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# 

# 

## 

## 

## PROPOSED EXCHANGE OF LAND 

## ON

**CUMBERLAND ISLAND NATIONAL SEASHORE**

#### BETWEEN 

## GREYFIELD LTD.

#### AND

#### THE NATIONAL PARK SERVICE

# 

# 

# 

# November 2003

### This Draft Environmental Assessment evaluates alternatives and associated environmental impacts arising out of the proposed exchange of land on Cumberland Island National Seashore between Greyfield Ltd. and the National Park Service.

### 

### **[Comments and Availability]{.underline}**

### 

### Comments on this Draft Environmental Assessment ("EA") for the Proposed Exchange of Land on Cumberland Island National Seashore between Greyfield Ltd. and the National Park Service must be delivered or postmarked no later than **January 5, 2004**. 

### 

### If you wish to comment on this environmental assessment, you may mail comments to the name and address below. Our practice is to make comments, including names and home addresses, available for public review during regular business hours. Individual respondents may request that that we withhold their names and/or home address from the record, which we will honor to the extent allowable by law. **If you wish us to withhold your name and/or address, you must state this prominently at the beginning of your comment.** We will make all submissions from organizations or businesses, and from individuals identifying themselves as representatives or officials of organizations or businesses, available for public inspection in their entirety. [Comments will not receive individualized, direct response.]{.underline}

### 

### Address all comments to:

Superintendent

Cumberland Island National Seashore

P.O. Box 806

St. Marys, Georgia 31558

FAX: 912-882-5688

Comments may be submitted by e-mail to: CUIS_Superintendent@nps.gov

The Draft EA is available for public review at the following locations:

Camden County Public Library, 1410 Georgia Highway 40E, Kingsland,
Georgia

St. Marys Public Library, 101 Herb Bauer Dr., St. Marys, Georgia

Fernandina Public Library, 25 N. 4^th^ Street, Fernandina Beach, Florida

Sea Camp Ranger Station, Cumberland Island, Georgia

Cumberland Island National Seashore Museum, 129 Osborne St., St. Marys,
Georgia

The Draft EA can also be viewed and downloaded at
[www.nps.gov/cuis](http://www.nps.gov/cuis).

**[Important Notice]{.underline}.** Reviewers must provide the National
Park Service (NPS) with their comments on the draft EA during the review
period. This will allow NPS to analyze and respond to comments at one
time and to use information acquired in the preparation of a Final EA,
thus avoiding undue delay in the decision-making process. Reviewers have
an obligation to structure their participation in National Environmental
Policy Act process so that it is meaningful and alerts the agency to the
reviewer's position and contentions. Environmental objections that could
have been raised at the draft stage may be considered waived if not
raised until completion of the Final EA. Comments on the Draft EA should
be specific and should address the adequacy of the analysis and the
merits of the alternatives discussed. 40 CFR 1503.3.

## 

## SUMMARY

### Cumberland Island National Seashore proposes to exchange a 32.14-acre upland tract located in the southern portion of the island for a 52.2-acre tract (21 acres of upland) located near the center of the island. The tract to be received by the National Park Service (NPS Tract No. 02-212) is owned by Greyfield Ltd. and lies within an area designated by Congress as potential wilderness. The 32.14-acre exchange tract (NPS Tract No. 02-213) includes the Margaret Sprague life estate (15.1 acres, with dwelling) and is located immediately to the north of, and contiguous to, a private tract of 206.13 acres owned by Greyfield Land Corp. 

### 

### The terms of the exchange are set forth in a contract by and among Greyfield Ltd., The Nature Conservancy, and the National Park Service. The parties agreed to the exchange in order to resolve a dispute that arose during the sale of the former Greyfield North tract to The Nature Conservancy for eventual conveyance to the National Park Service. As a result of the exchange agreement, the parties completed the final phases of the Greyfield North Transaction in 1999, with the understanding that the land exchange was to be completed by July 1, 2004. 

The preferred alternative would have no impacts on geology and
topography, air quality, water resources, historic structures, cultural
landscapes, ethnographic resources, lightscape management, prime and
unique farmland, the socioeconomic environment, or environmental
justice. The preferred alternative would not adversely affect any
special status species, including federally-listed threatened or
endangered species. Impacts to soils, vegetation, groundwater and
wildlife on the exchange tract could be affected if the tract were to be
developed by the new owner. Impacts would be minor to moderate,
long-term, and adverse. Impacts to archeological resources on the
exchange tract could be major, long-term and adverse, but these
potential impacts would be mitigated by implementation of a mitigation
plan. The mitigation plan would include data recovery and curation prior
to completion of the exchange. On the wilderness tract, soils,
vegetation, and wildlife would receive permanent protection for the
first time, resulting in long-term and beneficial impacts. Wilderness
resources and values at the seashore would be affected in ways that were
minor, long-term and beneficial. Soundscapes in the vicinity of the
exchange tract could experience minor to moderate, adverse, impacts over
the long term. For many visitors, impacts to visitor use and enjoyment
as a result of any new development on the exchange tract would be
adverse, minor to moderate in intensity, and long-term. Impacts to park
operations would be adverse, minor in intensity and long-term.

## TABLE OF CONTENTS

##### 1.0 PURPOSE AND NEED FOR ACTION

1.  Introduction
    ....................................................................................1

2.  Purpose of the Action
    ..........................................................................1

### 

### Need for Action ................................................................................5 

3.  The Proposed Action
    ..........................................................................5

1.5 Required Management of the National Seashore
.........................................5

1.5.1 Legislative and Executive Mandates
............................................5

1.5.2 Contractual Mandates
.............................................................8

1.5.3 Administrative Mandates
.........................................................9

1.6 Relationship of the Proposed Action to Previous Planning Efforts
...................10

####### 2.0 ISSUES AND IMPACT TOPICS

2.1 Impact topics Analyzed in this Environmental Assessment
............................11

2.2 Impact Topics Dismissed from Further Analysis
........................................13

## ALTERNATIVES 

3.1 Alternative A -- No Action (do not exchange parcels)
...................................17

### 3.2 Alternative B (Preferred Alternative) -- Swap the Exchange Tract for the

###  Wilderness Tract ..............................................................................17

3.3 Alternatives Considered but Dismissed from Further Analysis
........................18

3.4 Mitigation
......................................................................................18

# 3.5 Environmentally Preferred Alternative .....................................................23

**4.0 AFFECTED ENVIRONMENT**

4.1 Overview
.......................................................................................24

4.2 Natural Environment
........................................................................24

4.3 Cultural
Environment........................................................................27

4.4 Socioeconomic
Environment...............................................................29

4.5 Visitor Activities
.............................................................................30

##### 5.0 ENVIRONMENTAL CONSEQUENCES 

5.1
Introduction....................................................................................31

5.2 Methodology
...................................................................................31

5.2.1 Context
.................................................................................31

5.2.2 Duration
................................................................................31

5.2.3 Impact Intensity
.......................................................................32

> 5.2.3(a) Impact Intensity for Natural Resources, Visitor Use and
> Enjoyment, Socioeconomic Environment, and Seashore
> Operations.................................32
>
> 5.2.4 Impact Type
> ...........................................................................32
>
> 5.2.5 Direct versus Indirect Impacts
> ......................................................32

#### 

5.3 Considerations Specific to Archeological
Resources....................................32

5.4 Cumulative
Impacts...........................................................................34

5.5 Impairment of National Seashore Resources or
Values.................................34

5.6 Topics Dismissed from Further Analysis
.................................................35

5.7 Analysis of Impact Topics
..................................................................35

> 5.7.1 SOILS
> ..............................................................................35

### 

### 5.7.2 WATER QUALITY ..............................................................37

### 

> 5.7.3 VEGETATION AND WILDLIFE
> .............................................38
>
> 5.7.4 ARCHEOLOGICAL RESOURCES
> ...........................................40
>
> [Section 106 Statement]{.underline}
> ..................................................................41
>
> 5.7.5 WILDERNESS
> ..................................................................42
>
> 5.7.6 SOUNDSCAPE
> MANAGEMENT............................................43
>
> 5.7.7 VISITOR USE AND
> ENJOYMENT..........................................44
>
> 5.7.8 SEASHORE
> OPERATIONS...................................................45

**6.0 CONSULTATION AND
COORDINATION**.........................................46

## Selected References.............................................................................48

**[Figure]{.underline}**

Figure 1: Properties to be
exchanged............................................................2

**[Table]{.underline}**

Table 1: Comparative Summary of Environmental Impacts -- No Action

and Preferred
Alternatives.......................................................................
20

##### 1.0 PURPOSE AND NEED FOR ACTION

**1.1 Introduction**

### Cumberland Island National Seashore (CUIS or the Seashore) was established by Congress as a unit of the National Park System in the Act of October 23, 1972 (Public Law 92-536, codified at 16 U.S.C. 459i *et seq*. (the "Act")). The purpose of the park, as stated in Section 1 of the Act, is "to provide for public outdoor recreation use and enjoyment of certain significant shoreline lands and waters of the United States and to preserve related scenic, scientific, and historical values." Section 6 of the Act sets forth additional preservation mandates by stating that "the seashore shall be administered, protected and developed in accordance with the provisions of the Act of August 25, 1916 (39 Stat. 535; 16 U.S.C. 1, 2-4)" which established the National Park Service ("National Park Service" or "NPS"). On September 8, 1982, much of the northern half of Cumberland Island was designated as wilderness or potential wilderness to be managed under the National Wilderness Preservation System (Public Law 97-250, 16 U.S.C. 1131 *et seq*.).

### 

### At present, the federal government owns most of the upland areas within the Seashore boundary. However, certain landowners sold their property to the United States subject to specified retained rights of use and occupancy. In addition, some tracts of private property remain. This environmental assessment analyzes impacts to the environment arising out of a proposed exchange of federal land at the Seashore for a tract of private property near the center of the island that is located in an area designated as potential wilderness. 

### 

### **1.2 Purpose of the Action**

### 

### For many years the largest private tract on Cumberland Island was the "Greyfield North" tract, a 1,179.54-acre tract in the center of the island owned by Greyfield Ltd. ("Greyfield"). In 1997, The Nature Conservancy obtained an option to acquire all but a small portion of this tract from Greyfield, in five phases. [See]{.underline} Option for Purchase of Real Property, dated March 3, 1997 (the "Option Agreement"). Greyfield expressly retained for itself that portion of Greyfield North known as the Serendipity Compound. 

From 1997 through 1999, The Nature Conservancy acquired a total of
1,053.10 acres of the Greyfield North tract in five phases, pursuant to
the Option Agreement. Of this acreage, 842.30 acres was ultimately
conveyed to the National Park Service.

Prior to implementation of Phases 4 and 5 of the Option Agreement, the
parties renegotiated the terms of the agreement to address a
misunderstanding about the amount of property comprising the Serendipity
Compound. [See]{.underline} Substituted Agreement for Option for
Purchase of Real Property, dated June 30, 1999 (the "Substituted
Agreement"). Under the terms of the Substituted Agreement, it was agreed
that The Nature Conservancy would receive approximately 210.8 acres of
the remaining Greyfield North lands, with Greyfield to retain
approximately 126.5 acres (65 acres of upland) at the Serendipity
Compound. However, the Substituted Agreement also provided a framework
whereby, upon the satisfaction of various terms and conditions,
Greyfield would convey 52.2 of these acres (21 acres of upland) to the
National Park Service in exchange for a 32.14-acre tract farther south
on the island. The 52.2-acre tract is located in Congressionally
designated potential wilderness. It was further agreed that if for some
reason the exchange were not completed, The Nature Conservancy would
have an option to acquire the Wilderness Tract from Greyfield.

The land exchange was a precondition of Greyfield Ltd. agreeing to
proceed with Phases 4 and 5 of the transaction. When Phases 4 and 5
closed in 1999, The Nature Conservancy received 210.80 acres of land to
for eventual conveyance to the National Park Service, as noted above. As
of the date of this assessment, approximately 337.3 acres of Greyfield
North remains in private ownership, split among The Nature Conservancy
(210.8 acres) and Greyfield Ltd. (126.5 acres, including the 52.2-acre
tract proposed for exchange).

The purpose of the proposed action is to acquire and protect
approximately 52.2 acres of land (21 acres of upland) within the
Congressionally designated potential wilderness area at Cumberland
Island National Seashore. The 52.2-acre tract (NPS Tract No. 02-212) is
presently owned by Greyfield and is part of the Serendipity Compound. An
appraisal of this tract completed in 2000 projected that the tract could
reasonably be subdivided into 11 residential lots if developed (Kirkland
& Co. 2000: 33).

The National Park Service proposes to acquire the Greyfield tract by
exchange. The exchange property (NPS Tract No. 02-213) is a 32.14-acre
upland tract located north of and contiguous to a 206.13-acre tract
owned by Greyfield Land Corp. (See Figure 1.0) A portion of the exchange
property (15.1 acres) is subject to a retained life estate held by
Margaret Sprague. The Sprague life estate contains a single-story house
overlooking the salt marsh on the sound side of the island. The life
estate expires on the death of Margaret Sprague, her spouse, or last
surviving child, whichever occurs last. The 2000 appraisal cited above
projected that the exchange property could be subdivided into 15
residential lots, in addition to the existing residence (Kirkland & Co.
2000: 43). Six of the lots could only be developed after expiration of
the Sprague life estate.

> **Figure 1:**
>
> ![](media/image2.png){width="5.8700787401574805in"
> height="4.027165354330709in"}![](media/image3.png){width="5.881889763779528in"
> height="4.129133858267717in"}Properties to be exchanged

**1.3 Need for Action**

### 

The proposed exchange is needed so that the National Park Service may
acquire a strategic tract located at the southern boundary of the
Seashore's potential wilderness area. The property immediately adjacent
to and south of this tract (i.e., the Serendipity Compound) is already
developed with a set of several wood structures. Both the Serendipity
Compound and the potential wilderness tract are owned by the same owner.
Failure to acquire the potential wilderness tract could result in the
tract's being developed, thereby rendering it unsuitable for eventual
wilderness designation. No funds are available to acquire the potential
wilderness tract from the current owner and none are likely to be made
available. The National Park Service is contractually obligated to
pursue the exchange in good faith and the local Congressional
representative favors the exchange.

Under the provisions of the National Environmental Policy Act (NEPA),
the National Park Service must consider alternatives to the proposed
exchange and assess the possible impacts of these alternatives on the
human environment. As explained above, the National Park Service is
contractually bound to make a good faith effort to complete the exchange
on the terms set forth in the Substituted Agreement. Therefore, this

### *Draft Environmental Assessment* presents only two alternatives, namely, the proposed action (complete the proposed land exchange), and the no-action alternative (do not pursue the exchange). Consideration of the no-action alternative is specifically required by NEPA.

### 

### **1.4 The Proposed Action**

The National Park Service proposes to exchange a 32.14-acre tract of
federal land (the "Exchange Tract") for a 52.2-acre tract owned by
Greyfield Ltd. (the "Wilderness Tract"). Under the terms of the
Substituted Agreement, the National Park Service "covenants to use its
best efforts to effect the Land Swap as expeditiously as possible.\" The
deadline for completing the exchange is July 1, 2004.

A detailed discussion of the proposed action and the no-action
alternative is provided in section 3 of this assessment. Possible
impacts associated with each alternative are analyzed in section 5.

**1.5 Required Management of the National Seashore**

This document has been developed in a manner consistent with applicable
laws, regulations, and other legal mandates governing management of
Cumberland Island National Seashore. A review of these mandates and
related commitments is provided in this section.

**1.5.1 Legislative and Executive Mandates.** Legislative mandates and
special commitments include those measures that apply to the entire
National Park System, plus Seashore-specific requirements. The intent of
all the mandates and commitments is to establish sustainable
conservation and to avoid impairment of NPS lands. As a result, visitor
use can occur only to the extent that it does not adversely affect the
Seashore and its natural and cultural resources.

**National Park Service** **Organic Act (16 U.S.C. 1, 2-4):** The
National Park Service is established and its general obligations set
forth in its Organic Act and the General Authorities Act (16 U.S.C.
1a-8). These acts direct the agency to conserve the scenery, the natural
and historic objects, and the wild life, and to provide for the
enjoyment of those resources in such a manner as to leave them
unimpaired for future generations.

**Cumberland Island National Seashore Enabling Legislation:** The
enabling legislation for Cumberland Island National Seashore (16 U.S.C.
459i *et seq*.) obligates the National Park Service to manage the area
in a manner consistent with the Organic Act. The enabling legislation
specifically provides that, apart from limited recreational development,
the "seashore shall be permanently preserved in its primitive state, and
no development of the project or plan for the convenience of visitors
shall be undertaken which would be incompatible with the preservation of
the unique flora and fauna or the physiographic conditions not (sic)
prevailing."

**National Environmental Policy Act (NEPA)(42 U.S.C. 4321 *et seq*.):**
NEPA is the Nation's basic charter for environmental protection. Among
other actions, it calls for an examination of the impacts of a proposed
major federal action on the components of affected ecosystems. Various
Seashore and NPS policies provide general direction for the protection
of natural and cultural resources, including the *General Management
Plan* (1984), the *Resource Management Plan* (1994), NPS *Management
Policies* (2001), Director's Order 12 ("Conservation Planning,
Environmental Impact Analysis, and Decision Making"), and NPS-77
(*Natural Resources Management*).

Various agencies will be contacted and consulted as part of this
planning and environmental analysis effort. Appropriate federal, tribal,
state, and local agencies will be contacted for input and review
consistent with legislative and executive requirements.

**Clean Air Act (42 U.S.C. 7401 *et seq*.):** Cumberland Island National
Seashore is designated a Class II area under the Clean Air Act, as
amended. Section 118 of the Clean Air Act requires all federal
facilities to comply with existing federal, state, and local air
pollution control laws and regulations.

**Endangered Species Act (16 U.S.C. 1531 *et seq*.):** Section 7 of the
Endangered Species Act requires all federal agencies to consult with the
U.S. Fish and Wildlife Service to ensure that any act authorized,
funded, or carried out by the agency does not jeopardize the continued
existence of any federally-listed threatened or endangered species, or
any critical habitats of such species. Consultation with the U.S. Fish
and Wildlife Service is required if any impacts to threatened and
endangered species are anticipated.

**National Historic Preservation Act (NHPA) (16 U.S.C. 470 *et seq*.):**
This Act sets forth the policy of Congress for preserving "the
historical and cultural foundations of the Nation" and preserving
irreplaceable examples important to our national heritage to maintain
"cultural, educational, aesthetic, inspirational, economic, and energy
benefits." The NHPA also established the National Register of Historic
Places composed of "districts, sites, buildings, structures, and objects
significant in American history, architecture, archeology, engineering,
and culture." Section 106 of the NHPA requires that federal agencies
take into account the effects of their actions on properties eligible
for or included in the National Register of Historic Places, and permit
the Advisory Council on historic preservation an opportunity to review
such actions. Federal agencies consult as appropriate with state
historic preservation officers, tribal historic preservation officers or
representatives, and other interested parties in fulfilling section 106
requirements. Section 106 further requires federal agencies to propose
and evaluate alternatives to undertakings that would adversely affect
historic properties, or to adequately mitigate adverse effects if
avoidance cannot be reasonably achieved. Section 110 of the NHPA
requires federal agencies, in consultation with the state historic
preservation officer, to locate, nominate, and inventory all properties
that appear to qualify for the National Register of Historic Places. It
also requires federal agencies to manage and maintain historic
properties under their jurisdiction in a manner that considers the
preservation of historic, archeological, architectural, and cultural
values.

**Executive Order 11593 \"Protection and Enhancement of the Cultural
Environment,\" May 31, 1971:** This order instructs all federal agencies
to provide national leadership in historic preservation and to assure
the preservation of cultural properties in federal ownership. The order
directs all federal agencies to locate, inventory, and nominate all
sites, buildings, districts, and objects under their jurisdiction or
control that appear to qualify for listing on the NRHP.

**Archaeological and Historical Preservation Act (AHPA) (16 USC 469 --
469c-2):** This Act amends the 1960 Salvage Act, and provides for the
preservation of significant scientific, prehistoric, historic, or
archeological data that might be lost or destroyed as a result of any
alteration of the terrain caused by a result of any federal project or
program.

**American Indian Religious Freedom Act (AIRFA) (42 USC 1996 --
1996a):** This Act establishes that the policy of the United States is
to \"protect and preserve for American Indians their inherent right of
freedom to believe, express and exercise the traditional religions of
the American Indian, Eskimo, Aleut and Native Hawaiians, including but
not limited to site access, use and possession of sacred objects, and
the freedom to worship through ceremonial and traditional rites.\"

**Archaeological Resources Protection Act (ARPA) (16 USC 470aa --
470mm):** defines archeological resources as any material remains of
past human life or activities that are of archeological interest and are
at least 100 years old. This act provides for the protection of
archeological resources located on public and Indian lands, and
establishes criteria for issuing permits for any excavation or removal.
Per this act, information concerning the nature and location of
archeological resources may be exempt from the Freedom of Information
Act.

**Executive Order 13007, "Indian Sacred Sites", May 24, 1996:** This
order states that those with statutory or administrative
responsibilities for the management of federal lands shall accommodate
ceremonial use of and access to Indian sacred sites by Indian religious
practitioners, as well as avoid affecting the physical integrity of the
sacred site. Reasonable notice must be provided of any proposed actions
or land management policies that could restrict ceremonial use of or
access to, or affect the physical integrity of sacred sites. Those with
statutory or administrative responsibilities for the management of
federal lands will report the following to the President, through the
Assistant to the President for Domestic Policy: 1. Any changes to
accommodate ceremonial use of and access to sacred sites; 2. any changes
to avoid affecting the physical integrity of Indian sacred sites; and 3.
procedures proposed to facilitate consultation with Indian tribes and
religious leaders as well as to resolve conflicts relating to agency
action on federal lands.

**Native American Graves Protection and Repatriation Act (NAGPRA) (25
USC 3001 et seq.):** This Act governs the disposition of human remains,
funerary objects, sacred objects, or objects of cultural patrimony
excavated from Federal or tribal lands after November 16, 1990. Such
objects may be intentionally removed from Federal land only after (a)
consultation with the appropriate Indian tribe, and (b) preparation and
implementation of a written plan of action for handling objects covered
by the Act. The Act and associated regulations set forth a process for
determining the individual(s) or tribe(s) that shall be entitled to
custody of covered objects after removal from Federal land.

**Wilderness Act (16 USC 1131 et seq.) and Cumberland Island Wilderness
Act:** NPS wilderness management policies are based on statutory
provisions of the 1916 Organic Act, the 1964 Wilderness Act, and
legislation establishing individual units of the National Park System. A
unit of the National Wilderness Preservation System is any site so
designated by Congress and legally protected as wilderness in
perpetuity. NPS' *Management Policies* (2001) require the administration
of NPS-managed wilderness areas for the use and enjoyment of the
American people in such a manner as will leave them unimpaired for
future use and enjoyment as wilderness. Among other mandates are the
protection of wilderness areas and the preservation of their wilderness
character.

Public Law 97-250 (the Act of September 8, 1982) established the
Cumberland Island Wilderness. The law designated 8,840 acres as
wilderness and 11,718 acres as potential wilderness. When all uses
prohibited by the Wilderness Act on the 11,718 acres of potential
wilderness have ceased, the Secretary may designate those lands as
wilderness. "Subject to valid existing rights, the wilderness areas
shall be administered by the Secretary of the Interior in accordance
with the applicable provisions of the Wilderness Act governing areas
designated by that Act as wilderness areas..."

**1.5.2 Contractual Mandates.** Under both the Seashore's enabling
legislation and the Cumberland Island Wilderness Act, the National Park
Service is required to honor valid, pre-existing legal rights of island
residents. For purposes of this environmental assessment, the relevant
legal right to be honored is the life estate of Margaret Sprague, which
comprises 15.1 acres of the 32.14-acre Exchange Tract. Ms. Sprague sold
her property for inclusion in the Seashore subject to the following
specific retained rights:

-   Unrestricted vehicular travel on the Main Road.

-   Use of a dock at an acceptable site on Cumberland Island, including
    the right to use the United States' dock to unload supplies that
    cannot be unloaded at this alternate site.

-   Access to the United States' airfield, if built.

-   Road access between the estate property, the airfield, and the dock.

These rights expire on the death of Sprague, her spouse, or last
surviving child, whichever occurs last.

**1.5.3** **Administrative Mandates:**

**CUIS Land Protection Plan.** The seashore's Land Protection Plan
describes the minimum interest in land that should be acquired with
respect to privately owned tracts in order to meet legislative
objectives and establishes priorities for acquiring individual tracts.
The most recent version of the seashore's Land Protection Plan (1994)
states that full fee acquisition is the recommended action for most
tracts to ensure long term permanent protection of resources and to
"manage the wilderness as defined in the enabling legislation." The plan
indicates that the Wilderness Tract is part of a larger tract (the
Greyfield North tract) included within Priority Group I for full fee
acquisition. The Land Protection Plan does not specifically contemplate
disposing of the Exchange Tract in order to acquire the Wilderness
tract.

**NPS Management Policies.** NPS management policies prescribe the
manner in which the National Park Service will strive to meet its
obligations under the Organic Act and the General Authorities Act,
including the requirement that resources in its care be maintained
unimpaired for future generations. The policies recognize, however, that
not all impacts constitute impairment. The policies specifically state
that "\[t\]he laws ... give the Service management discretion to allow
impacts to park resources and values when necessary and appropriate to
fulfill the purposes of a park, so long as the impact does not
constitute impairment of the affected resources and values" (*Management
Policies* section 1.4.3). Impairment is defined as an impact that would
harm the integrity of park resources or values, or opportunities for
enjoyment of these resources or values, in the professional judgment of
the responsible NPS manager.

The NPS *Management Policies* provide that the National Park Service is
to manage potential wilderness as if it were designated wilderness to
the extent that existing non-conforming conditions allow (*Management
Policies* 6.3.1).

NPS policy authorizes land exchanges in accordance with the conditions
and procedures set forth in Section 11 of the NPS *Land Acquisition
Procedures Manual*. The procedures in the *Manual* are applicable to the
exchange of any land or interest in land administered by NPS, unless
legislation specifically prohibits acquisition by exchange. No such
prohibition exists in the case of Cumberland Island National Seashore.
Conditions placed on the exchange of lands are as follows: (a) the lands
to be exchanged must be in the same State, and (b) the lands must be of
approximately equal value. Both conditions are satisfied by the proposed
exchange.

**NPS Land Acquisition Procedures Manual.** The NPS Land Acquisition
Procedures Manual requires that a cultural resource survey be undertaken
by a qualified person in all exchanges. Section 11.4.3 of the Manual
provides that, "\[i\]n general, no lands containing sites eligible for
the National Register of Historic Places may be disposed of." If the
survey reveals cultural remains, the site must be mitigated or the
exchange dropped. Mitigation, the minimizing of resource damage, can
range from collecting found objects to full-scale excavations.

**1.6 Relationship of the Proposed Action to Previous Planning Efforts**

Executing the proposed land exchange is consistent, in part, with the
objectives of the Cumberland Island National Seashore General Management
Plan (1984), as well as the Seashore's Statement for Management (1990),
Natural Resource Management Plan (1994), Land Protection Plan (1994),
and Strategic Plan 2001---2005. Among these objectives are the
following:

-   To perpetuate forested environments in ways that promote natural
    ecological succession and minimize adverse impacts of man's
    activities.

-   To preserve and manage lands in wilderness and potential wilderness
    in such a way as to protect and enhance wilderness values.

The proposed action meets these objectives in the case of the Wilderness
Tract. As for the Exchange Tract, the foregoing planning documents are
generally silent with respect to land exchanges and do not encourage
actions that would make possible additional private development on the
island.

####### 2.0 ISSUES AND IMPACT TOPICS

Issues and concerns affecting this proposal were identified from past
NPS planning efforts, past communications from environmental groups,
historic preservation groups, and input from other state and federal
agencies. Major issues include conformance of the proposal with the
requirements of the Cumberland Island Wilderness Act; possible
introduction or dispersal of exotic species; and potential impacts of
the proposed action on recreational values, cultural resources, and
Seashore operations.

Specific impact topics were developed to focus discussion of
environmental consequences, and to allow comparison of the impacts of
each alternative. These impact topics were identified based on federal
laws, regulations, and Executive Orders, as well as NPS *Management
Policies* (2001) and NPS knowledge of limited or easily affected
resources. A brief rationale for the selection of each impact topic is
given below, together with the rationale for dismissing specific topics
from further consideration.

**2.1 Impact topics Analyzed in this Environmental Assessment**

**Soils.** According to the National Park Service's *Management
Policies* (2001), the National Park Service will strive to understand
and preserve the soil resources of park units and to prevent, to the
extent possible, the unnatural erosion, physical removal, or
contamination of the soil or its contamination of other resources.
Completion of the exchange could result in long-term protection of soils
in the Wilderness Tract. In contrast, adverse impacts could occur to
soils of the Exchange Tract if that tract were to be developed after the
exchange. Therefore, soils will be addressed as an impact topic in this
environmental assessment.

**Vegetation and Wildlife.** The National Environmental Policy Act (42
U.S.C. 4321 *et seq*.) calls for an examination of the impacts a
proposed action may have on all components of affected ecosystems.
National Park Service policy is to maintain all of the components and
processes of naturally occurring ecosystems, including the natural
abundance, diversity, and ecological integrity of plants and animals
(National Park Service *Management Policies* 2001).

Over the past three hundred years, many of the natural communities on
Cumberland Island have been extensively disturbed by human activities.
For example, in the years leading up to the Civil War, a significant
amount of forest cover on the island was cleared for cultivation of sea
island cotton and other crops. Nevertheless, the island's natural
communities began to recover in ensuing years and they continue to
undergo the processes of succession, albeit influenced by such human
factors as the introduction of feral animals and the full suppression of
fire. The island is now characterized by maturing forests and abundant
wildlife.

It is possible that the land exchange could cause impacts to vegetation
and a loss of native wildlife habitat on the Exchange Tract if the
property were to be developed after the exchange. Therefore, vegetation
and wildlife will be addressed as an impact topic in this environmental
assessment.

**Water Resources (Water Quality, Wetlands, and Floodplains).** National
Park Service policies require protection of water quality consistent
with the mandates of the Clean Water Act, including the provisions of
Section 404 of the Act governing wetlands. Executive Order 11990,
*Protection of Wetlands*, requires federal agencies to avoid, where
possible, adversely impacting wetlands. Similarly, Executive Order
11988, *Floodplain Management*, requires all federal agencies to avoid
construction within the 100-year floodplain unless no other practicable
alternatives exist. Proposed actions that have the potential to have an
adverse affect on wetlands and certain construction activities in the
100-year floodplain must be addressed in a Statement of Findings.

The proposed action, which involves the exchange of two upland tracts,
would have no effect on the Cumberland River, Cumberland Sound, any
tributaries or related bodies of water, or the Seashore's surface water
supply. Because of the island's flat topography, any sediment runoff
from construction on the Exchange Tract would be negligible. There would
be no noticeable impact on floodplains or any tidal or freshwater
wetlands, so a Statement of Findings will not be prepared. However,
groundwater resources could be affected by any subsequent development of
the Exchange Tract. Therefore, water resources will be addressed as an
impact topic in this environmental assessment.

**Archeological Resources.** An archeological survey of the Exchange
Tract identified three archeological sites that, collectively, are
potentially eligible for listing in the National Register of Historic
Places. Any development of the Exchange Tract could result in the
disturbance or destruction of these sites. Therefore, archeological
resources will be included as an impact topic in this environmental
assessment.

**Wilderness.** Approximately 45% of the federally-owned land at
Cumberland Island National Seashore is Congressionally designated
wilderness. The Wilderness Act directs the National Park Service to
protect and manage wilderness so that it "generally appears to have been
affected primarily by the forces of nature, with the imprint of man's
work substantially unnoticeable," and so that it "has outstanding
opportunities for solitude, or a primitive and unconfined type of
recreation." As a general rule, vehicular travel is prohibited in
Congressionally designated wilderness areas. However, due to the special
circumstances surrounding creation of the Seashore, Congress provided
that the Cumberland Island Wilderness shall be managed "subject to valid
existing rights," including rights to drive on certain existing roads.

The proposed action would exchange land to increase holdings within the
wilderness boundary, with potentially beneficial environmental impacts.
Therefore, wilderness will be addressed as an impact topic.

**Soundscape Management.** In accordance with National Park Service
*Management Policies* (2001) and Director's Order #47, *Sound
Preservation and Noise Management*, an important part of the National
Park Service mission is preservation of natural soundscapes associated
with national park units. Natural soundscapes exist in the absence of
human-caused sound. The natural ambient soundscape is the aggregate of
all natural sounds that occur in park units, together with the physical
capacity for transmitting natural sounds. Natural sounds occur within
and beyond the range of sounds that humans can perceive and can be
transmitted through air, water, and solid materials. The frequencies,
magnitudes, and duration of human-caused sound considered acceptable
varies among National Park Service units, as well as potentially
throughout each park unit, being generally greater in developed areas
and less in undeveloped areas.

Completion of the exchange could result in development of the Exchange
Tract, resulting in potential short-and long-term impacts to the
Seashore's soundscape. Because the protection of a natural ambient
soundscape and opportunities for visitors to experience natural sound
environments is an objective of Cumberland Island National Seashore,
soundscape management will be addressed as an impact topic in this
environmental assessment.

**Visitor Use and Experience.** Cumberland Island National Seashore is
open year round except December 25. Over the past decade, visitation to
the Seashore has fluctuated between 40,000 and 50,000 people per year.
Under the Seashore's approved General Management Plan, visitation is
limited to 300 persons per day in order to ensure visitors an uncrowded
experience on a largely wild and natural barrier island. Once visitors
arrive to the Seashore by ferry, almost all further travel is by foot.
(On the second Friday of each month, the National Park Service allows a
group of visitors to accompany park staff to the north end of the island
for regular inspections of the cultural resources associated with the
Settlement. This opportunity will no longer be available after November
2003.) Although most visitation is concentrated at the southern end of
the island, a number of visitors walk on or near the roads that are
adjacent to the tracts that are the subject of the proposed action. The
exchange could affect the experiences of some visitors to the island by
protecting the Wilderness Tract from development and opening up the
Exchange Tract to possible future development. Therefore, visitor use
and experience will be addressed as an impact topic in this
environmental assessment.

**Seashore Operations.** Completing the exchange could result in
additional development on the Exchange Tract and bring new residents to
the island, thereby increasing the burden on park staff responsible for
monitoring retained rights and, in particular, island driving
privileges. Therefore, Seashore operations will be addressed as an
impact topic in this environmental assessment.

**2.2 Impact Topics Dismissed from Further Analysis**

**Geology and Topography.** The National Park Service's *Management
Policies* (2001) require the protection of significant geologic and
topographic features. Cumberland Island National Seashore is located on
the largest barrier island off the Coast of Georgia. As a barrier
island, Cumberland is inherently dynamic and is characterized by slowly
shifting topography caused by wind and tidal action.

Under the proposed action, the existing topography of the island would
not change. Because there would be no impacts to geological features and
the topography of the ground would be unchanged, geology and topography
were dismissed as impact topics.

**Air Quality.** Section 118 of the Clean Air Act, as amended (33 U.S.C.
7401 *et seq.*) requires each park unit to meet all federal, state, and
local air pollution standards. Cumberland Island National Seashore is
designated as a Class II air quality area under the Clean Air Act. A
Class II designation indicates the maximum allowable increase in
concentrations of sulfur dioxide and particulate matter over baseline
concentrations, as specified in Section 163 of the Clean Air Act.
Further, the Act provides that the federal land manager has an
affirmative obligation to protect air quality-related values (including
visibility, plants, animals, soils, water quality, cultural resources,
and visitor health) from adverse pollution impacts.

Development of the Exchange Tract, should it occur, could result in
additional vehicle traffic on the island and increased wood smoke from
chimneys. The small increase in vehicle trips and number of houses that
may be associated with the proposed action could result in temporarily
increased vehicle exhaust and emissions. However, emissions of
hydrocarbons, NOx, SO2, and airborne particulates would be rapidly
dissipated by ambient air drainage. Moreover, the total amount of daily
traffic on the Main Road would remain small. Thus the proposed action
would result in negligible degradation of local air quality. Any effects
would be temporary, lasting only as long as vehicles were in operation.
Cumberland Island National Seashore's Class II air quality would not be
affected by the proposal. Therefore, air quality was dismissed as an
impact topic.

**Special Status Species.** The Endangered Species Act requires an
examination of impacts on all federally-listed threatened or endangered
species. National Park Service policy also requires an assessment of the
impacts on all federal candidate species, as well as state-listed
threatened, endangered, candidate, rare, declining, and sensitive
species. The federally-listed threatened or endangered species,
candidate species, and species of special concern that may be
potentially found in Camden County, Georgia include:

Scientific Name Common Name Federal State Species [(T, E, P or
C)]{.underline} [Listed]{.underline}

Caretta caretta loggerhead sea turtle T Y

Charadrius melodus piping plover T Y

### Chelonia mydas common green sea turtle T Y

Drymarchon corais couperi eastern indigo snake T Y

Gopherus polyphemus gopher tortoise T Y

Haliaeetus leucocephalus bald eagle T Y

Dendroica kirtlandii kirtland\'s warbler E Y

Dermochelys coriacea leatherback sea turtle E Y

Eretmochelys imbricata hawksbill sea turtle E Y

Eubalaena glacialis northern right whale E Y

Falco peregrinus peregrine falcon E Y

Lepidochelys kempii Kemps\' ridley sea turtle E Y

Megaptera novaeangliae humpback whale E Y

Mycteria americana wood stork E Y

Picoides borealis red-cockaded woodpecker E Y

Sterna antillarum Least Tern E Y

Trichechus manatus manatee E Y

Vermivora bachmanii bachman\'s warbler E Y

Charadrius montanus mountain plover P

Sageretia minutiflora tiny-leaf buckthorn Y

Neofiber alleni round-tailed muskrat Y

Sterna nilotica gull-billed tern Y

Aimophila aestivalis bachman\'s sparrow Y

Charadrius wilsonia wilson\'s plover Y

Elanoides forficatus swallow-tailed kite Y

Haematopus palliatus American oystercatcher Y

Thryomanes bewickii bewick\'s wren Y

No special status species are known to be present on either the
Wilderness Tract or the Exchange Tract. Both tracts have been
significantly disturbed in the past and neither is known to provide
suitable habitat for any special status species. Therefore, the topic of
threatened, endangered and candidate species, and species of special
concern was dismissed as an impact topic.

**Historic Structures/Buildings.** The National Historic Preservation
Act, as amended (16 U.S.C. 470 *et seq*.); the National Environmental
Policy Act (42 U.S.C. 4321 *et seq*.); the National Park Service's
Director's Order #28, *Cultural Resource Management Guideline* (1997);
*Management Policies* (2001); and Director's Order #12, *Conservation
Planning, Environmental Impact Analysis, and Decision making* (2001)
require the consideration of impacts on historic structures and
buildings listed in or eligible for listing in the National Register of
Historic Places.

The proposed action would not affect any building or structure listed in
or eligible for listing in the National Register. Therefore, impacts to
historic structures was dismissed as an impact topic in this
environmental assessment.

**Ethnographic Resources.** The National Historic Preservation Act, as
amended in 1992 (16 U.S.C. 470 *et seq*.); the National Environmental
Policy Act of 1969 (42 U.S.C. 4321 *et seq*.); the National Park
Service's Director's Order #28, *Cultural Resource Management Guideline*
(1997); *Management Policies* (2001); and Director's Order #12,
*Conservation Planning, Environmental Impact Analysis, and Decision
Making* (2001) require the consideration of impacts on ethnographic
resources listed in or eligible for listing in the National Register of
Historic Places.

Ethnographic resources are defined by the National Park Service as any
"site, structure, object, landscape or natural resource feature assigned
traditional legendary, religious, subsistence, or other significance in
the cultural system of a group traditionally associated with it"
(Director's Order #28, *Cultural Resource Management Guideline*: 191).
The exchange contemplated by the proposed action would not affect any
known ethnographic resource. Therefore, the subject of ethnographic
resources was dismissed as an impact topic.

**Cultural Landscapes.** The National Historic Preservation Act, as
amended in 1992 (16 U.S.C. 470 *et seq*.); the National Environmental
Policy Act of 1969 (42 U.S.C. 4321 *et seq*.); the National Park
Service's Director's Order #28, *Cultural Resource Management Guideline*
(1997); *Management Policies* (2001); and Director's Order #12,
*Conservation Planning, Environmental Impact Analysis, and Decision
Making* (2001) require the consideration of impacts on cultural
landscapes listed in or eligible for listing in the National Register of
Historic Places.

According to the National Park Service's *Cultural Resource Management
Guideline* (DO-28), a cultural landscape is

... a reflection of human adaptation and use of natural resources and is
often expressed in the way land is organized and divided, patterns of
settlement, land use, systems of circulation, and the types of
structures that are built. The character of a cultural landscape is
defined both by physical materials, such as roads, buildings, walls, and
vegetation, and by use reflecting cultural values and traditions.

Thus, cultural landscapes are the result of the long interaction between
people and the land, the influence of human beliefs and actions over
time upon the natural landscape.

The proposed action would entail the exchange of two small tracts within
the Seashore boundary. Implementation of the proposed action would not
alter the topography, vegetation, circulation features, spatial
organization, or land use patterns of the landscape. Because the
integrity of the existing landscape would not be affected, the subject
of cultural landscapes was dismissed as an impact topic.

**Lightscape Management.** In accordance with National Park Service
*Management Policies* (2001), the National Park Service strives to
preserve natural ambient landscapes that exist in the absence of
human-caused light. The proposed action conceivably could result in
future development of additional housing on the Exchange Tract. However,
the Exchange Tract is not located near any established camping or
night-use areas and any such development would have negligible impacts
to the lightscape of the Seashore as a whole. Therefore, lightscape
management was dismissed as an impact topic.

**Socioeconomic environment.** The proposed action would involve the
exchange of two small tracts within the Seashore boundary. The exchange
would involve equal values, so neither party would experience a change
in economic position. Any change to the social environment resulting
from possible future construction on the Exchange Tract is entirely
speculative at this time. Therefore, the socioeconomic environment was
dismissed as an impact topic in this environmental assessment.

**Prime and Unique Farmland.** In August, 1980, the Council on
Environmental Quality (CEQ) directed that Federal agencies must assess
the effects of their actions on farmland soils classified by the U.S.
Department of Agriculture's Natural Resource Conservation Service as
prime or unique. Prime or unique farmland is defined as soil that
particularly produces specialty crops such as fruits, vegetables, and
nuts. No qualifying soils exist on Cumberland Island. The proposed
action would result in neither the degradation nor irreversible
conversion of existing prime farmland to nonagricultural uses.
Therefore, the topic of prime and unique farmland was dismissed as an
impact topic.

**Hazardous Substances.** NPS policy requires that an environmental site
assessment be done on any property proposed for acquisition. The purpose
of the environmental site assessment is to determine whether the
property contains hazardous substances that might require cleanup or
pose a danger to the public. A Level I Pre-acquisition Environmental
Site Assessment Survey was performed on the Wilderness Tract by The
Environmental Company, Inc. of Pensacola, Florida. The final Survey,
dated February 8, 2002, concluded that "no recognized environmental
conditions were identified in connection with the property." Therefore,
the topic of hazardous substances was dismissed as an impact topic.

**Environmental Justice.** According to the Environmental Protection
Agency, environmental justice is the fair treatment and meaningful
involvement of all people, regardless of race, color, national origin,
or income, with respect to the development, implementation, and
enforcement of environmental laws, regulations, and policies. Fair
treatment means that no group of people, including a racial, ethnic, or
socioeconomic group, should bear a disproportionate share of the
negative environmental consequences resulting from industrial,
municipal, and commercial operations or the execution of federal, state,
local, and tribal programs and policies.

Presidential Executive Order 12898, "General Actions to Address
Environmental Justice in Minority Populations and Low-Income
Populations," requires all federal agencies to incorporate environmental
justice into their missions by identifying and addressing the
disproportionately high and/or adverse human health or environmental
effects of their programs and policies on minorities and low-income
populations and communities. The proposed action would not have health
or environmental effects on minorities or low-income populations or
communities as defined in the Environmental Protection Agency's Draft
Environmental Justice Guidance (July 1996). Therefore, environmental
justice was dismissed as an impact topic.

**3.0 ALTERNATIVES**

### The National Park Service has evaluated available alternatives related to the proposed land exchange. Alternatives selected for full analysis must meet the objectives of the park to a large degree, while also meeting the purpose and need for action. Two alternatives are described in this section. 

**3.1** **Alternative A -- No Action (do not exchange parcels)**

### Regulations implementing NEPA require the National Park Service to analyze a "no- action" alternative as a baseline against which to compare the other alternatives. In this instance, the no-action alternative would entail the National Park Service declining to consummate the land exchange. However, the no-action alternative would arguably constitute a breach of the Substituted Agreement, which obligates the National Park Service to "use its best efforts to effect the Land Swap as expeditiously as possible."

### 

### **3.2 Alternative B (Preferred Alternative) -- Swap the Exchange Tract for the Wilderness Tract**

### Under Alternative B, the National Park Service would swap the Exchange Tract for the Wilderness Tract on the terms set forth in the Substituted Agreement. Should an appraisal indicate that the fair market value of the Exchange Tract exceeds that of the Wilderness tract, Greyfield will have the following options: 

### Elect not to complete the exchange, in which case The Nature Conservancy shall have the right to exercise an option to purchase the Wilderness Tract

### Elect to complete the exchange, in which case it must make up the difference in value, at its sole discretion, by either (a) accepting a smaller portion of the Exchange Tract in return for the Wilderness tract, or (b) making a cash payment to the National Park Service equal to the excess value of the Exchange Tract. 

**3.3 Alternatives Considered but Dismissed from Further Analysis**

Other alternatives were considered during negotiation of the Substituted
Agreement, but the Substituted Agreement reflects the final agreement
among Greyfield, The Nature Conservancy, and the National Park Service
regarding the land exchange. After significant archeological resources
were discovered on the Exchange Tract, an alternative was considered
that would reconfigure the exchange property in order to "carve out"
these archeological resources while adding other land from the park to
equalize land values. However, adding new land to the exchange property
would necessitate a followup archeological survey, which could in turn
identify yet more archeological resources. Because such an approach
would make it difficult for NPS to complete the exchange by the
contractually-mandated deadline, this alternative was dismissed from
further analysis. No other alternatives were considered as part of this
environmental assessment because the National Park Service is bound by
the specific terms of the Substituted Agreement.

**3.4 Mitigation**

As noted previously, an archeological survey of the Exchange Tract
identified three archeological sites that, collectively, are potentially
eligible for listing in the National Register of Historic Places (SEAC
2003). In order to mitigate any damage to these resources resulting from
the land exchange and/or future development of the Exchange Tract, NPS
will contract with the NPS Southeastern Archeological Center (SEAC) to
implement a mitigation plan prior to the exchange. The strategy of the
mitigation plan will be to excavate (recover data) in areas of highest
artifact density based on the results of the archeological survey. (NPS
has received permission from the owner of the Sprague life estate to
enter the property to conduct data recovery, subject to certain
conditions that will not impede the project.) It is anticipated that
data recovery will cover between 30% and 50% of the site. In addition to
recovering raw data, the mitigation plan will entail preserving,
cataloging, storing, and repatriating (as appropriate) recovered
artifacts. It is anticipated that field work will last approximately six
weeks. A number of 1x1 meter test units will be opened around the areas
where artifacts were located during the archeological survey. These
areas will be excavated to a depth of between 1 to 3 feet and may be
several feet wide. Archeologists will be looking, in particular, for the
remains of postholes or other indicators of prehistoric structures or
activities that will further understanding of the earliest inhabitants
of Cumberland Island. SEAC will prepare a report that describes the data
recovery effort and summarizes what the data reveal about prior human
habitation of Cumberland Island. In the event that Native American human
burials are encountered, NPS will be required by law to contact the
Federally-recognized tribes for this area to establish how the burials
will be dealt with. The preferred method for dealing with Native
American human burials is to leave the burials in place. The discovery
of Native American burials could impact how and whether the Exchange
Tract is exchanged.

**Table 1: Comparative Summary of Environmental Impacts -- No Action and
Preferred Alternatives**

+----------+---------------------------+-------------------------------+
| **Impact | **Alternative A -- No     | **Alternative B -- Preferred  |
| Topic**  | Action**                  | Alternative**                 |
+==========+===========================+===============================+
| Soils    | Impacts to soil resources | Impacts to soil resources at  |
|          | at the Wilderness Tract   | the Exchange Tract would      |
|          | would vary, depending on  | vary, depending on whether,   |
|          | whether, and to what      | and to what extent, the new   |
|          | extent, the owner of the  | owner of the Exchange Tract   |
|          | Wilderness Tract chose to | chose to develop this         |
|          | develop this property.    | property. Impacts to soil     |
|          | However, given the size   | resources under this          |
|          | of the Seashore as a      | alternative could be minor to |
|          | whole, and the relatively | moderate in intensity,        |
|          | small size of the         | long-term and adverse. These  |
|          | Wilderness Tract, impacts | impacts would be more         |
|          | to soil resources would   | pronounced under this         |
|          | be minor, long term and   | alternative than under        |
|          | adverse. Soils at the     | Alternative A because the     |
|          | Exchange Tract would      | Exchange Tract is located at  |
|          | continue to be protected. | the relatively narrow         |
|          |                           | southern end of the island    |
|          |                           | and the tract itself extends  |
|          |                           | for much of the island's      |
|          |                           | width. Soils at the           |
|          |                           | Wilderness Tract would be     |
|          |                           | protected for the first time, |
|          |                           | resulting in beneficial       |
|          |                           | impacts to soils.             |
+----------+---------------------------+-------------------------------+
| Water    | Impacts to water          | Impacts to water resources at |
| R        | resources at the          | the Exchange Tract would      |
| esources | Wilderness Tract would    | vary, depending on whether,   |
|          | vary, depending on        | and to what extent, the new   |
|          | whether, and to what      | owner of the Exchange Tract   |
|          | extent, the owner of the  | chose to develop this         |
|          | Wilderness Tract chose to | property. Impacts to water    |
|          | develop this property.    | resources under this          |
|          | However, given the size   | alternative could be minor to |
|          | of the Seashore as a      | moderate in intensity,        |
|          | whole, and the relatively | long-term and adverse. These  |
|          | small size of the         | impacts would be more         |
|          | Wilderness Tract, impacts | pronounced under this         |
|          | to water resources would  | alternative than under        |
|          | be minor, long term and   | Alternative A because the     |
|          | adverse. Water resources  | Exchange Tract is located at  |
|          | at the Exchange Tract     | the relatively narrow         |
|          | would continue to be      | southern end of the island,   |
|          | protected.                | where some residential        |
|          |                           | development has already       |
|          |                           | occurred. Moreover, the       |
|          |                           | Exchange Tract itself extends |
|          |                           | for much of the island's      |
|          |                           | width. Water resources at the |
|          |                           | Wilderness Tract would be     |
|          |                           | protected for the first time, |
|          |                           | resulting in beneficial       |
|          |                           | impacts to water quality.     |
+----------+---------------------------+-------------------------------+
| Ve       | Impacts to vegetation and | Impacts to vegetation and     |
| getation | wildlife resources at the | wildlife at the Exchange      |
| and      | Wilderness Tract would    | Tract would vary, depending   |
| Wildlife | vary, depending on        | on whether, and to what       |
|          | whether, and to what      | extent, the new owner of the  |
|          | extent, the owner of the  | Exchange Tract chose to       |
|          | Wilderness Tract chose to | develop this property.        |
|          | develop this property.    | Impacts to vegetation and     |
|          | However, given the size   | wildlife under this           |
|          | of the Seashore as a      | alternative could be minor to |
|          | whole, and the relatively | moderate in intensity,        |
|          | small size of the         | long-term and adverse. These  |
|          | Wilderness Tract, impacts | impacts would be more         |
|          | to vegetation and         | pronounced under this         |
|          | wildlife resources would  | alternative than under        |
|          | be minor, long term and   | Alternative A because the     |
|          | adverse. Vegetation and   | Exchange Tract is located at  |
|          | wildlife at the Exchange  | the relatively narrow         |
|          | Tract would continue to   | southern end of the island    |
|          | be protected.             | and the tract itself extends  |
|          |                           | for much of the island's      |
|          |                           | width. In addition, more      |
|          |                           | acreage can be developed on   |
|          |                           | the Exchange Tract than the   |
|          |                           | Wilderness Tract. Vegetation  |
|          |                           | and wildlife at the           |
|          |                           | Wilderness Tract would be     |
|          |                           | protected for the first time, |
|          |                           | resulting in beneficial       |
|          |                           | impacts to these resources.   |
+----------+---------------------------+-------------------------------+
| Arche    | Foregoing the exchange    | Completing the exchange would |
| ological | would result in continued | result in first-time          |
| R        | protection of a potential | protection for archeological  |
| esources | national-register site on | resources on the Wilderness   |
|          | the Exchange Tract, with  | Tract, with impacts that      |
|          | impacts that would be     | would appear to be moderate   |
|          | moderate to major,        | to major, long-term, and      |
|          | long-term, and            | beneficial. However, giving   |
|          | beneficial. However,      | up the Exchange Tract could   |
|          | failure to obtain the     | result in loss or damage to   |
|          | Wilderness Tract via      | important archeological       |
|          | exchange could result in  | resources that are            |
|          | adverse impacts to        | potentially eligible for      |
|          | important archeological   | listing in the National       |
|          | resources if that tract   | Register of Historic Places.  |
|          | were to be developed.     | Impacts would appear to be    |
|          |                           | moderate to major, long-term, |
|          |                           | and adverse. Impacts would be |
|          |                           | mitigated via full data       |
|          |                           | recovery.                     |
+----------+---------------------------+-------------------------------+
| Wi       | Impacts to the wilderness | Approximately 52.2 acres      |
| lderness | value of the Wilderness   | would be added to the         |
|          | Tract would vary,         | Seashore's land base and      |
|          | depending on whether, and | would receive permanent       |
|          | to what extent, the owner | protection as potential       |
|          | of the Wilderness Tract   | wilderness. This acreage      |
|          | chose to develop this     | could eventually be included  |
|          | property. Overall,        | within the Seashore's         |
|          | impacts to wilderness     | designated wilderness area.   |
|          | would be minor, long term | Impacts to wilderness would   |
|          | and adverse.              | be minor in intensity,        |
|          |                           | long-term and beneficial.     |
+----------+---------------------------+-------------------------------+
| Sou      | If Greyfield or a         | If Greyfield or a subsequent  |
| ndscapes | subsequent owner decided  | owner decided to develop the  |
|          | to develop the Wilderness | Exchange Tract, construction  |
|          | Tract, construction       | activities could result in    |
|          | activities could result   | impacts to the soundscape     |
|          | in impacts to the         | that were minor to moderate   |
|          | soundscape that were      | in intensity, short-term and  |
|          | minor to moderate in      | adverse. Increased vehicular  |
|          | intensity, short-term and | traffic and other sounds      |
|          | adverse. Increased        | generated by an increased     |
|          | vehicular traffic and     | number of residents on the    |
|          | other sounds generated by | island could result in        |
|          | an increased number of    | impacts that were minor in    |
|          | residents on the island   | intensity, long-term, and     |
|          | could result in impacts   | adverse.                      |
|          | that were minor in        |                               |
|          | intensity, long-term, and |                               |
|          | adverse.                  |                               |
+----------+---------------------------+-------------------------------+
| Visitor  | If Greyfield or a         | If Greyfield or a subsequent  |
| Use and  | subsequent owner decided  | owner decided to develop the  |
| Ex       | to develop the Wilderness | Exchange Tract, the increased |
| perience | Tract, the area of        | traffic and presence of       |
|          | potential wilderness      |                               |
|          | available for visitor     | additional structures could   |
|          | enjoyment would be        | detract from the visitor      |
|          | permanently decreased. In |                               |
|          | addition, the increased   | experience of some visitors.  |
|          | traffic and presence of   | Impacts would be greater      |
|          | additional structures     |                               |
|          | could detract from the    | under this alternative than   |
|          | visitor experience of     | under Alternative A because   |
|          | some visitors. However,   | the Exchange Tract is located |
|          | impacts would be less     | closer to areas of principal  |
|          | than under Alternative B  |                               |
|          | because the Wilderness    | visitor use than the          |
|          | Tract is located farther  | Wilderness Tract. In          |
|          | away from the areas of    | addition, the                 |
|          | principal visitor use     |                               |
|          | than the Exchange Tract.  | Exchange Tract is located on  |
|          | Impacts to visitor use    | a narrower part of the        |
|          | and experience would be   | island, which would           |
|          | minor in intensity, long  | potentially make any          |
|          | term and adverse.         | concentrated development much |
|          |                           | more noticeable to visitors.  |
|          |                           | Impacts to visitor use and    |
|          |                           | experience would be minor to  |
|          |                           | moderate in intensity, long   |
|          |                           | term and adverse. Long-term   |
|          |                           | protection of the Wilderness  |
|          |                           | Tract would result in         |
|          |                           | beneficial impacts to         |
|          |                           | wilderness visitors. Impacts  |
|          |                           | to visitor use and experience |
|          |                           | would be minor to moderate in |
|          |                           | intensity, long term and      |
|          |                           | beneficial.                   |
+----------+---------------------------+-------------------------------+
| Seashore | If Greyfield or a         | If Greyfield or a subsequent  |
| Op       | subsequent owner decided  | owner decided to develop the  |
| erations | to develop the Wilderness | Exchange Tract, the result    |
|          | Tract, the result would   | would be additional residents |
|          | be additional residents   | and vehicular trips on the    |
|          | and vehicular trips on    | island. The amount of work    |
|          | the island. The amount of | required of National Park     |
|          | work required of National | Service staff to monitor      |
|          | Park Service staff to     | retained rights and enforce   |
|          | monitor retained rights   | driving restrictions would    |
|          | and enforce driving       | increase accordingly. Impacts |
|          | restrictions would        | to park operations would be   |
|          | increase accordingly.     | minor, long-term, and         |
|          | Impacts to park           | adverse.                      |
|          | operations would be       |                               |
|          | minor, long-term, and     |                               |
|          | adverse.                  |                               |
+----------+---------------------------+-------------------------------+

# 3.5 Environmentally Preferred Alternative

The environmentally preferred alternative is determined by applying
criteria set forth in NEPA, as guided by direction from the Council on
Environmental Quality (CEQ). The CEQ has stated that the environmentally
preferred alternative is the alternative that will promote the national
environmental policy as expressed in NEPA, Section 101. This includes
alternatives that:

-   Fulfill the responsibilities of each generation as trustee of the
    environment for succeeding generations;

-   Assure for all generations safe, healthful, productive, and
    esthetically and culturally pleasing surroundings;

-   Attain the widest range of beneficial uses of the environment
    without degradation, risk of health or safety, or other undesirable
    and unintended consequences;

-   Preserve important historic, cultural, and natural aspects of our
    national heritage and maintain, wherever possible, an environment
    that supports diversity and variety of individual choice;

-   Achieve a balance between population and resource use that will
    permit high standards of living and a wide sharing of life's
    amenities; and

-   Enhance the quality of renewable resources and approach the maximum
    attainable recycling of depletable resources.

The NPS has determined that the environmentally preferable alternative
is Alternative A (do not exchange parcels) because it surpasses the
action alternative in realizing the fullest range of national
environmental policy goals as stated above. Alternative A would prevent
additional development on the Exchange Tract, thereby preserving *in
situ* important archeological resources that may be eligible for listing
in the National Register of Historic Places. In addition, the Exchange
Tract abuts a private tract that already contains some of the highest
concentration of development on the island. By foregoing the exchange,
Alternative A would prevent additional development in this area, while
leaving open the possibility of acquiring the Wilderness Tract at a
later date with appropriated funds. While it is possible that foregoing
the exchange could result in development activities in potential
wilderness, any such development would take place in the vicinity of
existing structures on an adjacent private parcel. Moreover, the island
is much wider at the location of the Wilderness Tract than it is at the
Exchange Tract, so any impacts from development would be buffered to a
much greater degree at this location and would be less noticeable than
at the Exchange Tract. Finally, the possibility of future development is
diminished by the fact that the Substituted Agreement gives The Nature
Conservancy an option to acquire the Wilderness Tract if the exchange is
not completed.

Alternative A would a) fulfill the responsibilities of each generation
as trustee of the environment for succeeding generations, b) attain the
widest range of beneficial uses of the environment without degradation,
risk of health or safety, or other undesirable and unintended
consequences; and c) preserve important historic, cultural, and natural
aspects of our national heritage and maintain, wherever possible, an
environment that supports diversity and variety of individual choice.

### Notwithstanding the foregoing, the National Park Service proposes to implement Alternative B (swap the Exchange Tract for the Wilderness Tract) in accordance with its obligations under the Substituted Agreement. Agreeing to the land exchange was a pre-condition of NPS obtaining the lands in Phase 4 of the Greyfield North transaction (see section 1.2 above). 

**4.0 AFFECTED ENVIRONMENT**

**4.1 Overview**

This section describes the existing environmental resources of those
areas that would be affected if any of the alternatives were
implemented. Only those environmental resources that are relevant to the
decision to be made are described. This section, together with the
description of conditions in the no-action alternative, depicts the
baseline conditions against which the environmental impacts of the
proposed action are measured.

**4.2 Natural Environment**

Cumberland Island is the largest and southernmost of Georgia's barrier
islands. Located in Camden County, the island is about 17 ½ miles long
and 3 miles wide at its widest point. The closest upland area on the
mainland is approximately 2 ¼ miles away.

Cumberland Island National Seashore is bounded by the Cumberland River
on the west, by St. Andrews Sound on the north, and by Cumberland Sound
on the south. The authorized boundary of the national seashore
encompasses both Cumberland and Little Cumberland islands, but Congress
directed that Little Cumberland Island remain in private ownership so
long as the residents of Little Cumberland maintain an irrevocable trust
or other irrevocable agreement that insures the preservation of that
island's resources. Of the national seashore's 36,415 acres,
approximately 19,565 acres are considered upland and 16,850 acres
contain marsh, mud flats, and tidal creeks. The federal government
(National Park Service) owns 19,472 acres within the seashore boundary.
Most of the remaining acreage is either privately owned, owned by the
State of Georgia, or owned by the National Park Service subject to
reserved estates. (Two other federal entities own land at the Seashore:
the U.S. Army Corps of Engineers (518 acres) and the U.S. Navy (139
acres).) In 1982, Congress designated approximately 8,840 acres in the
northern section of Cumberland Island as part of the National Wilderness
Preservation System.

The barrier island landscapes are dynamic, with the ocean being the
primary force of change. Beach sands are in constant motion as a result
of southwest littoral (i.e., along-the-shore) currents, high waves and
surge caused by storms, routine wave action, and rising sea levels. Sand
movement changes the appearance of the island, sometimes accreting and
sometimes eroding the shoreline.

Vegetation is critical in maintaining what little stability exists on
the island. Extensive root systems of maritime grasses and herbaceous
plants help to stabilize sediments, whether windblown or waterborne. The
grasses themselves trap windblown sand. In this way, sand dunes build
naturally and the topography is elevated just enough so that other plant
life can take root. Shrubs and trees shield other vegetation from the
harsh salt-spray allowing different plant life to grow. Therefore, the
vegetation forms distinctive ecological zones across the island.

Just over 10% of the island is composed of dune plant communities. This
includes sparse stands of grasses, forbs, and sedges along the primary
dunes, interdune meadow and secondary dunes along the 17 ½ mile beach.
Sea oats (*Uniola paniculata*), railroad vine (*Ipomoea pes-caprae*),
beach morning glory (*Ipomoea stolonifera*), and beach pennywort
(*Hydrocotyle bonariensis*) are important stabilizing plants.

The entire tidal area of the west side of the island is linked into a
single functional unit. Extensive salt marshes meander along the creeks
and create pockets of stabilizing grasses dominated by salt-marsh
cordgrass (*Spartina alterniflora*). *Spartina* grows over the entire
marsh, is eaten by insects, dies decomposes, and, as detritus, furnishes
food for most of the other marsh fauna. Shrimp, crabs, and small fish
use the marshes as a nursery and feeding area, moving in and out with
the tides. Fiddler crabs are the most conspicuous animals that feed on
the detritus covering the soft mud. The tidal amplitude in Georgia is
large -- approximately seven feet -- so these "bar-built" estuaries are
energy absorbing systems.

The aquatic systems of Cumberland Island are more extensive and diverse
than those of other Georgia barrier islands. Permanent ponds comprise
0.2% of the island. Three quarters of these are freshwater ponds. Water
levels in ponds and sloughs fluctuate, changing the salinity of those
water bodies in contact with the sea. These areas provide nesting,
feeding, and roosting areas for a large number of wading birds and shore
birds, as well as many amphibians, reptiles, and mammals.

Fire, storms and grazing have been important driving forces in
determining the present vegetation communities of Cumberland Island.
Twenty-two plant communities have been described and mapped (Hillestad
1975). Mature forests are dominated by broadleaf evergreen species.
Thirty-nine percent of the island is made up of five upland forest
communities, with oak species playing an important role in every one.
Important tree species include live oak (*Quercus virginiana*), laurel
oak (*Quercus laurifolia*), several species of pine (*Pinus spp.*), and
bayberry (*Myrica cerifera*). Common understory plants include saw
palmetto (*Serenoa repens*), bristly panic grass (*Panicum aciculare*),
other grasses and many vine species. No endangered plants have been
found on the island.

The acorn crop provides an important food source for many native
animals, including deer and turkey. Cumberland Island supports more
species of large vertebrates than any of Georgia's other barrier
islands. There are resident populations of white-tailed deer
(*Odocoileus virginianus*), gray squirrels (*Sciurus carolinensis*), and
raccoons (*Procyon lotor*). There are many smaller mammals, including
rodents, bats, opossums, marsh rabbits, mice, and voles. Armadillos were
first documented on the island in 1974. NPS reintroduced the bobcat in
1988 and 1989. Exotic species include feral horses and hogs. The NPS is
in the second year of a hog eradication program.

Birds are by far the most numerous vertebrate animals on the island,
with approximately 323 species recorded within Seashore boundaries.
Their abundance is due to the Seashore's location on the Atlantic Flyway
and to lack of development and human disturbance. Of special importance
are the bald eagle and peregrine falcon that use the Seashore in limited
numbers for feeding and resting. The piping plover is threatened along
the Atlantic coast. Least terns nest in colonies behind beach/berm,
among scattered low dunes, and on tidal flats. At least 101 species are
known to nest on the island. Cumberland provides critical nesting
habitat for 18 species of colonial nesters such as least and gull-billed
terns, wood storks, herons, and egrets. The mature oak forest provides
nesting habitat for 77 species of tree nesting birds and feeding habitat
for over 100 species of insect-eating birds. Large multi-species flocks
of shorebirds frequent the beaches.

Reptiles dominate the herpetofauna of Cumberland Island. There are 42
species of reptiles and 17 species of amphibians. The loggerhead sea
turtle (*Caretta caretta*), a federally threatened species, is a regular
summer visitor to Cumberland Island, nesting on or near the base of
dunes fronting the beach. Over the last 11 years, the park has
documented an average of 196 sea turtle nests per year. During the 2002
nesting season, as many as 15,475 hatchlings crossed Cumberland Island's
beaches to enter the Atlantic Ocean. The park also reports strandings of
green, Kemps ridley, and leatherback sea turtles. The American alligator
occurs commonly throughout aquatic areas. Many varieties of tree frogs,
toads, snakes, and lizards are also common residents.

Marine animals inhabit the intertidal zones of the beaches, tidal flats
and salt marshes. Burrowing mole crabs, ghost crabs, and coquina clams
are found on the ocean beaches, and crustaceans and worms on the tidal
flats. Many species of commercially valuable invertebrates and fish are
supported by the food chain of the Seashore's salt marshes and tidal
creeks.

The national significance of Cumberland Island was recognized by
Congress when it included the island within the National Park System.
The significance of the diverse resources on Cumberland Island received
international recognition in 1986 when the UNESCO Bureau of the
International Coordinating Council for Man and the Biosphere designated
the Seashore as part of the Carolina-South Atlantic Biosphere
Reserve-Sea Island Unit.

**4.3 Cultural Environment**

For more than 4,000 years, a variety of human visitors and residents
have interacted with and relied upon the natural resources of Cumberland
Island. The island and its inhabitants have played important roles in
numerous significant periods of American history. The first Indian
occupation dates back to before 3000 BC, with early ceramic cultures
appearing around 2000 BC. Cultural affiliations shifted over time, but
at the time of first contact with Europeans the Timucuan Indians
occupied Cumberland Island. Later, a tribe named the Guale by the
Spanish used Cumberland Island seasonally, harvesting fish and
shellfish.

Numerous shell middens and other archeological sites remain on
Cumberland as a reminder of the long occupation by native people. Soon
after the European discovery of the New World, the Sea Islands of North
America's southeast coast were drawn into the larger Atlantic trading
economy. In the sixteenth century, the natural abundance of Cumberland
and other coastal islands attracted European galleons, which stopped
long enough to load game birds, pelts, and naval stores. The sailors on
these ships were drawn from various European and African trading areas,
and these visits witnessed some of the first encounters among Africans,
Europeans, and North American Indians.

The southeastern coast of North America, lying between Spanish Florida
and the British settlements in Virginia, was contested ground from the
early seventeenth to the late eighteenth century. Around 1600, Spanish
priests and soldiers established a string of missions and related forts
on the Georgia sea islands, including the missions of San Pedro de
Mocama and San Pedro y San Pablo de Porturibo on Cumberland Island. The
Spanish sought to Christianize the Indians and guard their more valuable
possessions to the south.

The settlement of Carolina in 1670 led to increasing conflict between
the British and Spanish and their respective Indian allies. Indian raids
instigated by the British pushed the Spanish farther and farther south.
During King George's War in the 1740s, General James Oglethorpe, founder
of the Georgia colony, fortified Cumberland Island against the Spanish
with Fort St. Andrew at the north end of the island and Fort Prince
William at the south end. The Battle of Bloody Marsh on St. Simons
Island in 1742 ended the near-term threat of Spanish occupation in
Georgia, but the fate of the Georgia sea islands continued to be
disputed in the French and Indian War, the American Revolution, and the
War of 1812.

The plantation system began to take root on Cumberland in the late
eighteenth century. The primary engine of development in the New World,
the plantation was based on African slavery and the production of staple
crops for export. Although timber, citrus fruit, and olives were
cultivated on Cumberland, long-staple cotton, commonly known as
sea-island cotton, emerged as the most profitable crop, commanding as
much as one dollar per pound in international markets. Revolutionary War
hero Nathaniel Greene began the development of plantation agriculture on
Cumberland in the 1780s, but his widow, Catherine, and their descendants
were the key players. An 1802 map of the island shows a system of roads
and cotton fields cleared by slave labor. By the 1840s, much of the
island was under cultivation by some 200 to 400 enslaved African
Americans under the direction of two to three dozen whites. The
substantial black majority in coastal South Carolina and Georgia and the
area's relative isolation from outside influences produced a unique
African-American cultural complex known as Gullah (in South Carolina) or
Geechee (more commonly used in Georgia). Hallmarks of this culture are a
distinctive Gullah language, and artistic, culinary, and religious
traditions strongly influenced by African heritage. Although little is
known specifically about Geechee culture on Cumberland, it undoubtedly
resembled the more intensively studied Gullah culture of South Carolina.

Agricultural production on Cumberland peaked during the two decades
preceding the Civil War. It was at this time that planter Robert
Stafford assembled holdings on the island totaling some 8,000 acres.
Early in the war, most white plantation masters abandoned their lands
and field slaves when it became apparent that Confederate forces could
not defend the sea islands. Union troops occupied Cumberland and
surrounding waters in March 1862, holding the area for the remainder of
the war. Much of the African-American population of Cumberland sought
refuge under federal auspices on nearby Amelia Island, just across the
sound in Florida. Following the war and short-lived efforts to
redistribute confiscated land to freed people, the landholdings on
Cumberland reverted to their pre-war owners.

In the 1870s, an expanding railroad and steamship network opened the
coastal South to more intensive recreational use. By 1878, two hotels
were operating at High Point on the northern end of Cumberland Island,
served by steamers from Brunswick. The hotel operations at High Point
reached a peak in the 1890s and 1900s, when groups like the Georgia
Teachers Association and the Georgia State Dental Society held their
annual meetings there. Starting in 1890, the hotel owners sold small
plots of land at the nearby Settlement (also known as Half Moon Bluff)
to several African-American families in order to ensure a steady supply
of labor. The hotel shut down in 1920, when the Cumberland Island Club,
a private organization, purchased the property. Eight years later, the
property was acquired by the Candler family, which had made its fortune
through the Coca-Cola family.

Wealthy northern industrialist families also saw the potential for
winter homes on the sea islands. In 1881, Thomas Morrison Carnegie --
brother of Andrew Carnegie -- purchased the Greene-Miller plantation at
Dungeness for his wife Lucy Coleman Carnegie and their growing family.
Despite Thomas' death in 1886, Lucy went on to amass 90 percent of
Cumberland Island and proceeded to turn it into a complex of family
estates, which included homes with extensive landscaped grounds for four
of her children. Lucy's home, Dungeness Mansion, was built on the ruins
of Catherine Greene's original Dungeness plantation house. During Lucy's
lifetime, Cumberland Island was a highly organized, largely
self-sufficient private preserve. It was staffed by some 200 employees,
most of whom were black, and through their labor the extended Dungeness
family was supplied with produce and livestock, supplemented by
provisions brought daily from Amelia Island on the family yacht.

With remarkable foresight, Lucy Carnegie established a trust that kept
the family's holdings intact until the death of her last child, which
occurred in 1962. By this time, plans for exploiting and developing the
island's natural and scenic resources threatened the island's future
preservation. Wanting to maintain its character, Carnegie and Candler
descendants who were interested in preserving the island banded together
to seek alternative ways to protect Cumberland from development. They,
along with environmental organizations and the Department of the
Interior, succeeded in having Cumberland Island set aside in 1972 as a
national seashore for all Americans.

The appearance of Cumberland Island today is largely a result of the
overlay of these successive waves of human habitation and development.
Many individual sites, such as Dungeness and Plum Orchard, bear the
imprint of Indian settlement, followed by the plantation regime, with a
final overlay of Carnegie-era development. From the late 1700s the bulk
of the labor that developed and maintained human life on the island was
supplied by African Americans, enslaved until the 1860s, and as paid
laborers thereafter. Although many of the prominent extant structures on
the island represent the leisure activities of the island residents, the
artifacts below ground -- the ruins of slave villages, patterns of field
and forest, gardens and outbuildings -- represent the considerable
contributions of Native Americans and African Americans to the
development of the island.

Historic districts have been established around the historic structures
at Dungeness, Plum Orchard, Stafford, and High Point -- Half Moon Bluff
as part of the Cultural Resource Management Plan. Each of these historic
districts has been included in the National Register of Historic Places.
Archeological districts have been established at Rayfield and Table
Point, and these districts have likewise been included in the National
Register of Historic Places.

4.  **Socioeconomic Environment**

Greyfield Inn is the only commercial operation on Cumberland Island. The
Inn has been in operation since the mid-1960s and houses related
business activities. Island residents have language in their retained
rights agreements permitting them to rent their homes for varying
lengths of time. This practice is consistent with the Seashore's
enabling legislation but is NOT considered to be commercial.

Commercial operations related to the park itself are limited. Those
identified in the Seashore's draft Commercial Services Plan consist of
the ferry concession, various Incidental Business Permits, a cooperating
association, and holders of certain Special Use Permits, e.g., for
commercial photography.

The sole concessioner, Lang Seafood, Inc., has provided ferry service to
the island for over a decade. The 1984 General Management Plan does not
permit other concessions at the Seashore. Eastern National is a
cooperating association founded in 1947. Its one outlet in the park is
located in the debarkation building, where books, videos and related
items are sold.

5.  **Visitor Activities**

The only available access to Cumberland Island is via water. A
concession tour boat accommodating 146 passengers operates twice a day,
five days a week, from December through February, and seven days a week
the remainder of the year. Additional ferry trips are scheduled twice a
month to Plum Orchard. Charters are also available.

Visitation to the Seashore from 1994 through 2001 ranged between 40,022
and 49,864 persons. March, April, and May are consistently the busiest
months of the year, accounting for about 40 percent of total annual
visitation. The remainder of the year, visitation figures range between
2,000 and 4,000 persons per month, with the exception of December,
during which usually less than 2,000 visitors come to the island.
Visitation is limited to 300 per day by the General Management Plan.

The first ferry stop is at Dungeness, near the southern end of the
island, where visitors can walk to the Dungeness ruins and related
buildings from the Carnegie era. The second ferry stop is at Sea Camp, a
short distance to the north. Visitor facilities consist of a dock (also
available for public docking), a front country campground with 16 sites
and two group campsites (total 60 campers), an information center, and a
boardwalk over the dunes providing access to the beach.

Four backcountry or primitive campgrounds accommodating a maximum of 20
persons each (total not to exceed 60 permitted campers per night) are
located in the middle and northern part of the island.

Brickhill campground is the only campground on the water and is a
favorite stop for canoe and kayak tours and camping guides. Plum Orchard
mansion also has a dock open to the public that is used by boaters.

As authorized by the Seashore's enabling legislation, the National Park
Service conducts five managed hunts per year. Hunters may take deer and
feral hogs in accordance with State regulations. However, this is the
final year for recreational hog hunting on the island as the NPS will
soon implement a plan to remove all feral hogs from the island under an
intensive 3-year program. The Plum Orchard area and Brickhill campground
are designated hunt campsites.

##### 

##### 

##### 

##### 5.0 ENVIRONMENTAL CONSEQUENCES 

**5.1 Introduction**

The National Environmental Policy Act requires that federal agencies,
before taking an action, discuss the environmental impacts of that
action, feasible alternatives to that action, and any adverse
environmental effects that cannot be avoided if the proposed action is
implemented. This section of the EA describes the potential
environmental impacts of implementing the two alternatives on natural
and cultural resources, the visitor experience, the socioeconomic
environment, and National Seashore operations. These impacts provide a
basis for comparing the advantages and disadvantages of the two
alternatives.

This analysis of environmental consequences consists largely of a
qualitative assessment of the effects of the two alternatives on
**eight** natural and cultural resource categories. The first part of
this section discusses the methodology used to identify impacts and
includes definitions of terms. The impact topics are then analyzed with
reference to each of the alternatives. The discussion of each impact
topic includes a description of the positive and negative effects of the
alternatives, a discussion of cumulative effects, if any, and a
conclusion. The conclusion includes a discussion of whether, and to what
extent, the alternative would impair park resources and values. For the
analyses, NPS considered the mitigation measures described in the action
alternative.

**5.2 Methodology**

Generally, the methodology for resource impact assessments follows
direction provided in the Council on Environmental Quality (CEQ)
Regulations for Implementing The National Environmental Policy Act,
Parts 1502 and 1508. The impact analysis and the conclusions in this
part are based largely on the review of existing literature and park
studies, information provided by experts within the National Park
Service and other agencies, park staff insights and professional
judgement.

The impacts from the alternatives were evaluated in terms of the
context, duration, and intensity of the impacts, as defined below, and
whether the impacts were considered beneficial or adverse to park
resources and values.

**5.2.1 Context**

Each impact topic addresses effects on resources inside and outside the
Seashore, to the extent those effects are traceable to the actions set
forth in the alternatives.

**5.2.2 Duration**

*Short term Impacts --* Those that would occur within five years of the
exchange.

*Long-term Impacts* -- Those that would occur or continue to exist five
years after the exchange.

**5.2.3 Impact Intensity**

**5.2.3(a) Impact Intensity for Natural Resources, Visitor Use and
Enjoyment, Socioeconomic Environment, and Seashore Operations**

For this analysis, intensity or severity of impact is defined as
follows:

-   *Negligible* -- The impact is barely perceptible, not measurable,
    and confined to a small area.

-   *Minor* -- The impact is perceptible and measurable but is
    localized.

-   *Moderate* -- The impact is clearly detectable and could have an
    appreciable effect.

-   *Major* -- The impact would have a substantial, highly noticeable
    influence on a regional scale.

**5.2.4 Impact Type**

Unless otherwise noted, impacts would be adverse.

CEQ regulations and the National Park Service's *Conservation Planning,
Environmental Impact Analysis and Decision-making* (Director's Order
#12) call for a discussion of the appropriateness of mitigation, as well
as an analysis of how effective the mitigation would be in reducing the
intensity of a potential impact, e.g. reducing the intensity of an
impact from major to moderate or minor. The action alternative assumes
that National Seashore managers would apply mitigation measures to
minimize or avoid impacts. If appropriate mitigation measures were not
applied, the potential for resource impacts would increase and the
magnitude of those impacts would rise.

#### 5.2.5 Direct versus Indirect Impacts

#### 

#### Direct effects would be caused by an action and would occur at the same time and place as the action. Indirect effects would be caused by the action and would be reasonably foreseeable but would occur later in time, at another place, or to another resource. 

#### 

**5.3 Considerations Specific to Archeological Resources**

As noted in Section 2 above, the proposed action could result in damage
or destruction to archeological resources on the Exchange Tract that are
potentially eligible for listing in the National Register of Historic
Places (other cultural resources would not be affected). Archeological
resources are typically considered eligible for inclusion in the
National Register because of the information they have or may be likely
to yield. Intensity of impacts to archeological resources relates, in
part, to the importance of the information they contain and the extent
of disturbance/degradation.

In this environmental assessment, impacts to archeological resources are
described in terms of type, context, duration, and intensity, as
described previously in Section 5.2, which is consistent with the
regulations of the Council on Environmental Quality (CEQ) that implement
the National Environmental Policy Act (NEPA). However, for purposes of
NEPA, intensity of impacts to archeological resources is assessed using
the following specific definitions:

-   *Negligible* -- Impact is barely perceptible and not measurable;
    confined to small areas or a single contributing element of a larger
    national register district or archeological site(s) with low data
    potential.

-   *Minor* -- Impact is perceptible and measurable; remains localized
    and confined to a single contributing element of a larger national
    register district or archeological site(s) with low to moderate data
    potential.

-   *Moderate* -- Impact is sufficient to cause a change in a
    character-defining feature; generally involves a single or small
    group of contributing elements or archeological site(s) with
    moderate to high data potential.

-   *Major --* Impact results in substantial and highly noticeable
    change in character-defining features; involves a large group of
    contributing elements and/or individually important property or
    archeological site(s) with high to exceptional data potential.

It should be noted that the analysis of impacts to archeological
resources is intended to comply not only with the requirements of NEPA,
but also with Section 106 of the National Historic Preservation Act
(NHPA). In accordance with the Advisory Council on Historic
Preservation's regulations implementing Section 106 of the NHPA (36 CFR
Part 800, *Protection of Historic Properties*), impacts to archeological
and cultural resources were identified and evaluated by (1) determining
the area of potential effects; (2) identifying cultural resources
present in the area of potential effects that were either listed in or
eligible to be listed in the National Register of Historic Places; (3)
applying the criteria of adverse effect to affected cultural resources
either listed in or eligible to be listed in the National Register; and
(4) considering ways to avoid, minimize or mitigate adverse effects.

Under the Advisory Council's regulations a determination of either
*adverse effect* or *no adverse effect* must also be made for affected,
National Register eligible cultural resources. An *adverse effect*
occurs whenever an impact alters, directly or indirectly, any
characteristic of a cultural resource that qualify it for inclusion in
the National Register, e.g. diminishing the integrity of the resource's
location, design, setting, materials, workmanship, feeling, or
association. Adverse effects also include reasonably foreseeable effects
caused by the preferred alternative that would occur later in time, be
farther removed in distance or be cumulative (36 CFR Part 800.5,
*Assessment of Adverse Effects*). A determination of *no adverse effect*
means there is an effect, but the effect would not diminish in any way
the characteristics of the cultural resource that qualify it for
inclusion in the National Register.

CEQ regulations and the National Park Service's *Conservation Planning,
Environmental Impact Analysis and Decision-making* (Director's Order
#12) also call for a discussion of the appropriateness of mitigation, as
well as an analysis of how effective the mitigation would be in reducing
the intensity of a potential impact, e.g. reducing the intensity of an
impact from major to moderate or minor. Any resultant reduction in
intensity of impact due to mitigation, however, is an estimate of the
effectiveness of mitigation under NEPA only. It does not suggest that
the level of effect as defined by Section 106 is similarly reduced.
Although adverse effects under Section 106 may be mitigated, the effect
remains adverse.

A Section 106 summary is included in the impact analysis sections for
archeological and cultural resources under the preferred alternative.
The Section 106 Summary is intended to meet the requirements of Section
106 and is an assessment of the effect of the undertaking
(implementation of the alternative) on cultural resources, based upon
the criterion of effect and criteria of adverse effect found in the
Advisory Council's regulations.

**5.4 Cumulative Impacts**

Regulations implementing NEPA issued by the CEQ require the assessment
of cumulative impacts in the decision‑making process for federal
actions. Cumulative impacts are defined as \"the impact on the
environment which results from the incremental impact of the action when
added to other past, present, and reasonably foreseeable future actions
regardless of what agency (federal or non‑federal) or person undertakes
such other actions\" (40 CFR 1508.7). Cumulative impacts can result from
individually minor but collectively significant actions taking place
over a period of time.

The cumulative impacts analyzed in this document consider the
incremental effects of the alternatives in conjunction with past,
current, and future actions at the Seashore. Cumulative impacts were
determined by combining the effects of a given alternative with other
past, present, and reasonably foreseeable future actions. The impact
analysis and conclusions are based on information available in the
literature, data from NPS studies and records, and information provided
by experts within the National Park Service and other agencies. Unless
otherwise stated, all impacts are assumed to be direct and long-term.

**5.5 Impairment of National Seashore Resources or Values**

In addition to determining the environmental consequences of the
preferred and other alternatives, the 2001 NPS *Management Policie*s and
Director's Order 12 require analysis of potential effects to determine
if actions would impair Seashore resources or values.

The fundamental purpose of the National Park System, established by the
Organic Act and reaffirmed by the General Authorities Act, as amended,
is to conserve the resources and values of each unit of the system.
Although Congress has given NPS management discretion to allow certain
impacts within individual units, that discretion is limited by statutory
requirement that the NPS must leave resources and values unimpaired,
unless a particular law directly and specifically provides otherwise.
The prohibited impairment is an impact that, in the professional
judgement of the responsible NPS manager, would harm the integrity of
unit resources or values, including opportunities that otherwise would
be present for the enjoyment of those resources or values. Impairment
may result from NPS activities in managing the unit, visitor activities,
or activities undertaken by concessioners, contractors, and others
operating in the unit.

To determine whether actions and management prescriptions involving
National Seashore resources would result in impairment, each alternative
was evaluated to determine if it would have a major adverse effect on a
resource or value whose conservation is:

> • necessary to fulfill specific purposes identified in the
> establishing legislation of the Seashore;
>
> • key to the natural or cultural integrity of the National Seashore or
> to opportunities for enjoyment of the Seashore; or
>
> • identified as a goal in the General Management Plan or other
> relevant NPS planning documents.

**5.6 Topics Dismissed from Further Analysis**

The topics dismissed from further analysis, and the reasons therefore,
are discussed in section 2.2 of this document.

**5.7 Analysis of Impact Topics**

**5.7.1 SOILS**

### 

### **Effects of Alternative A**

[Analysis]{.underline}. Under Alternative A, the National Park Service
would not pursue the land exchange. Soils on the Wilderness Tract could
be adversely affected if Greyfield or a subsequent owner decided to
develop this tract. Soils on the Exchange Tract would not be affected
because the tract would remain in NPS ownership and be subject to NPS'
resource protection policies.

[Cumulative Impacts]{.underline}. Other tracts of private property have
been developed at Cumberland Island. A number of structures have been
built at the Serendipity Compound, which is located adjacent to, and
south of, the Wilderness Tract. Development of the Wilderness Tract, if
it were to occur, could result in additional adverse impacts to soils.
Given the size of the Seashore as a whole, and the relatively small size
of the Wilderness Tract, this alternative's contribution to cumulative
impacts would be minor, long term and adverse.

[Conclusion]{.underline}. Under this alternative, impacts to soil
resources at the Wilderness Tract would vary, depending on whether, and
to what extent, the owner of the Wilderness Tract chose to develop this
property. However, given the size of the Seashore as a whole, and the
relatively small size of the Wilderness Tract, impacts to soil resources
would be minor, long term and adverse. Soils at the Exchange Tract would
continue to be protected.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

### 

### **Effects of Alternative B**

[Analysis]{.underline}. Under Alternative B, the National Park Service
would complete the land exchange as proposed. Soils on the Exchange
Tract could be adversely affected if Greyfield or a subsequent owner
decided to develop this tract. Soils on the Wilderness Tract would
receive permanent protection because the tract would now be in NPS
ownership and would be subject to NPS' resource protection policies.

[Cumulative Impacts]{.underline}. A number of structures have been built
on the Greyfield Land Corp. property, which is located adjacent to, and
south of, the Exchange Tract. Development of the Exchange Tract, if it
were to occur, could result in additional adverse impacts to soils.
Given the size of the Seashore as a whole, and the relatively small size
of the Exchange Tract, this alternative's contribution to cumulative
impacts would be minor, long term and adverse.

[Conclusion]{.underline}. Under this alternative, impacts to soil
resources at the Exchange Tract would vary, depending on whether, and to
what extent, the new owner of the Exchange Tract chose to develop this
property. Impacts to soil resources under this alternative could be
minor to moderate in intensity, long-term and adverse. These impacts
would be more pronounced under this alternative than under Alternative A
because the Exchange Tract is located at the relatively narrow southern
end of the island and the tract itself extends for much of the island's
width. Soils at the Wilderness Tract would be protected for the first
time, resulting in beneficial impacts to soils.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

### **5.7.2 WATER QUALITY**

### 

### **Effects of Alternative A**

[Analysis]{.underline}. Under Alternative A, the National Park Service
would not pursue the land exchange. Groundwater on the Wilderness Tract
could be adversely affected if Greyfield or a subsequent owner decided
to develop this tract. Groundwater on the Exchange Tract would not be
affected because the tract would remain in NPS ownership and be subject
to NPS' resource protection policies.

[Cumulative Impacts]{.underline}. Other tracts of private property have
been developed at Cumberland Island. A number of structures have been
built at the Serendipity Compound, which is located adjacent to, and
south of, the Wilderness Tract. Development of the Wilderness Tract, if
it were to occur, could result in additional adverse impacts to
groundwater, including lower groundwater levels and pollution from
septic systems. Given the size of the Seashore as a whole, and the
relatively small size of the Wilderness Tract, this alternative's
contribution to cumulative impacts would be minor, long term and
adverse.

[Conclusion]{.underline}. Under this alternative, impacts to water
resources at the Wilderness Tract would vary, depending on whether, and
to what extent, the owner of the Wilderness Tract chose to develop this
property. However, given the size of the Seashore as a whole, and the
relatively small size of the Wilderness Tract, impacts to water
resources would be minor, long term and adverse. Water resources at the
Exchange Tract would continue to be protected.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

### **Effects of Alternative B**

[Analysis]{.underline}. Under Alternative B, the National Park Service
would complete the land exchange as proposed. Groundwater on the
Exchange Tract could be adversely affected if Greyfield or a subsequent
owner decided to develop this tract. Groundwater on the Wilderness Tract
would receive permanent protection because the tract would now be in NPS
ownership and would be subject to NPS' resource protection policies.

[Cumulative Impacts]{.underline}. A number of structures have been built
on the Greyfield Land Corp. property, which is located adjacent to, and
south of, the Exchange Tract. Development of the Exchange Tract, if it
were to occur, could result in additional adverse impacts to
groundwater, including lower groundwater levels and pollution from
septic systems. Given the size of the Seashore as a whole, and the
relatively small size of the Exchange Tract, this alternative's
contribution to cumulative impacts would be minor to moderate, long term
and adverse.

[Conclusion]{.underline}. Under this alternative, impacts to water
resources at the Exchange Tract would vary, depending on whether, and to
what extent, the new owner of the Exchange Tract chose to develop this
property. Impacts to water resources under this alternative could be
minor to moderate in intensity, long-term and adverse. These impacts
would be more pronounced under this alternative than under Alternative A
because the Exchange Tract is located at the relatively narrow southern
end of the island, where some residential development has already
occurred. Moreover, the Exchange Tract itself extends for much of the
island's width. Water resources at the Wilderness Tract would be
protected for the first time, resulting in beneficial impacts to water
quality.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

**5.7.3 VEGETATION AND WILDLIFE**

### **Effects of Alternative A**

[Analysis]{.underline}. Under Alternative A, the National Park Service
would not pursue the land exchange. If Greyfield or a subsequent owner
decided to develop the Wilderness Tract, vegetation could be cleared and
wildlife habitat lost. Vegetation and wildlife on the Exchange Tract
would not be affected because the tract would remain in NPS ownership
and be subject to NPS' resource protection policies.

[Cumulative Impacts.]{.underline} Other tracts of private property have
been developed at Cumberland Island. A number of structures have been
built at the Serendipity Compound, which is located adjacent to, and
south of, the Wilderness Tract. Development of the Wilderness Tract, if
it were to occur, could result in additional adverse impacts to
vegetation and wildlife. Given the size of the Seashore as a whole, and
the relatively small size of the Wilderness Tract, this alternative's
contribution to cumulative impacts would be minor, long term and
adverse.

[Conclusion.]{.underline} Under this alternative, impacts to vegetation
and wildlife resources at the Wilderness Tract would vary, depending on
whether, and to what extent, the owner of the Wilderness Tract chose to
develop this property. However, given the size of the Seashore as a
whole, and the relatively small size of the Wilderness Tract, impacts to
vegetation and wildlife resources would be minor, long term and adverse.
Vegetation and wildlife at the Exchange Tract would continue to be
protected.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

### **Effects of Alternative B**

[Analysis]{.underline}. Under Alternative B, the National Park Service
would complete the land exchange as proposed. If Greyfield or a
subsequent owner decided to develop the Exchange Tract, vegetation could
be cleared and wildlife habitat lost. Vegetation and wildlife on the
Wilderness Tract would receive permanent protection because the tract
would now be in NPS ownership and would be subject to NPS' resource
protection policies.

[Cumulative Impacts.]{.underline} A number of structures have been built
on the Greyfield Land Corp. property, which is located adjacent to, and
south of, the Exchange Tract. Development of the Exchange Tract, if it
were to occur, could result in additional adverse impacts to vegetation
and wildlife. Given the possible concentration of structures at this
relatively narrow part of the island, the contribution of this
alternative to cumulative impacts would be minor to moderate, long term
and adverse.

[Conclusion.]{.underline} Under this alternative, impacts to vegetation
and wildlife at the Exchange Tract would vary, depending on whether, and
to what extent, the new owner of the Exchange Tract chose to develop
this property. Impacts to vegetation and wildlife under this alternative
could be minor to moderate in intensity, long-term and adverse. These
impacts would be more pronounced under this alternative than under
Alternative A because the Exchange Tract is located at the relatively
narrow southern end of the island and the tract itself extends for much
of the island's width. In addition, more acreage can be developed on the
Exchange Tract than the Wilderness Tract. Vegetation and wildlife at the
Wilderness Tract would be protected for the first time, resulting in
beneficial impacts to these resources.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

**5.7.4 ARCHEOLOGICAL RESOURCES**

**Effects of Alternative A**

[Analysis]{.underline}. Cumberland Island has been inhabited by humans
for thousands of years, and numerous archeological sites are present
within Seashore boundaries. Two archeological districts (Rayfield and
Table Point) have been established at the Seashore in accordance with
the Seashore's Cultural Resource Management Plan. Both of these
districts are included in the National Register of Historic Places.

Under alternative A, the exchange would not proceed. NPS would continue
to protect unrecorded and potentially significant archeological
resources on the Exchange Tract, including artifacts from the Orange
period (2300---1000 BC). These resources were identified in July 2003 by
the NPS Southeast Archeological Center ("SEAC") (SEAC 2003). Although
additional investigation and analysis would be required to fully
evaluate the significance of this site, preliminary indications are that
the site would likely be eligible for inclusion in the National Register
of Historic Places. Impacts from protecting this potential
national-register site would be moderate to major, long-term, and
beneficial.

On the other hand, by not pursuing the exchange, NPS would forego the
opportunity to protect any archeological resources on the Wilderness
Tract. This area was surveyed by SEAC in 1976. Archeological site 9CAM10
appears to be located within this tract. It is described as an erosional
remnant of a much larger occupation that was located along the
marsh-upland interface. This site was tested by J.T. Milanich,
Universitiy of Florida, and reported upon in his 1971 Ph.D.
dissertation. The title of his work is \"The Deptford Phase: An
archeological Reconstruction.\" The site is of the Deptford-Wilmington
Period. In 1976 the site dimensions were 250m X 75m X 20cm.

[Cumulative Impacts]{.underline}. Cumberland Island is remarkably rich
in archeological resources. Foregoing the exchange would protect
resources on the Exchange Tract, while possibly exposing resources on
the Wilderness Tract to disturbance or destruction. Without additional
study, it is not possible to say which of the two tracts has the more
significant resources. The cumulative impact of this alternative could
be a net loss of archeological resources if the Wilderness Tract were to
be developed.

[Conclusion]{.underline}. Foregoing the exchange would result in
continued protection of a potential national-register site on the
Exchange Tract, with impacts that would be moderate to major, long-term,
and beneficial. However, failure to obtain the Wilderness Tract via
exchange could result in adverse impacts to important archeological
resources if that tract were to be developed. Potential impacts to
resources on the Wilderness Tract are difficult to assess in the absence
of detailed archeological investigation, but would appear to be moderate
to major, long-term, and adverse. The cumulative impact of this
alternative would be a net loss of archeological resources if the
Wilderness Tract were to be developed.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

**Effects of Alternative B**

[Analysis]{.underline}. The proposed action conceivably could result in
future development of the Exchange Tract. Such development activities
would disturb, and very likely destroy, important archeological
resources discovered by SEAC in July 2003. Preliminary indications are
that this site would likely be eligible for inclusion in the National
Register of Historic Places. Impacts to archeological resources from
completing the exchange would be moderate to major, long-term, and
adverse.

[Cumulative Impacts]{.underline}. Completing the exchange could result
in the destruction of important archeological resources on the Exchange
Tract, while protecting resources on the Wilderness Tract. Without
additional study, it is not possible to say which of the two tracts has
the more significant resources. The cumulative impact of completing the
exchange would be a net loss of archeological resources if the Exchange
Tract were to be developed.

[Conclusion]{.underline}. Completing the exchange would result in
first-time protection for archeological resources on the Wilderness
Tract, with impacts that would appear to be moderate to major,
long-term, and beneficial. However, giving up the Exchange Tract could
result in loss or damage to important archeological resources located on
federal land within the boundary of Cumberland Island National Seashore.
Preliminary indications are that these archeological resources are
potentially eligible for listing in the National Register of Historic
Places. Impacts would appear to be moderate to major, long-term, and
adverse. The cumulative impact of this alternative would be a net loss
of archeological resources if the Exchange Tract were to be developed.

Under the preferred alternative, there could be major, adverse impacts
to a resource or value the conservation of which is (1) necessary to
fulfill specific purposes identified in the enabling legislation of
Cumberland Island National Seashore; (2) key to the natural or cultural
integrity of the Seashore; or (3) identified as a goal in the Seashore's
General Management Plan or other relevant National Park Service planning
documents. However, these impacts would be mitigated as described in
Section 3.4 of this assessment. As a result of these mitigation efforts,
there would be no impairment of the Seashore's resources or values.

**[Section 106 Statement]{.underline}**: After applying the Advisory
Council on Historic Preservation's criteria of adverse effects (36 CFR
Part 800.5, *Assessment of Adverse Effects*), the National Park Service
concludes that implementation of the land exchange could have *an
adverse effect* on archeological resources potentially eligible for
listing in the National Register of Historic Places. This conclusion
assumes that the Exchange Tract may be developed after the exchange,
thereby damaging or destroying known archeological resources and
surrounding context. It is believed that the mitigation activities
described in Section 3.4 of this assessment would be effective in
mitigating the intensity of potential impacts from moderate-to-major to
moderate. Although the integrity of known sites would be compromised via
invasive testing and excavation, a substantial quantity of data and
artifacts would be recovered for analysis and long-term preservation.

Given the potential impacts of the land exchange and proposed mitigation
plan, the National Park Service has initiated formal consultation
pursuant to Section 106 of the NHPA with both the tribal historic
preservation officers of affiliated tribes and the Georgia State
Historic Preservation Officer. The National Park Service will also
consult with other interested parties, as appropriate. Comments on the
project from the tribal historic preservation officers and the State
Historic Preservation Officer will be addressed in the final compliance
documents. Should the need arise, additional mitigation measures will be
developed in consultation with the tribal historic preservation officers
and the State Historic Preservation Officer.

**5.7.5 WILDERNESS**

### **Effects of Alternative A**

### 

[Analysis]{.underline}. Under Alternative A, the National Park Service
would not pursue the land exchange. If Greyfield or a subsequent owner
decided to develop the Wilderness Tract, those parts of the tract that
were developed would no longer qualify for eventual designation as
wilderness.

[Cumulative Impacts.]{.underline} Wilderness values at Cumberland Island
are already adversely affected by the presence of structures owned by
retained-rights holders and associated vehicle traffic. As a result,
cumulative impacts to wilderness from this alternative and other actions
at the Seashore would be minor in intensity, long-term and adverse.

[Conclusion.]{.underline} Under this alternative, impacts to the
wilderness value of the Wilderness Tract would vary, depending on
whether, and to what extent, the owner of the Wilderness Tract chose to
develop this property. Overall, impacts to wilderness would be minor,
long term and adverse.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

### **Effects of Alternative B**

### 

[Analysis]{.underline}. Under Alternative B, the National Park Service
would complete the land exchange as proposed. Approximately 52.2 acres
would be added to the Seashore's land base and would receive permanent
protection as potential wilderness. This acreage could eventually be
included within the Seashore's designated wilderness area.

[Cumulative Impacts.]{.underline} Completing the exchange would protect
52.2 acres within potential wilderness at the Seashore. Given the size
of existing wilderness area (approximately 8,840 acres) cumulative
impacts to wilderness from this alternative and other actions at the
Seashore would be minor in intensity, long-term and beneficial.

[Conclusion.]{.underline} Impacts to wilderness under this alternative
would be minor in intensity, long-term and beneficial.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

**5.7.6 SOUNDSCAPE MANAGEMENT**

### **Effects of Alternative A**

### 

[Analysis]{.underline}. Under Alternative A, the National Park Service
would not pursue the land exchange. If Greyfield or a subsequent owner
decided to develop the Wilderness Tract, construction activities could
result in impacts to the soundscape that were minor to moderate in
intensity, short-term and adverse. Increased vehicular traffic and other
sounds generated by an increased number of residents on the island could
result in impacts that were minor in intensity, long-term, and adverse.

[Cumulative Impacts]{.underline}. Sounds emanating from the Kings Bay
Submarine Base (e.g., public address system and construction noises) are
commonly heard in the wilderness area. In addition, a number of persons
still retain the right to live on island and drive on designated roads.
These rights are regularly exercised, thereby affecting the natural
soundscape for persons visiting the Seashore. Because this alternative
would only slightly increase the number of persons living and driving on
the island at any one time, the overall contribution of this alternative
to cumulative impacts would be minor in intensity, long-term and
adverse.

[Conclusion.]{.underline} Impacts to the natural soundscape under this
alternative would be minor in intensity, long-term and adverse. Given
that the soundscape at Cumberland Island is already affected by the
sounds of vehicular traffic, this alternative's contribution to
cumulative impacts would be minor in intensity, long-term and adverse.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

### **Effects of Alternative B**

### 

[Analysis]{.underline}. Under Alternative B, the National Park Service
would complete the land exchange as proposed. If Greyfield or a
subsequent owner decided to develop the Exchange Tract, construction
activities could result in impacts to the soundscape that were minor to
moderate in intensity, short-term and adverse. Increased vehicular
traffic and other sounds generated by an increased number of residents
on the island could result in impacts that were minor in intensity,
long-term, and adverse.

[Cumulative Impacts]{.underline}. Same as Alternative A.

[Conclusion.]{.underline} Impacts to the natural soundscape under this
alternative would be minor in intensity, long-term and adverse. Given
that the soundscape at Cumberland Island is already affected by the
sounds of vehicular traffic, this alternative's contribution to
cumulative impacts would be minor in intensity, long-term and adverse.

Because there would be no major, adverse impacts to a resource or value
the conservation of which is (1) necessary to fulfill specific purposes
identified in the enabling legislation of Cumberland Island National
Seashore; (2) key to the natural or cultural integrity of the Seashore;
or (3) identified as a goal in the Seashore's General Management Plan or
other relevant National Park Service planning documents, there would be
no impairment of the Seashore's resources or values.

**5.7.7 VISITOR USE AND ENJOYMENT**

### **Effects of Alternative A**

### 

[Analysis]{.underline}. Under Alternative A, the National Park Service
would not pursue the land exchange. If Greyfield or a subsequent owner
decided to develop the Wilderness Tract, the area of potential
wilderness available for visitor enjoyment would be permanently
decreased. In addition, the increased traffic and presence of additional
structures could detract from the visitor experience of some visitors.
However, impacts would be less than under Alternative B because the
Wilderness Tract is located farther away from the areas of principal
visitor use than the Exchange Tract.

[Cumulative Impacts]{.underline}. A number of private residences already
exist on Cumberland Island. Should additional development occur, as is
possible under this alternative, it would substantially increase (on a
percentage basis) the number of residents on the island. The
contribution of this alternative to cumulative impacts would be minor in
intensity, long-term, and adverse.

[Conclusion]{.underline}. Impacts to visitor use and experience under
this alternative would be minor in intensity, long term and adverse. The
contribution of this alternative to cumulative impacts on visitor use
and experience would be minor, long-term, and adverse.

### **Effects of Alternative B**

### 

[Analysis]{.underline}. Under Alternative B, the National Park Service
would complete the land exchange as proposed. If Greyfield or a
subsequent owner decided to develop the Exchange Tract, the increased
traffic and presence of additional structures could detract from the
visitor experience of some visitors. Impacts would be greater under this
alternative than under Alternative A because the Exchange Tract is
located closer to areas of principal visitor use than the Wilderness
Tract. In addition, the Exchange Tract is located on a narrower part of
the island, which would potentially make any concentrated development
much more noticeable to visitors.

[Cumulative Impacts]{.underline}. A number of private residences already
exist on Cumberland Island. Should additional development occur, as is
possible under this alternative, it would substantially increase (on a
percentage basis) the number of residents on the island. Any development
of the Exchange Tract would be closer to principal visitor use areas
than development on the Wilderness Tract. As a result, the contribution
of this alternative to cumulative impacts would be minor to moderate in
intensity, long-term, and adverse.

[Conclusion]{.underline}. If Greyfield or a subsequent owner decided to
develop the Exchange Tract, impacts to visitor use and experience would
be minor to moderate in intensity, long term and adverse. Long-term
protection of the Wilderness Tract would result in beneficial impacts to
wilderness visitors. Impacts to visitor use and experience from
protection of the Wilderness Tract would be minor to moderate in
intensity, long term and beneficial.

**5.7.8 SEASHORE OPERATIONS**

### **Effects of Alternative A**

### 

[Analysis]{.underline}. Under Alternative A, the National Park Service
would not pursue the land exchange. If Greyfield or a subsequent owner
decided to develop the Wilderness Tract, the result would be additional
residents and vehicular trips on the island. The amount of work required
of National Park Service staff to monitor retained rights and enforce
driving restrictions would increase accordingly.

[Cumulative Impacts.]{.underline} The National Park Service already must
incur costs to patrol the island. The contribution of this alternative
to cumulative impacts would be minor, short-term, and adverse.

[Conclusion.]{.underline} Impacts to park operations from this
alternative would be minor, long-term, and adverse. The contribution of
this alternative to cumulative impacts would be minor, long-term, and
adverse.

### **Effects of Alternative B**

### 

[Analysis]{.underline}. Under Alternative B, the National Park Service
would complete the land exchange as proposed. If Greyfield or a
subsequent owner decided to develop the Exchange Tract, the result would
be additional residents and vehicular trips on the island. The amount of
work required of National Park Service staff to monitor retained rights
and enforce driving restrictions would increase accordingly.

[Cumulative Impacts.]{.underline} Same as Alternative A.

[Conclusion.]{.underline} Impacts to park operations from this
alternative would be minor, long-term, and adverse. The contribution of
this alternative to cumulative impacts would be minor, long-term, and
adverse.

**6.0 CONSULTATION AND COORDINATION**

**Agencies and Organizations**

Governments, agencies and organizations that will review and comment
upon this environmental assessment include:

[American Indian Tribes]{.underline}

Catawba Nation

Cherokee Nation

Chickasaw Nation

Creek Nation

Eastern Band of Cherokee Indians

Kialegee Tribal Town

Muscogee (Creek) Nation

Poarch Creek Indians

Seminole Nation of Oklahoma

Seminole Tribe of Florida

Thlopthlocco Tribal Town

United Keetoowah Band of Cherokee Indians

In accordance with Federal regulations implementing Section 106 of the
National Historic Preservation Act of 1966, as amended, the National
park Service will consult with federally recognized American Indian
tribes (36 CFR 800.2) on a government-to-government basis, as specified
in Executive Order 13175. The National Park Service will consider and
address comments of the Tribal Historic Preservation Officers pertaining
to project impacts on historic properties of interest to affiliated
tribes.

[Federal Agencies]{.underline}

### U.S. Department of the Interior -- Fish and Wildlife Service

### Advisory Council on Historic Preservation

[State Agencies]{.underline}

Georgia Department of Natural Resources, Wildlife Resources Division

Georgia Department of Natural Resources, Office of State Historic
Preservation Officer

In accordance with 36 CFR 800, and the 1995 programmatic agreement among
the National Park Service, the National Conference of State Historic
Preservation Officers, and the Advisory Council on Historic
Preservation, the National Park Service will consider and address
comments of the SHPO pertaining to project impacts on historic
properties.

[Local Governments]{.underline}

### Camden County Commission

City of St. Marys, Georgia

Fernandina Beach, Florida

####### 

####### 

####### Principal Preparer 

####### 

####### Mark Kinzer, Environmental Protection Specialist, Southeast Regional Office, Atlanta

####### 

####### Contributors

### Andy Ferguson, Management Analyst**,** Cumberland Island National Seashore 

### John Fry, Natural Resources Manager, Cumberland Island National Seashore

### Richard Sussman, Chief, Planning and Compliance Division, Southeast Regional Office, Atlanta

James Strotman, Chief, Land Resources Program Center, Southeast Regional
Office, Atlanta

Tony Paredes, Cultural Anthropologist, Southeast Regional Office,
Atlanta

####### Recipients of the Environmental Assessment

For a list of individuals and other agencies receiving this
environmental assessment, please contact Cumberland Island National
Seashore.

## Selected References

Bullard, M.R. 1995. Robert Stafford of Cumberland: Growth of a Planter.
University of Georgia Press, Athens.

Hillestad, H. et al. 1975. The Ecology of Cumberland Island National
Seashore, Camden County, Georgia. Georgia Marine Sci. Center Tech. Rpt.
Series 75-5, Univ. of Georgia, Skidaway Island, Georgia. 299 pp.

Kirkland & Company. 2000. Appraisal Report on Tract 02-212 (52.2 acres)
and Tract 02-213 (68.3 acres) on Cumberland Island, Camden County,
Georgia for National Park Service as of October 14, 2000.

### National Park Service. 2000. Draft Wilderness Management Plan.

2000. Draft Cultural Resource Management Plan.

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2000. Draft Natural Resource Management Plan.

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2000. Draft Commercial Services Plan.

1994\. Natural Resource Management Plan.

1984\. General Management Plan.

Southeastern Archeological Center (SEAC). 2003. Trip report on shovel
testing of land section 02-213 Cumberland Island National Seashore
(CUIS) to be exchanged for land section 02-212, June 4 -- June 17, 2003;
SEAC ACC. 1845.

Torres, L. 1977. Historical Research Study for Cumberland Island
National Seashore. Denver Service Center, Denver Colorado. 348pp.