We urge the National Park Service (NPS) to recognize that the vast majority of the anglers and boaters that use the Park respect it and responsibly operate their vessels. The NPS must also acknowledge that recreational fishing is an historic use which existed long before the Park was established.  CCA reminds the NPS that the General Management Plan which is ultimately adopted will be a long term plan and any restrictions will have long term consequences and that an incremental approach is a much better alternative.

After reviewing the four (4) Alternatives, CCA strongly supports Alternative 1 and those portions of the other Alternatives as described below.  CCA has urged the Park to use education, signage, cooperation and law enforcement as alternatives to exclusionary management when it establishes its long term management plan. To the extent that each of the 2009 Alternatives recommend better boater education, better channel marking and increased law enforcement; those concepts are strongly supported by CCA. These measures are long overdue, were recommended in 2007 and should be implemented immediately.

It has been CCA’s experience that the boating public will positively respond to education and public awareness of environmental concerns. This is particularly true of the public response to the concerns raised about manatee mortality. There is every reason to believe that the boating public will positively respond to the concerns about seagrass scarring. In addition to education, the proper marking of the channels is a necessary element of the public compliance. It is noted that many of the channels are not completely marked or have not had damaged markers replaced.  Lastly, the public’s awareness is further enhanced by increased law enforcement and related publicity. These elements should be implemented immediately and their effectiveness measured before any more restrictive measures are employed. It is for this reason Adaptive Management has merit.

The access issue that arises from the large scale Pole and Troll Zones will have negative ramifications and may adversely affect recreational anglers for a lifetime. During the 2007 comment period CCA and many of public commenters expressed concern over the large Pole and Troll areas and the lack of any access channels depicted on some of the 2007 Alternatives. Apparently these comments fell upon deaf ears as the Pole and Troll Zones in Alternates 3 & 4 all fail to include any reasonable access channels. CCA strongly recommends that the NPS review the pole and troll zones and access channels presently in place in the Merritt Island National Wildlife Refuge and Fort Desoto area. These pole and troll zones provide reasonable access by trolling or poling; access which is lacking in the 2009 Alternatives for Everglades National Park. Additionally some areas will allow access by boats at idle speed. An area such as Garrison Bight that shows a pattern of scarring could be used as a test project under the concept of Adaptive Management and its effectiveness over time measured.

Alternatives 2, 3 and 4 (2009) each appear to have deleted numerous channels; channels which have been historically used by recreational anglers and are shown on virtually every printed chart of Florida Bay and even on the NPS Everglades national Park web page. These channels include; Twin Key, Twisty Mile, East Key, Cross Key back, Dragover, Largo to Nest Key and the channel that runs south between Frank and Palm Keys . These Alternatives fail to advise the public why these channels were deleted. Some of these channels provide access to large areas of Florida Bay and in addition to denying access, will cause an increase in boating traffic to those channels; increasing the potential for scarring at those channels and possible safety considerations.

The 2009 Alternatives each depict Boat Access Zones, but the regulatory or advisory effect of these zones is undefined. If these zones are intended to be advisory, such a determination should be more clearly defined. If the Boat Access Zones are intended to be regulatory, the zones and regulations need to be better defined. CCA is concerned regarding the vagueness of this element.
Miscellaneous comments: The Idle speed zone out of Flamingo marina appears to extend to the headpins of the channel. This is apparently a scaling error, but such a zone is unnecessary. The restrictions on Gopher creek, Turner River and Wood River are unnecessary. The idle speed zone from Hell’s Bay to Lane Bay is not clear and if intended to require idle speed along that path, it is unnecessary.

While there are elements or portions of elements of the several Alternatives that may be acceptable, the manner in which they are presented make it difficult to provide specific comments. The Alternatives suggest that Adaptive Management may be employed, if this is intended to suggest that some of these elements may be incrementally applied as warranted; this concept is acceptable. It is the implementation that is not adequately described. It is recommended that any such management zones which limit access either explicitly or as a result of unreasonable distances of poling or trolling be applied in an incremental fashion and with some measurable standards.           

When restrictive management methods are intended to be employed by adaptive management, CCA encourages the NPS to engage in additional public comments and utilize measurable goals and to include those individuals with local knowledge in the planning process and to help develop solutions.