Letterhead Logo


February 14, 2024

Tracy Stakely
Fort Sumter and Fort Moultrie National Historical Park
1214 Middle Street
Sullivan’s Island, SC 29482

Subject: Fort Sumter and Fort Moultrie Dock Replacement Environmental Assessment

Dear Superintendent Stakely:

I am writing on behalf of more than 2,500 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 45,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former NPS directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.

On behalf of our members and supporters, we applaud Fort Sumter and Fort Moultrie National Historical Park (FOSU) for creating this Visitor Use Management Plan (VUM). While our comments address the topic questions, the Coalition has organized its comments around the purpose statements of the plan as posed in the Winter 2024 newsletter.

Improve visitor experience and universal access at Fort Sumter and Fort Moultrie National Historical Park
The Coalition supports prioritizing accessibility, expanding the awareness of Fort Moultrie visitor opportunities, and improving interpretation experiences throughout the unit. We support consideration of alternative fee structures and improving connectivity through partnership, but we caution consideration of marketing strategies based on the following.

The Coalition agrees the plan “will support operational decisions to ensure that all sites are open and sufficiently staffed to support visitor use” in order to “provide visitors with meaningful and informed experiences.” This plan needs to certainly address this, but it also should address managed visitation in order to ensure a quality visitor experience and protection of resources.

As directed by the National Parks and Recreation Act, the National Park Service is required to set a visitor carrying capacity with park areas and a monitoring program. We encourage the park to set an overall visitor carrying capacity and set of desired conditions for both Fort Sumter and Fort Moultrie. We also encourage the park to establish additional scientifically based and peer reviewed indicators, standards, and thresholds for measuring visitor quality and resource conditions in all visitation areas. The monitoring of these indicators will ensure success and public credibility as management actions are implemented in the future.

Understanding visitation amounts and potential impacts of increased visitation to visitor experience and resources will be key to determining which preliminary concept related to ferry departure points and scheduling will be most effective at meeting the purposes of the VUM. Including a monitoring program will assist the park in creating opportunities for adaptive management strategies as new data is made available. Consideration of visitation numbers and their impact on ecological function should be a primary factor as well. For example, limiting visitor numbers on islands to protect wetland functionality may need to be a consideration.

Given fishing is a visitor activity in FOSE and water quality surrounding the park unit sites has a history of being very poor, the Coalition recommends incorporating water quality monitoring and education as important components of the VUM plan. The area has a history of toxins, per- and polyfluoroalkyl substances – known as PFAS, and line entanglement for wildlife. Education should address risks to people eating their catch. Interpretive signs about fishing line entanglements and danger to wildlife, use of non-lead fishing gear only, and other human health risks need to be included in the plan.

Provide general planning direction for the US Coast Guard Historic District
No management direction exists for the U.S. Coast Guard Historic District; therefore, the Coalition supports development of this direction, as well as investments to improve accessibility. The lighthouse in the U.S. Coast Guard Historic District is the only lighthouse with an elevator in the National Park Service system. The elevator currently is inoperable, and the Coalition recommends fixing it. With that in mind, any repair and restoration efforts to the lighthouse or the Historic District as a whole should be done in consultation with SHPO and other interested parties, including consideration about restoring the lighthouse to original configuration. Efforts should be planned only after obtaining, analyzing, and interpreting recent models for sea level rise. Based upon these models, the possible eventual need to move the lighthouse or other historic structures over the lifespan of this plan due to sea level rise should be an initial consideration. 

Ensure that park resources and values remain protected
The newsletter states the impact of climate change on resources and visitor use patterns will also be addressed, given the park’s especially sensitive coastal location. The Coalition applauds this. Ways to reduce the vulnerability of resources to climate change impacts must be a focal point for visitor use planning.

The Coalition recommends conducting a serious and current analysis on the potential impact on natural and historic resources due to rising sea levels to determine what policies can be put into place to mitigate the effects of shoreline change. When looking at potential impacts, the physical impacts to specific structures and historic districts are critical. It is also important to consider Charleston’s Historic District, which are National Historic Landmarks (NHL) in the planning process.

Lowering FOSE’s carbon footprint and supporting renewable energy are critical. The Coalition recommends using environmentally friendly boats, planning for kayak-friendly use to this end.

We recommend that an assessment of possible impacts include adaptation strategies, modeled vulnerability, and mitigation actions. Additionally, consideration of the risk of rising sea levels is paramount to the long-term success of the VUM plan and should include the following: 

  • Potential for water damage, as well as the impacts of rising water temperatures The surrounding communities and park units will be vastly altered or damaged beyond repair by coastal flooding, but many residents are not paying sufficient attention. Therefore, education must be a critical component.
  • The potential for a rise of sea levels inevitably will lead to loss of land and services.
  • Address how much loss is too much for communities to accept, and what is required to keep sea-level rise below that.
  • Consider not just protecting structures, but also how these mitigations and adaptations will protect ecological functions in this sensitive coastal area.

In closing, we appreciate the opportunity to comment on this important planning process and appreciate the forward thinking of this VUM effort.


Phil Francis signature.



Philip A. Francis, Jr.
Chair of the Executive Council
Coalition to Protect America’s National Parks