ATC Blog

Goal 2: Coastal Management and Conservation (Goal 5 in Fernandina Beach 2030 Comp Plan)

The Comp Plan/LDC Working Group is a group of citizens who are working together to provide input on the Fernandina Beach Comprehensive Plan and Land Development Code and then on the Nassau County Comprehensive Plan and Land Development Code. These documents are critical for the future of Amelia Island. This group was formed by Amelia Tree Conservancy; however, its composition is broader and it represents a far broader scope of interests and concerns. We will soon be posting all of the Goals except for School Facilities and the Port. Because we were requested to provide our draft on this goal to the Planning Advisory Committee as they begin working on the Comp Plan, we are posting our Introduction and Goal 2 in advance of the other goals. 

The Comp Plan/LDC Working Group does not perceive these drafts to be the final product of the Comprehensive Plan, but rather a working draft. Development of the Comprehensive Plan must be a process that brings together the world views of our diverse community of stakeholders. We represent some of these perspectives, but certainly not all. We look forward to discussing what we have developed thus far and look forward to your input.

To view the entire Coastal Management draft please click here.

Notes on Goal 2 (formerly Goal 5)

Goal 2 Coastal Management and Conservation (the 2030 Goal 5) has been rearranged in an attempt to match the challenges the City faces in the future. The context is summarized in the introduction to this Goal. The following notes address anticipated questions:

  • In a complex process like updating the Comprehensive Plan, it is fundamental that the City and community decide on the content of the plan for the future prior to investing a lot of time in how we craft the writing of the document. We made changes in organization when we felt they impacted comprehension of our intent, but left most of the previous text intact.
  • The Comp Plan/LDC Working Group is well aware of the problem of length in Goal 2. However, the above consideration and the following issues persuaded us to leave it as it is right now:
    • It would be relatively easy to divide Goal 2 into two goals, coastal management and general conservation objectives. However, in writing the 2030 goals, the PAB team decided to combine these previously separate goals. We suspect that one of the reasons was to demonstrate the relationship between coastal management and conservation needs and objectives–certainly a valid consideration. If these goals become separate, we need to make certain that the community understands the interrelationships between these goals. There may be other ways to break this out into separate goals that we have not thought of yet because we are in the early stages of this process.
    • The Comp Plan/LDC Working Group has deleted very little from the 2030 plan for fear of opening up unforeseen loopholes in the Plan. Once the final content is determined, it should be easier to delete unnecessary or redundant material.
  • The proposal to create a combined position for Floodplain Manager and Chief Resilience Officer should not be interpreted as implying any negative perceptions regarding Steve Beckman’s performance as Floodplain Manager. In fact, we have been impressed with his efforts to make City policy consistent with FEMA standards and with his insistence on monitoring building projects. We view this plan as looking forward to addressing our needs and as building on what has been done to date. In practice, someone with the specified credentials could be hired initially for the combined position, or someone currently on staff could take on this combined role. The initial combination of the positions could eventually evolve into two positions when needs justify that change.
  • The importance of long-term planning and the planning of incremental rollout cannot be overstated in addressing coastal management at the current time. How this will be done remains to be seen, but it is essential.

Comp Plan/LDC Working Group

Beth Foster, Pam Green, Lauree Hemke, Betsie Huben, Christine Joblon, Ann Kemp, Margaret Kirkland, Alexandra Lajoux, Pat Moore, Lyn Pannone,Helen Perry and Shameera Wiest

Recent Nassau County Vulnerability Study Results

Maps that may be helpful:

County Appraisers Maps: 1) Look at the Storm Surge and Coastal Construction Control Line (CCCL) under Safety. 2) Look at the Flood Maps

Fernandina Beach: These are the maps included with the current Comp Plan in 2020.

Fernandina Beach Comp Plan PAB Slides & Draft Introduction

Introduction to the 2045 Comprehensive Plan

The Comp Plan/LDC Working Group is a group of citizens who are working together to provide input on the Fernandina Beach Comprehensive Plan and Land Development Code and then on the Nassau County Comprehensive Plan and Land Development Code. These documents constitute the legal framework for the City and County and therefore are critical for the future of Amelia Island and the rest of the County. This group was formed by Amelia Tree Conservancy; however, its composition is broader and it represents a far broader scope of interests, affiliations and concerns. In working through revisions of the City Comprehensive Plan, our current focus, City staff will be seeking input from all residents; we represent one set of perspectives within that array. 

This post is the first in a series of thirteen posts that present our work to date. We are looking forward to your feedback and input. We believe it is healthy for the City for citizens to understand a variety of perspectives on the Plan. We are planning a series of Zoom meetings that will include presentations and discussion/feedback periods. This first post includes 1) the slides associated with the presentation we made at the Planning Advisory Board meeting on February 10, 2021, when we submitted our draft, and 2) our introduction to the draft Comp Plan.

Thus, our posts in this series will cover the following drafts:

  • The PowerPoint slides from the February 10 Planning Advisory Board meeting) and our draft Introduction to the Comprehensive Plan
  • Goal 1: Restoration of Public Trust
  • Goal 2: Coastal Management and Conservation
  • Goal 3: Recreation and Open Space
  • Goal 4: Historic Preservation
  • Goal 5: Housing
  • Goal 6: Mobility
  • Goal 7: Public Facilities
  • Goal 9: Economic Development
  • Goal 11: Capital Improvement
  • Goal 12: Future Land Use

The following goals are not included in these drafts:

  • Goal 8: School Facilities (because it is limited to facilities)
  • Goal 10: Port (because it needs to be dealt with through different channels)
  • Goal 13: Intergovernmental coordination (because it is so early in the process of writing this document. Each of the goals included in the draft has considerable material detailing this topic and a section on intergovernmental coordination at the end of the goal related to that goal.

In the process of researching each goal, we have sought input from those in our community who have relevant expertise. Our group is deeply grateful to all who have participated in this process to date. Many have devoted extensive time to this effort.

The Comp Plan/LDC Working Group does not perceive these drafts to be the final product of the Comprehensive Plan, but rather a working draft. Development of the Comprehensive Plan must be a process that brings together the world views of our diverse community of stakeholders. We represent some of these perspectives, but certainly not all. We look forward to discussing what we have developed thus far and look forward to your input.

Comp Plan/LDC Working Group

Beth Foster, Pam Green, Lauree Hemke, Betsie Huben, Christine Joblon, Ann Kemp, Margaret Kirkland, Alexandra Lajoux, Pat Moore, Lyn Pannone,Helen Perry and Shameera Wiest


  1. Slides from the February 10, 2021 Planning Advisory Board meeting (our broad perspective)
  2. Introduction to the entire Comprehensive Plan draft

Comments to keep in mind as you read:

  • The broad perspective of the Working Group is presented in the slide presentation.
  • This set of documents is a working draft at this relatively early phase of the process.
  • Considerably more work needs to be done for one or more of the following reasons: 
    • We were unable to find documents listed in the 2030 Comp Plan.
    • Further expertise is needed to progress further, sometimes in planning and sometimes in specialized areas such as transportation.
    • Input is needed from a variety of perspectives.
  • We have included some policies that should actually go into the Land Development Code rather than the Comp Plan to ensure that they are not forgotten.
  • We have included some objectives and policies from the 2030 plan that may not be necessary because we are waiting for a later stage in the process to delete them in order to ensure that deletion does not create loopholes in the plan. We have deleted objectives and policies that have been replaced or that we feel confident are no longer relevant or advantageous.
  • Where we felt it was advisable, we have retained the language of the current Comp Plan. Some elements follow the current plan fairly closely, while other elements have been changed substantially.
  • This set of documents contains considerable material that will also be of interest for the County as well.

2020 Amelia Tree Conservancy

Happy New Year! We all need to be prepared for 2020. If you have not read or watched the following, please do so. These are some of the materials that ATC has distributed to key decision makers in both the City and County over the last couple of years. We all need to be familiar with this content (at least) so that we can utilize it in our communication with City and County staff and elected officials.

Materials focused on our maritime forest environment:

  • It is important that we all understand the environment in which we live. There has been very limited research on maritime forests—we have just developed them, not realizing that it is a special environment that is important for our welfare. The US Fish and Wildlife Service report Ecology of Maritime Forests of the Southern Atlantic Coast: A Community Profile is available from Amazon and online at This book focuses on the southeastern maritime forest and we fit in just on the southern end of the primary area of focus. In recent years, some states, most notably North Carolina and Georgia, have started to focus on this and are trying to conserve or rebuild their maritime forest. In the southern part of Florida, we have completely lost this environment. The parts of this book that may be most interesting to those who are not really into environmental material are chapter 1, which provides an overview and interesting information about the origin of our island; chapter 2 because it helps us understand the role of salt spray in the development of this forest; and chapter 5, which provides interesting information on exactly how development of roads and communities have impacted this environment. This is important for figuring out the best options in terms of development.
  • In case you haven’t seen it, the ATC video, “Living in our Maritime Forest” ( is another opportunity to better understand the place we have chosen to live. It features Dr. Munsell McPhillips, a member of our community and an expert in restoring degraded urban rivers and riparian forests.

Materials focused on overdevelopment:

  • Better, Not Bigger is a book we learned about when doing research during the first public input phase of the EAR last spring to update the Fernandina Beach Comprehensive Plan. The next public opportunity for input is coming up soon. Right now, the City is in the process of identifying the process they will follow. ATC has distributed this book to both City and County Commissioners, key City and County staff, particularly in Planning, and the City Planning Advisory Board members and County Planning and Zoning Commission members (at the request of the County Director of Planning and Economic Opportunity). This is an effort to develop an understanding of the fact that there are different ways to think about development and that many of our assumptions about development are based on our culture and education, not necessarily on fact. For example, we have all been raised and educated to believe that development (in terms of expansion) is inevitable. This is not necessarily true, nor is it a road to success, as many municipalities discovered after they overdeveloped–our country is full of examples. We have also been educated to believe that development is essential to expand our tax revenue. However, residential development requires more infrastructure and services, which cost more than the associated tax revenue. The most recent numbers for Nassau County indicate that infrastructure and services to support residential development cost 1.75 times the tax revenue from that development. The previous year the cost was 1.5 times the tax revenue from residential development. So, we need to reexamine our assumptions regarding development and utilize methods of managing it so that our development is smarter, contributes to our quality of life and is in line with future sustainability. This little book provides a number of strategies that have been utilized by other municipalities. Some of these have also been used by our city and county, so there is something here that community leaders can relate to. This book is not new, but is so concise that anyone can get something out of it with limited reading time. It is available from Amazon.
  • We live in a time when people are bailing out of urban areas, choosing to live in and vacation in small towns and rural areas. We need to be sure the characteristics of our island are not destroyed because they are part of our “sense of place,” natural and manmade characteristics of a community that make it unique and attractive. The TED Talk by Edward McMahon, who holds the Charles E. Fraser Chair on Sustainable Development at the Urban Land Institute in Washington, DC, summarizes the importance of these features for our economic future:

If you have materials you would like to recommend, please post them to our Facebook Public Group (many of you have posted very useful materials) or email them to If you are interested in reading more on particular topics, let us know.

Local organizations file legal action against Fernandina Beach over Amelia Bluff

For Release:  Wednesday, May 15, 2019

From: R.M. Weintraub


 Local organizations file legal action

against Fernandina Beach over Amelia Bluff

Local environmental- and conservation-focused organizations have filed a complaint with the Florida Division of Administrative Hearings (DOAH) that the City of Fernandina Beach violated state law and the city’s Comprehensive Plan in approving the Amelia Bluff residential development on Citrona Drive.

The Amelia Tree Conservancy and the newly formed Conserve Amelia Now! are the initial plaintiffs asking for an administrative review of the city action according to the petition filed with DOAH May 14.  

The Sierra Club’s Nassau County Group will be joining the legal action as soon as required protocols with National Sierra are completed reported Julie Ferreira, Nassau Sierra chairwoman.

The plaintiffs are represented by attorney Robert C. Apgar of Tallahassee.  

The complaint lists ten state laws embodied in Florida Statutes and ten Objectives and Policies of the Fernandina Beach Comprehensive Plan that it claims were violated by the approval of the Amelia Bluff development.  

“The city commission ignored the objections of the public to the loss of this important part of our dwindling maritime forest and the development’s threat to the Egans Creek Greenway,”  Ferreira said in explaining the legal action. 

“We tried to negotiate a way out of this situation to avoid the legal costs on both sides, but we were rebuffed by the city manager and city attorney,” Ferreira said.  “They in effect said, ‘case closed’.”

The Florida Department of Administrative Hearings adjudicates administrative disputes with independent administrative law judges who conduct hearings on complaints.  It is anticipated that a hearing on the complaint will be held in Fernandina Beach in the near future. The administrative law judge typically schedules time during the hearing for public testimony. Due to the filing of this petition for administrative review, the approval of the Amelia Bluff FLUM change cannot take effect until the matter is resolved and work on the site, which has been stopped, cannot proceed.


At the crux of the issue was a conflict between the FLUM Conservation designation and an R-1 designation of the property on the city’s zoning map.  The FLUM shows a large triangle of Conservation land extending from the Egans Creek Greenway into the center of the property.

As the Comprehensive Plan is the city’s controlling law, the Amelia Bluff development, a 30-home project across Citrona from Fernandina Beach High School, could not continue unless the FLUM was changed. The developer, Amelia Bluff LLC, has acknowledged knowing about the conflict but was told by city planners it was a scrivenor’s error that would be corrected. The conservation issue never came up again in the many meetings of the city’s Technical Review Committee, Planning Advisory Board and City Commission.  At each meeting there was a staff report that included the statements that the development is “significantly compliant with the Comprehensive Plan” and is “consistent with the underlying FLUM category of low density residential.”

In November 2018 the new chairman of the PAB, Frank Santry, discovered the conflict and called attention to it. As a result, the city brought an amendment to the Future Land Use Map that would change the Conservation designation to Residential.  At three city commission meetings, hundreds of protestors overflowed city commission chambers and more than 90 speakers voiced their opposition to the FLUM change decrying the potential loss of maritime forest and danger to the Egans Creek Greenway.  Despite the overwhelming opposition, the city commission voted twice to approve the FLUM change on 3-2 votes.  Voting for the change were Mayor Johnny Miller and Commissioners Len Kreger and Phil Chapman.  Voting against the change were Commissioners Chip Ross and Mike Lednovich.

The complaint

The petition for an administrative review of the decision cites 10 violations of Florida Statutes Chapter 163 that it says make the FLUM amendment not “incompliance”with the law: 

* The amendment is part of a “use” that exceeds 10 acres, and therefore cannot be adopted pursuant to the process for a small scale amendment.  The city considered the plan change as a small scale plan amendment which has different requirements.  The Amelia Bluff development is 11.7 acres;

*  The amendment conflicts with and fails to implement the special protections of the Egan’s Creek Greenway, and thus renders the City’s comprehensive plan inconsistent;  

*  The amendment is not based upon surveys, studies, and data regarding the area, including the character of undeveloped land; 

*  The amendment does not ensure the protection of natural resources and the compatibility of adjacent land uses; 

* The amendment is inconsistent with the statutory requirements to protect water, wetlands, estuarine marshes, wildlife, and other natural and environmental resources;

* The amendment is not based on an analysis of the character of the undeveloped land, soils, topography, natural resources, and the suitability of the property for the proposed use; 

* The amendment fails to conserve or protect estuarine waters, soils and native vegetative communities, including forests, wildlife, wildlife habitat, and marine habitat;  

*  The amendment fails to protect the existing natural preservation area of the Egan’s Creek Greenway, its wetlands, and the natural functions of its wetlands.  

*  The amendment authorizes future land uses that are incompatible with the protection of the Egan’s Creek wetlands and wetland functions and fails to minimize the adverse effect and impact on wetlands.  

*  The amendment is not based on an accurate analysis of the effects of the Amelia Bluff drainage system on estuarine water quality.  

In addition, the complaint cites these ten objectives and policies in the city’s Comprehensive Plan that the city’s action violates:

*  Objective 6.05:  Open spaces shall be protected within urbanized areas for their aesthetic, health, environmental, and economic benefits.  The city shall continue to maintain standards in its land development regulations for the provision and maintenance of open space in the community, including in private developments and publicly-owned lands.

*  Policy 6.05.03 Privately-owned open space, such as those within subdivisions or PUD developments, which consist of a conservation future land use or contains environmentally sensitive lands, shall be protected through the acquisition of conservation easements.

*  Objective 6.10:  The City shall protect Egans Creek Greenway for its value as a recreational asset, for its significance as an outstanding natural resource, and for its role in providing wildlife habitat.

*  Policy 5.07.06:  The City shall consider expanding the Coastal Upland Protection Zone and implementing upland protection zones for areas adjacent to Egans Creek in order to protect and improve water quality.

*  Policy 5.07.09:  The City shall prohibit any development activity that would potentially endanger lives and/or harm property, water quality and quantity of any other valued environmental system resulting from an alteration to existing drainage structures and natural drainage patterns.

*  Policy 5.07.12: The City shall require low-impact development strategies or conservation-based landscape planning and installation, water efficient irrigation, and appropriate measures that promote conservation of water resources and reduction of non-point source pollution as part of sustainable water management for new public and private development.  New waterfront development shall be designed so that stormwater runoff and erosion are retained on-site or are channeled so as not to degrade water quality of adjacent waters .

*  Objective 5.08: The City shall direct incompatible land uses away from wetlands, and shall protect and preserve wetlands from physical and hydraulic alterations, in order to maintain the following functions:   natural biological functions including food chain production; general habitat; nesting, spawning, rearing and nesting sites for aquatic or land species; natural drainage systems impacting sedimentation patterns, salinity distribution, flushing characteristics; shielding other areas from wave action, erosion, or storm damage; storage areas for stormwater and flood waters; natural recharge areas; and natural water filtration processes that serve to purify water.

*  Policy 5.08.05 The City shall continue to ensure the protection and mitigation of wetlands…and shall ensure … land uses that have little or no adverse impact on wetlands

*  Policy 5.08.06:  The City shall protect wetlands from impacts of adjacent development, and shall ensure through regulations included in the Land Development Code:

a. Proper siting of development structures and infrastructure, including clustering of development away from wetlands;

b.  Location of buffer zones of native vegetation around wetlands and surface water bodies to prevent erosion, retard runoff, and provide habitat; and

c.  Setback of buildings and other structures from wetlands and water bodies.

*  Policy 5.08.08:  In instances in which development is proposed that is adjacent to a wetland, the boundary of a wetland transition area shall be established by an on-site field survey by a professional biologist or registered engineer provided the applicant and coordinated with the SJRWD, the DEP and/or the U.S. Army Corps of Engineers.  The City shall maintain land development regulations which ensure that the transition area provides a buffer between wetlands and upland development.  Such buffer shall ensure existing vegetation is not disturbed; where new vegetation is required, plants or ground cover native or appropriate to a wetlands transition area shall be used.

The complaint further states that the Northeast Florida Regional Policy Plan identifies the Egan’s Creek Greenway as a “Natural Resource of Regional Significance,” deserving special protection as it is part of the region’s “green infrastructure.”  The Regional Policy Plan states according to the complaint:  “In the absence of consideration of green infrastructure as a Regional system, individual development practices in Northeast Florida can have the unintended consequence of increasing the potential for storm water, pollutants, and chemicals flowing into the water supply and systems, resulting in health risks, flood damage, and increased taxpayers’ dollars to treat the water.”  

ATC 2018 Annual Business Meeting

The 2018 Annual Business Meeting of Amelia Tree Conservancy (ATC) was held on November 8 at the Fernandina Beach Golf Club. ATC has achieved several milestones this year that were cause for celebration: 1) Effective July 1, ATC incorporated as a not-for-profit in Florida and has acquired its own 501(c)3 status. Thus, it is no longer a part of NFLT, although we hope to partner with them on efforts to conserve land. 2) ATC is completing the fifth year of its effort to conserve the maritime forest canopy on Amelia Island. 3) ATC also completed its first video, which will soon be posted to our website, “The Secret Life of Trees” features Dr. Munsell McPhillips presenting a post-Irma analysis of our unique Amelia Island maritime forest environment. Dr. McPhillips, a biomedical engineer with a specialization in biomaterials, has analyzed and repaired ecological systems around the world. Live showings with Dr. McPhillips and Chris Hestand, our videographer, will be scheduled soon.

Following a review of the purposes of ATC, activities of the organization during 2018 and ATC finances, featured speaker, Pep Fuller spoke on the importance of maintaining and expanding our canopy in the context of global warming and sea level rise. Mr. Fuller is a retired Federal Senior Executive who worked for the EPA and in the Executive Office of the President under Presidents Reagan and Bush. Mr. Fuller was also a principal EPA negotiator for two global environmental treaties as well as the creation of the WTO and NAFTA.

Each year, ATC celebrates individuals and organizations that have contributed to preserving our canopy. This year, the ATC Award for extraordinary service to our canopy or the organization was awarded to the following individuals: Taco Pope, Director of the Nassau County Department of Planning and Economic Opportunity, for his efforts to protect canopy and improve the sustainability of Nassau County; Mike Manzie of Manzie & Drake for their story map of extraordinary trees on and near Amelia Island and their 2009 tree contest; Harry Weisenborn for the GIS work that laid a foundation for the ATC recommendations for land conservation in Fernandina Beach; and Samantha Hoskins for creating and managing ATC’s Instagram account and feed for our website Gallery page. The Voice of the Island Awardfor speaking out for the environment of the island orally, in writing or through photography was presented to the following individuals: Julie Ferreira for many years of speaking out orally and in writing for a safe and sustainable environment; Betsie Huben for speaking out for the environment orally and in writing in support of canopy preservation, land conservation and responsible, sustainable development; and Steve Leimberg, whose photography has sensitized the community to the beauty, complexity and character of the birds, trees, etc. in our environment.

ATC at the AIPCA Grand Opening of the Sunken Forest

On February 22, 2018 the Amelia Island Plantation Community Association held a ribbon cutting for the Grand Opening of the Sunken Forest. ATC was invited to provide “chats” on the maritime forest for those touring the Sunken Forest. After a number of years of disrepair, the Sunken Forest has now been redesigned in a very environmentally sensitive way and reopened to residents and guests. It provides an intimate glimpse into the world of the maritime forest.

The Sunken Forest is actually a swale behind the first major dune line, a protected area in which Live Oaks and understory plants like Yaupon Holly have thrived. We can see how the trees have been shaped by the wind and salt over the years. In fact, on the edges of this small forest, we can see where Irma removed foliage, while the sheltered area beneath the trees remained unharmed. A boardwalk with stairs allows us to walk through this swale and up to a dramatic outlook over the beach and ocean. There are several areas where the boardwalk is lined with benches—lovely places for contemplation and communing with the forest.

For the excellent restoration of this sample of maritime forest, we owe particular thanks to Carol Simon, Jim O’Malley, Geoff Clear, Larry Jones, Frank Adams, Jane Sandhaus Packer, Candace Bridgewater, and the Castle-AIPCA Management Company.

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