Block the Cumberland Island land exchange until analysis gaps are fixed
Voluntary Land Exchange Environmental Assessment - Cumberland Island National Seashore
National Park Service· Cumberland Island National SeashoreNPS Planning (PEPC) project page ↗
NPS PEPCWe track this on the agency’s own system of record, where most on-the-ground decisions live.
The groups on this fight
2 groups work this ground: Cumberland Island National Seashore
Works this ground means the editors' sourced record puts the group on this land, not that it has taken a side on this decision; predicted likely to care is a guess from footprint in Georgia, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Wild Cumberland
Works this ground · not linked to this decision
Works this ground at Cumberland Island National Seashore: Opposes all four proposed land exchanges, saying maps, acreage and valuations have never been disclosed and the homesites sit next to Wilderness and Potential Wilderness; held a September 30, 2026 virtual town hall ahead of the October 16 comment deadline.
Source ↗ - Wilderness Watch
Works this ground · not linked to this decision
Works this ground at Cumberland Island National Seashore: Its October 9, 2026 action alert asks readers to tell the Park Service "No land exchanges on Cumberland Island!" by the October 16 comment deadline.
Source ↗ - Center for Biological Diversity
Predicted likely to care · a guess
Works Georgia: joined the November 2022 environmental lawsuit challenging the Army Corps decisions that cleared the way for the Twin Pines mine beside the refuge.
- Defenders of Wildlife
Predicted likely to care · a guess
Works Georgia: founding member of the Okefenokee Protection Alliance and a plaintiff in the 2022 wetlands lawsuit against the Army Corps over the Twin Pines mine.
- National Wildlife Refuge Association
Predicted likely to care · a guess
Works Georgia: sued the Army Corps in November 2022 over the Twin Pines project, helped found the Okefenokee Protection Alliance in 2020, and produced the 2021 documentary Sacred Waters: The Okefenokee in Peril.
- Southern Environmental Law Center
Predicted likely to care · a guess
Works Georgia: filed the 2022 lawsuit against the Army Corps over wetlands decisions enabling the Twin Pines mine on behalf of four national groups, and its senior attorney chaired the Okefenokee Protection Alliance executive committee.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The National Park Service proposes trading about 80 acres of protected seashore land to private owners for about 130 acres of private inholdings, while its own analysis leaves cumulative development, wetland exposure, and species-specific impacts unresolved.
What’s at risk
The exchange places 3.4 acres of wetland and 5 acres of floodplain inside a buildable area on land leaving federal ownership, while the document's own wetlands table shows a net gain of only about 0.03 acres. The larger 119.3-acre exchange 2a parcel, despite containing shorebird and sea turtle habitat on an island that hosts 25 to 30% of Georgia's statewide sea turtle nesting, gets zero acres of new wilderness designation under Table 1. Required Section 7 species consultation and Section 106 historic property consultation are both still incomplete, and the document's own sections give conflicting descriptions of whether one transferred parcel touches the ocean shoreline.
If this goes through
Conservation easements would lock 80% of the two transferred parcels into low-impact use in perpetuity, but the remaining 20% building areas allow up to two homes on one parcel and six on the other, each up to 15,000 square feet, on land removed from direct federal management and protection. The public comment window on this EA is set at only 30 days, shorter than the 45-day scoping period that already drew 2,725 pieces of correspondence.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- Acres NPS would acquire from private owners
- approximately 130 acres
- Acres NPS would convey to private ownership
- approximately 80 acres
- Net wetland acreage change from the swap
- 5.42 acres in vs 5.39 acres out
- Share of Georgia's sea turtle nesting on the island
- 25 to 30% of statewide nesting total
- Wilderness acres designated from the 119.3-acre exchange 2a
- 0.0 acres
- Public comment period on this EA
- 30 days
LAND USE
Open the document ↗“The NPS would acquire approximately 130 acres of privately owned inholdings that would become part of the Seashore.”
LAND USE
Open the document ↗“the land exchange would remove approximately 80 acres of land from direct federal management and protection”
Table 5
Open the document ↗“Total Wetlands Exiting Federal Ownership 5.39 Total Wetlands Entering Federal Ownership 5.42”
WILDLIFE, INCLUDING THREATENED AND ENDANGERED SPECIES
Open the document ↗“Cumberland Island regularly accounts for 25 to 30% of the statewide nesting total”
Table 1
Open the document ↗“From Privately Owned to NPS (Exchange 2a) 119.3 Land to be Designated as Wilderness 0.0”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 2
- Hold up
- 3
- No support given
- 1
- Contradicted by its own record
- 3
- Never analyzed
The National Park Service wants to trade about 80 acres of federal land inside Cumberland Island National Seashore, under conservation easements, for about 130 acres of private inholdings. It says the swap would keep key trails continuous, protect forest, beach and sea turtle habitat, add 10 acres of wilderness, and move development to less sensitive spots.
“The purpose of the proposed action is to acquire, through voluntary land exchanges with conservation easements, parcels of privately owned land within the authorized boundary of the Seashore.”
Purpose of and Need for Proposed Action
Each Ask below goes into your letter when you write it with PLAN on this page, matched to what you tell it about how this land reaches you.
Effects
Contradicted by its own record
Building on the conveyed parcels would cause only short-term, minor harm to wildlife, including threatened and endangered species.
The agency points to small building areas, conservation easements, and its finding of no population-level effects or measurable habitat loss at the island scale. But a few paragraphs earlier the same section says limited construction and ongoing residential use could cause localized, long-term adverse effects. It names the eastern indigo snake and tricolored bat as listed species most likely to be affected. The section can't call the same effects both long-term and short-term. Endangered Species Act consultation isn't finished.
AskReconcile the short-term and long-term findings, and disclose the Fish and Wildlife Service consultation results for the indigo snake and tricolored bat before deciding.
The agency’s words, the record and the law +Hide the words
The agency says
“Overall, alternative 2 would result in short-term, minor, adverse effects for wildlife and wildlife habitat, including threatened and endangered species, if development were to occur on parcels conveyed to private ownership.”
Wildlife, Including Threatened and Endangered Species
Elsewhere in the same document
“Limited construction and ongoing residential use could result in localized, long-term, adverse effects on wildlife within or adjacent to the project area.”
Wildlife, Including Threatened and Endangered Species
“The NPS will complete the section 7 consultation process prior to finalizing the decision document.”
Endangered Species Act, Section 7 Consultation
The law
“Each Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency (hereinafter in this section referred to as an "agency action") is not likely to jeopardize the continued existence of any endangered species or threatened species” Endangered Species Act, 16 U.S.C. 1536(a)(2) ↗
Effects
No support given
Fill and foundations for new homes would permanently affect only about 0.69 acres of soil.
The agency says construction would be confined to the potential building areas, which make up 20% of the conveyed parcels. It says the other 80% would bar ground disturbance and that no unique or sensitive soils would be affected. But Chapter 2 allows up to two homes on exchange 1b and six on exchange 2b, each with a total building footprint of up to 15,000 square feet, plus driveways, patios and an access road. At the maximum, that's far more than the roughly 30,000 square feet that 0.69 acres represents. The document doesn't explain how it arrived at 0.69 acres.
AskRecalculate permanent soil disturbance using the full number of homes, footprints, roads and driveways the agreements would allow, and show the math.
The agency’s words, the record +Hide the words
The agency says
“Fill and foundations could permanently affect approximately 0.69 acres of soils (Cainhoy fine sand, Mandarin fine sand, and Pottsburg sand soil types) by compacting naturally occurring soils, reducing the porosity of the soil, and reducing the biological activity in the soil.”
Soils
Elsewhere in the same document
“Construction and maintenance of a maximum of six single-family residences would be permitted, together with ancillary structures and a single access road to Old House Road, provided the total building footprint does not exceed 15,000 square feet per residence.”
Exchange 2
Effects
No support given
Homes in the floodplain on the conveyed land are unlikely because of insurance costs and sea level rise risk.
The agency applies the same reasoning under the no-action alternative, where it calls floodplain development on the private parcels possible but unlikely. It adds that permits, wetland rules and state coastal laws would limit impacts. But the document offers no insurance data, cost figures or sea level scenario to back the judgment. It uses that judgment to discount floodplain in the building areas, including 5 acres on exchange 2b, while still counting acquired floodplain as newly protected.
AskEither bar building in the floodplain and wetlands within the building areas through the easement, or show the evidence that floodplain building is unlikely.
The agency’s words, the record +Hide the words
The agency says
“However, as noted under alternative 1, development within the floodplain is unlikely based on insurance considerations and risk to private landowners based on predicted future sea level rise scenarios.”
Water Resources
Elsewhere in the same document
“Conversely, the transfer of NPS property into private ownership would place 3.4 acres of freshwater forested/shrub wetland 5 acres of the 1% floodplain within the potential building area, subjecting them to potential future development (figure 19).”
Water Resources
Show 1 more claim +Show fewer
Effects
No support given
Homes on the conveyed parcels would sit outside key visitor areas and wouldn't affect major trails or backcountry routes.
Chapter 2 says twice that the conveyed parcels aren't in areas with high visitor use. Appendix B says they don't provide public recreational access and that homes would likely be low density, partially screened by vegetation, and unlikely to produce substantial night lighting. The easements also cap building at 20% of each parcel and set a 35-foot height limit. But the document gives no distances from the conveyed parcels to trails or campgrounds, and it says several campgrounds are near the exchanges. The Visitor Use and Experience section, where Appendix B sends visual and lighting effects, doesn't analyze views or lighting from the conveyed parcels.
AskMap distances from both building areas to trails, campgrounds and the marsh shoreline, and analyze views and night lighting from those places, including 35-foot structures.
The agency’s words, the record +Hide the words
The agency says
“As a result, potential impacts on recreation resulting from development of these transferred parcels would be limited, localized to areas outside key visitor use areas, and unlikely to affect major visitor routes or backcountry corridors.”
Visitor Use and Experience
Elsewhere in the same document
“Sea Camp, Stafford Beach, Hickory Hill, and Yankee Paradise are in the vicinity of the proposed parcel exchanges; visitors in these areas may use trails affected by the parcel exchanges.”
Visitor Use and Experience
“Future development could also introduce localized sources of artificial lighting that may alter nighttime visual conditions and contribute to minor changes in the area’s natural lightscape.”
Issues Considered but Dismissed from Detailed Analysis
What the document never analyzes
Not analyzed
Construction access and island traffic
The document says the island is reached only by water, the historic Main Road runs through the project area, and up to eight homes would need access roads to Old House Road.
Searched all 81 pages for ‘barge’, ‘traffic’, ‘construction materials’. None appear.
AskAnalyze how building materials and equipment would reach the island and how added vehicle use would affect the Main Road, trails and visitors.
Not analyzed
County property tax effects
About 130 acres would move into federal ownership and about 80 acres into private ownership in Camden County, but the document never discusses fiscal effects on the county.
Searched all 81 pages for ‘property tax’, ‘tax base’, ‘revenue’. None appear.
AskEstimate how the change in taxable land and new homes would affect Camden County property tax revenue.
Not analyzed
Fire risk from new homes
The document says fires may be suppressed to protect private property and that homes near wilderness would require more fire suppression, but it never weighs fire risk for homes on the conveyed parcels.
Searched all 81 pages for ‘wildfire’, ‘defensible space’, ‘evacuation’. None appear.
AskAnalyze fire risk and suppression needs for new homes on the conveyed parcels and how they'd affect the Seashore's prescribed fire program.
Where its own record backs the agency
EffectsMore wetland and floodplain would gain protection through the swap than would be opened to possible development.Why it holds +
Table 5 lists 5.42 acres of mapped wetlands entering federal ownership and 5.39 leaving it. The acquired land includes about 5 plus 12.8 acres of floodplain, versus about 1.5 plus 5 acres in the building areas. The margin on wetlands is thin, and 3.40 acres of wetland sit in the exchange 2b building area, but the agency's numbers support the claim as stated.
The agency says
“Overall, beneficial impacts on water resources would outweigh adverse impacts because more water resources would receive protection from NPS ownership and conservation easements associated with the land exchanges than currently protected resources that would be subject to potential development.”
Water Resources
Its own record backs it
“Exchange 1 would protect approximately 0.5 acres of estuarine wetland and approximately 5 acres of floodplain on lands that are currently privately owned and subject to potential development in accordance with local regulations and zoning (figure 16).”
Water Resources
EffectsGains for archeological sites would outweigh losses, since known sites would be protected by Park Service ownership and easements.Why it holds +
The agency's weighing rests on its own facts. The Park Service would gain three known sites, two eligible for the National Register and one unevaluated. The one site on the conveyed land is recommended ineligible, and its artifacts were removed and curated. The easements bar ground disturbance on 80% of the conveyed parcels. Caveats remain: consultation with the Georgia State Historic Preservation Office is ongoing, the survey says small intact pockets may have gone undetected, the easement terms don't name cultural resources, and parcel labels shift between paragraphs.
The agency says
“Overall, beneficial impacts to archeological resources would outweigh adverse impacts because known archeological resources would receive protection from both NPS ownership and conservation easements associated with the land exchanges.”
Archeological Resources
Its own record backs it
“The testing suggests that historic and modern landscape modifications over time have negatively affected several aspects of integrity, such that small pockets that retain integrity may remain, but were not identified at the resolution used for data collection.”
Archeological Resources
“Conversely, most of the NPS land involved in this exchange has been subjected to archeological investigations.”
Archeological Resources
Read from the agency’s own decision document ↗, all 81 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
What to say
Make these points, in your own words
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The EA's Reasonably Foreseeable Actions section flatly states that no reasonably foreseeable actions exist near the exchange, so cumulative impacts are never analyzed. But the same document's Land Use section, under Environmental Trends Impacting Land Use, documents that multiple new and expanded developments have been proposed within 30 kilometers of the island and that multiple private, developable parcels on Cumberland Island itself have already submitted rezoning and development proposals to Camden County. The agency cannot claim there is nothing foreseeable to analyze while its own Land Use chapter lists ongoing development proposals on and near the island. NPS should withdraw the no-reasonably-foreseeable-actions finding, identify the development proposals it already describes elsewhere in the document, and analyze their cumulative effects on wilderness, wildlife, and trail access…
- The Wildlife section concludes that sea turtles would not be affected by potential development on the exchange parcels because they sit on the marsh side of the island and lack nesting beach habitat. But the Water Resources section describes the same exchange 2b parcel as partially bordered by the Atlantic Ocean, which is ocean-facing frontage, not marsh-side land. Since Cumberland Island accounts for 25 to 30% of Georgia's statewide sea turtle nesting, a parcel with ocean frontage cannot be dismissed from sea turtle analysis on the grounds that it is marsh-side only. NPS should reconcile these two descriptions of exchange 2b and directly analyze potential sea turtle nesting and lighting impacts on any ocean-facing portion of the land being transferred to private ownership.
- Table 8 and its surrounding text label the archeological sites 9CM16, 9CM72, and 9CM104 (the Stafford Slave Cabins, eligible for the National Register) as located on the privately owned parcels exchange 1b and 2b. But Chapter 2 defines exchange 1b and 2b as the NPS parcels being transferred out to private ownership, not the privately owned parcels being acquired. The Environmental Consequences discussion then says acquisition of the privately owned parcels exchange 1a and 2b would bring these sites into NPS protection, again using 2b, a parcel Chapter 2 defines as leaving federal ownership. The document never clearly establishes which exchange actually contains the eligible slave cabin site, so the public cannot tell whether it will be protected under NPS management or left on land whose only protection is a conservation easement. NPS should correct the exchange labels throughout…
- Appendix A states that Section 7 consultation with the Fish and Wildlife Service on federally listed species, and Section 106 consultation with the Georgia State Historic Preservation Office on historic properties, will both be completed only prior to finalizing the decision document, meaning after the EA's conclusions about minimal effects on listed species and historic sites have already been drafted and released for public comment. The EA nonetheless reaches specific effect conclusions throughout Chapter 3 before these statutorily required consultations are complete. NPS should complete Section 7 and Section 106 consultation and disclose the results before or alongside the public comment period on this EA, not after it.
Show every point from the document
- The document's own wetlands accounting in Table 5 shows the exchange would move only 5.39 acres of NWI wetlands out of federal ownership and 5.42 acres into federal ownership, a net gain of roughly 0.03 acres. The conclusion that beneficial impacts on water resources would outweigh adverse impacts rests on this razor-thin margin, yet 3.40 acres of wetlands are placed directly in the potential building area of the parcel leaving federal ownership, exposing them to the same development the agency credits itself with avoiding elsewhere. NPS should disclose this near-zero net wetland benefit plainly in its impact conclusion and explain why wetland acreage was included in a buildable area at all.
- The Water Resources Environmental Consequences section acknowledges that transferring NPS land into private ownership under exchange 2 would place 3.4 acres of freshwater forested and shrub wetland and 5 acres of the 1% floodplain inside the potential building area, subjecting them to potential future development. This runs against the section's overall framing that alternative 2 is net beneficial for water resources, since it puts sensitive wetland and floodplain acreage into the one part of the parcel where construction is allowed. NPS should quantify the specific flood and water-quality risk of siting the building area over floodplain and wetland acreage, and explain why the building area could not have been drawn to avoid these features entirely.
- One of the stated objectives of this exchange is facilitating additional designation of wilderness, yet Table 1 shows that while exchange 1a converts all 10 acres acquired into designated wilderness, the much larger exchange 2a, at 119.3 acres of upland forest, salt marsh, and ocean frontage supporting shorebird and sea turtle habitat, results in zero acres designated as wilderness. The EA never explains why the larger, more ecologically significant parcel is not proposed for wilderness designation the way the smaller parcel is. NPS should explain the wilderness-eligibility analysis for exchange 2a or commit to pursuing wilderness designation for that acreage consistent with its own stated objective.
- The Land Use Environmental Consequences discussion states that no adverse impacts are expected from the acquisition of private land within the Seashore boundary, but the same discussion goes on to say that once roughly 80 acres are removed from direct federal management, future development could conflict with Camden County land use plans, policies, or controls for CP-Conservation future land use and zoning. A conflict with the county's own conservation zoning designation is an adverse land use impact, not a neutral one, and the document should not assert no adverse impacts in the same breath it acknowledges a potential zoning conflict. NPS should revise this conclusion to acknowledge the identified land use conflict rather than characterizing the transfer as having no adverse effect.
- The Wildlife section's discussion of trends under current management states that future construction on private parcels involves tree removal that has the potential to result in adverse impacts on bats by eliminating suitable roosting habitat, referring to the tricolored bat, a species proposed for federal listing as endangered. The Environmental Consequences section for alternative 2 then concludes only that listed species including the tricolored bat would see minimal adverse effects, without describing any bat-specific survey, acoustic monitoring, or habitat assessment of the maritime forest acreage placed in the potential building areas. NPS should conduct and disclose a tricolored bat habitat assessment for the specific acreage proposed for the potential building areas before concluding effects are minimal.
- The 2024 civic engagement period ran 45 days and generated 492 comments out of 2,725 pieces of correspondence, showing substantial public interest in this project. Despite that documented level of interest, Appendix A sets the formal EA comment period at only 30 days, shorter than the earlier scoping window, for a document that covers wilderness character, nine federally listed or proposed species, wetlands, floodplains, and archeological sites across five parcels. NPS should extend the EA public comment period to at least match the 45-day civic engagement window given the volume of public interest already documented in this same appendix.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
Voluntary Land Exchange Environmental Assessment
On the record for this fight
2 people have filed on this fight through PLAN. The official record is still catching up.
- Karen W.49 seals
- and 1 more steward
Ranked on letters found on the agency’s record, then letters filed. Readers appear as first name and last initial, or as a steward in their state; switch yours off in your record. All boards
Did the agency answer?
10 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingAppendix A states that Section 7 consultation with the Fish and Wildlife Service on federally listed species, and Section 106 consultation with the Georgia State Historic Preservation Office on histor
Appendix A states that Section 7 consultation with the Fish and Wildlife Service on federally listed species, and Section 106 consultation with the Georgia State Historic Preservation Office on historic properties, will both be completed only prior to finalizing the decision document, meaning after the EA's conclusions about minimal effects on listed species and historic sites have already been drafted and released for public comment. The EA nonetheless reaches specific effect conclusions throughout Chapter 3 before these statutorily required consultations are complete. NPS should complete Section 7 and Section 106 consultation and disclose the results before or alongside the public comment period on this EA, not after it.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document's own wetlands accounting in Table 5 shows the exchange would move only 5.39 acres of NWI wetlands out of federal ownership and 5.42 acres into federal ownership, a net gain of roughly 0.
The document's own wetlands accounting in Table 5 shows the exchange would move only 5.39 acres of NWI wetlands out of federal ownership and 5.42 acres into federal ownership, a net gain of roughly 0.03 acres. The conclusion that beneficial impacts on water resources would outweigh adverse impacts rests on this razor-thin margin, yet 3.40 acres of wetlands are placed directly in the potential building area of the parcel leaving federal ownership, exposing them to the same development the agency credits itself with avoiding elsewhere. NPS should disclose this near-zero net wetland benefit plainly in its impact conclusion and explain why wetland acreage was included in a buildable area at all.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA's Reasonably Foreseeable Actions section flatly states that no reasonably foreseeable actions exist near the exchange, so cumulative impacts are never analyzed.
The EA's Reasonably Foreseeable Actions section flatly states that no reasonably foreseeable actions exist near the exchange, so cumulative impacts are never analyzed. But the same document's Land Use section, under Environmental Trends Impacting Land Use, documents that multiple new and expanded developments have been proposed within 30 kilometers of the island and that multiple private, developable parcels on Cumberland Island itself have already submitted rezoning and development proposals to Camden County. The agency cannot claim there is nothing foreseeable to analyze while its own Land Use chapter lists ongoing development proposals on and near the island. NPS should withdraw the no-reasonably-foreseeable-actions finding, identify the development proposals it already describes elsewhere in the document, and analyze their cumulative effects on wilderness, wildlife, and trail access alongside this exchange.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Wildlife section concludes that sea turtles would not be affected by potential development on the exchange parcels because they sit on the marsh side of the island and lack nesting beach habitat.
The Wildlife section concludes that sea turtles would not be affected by potential development on the exchange parcels because they sit on the marsh side of the island and lack nesting beach habitat. But the Water Resources section describes the same exchange 2b parcel as partially bordered by the Atlantic Ocean, which is ocean-facing frontage, not marsh-side land. Since Cumberland Island accounts for 25 to 30% of Georgia's statewide sea turtle nesting, a parcel with ocean frontage cannot be dismissed from sea turtle analysis on the grounds that it is marsh-side only. NPS should reconcile these two descriptions of exchange 2b and directly analyze potential sea turtle nesting and lighting impacts on any ocean-facing portion of the land being transferred to private ownership.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingTable 8 and its surrounding text label the archeological sites 9CM16, 9CM72, and 9CM104 (the Stafford Slave Cabins, eligible for the National Register) as located on the privately owned parcels exchan
Table 8 and its surrounding text label the archeological sites 9CM16, 9CM72, and 9CM104 (the Stafford Slave Cabins, eligible for the National Register) as located on the privately owned parcels exchange 1b and 2b. But Chapter 2 defines exchange 1b and 2b as the NPS parcels being transferred out to private ownership, not the privately owned parcels being acquired. The Environmental Consequences discussion then says acquisition of the privately owned parcels exchange 1a and 2b would bring these sites into NPS protection, again using 2b, a parcel Chapter 2 defines as leaving federal ownership. The document never clearly establishes which exchange actually contains the eligible slave cabin site, so the public cannot tell whether it will be protected under NPS management or left on land whose only protection is a conservation easement. NPS should correct the exchange labels throughout Chapter 3 and Table 8 and state unambiguously which parcel contains each numbered site before finalizing this decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Water Resources Environmental Consequences section acknowledges that transferring NPS land into private ownership under exchange 2 would place 3.4 acres of freshwater forested and shrub wetland an
The Water Resources Environmental Consequences section acknowledges that transferring NPS land into private ownership under exchange 2 would place 3.4 acres of freshwater forested and shrub wetland and 5 acres of the 1% floodplain inside the potential building area, subjecting them to potential future development. This runs against the section's overall framing that alternative 2 is net beneficial for water resources, since it puts sensitive wetland and floodplain acreage into the one part of the parcel where construction is allowed. NPS should quantify the specific flood and water-quality risk of siting the building area over floodplain and wetland acreage, and explain why the building area could not have been drawn to avoid these features entirely.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingOne of the stated objectives of this exchange is facilitating additional designation of wilderness, yet Table 1 shows that while exchange 1a converts all 10 acres acquired into designated wilderness,
One of the stated objectives of this exchange is facilitating additional designation of wilderness, yet Table 1 shows that while exchange 1a converts all 10 acres acquired into designated wilderness, the much larger exchange 2a, at 119.3 acres of upland forest, salt marsh, and ocean frontage supporting shorebird and sea turtle habitat, results in zero acres designated as wilderness. The EA never explains why the larger, more ecologically significant parcel is not proposed for wilderness designation the way the smaller parcel is. NPS should explain the wilderness-eligibility analysis for exchange 2a or commit to pursuing wilderness designation for that acreage consistent with its own stated objective.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Land Use Environmental Consequences discussion states that no adverse impacts are expected from the acquisition of private land within the Seashore boundary, but the same discussion goes on to say
The Land Use Environmental Consequences discussion states that no adverse impacts are expected from the acquisition of private land within the Seashore boundary, but the same discussion goes on to say that once roughly 80 acres are removed from direct federal management, future development could conflict with Camden County land use plans, policies, or controls for CP-Conservation future land use and zoning. A conflict with the county's own conservation zoning designation is an adverse land use impact, not a neutral one, and the document should not assert no adverse impacts in the same breath it acknowledges a potential zoning conflict. NPS should revise this conclusion to acknowledge the identified land use conflict rather than characterizing the transfer as having no adverse effect.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Wildlife section's discussion of trends under current management states that future construction on private parcels involves tree removal that has the potential to result in adverse impacts on bat
The Wildlife section's discussion of trends under current management states that future construction on private parcels involves tree removal that has the potential to result in adverse impacts on bats by eliminating suitable roosting habitat, referring to the tricolored bat, a species proposed for federal listing as endangered. The Environmental Consequences section for alternative 2 then concludes only that listed species including the tricolored bat would see minimal adverse effects, without describing any bat-specific survey, acoustic monitoring, or habitat assessment of the maritime forest acreage placed in the potential building areas. NPS should conduct and disclose a tricolored bat habitat assessment for the specific acreage proposed for the potential building areas before concluding effects are minimal.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe 2024 civic engagement period ran 45 days and generated 492 comments out of 2,725 pieces of correspondence, showing substantial public interest in this project.
The 2024 civic engagement period ran 45 days and generated 492 comments out of 2,725 pieces of correspondence, showing substantial public interest in this project. Despite that documented level of interest, Appendix A sets the formal EA comment period at only 30 days, shorter than the earlier scoping window, for a document that covers wilderness character, nine federally listed or proposed species, wetlands, floodplains, and archeological sites across five parcels. NPS should extend the EA public comment period to at least match the 45-day civic engagement window given the volume of public interest already documented in this same appendix.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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