It’s time for the Army Corps of Engineers to bring some sanity to the examination of building a terminal groin at Rich Inlet on Figure Eight Island. It’s received an overwhelming stack of detailed comments from numerous federal and state agencies and community organizations, and it’s clear that the current draft Environmental Impact Statement is beyond hope of ever being viewed as having any credibility.
The draft document prepared by the applicant’s hand-picked and long-time terminal groin consultants is simply too biased in its construction to ever be considered an impartial and fair review of possible project alternatives for the island.
We have to ask why an Environmental Impact Statement is being prepared. A complete permit application has never been submitted. Normally for projects proposed by private parties with private funds, the National Environmental Policy Act (NEPA) review would only begin after a complete permit application has been submitted and a determination that an Environmental Impact Statement is necessary because the project has the potential to cause significant environmental impacts.
In this case, no complete application has ever been submitted to either the federal or state agencies. In fact, because the applicant has not secured the necessary private property rights to build its preferred alternative a complete application is not even possible under both federal and state permit application rules. Until a complete permit application is submitted and these property rights are secured, it is a colossal waste of everyone’s time and resources to evaluate the terminal groin alternative.
There’s even a question of whether any property is currently imminently threatened, and therefore whether state law allows consideration of a terminal groin. The inlet channel is shifting naturally, and the beach in front of houses that were imminently threatened is currently building back. The beach is accreting in front of the properties that are currently sand-bagged, and they are no longer within 20 feet of an erosion scarp. None of these properties can be deemed “imminently threatened.”
The project has not been adequately defined to even trigger a NEPA review. The project’s scope, purpose and need have been drastically changed without any public notice in the Federal Register. In this case, the applicant has been on a fishing expedition regarding project alternatives, and it has identified and defined these alternatives with no involvement by any outside agency or the public in the past two years. There has been no ongoing role in the development of the study by the Corps appointed “Project Delivery Team” that has not met for two years. This has allowed the applicant to define the project alternatives that are not its preferred alternative. They have been defined in a manner that makes them appear less desirable.
The draft study cannot be salvaged to make it a useful document. While it might be possible to correct inaccuracies, omissions, content and the disorganized state of the document, making the study a truly independent and unbiased analysis of alternatives will be impossible. It is fundamentally flawed because it is entirely constructed around justifying the terminal groin alternative.
One of the consultants that helped prepared the study recently made a presentation to the Figure Eight Homeowners Association annual meeting. His handouts further document that the consultant is totally sold on the need for a terminal groin, and the one-sided presentation to the homeowners clearly was designed to sell that alternative instead of giving a fair and balanced analysis of possible alternatives. Everyone is entitled to his or her own opinions, but just like the Corps would not hire the Coastal Federation to prepare this study, it should not be relying on a terminal groin advocate to do it either.
It’s time to call a time-out, and halt the study process. If the Figure Eight Homeowners Association wants to pursue a terminal groin, it should be required to submit a complete and acceptable permit application to the federal and state agencies. This will require proof that it has the property rights acquired from numerous individuals to build the structure on their land. Then a proper scoping notice can be published that fully discloses what’s proposed, independent contractors can be hired to prepare the report, and the process can start again if necessary.
Trying to fix the current process simply won’t work. Let’s hope the Corps of Engineers agrees, and we can all get back to work that’s much more beneficial and productive for our coast.