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Comments on the Proposed Union Island Rezoning

February 17, 2006

McIntosh County Commissioners
P. O. Box 584
Darien, Georgia 31305

Re: Comments on the Proposed Union Island Rezoning

Dear Sirs:

Union Island is among the most environmentally sensitive, vulnerable, and visually important sites that have been proposed for development in McIntosh County. Like all "marsh islands" or hammocks, Union Island serves as important habitat for migratory birds and a wide array of other wildlife, and the development of this site for residential use presents significant issues of concern, not the least of which is contamination of surrounding waters and wetlands from removal of vegetation, disturbance of soil, and stormwater runoff.

Furthermore, marsh islands are among the highest risk areas during major storms, including hurricanes and northeasters. In the path of storm surges caused by high winds, especially during higher tides when surge elevations can reach more than 20 feet above normal, structures built on hammocks are extremely vulnerable to damage or outright destruction. Short of surges, flooding alone can cause major threats to lives and property. Although coastal Georgia has been fortunate by being out of harm's way in the recent past, it is possible that our coast could encounter one or more major hurricanes similar to those that struck several times during the 1890s.

According to analysis recently presented by Dr. Mac Rawson of the University of Georgia's Marine Studies Program, a Class 5 hurricane comparable to Katrina would cause a storm surge that would completely inundate sites such as Union Island. Even a storm of lower intensity could produce flooding and surges that would destroy most if not all structures on the island. Further, Dr. Rawson pointed out that contrary to uninformed assumptions about coastal Georgia as a safe haven, under a direct hit from a major storm our coast presents one of the worst possible scenarios for damage to property and threats to life. Because of the low elevation of our shore-side landscape, combined with the low-sloping ocean bottom, storm winds here will push water into higher surges than in many other coastal areas. Last December, another coastal storm analyst, Chuck Watson of Savannah, told members of our organization that, based on his computer models, a storm like Hurricane Katrina would produce property damage here at least equivalent to last year's destruction along the Gulf of Mexico, despite the fact that our region's elevation is higher than that of New Orleans where much of that devastation occurred.

Limiting activities on Union Island to the recreational uses allowed under its current Conservation-Preservation zoning is not overly prohibitive and such restrictions make sense in light of the environmental risks and storm hazards just described. These currently permitted uses include camping, hunting and fishing, and nature study, and construction of the facilities need to support such activities. This zoning classification is intended to support land uses that are appropriate for environmentally valuable and vulnerable areas like Union Island, which is why it has been zoned that way.

Storm damage vulnerability on hammocks must be given serious consideration, and public officials should not support decisions that increase threats to property owners and residents by allowing more intensively developed facilities in these areas, especially permanently occupied structures. The proposed rezoning would significantly increase prospective risks to lives and property by allowing construction and occupation of numerous residential structures. If developed, evacuation of the island well in advance of approaching storms would compound the county's considerable existing hurricane preparedness burdens. In making land-use decisions, local elected officials are obligated to provide reasonable consideration of public health and welfare issues related to environmental factors and natural hazards. Decisions resting disproportionately on claims of economic benefits made by those promoting projects are improper and legally vulnerable to be being overturned.

However, if denying residential use of Union Island is not the Commission's decision, we strongly urge you to require conditions to be carefully enforced by the County that will help reduce and control adverse environmental impact and related problems created by development in marshfront and shorefront areas, especially marsh islands. The most important of these conditions is requiring sufficient buffers to keep structures and paved areas away from vulnerable public resources such as waterways and wetlands. In light of past studies and analysis, we urge the county to ensure that a buffer of at least 75 feet is provided along the edges of both marsh and shorelines. Beyond this highly important provision, we urge the county to require that no more than 15% of the total site is covered by impervious surfaces including driveways, streets, parking areas, and rooftops. Finally, it is imperative that storm water is property collected, filtered, and controlled to reduce both soil erosion and contamination of surrounding areas such as marshes and waterways. To accomplish this, the applicant should be required to submit and consistently follow a professionally prepared stormwater management plan that will include collection, retention, and drainage release systems that properly control water so as to retain pre-development conditions of both water quality and hydrology.

As we face unprecedented trends in population growth, we must give serious thought to the quality and location of additional development. The historic and projected aggregating cumulative impact of similar projects should be carefully considered in the context of this proposal. Since January of 2001, an estimated 1,000 acres of freshwater wetlands have been filled for development in coastal Georgia and some 10,000 acres of land have been developed just for residential purposes. Now nearly two-thirds of the waters in coastal watersheds fail to meet federal clean water standards. Environmental scientists at the Skidaway Institute have recently reported that dissolved oxygen essential for fish to live has been on a dangerous downward spiral in our waterways for several decades, directly correlating with adjacent land development. This creates a very disturbing outlook for the health and diversity of our fish and shellfish, not to mention our cherished quality of life. The only way to keep catastrophic impacts from resulting is to reduce the adverse effects of further development by keeping it as far away as possible from wetlands, ditches, creeks, and rivers, and carefully controlling drainage changes generated by land disturbance. In light of such remedies and the troubling trends that require it, development of marsh islands is clearly to be avoided whenever possible and strictly regulated when developing such areas cannot be prevented.

As the final decision-makers taking action on this proposal, you have a unique opportunity to set new standards for representing the public interest through the rational use of both private and public resources.

The legal basis for refining and applying these standards is already in the ordinances under your authority. The decision in this case, based on a complete and balanced evaluation of all of the above considerations, lies in your hands. I urge you to exercise your obligation to fulfill the purpose of the McIntosh County Zoning Ordinance in reaching the most responsible decision by denying the proposed rezoning of Union Island.

Sincerely,

David C. Kyler
Executive Director
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