Draft LTEs, a compendium

The Brunswick News is rather more selective than the New York Times. The paper prominently features a request for letters but doesn’t publish them on but a couple of days a week out of the six. So, I’ll post them here.
Addendum: The Brunswick News has revised its letters policy and has been publishing many more, including mine. (06-18-16)

Two back-to-back presentations by a Dr. Wickersham and Sheriff Jump to the Glynn County Commission on Tuesday made that pretty clear.
Wickersham’s Health Needs Assessment brought forward as evidence that half our children live in single-parent homes, an almost certain predicate for poverty conditions, a hundred and fifty of them a year suffer serious abuse or neglect and, while car crashes and fatalities are decreasing, injuries are way more than in the rest of the country.
Glynn also has some of the worst air, an inordinate number of prescriptions for controlled substances (1.29 for each of our 81,000 residents), and double the violent crime rate in the rest of the state (800 per 100,000 people). Not to mention 155 registered sex offenders having to be tracked. So, the Sheriff has reason to ask for nine more detention personnel to staff his new jail, a facility that’s three times as large as the present one. And who’s to argue with the assertion that 173 violent incidents a year (one every two days) have to be contained, or that the prisoners aren’t entitled to the services of a doctor, a dentist, a psychiatrist and 24 hour nursing that, because of the community’s sense of penury, they can’t get outside.
Half the population not being seen by a doctor in two years and Medicaid dollars being refused are not going to negate the effect of 14 hazardous waste sites and 1.3 million pounds of toxic chemicals being spewed. There are reasons Glynn people are unhealthy and dying off prematurely.

We should probably reconsider the whole concept of privacy when it comes to a fragile terrain like the Sea Island Spit. Privacy, in general, is a social right in that some other party has to respect it for it to be realized. But, in the context of real estate that’s purchased using a public utility — i.e. our common currency — and/or transformed into a man-made asset, there’s nothing private at all.
Private dealings are based on verbal commitments and handshakes. Once contracts are signed and dollars change hands, in a sense, it’s just like being issued a marriage certificate. A private relationship gets transformed into a public one.
Yes, there are some philanderers and real estate developers who would have us believe that their disregard for proprieties are none of our business.
But, whatever goes into the public record is ipso facto a public matter. And that includes the five hundred septic tanks polluting the dunes of Sea Island.

******
I totally agree with your letter writer, Van Box, that we should purchase what we wish to control, which is why I am going to make a presentation to the Glynn County Commission this coming Thursday to get the ball rolling on making application for a grant from the $900 million of oil lease dollars set aside by the President for the Land and Water Conservation Fund, to be doled out by the Department of the Interior, for the purpose of acquiring the marshes between St. Simons and Sea Island that we don’t already own. Since Glynn County hasn’t been the recipient of such a grant since 1990, it’s way past time.
The creeks (Village, Black Banks and Postell) are, of course, already waters of the state. In addition, the 8 acres that comprise the Ft. Frederica Monument annex on bloody marsh is owned by our federal government and two oak hammocks off Village Creek are the property of the State of Georgia. While it is unlikely that we could get a grant for the full $6 million + at which the majority of the parcels in question are appraised, the appraisals themselves need to be reviewed. Which is why I will also make a presentation to the Glynn County Board of Assessors to ask them to look into how these appraisals are arrived at. For instance, the $425,000 appraisal of the Ft. Frederica annex can’t possibly be market-based and should, probably, be appraised like the conservation lands of the Saint Simons Trust at $0. On the other hand, the 1300+ acres acquired by Sea Island Acquisitions north of the causeway are certainly worth more than the $600 (sic) appraisal. Not to mention that their $5.87 tax bill isn’t even worth sending out. I and, I’m sure, any number of other people would be more than happy to pay them the appraised value and donate the marshland to the County to be conserved and preserved for passive recreation and the sustainable harvesting of fish, oysters and crabs.
The land on the Spit, which is what Mr. Box was addressing, is likely going to be for sale, but at a significantly inflated price, more akin to the lots on the north end of the island, which people bought for between $3 and $4 million, but are now appraised and taxed at far lower values. One lot, without a residence, for example, was purchased for $4,200,000 and is now appraised at $480,000 and pays a whopping $15,500 for no services. Another undeveloped lot, with a dock, was purchased for $3,335,000 and is assessed at $536,520 to pay in $13,114 annually in tax. Another $4,800,000 dollar lot, also with a dock, is assessed at $644,520 and contributes $15,753 to our governmental coffers. Not a bad deal for the County.
One might ask how these inflated land prices were arrived at. In the early ’80s, inflation resulted from the flipping of lots and was a major cause of the S&L crisis. Then too the financial institutions that were suckered into lending for purchases at such “market prices” eventually ended up belly up.
If you like, I can make a packet of the information I intend to present to the Board of Assessors available to your reporter. I have written it all out, so it won’t take too long and tax their patience. The first run through is bound to leave them non-plussed. Mr.Glisson, our relatively new Tax Assessor seems intrigued by the prospect of having something other than disgruntled millionaires to deal with.
Obviously, this is too long to be published and only provided for your information.

**************************
Was the Sea Island Company/Corporation responsible when the local banker was induced to make bad loans?
http://www.bloomberg.com/news/2013-01-14/synovus-sea-island-settlement-bars-board-loan-approvals.html
Was it responsible to declare bankruptcy in 2010? Was it responsible to move all the employees off the island and make them park somewhere else? Is it responsible to retain ownership of the shore so SIA can dump more boulders and pretend that’ll hold the ocean back?

Is it responsible to locate a lift station at an elevation of one foot? Is it responsible to strip all the natural vegetation to build a golf course nobody but the elite can use? Is it responsible to keep increasing the size of the cesspool in the dunes instead of installing an adequate sewer and laterals?
Is it responsible to pay a mere $5.87 property tax on 1353 acres of marsh?
Is it responsible to rely on public sewage treatment for the hotel and pretend the system is their own? Is it responsible to utilize the marshes as a shooting range? Is it responsible to misrepresent the fragility of the land and ignore that ever since Tropical Storm Beryl raged ashore in 2012 the terrain has been permanently affected?
No, that’s not how responsible people behave. Dedication is not enough; it’s what people do that counts.

*************************

The Glynn County Commission is a sorry spectacle. On the one hand, when citizens address them with valid complaints about their dereliction in failing to enforce local ordinances or bring forward helpful suggestions, they sit like bumps on a log. Rather than taking the opportunity to refer citizens’ concerns to the appropriate administrative agent, Commissioners use the public comment period to make it clear that they don’t care to hear what the community expects from them.
On the other hand, the Commissioners’ interactions with citizens, whom they have invited to volunteer for service on various boards and committees and then reject for frivolous reasons, are downright embarrassing. No wonder there aren’t more applicants. No wonder committee recommendations are few and far between. Their only value to the Commission, it seems, is as an opportunity to show favoritism or disdain for some faction or clique.
Indecision is not amusing and sixty minute meetings are not efficient when they embarrass us. They’re a waste of time. And time, unlike money, is definitely in limited supply.
In part, it’s our own fault. Voting is not enough, but, since this is the season, it’s a start. Time to vote out the bumps on the log and bring in some new blood.

*************************
To the editor:

West Virginia’s reputation as the source of coal and its legendary miners has recently morphed into the story of mountain top removal to get at the stuff, while unemployed coal miners watch their mountains and rivers and valleys being destroyed. One has to wonder if that’s what Sea Island Acquisitions is proposing, on a smaller scale, for our beloved Sea Island.
No doubt there are some coal extractors who argue that the mountains are gradually eroding into the sea, so why not hurry it along. The loggers and bulldozer operators in the dunes may well arrive with a similar attitude. Indeed, harnessing the power to wreck the landscape in a short period of time might even provide them with a “high.” But, that’s no excuse.
Even if it took the Creator but a day to make, wrecking the landscape is the Devil’s work.
**************************
September 20–
Every month this year, residents and visitors to the Golden Isles have been advised not to even wade in the ocean. Sharks, although there are many of them, are not to blame. No, the culprits are nearly invisible bacteria (bugs) that can sicken or even kill if they get in your gut or under the skin. Every month, without exception, Georgia’s departments of health and natural resources have issued advisories and press releases which, apparently, the press doesn’t heed. Perhaps it’s because it’s no longer news.
Would it help if the beaches were actually closed? God forbid! That might interfere with the tourist industry.
One gets the sense that the testing and advising is little more than an exercise in law-suit prevention. Not even an effort to determine where this human-centric pollution is coming from so it can be stopped. On the other hand, with five hundred septic tanks on Sea Island pumping out leachate, it’s no wonder chlorinated pools are sprouting like mushrooms. Who says pollution and economic development can’t go hand in hand?
http://www.coastalgadnr.org/nn/beach.glynn.2014.advisoris

*******************
October 12

Today’s paper is commendable for highlighting the start of the electoral season and reminding citizens that they can vote early, before they forget or are distracted by the hoopla over golf and football. However, I’d point out that, although it’s referred to as a “right,” voting in general, not just in elections, is an obligation — one of the bundle of obligations of citizenship. That’s something some of our elected officials need to be reminded of when they sit on their hands or merely rubber stamp staff recommendations. The other obligations of citizenship?
serving on juries
drafting legislation
providing material support
running for public office
enforcing the laws
Fortunately, we can take turns and we can even afford not to carry them out at all. But, that’s only true because some of our citizens are really conscientious.

*******************
December 20

The United States Army Corps of Engineers did not “make” Georgia’s coastal plain a wetland, as some of our politicos seem to think. Just as surely as He made little green apples, God made the wetlands. And then he made Adam out of the mud. Why the same folk, who credit the Creator with whatever they like, blame someone else for what they don’t, is a puzzlement.

In any case, the problem with the coastal wetlands, which are not obliterated by being drained, isn’t so much that they are wet, but that the composition of the soils is such that they corrode concrete and steel and never hold still. It’s not just the dynamic dunes that are characterized by shifting sands.

That said, the Corps’ emphasis on navigation is perhaps misplaced, as is the region’s fascination with transportation. If we want visitors to tarry and refresh themselves, it’s counter-productive to construct more speedways through the marshes and woodlands of Chatham, Liberty, Bryan, Camden, McIntosh and Glynn.

******

To the editor:
About forty years ago, a Commissioner in Alachua County, Florida, figured, if one just looked at the raw numbers, the area could easily hold millions and millions of people because, having a land area of over eight hundred square miles, Alachua County is much larger than the island of Manhattan, whose twenty-two square miles, almost one and a half times larger than the size of St. Simons Island (16.6 square miles), are currently home to over one and a half million people (considerably fewer than way back then), .
Of course, what was impracticable in North Florida forty years ago, would be just as impracticable on the Georgia Coast now, if anyone had any idea about what was being planned. The truth is nobody knows, because the Glynn County Commission, for one, has been approving developments right and left without giving any thought to what the area needs or our infrastructure can support.
Why? Presumably because the fees are keeping county coffers filled. But now that the citizenry is up in arms about shoddy projects sprouting like mushrooms after a rain (and not just on the islands), they’re scratching their heads for a response. The logical solution would seem to be to declare a moratorium on any new residential development approvals, at least until we know how many are already in the pipeline. That 40% of our residential units are mostly unoccupied should also be a consideration since that 40% does not include transient accommodations.
*****************************
To the editor:

Your points on property and casualty insurance are well taken. There are
some relationships where a zero-sum situation exists. That is, as one
side increases, the other goes down. And the relationship between
property and casualty insurance companies and local governments is a
good example. When local government services and regulations preventing
shoddy construction practices and building in hazardous locations are
effectively applied — i.e. the quality of government goes up–then the
need for fire, flood and other hazard insurance is less. Which means the
dollars insurance companies can exact for their “services” get less. Our
agents of insurance have a vested interest in agents of government being
inefficient.

Logically speaking, the opposite would seem to be true. After all, if
houses don’t catch fire or sink into the swamp or get swept into the
creek, insurers keep all their premiums as profits. But, the fact is,
they do that anyway, since there is never any intention to pay out but a
pittance. Because, like their cohorts in the health insurance business,
which have traditionally excluded sick people (people with pre-existing
conditions) from service, property and casualty insurers don’t write
policies in distressed neighborhoods that have historically been
deprived of high quality public services, or even any. Which is not to
say distressed areas don’t have a purpose. Insurers, along with their
cohorts in the financial brotherhood, can point to them as examples of
what happens when insurance coverage isn’t kept up.

A few decades ago financial disinvestment was referred to as red-lining
and associated primarily with minority communities and banks. But, the
impetus was always more mercenary than ethnic in that the object was to
drive resident owners out of prime locations, snap up the real estate on
the cheap and hold up communities for redevelopment bucks. Alan
Greenspan, the former Chairman of the Federal Reserve Bank, called it
“liberating assets for the market” and it’s still going on. Elders can’t
sell and youngsters can’t buy a modest stake because insurers won’t
insure and bankers won’t lend below a certain level. In Rochester, New
York, it was seventy five thousand dollars.

Wonder what it is in Brunswick, where the household income is just
$29,000, compared to almost $31,000 in Rochester.

Unfortunately, the struggle for equality has not turned out as we
imagined. Who knew that 99% could be given the shaft and equally
deprived? The financial gurus knew. That’s who.

*****

Dear Mr. Leavy,

Other than Former Commissioner Gunn, none of your respondents on St. Simons’ future have any environmental awareness. The line about “century oaks” is an excuse for cutting down old trees and letting nurseries and landscape contractors sell new. If the concern were real, everyone would be attentive to the fact that the oaks at the corner of Riverview and Frederica are large, but relatively young and cutting their roots to plant gas tanks underground is certain to kill them off.

Also, if the conern about traffic were real, then Glynn County would not be rejecting the $600,000 a year the folks in Washington are offering for public transportation. Cap Fendig and even the SIA PROPCO, LLC, know that buses and trolleys are much more efficient for moving people relatively short distances. They also know that, if people are relatively healthy and live long enough, there’s a social benefit to getting them out from behind the steering wheel, encouraging walking and leaving the driving to someone else. Contrary to Provenzano’s notion, concrete bikeways along side the roadways for automotive vehicles are not a proper traffic solution. All over the country, it has been proven that vehicles need to share the road and pedestrians need to have the right of way. Moreover, if people are to be neighborly and have a connected feeling, then, instead of being separated by walls and fences, residential areas need to be connected with pedestrian facilities, like the garden gate between The Meadows and Kelvin Oaks.

Segregation is alive and thriving on St. Simons Island, and on the mainland. It disguises itself as “security” and the promotion of private property rights.

Private property, btw, has been a deception from the start. Some people were guaranteed the right to own property, including other people (slaves, wives, children) in exchange for having everyone’s human rights denied at will. People are being deceived. Read one of those condominium association tomes of deed restrictions and then argue that people aren’t signing their most basic rights away. For example, though the association rules at the Reserve at Demere prohibit the units being used for time sharing, they’re being advertised all over Europe as vacation rentals “by owner” to as many as seven “tourists” at a time. Then too, in addition to the new Beach Club condos having only one resident owner, 24 of the Cloister Cottages are owned by Exclusive Resorts SI1 LLC, which welcomes anyone with a large enough wad of money to vacation for a few days or weeks, as if dollars are going to guarantee they’re not crooks. So much for security!!

Finally, because the first Exclusive Resorts listing (Buffer Cloister Cottages) reminds me, there seems to be a gross misunderstanding in the Coastal community about the functional importance of vegetative buffer zones where impervious surfaces are banned. Buffers aren’t about vistas or visual segregation. Buffers are about what happens on the ground in a largely watery environment. Their purpose is to prevent chemical pollutants from industrial, commercial and transport activities from reaching our fresh and salt water bodies and poisoning the biota that normally live in them. Erosion is to be prevented and sediment is to be retained on land because soil particles serve as carriers for chemical pollutants and toxins when storm water carries them off. So, for example, while the butchery of the high marsh vegetation by the county along Highway 17 LOOKS bad, appearance is the least of our problems. Our problem is that our watery environment is being poisoned from above and below ground and our optics-dependent public servants seem totally unaware. People are supposed to be their main concern, but people are being sickened as we speak and “world class health care” is not something we should need.

We, of the Sidney Lanier Environmental Action Team, hope to pass out a short survey at the February 17th meeting of the IPC. Perhaps we’ll be able to generate a more balanced and environment-centered response. Which is not to say I don’t appreciate the Coastal Illustrated effort, which I missed in my paper, probably because I routinely discard all the inserts at the start. My bad.

Monica Smith, aka Hannah

*****

Now, here’s a new wrinkle. I sent a letter to the Times Union the other day. Today I got a request to submit a letter — ON ONE OF TWO SUGGESTED TOPICS!!!! They now thing letters to the editor can be ordered???!!!

I sent back this one:

To the editor:

Let’s get one thing straight. Currency is a public utility. So, any transaction which involves that currency is therefor not private. Moreover, because currency is a public utility, the agency that issues it — i.e. the federal government — is entitled to determine and define how it is to be used and under what conditions it needs to be returned. Settling those accounts is what we are obligated to do by April 15th. Think of it as sort of a spring cleaning — like taking all those bottles and cans to the recycling center. Why should hoarders be praised? Because, having been issued as electronic bits, it doesn’t take up much space?
Hoarding currency might not be as detrimental as it once was, but that doesn’t make it admirable. If you don’t need to spend the dollars, send them back.

April 30, 2015

To the editor:

To cultivate or culture is coercive. That’s true whether we are talking about, horticulture, viniculture, agriculture or abbreviate it as in “cult.” In each case, the cultivar is constrained to follow some course or behave in some manner contrary to its nature. So, I am somewhat nonplussed that people, who have labored on Sea Island for many years, are being “honored” (in a four page supplement to today’s Brunswick News) for their submission to “our culture.” One wonders if being honored as “part of this special club” is supposed to be a substitute for adequate material rewards (good pay, health care, secure retirement).

One might also wonder about the touting of “successful words.” Scott Steilen, the new President of the corporation, claims “one of the fundamental keys to sustained success is having a great team,” apparently forgetting that the recent decade was marred by a rescue out of bankruptcy by a group of absentee owners from Wall Street, who dubbed themselves “Sea Island Acquisitions,” and then morphed more recently into SIA PROPCO II, LLC. So much for consistency.

Are we, the “families, friends, neighbors and fellow community members” being reminded that, like the children whom every politician claims to value and protect when education programs are cut, the “loyalty, passion, grace and service” of Sea Island team members might well be for naught, if we don’t reciprocate the Limited Liability Company’s “appreciation.”

Perhaps I’m just jaded by their habit of paving the wetlands for parking and driving snack food trucks in the dunes.

Monica Smith

*****

The Saint Simons Land Trust, an eleemosynary enterprise par excellence, is looking for more trusting members, according to a half page color ad in today’s paper. That the associated picture is of the creek bank and marsh they have scoured away to replace with bags of oyster shells is not mentioned.
Combo-Cannons-Point-2-1024×441
Neither does the ad make mention of the fact that perhaps their stewardship so far has been somewhat profligate. While the thirteen million spent to acquire 600+ acres forest lands on Cannon’s Point might seem excessive, no doubt, the Trust having paid almost half a million for less than a half acre of creek bank in the middle of the Glynn Haven neighborhood in 2006 set a sort of precedent that has to be maintained.

On the other hand, that the acre donated by Glynn County for the restoration of the Harrington Graded School and its conversion into a museum is now worth over two hundred thousand sounds like a good deal. Too bad it doesn’t look like one. Progress on the building is going at a snail’s pace and the site itself is a scandal, littered with shards of glass, boards with rusty nails, a mosquito-breeding roll off that hasn’t been emptied in months and rickety scaffolding that wasn’t safe when it was actually in use. As it stands, it’s not even possible to organize a neighborhood work session for the park. If the ostentatious sign is to be believed, the project is two years behind schedule.

“The work is not yet done,” according to the ad. You can say that again. The work is not done. But the Trust wants more members to send money, for preservation. Maybe that’s the problem. If preserving the decrepit is what the St. Simons Land Trust is about, maybe we should rethink our investment in this eleemosynary enterprise. While it has shrunk our tax roll by about twenty-one million dollars, the public hasn’t seen a lot of bang for its bucks.

*****

Water and sewer utilities are an issue in Coastal Georgia, as most everywhere else. Here they seem intimately connected with ground water and surface water pollution that, unlike elsewhere, can still be corrected before it gets too bad.

So, I’ve been in contact with local agencies to get the lay of the land and will index the documentation as “the squeaky wheel II” as a separate page on the blog.

Sent: Sunday, February 23, 2014 11:17 AM
To: Swiger, Cliff
Subject: St. Simons Island WPCW

Dear Mr. Swiger,
Again, thanks for forwarding the St Simons Island, Water Pollution Control Permit, which, of course, already signals with its name that “control” rather than prevention is the name of the game. Just want to get that prejudice up front.
After reading through that document, as well as the January operations and testing report, I do have some questions.
1) While it is good that the report indicates 99% of suspended solids are being removed, instead of the required 85%, I have a hard time imagining that the raw sewage is being sampled coming into the plant to determine that removal rate. Also, since that standard presumably applies to all Public Wastewater Plants, leaving 15% solids behind seems excessive.

The requirement is a minimum of 85% TSS removal. If a facility begins to approach the 85% minimum then Georgia EPD will investigate potential causes such as infiltration and inflow. The calculation is indeed a mathematical comparison of influent samples and effluent samples. The 85% minimum removal is a federal regulation found in Title 40, Part 133 of the Code of Federal Regulations, and is incorporated by reference into the Georgia Rules for Water Quality Control. This is a technology-based regulation required for all municipal treatment plants and is a minimum level of treatment for point sources based on currently available treatment technologies. The BOD and TSS effluent limits for St. Simons Island WPCP are “water quality-based” limits and provide a much more restrictive limitation than the percent removal requirement.

2) Does the “influent” being reported on represent the receiving body of water (the creek) into which the effluent of the plant flows? If so, then does the background condition of the receiving water define how much additional contamination can be allowed?

The influent being reported is not the discharge into a receiving stream. It is the wastewater entering the water pollution control plant. The quality of the receiving stream generally dictates the effluent loading permitted by the water pollution control plant.

3) Is there a sludge management plan beyond the number of times and the quantities being picked up? Where is the sludge being brought? Is there a grease separator in place? What happens to the inorganics? Are they skimmed and trucked to a landfill?

The St. Simons Island WPCP does not land apply the sludge generated at the plant. Sludge from the facility is disposed in a landfill, and the quantity of sludge is monitored and reported. Grease can accumulate in the aerators and clarifiers of wastewater treatment plants but is controlled by mechanical (skimming) removal and disposed in a landfill. Inorganics commonly referred to as “grit” settle out at the inlet of the treatment process. The grit is routinely removed from the collection area and disposed in a landfill.

4) Is that the norm that only a fifty percent kill rate of the critters on which the water is tested has to be reported? Also, the things being tested for seem rather skimpy. Copper seems to be the only heavy metal. What about periodic testing for pharamaceuticals going through the system?

In reference to Part 1.A.5. of the permit, the data that must be reported is the concentration of the effluent that is lethal to 50% of the test organisms for an acute toxicity test. That concentration is determined in the laboratory and is used to determine whether the effluent is toxic. Saint Simons Island is required to test for chemical constituents for which the State has established Water Quality Standards (Chapter 391-3-6-.03) once a year. The chemical constituent testing is commonly known as Priority Pollutant Scans. The results of priority pollutant scans are evaluated by EPD to determine if there is reasonable potential to cause or contribute to a water quality standard violation. Whenever, EPD determines that there is concern of causing or contributing to a water quality standard violation, the permittee will be required to conduct additional testing for the parameter of concern. In the case of Saint Simons Island, copper was found at levels of concern and in accordance with EPD’s Reasonable Potential Procedures, EPD required additional monitoring for copper. The copper monitoring conducted by Saint Simmons Island has been evaluated by EPD and there is no reasonable potential for copper to cause or contribute to a water quality standard violation. EPD will continue to evaluate priority pollutant scans submitted by the permittee to determine if there is reasonable potential for any constituent to cause or contribute to a water quality standards violation.

In addition to monitoring for chemical constituents for which the State has established Water Quality Standards, Saint Simons Island is required to conduct annual chronic Whole Effluent Toxicity (WET) tests. WET Test are helpful in determining if there is toxicity being caused by the discharge. Even if the priority pollutant scans did not raise concerns, a WET Test can identify problems with the treatment plant discharge. Based on the results of the WET test submitted by Saint Simons Island, chronic toxicity is not predicted.

There is a potential for pharmaceutical drug residues to be present in treated municipal wastewater. US EPA has conducted research on this matter and “preliminary study results suggest that risks posed to healthy adult humans (and animals with similar physiology) by water-borne pharmaceutical residues is very low”. For more information, please visit the following website: http://www.epa.gov/eerd/research/pharmaceuticals.html

5) I’m not sure that analytical methods being “sufficiently sensitive” is much of a standard.

Sufficiently sensitive means that the procedures and instruments must be capable of detecting and measuring at or below the parameter limit.

6) On page eight there is reference to a watershed protection plan. Where can I get a current copy of that?

The Watershed Protection Branch should be contacted at 404-675-6232 regarding copies of the Watershed Protection Plan. The Coastal District does not maintain a copy of the Plan. As a matter of enforcement we do address any non-reporting violations.

7) There is mention of several industrial contributors. How many are there? Do they have pre-treatment plans ? Are there any non-compliance reports? Will the March 1 deadline for filling the pre-treatment reports be met?

There are no industrial pretreatment facilities which discharge to the St. Simons Island WPCP. A Pretreatment Annual Report is required to be submitted to EPD each March.

8) The provision that notice of bi-pass has to be given ten days in advance suggests that this is a rather routine occurence. What plans are there to build in redundancy so that bi-pass can be avoided entirely?

There have not been any bypasses reported to EPD for the St. Simons Island WPCP. When equipment must be shutdown for maintenance and repairs, the facility has duplicate equipment to prevent the need for a bypass.

9) On page eleven it reads that alternative power can be used IF available. Is such a plant not required to have back-up power that won’t fail? Doesn’t the EPA and FEMA require that.

The St. Simons Island WPCP has an emergency backup generator.

10) Speaking of FEMA, the latest data set suggests that half of Glynn County critical plant lies in the flood plain. Does that include the St. Simons Sewage plant? If so, wouldn’t it make sense to plan for elevated improvements on site so the inflow can be easily rerouted? The county supposedly has a $30 million surplus set aside. http://www.csc.noaa.gov/snapshots/

The Coastal District office in Brunswick plays no role in the development of F.E.M.A. flood zone mapping. If St. Simons Island WPCP desires to make elevated improvements, the Division will need to review and approve those plans. There are no EPD regulations that require modification of sewage treatment plants to meet FEMA flood plain maps.

11) Is Sea Island one of the industrial users. Do they have a complete collection and treatment system or do they send their separately metered flow to the POTW? If the latter, how much do they contribute in terms of flow and dollars? Is there a special rate for industrial users? If Sea Island does its own treatment, is there a different kind of permitting regimen?

Wastewater from Sea Island is treated at the St. Simons Island WPCP, but it is not classified as an industrial pretreatment facility. The Brunswick Glynn County Joint Water and Sewer Commission (BGCJWSC) should be able to provide you with any rate structures applied to Sea Island.

12) How does the January flow (when there was no rain and little infiltration) compare to the flows in summer when the island is full and it is the rainy season?

Flows can increase in periods of heavy precipitation (due to inflow and infiltration) and during tourist season. The St. Simons Island WPCP has maintained compliance with flow limitations specified in the permit.

The 2010 census indicated that only 60% of island residences are occupied. That means up to 40% may be paying for the utilities, but not using up plant capacity. So, if all those houses were either occupied by current owners or sold to people who want to move in, then the flow to the plant could be expected to increase by about 50%. Never mind all the lots that have been platted but not yet hooked in to the plant. Ideally, any subdivision would be conditioned on the current availability of utilities. Developers may have to pay for the piping, but the plant has to be adequate to accept the flow. Just repeating in each report that the data from 2006 are being relied on is not adequate.

Finally, where can I find a map of the distribution systems for St. Simons and Sea Island? Lanier Island doesn’t interest me at the moment.

EPD does not maintain maps of the distribution system. The BGCJWS Commission could possibly assist you with this request.

Thanks for your attention to this and excuse the dumb questions. Unlike a good lawyer, I do ask questions to which I don’t know the answers.

Monica Smith

*****

March 6, 2014

Good morning, members of the Facilities Committee of the BGJWSC

A couple of weeks ago, after reading your Master Plan for the water and sewer utilities, as well as the latest report on the operations at the Dunbar Creek Pollution Control Plant on St. Simons Island, I sent about 12 questions to the Coastal District office of the Environmental Protection Division. I say “about” because, as you will see from the hand-out, some of the questions had several parts. Given how informative the responses from Davil Lyle and Cliff Swiger were, I thought I’d just pass them around and make a few comments, mostly about what isn’t there.

The response to question 6 is still hanging fire because nobody at the EPD number given seems to know what a Watershed Protection Plan is. Which probably accounts for why the District office doesn’t have a copy. Perhaps such a plan, which seems necessary to address the obvious degradation of our streams and coastal water, was just an aspiration, a twinkle in some politician’s eye. I will keep looking.

From the answer to question 7 we can conclude that, since Sea Island is not an industrial user, it must be a commercial client. How the fees are calculated is not quite clear from you rate chart, so I’d ask the Commission for an elaboration, perhaps even a discussion of how a transition to full centralized sewer service for Sea Island will be paid for and accomplished. Your most recent performance audit again suggests that eventually regulations will make it necessary to fully integrate the Sea Island community when it comes to disposing of sewage appropriately.

Number 10 seems to tell us two things, or perhaps three. One is that the Environmental Protection Division is almost entirely dependent on information it derives from the permitting procedure. No permit, no info. This is unfortunate because not only do permits have to be issued (they’re not optional), but if there’s no independent input from other sources, the criteria for improving the results (a healthy environment for man and beast) can’t be adjusted. The second is that co-ordination with other agencies, whose activities the EPD obviously doesn’t permit, is, ipso facto, missing. That EPD might second guess FEMA-suggested efforts to get public utilities out of the flood plain, or at least impervious to flood water intrusion, is a bit startling, especially since rain water flowing into the manholes and infiltrating the sewer collection lines has been identified as a problem since 2006. That relatively clean rain water flowing into the system makes it easier to have a clean effluent is not a positive, if it means that the plant lacks the capacity to treat sewerage from areas that haven’t yet been connected (St. Clair, e.g. would seem to account for 172 units). The Master Plan referenced 50 septic tanks on St. Simons, but that’s probably low, as was the assessment of 400 septic tanks on Sea Island in 2006 or 2008, if the records of the Environmental Health section of the Department of Health are to be believed. That the EPD does not issue permits for septic tanks probably accounts for why they have no records and no idea whether periodic spikes of contamination in the coastal waters are related to the maintenance and proliferation of on-site septic systems. Sand dunes provide good (quick) drainage, and little time for the digestion of contaminants.

It seems that Sea Island is classified as a private water utility as well as a private sewer collection facility, although it pumps and meters the effluent it sends to the Dunbar Creek plant. The average flow of 11,000 gallons per day, which has been reported, suggests, if 300 gpd per Resident Equivalent Unit (REU) is accurate, that about 350 REUs are being served by the force main, which has been installed down the spine of the island. Since, I’m assuming, potable water is being distributed from on-island wells by the Sea Island Corporation, water consumption can’t be used as a base for sewerage charges. So, what I’d ask of this Committee, or the whole Commission, is an explanation of how rates are set for such a large commercial user and, more important, what provision is being made for providing full service to the residents of Sea Island. Because, if the current system fails, the public sector has an obligation to step in. If it’s an unfunded obligation, then that’s potentially detrimental to the rest of the community. Never mind that we all suffer when our natural environment is abused.

I’m not sure that our various planning and zoning bodies understand that their determinations represent commitments which not only have monetary value to land owners and developers, but also represent a commitment by the community to provide necessary services. Water and air and, for that matter, soils that are free of contaminants and toxins aren’t options and “buyer beware” does not apply. When permits are issued, they are based on the assumption that the activity being permitted is good and proper and appropriate. Turning sand dunes into cesspools is not.

In the interim, I have determined that the Commission’s data systems are managed by Glynn County’s Department of Community Development, which helpfully generated a map of known water and sewer distribution and collection lines on Sea Island. There are lots of fire hydrants, water distribution lines to virtually all houses and, as I said, a force main for collecting sewerage running down the spine from the Ocean Forest development on the north end. However, there’s only one manhole that’s been identified, in the area of the hotels and the designation of many lift stations has to be suspect. Because, for example, the one that’s shown on the lot, whose address is 801 Ocean Blvd, would seem to be co-located with a three million dollar mansion at an elevation of ONE foot.
Now, it may be that the data are all wrong, but it seems to me that, as the provider of a necessary public service, BGJWSC has an interest in having an accurate picture of the environment in which it operates. The Sea Island companies may prefer to keep their business private and let the public incur the risks of their mismanagement, but enough is enough. If they want to access public facilities, they have to be inspected. I notice they have no objection to having their trash collected, having the fire engines and EMS respond, but when it comes to planning for the future, they are stand-offish. It’s not doing anyone a favor to let them get away with that.
We’ve got the technology and we’ve got the manpower and the Commission has extra funds, so let’s start collecting all the data of what’s underground before any more facilities are planned. The auditors say the recession has given us time because population growth hasn’t been as rapid as expected. But, we should have been using that time to do what was already recommended over five years ago. Oh, and when you contract with consultants, don’t let them get away with saying they could find no information.

*****************
Letter to the editor — not yet published

Private Property Rights
We should probably reconsider the whole concept of privacy when it comes to a fragile terrain like the Sea Island Spit. Privacy, in general, is a social right in that some other party has to respect it for it to be realized. But, in the context of real estate that’s purchased using a public utility — i.e. our common currency — and/or transformed into a man-made asset, there’s nothing private at all.
Private dealings are based on verbal commitments and handshakes. Once contracts are signed and dollars change hands, in a sense, it’s just like being issued a marriage certificate. A private relationship gets transformed into a public one.
Yes, there are some philanderers and real estate developers who would have us believe that their disregard for proprieties are none of our business.
But, whatever goes into the public record is ipso facto a public matter. And that includes the five hundred septic tanks polluting the dunes of Sea Island.

**********************
Presentation to Glynn County Commission

A few weeks ago, when the President’s latest budget was announced, it was noted that he recommended the transfer of some nine hundred million dollars, collected from off-shore drilling fees, into the Land and Water Conservation Fund, a program of grants that has been administered by the Department of the Interior since the 1960s. Governmental subdivision, the only entities qualified to receive such grants, were invited to submit proposals.
Since Glynn County, which had received 16 such grants in the past, but none since 1990, seems about due, it occurred to me this would be a good time to put together a proposal to acquire much of the marshland between St. Simons, East Beach and Sea Island. So, I have identified an area, extending roughly from the East Beach Causeway to North Harrington Road for possible acquisition for conservation, preservation and passive public recreation, including sustainable fishing, oystering and crabbing. While the 3000+ acres, in 23 parcels, are valued at about $6.6 million by our property appraiser, they are not likely to be funded at that full amount. Besides which the process by which these values are set seems rather arbitrary and capricious and, frankly, incomprehensible to the layman. Which is why I have asked our Board of Assessors to review the process and perhaps develop more realistic values.
For example, the eight and a half Fort Frederica Bloody marsh acres are appraised at almost half a million dollars, even though the National Monument is never going to be sold. On the other hand, Sea Island Acquisitions owns over thirteen hundred and fifty acres supposedly worth six hundred dollars. I’d be embarrassed to submit a request based on that kind of information to a federal agency.
It might be suggested that we should rely on the Corps of Engineers and the GADNR to wield their restrictions and specifications to protect the wildlife and vegetation of the marshes, not to mention the quality of the waters. However, the ministrations of these agencies have not been particularly efficacious, in part because they are in the permitting business and if they don’t issue permits for docks and dikes and bulwarks and boardwalks, they have nothing to do. So, they set their demands at whatever level they can extort and the people for whom money is no object get their way and the natural inhabitants get short shrift.
So, what I’m asking is that you refer this proposal, admittedly only roughly outlined, to the Parks and Recreation Committee for their review and assessment as to whether it would be worth while for Glynn County to apply for a grant from the Land and Water Conservation Fund to bring the marshes on the east side of Saint Simons into the public domain.

*****************************

Commissioner Provenzano,

The letter-writer has it exactly right. One of the “advantages” of planned development ordinances for the community is supposed to be that planning ahead obviates the need for constant vigilance, even as developers are able to phase their enterprises as financial and market conditions demand. A planned development ordinance is not supposed to be a blanket permission subject to constant amendment and “tweaking.” Amending an ordinance is supposed to be complex. Delegating it to the IPC is inappropriate.

Moreover, while many citizens are naturally concerned about appearances, increased traffic and the arrival of more strangers in their neighborhood, the county’s regulations should be mainly concerned with impacts on the physical, rather than psychological environment. So, for example, landscape buffers and reserved areas serve environmental interests, such as storm-water retention and treatment, air drainage, protection from solar rays, etc. We need to keep in mind that storm-water, because it washes the various car deposited toxins from roadways and parking lots, is more polluted than the effluent from a well-functioning waste water treatment plant.

It is my impression that landscape requirement for parking lots are fairly minimal in our ordinances and storm water is direct into the marshes and creeks as expeditiously as possible. What developers should be required to provide is compensatory detention areas for any impervious surfaces they install (roofs, parking lots, driveways).
The power to regulate, if it is not to be arbitrary, needs to be based on measurable criteria that affect health and safety of people and the natural environment that sustains them.

I realize the temptation to do nothing is strong. However, that’s not why public servants are elected. If the Community Development staff is not providing good information, that needs to be addressed. Although I will be gone for about three months, when I return in August, I will try to interact with our administrator and some of the department heads. The County Commission, unlike the JWSC on which you also serve, comes across as little more than seven bumps on a log. Administrators prefer that because it gives them autonomy, but the citizens are not well served either by bumps on a log, or rubber stamps.

Sincerely,
Monica Smith

SpitLTE41814.jpg
**************************
May 2, 2014

Commission should not put spit decision on others
5/2/2014
So, Scott Steilen wants his choice. Unfortunately, property ownership is a lot like citizenship, a bundle of obligations. It may be called “private property,” but entry into the agora makes it public. In this instance, the public interest is not served by plopping down yet more McMansions, whose footprint on seven-plus pristine acres would be far in excess and house fewer people than another condo building served by already existing utilities.

While some people are quite content to have the leisure class secrete themselves in their gilded cages, it’s not a kindness to them. Nor is it generous of the chair of the Island Planning Commission to leave it to the potential buyers to beware.

Finally, the Glynn County Commission should be ashamed to be looking for vetoes from the Coast Guard and the Department of Natural Resources. Their mission is in the national and state interest. We count on the county to serve the people and the environment that sustains us.

Monica Smith

St. Simons Island

*********************************
Variations on a theme:
Dick Yarbrough started it:

YARBROUGH: Sea Island Company defends proposed 7.2 acre development

By Dick Yarbrough – Special to The Telegraph

June 3, 2014

I wrote recently about the concerns of environmental groups over a proposal by the owners of Sea Island to develop 7.2 acres on the south end of the island. They say that the land is too fragile for the proposed development.

Those opposed were savvy enough to alert me to their concerns and I was interested enough to weigh in on the issue. As is my policy, I was preparing to contact Sea Island Acquisition LLC, the consortium that bought Sea Island out of bankruptcy in 2010, and get their side of the story.

Before I could pick up the phone, Sea Island Acquisition LCC was running full-page newspaper ads around the state refuting my opinions and making troublesome implications about my credibility.

Their response inspired opponents to run full-page ads of their own, rebutting the company and defending me and my credibility. The net result was to make the issue higher profile and more controversial than Sea Island would like it to be. Some overpaid lawyer probably thought the company was justified in its response. A first-year public relations student would have told them their strategy was dumb as a rock.

Still, I trudged down to the coast to hear from Scott Steilen, SIA’s president, and get his side of the story. The fact that while I was there I managed to scarf down copious amounts of corn-fried shrimp at the exquisite little Georgia Sea Grill on St. Simons Island was a total coincidence.

Give Steilen style points for not trying to justify his (and it was his) over-the-top reaction to my column. I got the feeling that given another opportunity, he might have done things differently.

With that matter behind us, we talked at length about the proposed construction — to be called Cloister Reserve — on the south end of Sea Island. Steilen is emphatic that the eight lots are not on a “spit” as claimed by opponents but on a “peninsula.” There is a difference in the two that would take me too long to explain and would likely give you eye-glaze if I tried, but it is an important distinction to Sea Island.

Steilen says the eight proposed parcels on the peninsula are over a mile from the southern end of Sea Island (the “tip”) and more than 20 feet above the mean sea level.

Even though the property is zoned for higher-density hotel rooms or condominiums, Sea Island says they will limit the “buildable footprint” to just 3.5 acres. The homes will be set back from the ocean and will not impact the beach habitat of sea turtles and birds.

I asked about the fact that Cloister Reserve owners would not be eligible for federal flood insurance. Steilen states that homeowners, not taxpayers, would bear the risk in case of flooding and that the current Cloister Ocean Residences are also not eligible for federally-subsidized flood insurance.

One of the major concerns of environmentalists is erosion. They say Glynn County tax parcel maps show the spit’s shoreline has lost 200 feet over the past four decades and that studies by noted coastal geologist Dr. Chester Jackson, of Georgia Southern, indicate the area has lost 100 feet of shoreline in just the past 10 years. Steilen disputes those numbers and calls them “misleading.”

He says the rate of shoreline recession depends on a great number of factors and that it is the southernmost tip — a mile from the proposed development — that is “most dynamic” and that available information does not support the contention that the Cloister Reserve site is eroding at a long-term rate of 10 feet a year. He claims that construction activities will not cause the island to erode.

Steilen is most animated when talking about his company’s commitment to Sea Island. He bristles at the charge of “damaging the Sea Island brand,” citing a dedicated staff of employees who he applauds for having been through tough financial times with the company and never wavering in their commitment to building and enhancing Sea Island’s reputation, which he says is at the top of many industry rankings.

With that and a tour of the area, we were done. However, I suspect the issue is far from done with the opponents of the project. As for me, I have given both sides their say and I am moving on to other topics, such as the upcoming political races and our unappreciated public schoolteachers and how one is likely to impact the other. Stay tuned.

You can reach Dick Yarbrough at yarb2400@bellsouth.net; at P.O. Box 725373, Atlanta, GA 31139; online at dickyarbrough.com or on Facebook at www.facebook.com/dickyarb.

Read more here: http://www.macon.com/2014/06/03/3129516/yarbrough-sea-island-company-defends.html#storylink=cpy

I followed up:

Mr. Yarbrough:

The thing about half-truths is that they are worse than lies because they aim to mislead and are hard to refute. It is true that one of the sand dunes on which a McMansion is proposed to be plopped is at an elevation of 20′ above sea level. But, the road to get to it and the sewer lines in the ground are going to level that down, sort of like mountain top removal does to the landscape in West Virginia.
Never mind that the last thing we need is eight more McMansions with transient residents. The county and state likely relish the prospects of collecting more property taxes, but, as an abuttor, I don’t want the detritus from their inevitable demise ending up in my marsh.

Then, when the piece got published in The Brunswick News, Holland followed up:

Subject: Dear Editor
Date: Mon, 9 Jun 2014 21:20:42 -0400

This is in response to the “Sea Island Project Two-sided” article by Richard Yarbrough in today’s Brunswick News. Mr. Scott Steilen told Yarbrough the proposed parcels are over a mile from the tip of Sea Island and more than 20 feet above the mean sea level. That part is far from the truth because there is only one small spot on the site that is 20 feet above sea level and the bulldozer building Dune Lane will take care of that 20 feet down to (?). Mr. Steilen disputes Dr. Jackson’s comment about the spit losing about a hundred feet in ten years due to erosion.

Mr. Editor, I am only a layman and Mr. Steilen has no idea what he is talking about when disputing Dr. Chester Jackson. I have attached some Google Earth Images that Mr. Steilen should take a look at if he has more education than I. The graphics that I have drawn on these images should make them self explanatory even to Mr. Steilen and they (images) clearly indicate that Dr. Jackson is correct. When anyone talks to a reporter about this site they should know the facts before they open their mouth.
James Holland

*****

Dear Mrs. Vick,

On 7/15/14 10:21 AM, you wrote:
>
> Ms. Smith,
>
>
>
> Thank you for your interest in protecting Georgia’s environment.
Don’t you think it is rather presumptuous for an employee of the state to be thanking a citizen/voter/taxpayer for taking an interest in how well we are being served? If it’s not presumptuous, it’s unquestionably condescending.

> My response to Mr. Holland was brief because we had already discussed the issues at length.
Having dealt with various levels of governmental bureaucracy for over forty years, I am quite aware that, although bureaucrats specialize in making and keeping records, they are significantly less keen on having those records inspected. So, a rather common response to open records requirements has been to just not make written records, often under the aegis of “paper work reduction” initiatives ostensibly to save trees. From the citizens’ perspective, the absence of written records makes it very difficult to hold public officials to account. Ditto for property owners whose assets and livelihood might be negatively affected by the state’s failure to prevent pollution, contamination and/or the destruction of biota in the name of “public works.”
>
> If you would like to come in or call, I would be happy to explain the details of this site with you.
>
>
So, while I’m not looking for an explanation, I am interested in reviewing the files on the Spur 25 extension, including the funding source, and hope that can be arranged in due time.

Sincerely,
Monica Smith

P.S. In the interest of completeness, I will be forwarding a hard copy of our exchange by snail mail.

>
>
> From: Monica Smith
> Sent: Saturday, July 12, 2014 8:39 AM
> To: Vick, Alice
> Subject: Vick response to JR Holland re: Spur 25 extension
>
>
>
> Dear Mrs. Vick,
>
> Your latest communication (see infra) with Mr. Holland regarding the DOT project on the Spur 25 extension is not satisfactory.
> While a rock filter dam is undoubtedly an approved method of preventing erosion in some instances, restricting or reversing a natural water course is not an approved activity. So, what we seem to have here is an approved mechanism being misused. We might compare it to our legal tender, the dollar, being used to bribe a public official. Reversing water courses and bribing public officials are both inappropriate behaviors, a misuse of approved tools.
> Furthermore, when the miscreant body is a state (Georgia in this case)on , passing enforcement responsibilities to the United States Army Corps of Engineers is beyond cynical. It is well known that our federal agencies have only one viable enforcement tool, the purse. That is, when the rules aren’t followed, funds are withheld. And, of course, if there are no funds flowing to the states to begin with, that mechanism doesn’t work. Which, one is led to conclude, has been the Republican majority’s intent in rationing dollars to the states.
> On the other hand, if states don’t follow their own rules on their own, the validity of the rules themselves is called into question. This tends to support the conservative prejudice that the rules aren’t well-grounded to begin with. Which is why I suggest that, as the program manager of environmental protection, your response to Mr. Holland’s complaint is beyond cynical. After all, the object of environmental protection is to sustain the health of our natural systems, not to give petty bureaucrats another venue for exacting compliance from the citizenry.
> Finally, I totally agree with Justice Anthony Kennedy that the people are the ultimate enforcers of the law, not just at the ballot box but by fostering public awareness of how our public servants perform. We are grateful that citizen Holland keeps us informed.
>
> Sincerely,
> Monica Smith
>
> **********************************************
>
>
>
> From: Alice.Vick@dnr.state.ga.us
> To: jamesrholland
> CC: Bruce.Foisy@dnr.state.ga.us
> Date: Fri, 11 Jul 2014 15:41:33 -0400
> Subject: RE: Spur 25 & The Georgia Water Quality Control Act (GWQCA)
>
> Good Afternoon James,
>
>
>
> Part IV C of the Infrastructure Construction Permit requires the amendment of E&S plans should the original plan prove ineffective in controlling sediment. The Rock Filter Dam is approved for use on Page 6-117 of the 5th addition of the Green Book and on page 6-175 of the 6th Green Book addition.
>
>
>
> Please contact the USACE with questions regarding compliance with their permit issued under the Federal Clean Water Act Section 404.
>
>
>
> Regards,
>
>
>
> Alice Vick
>
> Program Manager
>
> EPD Coastal District Office
>
> 400 Commerce Center Drive
>
> Brunswick, Georgia 31523

*****

To the Glynn County Commission:

Commissioners:

The Glynn County Water Resources Protection Ordinance, which went into effect in August of 2006, asserts:

Glynn County establishes this set of water quality and quantity policies applicable to all surface waters to provide reasonable guidance for the regulation of stormwater runoff for the purpose of protecting local water resources from degradation. It is determined that the regulation of stormwater runoff discharges from land development projects and other construction activities in order to control and minimize increases in stormwater runoff rates and volumes, soil erosion, stream channel erosion, and nonpoint source pollution associated with stormwater runoff is in the public interest and will prevent threats to public health and safety.

Among other things, the ordinance recognizes that Glynn County is the Local Issuing Authority, whose certification as such was recently announced at the MPO meeting by your County Engineer. In other words, the Glynn County Commission is responsible for seeing that all permits, including those from other agencies, are effectively enforced. And, indeed, only the County has the effective means (revoking business licenses, ordering stop work orders, requiring construction bonds, seeking court injunctions, declaring a public nuisance, etc.) to insure that commercial enterprise complies with rules and regulations, whether they are the minimum (county) or set a higher standard (EPD). The principle which applies (home rule) has been cited to me by a number of other state agency representatives: both the Environmental Protection Division of the Department of Natural Resources and the Division of Surface Mining, as well as agents of the Georgia Department of Transportation. Since the latter rely almost entirely on private contractors to carry out projects, the GaDOT lack of enforcement mechanisms has proved most vexing.

Which is why I have requested to address the County Commission with an historical presentation, pictorial evidence of lax enforcement going back, co-incidentally to 2006. Your Clerk had me informed that she does not consider the matter germane to your duties. I disagree. However, if an objective historical presentation is not wanted, I can address the Board of Commissioners about current threats to public health and safety resulting from the county’s failure to effectively enforce its ordinances. I could even throw into the mix homeowners having to abandon their new houses because they were built in wetland soils unsuitable for septic tanks and concrete in-the-ground foundations, the continued high coliform counts in our creeks and rivers, with the result that the Department of Natural Resources discourages swimming in all our surface waters, even the beaches because of the persistent failure to prevent nonpoint source pollution, not to mention permitting the discharge of stormwater from one property (the Reserve at Demere) onto another’s (St. Simons by the Sea) and expecting the recipient of this nuisance to deal with it via a law suit.

I will attempt to consult with your Administrator later in the day to brief him on my concerns. Mr. Ours chaired the meeting at which the County’s re-certification as an LIA was proudly announced.

Sincerely,

Monica Smith

P.S. I entitled my slideshow, “Killing the Golden Goose” because, of course, the ruination of our natural coastal Georgia environment by careless development, much like mountain top removal in West Virginia, destroys the very landscapes the people in the rest of the country are being invited to visit and view for a refreshing change.

*****

Since this was written in December, I have received no response. It seems our public servants are schooled to be deaf and dumb.

Mr. Alan Ours, Glynn County Administrator
W. Harold Pate Building
1725 Reynolds Street
Suite 302
Brunswick, GA 31520

Dear Mr. Ours:

This is to inform you that in recommending the development of the 15 acre parcel on Hamilton Road on St. Simons Island into a 125+/- multifamily residential community to the Island Planning Commission, the Glynn County planning staff was either negligent or grossly deficient. Having visited the site, I can only conclude that either,

1) the planning staff failed to conduct a site visit and accepted the owner’s (Gascoigne LLC, a Florida corporation) and the owner’s surveyor’s representations at face value

or
2) the planning staff, after visiting the site, chose to misrepresent conditions to the Island Planning commission as to the appropriateness of the site for development of any kind.

Had they provided an accurate description, the staff would have noted, among other things, that
a. the fifteen acres are currently operating under a surface mining permit from the Department of Natural Resources, which does not, however, allow for the dumping of soils, stumps and building debris that is going on
b. the contours presented by the surveyor/engineering consultant are obviously in error in that they do not accurately portray either the two pits that have been dug, or the 12′-15′ mounds of dirt that have been trucked in from elsewhere to elevate the terrain
c. the pits left as a result of the mining operation are being mechanically dewatered and the effluent is being discharged into a ditch along Sea Island Road, a ditch which, in turn, drains into the salt marsh at the gateway round-about.
d. the site is being used as a repository for hazardous wastes in ad hoc storage containers
e. the site is serving as a repository for broken down equipment, as well as operational Sea Island Company vehicles
f. excavated soils are being routinely delivered from off-site in vehicles that are not properly covered with mesh and whose tires are depositing dirt on public streets
g. in addition to sand, clay and soil, the excavata contain plastic pipe and other building materials suggesting off-site demolition debris is being trucked in
h. the stagnant water in the borrow pits is a source of mosquitoes, as are the multitudinous plastic containers littering the site.

In other words, the planning staff failed to inform that what is being approved for residential development is an unpermitted landfill and dump site where who knows what hazardous materials have been deposited and leaked over a considerable number of years. While the property is locally known as the “nursery site” because of its historical use to grow and propagate various flowering plants, bushes and trees to beautify Sea Island properties, worse management practices (WMPs) cannot be imagined and the property looks to have been a pollution source for some time.

Had the staff been conscientious, they would have made a referral to codes enforcement, the Department of Natural Resources, the Environmental Protection Division, the Fire Department and whoever is in charge of dealing with hazardous waste in order to set up a remediation plan before any development for residential uses can occur.

Please consider this a notice that much work needs to be done before the threats to public health and safety presented by this site are abated.
Sincerely,
Monica Smith

*****

Sidney Lanier Environmental Advocacy Team

February 3, 2015
Summary minutes of January 31st meeting.

Present were Lisa Norton, Mimi Waite, James Holland and Hannah Smith. After some dithering and additions, the agenda was adopted and the team proceeded to discuss a statement of purpose for the organization being proposed.

“To promote awareness and accountability of ecological concerns in Glynn and McIntosh Counties and provide an environmental movement of activism for addressing such issues” – was agreed to.

Since the organizational alternatives seem to be either a traditional 501.c.3 not for profit corporation or a Limited Liability Corporation, whose disreputable associations are off-putting, it was agreed we should explore the former and solicit the assistance of one June Sortwell, with whom Mimi is in regular contact.
It was also suggested and agreed to that we should seek to establish a steering committee of seven (7) persons to advise and support a board of directors. Our recruitment of additional members should focus on identifying persons to serve in those roles.

Current issues, as usual, took up most of the 3.5 hours we met.
A. The IPC meeting on the proposed gas station for the corner of Frederica and Riverview needs constant attention. A visibility in three locations is planned for the 16th. SP2906, a petition by Lucas Properties is also a concern because access by emergency and service vehicles (including trash pickup) is already not adequate. After some discussion, it was agreed to prepare a survey to pass out to the attendees at St. William’s church, as well as offer them a petition for a moratorium on development to sign at the door. The survey should solicit opinions on quality of life issues such as the tree canopy, the preservation of the marshes, pedestrian circulation and protecting the public interest, including the negative effects of industrial and military incursions into the ocean waters with submarine sonar and oil exploration technologies.
B. The Coastal Resources Division will review the Beach Club desire for a variance from Shore Protection Act provisions on February 27 at 9:30 AM. Many citizens should attend, but not be expected to speak.
C.James called our attention to the fact that the SIA had sought a letter of permission to drive heavy equipment on the beach to install yet another tent. Comments raising objections need to be received by February 10 – even though seeking public comment after the LOP has been issued is another example of ass-backwardsness.
D.Brailsford Plantation, which is infringing on the Longview and King Marsh neighborhoods, is being addressed by attorney Maria Coughenour.
E.The proposed Stables roundabout and the expansion of the illegal Sea Island parking lot in the wetland north of the Sea Island Road needs to be closely monitored. Roundabouts are the most recent fad among traffic engineers, whose mission is always to keep the cars moving.
F. Mariner’s Landing was merely identified as a problem, as well as a potential vector for spurring Garden and Cassina Club involvement in island decision-making.
G. Letters to Senator Ligon and Representative Atwood are to be written to laud their support for a ban on Aquifer Surfacewater Recharge (ASR) and to elicit support for the establishment of protective marsh buffers.
H. The decimation of vegetation along State Route 17 north of Brunswick is an issue James will continue to research and address. Ditto for the Reserve at Demere, where development is on-going despite final plats not having been approved. More evidence that the Glynn County development ordinances are in need of revision.
I. On February 6, 2015 the DNR Board of Directors will hold their spring meeting on St. Simons Island at 9:00 AM at the A.W. Jones Heritage Center next to the Lighthouse. Citizens are encouraged to attend and become familiar with the Governor’s appointees.
We discussed recruiting new members, but not membership fees. Among individuals who might/ought to be invited to join this organization with an evolving name are:

Maria Coughenour
Mary Katherine Boyd
Carl Pennington
Dick Wiederhorn
Bonnie Haron
Miriam Lancaster
Becky Gilger
Laura Wallace
Doug Gilleland
Steven Ryner
Joan Wilson, former member of the ICP

The next meeting was scheduled for February 14, at 2:00 PM in good time to make last minute preparations for the meeting on February 17th . 6:00 PM –Regardless of County video coverage, Hannah plans to record the event, as she did the Incorporation Presentation.

As mentioned above, the name of this organization is still evolving. As a consequence of Puddy Smith’s input, we are now considering highlighting appreciation for the marshes of Glynn by appending Sidney Lanier, whose birthday happens to be today and should be commemorated next year, to our name.
So, we might well be the Sidney Lanier Environmental Advocacy Team or SLEAT, or “So Let’s EAT” instead of just “EAT”

Our motto can still be “Making the Environment Good to Eat” which co-incidentally leaves no other living creatures out. Though, it does call into question the practice of feeding poison to organisms we don’t like.

Respectfully submitted,

Hannah

*****

For the record:

Some many months ago, Paul Andrews, the Glynn County Engineer, assured me that his office has access to much more detailed construction records when it comes to evaluating the adequacy of storm water management and drainage structures than are available to the folks in the Geographic Information System (GIS), who put together a map of all such structures in Glynn County at my request–a level of detail that cannot be displayed on a single map. Other than the reference to his office, Mr. Andrews did not specify where these documents are kept. Community Development does not have them.

So, about a week ago, I had occasion to call the Department of Public Works to inquire where these documents could be physically inspected. The person on the phone, whose name I did not recognize and did not get, wrote down the question and promised to get me an answer. Next thing, many hours later, an email from Ben Pierce arrived, telling me he had heard I’d made an inquiry and should let him help. So, I sent him my question–i.e. where can I find the construction plans for drainage facilities, specifically those installed west of the Post Office lot on St. Simons. Ben Pierce eventually responded that he does not have access to such documents and I would have to contact Mr. Andrews.

This prompted me to send the following communication to Mr. Ours, the County Administrator:

This is incredible. The Division Manager of Roads and Drainage does not have access to all County archives? The person I first talked to on the phone gave no hint that there would be any problem getting the information I was looking for and now I’m getting a run-around.
Since Mr. Andrews no longer answers communications from me, I hope you’ll be able to straighten this out. I cannot believe Glynn County has thrown all construction plans for public infrastructure out.

Mr. Ours responded promptly that he would check it out. That was on Tuesday, February 17.

I heard nothing. Although I saw Mr. Ours at the County Commission Planning Session on Thursday morning, I did not ask him what he had learned. Instead, Thursday evening, since Mr. Austin, the Director of Public Works, was sitting in the audience of the County Commission meeting, I responded to his query about my well being that I was still waiting for a response from someone about the location of storm water facility construction documents. Mr. Austin allowed as he’d heard I had posed a query. I said, yes, Ben Pierce had offered to help, but couldn’t because he does not know where the records are kept. To which Mr. Austin replied that in his previous place of employment they were kept in the Engineering Department, but he was unsure about Glynn County. But, he did pull out his smart phone, on which he perused the communication I’d had with Mr. Pierce and then allowed as how Mr. Andrews had said he’d take care of it and give me a call. So, I had to tell Mr. Austin that I’d had no call or email from Mr. Andrews and Mr. Austin indicated he’d remind him.

Apparently, that worked because first thing this morning I got a call from Mr. Andrews wanting to know what I was looking for. I tried to convey to him that the drainage facilities behind the Post Office and running along what is now Kings Marsh Way are representative because the water and sewer people obviously know where their lines are, since they’ve been neatly cutting up the roadway to access them, AND because I’d run across the deed in which the easements to the county for utilities are mentioned. To which Mr. Andrews responded that the County has not been maintaining the facilities (which is true all over the county) and that he doubted the county has a legal easement, which he assumed would have been in conjunction with the building of the hotel (formerly Days Inn, now Sea Palms Condos). So, I mentioned that I’d seen it in a deed referencing an easement from Skiff Landing to Riverview Road.

After that, Mr. Andrews sort of explained about having an archivist; the hard copies not being available to the public; the effort to digitize everything (to which I object because electrons are unreliable) AND his ability to secure the documents and let me have a look some time next week. We will see. I’m not holding my breath. The last time I asked for the drainage plans for the Reserve at Demere, Mr. Andrews produced the drainage study that had been put together for phase I and II and, in addition to being inadequate for that, didn’t address and hadn’t been updated for phase III — a deficit that, unlike some others, was not mentioned in the departmental comments to the planning division. The plan reviewer did note that they were missing. (One is left with the impression that departmental review comments are an exercise in CYA). The failure to pay close attention to comments from the water and sewer utility is not unique.

*****

March 24, 2015

A letter to Spud Woodward and Mark Williams at the Georgia DNR

Gentlemen:

This is to inform you that the Coastal Resources Division habit of doling out Letters of Permission for the commercial exploitation of our shores, beaches and dunes is getting downright tedious. While the public is already precluded from gaining easy access to our beaches by the unwise gating of the Sea Island community and the abandonment of public rights of way to an irresponsible corporate enterprise are bad enough, giving the Beach Club or SIA PROPCO II, LLC vehicular access for non-emergency commercial/recreational purposes is contrary to the public welfare and violative of the Shore Protection Act.

As regards the Westin Hotel request to deliver equipment to the beach on a daily basis because carrying chairs and tables is tedious and/or considered hard labor, that’s just plain ridiculous and Brad Gane ought to be ashamed to have accepted that as a rationale for introducing polluting vehicles onto the shore. If people want to interact with automotive vehicles on the beach, they visit Daytona. The visitors to the Golden Isles come because they expect to find them unspoiled. That these expectations are not satisfied but unbeknownst to them when it comes to the waters, which are often polluted by unacceptable levels of e-coli bacteria, is not an excuse for letting the sand beach be polluted, as well.

For that matter, that the waters are often unfit even for recreation should be more widely publicized, as should the fact that the classification of our coastal waters as “recreational” means that the fish and crustaceans aren’t fit to be consumed on a daily basis. In the interest of not repeating myself, let me refer you to a couple of articles:

An open letter to Georgia Representative Alex Atwood

LCP White-Wash

It is clear that the Department of Natural Resources and the Coastal Resources Division, including the Division of Ecology Services, have not satisfied the intent of the Shore Protection Act if consuming the resources kills.

Consider yourselves informed.

Sincerely,

Monica Smith
61 Maxwell Avenue
St. Simons Island, Ga.

*****

Dear Mr. Hainley, (the Director of Community Development in Glynn County)

I’d very much appreciate answers to the following:

1. The number of soil disturbance permits issued by Glynn County
during the last fiscal year.

2. The total amount of the fees paid in conjunction with those
permits. Does the County keep the entire fee or does it have to be
shared with the state?

3) Does the revenue cover the cost of the inspections associated with
the soil disturbances?

4) What are the penalties for soil disturbance undertaken before a
permit is sought?

5) Which soil disturbances, besides gardening, are exempt from the
permit requirements?

6) Are the exemptions based on quantifiable measures (area, depth)
relative to the soil or are some disruptive agencies exempt?

7) Is there a privileged class that’s not required to comply with the
law? If so, why?

8) Are exemptions granted by state statute? If so, could you specify
the relevant statute?

9) Are best management practices a condition of soil disturbance
permit compliance?

10) Does the County conduct random inspections as part of the
enforcement process?

11) Have any violators of the soil disturbance ordinance provisions been
referred to the County Attorney for prosecution during the last fiscal year?

12) Were there court-imposed sanctions?

*****

July 20, 2015
Mr. Chris Novack, PE

Director of Engineering

and Facilities Maintenance

Georgia Ports Authority

P.O. Box 2406

Savannah, Georgia 31402

Re: Moffatt and Nichol annual inspection reports for two GPA facilities in Brunswick for 2013&2014

Dear Mr. Novack:

Having read through four annual inspection reports by the consultants who initially prepared the SWP3 for the Mayor’s Point Terminal and the Colonel Island Terminal, let me just make a couple of general comments to begin with:

Reading similar verbiage to describe the venues in subsequent years and noticing that, despite the repetitions, even typographical errors have not been corrected from one year to the next, is not reassuring. I don’t get the sense that these consultants are particularly attentive.

Mid to late December is not a good time of year in Georgia to assess storm water treatment, nor does a once a year sample of effluent tell us much about quality.

Quarterly visual inspections of effluent tell us nothing about heavy metal and chemical contamination. From which I conclude that the inspection regimen is inadequate.

While establishing a benchmark for future inspections is a good idea, in practice the consultants seem to have focused on different areas of the facilities in subsequent years and there is no evidence in the reports of follow-up, with the exception of calling for the collection of wash down waters in containers (which I shall come back to later).

The statement, much favored by the consultants, “inspection . . . confirmed existing vulnerabilities that are typical in all marine environments” makes no sense. If contaminants leak into the river, that’s not because the river and ocean are nearby. That’s because people are being either careless or lazy. Never mind that the spill locations identified on Appendix A for the MPT are about as far away from the water’s edge as can be.

Appendix B for the MPT review describes an area that drains across grass into Flint River, which is in North Carolina. This raises the question whether this report is even germane to this location. Moreover, addressing that contamination has most likely occurred in ground adjacent to wash pad, is not going to mitigate a pump failure. Failed pumps need to be replaced and replacements should be kept on hand. To mitigate is to lessen; it does not prevent nor correct.

I’ll ignore the fixation on cat litter, however, the concern with overgrowth suggests the consultants are persuaded that storm water needs to be drained away as expeditiously as possible, whereas I would argue that storm water needs to be detained, retained, infiltrated and percolated through soil so that the heavy metal and mineral contaminants can be captured for treatment by organisms in the soil, rather than being sent into our waterways. My impression of the consultants’ prejudice seems confirmed in the 2014 MPT inspection when they write Consider installing cub (sic) and slope drain to carry water directly to river.

Turning now to the 2013 CIT report, my impression above is affirmed. However, this sentence is a puzzlement:

Remove stormwater promptly to allow for maximum containment and to prevent contaminant collected in sump from entering drainage system.

Doesn’t a containment sump automatically drain into a special tank for treatment?

9. That 10 out of 11 items were not acceptable in 2013 is concerning; that none of them were revisited in 2014, is more so.

10. There is no disputing this finding, though the writing is careless.

Trash, dust and other materials accumulate on the pavement, which is carried to the fence line and/or the outfalls by wind and stormwater. Regular sweeping of the pavement and trash pickup along the fence line needs to be set up to reduce the trash and contaminants entering into the receiving waters.

However, I would suggest that the object should be prevention, not reduction, and the method of proper disposal of the sweepings should be identified. (I understand the parking lots are swept, so the new cars won’t be scratched by dust and grit).

11. This, from the 2014 CIT, I do dispute:

Wash down area with secondary containment. Oils and other hydrocarbon deposits from washing vehicles and other equipment. Wash water and storm water that collects in containment is being pumped onto adjacent pervious area. Possible contamination of soils and groundwater.

If this is perceived as a problem, then it explains the emphasis on sending storm water as quickly as possible to the river. Which, to my way of thinking, is contrary to the objective of preventing the contamination of our water bodies.

12. If I were confident that the referenced Spill Prevention, Control & Countermeasures Plan were more on point than the plans to which these inspections respond, I’d ask to see that, but it doesn’t seem worth the bother for now.

When the GPA seeks to expand and add more impervious surfaces, at both the Mayor’s Point and Colonel’s Island facilities, I think it will be in order to plan for some acreage to be set aside for detention, retention, infiltration and percolation. Erosion is natural. It is how our islands are built. What we need to prevent is the introduction of heavy metals and man-made toxins into our water bodies.

Finally, the Golden Isles communities need to be concerned about the fact that much of the waterfront that is owned and managed by our Georgia Ports Authority is not being properly regulated and inspected for compliance with environmental and structural safety standards.

I am assuming that as the LOGISTEC facilities are proposed to be rebuilt, they will be properly reviewed and permitted by the City of Brunswick and the Divisions of the EPD. If not, please let me know, and let me know whom to contact to see that higher standards are set and met in future.

In case you missed it, LOGISTEC has not had a stellar first quarter. From their quarterly report:

During the first quarter of 2015, consolidated revenue totalled $60.4 million, a decrease of $2.4 million or 3.8% from the equivalent period of the previous year. The marine services segment’s revenue grew by $2.4 million or 5.2% to $48.1 million for the first quarter of 2015, whereas the environmental services segment’s revenue amounted to $12.3 million, down by $4.7 million or 27.8% from the first quarter of 2014. The revenue growth in the marine services segment came from an increase in bulk cargo volumes, while the revenue decrease in the environmental services segment is explained by lower woven-hose manufacturing volumes. The first quarter of 2015 closed with a consolidated profit attributable to owners of the Company of $2.5 million, compared with $4.3 million for the first quarter of 2014.

The GPA might want to review its leases and insist on a substantial bond to insure that the rebuilding goes forward as planned.

Also, updated information on the date and location for the next monthly meeting of the Board would be helpful. Whom should I contact about getting an agenda?

If you would prefer a hard copy of this email, please let me know.

Thanks again for spending time explaining things. I’m hoping that together we can have things work even better and more profitably for our beloved Golden Isles.

Sincerely,

Monica Smith

*****

This is apparently in response to a letter in the local paper by one James Davies that didn’t get published, so a copy stayed in the files.

What exactly was the point of James Davies’ lament about the impossibility of owning property in a democracy? Does he want us to prove him wrong, get rid of democracy or rsign ourselves to living a fantasy?

Davies is wrong, of course. Owning property goes particularly well with democracy, but it’s also possible in a monarchy, empire or tyranny. In fact, owning property has become the norm in just about any kind of human society, regardless of what political or economic system happens to be in place. There’s hardly any property on the face of the earth that some-one or some group doesn’t claim to own. The deepest parts of the oceans and protions of the polar zones may be exceptions, but probably not for long.

But Davies is right, if you accept his definition of ownership as being the equivalent of total control. There’s nothing that humans control totally, except themselves, and that’s a rare exception. Democracy has nothing to do with it. Though, we like to think that in a democracy people exercise a little more self-control than in some other political systems.

Owning property is a convenient fiction, invented by humans to bring some order into how the resources we need to sustain our existence are used. Ownership is an assignment of exclusive use to members of our own species. It is not recognized nor honored by any other, and often ignored by our own. How often is recorded in our crime statistics.

Actually, if the Bible is to be believed, it was God who invented owning property when He told Adam and Eve, in effect, “those trees and everything else are yours, but this tree is mine. Eat its fruit and die!” So, Eve, with a little encouragement, committed the first petty theft and Adam received stolen property. In the beginning, the crime rate stood at 100%.

But I digress. Eve missed the point. Satan implied that God was merely being selfish in holding that one tree back. Actually, what God did was make a bargain, which Adam and Eve were free to refuse. He promised that they and all their descendants would enjoy sustenance and live forever if they reserved that one tree for His exclusive use. It was a bargain to free them from the laws of predation.

Predators lead a precarious existence: the likelihood of extinction increases with every increase in the population. When their source of food is exhausted, predators die. Setting aside the fruit of one tree, or a portion of any other food source, for that matter, guarantees a self-replenishing supply. It makes sense. If we take less than we want and leave something for the future, the future is assured. Call it resource husbandry, responsibility, or ownership. It’s a bargain that still seems too good to refuse.

God, being good, gave Adam and Eve another chance, and though Cain, the predator killed Abel, who practiced husbandry, the human species has managed to survive on a delicate balance between responsibility and controlled predation. Our predatory instincts have been redirected, either against members of our own species or to the extermination of all organisms that might prove harmful or of no human use. We been so successful in increasing the human population, that perhaps the predatory descendants of Cain provide a useful check.

We seem to have controlled the predatory isntinct just enough to escape extinction, and, we tell ourselves that predation is good, as long as it isn’t selfish. As if self-awareness and self-repservation were inherently evil. What is evil is wanton destruction, or, as Davies might put it, absolute control to dispose.

Satan lied. Eating the fruit of the tree of knowledge did not make humans more god-like. It introduced us to the concept of evil. Having failed to comply with the terms of the bargain, humans are left with the freedom of choice.

The choice, it seems clear, is between wanton destruction and responsible participation in the ongoing process of creation. But, which is which?

I have a hard time deciding whether to squash that roach before I throw it out the door. Or not. One thing is certain; I don’t own the roach ; it’s not my property and I am not responsible for its fate ….. Or am I?

Just a little wierd.

April 24, 2014
To the editor of the Brunswick News

Right, in the original U.S. Constitution, property rights trumped natural human rights. Had to — otherwise owning people couldn’t have been considered legal. The supremacy of property rights is the echo of our tradition of slavery. Indeed, that tradition persists to this day in the legal status of children as the property of their parents.

Which is why it is very difficult to rescue the children when they are being abused. Just as is happening with the Spit. After all, doesn’t all of nature exist to be subservient to man? Isn’t that what makes him exceptional, that he’s got the power of life and death over all the other creatures on earth?

*****

This seems to have been composed some time in the early eighties when I was still using a mechanical typewriter — economic development was the partner of urban renewal. Which, as we now know, had ulterior motives.
What does economic development mean? This isn’t a question about expectations or results, but definitions. What kind of activity is economic and what constitutes development?

In its broadest sense economic activity is what people do to manage the resources necessary to sustain life. Because humans, unlike frogs for example, are not self-sufficient, managing resources–their allocation and distribution–is essential.
Humans can choose to allocate and distribute resources in a variety of ways. Some are dependent on social organizatio; others are not. Sharing, barter, sale and even theft all involve resource allocation, though not all are classified as economic activities.
Economic activity has come to be rather strictly defined as production that is intended for trade or exchange, not for one’s own use. And, as the use of money as a medium of exchange has increased, economic analysis has focused almost entirely on those activities which can be calculated in monetary terms.
To develop is to undergo change in one of two ways. Development is either a process whereby something that wasn’t is brought into existence, or it involves a modification or transformation of something into something else.
When barter gives way to monetary exchange, that constitutes economic development. Women earning wages is an economic development, as is the change from familial self-sufficiency to trading in the marketplace. By definition a self-sufficient family farm is not an economic entity and managing a household is not an economic actitivy. Economic development can not be measured by the amount of resources available to sustain a particular population, but by the amount of trade and exchange.
However, that economic development is beneficial seems obvious. More people are living longer, so they must be living better. Trade and exchange in the marketplace is more efficient than trudging from house to house and the use of money makes it possible to overcome not only the limitations of place, but time as well. Resources not needed here and now can, in effect, be saved for future use by exchanging them for money. And the invention of credit has made it possible to use today what we don’t expect to need in the future.
But is that what is generally understood by those who promote and support economic development? Do they anticipate that the use of money as a medium of exchange will increase to affect an ever-incresing range of human activities, or do they merely look for the wages of paid labor to rise? Do they intend to increase production for exchange and trade, or do they anticipate an increase in the resources available for individual use? Do they expect economic development to increase self-sufficiency or expand the pool of people who depend on earning wages to survive?
Calls for economic development in Gainesville are usually associated with a perceived need to create jobs. Does that mean that more homemakers and asoorted volunteers deserve to earn wages for their work, or does it respond to a concern about people who aren’t doing anything and are considered unemployed? Is there an awareness that these people represent a potential pool of cheap labor which depresses the wages of those who are already being paid, or does it represent a commitment to making the entire population dependent on a wage?
The latter represents an economic development which has serious implications for the survival of free enterprise, while the former can be accomplished through economic growth. Since we already have an economy in which most production is for trade and exchange, any development might well be negative. What we should be concerned with is how to make our economy grow.
What must we do to promote economic growth? Gainesville is generally described as having a service economy, which some people seem reluctant to promote. This reluctance is based, in part, on the perception that the production of services is less desirable than the production of goods. A service economy is thought to be less stable because the taste for services seems to fluctuate more than the need for goods. But the disctinction between goods and services is largely artificial. A bushel of wheat is clearly a good, but what we really pay for is the time, energy and expertise expended by the farmer in its production. The alternative would be to plant and harvest our own, or gather a substitute. The farmer’s investment of time, energy and expertise is essentially no different from that of the nurse whose service is more direct. The only difference is that what the farmer produces is easier to measure and calculate than the value of a nurse’s care. Besides, agricultural production has a much longer history as an economic activity.
The distinction between goods and services is convenient from an economist’s point of view, but it tends to obscure that the components of production are the same in either case. Time and energy are essential, whether production is for trade or individual use; expertise is what produces a surplus for trade and exchange.
Initially, expertise is the result of simple repetition. But time, energy and expertise form a peculiar equation. As expertise increases, the amount of energy and time needed to produce the same amount decreases. If time and energy are held constant, expertise increases production. Expertise is what drives economic activity. Moreover, while time and energy are essentially limited, expertise has the potential of increasing almost indefinitely. Trading goods in the marketplace fosters the exchange of ideas as well, leading to an accumulation of knowledge by which expertise is enhanced.
But, while the production of services has only recently developed into an economic activity, the development of expertise, i.e. education, as an economic activity is hardly recognized. Because expertise produces a reduction in the expenditure of energy and time, its value is even more difficult to calculate. And then, the introduction of money into any transaction tends to meet resistance.
That is what Gainesville is up against. Almost from its beginning Gainesville was a marketplace for goods because of its strategic location. The exchange of ideas followed quite naturally and was formalized by the establishment of the University. But its function as a marketplace was never fully realized. Various goods-producing enterprises, from cotton to citrus, phosphate and naval stores, were tried and, having exhausted the resource base, failed. The exchange of goods and ideas in the marketplace was looked upon as little more than a hedge against total collapse. Even now, economic development is touted in terms of producing tangible goods and the future of Gainesville as a marketplace is generally ignored.
Part of the reason, no doubt, can be found in the fact that the function of a marketplace is to provide service. Though it works much like a factory, whose success depends on the rate and volume of flow and, in the long run, the quality of what is processed through, this similarity has perhaps not been recognized. Nor has it been recognized that, while size is important, an increase in size to accommodate storage of inventories that can’t be sold, is an indication that economic activity is being stalled. Of course, both a factory and a market can be converted into a warehousing enterprise, though such economic development usually signals economic decline.
Perhaps that explains why Gainesville has enjoyed little economic growth. Ignorance of its role as a marketplace has led to an emphasis on physical growth while the rate at which both goods and ideas are exchanged has slowed. Our students take to long to acquire expertise, and too many remain after the process is supposedly complete. And the commercialsector, which purports to trade in goods, behaves more like a purveyor to a cpative population, which it presumes not to have any alternatives.
The University of Florida, to its credit, has begun to reject the warehouse mentality. No longer will it concentrate on getting bigger; now the emphasis is on quality and efficiency. But already there’s a perception that this threatens economic development.
Indeed, in Florida economic development generally involves warehousing. South Florida has developed to store the elderly and North Florida seems dedicated to housing criminals. Since neither population is economically active, producing nothing for exchange or trade, it’s not surprising that Florida as a whole has experienced little economic growth.
Gainesville has an opportunity to be different, to expand its role as a marketplace of goods and ideas, rather than considering education as nothing more than the warehousing of the young. Gainesville is still at the cross-road. We can focus our energies on producing expertise to create economic growth, or we can fall in behind the rest of the state to develop warehousing alternatives as the young population shrinks.
Warehousing has lot of growth potential. The elderly population is growing and there’s a lot of waste material that has to be stored. That sort of development might be stable but it doesn’t generate economic growth. Expertise is the key to the future. Why would we choose to throw it away?