Jessica Bowron
Comptroller, Exercising the Delegated Authority of the Director
National Park Service
1849 C Street NW
Washington, DC 20240
Darrell Echols
Acting Regional Director
National Park Service, Region 2
100 Alabama Street SW
1924 Building
Atlanta, GA 30303
Melissa Trenchik
Superintendent
Cumberland Island National Seashore
National Park Service
101 Wheeler Street
St. Marys, GA 31558
RE: Comments on the Environmental Assessment for the Proposed Voluntary Land Exchanges at Cumberland Island National Seashore (PEPC Project No. 124458)
October 15, 2026
Dear Acting Director Bowron, Acting Regional Director Echols, and Superintendent Trenchik,
On behalf of our organizations, and our millions of members and supporters across the country, we urge you to oppose the proposed transfer of approximately 80 acres of Cumberland Island National Seashore into private ownership.
The National Park Service (NPS) is considering two land exchanges that could allow up to eight new residences on land that is currently federally owned and protected as part of the Seashore, each with a potential building footprint of up to 15,000 square feet.
These are not lands outside the Seashore that NPS is considering whether to acquire. They are lands the American public already owns.
NPS relies on the threat of private development to justify these exchanges. Yet NPS has identified no specific development proposal for the private lands it seeks to acquire. The agency has not explained why this amorphous threat justifies creating new private development opportunities on already protected federal parkland, or what public benefit warrants the permanent loss of those lands.
If development threatens Cumberland’s resources, creating new development opportunities on existing federal parkland is not a conservation solution.
Cumberland Island protects one of the largest undeveloped barrier islands on the Atlantic coast, with maritime forests, wetlands, salt marsh, beaches, and other habitats that support hundreds of bird species, nesting sea turtles, and an extraordinary diversity of wildlife. Its ecological value depends in no small part on the very thing these exchanges would erode: the island’s largely undeveloped character.
The loss contemplated by the exchanges would be permanent. Some of these federal lands were originally acquired specifically to protect the Seashore, yet NPS now proposes to dispose of those lands without explaining why these tracks are suitable for exchange. Furthermore, NPS has not disclosed that acquisition history, nor have they disclosed sufficiently detailed maps for the parcels. If transferred, these lands would open currently protected maritime forest and wetlands, including the marsh border zone, to clearing and development, bringing new roads, infrastructure, lighting, vehicles, and human disturbance into sensitive wildlife habitat.
Congress established Cumberland Island National Seashore to conserve its extraordinary natural, scenic, and historic resources and directed that the Seashore be “permanently preserved in its primitive state.” Transferring protected federal lands into private ownership for residential development directly conflicts with that congressional purpose.
We urge NPS to reject these proposed exchanges and retain these lands in federal ownership for the benefit of the American public.
Sincerely,
American Bird Conservancy
Californians for Western Wilderness
Carolina Oceans Alliance
Coalition to Protect America’s National Parks
Center for Biological Diversity
Center for a Sustainable Coast
Defenders of Wildlife
Endangered Species Coalition
Environment America
Environment Georgia
Environmental Protection Information Center
Forest Keeper
Four Paws USA
Friends of Big Ivy
Friends of Merrymeeting Bay
GreenLatinos
Heartwood
Inland Ocean Coalition
Izaak Walton League Rapid City, SD Chapter
John Muir Project
Kettle Range Conservation Group
League of Conservation Voters
Mtn Bio
Nassau Hiking & Outdoor Club
National Parks Conservation Association
Natural Resources Defense Council
New Hampshire Audubon
New York State Ornithological Association
Northeastern Minnesotans for Wilderness
NYC Plover Project
Oceans Connect
Public Lands Conservancy
Resource Renewal Institute
Save our Sky Blue Waters
Saw Mill River Audubon
Sea Turtle Conservancy
Sierra Club
Standing Trees
The Ocean Project
Voters for Animal Rights
Western Watersheds Project
Whale and Dolphin Conservation
Wild Cumberland
Wild Lessons
Wilderness Watch