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Jekyll Island RFI Response June 16, 2006

Mr. Jim Broadwell
Jekyll Island-State Park Authority
381 Riverview Drive
Jekyll Island, Georgia 31527

Dear Mr. Broadwell:

We are responding to your March 17, 2006 "Request for Information #233" (RFI), which is intended to help the Jekyll Island Authority (JIA) Board formulate a strategy for future management and development of Jekyll Island.

We concur with many of the concerns expressed by the Georgia Conservancy, as reported in their comments on response to the RFI, which they have generously shared with us. These comments focus on conservation, public accessibility, and compatibility of future development with the traditions and purpose of Jekyll as a public resource, supported by ample attention to public involvement, consensus building, and extensive collaboration within coastal Georgia's regional context. Throughout our remarks, we presume the JIA will honor the adopted limit of 35% of the Island being developed, with the hope that this development will be at a density that is consistent with conservation objectives applicable to the remaining 65% of the land area under your jurisdiction. Further, we presume that active recreational land uses, such as golf courses, will not be counted as conservation areas, but rather as developed ones.

Accessibility and Affordability
The Center for a Sustainable Coast is particularly concerned about the effects of the Œfree market' on the future costs of activities on Jekyll Island. As you undoubtedly know, trends in land values, taxes, insurance, and infrastructure are fueling rapidly rising costs that are beyond the means of many segments of the public. If the Island is to meet the objective of public accessibility set forth in the JIA's enabling statute, JIA policies and practices must consciously compensate for the exclusionary effects of such trends. To that end, we are opposed to the privatization of property, which would be prone to accommodating if not propagating the counterproductive and restrictive effects of rising costs.

A distorted representation of fiscal responsibility must not be used to subvert other public objectives in managing this important resource. True fiscal responsibility in the public realm is best achieved when the interests of the least among us are equally represented with those of the most economically advantaged. Placing excessive emphasis on the revenue-generating capacity of the Island and its facilities would fundamentally contradict the founding objective of affordability to people of average income.

Furthermore, it is likely that allowing unfettered free-market discretion in the Island's development would lead to design styles and intensities of use that would undermine the classical appearance and unique quality of experience for which the best of the Island's developed resources are deservedly renowned. While this problem could conceivably be controlled using carefully implemented design standards, applying them within the private realm in the face of development pressures and volatile economic prospects would be a major administrative challenge, imposing an awesome burden on JIA resources.

Conservation
In keeping with the Island's natural features, including some of the most striking dune formations and remnant maritime forests found among the mainland-accessible barrier islands in the nation, the Center firmly believes that plans and policies must be steadfastly and accountably committed to protecting, and where possible, restoring natural resources. These include tidal and freshwater wetlands and the habitats they sustain. Consistent with this strong conviction, we advise that there must be sufficient budgeting provided on an ongoing basis to ensure proper management of these vital natural areas in the foreseeable future, and whenever possible, setting them aside as protected conservation easements in perpetuity.

The natural resources of Jekyll Island, like those everywhere else in the region, are under stress from many factors beyond the control of individual landowners and local communities. Among these threats are geographically dispersed non-point source pollution and atmospheric deposition causing various forms of "impaired waters" (see attached map), fish contamination, and the endangerment of a variety of plant and animal species. In the face of these imposing threats, the JIA must be doubly vigilant in its obligation to responsibly protect the public interest by devoting sufficient time, energy, and political commitment to careful stewardship of the unique and profoundly valuable natural wealth under its care.

Consistent with our comments in the previous section of this letter, we believe that these conservation objectives will be more attainable if privatization of the Island's resources is steadfastly avoided. Equally important, JIA must adopt rigorous standards for development and maintenance that incorporate evolving best management practices, including stormwater controls, preserving/restoring natural hydrology, and undisturbed natural buffers. In keeping with the principles of adaptive management, JIA should routinely review and upgrade these standards as justified by field monitoring, combined with new management practices supported by the latest environmental research.

Jekyll Island should be viewed as a living laboratory within which state-of-the-art environmental management is practiced, evaluated, and documented. This will not only support the best possible protection of natural systems and progressive development techniques, but this function could become an important source of media attention and correlated income, both public and private. We strongly urge you to develop creative collaborative relationships with research organizations such as the Marine Extensive Service, the Marine Institute on Sapleo, and the Skidaway Institute of Oceanography. Ideally, the JIA should sponsor the creation of an independent research and outreach institution focusing on the interrelationships between developed and conserved areas. The mission of this proposed institute would be to generate information needed to attain the sustainable balance between development and a healthy natural environment, as intended in the state's acquisition of Jekyll Island.

It is reasonable to expect that this kind of research would attract substantial research funding, and that its application would provide extensive benefits in numerous Southeastern communities where environmental quality is a primary concern.

Public Involvement & Consensus
We fully concur with the excellent reasoning presented by the Georgia Conservancy on the matters of public involvement and consensus-building. As competition for coastal resources grows and surrounding regional development impinges on natural systems, the importance of these functions rises exponentially. Both the Island's history and current trends affecting its prospects underscore the value of an adaptive management strategy, rigorously accountable to public purposes and appropriate methods of decision-making that truly represent, and further refine understanding of, the public interest.

We therefore emphasize the key role that JIA must play in the region's understanding of the larger framework within which responsible decisions must be made affecting the future of Jekyll Island. One of the most imminent opportunities for fulfilling that role is for an appropriate JIA representative to be actively involved in the regional planning endeavor set forth by Governor Perdue early last year, as the Georgia Conservancy advises. The benefits of participating are likely to be both serendipitous and synergistic ­ meaning that the advantages will include aspects that are unpredictable and multi-lateral ­ hopefully producing long-term rewards for Jekyll Island and our region at large.

Among the many benefits that are likely is the development of a network of potentially productive relationships with other stakeholders. Working together with your counterparts, you can establish the means for breathing life into regional planning, including periodic appraisals of coastal Georgia's conditions and trends, such as documented in the Center's report, The State of Georgia Coast. Enriching the information available and its coordinated application through the activities of local and state government, homeowners associations, non-profit organizations, and the business sector could help this region achieve enlightened advancements in resource protection and growth management. Without such collaborative efforts, it is unlikely that our region will realize its potential, since the pressures of development and dominant short-term economic motives would be far more likely to overpower deliberative decision-making in support of prudently balanced long-term goals.

We hope that these comments will expand and enrich the discussion over the future of Jekyll Island.

If you have any questions or comment, we encourage you to respond at any time.

Sincerely,

David C. Kyler
Executive Director
Center for a Sustainable Coast
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