
Cumberland Island Land Exchange Proposal Opposition
Comments Submitted by Wild Cumberland on the Cumberland Island Land Exchange
Read the comments submitted to the NPS on the Cumberland Island Land Exchange by Wild Cumberland below.
Wild Cumberland opposes what the National Park Service has most recently proposed for the Cumberland Island Land Exchange.
The agency has been negotiating deals with select private property owners at Cumberland Island — costing millions of dollars — without any public input or involvement for at least the last five years:
- In September, the agency released a 9-page concept reprivatizing public lands within the boundary of Cumberland Island National Seashore.
- A 30-day public comment period ends October 6, 2024, and should influence future NEPA compliance (the development of a future Environmental Assessment (EA) or Environmental Impact Statement (EIS)).
Previous landowners (many of whom had limited resources) transferred their lands to the agency in order to establish the Seashore. They “bought in” to the vision the NPS espoused — and trusted the agency would fulfill its promises.
Here are some important things to know:
- The agency has proposed to convey public lands into private ownership — with NO conservation easement assurances.
- Several of the parcels proposed for private ownership are owned by the federal government, but have been inaccessible to the public for the last 50 years. Others are existing homesites that have already converted to federal ownership.
- Camden County can still rezone privately-owned properties. Property owners would potentially still be able to subdivide and/or sell these properties.
- Potential development tracts are adjacent to, or near, designated Potential Wilderness.
- None of the documents presented by the agency indicate any interest in, or adherence to, its 1972 legislative intent. It also does not mention or adhere to the unit’s 1984 General Management Plan, 1994 Land Protection Plan, or 2012 Former Reserved Property Management Plan.
The NPS has been negligent in the development and implementation of a Wilderness Management Plan since its authorization (42 years ago).
- This plan must be completed before any transactions are considered or take place. The need or possibility for any of the proposed exchanges may have been eliminated if a Wilderness Management Plan had been completed in a timely and responsible fashion for Cumberland Island National Seashore.
Wild Cumberland believes that if we are to respect the Congressional intent of Cumberland Island National Seashore and its Wilderness designation – every parcel of land would have a plan in place to eventually convert to federal ownership, and the island would become an increasingly wilder, more ecologically-valuable resource to Americans.
Wild Cumberland believes that NO land exchanges are acceptable for this barrier island park unit. This may warrant the agency’s use of condemnation and/or imminent domain (as authorized in 2006 NPS Management Policies, CUIS’ 1984 General Management Plan, and/or CUIS’ 1994 Land Protection Plan).
- Why isn’t the NPS focused on the expiration of retained rights and returning Cumberland Island National Seashore to a “primitive, undeveloped” condition?
- How does the proposed land exchange – which increases the number of private residences and potential for future development — align with the intent of Congress or its subsequent Wilderness designation?
The proposed Cumberland Island Land Exchange plan seems to indicate that the NPS, taxpayers, volunteers — and fee-paying visitors — are merely functioning as interim “caretakers” for residents employing long-term strategies to ensure a permanent presence on the island.
Remember — the majority owner in Cumberland Island is the American public. We must not allow the private motives of a few individuals to undermine the qualities of, and vision for, Cumberland Island National Seashore.
Here’s What You Can Do:
- Submit your comments by October 20, 2024.
- Make sure to save a copy of your submission.
- Get general tips for writing your comments below
- View a recording from our virtual Town Hall and view our presentation. You can also access historical documents, additional maps, & more.
- Share this comment opportunity with others.
- Donate to support our work to keep Cumberland Island wild.
Wild Cumberland – Land Exchange Town Hall Slide Deck
What We Covered:
- Helpful terms
- Overviews of the 4 individual land exchanges
- The stated purpose of the plan
- What is missing from the documents
- Maps that show the full scope of the proposed land exchange
- How Cumberland Island compares to other national parks in this type of land exchange situation
- Wild Cumberland’s position
- How to comment on the NPS proposal
- and what’s next!
- plus we have a great Q&A session that covers a lot more!
Links to More Information:
- Wild Cumberland’s Slide Presentation (Also Viewable Below)
- Wild Cumberland’s NPS Land Exchange Special Email
- NPS Proposed Land Exchange – Plan, Public Meeting Details, etc.
- Camden GA Property Tax Map (public records)
- Land Acquisition History, Cumberland Island
- NPS Management Policies, relating specifically to Land Protection
- 2012 Former Reserved Properties Plan
- Federal use of Eminent Domain
- Cumberland Island National Seashore Enabling Legislation
Submitting Your Public Comments for the Cumberland Island Land Exchange
DEADLINE HAS PASSED. IT WAS OCTOBER 20!
WHERE & HOW TO SUBMIT YOUR COMMENTS:
Electronically:
Click the link below to go to the NPS website where you can leave your comments.
Click Here to Get to the NPS Land Exchange Comment Page
By Mail:
Cumberland Island National Seashore
101 Wheeler Street
St. Marys, GA 31558
Tips On Writing Your Comments:
Start with a brief opening statement and explain your personal connection. Share a personal story or experience that identifies your connection to Cumberland Island, Wilderness, and/or public lands. If applicable, mention relevant affiliations, such as community organizations or environmental groups.
Example: “I oppose the proposed land exchanges on Cumberland Island because…”
Make your key arguments. Summarize your strongest arguments and concerns about the Cumberland Island Land Exchange. Provide evidence, documentation, or data that supports your position or relates to the decision-making criteria, if available.
Example: “As a XXX, I [ cherish / value ] XXXX”.
Make a clear conclusion. Use this opportunity to reiterate your opposition and express a desire for XXX that XXXX.
Example: “We must XXX”.
General Tips:
- Make sure to include all your concerns, because any concerns you do not raise at the commenting stage can be considered “waived.”
- Provide contact information if you are comfortable (this adds credibility).
- Proofread for clarity, spelling, & grammar.
- Save a copy of your comments (print to PDF or screenshot).
- Share a copy of your comments with any of the organizations you are affiliated with, if you mentioned them.
The NPS Indicated that the most “useful” types of public comments include:
- Alternative approaches and ideas for addressing the purpose and need for the project.
- The range of environmental issues that need to be considered.
- Other potential projects or actions that might affect or be affected by this project.
- Likes & dislikes about the concept of these proposed land exchanges.
- Information on how you use the Seashore and how a land exchange might affect that use.
Sample Public Comment Letter on the Cumberland Island Land Exchange:
Thank you for the opportunity to provide comments on the proposed land exchanges for Cumberland Island National Seashore. I am [ introduce yourself or your group ]. Offer a few sentences about your background, your credentials, and why this matters to you. If you are commenting because you live in St Marys, for example, mention how close your home is to the Wilderness: “I have lived in St Marys, Georgia, for twenty years, and my home is less than three miles from Cumberland Island and its Wilderness.”
I would like to [ state the purpose of your comment ]. In other words – do you oppose the proposal outright? Are you asking the agency to consider additional information? Make sure to state what you want the agency to do! You might say “I would like to ask that you XXX, for the following reasons:”
1. [ First (your “most important”) reason why the agency should do what you want. ]
Keep each reason a separate number or bullet point. Include all the information you have that supports this point. (It’s okay for each point to require several paragraphs, or even pages.) Reference any sources, like newspaper articles or scientific research, that support your position. You can include a list of your sources at the end of your letter.
2. [ Second reason why the agency should do what you want. ]
3. [ Put as many reasons as you have, but try to order them from most important to least important. ]
Therefore, [ re-state what you want the agency to do, like deny the permit or choose an alternative site. ].
Thank you for the opportunity to comment on the proposed Cumberland Island Land Exchanges.
Add your sources here.