Shoreline Management Plan Survey Update

After many months of hard and tedious work, our SMP Survey report has been finalized and delivered to the Corps of Engineers. We conducted a rigorous review of the roughly 3,000 comments we received – and rest assured that every one was read, more than once. But beyond merely reading the comments, we concentrated on ensuring that we truly comprehended the problems you reported so that we could craft practical solutions for them. We condensed the comments into subcategories of common themes. We then assessed each issue against the SMP provisions that were relevant to it and evaluated potential solutions that addressed as many of the comments as possible. We then not only recommended changes but also drafted literal SMP language modifications to implement each recommendation. This was an iterative process that took over 1,000 hours of detailed, painstaking work, and we are confident the finished product accurately reflects the changes you told us need to be made both in the SMP itself and in the way the Corps conducts its business as it interfaces with permit holders.

In the final evaluation, we merged a number of the original 46 categories due to the fact that many comments in some categories mirrored the comments in others. For example, the categories titled Permit Action Resolution, Timing and Communication, and Administrative Appeals all addressed a series of common themes. When consolidated, those three categories totaled a whopping 243 substantive comments, making it the largest category of all. Dock Storage Boxes, which originally topped the leaderboard, came in second with 224 substantive comments. Notably, there was a tremendous amount of dissatisfaction with the Corps’ handling of permits, especially the length of time it takes for the Corps to issue renewals, as well as a lack of responsiveness to inquiries from permit holders. In all, there are 39 subject matter reports and five more that coordinate language changes from multiple categories that dovetail in the SMP.

We have already met with the Corps to preliminarily review the report and are exploring the possibility of resolving a number of the recommendations through Administrative Changes so that solutions can be implemented as quickly as possible.

This was not in any way a perfunctory undertaking, and it took a team of people at LLA to bring it all together. Although the Corps previously performed major updates on the SMP in 1988 and 2004, there has never been an independent (i.e., non-Corps) attempt to collect comments from the public, perform the rigorous process of assessing, summarizing and explaining them, and then turning them into actionable language changes for implementation by the Corps. As promised, we will continue to advocate for the changes you asked for and we will keep you apprised of our progress.