Stop the Corps from Killing Georgia’s
Sea Turtles

Georgia’s Sea Turtles: A Legacy of Conservation

7/7/21: Action Alert

5/20/21: Court Orders Corps to Halt Georgia Coastal Dredging Plans

Georgia’s coast has a long legacy of protecting threatened loggerhead sea turtles. Little Cumberland Island is home to the oldest loggerhead nesting project in the world—started nearly 60 years ago, in 1964. Today, more than 200 dedicated volunteers, researchers, and state and federal employees make up the Georgia Sea Turtle Cooperative, a collaborative network that devotes thousands of hours and significant resources to protecting our barrier islands for sea turtle nesting and strandings.

Georgia’s most common nesting sea turtle, the loggerhead, is listed as threatened and protected under state and federal laws. In recent years, our coast has come together to celebrate record-shattering nesting seasons that are the direct result of early nest protection efforts in the 1970s and 80s and the implementation of turtle excluder devices (“TEDs”). But it was only 17 years ago, in 2004, that we saw our lowest nesting totals on record. The string of low nesting years in the 2000s means that—if current protections and management practices are kept in place—our loggerhead population is predicted to plateau or even decline, for the next two decades. In other words, loggerhead sea turtles are far from being recovered in Georgia, and we must continue to do everything in our power to protect them.

We’re working to prevent the U.S. Army Corps of Engineers from conducting year-round dredging during spring and summer nesting season. Stay tuned for updates and ways to make your voices heard.

We took legal action to stop this dangerous plan—and won. Now, we’re continuing the fight.

Learn more

Summer Dredging Will Kill Our Nesting Turtles

Earlier this year, against the concerns of state biologists, the U.S. Army Corps of Engineers (“USACE” or “The Corps”) announced plans to expand maintenance dredging year-round and dredge in the Brunswick and Savannah shipping channels throughout the 2021 summer nesting season (and soon, in the King’s Bay channel). In May, a federal court granted a preliminary injunction preventing all hopper dredging until December 15, 2021. Unfortunately, the Corps continues to push their plan—they recently released an updated Environmental Assessment, which outlined their plan to conduct year-round dredging in Brunswick Harbor. OHM, the Southern Environmental Law Center, and nearly 1,000 advocates submitted comments in opposition to this dangerous plan. Read our comments here.

We continue to monitor and oppose any future attempts to eliminate highly successful seasonal limitations on dredging projects that have protected sea turtles and other marine life for decades, as well as any attempts to shortcut the environmental review process. Once published, we will review the Corps’ environmental review and are prepared to take further action as needed.

Dead sea turtles killed by a hopper dredge

We have too much to lose.

The Corps claims that the South Atlantic Biological Opinion (SARBO)—a new document guided by Endangered Species Act rollbacks under the previous administration—gives them the authority to disregard these long-standing protections and “take” (or less euphemistically, kill) as many as 214 loggerheads across the Southeast over the next three years. While similar projects are proposed throughout the Southeast, the USACE appears to be targeting Georgia’s coast as their test case—setting a dangerous precedent for the rest of the region. No risk assessment has been conducted to show the consequences of lifting these long-standing seasonal restrictions.

This legal allowable take for loggerheads could lead to significant declines in our population—potentially killing as many as 87% of the females nesting in the vicinity of the Brunswick shipping channel and 47% of those near the Savannah shipping channel, according to GADNR data.

Most ominously, there are no restrictions on the age class or life stage of the animals allowed to be killed during this process. While any loss is unwanted, the take of reproductively-active adult females will be particularly devastating. Unlike other species affected by dredging activity, loggerhead sea turtles don’t reach sexual maturity until their early to mid 30s. Any adult loggerhead killed will take at least three decades to replace—approximately three times as long as the other species of concern.

Recent history provides a good example for just how devastating summer dredging would be. In September 2009 (several months earlier than the typical start in December but still after the majority of adult females had left the area), USACE conducted a test case to determine the feasibility of summer dredging on Georgia’s coast. Within the first nine days of dredging in Brunswick, four loggerheads were killed before the project was discontinued, including one large loggerhead believed to be an adult or older subadult. In Savannah, six loggerheads were taken in 15 days of dredging, including at least one adult. This late summer mortality rate was more than eight times higher than that of the winter dredging window—and presumably would have been even more significant, if it had taken place during the early summer timeframe the Corps intends to use this year. Further, there are multiple examples of the Corps reaching their legally allowable take limits and, instead of shutting down the project, simply asking for—and receiving—permission to kill even more turtles.

An Unnecessary Risk

The U.S. Army Corps of Engineers has long pointed to dredging windows as an example of their good stewardship. There is no justification for moving these now and jeopardizing sea turtle conservation efforts. Unfortunately, the USACE attempted to pit one species against the other in their rush to open up dredging. While the North Atlantic right whale is critically endangered and deserves our protection, hopper dredges have been operating during calving season in Georgia for the last 30 years. During that time period, there have been zero documented takes or other interactions, and there is no scientific reason to believe that this will increase in the future. The Corps also claimed that dredging outside the long-accepted windows would be more ‘cost-effective’ to federal taxpayers, but there is—and always should be—a high cost associated with killing endangered species. Georgians have long invested in the protection of our loggerhead sea turtles, and we aren’t going to let the Corps ruin decades of progress for their own convenience.

Loggerhead killed by hopper dredge

Frequently Asked Questions

Wait, what happened? I thought OHM won their recent court case? Yes, our lawyers at the Southern Environmental Law Center (SELC) were successful in arguing for a preliminary injunction to stop all hopper dredging during the spring and summer of 2021. However, the case continues to be litigated and the ultimate decision as to whether hopper dredging will be allowed along Georgia’s coast in the spring and summer months is still unknown.

In July, the Corps accepted public comments on their draft Environmental Assessment (EA). Unfortunately, the EA contained multiple inaccuracies and misrepresented the data collected by the Georgia Sea Turtle Cooperative. SELC submitted comments on OHM’s behalf—along with nearly 1,000 comments by concerned advocates! Other agencies, including Georgia DNR and the National Marine Fisheries Service, also submitted comments in opposition.

The next step in the process will be for the Corps to release their final Environmental Assessment. We are continuing to monitor and oppose any future attempts to eliminate highly successful seasonal limitations on dredging projects that have protected sea turtles and other marine life for decades, as well as any attempts to shortcut the environmental review process. Once published, we will closely review and assess the Corps’ environmental review and will take further action as needed.

The preliminary injunction was granted for the 2021 season. What will happen next year?
While the Corps continues to push for year-round dredging, there have been a couple of notable developments in recent months. First, the Commander of the Savannah District ordered that historic dredging windows remain in place in Savannah Harbor moving forward and that no hopper dredges be used during the spring or summer moving forward in Brunswick until the Corps completes its NEPA process. Further, the bid solicitation notice for 2022 Brunswick and Savannah Harbor maintenance dredging (available here) includes traditional winter dredging windows for both Brunswick and Savannah Harbors. These are positive developments, but we know there is still work left to do. We will continue to monitor the situation closely and take additional action as needed.

Do my comments matter? YES! More than 1,500 Georgians made their voices heard in March, when the Georgia Department of Natural Resources opened up a comment period on the proposal for year-round dredging in Brunswick Harbor. 100% of those letters were in opposition! During the Corps’ public comment in July, nearly 1,000 additional comment letters were submitted. If you were one of the ones who submitted a letter, thank you! We will continue to update you on next steps in the process and opportunities to make your voices heard.

What would happen if dredging is conducted in the spring and summer months? The simple answer is, we expect adult loggerhead sea turtles to die. Historically, loggerheads have been the most significantly impacted by hopper dredges in Georgia. The summer months are when adult, reproductively-active females congregate in local waters—putting them directly in harm’s way. 214 loggerheads could legally be killed over a 3-year period before the Corps would have to stop the project or request a higher take limit.

So, are you against all dredging? No. We recognize that annual removal of sediment is necessary in order to maintain safe shipping channels. We also know that some incidental take is expected with normal dredging activities. However, this “operations and management” dredging has been conducted during winter months, when adult nesting loggerheads are far less abundant, for more than three decades. From a conservation perspective, the loss of an adult turtle is much more damaging than that of a juvenile and must be avoided at all costs. To ensure the continued survival of the species, the December 15-March 31 annual maintenance dredging windows must remain in place.

What is a ‘take’ of an endangered species? To conduct dredging in waters where sea turtles or other protected species occur, the U.S. Fish & Wildlife Service and the NMFS must authorize incidental “takes” in accordance with the federal Endangered Species Act. This means that some animals will die or be maimed by an activity authorized by the federal government. A “take” is a kinder, gentler way of saying kill—in this case, essentially grinding up live turtles in the blades of a hopper dredge. Photographs like the ones on this page show just how gruesome an end a sea turtle suffers when falling victim to dredging.

What is the SARBO? SARBO stands for South Atlantic Regional Biological Opinion. NMFS issues Biological Opinions to document their opinions on how federal agencies’ actions affect Endangered Species Act (ESA)-listed species and critical habitat in the southeast. These opinions provide an exemption for the take of federally listed species and specify the extent of take allowed and the conditions with which the agencies must comply. The most recent SARBO is a 653-page document released in July 2020. It contains analyses conducted within the framework of recent ESA rollbacks and new standards that afford endangered species far less protection. The 2020 SARBO eliminated the use of dredging windows to reduce sea turtle mortality. As a consequence, the USACE has informed Georgia DNR that they intend to dredge the Brunswick and Savannah channels during the spring and summer of 2021.

Aren’t loggerhead sea turtles recovered already? No. But if you’ve been following sea turtle conservation for the past few years, you’ve probably heard a lot of celebration. The excitement is understandable—record-setting nesting years like those in 2019, 2016, and 2015 represent decades of hard work on behalf of many dedicated volunteers and staff. But while annual nesting is slowly increasing, models show that the Northern Recovery Unit population (loggerheads born on nesting beaches from the Florida/Georgia border through southern Virginia) is only a third to half of its size from the 1960s. And despite the recent highs, it wasn’t long ago when we experienced record low nesting seasons—setting up a period of plateau or decline until 2040. If dredging windows or other protections are lifted, there could be even more precipitous declines.

What about right whales? One Hundred Miles is passionate about protecting the North Atlantic right whale. But winter dredging has safely coincided with the right whales’ annual calving season in Georgia for more than 30 years. In all that time, there have been no documented interactions between maintenance dredges and right whales. It is extremely rare for right whales to venture into the channels where dredging operations take place, and even if they did, maintaining slow ship speeds would mitigate any risk. GADNR, whose biologists devote significant resources to protecting North Atlantic right whales and assume great personal risk in monitoring and responding to entanglements, opposes the change in dredging windows.

Further, while the Corps claims that their actions are due to concerns over right whale safety, they inexplicably claim that their survey vessels must travel at high speeds to complete surveys and to reach offshore disposal sites. This is not the case. If the Corps is truly concerned about protecting right whales, why aren’t they willing to comply with recommended ship speed regulations of ten knots or less?

What other protected species could be affected?
Atlantic sturgeon are found in the lower estuaries and shipping channels during the winter and spring (December-May). Some takes are expected during winter dredging. However, based on the relatively large size of the Savannah and Altamaha River populations and the fact that documented mortalities are low (3.4 Atlantic sturgeon annually across 3 channels) and primarily juveniles and subadults, it is unlikely that the current mortality level associated with channel maintenance dredging will have an effect on population recovery. Further, unlike with sea turtles, preventative methods, such as having a trawler sweep ahead of the dredge to clear its path, is effective.

What can I do to help?
Please stay tuned. Comments are currently closed, but we will continue to post updates and opportunities for you to take action. We couldn’t do this work without you!