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[SELC Letterhead]

June 28, 2018
Via U.S. Mail and E-mail

Colonel Marvin Griffin, Commander
Attention: Sarah E. Wise
U.S. Army Corps of Engineers
Savannah District

100 West Oglethorpe Avenue
Savannah, Georgia 31401-3640

Re:      Sea Island Groin, Application Number SAS-2015-00742

Dear Colonel Griffin:

The Southern Environmental Law Center submits the following comment letter on behalf of One Hundred Miles, Altamaha Riverkeeper, and the Surfrider Foundation. This letter is meant to supplement the comments that we submitted on January 15, 2016; February 28, 2017; and May 23, 2018. Thank you for including these prior comments in the record; we ask that you include this last set in the record as well. In these final comments, we attach an expert report that further supports our opposition to Sea Island Acquisition, LLC’s (SIA) request for a U.S. Army Corps of Engineers (Corps) permit. The permit would, should it be granted, authorize SIA to do the following: (1) construct a T-head groin in front of eight undeveloped building lots; (2) pump between 1,315,000 to 2,500,000 cubic yards of sand from an offshore source; and (3) place that sand in front of a revetment stretching 2.8 miles along the main part of Sea Island.

As we have stated in each of our comments, should the Corps grant this permit, it would be opening itself up for a legal challenge. As it is now configured, the project would violate federal law.

In the attached expert report, Bret M. Webb, Ph.D., P.E., D.CE, describes the irreparable harm that the Sea Island project could cause to the Spit. According to Dr. Webb, the storm surges that accompanied Hurricanes Irma and Mathew robbed the Spit and its beach of a tremendous amount of sand. And in some places these waves overtopped the Spit and reached the river on its landward side. As we demonstrated in our state challenge to the proposed project, the Spit was vulnerable even before the hurricanes made landfall. The proposed groin would exacerbate that problem. The groin would sit immediately updrift of where the Spit is the weakest. Any downdrift erosion would make it that much easier for the next set of storm surges to break the Spit in two.

Dr. Webb also explains in his report that SIA did not explore all reasonable alternatives. In particular, SIA did not perform a meaningful analysis of any alternative that would involve beach nourishment on the Spit south of the proposed project area. According to Dr. Webb, in light of the massive beach nourishment project SIA has proposed for the main part of the island, SIA could extend the proposed beach nourishment down the Spit. Not only would this alternative be logistically possible, but it also would be reasonable in cost.

We ask that the Corps take Dr. Webb’s report into consideration when it makes its final permit decision regarding the proposed project. If it does, the Corps must conclude that the proposed project would not meet applicable federal requirements.

Thank you for the opportunity to comment on the proposed project. If you have any questions concerning these comments, please feel free to contact me by email at or by telephone at 404-521-9900.


William W. Sapp

Senior Attorney


cc: Megan Desrosiers, One Hundred Miles
Jen Hilburn, Altamaha Riverkeeper
Staley Prom, Surfrider Foundation
Steve Combs, Surfrider Foundation



  • Surfrider Foundation, on behalf of its Georgia Chapter, and the Altamaha Riverkeeper, filed an administrative appeal challenging the Georgia Shore Protection Committee’s decision to permit a permanent 350-foot long rock groin (with a 120-foot T-shaped head) on Sea Island, in southeast Georgia. The Committee’s permit would also allow applicant Sea Island Acquisition, LLC to engage in dredge and fill and other shoreline development along the pristine Sea Island Spit, including placement of a 200 square foot layer of rock on the landward end of the groin.
  • Surfrider Foundation and Altamaha Riverkeeper allege that this new project would exacerbate erosion of this already highly erosive coastal barrier island, with devastating impacts.
  • Petitioners are generously represented by attorney Steve Caley at GreenLaw. GreenLaw is a non-profit organization based in Atlanta, Georgia, which takes legal action in defense of our environment.

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