July 31, 2007
VIA EMAIL
Mary Bomar
Director, National Park Service
Patricia Hooks
Southeast Regional Director , National Park Service
Dan Kimball
Superintendent, Everglades and Dry Tortugas NP
Pat Kenney
National Park Service, Everglades Park Team
These comments are being submitted on behalf of the Sierra Club, representing nearly 750,000 members nationwide. We are pleased to participate in this process which will culminate in the first revision of the general management plan for Everglades National Park in decades.
Global Importance of Everglades National Park
Here are no lofty peaks seeking the sky, no mighty glaciers or rushing streams wearing away the uplifted land. Here is land, tranquil in its quiet beauty, serving not as the source of water, but as the receiver of it. To its natural abundance we owe the spectacular plant and animal life that distinguishes this place from all others in our country.
-- President Harry Truman on the dedication of Everglades National Park, December 6th, 1947.
As we approach the 60th anniversary of its founding, the national and international importance of Everglades National Park (ENP) cannot be overestimated. Fully established as a national park in 1947, the park is today classified as an International Biosphere Reserve (1976), a UNESCO World Heritage Site (1979), and a Ramsar Wetland of International Importance (1987). Most of the park (about 86%) was declared wilderness in 1978 and is by far the largest such area in the eastern United States to receive this special level of protection.
Ecological habitats within the park form a complex mosaic composed of marine and estuarine environments, mangroves, coastal prairie, freshwater marl prairie, freshwater slough, cypress, hardwood hammocks, and pinelands. The flora and fauna of ENP are legendary, comprising a unique mix of temperate, sub-tropical and tropical species found nowhere else on earth. Biodiversity is staggering. The park is home to 25 varieties of orchids, 1000 species of seed bearing plants and over 120 species of trees. No less than 36 animals listed as endangered or threatened call the park home, and it is the only place on earth where alligators and crocodiles exist side by side. Of the more than 350 species of birds known to exist in the park, seven are listed as endangered or threatened. More than any of its other scenic, cultural, or historical qualities, ENP is truly a 'biological park' with immense importance to the natural heritage of our nation and our planet.
Everglades National Park -- a Park at Risk
In the most recent (May, 2007) National Park Service (NPS) newsletter, four alternative plans were released which reflect a wide range of management options. Although labeled a 'general management plan' (GMP), it is clear that what the public is actually being presented are a range of options which deal exclusively with questions of use and recreation. We understand that this is largely unavoidable as the most significant impacts on the park's ecosystems originate from outside its boundaries and are not under the direct control of NPS administration. A brief excerpt from the message that was sent out to Sierra Club members and supporters explains some of the external problems in need of mitigation in more detail --
Established to permanently safeguard the last remnants of the once vast everglades ecosystem, today the very survival of Everglades National Park is threatened as never before. Agricultural and other chemicals, including mercury and arsenic compounds, sulfates, phosphates and pesticides have made their way into the ecosystem to the extent that virtually no fish - fresh or salt - caught in park waters is considered completely safe to eat. Sawgrass gives way to cattails as agricultural runoff changes the original chemistry of the water and underlying muck. The thousands of tree islands - also called hammocks - which once dotted the 'glades' and supported an almost incredible diversity of plants and animals are rapidly dying off due to artificially produced changes in water levels and chemical intrusion. Canals and roads built to facilitate agriculture, residential settlement and transportation have completely altered the natural waterflow of the glades from its origin in the Kissimmee chain of lakes near Orlando down to Lake Okeechobee and on through the 'river of grass' to Florida Bay.
Other changes caused by outside influences not mentioned above relate to severe impacts to Florida Bay and the Gulf coast sections of the park. The massive amounts of freshwater that once regularly inundated Florida Bay and the Gulf Coast and greatly contributed to their unique chemistry are no longer arriving due to upstream use (agricultural, residential, and business/industrial) and flood control for populated areas leading to dramatic changes in salinity. And the quality of that water which does manage to arrive, now mixed with agricultural runoff from the Everglades Agricultural Area (EAA) and chemicals from other sources, is nowhere near the purity that characterized the biological conditions under which these ecosystems formed only 5 to 6 thousand years ago.
While not subject to the terms of the Organic Act and other NPS legislation, laws and rules which directly regulate activities inside units of the National Park Service, these external impacts are both longstanding and severe in terms of their effects on both the natural resources of ENP and the public's enjoyment of them. The Sierra Club applauded the recent letter from ENP Superintendent Dan Kimball when he publicly expressed his concerns over pollutants which would be released into the air, water and land of ENP if the proposed Glades Power Plant a massive coal powered electricity generating plant near the Lake Okeechobee community of Moore Haven were to have been approved and built. Fortunately, the proposed plant was unanimously rejected by the Florida Public Services Commission.
ENP comprises the lower one fifth of the original Everglades ecosystem. It is the recipient and not the source of the water which characterizes it (and which spreads through virtually its entire terrain due to a nearly flat and only gently sloping topology) and thus its health and vitality are directly related to upstream water management practices probably more so than any other park within the NPS system. Virtually all 'interested parties', groups and individuals, commenting on this current newsletter are in complete agreement as to the most severe threats to the long-term health of ENP. The Sierra Club advises that the NPS continue to advocate for the strongest possible safeguards to the park's upstream environment and water supply. Both the quantity and quality of this water is absolutely essential to the biological resources of the park. As stewards of this protected land, the NPS has an obligation to keep the public well informed as to outside threats and not only work cooperatively with other agencies in mitigating these threats, but speak out and act forcefully when the health of ENP is threatened by decisions and practices outside of its boundaries.
Protecting ENP essentially means 'getting the water right' in quantity, quality, timing and distribution. The recent highly controversial decision by UNESCO to remove ENP from its list of World Heritage Sites in Danger not withstanding, this means taking steps such as the decommissioning of upstream canals which divert water away from the park as called for by the Comprehensive Everglades Restoration Project (CERP); the effective removal of impediments and return to the natural hydrology of the Shark River Slough waterflow under Tamiami Trail in accord with the 'Mod Waters' agreement of the Everglades Expansion Act of 1989; removal of agricultural and chemical runoff from the EAA and other sources; and limiting to the extent possible human use of the Biscayne Aquifer when it would deny sufficient water to ENP.
This list is by no means comprehensive. With a Florida population of nearly 16 million in 2000, which the U.S. Census Bureau predicts will grow to about 29 million in 2030, we can expect old threats to remain and new ones to almost certainly emerge. It will be interesting to see how the new Regional Water Availability Rule passed by the South Florida Water Management District (SFWMD) this past April and which prohibits any new users from tapping the Biscayne Aquifer (and by extension the water supply for ENP) will be applied. Water utilities will be forced to develop alternative water supplies and virtually no processes are currently on line or even being developed for that purpose. This is a good example of an issue for the NPS to weigh in on as the local public utilities (and the taxpayers) cope with the cost and engineering challenges of developing the now mandated alternative water supplies.
Revised Alternative D Would Best Protect ENP's Natural Resources and Be Most Consistent With Legal Mandates
As mentioned above, the scope of the current newsletter deals with how the park is to be managed with respect to visitor use and recreation. Within this context and after an examination of the alternatives offered, The Sierra Club has singled out Management Alternative D as the best general blueprint for how we would recommend the park be managed. It is the one management plan which puts the protection of the plants and animals of one of America's most unique and threatened national parks up front and center where they belong. As summarized in the newsletter's introduction, Alternative D
Emphasizes the park as an integral partner in the network of local, state, and federal land management agencies and organizations in South Florida; protection of park resources increased as uses with potential for adverse impacts are reduced/minimized.
This statement is very much in line with the recommendations for park management as put forward by the Department of the Interior (DOI) in their recently released (Fall, 2006) guidelines for management of units of the NPS
In cases of uncertainty as to the impacts of activities on park natural resources, the protection of natural resources will predominate. The Service will reduce such uncertainty by facilitating and building a science based understanding of park resources and the nature and extent of the impacts involved.
Alternative D will also provide for the enjoyment and usage of the entire park by a variety of visitors - both motorized and non-motorized - while still adhering to the official mission of the National Park Service as stated in the Organic Act of 1916 -
...to promote and regulate the use of the...national parks...which purpose is to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.
Stated again and again in congressional legislation, federal laws, the Code of Federal Regulations, Executive Orders, judicial rulings and DOI management guidelines, protection of natural resources is the number one priority of the NPS in managing the many and diverse units which are under its stewardship.
Everglades National Park as a Designated Wilderness Area
With the passage of the National Parks and Recreation Act of 1978 - Public Law 95-625 1,296,500 acres of ENP became a designated wilderness area and part of the National Wilderness Preservation System. This designation creates a new and higher level of protection beyond that which exists for national parks in general. Although §4(d)(1) of the Wilderness Act of 1964 allows for "the use of aircraft or motorboats, where these uses have already become established," this use is subject to "desirable" restrictions. As all of the lands covered in the current newsletter are included in this wilderness (the lands of the East Everglades Expansion Area are 'potential wilderness' and "shall be managed by the Secretary insofar as practicable as wilderness until such time as said lands are designated as wilderness"), another way to view the writing of the new GMP for ENP is the determination of what those "desirable restrictions" ought to be. The general definition of wilderness provided for in the Act (below) must be taken into consideration in the decision-making process. With regard to the management of Florida Bay, the Gulf Coast and the East Everglades Expansion Area, the call for terrain in which the imprint of man is "substantially unnoticeable" must be carefully adhered to.
DEFINITION OF WILDERNESS
(c) A wilderness, in contrast with those areas where man
and his own works dominate the landscape, is hereby recognized
as an area where the earth and its community of life are untrammeled
by man, where man himself is a visitor who does not remain. An
area of wilderness is further defined to mean in this chapter
an area of undeveloped Federal land retaining its primeval character
and influence, without permanent improvements or human habitation,
which is protected and managed so as to preserve its natural
conditions and which (1) generally appears to have been affected
primarily by the forces of nature, with the imprint of man's
work substantially unnoticeable; (2) has outstanding opportunities
for solitude or a primitive and unconfined type of recreation;
(3) has at least five thousand acres of land or is of sufficient
size as to make practicable its preservation and use in an unimpaired
condition; and (4) may also contain ecological, geological, or
other features of scientific, educational, scenic, or historical
value.
Clearly, Everglades National Park, wherever 'non-conforming uses'
are eliminated by management decisions, easily meets these lofty
standards for wilderness designation.
Seagrasses in Florida Bay, the Gulf Coast and the Ten Thousand Islands
The seagrasses of Florida Bay and the Gulf Coast of ENP are the source of virtually all life found in the marine waters within the park. Nearly every fish, invertebrate, bird, mammal, reptile, amphibian, insect or micro-organism which inhabits or utilizes these waters depends on them as a source of food, shelter, a nursery for its young or as a source of prey. Two mainly herbivorous federally listed endangered species, the manatee and green sea turtle, rely on them as a principal source of food. Highly dependent on strong sunlight for health and growth, seagrasses in ENP are mainly found in shallow waters where they are unfortunately subject to damage by power boat hulls, propellers and anchors. Substrate is also lost as a result of this damage and this has the secondary effect of contributing to the turbidity of waters and reduction of sunlight as well as deposition of sediment on top of undamaged seagrass beds.
The turbidity of 'prop wash' is also known to displace a huge variety of small crustaceans and other invertebrates, a vital link in the food chain of ENP marine waters. These marine invertebrates adhere to and graze on the seagrasses and the disruption caused by passing boats can occur without any direct contact from hulls or propellers. And sea grasses also provide a substrate for epiphytic algae to grow on. These algae are a critical component of the Florida Bay ecosystem and exist at the very base of the food chain. They are lost along with the seagrasses when damage occurs.
In addition to benefits to the fauna of ENP, seagrasses play other vital roles. The roots and rhizomes of seagrasses form dense mats and act to stabilize the sediment. Substrate erosion from frequent storms and hurricanes in and around ENP increases to the extent that seagrass beds are damaged or lost. (Florida as a whole has lost massive amounts of its original seagrass beds with Tampa Bay showing a loss of approximately 81 percent.) Seagrasses are also extremely efficient at water filtration. They remove dissolved nutrients that enter marine waters as a result of agricultural runoff and also trap sediments and fine particles in their blades and roots. The resultant high clarity, nutrient poor waters are essential to nearby coral reefs. Seagrasses are thus vital to nearly every form of marine life in ENP.
An excellent short summary of the physical effects of boating on seagrasses is provided in a report on seagrass habitat by the Smithsonian Marine Station in Fort Pierce. Their website also provides a list of references to some of the animal species (125 are listed), invertebrates and vertebrates, associated with and dependent on seagrass habitat in Florida.
Prop scarring is another factor that threatens seagrasses. Accidental or intentional groundings of boats in shallow areas may lead to significant, localized impacts on seagrasses. Scarring occurs in water that is shallower than the draft of the boat. Boaters entering these shallows often dig up the seagrass beds as they motor, cutting not only the blades, but more catastrophically, slashing underground rhizomes and roots as well. Prop scarring often results in a continuous line of seagrass damage, which acts to fragment the habitat, especially in areas where seagrass coverage is sparse. Seagrasses that remain in fragmented areas are then susceptible to erosion effects and are vulnerable to increased damage as boaters continue to scar the meadow.
Alternative D and Seagrass Damage
Alternative D provides access to shallow and vulnerable areas (3 foot depth or less - the average depth of Florida Bay) by paddling (canoes or kayaks), or by poling or electric trolling motors on larger boats. Use of gasoline power engines in designated and pre-existing deep water channels will continue to provide access to most of the bay and Gulf coast. These channels were unfortunately omitted from the map and textual description of this alternative provided in the NPS newsletter. Unfortunately, this gave most readers the impression that almost the entire bay would be closed to power boat usage under Alternative D. We have consulted with the park administration on this point and this is definitely not the case as deep water channels and passes will continue to provide access to marine and estuarine areas. The Sierra Club is not against the use of motor powered boats in Everglades National Park as long as they are managed in such a way that does not damage the park's natural resources.
The Sierra Club is requesting an accurate presentation to the public be made of Alternative D with regard to Florida Bay and the Gulf Coast/Ten Thousand Islands/Whitewater Bay areas in the southwest portion of the park. This 'Revised Alternative D' would indicate all channels and deep water zones. These areas would not be subject to management by three foot water depth and would provide safe and non-damaging passage. The Sierra Club would also like to see damaged areas of ENP (seagrasses and substrate) caused by boat propellers, hulls, anchors, and grounding be presented to the public in the form of comprehensive GIS based maps. The entire bay bottom is designated wilderness and this type of damage by motorized boats should, quite simply, not be occurring in an area so dedicated. Representative photographs of the damage to significant areas should also be made available with their dates, sizes, locations and level of severity (light, moderate, severe) indicated. While not in agreement with the Sierra Club on our request that a revised version of Alternative D be selected as the preferred management plan, we noted that this same type of damage inventory was called for by the Coastal Conservation Association (CCA) of Florida. In their position statement posted on the group's website, CCA asked the NPS to provide the following -
We have requested the NPS to provide documentation such as boat stranding data, aerial photos of grass bed damage or other such evidence which may indicate a need for additional protection measures. The seagrass information should be over a specific time period and in the context of total seagrasses within the park.
In the context of a management decision that is supposed to take place largely on the basis of 'best available science', there has been entirely too much anecdotal discussion on this critical point of damage by motorboats to seagrass and substrate. A comprehensive damage inventory made easily available to the public is essential to this process. There is no reason that all interested parties should not be on the same page at least with regard to what the existing damage to the park is.
In terms of how Alternative D would actually work for gas powered boats in depth managed areas boaters can switch to alternative power (poling and electric trolling) while over identified shallow and sensitive areas where seagrass damage is known or likely. Gas powered boats could also carry canoes and/or kayaks on board which would then be utilized in no gas motor zones. While we understand these practices may be seen as a sacrifice to some, they will greatly protect the vulnerable seagrasses from damage and also allow for much needed recovery. Florida Bay will also greatly benefit from the recovery of habitat which takes place through this process. Although not directly related to protection of natural resources, we should also note that paddling is an extremely healthy activity and is in line with general NPS directives to provide opportunities for such activities. Furthermore, the no gas motor zones would provide new opportunities for other users who desire exposure to true wilderness and the natural soundscape of Florida Bay. For those who come to the park seeking out the type of experience an officially designated wilderness is supposed to provide, these no gas motor zones will provide for greatly enhanced trips to the Everglades backcountry.
As recovery rates are correlated with the amount of sediment removed (i.e. the deeper and more extensive the damage to the bay bottom or substrate, the longer the recovery time. Areas where substrate has been removed down to rock may never naturally recover) it is essential to put these protective measures in place as soon as feasible. Closed resource sensitive areas would be indicated by adequate signage and information would be transferred to navigational maps and Global Positional Systems (GPS) as soon as their boundaries were worked out. It is also important to allow for adequate buffer zones around closed areas to prevent inadvertent damage by boaters straying too close to a restricted area. Signage and other navigational aids need to be adequate to the task. Existing channel markers need to be upgraded wherever clarity as to the location of the channel would be in doubt.
The 1995 study of seagrasses conducted by the Florida Marine Research Institute (FMRI, Scarring of Florida's Seagrasses: Assessment and Management Options; F.J. Sargent, T.J. Leary, D.W. Crewz and C.R. Kruer, 1995) recommended a four point solution to the problem of seagrass damage in Florida waters by powerboats. While the basic nature of the problem has not changed in the 12 years since this study was carried out, the severity has grown tremendously as thousands of new boats have been registered in the state of Florida during that interval. (For two years in a row, Florida has been the state with the most registered boats now nearly 1 million.) As the NPS does not have accurate statistics on boat use in either the bay or the Gulf coast other than those gathered from the concession marina in Flamingo and the Everglades Visitor Center (boats leaving from the many marinas along US 1 in the keys or from other municipalities outside of park boundaries are not counted), it should be assumed that boater activity in Florida Bay in close proximity to the now 6 million inhabitants of south Florida (where many of these new boats have been registered) has grown proportionately. From the FMRI study --
Management programs that address scarring of seagrasses should be based on an approach that involves (1) education, (2) channel marking, (3) increased enforcement, and (4) limited-motoring-zones. Aerial monitoring and photography of the managed area are essential in evaluating the effectiveness of a program. Management programs that use this multifaceted approach have been instituted by a few local governments and at several state parks. Initial results of the programs indicate that in some areas seagrass scarring has been reduced and that in other areas emphasis may need to be increased on one or more of the components of the four-point approach. A statewide management plan is needed to address the most egregious scarring over large areas that may be difficult to regulate at the local-government level.
The study recommends these techniques be applied in varying combinations based on numerous factors including the nature of the waters, depth of the seagrass, boater traffic and the extent of damage to seagrasses. The marine waters of ENP are of immense biological importance to the biodiversity of our planet. They are heavily used for recreation and that use will continue to grow in proportion to the population. The study identifies Monroe County as the Florida county with by far the greatest amount of both seagrass and damage. Considering what is at stake, the Sierra Club recommends utilizing all four approaches identified by this study simultaneously. This proven success story in Pinellas County cited by the above study is particularly of note due to the results limited-motor zones produced.
Weedon Island State Preserve (Pinellas County) has experienced a 95 percent reduction in the number of scars since it was closed to combustion engines -- electric trolling motors are still allowed --in October 1990 (Folit and Morris 1992).
The Sierra Club was extremely pleased that an alternative put forward by a coalition of boating and angling groups and individuals, Alternative E, made use of all of these techniques as well. As one of its main components, Alternative E would require all boaters using park waters to complete an online or classroom based boater education course and be certified in order to operate a motorboat in park waters. The Sierra Club has also had discussion on this topic with NPS. We feel that this provision will be an extremely beneficial aid to the protection of park resources. Alternative E also calls for stricter penalties for those who willfully operate boats in ways that are known to cause damage to the natural resources of the park and we agree that enforcement with penalties will definitely act as a deterrent to this type of behavior.
Where the Sierra Club's position mainly differs from that of Alternative E is in the use of 'management by water depth zones' which utilize only a two foot depth as opposed to three and in the application of those zones. Alternative E calls for a single limited no motor zone in the area off Flamingo and requests that no other areas be put off limits to gas power motors. We have discussed this proposal with NPS representatives and NPS has found many other areas in the bay which would meet even the same limited criteria for closure that Alternative E provides in the area off Flamingo. Closures based on water depth and damage to seagrasses and substrate needs to be applied evenly with only resource protection as the criteria for application and not access for recreational purposes. The DOI Management Policies should apply. As noted earlier, these stress the need for management decisions to favor resource protection over recreation whenever there is a conflict between the two.
Another difference we have with Alternative E deals with the need to provide permanent buffer zones around sensitive keys not seasonal to relieve stress on rookeries and wading birds. The waters around many of these keys are also some of the shallowest areas in the bay and definitely require protection for substrate and seagrass as the many photos of damage to these areas indicate. And while Alternative E would redesignate Little Madeira Bay and Joe Bay as 'backcountry' and allow them to be used not only by paddlers but by power boaters with engines removed, our opinion is that these waters need to remain closed to all. They serve as sanctuary and breeding ground for the extremely endangered American crocodile. This species has lost virtually all privately owned habitat outside of ENP and Biscayne National Park and needs complete sanctuary in one of its last remaining habitable areas.
The Need for Manatee Protection
In addition to seagrass and substrate damage, manatee protection must also be a part of the revisions being made to the GMP. Manatees are a federally listed endangered species which make extensive use of the southwestern waters of ENP. A recent study conducted by the United States Geological Survey (USGS Review and Synthesis of Manatee Data in Everglades National Park; Bradley Stith, Daniel Slone, James Reid, 2006) identified boater/manatee collisions as the leading cause of death for manatees in this area
Salvage records documented 520 carcasses from 1977-2004 that were in the area of this study (Fig. 36) and for various causes (Figs. 37-44). The cause of mortality could not be determined for 45% of the carcasses recovered in the Everglades area (Fig. 37). In cases where the mortality cause was known, over 40% were from watercraft collisions (Fig. 38). Red tide and other natural causes accounted for 27%, and perinatal mortality was the cause in 20% (Fig. 39) of the known cases. Inland sites were overrepresented in the carcass database (and offshore areas were underrepresented), possibly because the carcass of a manatee that dies offshore might drift inland and be found, or float out to sea and be lost, depending on currents and tides.
This is an unacceptable level of 'take' of a federally listed endangered species. Statewide, boat collisions killed 82 manatees between January 1st and December 8th in 2006 still the largest cause of death overall and well above death rates for red tide which were estimated at 49 for the same period. And in spite of the recent decision by the Florida Fish and Wildlife Conservation Commission to change the state listing of the manatee from endangered to threatened, an Associated Press article on the topic (12/25/2006, 2006: A Deadly Year for Florida Manatees) reported scientific predictions of a 50% decrease in the total current manatee population of about 3,000 individuals due to habitat loss, boater collisions, and red tide algae over the next five decades. The manatee remains federally listed as endangered by the U.S. Fish and Wildlife Service (USFWS). The USFWS' full consultation on this issue in the preparation of the draft GMP will be a very important component of this process.
As a major source of manatee habitat already completely protected against development, Everglades National Park is in a unique position to help maintain a healthy population of manatees, the official Florida marine mammal. This will become especially true over time as more and more coastal areas and submerged aquatic vegetation are lost to development. Alternative D would again provide the best prevention against boater/manatee collisions and injury by propeller by limiting gas motor access in the narrow and shallow mangrove channels of the southwest coastal area where manatees are known to congregate and feed. It should be noted that the actual percentage of manatee deaths by boater accidents might well include many of the deaths that 'could not be determined' in the USGS study. Many of these may well have been manatees which died of infected wounds caused by boater collisions or prop damage and whose decomposed carcasses no longer showed evidence of boat or propeller impact. There is also an unknown percentage whose carcasses drifted out to sea and were never found some of which also died directly from collisions or from infected wounds caused by power boats.
The Need for Research and Science Based Decision Making
Title II, Resource Inventory and Management, of the National Park Omnibus Act of 1998 clearly points out the requirement for science based management decisions within the NPS. Sections 201 and 202 of the Act state the following
Sec. 201. PURPOSES.
The purposes of this title are-
(1) to more effectively achieve the mission of the National Park
Service;
(2) to enhance management and protection of national park resources
by providing clear authority and direction for the conduct of
scientific study in the National Park System and to use the information
gathered for management purposes;
(3) to ensure appropriate documentation of resource conditions
in the National Park System;
(4) to encourage others to use the National Park System for study
to the benefit of park management as well as broader scientific
value, where such study is consistent with the Act of August
25, 1916 (commonly known as the National Park Service Organic
Act, 16 U.S.C. 1 et seq.); and
(5) to encourage the publication and dissemination of information
derived from studies in the National Park System.
Sec. 202. RESEARCH MANDATE.
The Secretary [of the Interior] is authorized and directed to
assure that management of units of the National Park System is
enhanced by the availability and utilization of a broad program
of the highest quality science and information.
A scientific inventory of damage to the bay the site of most controversy in the current GMP process - must be a prerequisite to the selection of the preferred management plan by the NPS. As accurate photography is apparently not available on the Gulf side due to lack of clarity of water, it is only logical to assume similar conditions (and need for similar management) at the same water depths for those areas.
NPS has clearly identified Alternative D as the management plan which will maximize protection of the natural resources of Everglades National Park. As already noted, this protective aspect of NPS policy in an area that is not only a National Park but a designated national wilderness is not discretionary but mandated. Therefore, selection of a different alternative or revisions to Alternative D which would make park waters more conducive to motorized recreation must be consistent with science that indicates that this usage is not likely to damage the natural resources of ENP.
NPS, under the direction of Fred Herling, Senior Park Planner and David Hallack, Chief of Biological Resources will be conducting an updated study on seagrass damage to the park. We have been told that this study will be completed before the draft management plan is written and released to the public. The Sierra Club would recommend expanding the scope of that study to include not only an inventory of affected areas as described above, but other topics which will help determine the extent and range of boating activities consistent with the mandate of resource protection. Some variables that should be included in the study would be:
1. The effect of boat length, hull type ('V' hull vs. flat bottom), and power on damage to the seagrass and substrate. If significant findings appear on a study of these variables, NPS should conduct permitting on boats as well as of boaters. This would take place in a simple, one time inspection prior to a boat's usage in park waters.
2. The effects of varying speed limits and mandatory idle speeds on damage and protection to substrate, seagrasses, wildlife, coastal areas, and the keys found throughout Florida Bay.
3. The effects of boaters' behavior and decisions (e.g. loading of a boat and its effect on a boat's draft) in relation to sea vegetation and substrate damage. Significant findings should lead to appropriate rules as well as enforcement and penalties.
4. Buffer zones along shorelines and around keys in Florida Bay. Known bird nesting areas should all be identified and the correct no-motor buffer zones with regard to natural resource protection should be established.
5. As stated above, manatee deaths by motor boats constitute unacceptable take of an endangered species. As manatees can be found at all water depths, and rest just below the water surface where they are not easily seen, a great deal of research will be needed on how to manage gas powered watercraft safely in known manatee areas. Their movement is still not well understood and is related to a number of factors including tides, water temperature, salinity, available food supply and what appears to be a strong propensity on the part of manatees to explore new areas. However, eliminating power boats from the shallowest areas of their known habitat will almost certainly have a beneficial effect on this problem. The need for this step was identified at least as early as the 1989 study ('Recommendations to Improve Boating Safety and Manatee Protection for Florida Waterways) conducted by the Florida Department of Natural Resources.
Due to the continued high boat/barge related manatee mortality, harassment, and loss of essential habitat, it is important to manatee survival to set aside large preserves (motorboat prohibited areas) in which the animals can feed, rest, mate and give birth in relative safety.
The above list is not meant to be exhaustive of these research topics, but does indicate many of the variables and factors that relate to natural resource damage and protection within the marine waters of ENP. The more thorough the research on these topics, the more effective the management policies will be that derive from that research.
The East Everglades Expansion Area
Alternative D calls for the eventual phasing out of small private airboats (no permits other than by owners of record as of 1989 - no new permitting); the buyout by the National Park Service of three commercial airboat operations which run tours within the boundaries of ENP; and the creation of a new 106,000 acre wilderness area just west of Krome Avenue and south of Tamiami Trail less than an hour from downtown Miami. New access and camping opportunities are to be provided for paddlers.
As this area is in the heart of Shark River Slough, the main source of water for most of ENP, airboat trails are not to conflict with the terms of the Everglades Expansion and Protection Act which calls for the restoration of "the natural hydrological conditions within the park." The elimination of airboats from this area will greatly facilitate a return of the natural vegetation and hydrological flows (a study conducted in the adjacent Big Cypress National Preserve found that airboat trails increased water flow five times over surrounding areas regardless of their directional orientation); decrease stress on animal life (commercial airboats are enormous and loud twin engine 'buses'); and provide visitors with a tranquil experience of the natural ecosystem that is very near and accessible to the dense urban populations of the east coast of Florida. Fishing opportunities and access to fishing spots south of Tamiami trail would improve as well as a result of this decision.
It is also absolutely essential that designated airboat trails for private airboat owners be established and laid out so that paddlers can have safe and tranquil access to this easily accessible area without the noise or danger of an airboat encounter. Given the proximity to Miami, we can expect this area to receive heavy use from paddlers once access is provided. Routes should be created for those who want access to the natural soundscape of East Everglades and the wildlife viewing opportunities the quiet atmosphere will facilitate. Freedom to paddle without worrying about a collision with an airboat in the dense sawgrass of this area is also a major consideration in the establishment of routes for both types of users.
East Everglades is a great representation of the 'classic Everglades' sawgrass and alligator marsh habitat and ridge and slough topology (low wet areas interspersed with higher tree hammocks). In extremely wet seasons, it allows for a canoe/kayak route from Tamiami Trail to Florida Bay through the historical waters of Shark River Slough. New visitor access in terms of canoe and kayak rental concessions, walking trails and boardwalks should be constructed to allow for non-damaging usages of the area by tourists and residents alike. Currently there is no public access to this area for paddling activities as the private concessions do not permit passage through their properties. The L67 Canal extension runs along the western boundary of the expansion area and does allow access to the park. However, it is a completely confined north-south channel offering no paddling access to the surrounding Everglades for the first 7 miles south of Tamiami Trail.
The buyout of the airboat concessions will also make it easier for the eventual construction of the Tamiami Trail Skyway. This eleven mile elevated roadway has been identified by the Army Corps of Engineers as the optimal method for restoring sheetflow into the main body of Everglades National Park. This project is very much supported by the Sierra Club as it will bring in much needed water to vast areas of ENP.
The Wilderness Waterway
Alternative D provides for the creation of a non-motorized paddling route adjacent to a motorized passage from Flamingo to Everglades City. This is currently a challenging 99 mile route for canoeists and kayakers which for many is a once in a lifetime experience of south Florida. It requires about 7 hours by outboard motor versus 9 days by paddling. The ability to be in contact with true wilderness for an extended period of time away from the sounds, wakes and exhaust fumes of motorized transport, as well as other characteristics of modern life, and to rely only on one's own ability and skills in navigation and outdoorsmanship is a part of the heritage of south Florida. From the Calusa people who first inhabited this area to the Miccosukees, Seminoles and early European and American explorers and setters (see the late 19th century chronicle 'Across the Everglades' by Hugh Willoughby), people have explored and fished this area by cypress dugout, canoe and now kayak. If one looks at the other access points to the park the Ernest Coe Visitor Center, the Shark River tram route off Tamiami Trail, Florida Bay off of US 1 or Flamingo none of these offer the ability to explore the Everglades backcountry in the relatively protected, tranquil, and natural setting of the Wilderness Waterway canoe and kayak route.
Kayaking and kayak fishing are two of the fastest growing outdoor sports in the United States. Establishing and publicizing a completely non-motorized 99 mile route through the backcountry of ENP, and providing for sufficient chickees and other campsites, will greatly increase this route's attraction to those who seek out one of the last remaining areas in south Florida available for a wilderness experience. As Florida's population continues to grow, areas like this will become that much more rare and precious for what they offer. The new, non-motorized Wilderness Waterway will in all likelihood never see the crowds who go off on the glass bottom boats from the Flamingo marina to view Florida Bay on a short and comfortable 'sunset cruise'. However, it does offer the kind of experience many Americans still value above all others.
Concluding Remarks
ENP is a vast and diverse park with many management zones, ecosystems, recreational activities, and users. As the DOI management guidelines point out, users of a national park include not only those who actually visit the park but those who 'enjoy a national park from afar'. Countless authors, filmmakers, artists and photographers have attempted to describe the Everglades in travelogues, paintings, mystery novels, photographic essays, documentaries, scientific studies, feature films, television programs, natural field guides, histories and, with the writings of local author Carl Hiaasen, even comedy. There seems to be a never ending fascination about this part of Florida that has captivated and intrigued the world as a whole for hundreds of years. Much about it is still unknown, and new information about its geology, biology, and history are uncovered on a regular and almost routine basis.
In writing these comments, we have had a great deal of discussion amongst ourselves on the needs and desires of different users. As noted above, we are not against the use of powerboats in the marine waters of Florida Bay or the Gulf Coast. Many of our members are kayakers (as well as powerboaters and anglers) and fully recognize that Florida Bay is not a body of water that can be easily negotiated by paddling. Distances and wind conditions are such that, unless one is planning on an overnight in one of the camping locations on the bay, powerboats provide access if any appreciable distances off of US 1, Flamingo or the Gulf Coast are to be covered. However, we have successfully shown in these comments that motorized access can take place in such a way that the natural resources of ENP are not compromised and that the many users who seek out a wilderness experience are able to have that experience in a park established for that purpose.
In May of this year, The USFWS released its 2006 National Survey of Fishing, Hunting and Wildlife-Associated Recreation. This survey has been conducted every 5 years since 1955 and is considered to be the most definitive study and database with regard to wildlife related recreational activities of Americans. While these activities appear to be extremely important to Americans with 87 million participating (and spending $120 billion in the process!), there were some interesting trends. Comparing numbers from the 1996 study to the most recent one, the numbers of people participating in hunting and fishing were down (10 and 15 percent respectively) while those who participated in wildlife watching were up 13 percent. Total numbers also favored wildlife watching with 71 million participating in this activity in the current survey as compared with 12.5 million participating in all forms of hunting and 30 million in angling. These numbers are not exclusive and some Americans participate in all three of the activities covered in the survey. It should also be noted that in counting those who participated in wildlife watching, a "strict definition" was utilized. As stated in the survey results
Participants must either take a "special interest" in wildlife around their homes or take a trip for the "primary purpose" of wildlife watching. Secondary wildlife-watching activities such as incidentally observing wildlife while pleasure driving are not included.
An attempt at explanation for these changing patterns in the way Americans recreate in the outdoors lies beyond the scope of these comments. But they do perhaps hint at the explanation for two recent surveys which dealt with American's views on how they want their national parks managed and for what purposes. As more and more of our natural world disappears, there seems to be a renewed appreciation for what's left. The results of these national surveys are both clear and consistent.
1. Los Angeles Times/Bloomberg Poll. July 28-Aug. 1, 2006. N=1,478 adults nationwide. MoE +/- 3.
"As you may know, some national parks are very popular and draw large crowds. In managing those parks, officials must decide between providing more access to the public by adding roads and opening up more parkland to motorized recreational vehicles, such as snowmobiles and ATV's or All Terrain Vehicles, or protecting natural habitats and wildlife. Should officials give the public more access by opening up parkland, or should officials limit or restrict such access?"
More access - 18%
Limit access - 77%
Unsure 5%
2. Washington Post-ABC News-Stanford University Poll. April 5-10, 2007. N=1,002 adults nationwide. MoE +/- 3.
Question 26. What do you think should be a higher priority in management of the country's national parks? (protecting natural habitats and wildlife), or (providing public access for recreational use)?
Protecting natural habitats and wildlife - 79%
Providing public access for recreational use - 13%
Both - 7%
No opinion - 1%
Question 27. And regardless of your own preference, which of these do you think is currently getting a higher priority in the management of the country's national parks? (protecting natural habitats and wildlife), or (providing public access for recreational use)?
Protecting natural habitats and wildlife - 34%
Providing public access for recreational use - 56%
Both - 2%
No opinion - 8%
While not utilizing the scientific sampling procedures found in the above surveys, a more specific survey was run June 21st, 2007 in the Ft. Lauderdale Sun-Sentinel Newspaper alongside an article on the topic of seagrass damage and recreational access in ENP. The results were very similar.
Worried about damage to seagrass and the environment, Everglades National Park may ban powerboats longer than 24 feet in Florida Bay and establish extensive no-motor zones. Your opinion?
Good idea 85.3% (4009 responses)
Bad idea 10.4% (488 responses)
I'm not sure 4.4% (205 responses)
Total responses 4702
What these surveys all point to is how seriously concerned Americans are about the health of our National Parks and what their priorities are in the way they want them managed. In a secular society they may well be the closest thing we have to 'sacred places'. They are rightfully famous throughout the world for their vastness, isolation and natural beauty. As populations continue to rise and development destroys more natural habitat worldwide, they are also increasingly unique places which will grow only more unique in the future. And while few citizens would necessarily be familiar with the Organic Act and other legislation that determines national park management practices, the principles, values, and ideas put forward in those laws and regulations do seem to be the same ones which are held by the overwhelming majority of Americans.
Everglades National Park is practically synonymous nature in Florida. It has received national and international recognition for its biological importance to our nation and to our planet. Well over a million people visit ENP annually to experience its beautiful landscapes and its wildlife. It is currently a major focus of an unprecedented effort by countess individuals, environmental and sportsmen's groups, corporations, elected officials, engineers, lawyers, lobbyists, scientists and divisions of local, state and federal government to fund and restore an ecosystem almost completely destroyed by man in a short and very recent period of time. In choosing the preferred management plan, please take into the consideration what version of Everglades National Park the American people want future generations to inherit.
Sincerely,
Matthew Schwartz
Political Chair and Outings Leader,
Broward Group of the Sierra Club
Member,
Florida Chapter of the Sierra Club Everglades Committee
Kim Anaston-Karas
Drew Martin
Co-Chairs,
Florida Chapter of the Sierra Club Everglades Committee
Sierra Club Contributors:
Mark Oncavage
Peter Rauch
Brian Scherf
Mara Shlackman
Roderick Tirrell
Kristina Trotta
Jonathon Ullman