February 12, 2016
Tamara Whittington, Superintendent
Big Cypress National Preserve
33100 Tamiami Trail East
Ochopee, Florida 34141-1000
Subject: Backcountry Access Plan/Wilderness Study Newsletter
Dear Superintendent Whittington:
I am writing to you on behalf of over 1,100 members of the Coalition to Protect America’s National Parks (Coalition). Our membership is composed entirely of retired, former, or current salaried employees of the National Park Service (NPS). As a group, we collectively represent more than 30,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. We count among our membership former NPS employees of Big Cypress National Preserve (BICY), who, like us, are quite concerned about a number of recent management decisions at BICY.
The purpose of this letter is to submit comments on the January 2016 “Preliminary Alternatives Newsletter” for the BICY Backcountry Access Plan/Wilderness Study/Environmental Impact Statement (BAP/WS/EIS). First, we commend you for taking the optional extra step to seek public comment on the preliminary alternatives described in the newsletter and hope you will take an active role in overseeing the development of the plan. We offer the following comments about the newsletter.
- First Things First: Proper Characterization of the BICY Enabling Legislation – Though not specifically mentioned in the newsletter, given recent planning documents at BICY, we are concerned that in the forthcoming BMP/WS/EIS NPS will continue to mischaracterize the management of BICY under its enabling legislation as a “multiple use management” requirement, rather than affirming that as a unit of the National Park System BICY is to be managed consistent with the “conservation mandate” of the NPS Organic Act of 1916. This mandate is summarized in NPS Management Policies 2006, Section 1.4.3, which states, in part:
“Congress, recognizing that the enjoyment by future generations of the national parks can be ensured only if the superb quality of park resources and values is left unimpaired, has provided that when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant. This is how courts have consistently interpreted the Organic Act.”
BICY’s enabling legislation reinforces the NPS “conservation mandate” with its own “preservation, conservation, and protection mandate” stated in the opening clause of the legislation:
“(a) in order to assure the preservation, conservation, and protection (emphasis added) of the natural, scenic, hydrologic, floral and faunal, and recreational values of the Big Cypress Watershed in the State of Florida and to provide for the enhancement and public enjoyment thereof, the Big Cypress National Preserve is hereby established.”
Despite these strong legislative mandates to conserve park resources at BICY, NPS has mischaracterized the park’s enabling legislation as a “multiple use management” requirement in recent management documents, such as the seismic survey EA. Our concerns arose well before that EA and are described in detail in an amicus curiae brief accepted by and filed with the 11th U.S. Circuit Court of Appeals on September 22, 2015. The brief is available on-line at: http://protectnps.org/wp-content/uploads/2016/01/Brief-of-Amicus-Curiae-CPANP-filed-09_22_2015.pdf; and more recently in a January 8, 2016 letter to NPS Director Jon Jarvis, which is available on-line at: http://protectnps.org/big-cypress-planning-document-has-unexpected-reference-to-disputed-court-statement/ Since the NPS PEPC website does not allow us to include attachments with our comments, we are providing links to those documents herein and ask that the documents be considered part of our comments on the newsletter.
Regarding the appropriate characterization of BICY’s legislative mandate, we recommend that you refer to the 2000 Recreational Off-Road Vehicle Management Plan (ORV plan) for BICY, which is mentioned in the preliminary alternatives newsletter. By and large, that ORV plan provides a solid foundation upon which to manage ORV use at BICY and should remain the basis for ongoing ORV management. The ORV plan’s sections on “Legislative Background and Purpose of the Preserve” (p. 10) and “Legislative Mandates and Special Commitments” (pp. 11-15) are particularly well written and accurately reflect the park’s legislative history. Such appropriate characterization of the BICY enabling legislation seems to have disappeared in recent planning documents at BICY, and this lack of perspective has been reflected in recent management actions. Given these concerns, we recommend that the legislative background and mandates sections from the 2000 ORV plan (i.e., the sections cited above), be reviewed and updated, as needed, for use in Chapter 1 of the upcoming draft BAP/WS/EIS.
- Project Purpose – The newsletter states “The purpose of this project is to develop a backcountry access plan for Big Cypress National Preserve that provides reasonable management guidelines for backcountry access and use, while protecting the Preserve’s natural and cultural resources and providing for public enjoyment.” However, based on the content of the newsletter, it appears the plan’s primary focus is to expand ORV trails at BICY. This disproportionate emphasis on increasing ORV use is reflected in the level of detail in the respective ORV access action alternatives and the relative lack of detail for non-motorized forms of access. If NPS is to truly consider a “full range of reasonable alternatives,” as required by the National Environmental Policy Act (NEPA), then NPS should also consider a full range of reasonable alternatives for non-motorized forms of access. We offer more specific comments about this in the section below titled “Preliminary Alternatives.”
- Plan Needs – The content of the “Plan Needs” section on p. 2 of the newsletter reinforces the perception that the plan is primarily concerned about increasing ORV access. There is no “need” listed for improved and more diverse non-motorized access opportunities, which could include an expanded hiking trail system or improved paddling trail opportunities. To make clear that the plan is truly about all appropriate forms of backcountry access, including non-motorized, we strongly recommend that additional “needs” be developed and added to this section, something along the lines of the following:
- Evaluate potential alternatives for additional hiking trails in the original Preserve, which are not dependent on ORV access and provide reasonable access to backcountry destinations, including hike-in campsites, while protecting the natural and cultural resources of the Preserve.
- Evaluate potential alternatives for additional paddling trails in the original Preserve, which are not dependent on ORV access and which provides reasonable access to backcountry destinations, including paddle-in campsites, while protecting the natural and cultural resources of the Preserve.
In addition, NPS should be transparent about the need to designate secondary ORV trails. According to the BICY website, “[a]s part of a settlement agreement with plaintiffs…, the National Park Service will leave all secondary off-road vehicle trails closed until further environmental review and analysis can be completed.” See: http://www.nps.gov/bicy/learn/news/secondary-trails-to-remain-closed-and-further-evaluated-through-planning-process.htm This requirement should be identified in the Plan Needs section, which could be stated as follows (“the plan is needed to…”):
- Comply with a court-enforced settlement agreement requiring further environmental review and analysisbefore any secondary ORV trails can be opened.
Lastly, several of the “Plan Needs” listed in the newsletter include “Evaluate potential alternatives for a secondary off-road vehicle (ORV) trail network…” and “Clarify definitions of key [ORV management] terms…”. Presumably, designating new ORV trails and revising definitions related to ORV management could (or should) require rulemaking to revise 36 CFR § 7.86 (a). To the extent that the plan is “needed” to serve as a basis for such rulemaking, it should be made clear in the draft BAP/WS/EIS.
- Plan Objectives – The “Plan Objectives” on p. 2 of the newsletter are top-heavy with ORV-related objectives. This too reinforces the perception that the draft BAP/WS/EIS is primarily focused on increasing ORV use, rather than providing a more diverse approach to backcountry access for park visitors. To correct this perception, at the top of the list of objectives (or immediately after the wilderness objective) there should be an overarching “backcountry access” objective along the lines of:
- Provide a diverse range of backcountry access options, both non-motorized and motorized, that would improve opportunities for park visitors to explore the Preserve’s backcountry and enjoy a variety of resource-related recreational activities
This overarching objective could then be followed by the more specific ORV, hiking, and camping objectives.
The last objective listed in this section appropriately emphasizes the NEPA requirement that there be a full range of reasonable alternatives considered. The listed objective states:
- Complete NEPA analysis on a range of alternatives for wilderness designation, secondary trails, hiking trails, and backcountry recreational uses, including camping.
Despite the variety of activities listed in the objective, the newsletter provides a relative lack of detail or varied options (not a “range”) related to the activities listed other than “secondary trails” for ORV use. This disproportionate emphasis on ORV access in the newsletter and relative lack of a “full range of reasonable alternatives” for the other activities, if carried forth into the draft BAP/WS/EIS, will not satisfy NEPA or NPS policy requirements for environmental planning. We offer suggestions below for addressing this concern.
- Desired Future Conditions – Rather than articulate a number of positive goals regarding the protection of park resources and values, many of the Desired Future Conditions (DFC’s) listed in the table on p. 3 of the newsletter are written in the negative sense, using language based primarily upon (minimization of) “detrimental effects” to resources. A few examples of the negative wording for the DFC’s: (Protected Species) “Trails avoid areas where their construction, maintenance, and use may have a detrimental effect on listed species or their habitat; Detrimental effects on listed species and their habitat are avoided or minimized.” (Air Quality) “Air quality is not degraded by backcountry use.”
The BICY enabling legislation mandates the “preservation, conservation, and protection” of park resources and the assurance that activities allowed are “compatible” with this goal; yet this legislative context is not reflected in the proposed DFC’s. To support the park’s legislative mandate, the DFC’s should include “positive” goals that lead to “beneficial” effects on park resources. Absence of such positive DFC’s reaffirms our concerns described in the section below about the “Lack of Environmental Benefits in Action Alternatives.” We recommend that NPS revise the “preliminary” DFC’s to the extent necessary to create more proactive, conservation-oriented goals.
Lastly, for the DFC’s to function effectively as a management tool, they must be closely linked to measurable standards (or as NPS calls them “indicators and thresholds”) and monitoring procedures under an integrated “program.” The newsletter acknowledges this on p. 14 (“Indicators, Thresholds, and Monitoring”), but is sparse on specifics. We would expect to see a more detailed description of such a program in the draft BAP/WS/EIS.
- Preliminary Alternatives – As mentioned previously, the content of the newsletter is heavily oriented toward increasing ORV access and addressing ORV access concerns. If the plan is to truly present a more balanced and diverse approach to backcountry access, then there needs to be a full range of reasonable alternatives developed for non-motorized access.
- Non-Motorized Trails – There should be a broader range of options for increased non-motorized trails that is more diverse than just realigning a section of the Florida National Scenic Trail (FNST), which is the primary proposal in the hiking alternatives described in the newsletter. Alternatives could include options for creating new hiking trails including some that connect proposed or existing trails to form a “network,” establishing nature trails and boardwalks in representative terrain and habitats, and creating additional paddling trails where appropriate. At least some, if not the majority, of proposed new non-motorized trails should be accessible to park visitors without dependence on off-road vehicle travel.
Alternatives for increasing non-motorized trails should not be linked only to option(s) involving increases in ORV trails. For example, as described in the newsletter, Preliminary Alternative # 5 is the only action alternative that (in addition to realigning the FNST) would provide a modest increase (20 miles) in the hiking trail system. However, Alternative # 5 also includes by far the largest mileage increases in primary and secondary ORV trails. To present a “full range” of non-motorized trail alternatives, there should be an action alternative developed that emphasizes a maximum increase in non-motorized trails paired with minimal-to-no increase in ORV trail mileage.
We understand that presenting a more balanced approach between motorized and non-motorized access will not be as popular with ORV users as the current focus. We suspect the predictable outcry from ORV advocates will be that “unlike ORV use, which is closely managed at BICY, hiking is allowed anywhere, anytime at Big Cypress.” The argument that that no new hiking trials are needed because visitors can already hike anywhere they want is predictable. However, our experience with backcountry management in many units of the National Park System has been that many park visitors, particularly those who are not local to the area, are more comfortable when using marked trails in unfamiliar terrain. Of course, the unique hazards of the BICY environment (such as seasonally flooded areas, deep water strands, and potholes in limestone) necessitate designated and maintained trails for visitor safety.
And, as we all have learned, designated hiking trails result in greater resource protection by concentrating visitor use along predictable travel corridors. Studies in other parks have shown that in backcountry settings wildlife often adapt to predictable patterns of human disturbance, such as visitors hiking on trails rather than cross-country. This is why off-trail foot travel is seasonally prohibited in some parks during the wildlife breeding season (e.g., in certain grizzly bear breeding areas at Yellowstone NP). Given concerns about the potential disturbance of backcountry use on Florida panthers at BICY, NPS should evaluate the potential benefits of restricting hiking opportunities to established trails in critical habitat areas.
- Camping – We support the concept of designated backcountry campsites at BICY, rather than dispersed backcountry camping, especially dispersed camping involving ORV access. Policies that limit back-country camping to designated campsites have been established at many parks for the simple reason that such practices limit impacts to a finite number of known locations. Such restriction also narrows where patrolling rangers need to focus their time.
So we are particularly concerned with Alternatives 1, 4, and 5, which would allow dispersed camping along ORV trails, suggesting that much of this camping would be done by ORV users. Obviously, ORV’s provide the capacity to transport greater quantities of supplies and equipment into the backcountry, and generate greater quantities of trash and cause greater adverse impacts, than non-motorized camping. When considering the specific location(s) for designated campsites in the action alternatives, we encourage NPS to be mindful of the past Federal Court ruling regarding trespass camps at BICY. Using strongly worded language, the Court found the presence of those camps to be a detriment to the Preserve’s resources. The proposed designated campsite locations should be small in number and footprint, and carefully located so as not occur at former trespass camp locations. It would be unfortunate if NPS were to designate campsites at former trespass camps locations, which could inflame old resentments and create the perception that the NPS removed the trespass camps under the guise of “resource impacts” but is now willing to resume use of the same locations where similar resource damage is likely to occur.
- Closures – In Alternatives 4 and 5, no rationale for eliminating the annual 60-day closure is provided. We would like to see a full analysis in the draft BAP/WS/EIS of this proposal, including information on the documented benefits and shortcomings, if any, of the existing annual closure.
- Lack of Environmental Benefits in the Action Alternatives – The description of Alternative A, the “No Action” alternative, on p. 4 of the newsletter states: “This alternative would provide for the greatest degree of resource protection among the alternatives (emphasis added), since no secondary or new primary ORV trails would be opened.” This indicates that none of the currently proposed action alternatives would have beneficial impacts for park resources that would equal or exceed those of “no action.” We agree with this assessment; clearly, all action alternatives call for increases, sometimes substantial increases, in ORV access, which will undoubtedly increase the level of harmful impacts from ORV use.
The fact that “no action” would be the most beneficial alternative for park resources is a major concern. In our experience it is extremely rare in NPS management planning documents for the “no action” alternative to be the “environmentally preferable alternative.” Yet that appears to be where this plan is headed. What that tells us is that there has been little thought given by NPS to incorporating resource conservation measures into the action alternatives. It also suggests that NPS has not yet considered the potential resource benefits of wilderness designation, which could be elevated (e.g., through increased acreage) in some alternatives to offset the impacts from increased ORV use. To address these concerns, we recommend that at least some of the action alternatives be revised to include conservation measures that would provide long-term beneficial effects to park resources. For example, such beneficial options could be created by shifting current use(s) in sensitive habitat areas away from relatively high intensity/high impact activities such as ORV use to relatively low intensity/low impact non-motorized activities, such as hiking or paddling.
Again, to draw from the good work that already went into the 2000 ORV management plan, there are many items in the ORV plan that addressed resource protection, monitoring, and research. Many of these activities are or could be beneficial to park resources, and some could and should be reflected in the proposed BAP/WS/EIS. And, as described above in our comments about non-motorized trails, the designation of hiking trails can be an effective management tool for concentrating human-caused impacts along manageable corridors and thus minimize human disturbance of wildlife in areas with particularly sensitive human-wildlife interactions, such as in the Florida panther habitat at BICY. For these reasons, we recommend that NPS develop at least one action alternative that would provide for more diverse, non-motorized backcountry access opportunities, such as a significant increase in hiking trails without also expanding the ORV trail system. Such an alternative could and should include sufficient resource benefits (such as rehabilitation of previously disturbed areas or reduction/minimization of wildlife disturbance) that would establish a true alternative as the “environmentally preferable alternative” in the forthcoming draft BAP/WP/EIS.
- Wilderness Study – Based on what is described in the newsletter, we have several significant concerns about the proposed wilderness study (WS).
- Basis for WS – According to the newsletter, the starting point for the upcoming WS will be a 2015 wilderness eligibility assessment (WEA) for the original Preserve. We are aware that the WEA followed the same methodology and process used previously at BICY in preparing a 2010 WEA and subsequent WS in 2011 for the Addition. As you are aware, the WS (and GMP) for the Addition, in part due to the 2010 WEA, is still the subject of litigation. Because of that, we believe it is unwise for NPS to rely on the same disputed methodology in the forthcoming WS for the original Preserve; and the following discussion of the wilderness eligibility process for the Addition is, in fact, relevant to the proposed planning process for the draft BAP/WS/EIS.
As policy background, NPS Management Policies 2006 Section 22.214.171.124 identifies the “primary [wilderness] eligibility criteria” used throughout the National Park System to determine wilderness eligibility. The “primary eligibility criteria” are based directly on wilderness “characteristics” identified in the Wilderness Act of 1964. NPS Management Policies 2006 Section 126.96.36.199 also identifies “[a]dditional considerations in determining eligibility.”
In 2006, NPS prepared a WEA for the Addition based on the “primary eligibility criteria.” That WEA determined 111,601 acres out of the Addition’s 147,000 acres (76% of the Addition) to be “eligible” as wilderness. However, as the planning process proceeded (and as is reflected in the administrative record for the litigation), then-Superintendent Pedro Ramos wanted to designate ORV trails in parts of the Addition that the 2006 WEA had already determined to be “eligible” as wilderness. NPS policy requires that areas considered “eligible” as wilderness must be managed as wilderness, which would preclude the designation of ORV trails in the eligible areas.
In early 2010, Ramos requested a waiver of the policy and his request was subsequently denied by NPS Director Jon Jarvis. Shortly thereafter, BICY conducted a new assessment (a re-assessment) of wilderness eligibility for the Addition. This time, instead of basing the WEA on the servicewide “primary eligibility criteria,” NPS devised a new set of wilderness eligibility “assumptions” for BICY that in effect re-interpreted the NPS’s “primary eligibility criteria” in a way that significantly reduced the number of wilderness eligible acres in the Addition and enabled the Superintendent to designate more ORV trails than would otherwise be allowed.
As a result of the reassessment, the eligible wilderness acreage for the Addition was reduced from approximately 111,601 (76%) to 71,263 (48%), a net loss of over 40,000 acres of eligible wilderness. Then in the 2011 record of decision for the Addition’s wilderness study, NPS concluded that only 47,067 acres (32% of the Addition) would actually be proposed for wilderness designation under the selected alternative. An additional 24,196 acres were found to be “eligible” for wilderness designation but were ruled out as proposed wilderness because of the application (again) of one of the novel BICY wilderness eligibility “assumptions.”
In summary, after the amount of eligible wilderness had been identified in the 2006 WEA, NPS created an unprecedented process involving the novel wilderness eligibility “assumptions” in order to reach a decision more in keeping with the Superintendent’s desired outcome. The creation and use of the novel wilderness eligibility “assumptions” at BICY, instead of basing the determination on the “primary eligibility criteria” identified in servicewide management policies, is one of the primary reasons why the 2011 GMP/WS for the Addition is still in litigation. The Coalition and others believe that the creation and use of the novel “assumptions” at BICY is not only inconsistent with the letter, spirit, and intent of NPS management policies and the Wilderness Act, but it also resulted in the NPS significantly undervaluing the amount of eligible wilderness at BICY.
This brings us to our present concern about the newsletter for the draft BAP/WS/EIS. As stated above, the newsletter indicates that the starting point for the upcoming wilderness study will be a 2015 wilderness eligibility assessment (WEA) for the original Preserve. In reviewing the 2015 WEA, we note that it is based on the same 2010 novel wilderness eligibility “assumptions” that remain in dispute in the Addition litigation. We are concerned that use of the “assumptions” again will be inconsistent with the established NPS process for determining wilderness eligibility based on the “primary eligibility criteria;” and the BICY approach will once again systematically undervalue the amount of eligible wilderness, this time in the original Preserve.
To illustrate how this “undervaluing process” could occur, we call your attention to a 2002 wilderness suitability assessment for the original Preserve that was prepared two years after the 2000 ORV management plan was approved. The document is available on-line at: http://www.nationalparkstraveler.com/sites/default/files/attachments/bicy-donahue_wilderness_survey.pdf
The 2002 assessment found 225,160 acres (40%) of the original Preserve to be “suitable” for wilderness. Note: The term “suitable” was commonly used by NPS at the time, instead of “eligible” which has become the standard terminology under NPS policy. That assessment was based on the NPS “primary eligibility criteria” and therefore serves as a useful frame of reference for the 2015 WEA, which used the novel “assumptions.”
By the time the 2015 WEA was prepared, areas of the original Preserve not designated as “ORV trails” in 2000 had been closed to ORV use for over 15 years and would have had that length of time for natural recovery from the impacts of past ORV use. As a result, one would expect that a contemporary WEA, if based on the same “primary eligibility criteria” used in the 2002 assessment, would find at least the same if not a greater number of acres to be “eligible” as wilderness (because of the 15-year recovery period) than was determined in the 2002 assessment. However, the 2015 WEA for the original Preserve, based on the “assumptions,” found only 188,323 acres (34%) of the original Preserve to be eligible as wilderness, a net reduction of almost 37,000 acres of eligible wilderness compared to the 2002 assessment, despite the 15 years of recovery. Thus, it appears that NPS is headed once again toward significantly undervaluing the number of wilderness eligible acres at BICY, based on the novel BICY “assumptions,” only this time it will be in the original Preserve.
To ensure consistency across the National Park System, we assert that NPS should base its wilderness eligibility determinations for all parks, including BICY, on the same statutory definition of wilderness and “primary eligibility criteria” described in Management Policies 2006, Section 188.8.131.52. Conversely, NPS should not allow individual parks, such as BICY, to create and/or use novel or park-modified wilderness eligibility criteria or “assumptions” that re-interpret the servicewide criteria. Yet that is what has already happened with the Addition wilderness study and it appears to be what may happen again in the WS for the original Preserve. Our hope is to encourage NPS to follow its servicewide wilderness management policies at BICY (and at all parks for that matter). It is clear to many who have been involved in this issue that if the NPS bases the decision-making process for the upcoming wilderness study on the same novel “assumptions” used in the Addition GMP/WS, it will undoubtedly result in additional litigation.
Our concerns are also described in a May 26, 2015 letter to NPS Director Jon Jarvis, which is available on-line at: http://protectnps.org/big-cypress-national-preserve-wilderness-eligibility-criteria/; and on pp. 9-11 of the Coalition’s amicus curiae brief (also referenced above under Comment # 3), which is available on-line at: http://protectnps.org/wp-content/uploads/2016/01/Brief-of-Amicus-Curiae-CPANP-filed-09_22_2015.pdf Since the NPS PEPC website does not allow us to include attachments with our comments, we are providing links to these documents and ask that they be considered part of our comments on the newsletter.
- Lack of Preliminary Alternatives for the Wilderness Study – As mentioned previously, one the “Plan Objectives” listed on p. 2 of the newsletter is to “Complete NEPA analysis on a range of alternatives (emphasis added) for wilderness designation, [etc.]…;” yet the newsletter contains no preliminary alternatives, none whatsoever, for the wilderness study (WS). Given the variety of detailed preliminary alternatives for increasing ORV access that are described in the newsletter, the absence of any wilderness designation alternatives, or even concepts for the designation, suggests that NPS will simply follow the same disputed process (described above) that was used in the contested Addition wilderness study. If that approach is, in fact, followed, it would inherently limit the alternatives for designating wilderness to a narrow range of similar proposals (based only on the disputed 2015 WEA’s number of acres of “eligible” wilderness); and therefore would not meet the NEPA requirement of evaluating a “full range of reasonable alternatives.” As a result, we recommend that NPS develop one or more wilderness designation action alterative(s) based on a re-assessment of the 2015 WEA, using (only) the “primary eligibility criteria” described in NPS management policies. Chances are, the resulting acres of “eligible” wilderness would be similar to, if not greater than, the findings on the 2002 assessment. This approach would create one or more alternatives that are not based on the BICY “assumptions,” providing for a legitimate “full range” of alternatives as required by NEPA and a more defensible basis for determining wilderness in the draft BAP/WS/EIS.
- Resource Management, Indicators, Thresholds and Monitoring (p. 14) – The first paragraph in this section of the newsletter states, in part: “Monitoring would occur to determine if resource or social conditions are approaching the threshold, and adaptive management strategies would be implemented if the threshold is met (emphasis added), using a phased approach from least stringent actions (indirect actions) to most stringent actions.” In general, waiting until a threshold of detriment or unacceptable impacts is met, rather than taking a more cautious resource conservation-oriented approach, strikes us being inconsistent with NPS management policies and BICY’s legislative mandate. That said, some of the proposed alternatives for “indicators, thresholds, and monitoring” appear to be more resource-appropriate than others.
As described in the newsletter, “Alternatives 2 and 3 are designed to correlate visitor use to trail condition and would permit Preserve staff to adaptively assign use limits at or under sustainable levels. Alternatives 4 and 5 would rely strictly on targeted closure to allow for resource recovery.” In essence, the methodology described for Alternatives 2 and 3 would monitor use and make adjustments in use limits before unacceptable impacts occurred. In contrast, Alternatives 4 and 5 would wait until after unacceptable impacts have occurred before it takes action, which would be to close the area until resource recovery is achieved. In our opinion, the “wait-until-something-bad-happens-then-close-it” methodology described for Alternatives 4 and 5 is not consistent with the NPS conservation mandate or with BICY’s mandate under its enabling legislation. Lastly, consistent with comment # 5 above about Desired Future Conditions (DFC’s), in the draft BAP/WS/EIS we would like to see a more detailed description (than is provided in the conceptual description provided in the newsletter) of the proposed indicators, thresholds, and monitoring “program” and how it would relate to ensuring the achievement of the DFC’s.
In closing, we appreciate the opportunity to comment on the preliminary alternatives newsletter and look forward to reviewing the draft BAP/WS/EIS.
Maureen Finnerty, Chair
Coalition to Protect America’s National Parks
Stan Austin, Southeast Regional Director, National Park Service
Jon Jarvis, Director, National Park Service