Attention: Jill Andrews
Coastal Resources Division
Georgia DNR
One Conservation Way
Brunswick, GA 31520
Ms. Andrews:
In addition to our previous letter submitted to CRD on July 24, 2026 please enter the following into the record of public comments on the proposed private dock rules for consideration by the DNR board.
Assessment of Public Interest:
According to detailed analysis of the proposed DNR dock rules, approximately 1500 properties could be affected by these regulations if they are adopted as proposed. If all such property owners build access boardwalks to the maximum allowable length of 1500 feet, the area of marshlands directly degraded by the measure would exceed 300 acres. In addition to the ongoing harm done to marsh ecology by boardwalk shading caused by these rules, the consequences of coastal storm damage to boardwalks would be greatly multiplied, risking additional marsh contamination and public harm resulting from debris being spread across vast areas of surrounding marsh.
Moreover, reputable online sources estimate that the price of such properties would increase between 10 and 15% when new access to waterways is accommodated by these regulatory reforms. Thus, if adopted these new rules will cause a cumulative increase in the potential market value of the 1500 properties affected, which would be in the hundreds-of-millions of dollars.
Any benefits being used to justify an increase in the length of dock access structures from 600 to 1500 feet will be gained by only a select wealthy few who can afford such properties or by developers already owning such properties who will greatly profit from the projected increase in market value generated by this measure. Conversely, the vast majority of Georgians will suffer both degradation of the tranquility and beauty of natural marsh vistas as well as a decline in the vital fish and wildlife habitat functions of tidal marshlands. Both of these uniquely valuable public benefits are meant to be protected under Georgia’s Coastal Marshlands Protection Act of 1970.
Furthermore, the ecosystem services of Georgia’s marsh habitat are essential to sustaining commercial and recreational fishing as well as tourism businesses, which combined directly and indirectly support tens of thousands of Georgia households. Likewise, the value of these areas in their undisturbed state adds immeasurably to the region’s quality of life enjoyed by millions of Georgia citizens as residents and visitors.
Note that the CMPA declares that the marshes of the state are to be held and conserved as a public trust resource. The proposed private dock rules directly conflict with Georgia’s public trust doctrine by favoring a few private individuals who will benefit at the expense of Georgia citizens who will incur the degradation of, and added risks to, the state’s vulnerable marshlands.
Conclusion:
Based on our well-reasoned, factual analysis, the Center for a Sustainable Coast finds that the proposed dock rules are not in the interest of the state because they violate the intent and purpose of Georgia’s Coastal Marshlands Protection Act by benefiting a privileged few while the vast majority of Georgians would be harmed by jeopardizing the critical value of these natural areas as a public trust resource.
Submitted by:
David Kyler, Co-Founder & Director
Center for a Sustainable Coast
221 Mallery Street, Suite B
Saint Simons Island, Georgia 31522