Broward County Government Contacts
Big Cypress Lands
Sierra Club's Everglades National Park GMP Comments
BIG CYPRESS LANDS |
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June 14, 2007
VIA EMAIL Mary Bomar Pedro Ramos Dear Director Bomar and Superintendent Ramos, These comments are being submitted by the Sierra Club, representing
over 750,000 members nationwide, in response to Newsletter #5,
Revised Preliminary Alternatives, Big Cypress National Preserve
(BCNP) Addition Lands. The Sierra Club fully supports Alternative
F and urges the National Park Service (NPS) adopt this alternative
as its preferred management plan. Covering nearly the full range
of habitats once found throughout the historic boundaries of
the Big Cypress Swamp pine uplands, cypress strands, hardwood
and sabal palm hammocks, marshes and various types of prairie
the Addition Lands remain a small but crucial living example
of Florida's natural heritage. The Wilderness Eligibility Study The Sierra Club rejects Alternatives B through E as suitable
management alternatives for the Addition Lands. The Addition Lands represent one of the last pieces of the once vast Big Cypress Swamp that retains in large measure its original characteristics. The section of the Addition Lands north of I-75 contains rare patches of pine uplands that are distinctly different and at higher elevations than exist virtually anywhere else in the preserve. It is to the credit of the National Park Service that staff recognized these characteristics and elected to identify fully 109,000 acres of this land as "wilderness eligible". Once covering nearly the same sized area as the original Everglades, and spreading over almost the entire terrain from the western edge of the Everglades to the gulf coast, huge chunks of this unique wetland have been lost to development and continue to be lost to new projects. Relatively small patches such as the Fakahatchee Strand, Corkscrew Swamp Sanctuary, and the Florida Panther Wildlife Refuge remain but are fragmented and divided by roads and development. In spite of being transversed by Interstate 75 in the north and Tamiami Trail in the south, the main body of the Big Cypress National Preserve contains the largest remnant of this once great swamp. Yet the effects of years of dispersed use of recreational ORVs have scarred huge swaths of this land almost beyond recognition (see NPS aerial photo). In spite of the 1995 settlement with Florida Biodiversity, dispersed use of ORVs continues to this day and a brief flyover will still reveal huge sections of disturbed soil and vegetation. With the removal of vegetation and oxidation of fragile soil, much of the original preserve has been significantly degraded as habitat for the preserve's 30 listed animal species and 72 listed plant species. A number of the detrimental effects ORVs have had on the Big Cypress ecosystem are worth noting in detail. Almost all of the research the NPS has assembled in their own analysis of the effects of ORVs was conducted in the original preserve. This was of necessity as during the period when these most of these studies were done, the Addition Lands have been off limits to recreational ORVs (except for limited access by inholders to access their property plus some illegal usage). But the Addition Lands are part and parcel of the same ecosystem and all of the noted effects would apply.
Effects on the Florida panther. We are enclosing with these comments two telemetry maps which demonstrate the high concentration of panthers in the Addition Lands north of I-75. These are taken from the Off-road Vehicle Management Plan (ORVMP) written for the original preserve in 2000 and from the Florida Fish and Wildlife Conservation Commission's Florida Panther Annual Report, 2004-2005. These telemetry maps are backed up by a 2006 telephone conversation Sierra Club officer Matthew Schwartz had had with Darrell Land of the Commission where he estimated that somewhere in the neighborhood of twenty to thirty panthers might use the Addition north and south of I -75 throughout the course of the year. In examining the effects of ORV use in Big Cypress, the ORVMP cites the four year Janis and Clark study which examined panther use of Bear Island adjacent to the western boundary of the Addition Lands (The Effects of Recreational Deer and Hog Hunting on the Behavior of Florida Panthers, 1999). This study concluded that panther use of the area decreased from 30 to 40 percent during hunting season. In the ORVMP, the U.S. Fish and Wildlife Service concludes that the reduction of ORV trails in Bear Island will likely produce benefits to the panther but maintains that "The panther will continue to move away from designated trails in Bear Island and possibly elsewhere as a result of the proposed action. This could alter normal breeding, feeding, and sheltering behavior." (ORVMP, page 577) In the case of the Addition Lands, four out of five of the alternatives being considered (Alternatives B through E) would introduce designated ORV trails into areas of panther habitat which currently do not have them. The area is contiguous with Bear Island and one would have to conclude a negative effect on the extremely threatened panther if any of the alternatives with an ORV trail component are compared with the current baseline on no recreational ORV activity (the No Action alternative). In the Janis and Clark study, the authors note that private lands north of the preserve are utilized by panther as "refugia" and conclude that it would be a "serious concern" if these lands were lost to panther use. That situation has in fact occurred with Collier County adding hundreds of thousands of new residents in the years since the study was carried out. The Ave Maria planned community in Collier County alone will add approximately 30,000 residents to former panther habitat. As remaining habitat for the panther continues to shrink, the re-introduction of recreational ORVs to the 146,000 Addition Lands a sizeable portion of remaining primary habitat for the panther will certainly result in pressure on this extremely endangered species. Hydrological changes and surface waters The L-28 Interceptor canal runs generally northwest-southeast through the northeast corner of the Addition Lands. It drains an area considered the general boundary between the waters of the Everglades and those of Big Cypress Swamp. It has been described as south Florida's very flat "continental divide". Historically, some waters from the Everglades would have seasonally drained into Big Cypress Swamp across that divide and added to the gentle sheetflow of water moving in a generally southwest direction. As the NPS is well aware, the Comprehensive Everglades Restoration Program (CERP) has earmarked the L-28 Interceptor Canal for full or partial removal in order to restore the previous movement of water in this area. The ORVMP discusses hydrological changes in the preserve which can be caused by ORV activity. This relation, while not entirely understood, is described in the following passage "ORV ruts, which can be 2 or more feet deep, can channel water and potentially alter natural water flow patterns and timing. Two studies have documented greater water flow rates within ORV ruts than in adjacent undisturbed areas. Duever et al. (1981) found that over wet and dry seasons, water flows accelerated from two to four times in trails oriented parallel to the direction of water flows. Flows in some trails continued after water had ceased flowing in surrounding areas, possibly leading to a shortened natural hydroperiod in a localized area". These completely unnatural water flows work completely against the mission of CERP, which is to restore, as much as possible, the natural flow of water to the areas of south Florida in need of remediation. This is essential to retaining the incredible diversity of native plants and animals of south Florida which are unable to adapt to the severe changes technological reworking of the landscape has brought in only about the last 100 years. With the tremendous public investment in the CERP project and the high importance given to it by Congress and the Florida state legislature, the re-introduction of ORVs into this area with their enormous documented potential for gouging out what are essentially mini-canals in the soft, loose soils of the Addition Lands should simply not be done. And while it can be argued that some of the trails that would be utilized are existing trails, the ORVMP also makes it clear that these trails would only deepen and widen with greater use and expand their capacity for the hydrological disruptions described above. Invasive Species The spread of invasive plant species is another area that has been cited with regard to ORV use in the preserve. Again as stated in the ORVMP "Invasive Plants. There are indications that ORVs have resulted in the spread of invasive plants, such as Schinus terebinthefolius (Brazilian pepper), Melaleuca quinquenervia, Typha (cattail), and Lygodium microphyllum (old world climbing fern) within Big Cypress National Preserve. ORVs can collect seed in their tire tread and beds and distribute it in currently unaffected areas of the preserve as they travel (Pernas 1999)". According to the preserves own website, "Exotic plants are displacing native vegetation and destroying habitats needed for ecosystem health". The huge diversity of plant species in Big Cypress is one of its most special and valuable qualities. A recent (2003) study - Plants of the Big Cypress National Preserve published in the Journal of the Torrey Botanical Society emphasizes this diversity and the threats to it from invasive species. From the abstract "A new survey of the Big Cypress National Preserve shows that the vascular flora consists of 145 families and 851 species. Of these, 72 are listed by the State of Florida as endangered or threatened plants, while many others are on the margins of their ranges. The survey also shows 158 species of exotic plants within the Preserve, some of which imperil native species by competing with them. Finally, we compare the flora of the Big Cypress National Preserve with those of the nearby Fakahatchee Strand State Preserve and the Everglades National Park. Although Big Cypress is less than half the size of Everglades National Park, it has 90% of the native species richness". This study goes on to point out that the survey was undertaken in the main body of the preserve and the authors believe that there are significant numbers of plant species not yet identified and inventoried in the Addition Lands. The risk to this national treasure of botanical diversity by recreational motor vehicles directly damaging plants by crushing, and uprooting, oxidation and degradation of soils, destruction of underlying root systems, and by facilitating the spread of invasive species in disturbed soils to this resource is simply too great to be acceptable. Other physical damages to the natural resources of the preserve The ORVMP lays out a complete list of natural resources that are impacted by the use of off-road vehicles in Big Cypress National Preserve along with the science that substantiates it. It is a very comprehensive document and we have quoted from it at length in our previous comments on this topic. The effects on the soil and vegetation are obviously the most visible and easily noticed of these. As noted in the ORVMP "ORV use causes soil rutting, displacement and compaction. This causes soil loss or reduced productivity. (ORVMP, page 19). This was quoted in previous comments and it is restated here. In prairies, huge amounts of soil and vegetation have been lost as ORV drivers are forced to move laterally on to undamaged ground in order to gain traction for their vehicles. In addition, as ruts deepen with use, they often become too deep for the passage of axles and the undercarriage of smaller vehicles. This again forces drivers to move to undamaged ground in order to gain clearance. When the NPS has attempted to correct both of these conditions through the use of geotextiles and the dumping of limestone on top of these areas, they essentially create roads which completely change the ground cover and remove vegetation as well as marring the landscape and taking away from the wilderness character of the preserve as called for in the enabling legislation. Concho Billy Trail off of Turner River Road in the main body of the preserve is one example of the NPS attempts to prevent damage to the natural substrate on a heavily used ORV route. The stabilized portion of Concho Billy trail has had its own very severe effects that completely detract from the wilderness character of the preserve. It is in essence a road that a car could negotiate fairly easily. Damage to the vegetation buried under it as well as presumed changes in surface water flows caused by significant raising of the roadway are other serious considerations. "Fragmentation" of the Addition Lands in Alternatives B through E Years of accumulated science have indicated the known and likely damaging effects of ORV usage on the Big Cypress ecosystem. Alternatives B through E totally neglect that large body of knowledge and the negative impacts which ORV trails, ORV usage and the proposed "Management Zone" delineations will create in the Addition Lands. They would re-introduce their effects on an area that has not had such usage in more than a decade. Recovery of soil and vegetation from past use is occuring in some locations of the Addition Lands due to the current moratorium on recreational ORV usage. In others, especially areas of moderate to heavy compaction, recovery is still a long way off and, according to the ORVMP data on this issue, will be difficult to achieve. The damage is however, not being exacerbated by new usage at this time. ORV trails in the proposed "Backcountry Recreation" areas will disrupt and split the continuity and quality of wilderness in the area, create habitat fragmentation, intrude on both the visual landscape and the soundscape, and will create unnecessary and detrimental "Front Country" intrusions within the proposed wilderness areas. Portions of the exceedingly rare south Florida terrain which have met the rigorous standards for federal wilderness eligibility will be lost. The resulting patchwork of wilderness and non-wilderness areas will create a complex multitude of border areas as trails and users move from one management zone to another. User conflicts of many types brought on by the usage of recreational ORVs are extremely likely in alternatives B through E. Signage and law enforcement will also be necessary throughout the area and usage rules will be extremely difficult to enforce as will be noted in the section which follows. NPS budget and managerial considerations While ecological concerns and the enormous potential ORVs have for damage to natural resources are paramount in the Sierra Club's rejection of Alternatives B through E as viable management options for the Addition Lands, there are other factors to consider. Setting aside for the purposes of this discussion the legal issues associated with the Bear Island trails, they are a useful example for an analysis of this topic. Before being re-opened to recreational off-road motor vehicles, eastern Bear Island was a popular destination for Sierra Club organized walk-in hikes from the I-75 mile marker 70 access gate. Access directly from the interstate is easy and parking is located right next to the trail head. There was no signage beyond the trail head, no off-road vehicle trails to maintain, no need to enforce illegal usage in terms of motor vehicles driving off designated trails, no need to consider or implement trail 'stabilization' and certainly no need to have plastic reminders placed throughout the area reminding drivers to stay on the trail. The area's many prairies and marshes appeared untrammeled and organized hiking groups and interested tourists would simply walk in from I-75. Visitors were completely self-reliant in an area that had remarkable scenic beauty as well as the same wilderness characteristics the NPS now attributes to the bulk of the Addition Lands. With the re-opening of this section of the preserve at the end of February of 2007, this situation has completely changed. From a low to no maintenance area, the Big Cypress Administration has now spent huge amounts of time and labor on ORV trail layout, mapping, signage, public communications, monitoring, law enforcement, and legal considerations and consultation. This was obvious during a hike to this area in mid-April of this year after the conclusion of the spring turkey hunting season. On a single 10 mile loop (walking north from the I-75 mm 70 access gate, east at the furthest south secondary trail and then counter-clockwise around the primary trail back to the I-75 walk in trail) Sierra volunteers counted and marked by GPS nearly 50 locations where drivers had gone off either the primary or secondary trails leaving noticeable impacts on the terrain. The most used starting points for those excursions off designated trails were marked by the NPS with plastic posts or barricades detracting enormously from the wilderness character which prevailed in this area just a short time ago. We should point out that there were also a number of low lying locations in prairies where the areas being driven over had been denuded of vegetation and had widened out to the width of many vehicles. This was most likely due to the traction factors noted above. There were also newly made trails marked 'closed' and not showing up on any of the trail maps provided by the preserve administration and that extended for lengthy distances through the terrain. This area is mostly prairie and the ORVMP does point out that with their complete lack of natural obstacles, prairies offer virtually no natural resistance to dispersed use. And this in spite of signage and written instructions to ORV permit holders. If the re-opening of these trails does survive legal challenge, a great deal of preserve funds will be needed to sustain them without unacceptable impacts to preserve resources. With National Park Service money concerns always an issue, there is no point in adding to an already financially strained preserve budget by taking on the responsibility of ORV trail layout, maintenance, and law enforcement operations in an area where the use of recreational motor vehicles is not essential to the purpose and values of the preserve. In fact, ORV use will be harmful to preserve natural resources and create user conflicts. When the ORVMP for the main preserve is actually implemented, ORV enthusiasts will have access to 400 miles of primary trails plus an untold number of miles of secondary trails. Most of the original preserve is and will remain accessible to ORV travel and much of it is currently accessible to dispersed use as the ORVMP has in large measure not been implemented. Law enforcement in the preserve is already at minimal levels for a preserve of this size and the situation in Bear Island is ample proof of the difficulties involved in ORV trail management. In addition, few if any of the 25 research items enumerated on pages 60 to 63 of the ORVMP and deemed important to management decisions with regard to ORVs have been started or completed. Fourteen of these were given 'high priority' by the plan. For example, a proposed project would have identified and analyzed the cumulative effects of ORV use over time. According to the ORVMP its cost was estimated at $400,000 and was justified by the "need to comply with NPS mandate to protect resources in perpetuity". Other studies would have looked at ORV impacts on surface water flows, on the Florida panther, on vegetation and invasive species, and on the natural soundscape and attempt to establish a natural baseline of ambient sound. The reason given by the administration for the preserve's failure to carry out these studies has been lack of funds. The Addition Lands are a short hop from the extremely dense populations of south Florida which are growing more crowded by the day. The pressure will be far greater than in the Bear Island area with millions more residents located in the nearby communities than is the case in the western part of the preserve. The Addition Lands are also much further from the preserve's administrative headquarters. Illegal hunting and ORV travel in the Addition in areas off the Interceptor is already a problem now when the area is currently off-limits to both activities. Opening up the area to legal use as Alternatives B through E would do will not only bring legal permitted drivers into the area, but will make distinguishing between legal and illegal (i.e. non-permitted drivers and vehicles) far more difficult should law enforcement actually be available to check permits or to police designated trails. If alternative F is chosen and the current lack of use by recreational motor vehicles travel stays in effect, the area's natural resources can be maintained with minimal maintenance, enforcement or expenditure. User conflicts As the last topic for analysis in these comments, the huge potential for user conflicts which would certainly occur should recreational motor vehicles be allowed access to the Addition Lands is by no means the least important. This topic has inevitably been touched on in several of the above sections as we are asked to imagine the future of the Addition Lands. The Addition Lands represent one of the last wilderness areas in south Florida certainly the one most accessible to residents of Broward, Palm Beach and northern Miami-Dade Counties. Only officially in the public's hands since 1996, many south Florida residents are only just now learning of their existence. New people are constantly going out on Sierra Club sponsored hikes, as well as hikes and outings organized by other organizations. Visitors never fail to marvel at the beauty, solitude, quietness, and remoteness of an area so close to our urban communities. These lands are thus being utilized by a growing percentage of the millions of residents who live in the gateway community and who see the Addition Lands as a place to experience tranquility, view native flora and fauna, or just escape from the chaos of an ever more crowded area. Local teachers with an interest in ecological issues have expressed a desire to the Broward Group of the Sierra Club in bringing their students out to get a first hand look and experience of the original Big Cypress Swamp. Educational activities constitute an area of use which can and should definitely be developed in the future. All of the above usage conflicts with damage to the ecosystem and changes to the natural smells, sounds and landscapes which would be introduced in the Addition by alternatives B through E. As we have noted above, the NPS estimates 450,000 annual visitors who do not utilize ORVs during the course of their visit. While granting access to ORV enthusiasts, many of these non-ORV using visitors the vast majority of which come from outside the gateway community - would lose access to the values that bring these visitors to the preserve in the first place. Bird and wildlife viewing opportunities would also decrease. This reference from the ORVMP is worth quoting "Other Visitation. Approximately 450,000 people who visit the preserve each year engage in activities other than those associated with ORV use. There is concern that noise and visual intrusions resulting from ORV use may adversely affect these non-ORV preserve visitors. ORV use and its impact on vegetation and soils could impact the scenic quality of the preserve, especially in areas frequently used by other visitors such as near roads, hiking trails, and campgrounds. ORV use could also affect natural sounds, and viewing opportunities for wildlife". As virtually all of the Addition Lands are easily accessible by hiking trails off of I-75 or the Interceptor Canal road, all of the above impacts and conflicts are likely in alternatives B through E. Far from being difficult to reach by foot, the flat soft landscape of the Addition Lands makes for exceptionally easy walking. Senior citizens are frequent attendees on Sierra Club sponsored outings in the Addition. A change of dry footwear for the wet season is a very small price to pay for this experience of south Florida wilderness. In attempting to understand visitation patterns to the preserve, the NPS undertook a visitor study conducted by the Cooperative Park Studies Unit, University of Idaho (Meehan, winter of 1999). As noted above, the single largest group of users to BCNP are not locals or even visitors from Florida, but tourists from out of state or from outside of the U.S. These visitors have either read about the preserve in one of the many citations found in every tourist guidebook written for Florida, heard about it by word of mouth, or were attracted to it by a roadside sign. Yet in spite of being by far the largest group of users, few are on the mailing list to receive Big Cypress/NPS newsletters and are completely 'out of the loop' as far as the current discussion and comment period is concerned. Sierra Club officers had some discussion on this topic with NPS officers present at the May, 2007 public meeting in Weston. It was agreed that NPS would, in the future, attempt to 'capture' contact information of visitors at the main visitor's center and solicit opinions on important decisions being discussed with the public. Reference to the summary of findings from the user study will help compensate for the lack of input from this user group in this latest and most critical round of comments. According to the newsletter #5, this is the last opportunity for the public to weigh in prior to NPS' draft decision on how the Addition Lands are to be managed. As reported in the ORVMP "The Big Cypress National Preserve visitor study conducted in the winter of 1999 by the Cooperative Park Studies Unit, University of Idaho (Meehan 1999) identified general visitor demographics as follows. These findings are based on 857 questionnaires that were distributed January 2 through 10, 1999 at nine locations; 582 surveys were returned for a 68 percent response rate. Surveys were distributed at many locations, including ORV access sites and hunter check stations. Twenty-five percent of total visitors surveyed were Florida residents. New York, Indiana, and California followed with 4 percent each. International visitors from 21 countries comprised 21 percent of the visitors surveyed. Germany, Canada, and England were the most frequently cited countries of origin. Twenty-two percent of those surveyed had used an ORV during their visit to the preserve. Of those, 70 percent had been on a commercial airboat tour, 15 percent used a street-legal 4 x 4, 11 percent used an all-terrain cycle, 10 percent used a swamp buggy, and 2 percent used a privately owned airboat. This totals more than 100 percent because a few individuals had used more than one type of ORV. Birdwatching, viewing wildlife, sightseeing, experiencing wilderness, and experiencing solitude were rated as the most important activities by those surveyed. To the question, "What did you like least about your visit to Big Cypress National Preserve?" the most frequent answers included lack of information, poor quality of roads, too much litter, hunting and fishing, people driving too fast, ORVs and ATV's, lack of animals, lack of time, and too many bugs. Another question was "If you were a park manager planning for the future of Big Cypress National Preserve, what would you propose?" Frequent responses included better signage; more guided foot and bike tours; need to promote the area; boardwalks into wet areas; increased number of trails; more overlooks and roadside parking areas; improved quality of roads; discontinue ORV, airboat, and ATV usage; prohibit hunting and fishing; discontinue mining and drilling; no further development; expand preserve boundary; provide careful preservation of area; and restore water quality". As we noted, this NPS user study may be the only sizable sample of opinions obtained from non-Florida visitors. The results should be included in all deliberations on what factors this large class of users expect the NPS to consider in making their decision and what their preferences are. Completely consistent with the above findings from the NPS user study, were the results of two recent national polls which asked questions related to respondents' preferences of management priorities by the NPS. The results of these surveys are below 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?" 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)?
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% On these and other studies, the American people consistently voice similar opinions on the topic of how they wish units of the National Park Service to be managed and what principals should hold sway. These same types of results were again provided to the Department of the Interior when the current management policies were revised and the American people weighed in on the subject during the comment period. Over 45,000 responses were received. The Department of the Interior's 2006 decision to maintain the priority of natural resource protection over recreation, and to choose resource protection over recreation whenever there was a conflict between the two, is the result of that same sentiment. Apparently, protection of the natural resources found in our National Park system are valued above all else by the American people. Hunting The question of hunting in the Addition Lands was not raised in the newsletter and we will not dwell long on that topic here. Many Sierra Club members are themselves hunters and are deeply involved in the struggle to preserve remaining animal habitat. However the Sierra Club would raise the question of compatibility between hunters and non-hunters using the Addition Lands simultaneously. As the hunting season in the main part of the preserve extends almost unbroken from September to April, many passive users who do not feel safe or comfortable walking in an area where hunting occurs will in fact lose their access to these lands during the most comfortable months of the year. This effect could be mitigated by having hunting seasons which are considerably shorter than those in the main part of the preserve. This is done in other parts of the state. Another solution would be to maintain the current restriction on hunting in the Addition Lands. According to the Florida Fish and Wildlife Conservation Commission, of the 720,566 acres in the total preserve including the Addition Lands, fully 565,848 are already managed by the FWC as a Wildlife Management Area (WMA). With a total acreage of about 5.6 million acres of state, private and federal land open to public hunting, the acreage cooperatively managed with the NPS as a WMA in Big Cypress already represents about 10 percent of the total of public hunting land for the entire state. Having a small portion of the preserve (approximately 20%) off-limits to hunting would have the immense benefit of easing user conflicts while also acting as a recharge area for species that would move into other areas of the preserve already managed as a WMA. The other question that would be necessary to answer with regards to hunting would be the potential effect the removal of prey species (e.g. feral hogs and white tail deer) would have on the endangered Florida panther population in this area. Humans and panthers would in effect become competitors although it would be for the purpose of recreation for the former and survival for the latter. Conclusion The ORV management plan for the original preserve and the
one being considered for the Addition Lands differ in a very
fundamental way. In the case of the original preserve, an ORV
management plan was written in response to a successful lawsuit
by the Florida Biodiversity Project and others which essentially
charged that the NPS was in violation of laws and legislation
which demanded that the NPS place protection of natural resources
above recreation. These laws also unanimously demand that whenever
there is a conflict between the two, NPS must decide in favor
of resource protection. The resulting management plan was adopted
to decrease the harmful impacts of ORVs which had previously
been allowed virtually unfettered use of the preserve. The impacts
were obvious and Big Cypress National Preserve had developed
the reputation as one of the most poorly managed units of the
entire National Park system. In the current NPS newsletter, the NPS communicates that it will begin the writing of the draft management plan and supplementary EIS at the conclusion of this comment period and present it to the public for review by next summer. It is highly unlikely that in this short time significant new research will be undertaken to examine the impact the re-introduction of ORVs will have to this special area. The Sierra Club therefore requests that all of the extensive scientific research already conducted on this topic and incorporated into the ORVMP be utilized in the decision making process. Any more recent research which has not been included in the ORVMP or any research completed within the time period in which the draft is being written should of course be included as well. With some degree of natural variation based mainly on slight differences in elevation and soil depth, the area constitutes a single ecosystem and the effects ORVs have already had in the main body of the preserve will not differ significantly from those that would occur with their re-introduction to the Addition. It is not possible to cover all areas of concern with regard to the health and vitality of the unique Big Cypress Addition Lands. During an open house discussion last summer on the future of the Bear Island area, Dr. James Burch, supervisory botanist at Big Cypress shared his opinion with Matthew Schwartz that Big Cypress and the Addition Lands may well contain more biodiversity than any land in the continental United States. This should definitely qualify Big Cypress as far more than just a place for recreation. With 72 listed plant species and 30 listed animal species it is in fact a national treasure that needs as much protection as the American people as a whole are willing to give it. Many of the threats to the biological resources of the preserve come from outside the preserve's boundaries, and these must of necessity be outside the scope of these comments. For example, a male panther can have a home range of approximately 200 square miles. While part of this range might be in Big Cypress, other parts are on private land which all too often is being lost as habitat to development. There is little the NPS can do to prevent that but it can assure that habitat which is essential to the panther on property it does have control over is given maximum protection. This obviously means not re-authorizing an activity such as the use of recreational ORVs that best available science says will cause panther movement away from that activity. For panthers in the Addition Lands there is no new habitat outside of the preserve boundaries for them to move into and frequently less. Another example of serious damage from outside the preserve can come from harmful chemicals entering the ecosystem through air and water. The preserve and the Addition Lands dodged a very dangerous bullet only just last week when Florida's Public Service Commission (PSC) voted to deny a 'determination of need' for two proposed coal power plants that were to be sited just southwest of Lake Okeechobee in Glades County. Although the PSC decision was based on cost effectiveness of the proposed plants, both Dan Kimball, Superintendent of Everglades National Park and Karen Gustin, Superintendent of Big Cypress National Preserve expressed serious concerns for the amount of pollution that would have been released in the area surrounding these coal plants. The Sierra Club very much appreciated those opinions being expressed to the decision makers and we agreed fully with that concern. The amount of particulate matter and chemicals such as mercury which would have been released into the south Florida atmosphere and which would have entered the food chain and led to biological accumulation could have been devastating to life throughout the preserve. As energy needs and factors like auto exhaust grow with population, it is likely that issues like the coal plant will soon arise again in the future. It is thus extremely important that any incremental steps that the National Park Service can take to give this precious ecosystem the maximum protection possible be undertaken. ORV use in Big Cypress has been shown to be damaging to the main body of the preserve with effects that only worsen with time. If the NPS is to act in accord with the eloquent language of the Organic Act and manage the Addition Lands of Big Cypress National Preserve "in such manner and by such means as will leave them unimpaired for the enjoyment of future generations" then it will go along with the will of the vast majority of Americans, the true owners of this land, and choose an alternative that provides maximum protection for this small slice of wild Florida. Alternative F is by far the one most in accord with this language and allows for use and enjoyment by all while at the same time protecting the natural resources of this national treasure. With the expansion of the designated wilderness area along the west edge of the Interceptor Canal described above, the Sierra Club strongly urges the NPS adopt alternative F as its preferred management plan for the Addition Lands. Sincerely, Matthew Schwartz Kim Anaston-Karas Photos enclosed with comments - Cypress dome and prairie BCNP Addition Lands |