Comments submitted to:
National Park Service – PEPC – Environmental Assessment
October 29, 2024
Superintendent Eric Brunnemann
Padre Island National Seashore
PO Box 181300
Corpus Christi, TX 78480
Subject: Padre Island National Seashore (PAIS) Draft Feral Exotic Invasive Species Management Plan and Environmental Assessment Comments
Dear Superintendent Brunnemann:
I am writing on behalf of the Coalition to Protect America’s National Parks (Coalition), which represents over 2,900 current, former, and retired employees and volunteers of the National Park Service (NPS). Collectively, our membership represents over 50,000 years of national park management and stewardship experience. Our members include former National Park Service directors, deputy directors, regional directors, and park superintendents, as well as a variety of program specialists and field staff. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System, and mission-related programs of the National Park Service.
We write today to express our pleasure at the quality, thoughtfulness, and thoroughness of the Padre Island National Seashore’s (PAIS) plan to address exotic and invasives species that are degrading cultural and natural resources, as well as the visitor experience.
The Coalition fully supports Alternative B but offers a few suggestions to strengthen the plan as well as ensure implementation is successful.
We offer the following:
Page 1. “…management of feral exotic invasive wildlife, including feral swine (Sus scrofa) and other feral exotic invasives that are present, like nilgai antelope (Boselaphus tragocamelus), as well as any species that may be discovered in PAIS in the future where implementation of the proposed plan would protect resources.”
Recommendation: Please provide the list of non-native species that the park has compiled, or that the Inventory and Monitoring Program provides to the National Park System. This should include not only mammals but herpetofauna, other vertebrate species such as fish, and even non-native avian species such as cowbirds, non-native English or House sparrows, or other.
Page 15. – Final Disposition
“Feral swine or nilgai that are killed would be left in the field to decompose on the ground without burial or transported off-site for disposal, which corresponds with practices nationwide (USDA, 2015). Strict adherence to established health and safety protocols will be maintained during the handling of deceased feral swine to minimize exposure to body fluids and ensure the safety of personnel.
Any killed feral swine or nilgai left to decompose would be moved would be out of view from visitor use areas such as hiking trails, boardwalks, day use or camping areas, parking areas, and the visitor center.”
Recommendation: Consider the meat of both antelope or swine to be donated to homeless shelters such as other parks have done with deer, geese, and elk. If the NPS were to offer carcasses for use by a food shelter, then the food shelter or volunteers could retrieve the carcasses from a central location within the park with specific pickup times. The park should not necessarily have to go to extra means or costs to salvage and preserve the meat, nor commit to supplying every carcass. Only carcasses that are logistically simple to centralize could drive the process in order to minimize waste. Other carcasses can be left in the field to benefit native carnivore and omnivore species such as coyotes, foxes, vultures, etc.
Donating takes time and resources, which we understand. Many parks are available for consultation on this process (GETT, THRO, CATO, etc.). Guidelines for human safety and animal welfare are available from the WASO Natural Resource Stewardship and Science Directorate.
We applaud the park for implementing the non-lead policy for the removal of the non-natives. We encourage you to articulate the intent to implement a restoration plan for disturbed and damaged cultural and natural resource areas damaged by the exotic and invasive species. We also recommend you emphasize continued and ongoing monitoring and collaboration with federal, state, and private partners to control exotics outside of the park boundaries.
The Coalition fully supports the plan, and Alternative B is the approach that will ensure protection and preservation of the park’s resources and provide for the continued quality visitor experience the public expects. Thank you for the opportunity to comment and we are happy to answer any questions generated from this response.
Sincerely,
Phil Francis
Chair
Coalition to Protect America’s National Parks