Orange Crush® Festival Issues Statement Following Apr 11th Orange Crush Tybee Island Permit Determination (ALL NON TYBEE EVENTS UNAFFECTED)

Savannah, GA [December 2025]

Orange Crush Festival®, the federally registered trademark and cultural event platform, has been formally notified that its permit application for the planned April 11, 2026 Tybee Island daytime beach activation (Week 1) will not be approved.

Orange Crush Festival® acknowledges the City of Tybee Island’s decision and confirms that no permitted Orange Crush® Festival event will take place on Tybee Island on April 11, 2026 under the denied permit. We are officially appealing the December 8th Denial for the Special Event Permit for event to be held on Saturday April 11th, 2026.

Commitment to Compliance & Public Safety

Orange Crush Festival® has consistently operated with an emphasis on coordination, compliance, and public safety, including:

• Advance permit submissions

• Structured programming

• Professional security planning

• Clear communication regarding official events

While disappointed by the determination, Orange Crush Festival® respects the municipal permitting process and remains committed to lawful operations across all jurisdictions.

Clarification Regarding the Orange Crush® Trademark

Orange Crush® is a protected trademark and brand, and its cultural recognition spans decades. However, the presence of individuals or visitors on a public beach does not constitute an Orange Crush® Festival event unless formally produced, permitted, and announced by the trademark owner.

Orange Crush Festival® does not organize, sponsor, or produce unpermitted gatherings and does not control independent travel or public use of public spaces.

Festival Programming Continues Elsewhere

Despite the Tybee Island permit determination, Orange Crush® Spring Break 2026 programming continues as scheduled in permitted venues and private properties throughout the region, including:

• Official nightlife events in Savannah

• Trademark-produced cultural programming

• Weekend 2 “Orange Crush Reloaded™” events

• The Crush the Block® finale in Allenhurst, Georgia

All official Orange Crush® events are clearly identified, ticketed where applicable, and communicated through authorized channels.

Looking Forward

Orange Crush Festival® remains open to continued dialogue with municipal leaders regarding future opportunities to collaborate in ways that support:

• Public safety

• Tourism management

• Cultural celebration

• Economic impact

The organization appreciates the communities that continue to engage constructively and recognizes the importance of balancing tradition with modern operational realities.

Public Advisory

Attendees are encouraged to rely only on official Orange Crush® communications for event information. Orange Crush Festival® does not endorse unofficial or unpermitted activities and urges all visitors to comply with local laws and regulations.

About Orange Crush Festival®

Orange Crush Festival® is a nationally recognized cultural platform rooted in HBCU Spring Break tradition, nightlife production, creator culture, and motorsports events. All official events are produced under registered trademarks and executive leadership.

Media Contact:

Press & Legal Communications

Orange Crush Festival®

OrangeCrushFestivalTybee@gmail.com

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OFFICIAL ADMINISTRATIVE APPEAL & PUBLIC RESPONSE

Re: Appeal of Dec 8, 2025 Sent Denial Recieved Dec 19, 2025 of Special Event Applications – April 11 & April 18, 2026 (Pier Lot and/or North Beach Lot)

Submitted to:

City Manager Bret Bell

Mayor Brian West

Tybee Island City Council

Submitted by:

George Turner

Owner & Federal Trademark Holder – Orange Crush®, Orange Crush Festival®, Orange Crush University™

Service-Disabled Veteran

Business Developer & Educational Program Coordinator

Date: December 2025

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I. EXECUTIVE SUMMARY

I submit this appeal regarding the City’s December 8, 2025 denial of my special event applications for April 11 and April 18, 2026. I received and replied to the Denial Letter on Dec 19, 2025. These events are university-affiliated, registration-only programs, capped at 250–500 participants, conducted entirely within fenced lots, and staffed with private EMS, licensed security, transportation, and sanitation. They are fundamentally distinct from historical, unpermitted beach gatherings cited in the denial.

I respectfully request that the City:

1. Approve the April 11 and/or April 18 applications;

2. Issue conditional permits consistent with the April 18, 2025 precedent; or

3. Re-evaluate the applications, correcting procedural defects, as required by Tybee Island Code §54-76(b).

The denial lacks event-specific findings, relies on historic third-party activity, and does not consider my operational plans or mitigation measures.

Takeaway: The City cannot lawfully deny my permit without reviewing the actual plans I submitted.

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II. GOVERNING LEGAL STANDARDS

Tybee Island Code §54-76(b) requires that any denial be based on “reasonable, evidence-based findings,” including anticipated attendance, site suitability, public safety impacts, resource demands, and whether concerns can be addressed through reasonable conditions.

Takeaway: The City must examine my submitted plan before issuing a denial.

Georgia Administrative Law requires that municipal permitting decisions be:

• Supported by substantial evidence (Atlanta Cellular Tel. Co. v. Fulton County, 224 Ga. App. 886 (1997)). This means the City must review site-specific, plan-specific facts before denial.

• Not arbitrary or capricious (Bentley v. Chastain, 242 Ga. 348 (1978)). This ensures decisions are rational and justified, not based on assumptions.

• Consistently applied across similarly situated applicants (City of Atlanta v. Wrecking Co., 286 Ga. 749 (2010)). This prevents unequal treatment of applicants with comparable plans.

• Accompanied by findings tied to the specific application (Zywiczynski v. City of Atlanta, 283 Ga. App. 135 (2007)). This requires evaluation of the facts of my actual application, not historical or unrelated events.

Takeaway: Denying my permit based on historic third-party activity violates both City Code and Georgia law.

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III. WHY THE DENIAL IS DEFICIENT

The City’s denial relies solely on historic, unpermitted crowds unrelated to my proposed events. No site-specific or plan-specific analysis was conducted, including: attendance caps, fencing plans, controlled ingress/egress, private EMS/security, or transportation.

Event-specific highlights:

• Controlled, fenced, registration-only events with 250–500 participants

• Timed cohort rotation to manage flow and density

• ICS/NIMS-based safety and command structure

• Fully staffed private EMS, security, sanitation, and shuttles

Takeaway: These measures directly mitigate the City’s cited concerns, making the denial factually unsupported.

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IV. RESPONSE TO CITY CLAIMS

1. “Large groups have come for informal spring break gatherings referred to as Orange Crush.”

This references unpermitted events not organized by me. Takeaway: Georgia law forbids using historical third-party activity as a basis for denial.

2. “This unpermitted event caused serious public safety problems requiring hundreds of officers and $200,000 annually.”

My events are controlled, fenced, and fully staffed privately; no site-specific assessment occurred. Takeaway: Denial cannot rely on generalized past events.

3. “Conditional permit was granted to Mr. Smalls… resources cannot accommodate multiple events.”

Both applications are similar in site, attendance, and private support. Denying mine without explanation is arbitrary. Takeaway: Equal-treatment principles were not applied.

4. “The event will present a clear and present danger to public health and safety.”

Attendance limits, access control, cohorting, and private safety measures were not evaluated. Takeaway: Conclusory language cannot replace evidence-based findings.

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V. OPERATIONAL, SAFETY, AND COMMUNITY BENEFIT

Submitted plans (Exhibits A–F) exceed typical special-event requirements:

• Governance: ICS/NIMS-modeled command structure with Safety Officer, Security Chief, Medical Lead, Logistics Captain

• Attendance Control: Registration-only, ID verification, maximum 500 participants

• Security: Fenced perimeters, controlled ingress/egress, licensed officers

• Medical & Sanitation: On-site EMTs, treatment tents, rotational trash pickup

• Transportation: Private shuttles, off-island staging, minimized traffic impact

These measures reduce unpermitted activity, protect participants, minimize City resource burden, and provide safe, structured, university-supported programming.

Takeaway: My events provide measurable public benefit while minimizing City impact.

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VI. OPEN RECORDS & TRANSPARENCY

Under O.C.G.A. §50-18-70, I request within 3 business days:

1. Internal communications referencing my applications

2. Risk assessments, EMS, or safety analyses informing the denial

3. Documentation supporting the April 18, 2025 conditional permit

4. Materials comparing City resource allocation for April 11 and April 18 weekends

Takeaway: This ensures transparency and verifies that denial was evidence-based, not generalized or arbitrary.

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VII. REQUEST FOR RECONSIDERATION

Option A – Full Approval: Approve April 11 and/or April 18 events at Pier Lot and/or North Beach Lot.

Option B – Conditional Approval: Apply conditions consistent with April 18, 2025 precedent (attendance caps, fencing, security, EMS, transportation, sanitation).

Option C – Collaborative Site Walkthrough: Meet with City staff to finalize conditions based on operational evidence.

Takeaway: These options allow the City to ensure public safety while upholding equal-treatment obligations.

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VIII. CONCLUSION

The December 8 denial is unsupported, procedurally defective, and inconsistent with City precedent and Georgia administrative law. My applications are fully documented, professionally planned, and designed to minimize City resource burden. Reconsideration—either full approval or conditional permitting—is the lawful and appropriate remedy.

Respectfully Submitted,

George Turner

Owner & Federal Trademark Holder – Orange Crush®, Orange Crush Festival®, Orange Crush University™

Service-Disabled Veteran

Business Developer & Educational Program Coordinator

Exhibits A–F available upon request.