in a natural state (i.e., it must not suffer real-estate development).  By "upland", I mean the land inland of the legally defined edge of the salt marsh.  This definition, put together by Georgia DNR, is based on the salt-requiring plants that grow where the higher tides have an effect.  The 65% legal requirement should be clearly pointed out in the Plan, especially under the section on Environmental Assessment.  A goal of the Plan should be to ensure that development does not invade the 65% set aside as natural, and another goal should be to make the boundaries of the 65% firm and unchangeable (e.g., by putting it into a conservation easement).  It has been argued that this issue should be saved for the forthcoming update to the Master Plan – I disagree: I believe that it is reasonable to put plans for solving this important problem into both the Conservation Plan, and into the Master Plan.  I see no reason to put this plan into only one of these two important documents, and it goes without saying that securing an easement for the well-identified 65% is a conservation goal.

>> [The Cabin Bluff Plan is the former Jekyll Island State Park Conservation Plan, which included lists of imperiled species living in the Park.]  Will the entire Cabin Bluff Conservation Plan be included in Appendix A?  If not, what parts of the Cabin Bluff plan will be included in Appendix A?  Will the whole Cabin Bluff Plan be placed on the Park Authority website (where it once was available in its entirety)?  It is a valuable document, which should not be wholly superseded by the new Conservation Plan.

>> [Real-estate development is not listed among the threats to the ecosystems of Jekyll Island State Park.]  Let's be honest with ourselves about this: a major threat to the ecosystems of Jekyll Island State Park, just as is true in many parts of the world, is real-estate development.  Let's go ahead and state this clearly.  Regardless of the ecological sensitivity of our current Park Authority, we do not know who will be in charge in the future, and the destructive work of past Park Authorities does not inspire confidence in unknown Authorities of the future.

>> [The plant community including giant aquatic hibiscus (swamp mallow) is not mentioned in the appropriate place.] Why is Community 12 omitted here?  The giant aquatic hibiscus (swamp mallow) of this Community is considered critically imperiled by Georgia DNR.

>> [Re the section covering management of the beaches…] This zone is covered by the Shore Protection Act; any management activities will require a permit from the Shore Protection Committee, and this should be clearly stated here.

>> [Re the team designated for review of development projects…] What will be the composition of the "project review team"?

>> [Re the person designated to review ecological impacts of proposed development projects…] We should define the "conservation specialist" as clearly as we can.  Shouldn't we also provide information here on the longevity of the current Conservation Committee, since it will have project-reviewing  responsibilities after the Plan is complete?

>> [Re the decisions to be made after reviewing projects that could have impacts upon critical nesting habitats of endangered or threatened species…]  The options for potentially eco-destructive projects should not be only "design changes" or "alternative locations".  Rejection of project ideas should be possible.

>> [Sea turtle nesting areas are not specifically listed under areas of particular sensitivity.]  "Specially Protected Areas" should include nesting sites of loggerhead turtles (any disruption of nesting success of this species is a violation of federal law).  Nesting sites of wood storks and Wilson's plovers should also be included here.  All of the unarmored beach is critical nesting habitat of loggerhead turtles, and therefore protected by federal law.  Should we include the nesting areas of diamondback terrapins, along the causeway?  I believe that Georgia DNR lists these turtles as vulnerable to pressure from development.

>> [Figure 6 of the draft Plan…]  There is a patch of the critically imperiled giant aquatic hibiscus (swamp mallow) right across from the new Convention Center, on the south shore of a brackish lake.  This area needs special protection, since it is so close to the major center of new development.  (Furthermore, part of this lake is bounded by protected salt marsh.)

>> [Protection of critical nesting habitat of sea turtles is not specifically listed under "Management Objectives".]   A management objective should be prevention of damage to and interference with critical nesting habitat of federally listed endangered and threatened species, such as loggerhead turtles.

>> [Re "Management Priorities" for beaches…] Management Unit #1 – Shouldn't we add, "rebuild dune structures where they have been damaged or flattened"?

>> [Re "Management Priorities" for the southern oak forest…]  Management Unit #2 – Since there are critically imperiled hibiscus plants in this unit, we should add "protect critically imperiled plants".

>> [Re "Management Priorities" for beach areas with hotels…] Management Unit #6 – We should add "strictly enforce the Park's ordinance against light pollution of beaches".