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 a historic use which existed long before the Park was established. CCA reminds the NPS that the General Management Plan which is ultimately adopted is intended to be a long term plan and any restrictions will have long term social and economic consequences; CCA believes that an incremental approach is a much better alternative.

After reviewing the four (4) Alternatives, CCA can only support 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 and resource protection. This is particularly true of the boating public’s response to the concerns raised about manatee mortality. There is every reason to believe that the Park’s angling community 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, poorly 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 incremental implementation of any such management has merit.

The access issue that arises from 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 the 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 2, 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 corridors; access which is lacking in the 2009 Alternatives for Everglades National Park. No areas of the Park which are presently open to the responsible boating public should be closed off. Areas such as Snake Bight or Garfield Bight that show a pattern of scarring could be used as a pilot project and its effectiveness could be measured over time.

Alternatives 2, 3 and 4 (2009) have deleted numerous existing 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 but are not limited to Twin Key, Twisty Mile, East Key, Cross Key back, Dragover, Largo to Nest Key and the Frank/Palm Channel. 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 a reduced number of remaining channels; increasing the potential for scarring at those channels and safety considerations. It has been suggested that the NPS intends to only employ official Coast Guard channel markings in those channels shown on Alternatives 2, 3 and 4.  CCA strongly urges the NPS not to eliminate these channels and to limit the more expensive Coast Guard markers to wide channels. The NPS should look to the types of markers used in the Merritt Island National Wildlife Refuge and the types of markers presently and widely used in Florida Bay. In addition to the increased cost of standard Coast Guard type markers, those “I” beam or thick pole markers will be difficult to deploy in many of the narrow or winding channels of Florida Bay. The reduction of channels will only increase traffic in the remaining channels, likely to result in additional seagrass scarring in the channels that will no longer be marked and will cause longer runs to access the Bay.

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 and opposes these designations if they are intended to be regulatory.

The establishment of an Alternative Wilderness Waterway while appealing is not necessary nor is it economically viable given that those resources are better used to channel markers or markers along the flats in those portions of Florida Bay where seagrass scarring is occurring or for education or increased law enforcement. In particular, Hurddles Creek is a necessary access channel for boaters in times of inclement weather or exceptionally low tides.  The restrictions on Gopher Creek, Turner River and Wood River are likewise unnecessary. CCA-FL does not support any changes north of the Flamingo area, and this includes changes to the current designation for Gopher Creek, the waterway from Onion Key to Willy Willy, Turner River, Wood River and the Hurddles Creek area.

Increased boating and paddling access from the “18 mile stretch” is strongly supported and it will benefit paddlers and boaters.  This should be considered as a replacement of the access points that had historically been used by Park’s paddlers and boaters.

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 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 with measurable goals being established; this concept is acceptable if user groups are included in the process. 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.

SUMMARY
CCA strongly supports:

1. Establishment of a boater education program, specifically CCA recommends and supports the use of the Eco-Mariner program;
2. Better marking of channels and maintenance or replacement of those channels where markers have fallen into disrepair, have been destroyed or are mislocated;
3. Increased informational signage to protect grass beds in shallow waters;
4. Increased law enforcement presence; and
5. A strong public awareness program.

To the extent that each of the 2009 Alternatives recommend these elements; those concepts are strongly supported by CCA. These measures are long overdue, were recommended in 2007 and should be implemented immediately!

In considering the four 2009 Revised Preliminary Alternatives for Marine Waters as a whole, CCA-FL finds;
 Alternative #1 is acceptable, but should include the five items listed above;
Alternative #2 is acceptable only if modified as indicated below;
Alternative#3 is not acceptable due to the large pole & troll zones that lack reasonable access, but a limited pilot pole and troll zone for Garfield Bight and a portion of Snake Bight may be acceptable if incrementally applied, with established metrics for measurement of their effectiveness and with reductions in size and reasonable access corridors: see the comments below. It is also suggested that in lieu of a pole & troll zone south of Tin Can Channel, that the flats along the edges of the Tin Can Channel and north portion of Frank/Palm Channel be marked to address localized scarring that is clearly a result of those channels; and
Alternative #4 is not acceptable as its large pole & troll zones are de facto no motor zones and the idle zones and the no motor zones north of Flamingo to include the Alternative Wilderness Waterway and Hell’s Bay areas are not warranted. It is indicated that operation of combustion engines in pole and troll zones is limited to marked channels (page 10); this is unacceptable given the significant reduction in marked channels that is part of Alternatives 2, 3 and 4.

CCA-FL recommends that education, better marking of channels and signage, increased law enforcement, a public awareness program and seagrass restoration projects be implemented before restrictive or exclusionary measures are employed and that if restrictive measures are employed, they should be phased in on an incremental basis.

Of the “Elements Common to All Alternatives” CCA-FL supports:

1. Improved marking of boundary, channel marking and navigational aids;
2. Continuing the current management of Florida Bay Keys to protect nesting/rookeries;
3. Establishment of a seagrass restoration program- CCA has submitted to the NPS a proposal for the placement of Bird Defecation Stakes and desires to establish this as an ongoing program- approval of this program is requested; and
4. Implementation the approved Commercial Services plan.

Alternative 1:  This Alternative continues present Park management. It is acceptable, but it does little to address some concerns and must be combined with the four elements above and the items marked below with an asterisk (*).

CCA supports the following which are “Elements Common to All Alternatives
( Alternatives 2, 3 and 4):

• Development of an education program, specifically the implementation of the web based “eco-mariner” project*.
  
  
• Enhance backcountry wilderness opportunities by providing additional backcountry camping platforms or “chickees” (Florida Bay and Gulf Coast)*;

Alternative 2:

DEFINE BOAT ACCESS ZONES: This Alternative establishes “Boat Access Zones” which are depicted on the charts of the Park’s waters and are in three shades of blue. These Access Zones must not be regulatory or prohibit passage; they must be defined as advisory. The designation of Little Madeira Bay as Poll and Troll Zone and Joe Bay as a Backcountry Zone is acceptable. An access corridor should be established, but since access has been restricted, it is not possible to provide a preferred location for such access.

MARK AND INDENTIFY THE “DELETED” CHANNELS: Alternatives 2, 3 and 4 no longer depict historically established and commonly used channels. These “deleted” channels include the Frank/ Palm, Twin Key, Twisty Mile, East Key, Cross Key, Dragover, Largo to Nest Key Keys Channels. These channels are shown on virtually every published chart and on the chart on the Park’s web site. These channels must be maintained for access and should be marked for boating safety and seagrass protection. These channels must have gated entry points and signage that indicates “Local Knowledge-Shallow Draft Vessels”.

MODIFY THE FLAMINGO IDLE SPEED ZONE: The channel that leads from the marina to marked channel is designated as idle speed for its entire length. This should reflect present regulation.

NO MODIFICATION TO WILDERNESS WATERWAY: The Wilderness Waterway should remain as indicated in Alternative #1. CCA-FL does not support any changes north of the Flamingo area, and this includes changes to the current designation for Gopher Creek, Onion Key to Willy Willy camp, Turner River, Wood River and the Hurdles Creek area.

CCA supports the construction of additional Chickees.

Alternative 3:
THIS ALTERNATIVE IS UNACCEPTABLE.

CCA DOES SUPPORT A REDUCED SNAKE BIGHT AND GARFIELD BIGHT POLE & TROLL ZONES AND PROVIDE ACCESS CORRIDORS- The incremental establishment of a reasonable pole and troll zone for a portion of Snake Bight and Garfield Bight will provide protection to seagrasses in that area and will enhance the angler experience, but reasonable access must be provided. These types of zones have shown to be successful in the Mosquito Lagoon and Ft. DeSoto areas when reasonable access corridors have been established.  See the attached chart which depicts such a scaled down Pole & Troll Zone and access corridors for Snake Bight. The Park must recognize that these access corridors are analogous to trails that are universally provided in our terrestrial National Parks and some loss of seagrass may occur, but defined access points will significantly reduce seagrass damage to other areas and allow reasonable access. The lack of reasonable access corridors is tantamount to a denial of access.

THE PROPOSED IDLE SPEED ZONE SHOULD TERMINATE AT CURRY KEY AND RESUME AT EAST CAPE.

TREAT THE FORMER CROCODILE SANCTUARY AS IN ALTERNATIVE #2.

Alternative 4:
UNACCEPTABLE
No further comment is warranted

Prepared by: Ted Forgsen
CCA Florida
905 E. Park Avenue
Tallahassee, FL 32301
(850) 224-3474