Wilmington Plantation Marina Project
August 20, 2004
NOTE: Corrected final draft
Commander, US Army Corps of Engineers
Savannah District
Attn: Regulatory Branch
P.O. Box 889
Savannah, GA 31402-0889
Re: Application Number 200406890
Wilmington Plantation
New marinas, docks, and boating activities are proliferating at an unprecedented pace in coastal Georgia. Between 1995 and
2002 (eight years inclusive), there were 1,688 dock permits issued, averaging 211 a year. Although it is generally recognized
that the cumulative impact of these multiple activities may be significant, such aggregate effects are not substantively
considered by the state and federal agencies responsible for making individual permitting decisions.
In one county alone (Camden), there are presently plans in process for projects that would provide wet and dry storage for
more than 2,000 additional boats. When considering marina and dock permits, state and federal authorities must consider
both the impact of the construction and maintenance of these structures as well as the intensified disturbance of water
bottoms, shorelines, and aquatic habitat caused by the concentrated use of motorized vessel that are served by these water
access and vessel storage structures. The aggregate impacts of hundreds of motorized vessels clearly contribute to water
contamination and the disturbance of water bottoms and shorelines, but no measurable quantitative limit on such disturbance
is set when permits are issued for marinas and docks. Because no quantitative limit of impact is stated as a condition of
permits for docks and marinas, there is no reliable, accountable method for protecting the public against possible adverse
effects of these activities on state and/or federal resources within coastal waterways. This makes cumulative resource
degradation far more likely.
We know from water quality sampling data collected and reported by the Georgia DNR's Environmental Protection Division that
some 60% of Georgia waters are impaired, and that many of these impairments include threats to fish within the coastal watersheds.
According to Georgia DNR's Fish Consumption Advisory Handbook, about half of the entire state's listings of contaminated fish are
in coastal waters, a highly disproportionate share considering that the coastal region represents only about 7% of Georgia's
geographic area. In effect, this means that the coastal Georgia fishery is about seven times more likely to be contaminated
than the state's native fish stock overall.
Added to these problems are adverse conditions symptomatic of other disruptions in coastal Georgia's intertidal habitat, including
a drastic reduction in the number, health, and size of blue crab. Landings data in recent years are a fraction of their average
over the past 45-year period, although the cause of the steep decline in this important species remains uncertain. It is believed
that there is a combination of causes, including disruption of freshwater flow brought by both drought and development activities
(removal of vegetation, construction of impervious surfaces, and the ditching/filling of wetlands), plus point and non-point source
water contamination.
Under federal guidelines, the Wilmington River and virtually all coastal Georgia intertidal waterways are designated Essential Fish
Habitat by the South Atlantic Fishery Management Council. The term 'essential fish habitat' means those waters and substrate
necessary to fish for spawning, breeding, feeding or growth to maturity. [Magnuson-Stevens Act §3(100)] The SAFMC
has adopted a Habitat Plan for the management of the fishery under federal law, and is pursuing an ecosystem-based
approach that will improve protection of a multitude of interdependent species. In the meantime, a precautionary
management approach should be taken that will help prevent or at least reduce further threats to these important
areas that provide ecosystem goods and services of immense value to the state and nation.
Based on estimates made by acclaimed Georgia ecologist Eugene Odum in a paper published some thirty years ago [The Value of Tidal
Marsh, Odum et al. Center for Wetland Resources, Louisiana State University, May 1974], updated to current dollars using the
Consumer Price Index, the annual amount of ecosystem goods and services produced by an acre of healthy tidal marsh averages
some $14,000. With some 400,000 acres of tidal marsh in coastal Georgia, the total annual value of these goods and services
in Georgia alone is $5.6 billion. Another indication of the value of these intertidal areas is the annual dollar value of
recreational fishing in coastal Georgia, which DNR estimates to be over $500 million. Further, we estimate that coastal
Georgia eco-based tourism contributes some $500 million annually.
Despite these impressive economic contributions attributed to the coastal region's natural resources, public investment in
environmental monitoring has declined relative to Georgia's state budget, and the same trend is true nationally of federal
funding in proportion to the federal budget. A Georgia State University study published last year reported that during a
12-year period ending in fiscal year 2003, the DNR budget shrank by more than 30% as a share of the Georgia budget. During
the same period, the state's population grew by more than 20%, compounding the burdens being imposed on air, water, wildlife
and other public resources. Although no figures are immediately available to quantify the circumstances with federal functions,
it is widely reported that funding for environmental protection, monitoring, and assessment has also dwindled relative to the
total federal budget in recent years, while permitting standards have become more permissive.
Given the above description of current environmental conditions, known trends in resource management funding, and well documented
esource values, justification for such precaution is amply evident, and therefore the burden of proof clearly rests on those who
propose to further use, and possibly degrade, public resources. The merits of this rationale are amplified by the declining
capacity of state and federal agencies to keep pace with the need to review permits, monitor conditions, and assess consequences
of permits once they have been issued.
For all of these reasons, the Center for a Sustainable Coast believes that a permit finding for the proposed marina project at
Wilmington Plantation, and all similar permits, must rest on specific, verifiable standards that include:
- Evaluation of the initial and ongoing effects of the marina and use of the marina by boaters at the scale proposed, including
impact on water bottoms, shorelines, vegetation, aquatic animals, and water quality/flow.
- Assessment of the impact of the marina and use of the marina by boaters at the scale proposed in light of existing water quality,
ecosystem productivity, and cumulative impacts on ecosystem services compared with project benefits over a period of at least 20
years.
- Specification of the standards and methods for competently monitoring and evaluating project impacts (including reporting and
information verification) for a period of at least 5 years, or until impacts stabilize (whichever is longer) and the costs of
conducting complete and reliable evaluation using these standards.
- Comparison of the costs estimated to meet the previous condition, compared with the funding and professional services available
to the respective authorities (by agency/section name) that will be responsible for enforcing permit conditions and evaluating
project impacts.
Once the above evaluation elements are completed, the permit decision should be based on the findings in light of the public
interest objectives of all applicable legal requirements. If it is determined that proper monitoring and assessment of the
project will require more enforcement capacity than that which is available at the responsible agencies, permit conditions
should require that these costs be met by a contribution from the permit applicant in the amount(s) needed so that agency
staff can be supplemented by appropriate qualified professional services retained and administered by the permitting agency.
Given the conditions cited and current deficiencies in enforcement capabilities, these steps provide a reasonable means of
meeting legal obligations to protect the public interest.
Signed,
David C. Kyler
Executive Director
cc. Susan Shipman, CRD
Carol Couch, EPD
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