Hello Jekyll Friends,
We need your help again!
Last month, the Jekyll Island Authority filed with the DNR for a 'General Permit' to conduct beach management activities on Jekyll. The purpose of this Beach Management Permit (BMP) is to allow the JIA to conduct management and maintenance activities within the jurisdictional area of the Shore Protection Act (SPA) without filing for a SPA permit.
While a general permit would facilitate regular beach maintenance activities and enable the JIA to act quickly when needed, the permit application suffers from a number of problems that need to be brought to the attention of the Shore Protection Committee when it discusses the application. Below you will find the statements to the DNR from IPJI, the Center for a Sustainable Coast, and One Hundred Miles regarding the flaws in the JIA's permit application.
What you can do to help:
1. Write to the Georgia Coastal Resources Division and request that the permit be amended. You can simply state that you agree with the objections presented by IPJI, the Center for a Sustainable Coast, and 100 Miles, or you may draw from the concerns submitted by these three organizations to produce your own
statement to the DNR. Comments will be accepted through April 14, 2017 and should be emailed to Karl Burgess at Karl.Burgess@dnr.ga.gov
2. If feasible, attend the public meeting and deliver your comments in person to the Shore Protection Committee. The Shore Protection Committee will meet on April 28th at the Susan Shipman Education Building at One Conservation Way, Brunswick, GA 31520. The building is a one story, white building on the east side of the parking lot of the DNR site.
We are sorry for the late notice! As always, thank you for your efforts to protect Jekyll Island State Park.
If you have any questions, please contact us.
David and Mindy Egan
Subject: The Jekyll Island Authority's Application for a Beach Stewardship General Permit per O.C.G.A. 12-5-230 -- http://coastalgadnr.org/node/100942
Statement from: The Initiative to Protect Jekyll Island State Park
The Initiative to Protect Jekyll Island State Park agrees with the concept behind the Beach Management Permit (BMP) the JIA has requested but believes the permit application needs a number of amendments if it is to serve its stated purpose while honoring the intent of the Shore Protection Act.
In addition to the objections stated by the Center for a Sustainable Coast and the One Hundred Miles organization, we have the following concerns:
The BMP was crafted by the JI Conservation Director and endorsed by the JIA board without any public input, violating national standards for public land planning and side-stepping all but one of the twelve "public engagement" opportunities cited in the BMP application
. The JI Conservation Plan was subject to intensive review by conservation professionals and concerned citizens, resulting in a much improved and widely accepted plan. The BMP should be subjected to the same process, amended accordingly, and then resubmitted for consideration by the Shore Protection Committee.
The BMP does not provide convenient and adequate means for concerned citizens to comment on a permitted activity before it takes place
. Scheduled BMP activities should be made public through multiple sources, including a listserv created expressly for this purpose, an easy-to-locate designated place on the JIA's website, and informative signage placed at the site where the activity will take place. Clearly, citizens should have the same opportunity for comment on proposed BMP activities that they would have for formal permit applications that are reviewed publicly by the Shore Protection Committee.
The BMP does not provide a mechanism for external evaluation of a permitted activity after it takes place.
Allowing the JIA to serve as judge and jury in evaluating the impact of measures it takes in accord with the BMP negates accountability, limits objective analysis of permitted activities, and makes possible less than ideal beach management practices. A means of providing independent, periodic evaluation of actions authorized by the BMP should therefore be included in the JIA's permit application.
The BMP would allow the JIA to supplement activities within the Shore Protection Act's jurisdictional area that are connected with a commercial or private initiative
. The application's statement that "the permit would only apply to actions carried out by the JIA on non-leased land" does not rule out the use of the BMP to benefit a private enterprise. Needed is a statement in the BMP specifying that it may not be used in conjunction with a non-JIA activity or project requiring a permit or a Letter of Permission from the Shore Protection Committee.
In summation, if the BMP is to be an effective management tool, its uses as well as its limitations must be specified in detail, and there must be some accountability for actions taken in accord with the BMP. Clearly, the BMP must be limber if it is to serve its intended purpose, but it must also include safeguards to ensure that it achieves its intended results and is consistent with the SPA regardless of who is charged with beach management on Jekyll Island State Park. We therefore request that the Shore Protection Committee hold off on granting this permit until the Jekyll Island Conservation Staff submits a Beach Management Plan that is thoroughly vetted and has the necessary components to be an effective tool under the Jekyll Island Conservation Plan.
Mindy and David Egan, Co-Directors
Initiative to Protect Jekyll Island State Park
Statement from One Hundred Miles
We appreciate the JIA's interest in conducting projects with the potential to enhance our beach ecosystems and understand why they seek to simplify the process. Unfortunately, we are concerned that, if granted, the permit will cover an area too broad to be adequately regulated, and that the application lacks the details to uphold the intent of the SPA.
We have discussed the application with JIA staff, but oppose the permit application as it now stands. Here's why:
1. The JIA is proceeding with an overly broad, general permit without the context of an updated conservation plan.A good plan should guide permitting--not the other way around. Instead of rushing through a permit, Jekyll has an opportunity to work with coastal partners, scientists, and other stakeholders to create an updated plan that will protect the island's natural resources.
2. This permit would apply to ALL of Jekyll Island beach and dunes, without any specificity about where projects will take place.The application should include vicinity maps, including latitude and longitude coordinates, and must identify those beach access points in need of maintenance. Currently, these important points are lacking from the JIA's application.
3. The permit does not specify the best management practices that will be employed to carry out the activities.The application only describes case studies of past projects, providing regulators and the public with very little understanding as to how the project will be completed.
4. Most alarmingly, the permit would allow JIA to conduct major activities including the removal and storage of sand, as well as the restoration and enhancement of sand dunes.These are major activities that would require the use of heavy machinery and equipment, intensifying the negative impact on the dunes. Our sand dunes offer critical protection and provide habitat for nesting sea turtles and shorebirds. These types of major activities should require the issuance of an individual permit, and should not be included as a minor activity under a general permit (as JIA seeks to do).
Alice Keyes, Associate Director
One Hundred Miles
Statement from the Center for a Sustainable Coast (CSC)
CSC agrees that there is an advantage to creating a beach management permit (or something equivalent) for Jekyll Island, but procedures and controls must be adopted that ensure the use of such a permit serves the intended public purpose.
Like those who are commenting on behalf of other organizations (IPJI and OHM), we also agree that any such beach permitting should be formally integrated with the Jekyll Island Conservation Plan. However, we remain concerned that the Conservation Plan is not a "management plan" nor is there an existing, legitimate "management plan" for the beach area of Jekyll Island.
As I've previously commented, the term "management" should be strictly limited to circumstances where specific objectives have been formally adopted (under public review) and when benchmarks for evaluating achievement of those objectives have been implemented and are being administered. While there may be value in taking conservation measures such as those described in seeking approval for this so-called beach-management permit, they do not qualify as management actions, nor does the permit deserve being called a "management" permit.
Therefore, we advise that the permit should be described as a "beach conservation/maintenance permit," subject to specific requirements and prohibitions. These include:
(1) Adoption of the permitting process - and associated allowances and prohibitions - should mandate a public hearing and corresponding public comment, as now being endorsed by others.
(2) In addition to the well-reviewed initial permitting process described above, we agree with IPJI's proposal that individual activities to be conducted under the general Jekyll beach permit should be required to issue a public notification about the nature, location, and duration of the proposed action(s) so that affected members of the public can comment. There should be a period of no less than two weeks allowed between the date of notification and the initiation of the proposed activity.
(3) Within the auspices of the beach conservation permit, there must be no allowance for either beach driving nor for the use of heavy (earthmoving) equipment within the dune-field or beach itself. If using such equipment or beach-driving is proposed, such activity must seek a separate permit, subject to staff recommendations, public review and comment, and a formal permitting decision by the Shore Protection Committee.
We agree with IPJI's recommendation to provide improved accountability for activities conducted in beach maintenance and conservation. This recommendation is consistent with our above concerns about the important criteria for achieving "management" - which include measures to evaluate the effectiveness of actions taken under this proposed SPA beach-permitting program for Jekyll. Such bench-mark reports must include assessment by third parties (residents, coastal scientists, etc.) and such findings must be released to the public.The respective authorities (CRD, JIA, etc.) should then be required to modify permitted activities and procedures accordingly, consistent with officially released evaluation findings.
Likewise, we share concerns about the possible use of this generalized beach maintenance/conservation permit to allow activities benefitting a private entity rather than the general public. If any proposed activity fails to serve a specific, previously identified public purpose related to the beach area, that non-conforming activity must be considered under a separate permitting application.
Thank you for the opportunity to comment.
David Kyler, Executive Director
Center for a Sustainable Coast