By Andrew H. Ernst, published on April 2, 1992, in The Journal of Environmental Permitting 1, no. 2 (Spring 1992).
Coauthored with Richard D. Knowlton, president and chief executive officer of the Savannah Economic Development Authority (SEDA).
Originally printed in The Journal of Environmental Permitting, Vol. 1, No. 2, Spring 1992.
The Savannah Economic Development Authority(SEDA) recently received a “first of a kind” 404 permit from the U.S. Corps of Engineers for a 1,784-acre business park based on environmental factors that affect property rather than on typical land use patterns. SEDA formed a team consisting of an engineering firm, an environmental lawyer, an environmental engineer, conservation groups, including the Georgia Conservancy, and local citizens to develop the plan and consulted with the Environmental Protection Agency and the U.S. Army Corps of Engineers prior to submission of the permit to the Corps.
Chatham County, Georgia, was recently the focus of a “first of its kind” permitting accomplishment. This area of coastal Georgia, like many other coastal areas around the nation, bore the brunt of the push toward greater federal protection of wetlands—a push which, to date, has been spearheaded by the legislative and regulatory requirements of Section 404 of the Clean Water Act. This permitting saga describes an attempt, ultimately successful, by various parties working together in an unusual coalition to (1) secure large-scale commercial development of an area, (2) meet the economic needs of the regional community, and (3) strike a balance that appropriately recognizes the wetland protection philosophies embodied in the Section 404 program.
In the mid-1980s, the Savannah Economic Development Authority (SEDA), then named the Savannah Port Authority, began to realize that the City of Savannah and surrounding area needed a regional business park with large, fully developed sites in order to successfully attract large businesses and industry. SEDA is the organization with the leadership role to recruit new industry into the Savannah community. Early in 1986 two companies notified SEDA that they would consider the Savannah area as a potential location for their planned projects if the community was able to meet certain locational criteria. The locational criteria were detailed and demanding.
In pursuing its goal of securing appropriate sites for industrial development, SEDA took these criteria, expanded them, and developed site criteria for a regional industrial park. Thus began the planning and development of what eventually came to be known as the Crossroads Business Center (CBC).
Due to coastal Georgia’s preponderance of jurisdictional wetlands, even before the jurisdictional expansion accomplished by implementation of the Federal Manual for Identifying and Delineating Jurisdictional Wetlands, Section 404 permitting was pushed to the forefront of CBC’s planning and analysis phase. After implementation of the Federal Manual in 1989, SEDA realized even more fully that the only way to keep the CBC project economically viable and attractive for new business was to seek a comprehensive Section 404 permit for the entire project (consisting of 1,700 to 1,800 acres), much of which would be classified as wetlands under the jurisdiction of the U.S. Army Corps of Engineers. Such a permit, SEDA believed, would provide a necessary degree of certainty to prospective businesses desiring to relocate in the area.
After much planning and pre-application consultation with regulatory agencies and industrial and environmental groups, the permit application for CBC was submitted on February 14, 1991, and 155 days later, on July 19, 1991, the Section 404 permit was issued by the Corps. Because of the unique nature of the permit, the Corps held a national press conference on August 14, 1991, at the Washington Press Club to unveil and describe the Crossroads permit. This article describes the project history leading to the decision to seek a comprehensive 404 permit and further describes the hurdles that were overcome to achieve the permit itself.
PROJECT HISTORY AND PLANNING
A detailed analysis and review was made of all large sites in Chatham County that could meet the majority of the locational criteria described below. Site data was obtained on each location under consideration. Property owners were contacted to determine which sites would in fact be available and a list of potential sites was compiled. The two companies that assisted SEDA in compiling the site criteria were again consulted for the purpose of analyzing the data collected for each potential site.
Based upon the criteria, a large tract of land owned by Union Camp Corporation and located in western Chatham County adjacent to Godley Road was identified. The Godley Road Tract was found to be the most appropriate location for a large business park. The site was chosen for a variety of reasons:
* It consisted of approximately 2,000 acres.
* There was a lack of residential development in the area, and the property could easily be rezoned “heavy industrial.”
* The property was contiguous.
* It was within seven miles of the City of Savannah.
* It was owned by a single company.
* Hook-up to existing municipal water and sewer systems was possible.
* The site was isolated, with natural buffers on all sides.
* It was adjacent to the Savannah International Airport
* A natural gas service main crossed the property.
* The site was traversed by and service could be provided by two separate rail companies.
* It was adjacent to an interstate highway and would have an interchange at the site.
* It was within five miles of the port of Savannah, with existing tank storage and rail and tank-truck service.
In August of 1986, SEDA entered into negotiations with Union Camp Corporation to acquire up to two thousand acres of the Godley Tract. In September of 1986, appraisals were made of the value of the property. In December of 1986, the parameters of the sale were established and agreed to by both the Savannah Economic Development Authority and Union Camp.
Development planning started in the fall of 1986. An analysis of community-owned industrial parks throughout the southeast showed that the new industrial park would need to serve many markets rather than strictly serve as a location for heavy industry. SEDA determined that the new park needed to be developed in such a way that it could serve multi-use functions including corporate office, assembly, distribution, and research uses, as well as manufacturing.
Established industrial and business parks in Florida, Georgia, North Carolina, South Carolina, and Virginia were visited between March and November of 1987. After SEDA’s review of such areas, it was determined that Technology Park, Deerwood Park, Quadrangle Park, Central Florida Research Park, Orlando Central Park, Research Triangle Park, and other industrial parks in the Charlotte area were examples of the types of atmosphere and facilities SEDA hoped to create at the Crossroads Business Center. Analysis of Savannah’s potential, and of the types of businesses that had previously considered Savannah as a location, indicated the establishment of a “Class A” park would be most advantageous and desirable from a community perspective.
Use of existing environmental characteristics
From the beginning, SEDA instructed its consultants to utilize the existing environmental attributes of the land to enhance the atmosphere of the park. Land was to remain natural and habitats were to be preserved by the use of open space. In June of 1987, a detailed memo defining the project was provided to SEDA’s Board of Directors and regular briefings were held after that time. Through July of 1987, SEDA and its consultants had numerous meetings in which plan revisions were made.
Because of SEDA’s desire to create an environmentally sensitive and attractive project, additional criteria were developed in July of 1987. SEDA determined that the park should remain heavily wooded; the user of one parcel should not be able to see the user of an adjacent tract; the properties should be well landscaped; the existing water amenities should be utilized wherever possible; and well-planned internal access roads for both cars and trucks should be used on every parcel if possible. SEDA began to prepare sign criteria, covenants, and restrictions for the park. The National Association of Office and Industrial Parks was contacted to obtain sample covenants of parks throughout the country that might be utilized for the CBC project. A revised land use plan was prepared with the goal of utilizing the unique assets of approximately eighteen hundred acres of the Godley Road tract. The focus was on creating locations for multiple types of business in a large, low-density park with a sensitive approach to environmental concerns.
By November of 1987, it was clear that multiple governments would benefit from the development of the business center. Discussions and briefings were held with Chatham County, City of Savannah (and its Metropolitan Planning Commission), City of Pooler, City of Port Wentworth, Garden City, and the State of Georgia to discuss the development and to determine how the extension of infrastructure could best be accomplished. In December of 1987, to assure proper planning in west Chatham County, the Metropolitan Planning Commission (MPC) requested development of data regarding estimated future traffic and road needs in the CBC project area.
Throughout the planning period, a number of additional businesses considered locating in Chatham County. Two such businesses required close proximity to airport runways, and discussions were held in September 1987 with the Savannah International Airport to assure that direct “fly-in-fly-out” access could be made available for companies considering the CBC site, which is immediately adjacent to the Savannah International Airport.
As plans for the Crossroads Business Center continued, discussions focused on how to best integrate the multiple projects under consideration in the region, including the proposed Savannah International Airport expansion, ongoing expansion of Savannah Quarters (an upscale residential development) ongoing port expansion planned by the Georgia Ports Authority, and development of the Crossroads Business Center. With the recommendation of SEDA’s local engineering consultant, SEDA joined with the Georgia Ports Authority to perform a traffic analysis of the western portion of Chatham County.
Planning of the entire westside area, including SEDA’s project, began. A local consultant was hired to perform soil tests at three locations within the property in April of 1988. In mid-1988, SEDA’s Board approved the new conceptual plan for development of the Crossroads Business Center and performed a financial feasibility analysis of the revised project. In December of 1988, the analysis confirmed that the project was economically viable. The report also confirmed the desirability of the “Class A Business Center” concept from a marketing perspective. So marketing planning began.
In 1989 additional companies with large projects considered locating in Chatham County. Individual site plans were prepared for these companies, but none chose Savannah because the area was not yet able to offer development sites or to assure that environmental permits could be obtained. This underscored the fact that it was necessary to have large sites available for construction in order to compete for recruitment of new industry. SEDA realized that the attraction of potential businesses to the Savannah area was critically linked to large-scale, long-range development planning, including efforts to secure necessary permits and zoning changes in advance, to make the regional transition “convenient” for business.
Infrastructure plans for CBC continued to be developed and were reviewed with all municipal governments as individual companies considered locating in the Crossroads Business Center. Plans were approved to include funding, by means of a local one-cent sales tax increase referendum, for the construction of the Jimmy Deloach Parkway, an important west-side connector road vital to the project. The community, in a show of support, approved the referendum funding the road construction project in July of 1989 by a three-to-one mandate.
THE NEW FEDERAL MANUAL: A NEW WETLAND DILEMMA
In early 1990, SEDA became aware of new wetland interpretations found in the Federal Manual that went into effect in March of 1989 and could affect the community’s business center development. The initial plan for the project, created in early 1987, recognized that approximately 35 percent of the property could be considered jurisdictional wetlands. The property could initial plan had avoided and minimized impacts to these wetlands. But in reviewing the potential impact of the new wetlands interpretations pursuant to the 1989 Federal Manual, SEDA concluded that the economic viability of the park was in jeopardy. According to the new manual, the jurisdictional wetland areas within the CBC almost doubled. In fact, it was estimated that approximately 80 percent of all of Chatham County could now be deemed jurisdictional wetlands under the new interpretations.
Section 404 Affects Land Use Decisions
It was also about this time that a large international company planning an initial investment of $60 million and employment of eight hundred people in the southeast contacted SEDA expressing interest in the community as a possible location for its new manufacturing facility and corporate headquarters. The company required a fully developed, two hundred acre site. During the company’s investigation of Savannah, SEDA briefed company representatives on all sites in the area that met their criteria. The company was aware of the Corps’ expanded wetlands jurisdiction and the probability that a Section 404 permit would be required at virtually any site within Chatham County.
The firm indicated that its large-scale industrial project would require multiple permits of all types from the federal government and the company was in a position to comply with any and all regulations. Moreover, the company expressed specific interest in CBC and indicated they favored environmental protections and would support proposed covenants for CBC that required conservation, recycling cooling waters, and enhancing wetlands on their site. The company, however, was very troubled by the uncertainty of the Section 404 permitting process in the coastal area of Georgia and the potentially long processing time required. In light of the uncertainty and confusion generated by the new federal wetland policies, the company wanted assurances regarding compliance with Section 404 requirements. Such assurances were important to the company from an economic analysis and planning perspective.
The company indicated that unless they could receive a specific and definitive opinion as to the regulatory requirements prior to acquiring the site, they could not consider Savannah as the location of either their manufacturing facility or corporate headquarters. In October of 1990, the company informed SEDA they would locate in another community because of the increased uncertainty surrounding the Section 404 permitting process. SEDA, as well as the district office of the U.S. Army Corps of Engineers, had been unable to inform the interested company with certainty regarding how long it would take to complete the permitting process. The company was also concerned about what mitigation requirements might be contained in a permit, if issued, to offset unavoidable wetland impacts. Faced with these unascertainable delays and uncertain costs, the company simply elected to locate in another area where “wetlands” were less of a problem.
SEDA became concerned that years of work, staff time, and substantial expenses and obligations connected with CBC would have to be discarded because of the potential difficulties posed by Section 404 permitting. Although the original plans had recognized the need for protection of wetlands with buffers and open spaces, SEDA now questioned whether any business with a large project would seriously consider investing in the Savannah community in light of the new Federal Manual.
Advance Section 404 Permitting Can Assure Business
One conclusion was evident: The only way SEDA could address the wetland issue and provide certainty to prospective businesses was to accomplish required Section 404 permitting in advance. Once this was accomplished, SEDA could assure a business that it could use a development parcel in the Crossroads Business Center, provided the business could comply with the stated permit conditions. It became apparent that SEDA would have to create a master plan that could meet the environmental objectives of the 404 permitting process and still be practical from a development perspective.
SEDA decided to set aside previous plans for the project and to develop a new concept. SEDA established a team of consultants to assist in reevaluating the proposed business park and to coordinate with the Union Camp Corporation.
The site selection process began anew and the development team was given the challenge of creating a business park with the same quality standards previously desired, but using environmental criteria as the principal planning constraints. The development team was directed to assess locations for new businesses within the community that would have the least potential impact from all environmental perspectives. After reviewing all the data available, the development team determined that the Godley Road Tract was still the preferred site from an environmental standpoint.
Site Instead of Parcel Permitting
During May through December of 1990, SEDA spoke with numerous organizations to determine how it might proceed with development of the Crossroads Business Center. The goal was to fill the community’s need for large-scale sites and, at the same time, to do so in an environmentally sensitive manner. During pre-application meetings with the Corps of Engineers, EPA, The Georgia Conservancy, citizens’ committees, potential park users, and other groups, the concept of a general permit for the entire tract was discussed. Most groups responded favorably to the idea. SEDA, EPA, The Georgia Conservancy, and the Corps all became convinced that, from an environmental standpoint, the overall permitting of a large tract that incorporated a sensitive environmental design would be preferable to the piecemeal permitting of small, individual parcels. Thus, SEDA’s concept of a single permit for the Crossroads Business Center began to take shape. The development team, along with the Corps, recognized that a permit of this type would probably be a first of its kind. Previously, permits for industrial sites had been permitted on a site-by-site basis depending on the specific industrial use.
As a result of reviewing previous projects, SEDA’s development team determined that a series of impact areas would be created within the park. Most large projects might require a site consisting of 150-350 acres, but the acreage that would actually be disturbed for construction of a facility was more often in the range of 50-100 acres. SEDA decided the CBC design would generally contain 50-to-75-acre impact areas where facilities could be built.
Eliminating the Confrontational Atmosphere
Conceptual plans for the park changed many times in order to limit the impact on wetlands. SEDA’s Board reviewed the new plans and enthusiastically adopted the concept. SEDA strove to create a park that was sound from an environmental perspective, an economic perspective, and a land use and engineering perspective. This concept, SEDA believed, would best serve local, regional, and national interests, while potentially eliminating the confrontational atmosphere often present between environmental interests and economic development interests.
The development team analyzed the eighteen hundred-acre tract, identifying development locations that avoided and minimized wetland impacts to the greatest degree practicable. Soils analyses were prepared and efforts were made to identify upland areas. Maps of the existing pine plantings were made to indicate the recent history of the land. Wetland determinations were made of the property. An endangered species review was made and no endangered species were found on the property. An overall environmental assessment was prepared of the site.
One of the factors influencing the initial CRC site selection had been the National Wetland Inventory (NWI) maps for the area. Although these maps were not intended for jurisdictional determinations, they were used for preliminary planning purposes. According to the NWI maps, the majority of the site was not wetland. However, anticipating the impact of the Federal Manual and its new regulatory guidance, it was entirely possible that up to 1,323 acres of the CBC project area could be characterized as wetlands although scattered upland areas were found within the project site. These upland areas were utilized to the greatest extent possible and, using this information, SEDA’s engineers prepared a master plan for CRC consisting of eleven sites with twelve impact zones.
SEDA also adopted a conservative stance when preparing its permit application in an effort to avoid extended delay and confrontation with the regulatory agencies. SEDA decided to assume for purposes of its Section 404 permit application that the majority of the planted pine plantation located within the site was jurisdictional under the new Federal Manual. This was done despite the fact that such a broad regulatory interpretation might be legally questionable and the new Federal Manual was under attack throughout the country.
Establishing Available Parcels
Taking advantage of the scattered islands of uplands, SEDA’s plan envisioned 12 development parcels consisting of a total of 580 acres. Of this 580 acres, an estimated 2 acres was clearly jurisdictional and delineated on the NWI maps. Planted pine plantations, conceded to be jurisdictional, resulted in another 340 acres of possible wetlands impact. The remaining 238 acres contained within the development parcels were clearly upland areas and nonjurisdictional.
The remainder of the business park, consisting of 1,130 acres, was to remain undisturbed. This acreage was composed of 718 acres of pine plantation, 263 acres of wetlands as shown by NWI maps, and 149 acres of upland area. SEDA, striving to protect the economic viability of the project but recognizing the values and benefits generally attributed to wetlands, then developed a plan to offset the potential adverse wetland impacts associated with the project.
In order to understand the value of the mitigation plan developed by SEDA, it is first necessary to understand the ecological values and differences existing between a hardwood wetland community and a planted pine community.
Hardwood wetland communities exist as linear drainage ways or as discrete depressional areas within the project site. The species composition of the hardwood areas is typically mature and diverse including tupelo, red maple, bald cypress, sweetgum, and water oak. In addition to the forested, hardwood wetland communities that occur on-site, much of the project area is characterized by transitional pine flatwoods or pine plantation communities. Through normal silvicultural activities, pine plantations have been established on bedding rows within poorly drained portions of the site, resulting in a monoculture of slash pine. These areas have been clear-cut, usually on a twenty-five-year rotation, which has not allowed native communities to mature. The pine plantation exhibits relatively low habitat diversity, which results in low species diversity in both plant and animal species. The forested hardwood communities, on the other hand, exhibit higher habitat diversity and a regular hydrologic regime, resulting in normally high concentrations of wildlife in both species and numbers of individuals. It has been found by many that hardwood forests typically support two to five times the wildlife populations of coniferous forests.
The diversity of hardwood bottomlands provides greater sources of food, escape cover, protection from inclement weather, and reproductive habitat. Low and mid-story vegetation are common and tree form is unique, unlike pine plantations. Diversity results from a variety of plant species providing food at different times of the year. This also assures that if one crop fails, another is likely to be successful. Bottomland hardwood forests also provide shelter and living space not found in pine plantations. Snags that are standing dead or dying trees that provide perching and nesting sites for various animals are also rich in insects. Cavities found in the wood of standing or fallen trees are very important to wildlife. Few cavities typically occur in pine trees because of their greater fire resistance and high resin content.
Offsetting Wetland Impacts
To offset wetland impacts associated with the project, SEDA proposed the preservation of 263 acres of forested hardwood wetlands on-site and the enhancement of an additional 718 acres of former hardwood areas on-site that, over the years, had been converted to a planted pine plantation. SEDA’s plan called for the enhancement to be accomplished by selectively thinning the pine plantation to an average density of fifty stems per acre. This would encourage the return of native hardwood wetland species found in the subcanopy and should increase habitat diversity. Species presently found in the subcanopy include red maple, sweetgum, black gum, water oak, wax myrtle, sweet pepperbush, gailberry, and cinnamon fern. SEDA’s plan would foster the development of a community comparable to that of the adjacent wetlands, allowing for the maturation of native communities, increased habitat diversity, and increased species diversity and abundance of both plants and animals. Upland areas scattered throughout this transitional community would be retained in their current state to provide additional diversity. Also, a 50-foot buffer surrounding the hardwood wetlands would be left intact with no physical disturbance. The proposed blockage of existing drainage ways within the planted pine areas would also do much to restore the hydrology of the area.
Through a combination of preservation and enhancement, SEDA’s mitigation plan would allow the conservation of a large tract of forested land and the restoration of more natural wetland vegetative communities. The enhancement measures would provide new habitat potential and the preservation would create significant forested wildlife corridors throughout the project area. SEDA’s proposal would encourage new wildlife utilization and would maintain appropriate habitat to support the current wildlife populations. For these reasons, SEDA’s plan was approved by the regulatory agencies and strongly supported by such groups as The Georgia Conservancy.
A WELL-PLANNED APPLICATION
As mentioned, SEDA was able to obtain its Section 404 permit from the Corps within 155 days of the date the application was initially filed. This in itself was quite a feat considering the substantial size and nature of the project. Undoubtedly the Corps’ review process was shortened significantly because of the tremendous amounts of data and support documentation prepared by SEDA prior to submitting its application to the Corps.
The application was filed in February of 1991, and it was accompanied by a bound volume of support documentation that contained such items as (1) wetland maps and field data sheets; (2) an endangered species survey; (3) a preliminary environmental assessment of the site; (4) a detailed analysis describing the Crossroads Business Center site selection process; (5) jurisdictional determination maps; (6) permit evaluation factors; (7) a proposed mitigation plan; (8) a cultural resource assessment of the site; and (9) zoning documentation associated with the recent rezoning of the property from “R-A” (ResidentiaL/Agricultural) to “P-H-I” (Planned Heavy Industrial).
The support documentation also contained a detailed analysis of the site selection process pursuant to Section 404(b)(1) guidelines. Through such documentation, SEDA was able to demonstrate to the agencies that alternative siting had been considered pursuant to the guidelines and that the Godley Road tract was the best site for the project from an environmental standpoint.
Corps Public Interest Review Factors
The general regulatory policies of the Corps of Engineers also define a number of factors that are integral to the evaluation of a dredge and fill permit application. These issues, often referred to as the “public interest review factors” include such matters as conservation, economics, aesthetics, general environmental concerns, wetlands, historic resources, fish and wildlife values, flood hazards, flood plain values, land use, navigation, shoreline erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, considerations for property ownership, and finally the needs and welfare of the people. SEDA’s support documentation contained a detailed discussion of the project and its impact on each of these factors. In short, SEDA made every effort to supply the agencies up front with all the necessary documentation required for review of the permit application.
Although the response to SEDA’s permit application and development plan was generally favorable, certain obstacles were presented during the permitting process. EPA and the Corps were basically supportive of SEDA’s proposed plan, provided that sufficient safeguards such as conservation easements and stringent restrictive covenants were put in place to ensure compliance with the mitigation plan’s conservation and enhancement objectives.
One of the commenting agencies, however, did have some reservations about SEDA’s permit application for the CBC project. This agency was concerned not with the adequacy of the proposed mitigation plan, but with SEDA’s inability to identify in advance the exact business or industry that would be allowed to locate in CBC. Yet, the purpose of SEDA’s advance planning was to allow for future development with appropriate environmental safeguards. And until the uncertainties surrounding the Section 404 permitting process were resolved, SEDA was certain it would be all but impossible to convince viable businesses to locate in the area. SEDA was, however, able to identify the general types of businesses that might locate in the park.
Perhaps SEDA’s largest hurdle in the permitting process was convincing the Corps and the other regulatory agencies that attempts to regulate types of “land use” were improper because not only would each prospective industry be subject to local zoning controls, but each industry and business would also be subject to myriad other state and federal laws regulating such aspects of the environment as waste disposal and soil, water, and air pollution, in the end, SEDA was able to convince the Corps that its proposed CBC project complied with Section 404, that the permit should be granted, and that compliance by each user of the park with other state and federal environmental laws would also serve to sufficiently protect and safeguard the environment.
HELPFUL HINTS IN THE PERMITTING PROCESS
SEDA is quick to point out that the permitting strategy utilized for development of the Crossroads Business Center may not work for every developer. It is SEDA’s function to foster industrial development and secure available sites for industrial location. The purpose of the organization is to bring about economic development, jobs, and the betterment of the community, not necessarily to make a profit. Because of this, maximum land utilization of the entire 1,784-acre site was not necessarily SEDA’s primary concern. The design concept of utilizing heavy buffers and conservation easements may not always work from an economic standpoint in the world of private development. However, it had been SEDA’s goal from the beginning to have an environmentally sensitive park that would utilize many of the environmental concepts contained in the final Corps permit, even if those environmental concepts had not become regulatory requirements.
In all likelihood, one of the major factors contributing to SEDA’s success was its willingness to work as a partner with representatives of the Corps, the Environmental Protection Agency, and private conservation groups such as The Georgia Conservancy. The willingness of SEDA to seriously consider and incorporate suggestions from these groups did much to convince the regulatory agencies that the applicant was sincere in its desire to create an environmentally sensitive project. Thus, the confrontational atmosphere that often surrounds such projects was avoided.
SEDA also put together a well-trained and well-disciplined development team, which systematically developed a pre-application strategy of meeting with the regulatory agencies and concerned citizens groups prior to the actual filing of the application, negating any controversy that might have surrounded the application. SEDA’s development team also generated tremendous amounts of support documentation regarding the project which, when presented with the application, made the Corps’ job in reviewing the application much easier.
SEDA’s dream of a large, multi-use business/industrial park with fully permitted development parcels is now well on its way to becoming a reality. Presently, at least two major businesses are seriously considering locating within the park. SEDA could not afford to wait and see if a change in the new regulations would occur. The need for developed sites was immediate and SEDA was determined to find a workable solution to the problem within the present regulations and procedures.
As recently stated by the Vice President of The Georgia Conservancy, “This has been a very innovative approach to development in an area that contains a large portion of wetlands. “We congratulate SEDA for proving that the process will work if you do some key things.”
Richard D. Knowlton is president and chief executive officer of the Savannah Economic Development Authority (SEDA), which was named one of the top ten development groups in the United States. He is a certified industrial developer, has been in the economic development field since 1970, and is a member of the American Coastal Conservation. Andrew H. Ernst heads the environmental law section of the Savannah firm of Hunter, Maclean, Exley & Dunn, P.D. and practices primarily in areas relating to environmental regulation with particular emphasis on Section 404 of the Clean Water Act, real estate acquisition, development, and land planning.