ELECTRONIC TRANSMISSION – NO HARD COPY TO FOLLOW
March 20, 2024
Superintendent Pedro Ramos
Attn: Wilderness Stewardship Plan
Everglades National Park
40001 State Road 9336
Homestead, FL 33034
Subject: Everglades Wilderness Stewardship Plan
Dear Superintendent Ramos:
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.
We appreciate the opportunity to comment early in the process of your preparing a wilderness stewardship plan. We compliment you and your staff for developing a user-friendly story map as a good way to get input from those that know the park well, and for proposing strategies that would adhere to the basic direction called for in the park’s 2015 General Management Plan (GMP). The draft “desired conditions” and ”strategies” to achieve them seem sound, if general, and we appreciate the language about protecting natural and cultural resources while conducting the necessary compliance. We especially support the intent to implement the following:
- “inventory, assess, remove or eliminate as appropriate” nonconforming uses in potential and proposed wilderness;
- evaluate research and monitoring installations in wilderness and remove them (or hold researchers accountable to do so) when no longer essential;
- pursue programmatic minimum requirement analyses for necessary NPS operations, such as repair or replacement of campsite platforms, hydrologic monitoring stations, and specific kinds or search and rescue events;
- explore shared stewardship strategies with indigenous people; and
- continue to encourage tribal activities such as arts and crafts, access to sacred sites, and religious ceremonies. We look forward to reading more about what existing and planned ‘subsistence gathering” activities you permit and how.
The story map does not explain whether the park is responding to increased demand for access and services and/or whether you have identified problems related to current or anticipated future levels. We appreciate that you are seeking public input early in this planning process to help determine such answers. It appears that you are considering the addition of campsites and hiker/equestrian trails; undesignated camping; expanding or enhancing access to wilderness water routes, mostly via commercially operated services, and we hope that as much as possible, these commercial activities would initiate outside the wilderness boundaries.
Since your GMP noted the park’s intent to establish a user capacities program, and many parks are currently dealing with demand and capacity issues, the plan should clearly describe existing and desired use levels, capacities, and related challenges. We look forward to a thorough analysis of expected and potential unintended consequences of promoting more wilderness use as you address alternatives and their associated environmental effects in a draft plan.
In several districts, the story map suggests that as you add new water platform campsites, some would be made accessible. We encourage that all new facilities and services be fully accessible whenever feasible. We appreciate that the park intends to evaluate existing campsites for decommissioning, restoration, or relocation for either climate change reasons or other destructive natural events. We support efforts to respond to overuse causing resource damage along with continued restoration at the Hole in the Donut. These efforts would not only benefit Everglades visitors but could inform restoration efforts at other parks across the nation.
We appreciate the opportunity to provide input on this important plan that will guide Everglades wilderness management for the future and look forward to engaging further as your planning process advances.
Sincerely,
Philip A. Francis, Jr.
Chair of the Executive Council
Coalition to Protect America’s National Parks