Everglades National Park
Attention: Superintendant Dan Kimball
40001 SR 9336
Homestead, FL 33034

Dear Mr. Kimball:

CCA Florida (”CCA”) has reviewed the Proposed Draft General Management Plan Alternatives for Everglades National Park and provides its comments and suggestions. CCA has met with representatives of Everglades National Park and has presented them with a graphic that more fully defines these comments. CCA urges the National Park Service (NPS) and the management of Everglades National Park (ENP) to continue a dialogue on the development and implementation of the General Management Plan. The Park and its users’ interests are best served when the Park engages its anglers and boaters who constitute a majority of the users of the Park’s marine areas. These sportspersons are conservationists who truly value the Park’s unique resources. But to be clear, the Preferred Alternative as proposed is unacceptable to CCA. CCA will address and suggest modification of those unacceptable elements. The suggested modification of those components meets the needs of the Park’s management and allows reasonable access to its boaters and anglers.

CCA's members and sponsors well recognize the need to provide resource protection for the Park's marine resources. CCA also believes that the vast majority of the anglers and boaters who frequent the Park are good stewards of the resource and hold the Park's resources in high regard. These anglers and boaters will favorably respond to better signage and marking of the Park’s channels, access corridors and shallow water areas. CCA believes that additional marking is needed on the eastern boundary of the park to educate boaters on proper navigation, prevailing water levels and areas requiring local knowledge. CCA also strongly believes that the overwhelming majority of the Park’s boaters and anglers will favorably respond to educational and informational programs.

CCA equally believes that the Park needs to stay true to its tradition as being a premier fishing destination. CCA has supported the use of Pole & Troll Zones (PTZ's) in other locations as well as the concept for Snake Bight as they provide for seagrass protection and enhance the angling experience. But, as implemented the Snake Bight PTZ suffers from access issues. Suggested modifications to the Snake Bight Pole and Troll Zones include better access along the shoreline from Porpoise Point to the northern shore of Snake Bight, an expansion to the north of the Jimmy’s Lake idle speed access areas, increased access along Snake Bight Channel onto the flats, to the west and continuing northward towards the northern shore of Florida Bay. (See the attached Graphic).

The PTZs proposed for ENP are too large and, contrary to statements within the planning document, lack reasonable access. Most of the PTZs in the Preferred Alternative are miles long and across. PTZs of that size, without adequate access corridors, effectively exclude most anglers. A functional PTZ requires access corridors similar to those in use in the Pole and Troll Zones of the Merritt Island National Wildlife Refuge with poling or trolling distances of less than 200 yards. The proposed PTZs comprise every shallow water flat in the waters of Florida Bay within the Park’s boundaries. The lack of access to the proposed PTZs essentially places these flats off limits to most anglers! The Park should also recognize that there will be adverse unintended impacts due to these large PTZs; the fishing effort that is now directed to these flats will be transferred to other flats that are outside, but adjacent to, the Park.

The PTZs which are in the bights of northern Florida Bay and in the central and lower portion of the Park's waters in Florida Bay are significantly influenced by tidal flow, winds and seasonal variations in water levels. These PTZs include Nine Mile Bank, Sandy Key Bank and Dildo Key Bank and the Palm-Cormorant-Curley-Buoy Flats. The access corridors requested by CCA and virtually every other organization that represents the users of the Park’s marine waters are largely based on naturally occurring channels, basins and runoffs. As an example, the poling distances into and out of Garfield Bight would exceed 4 miles. These suggested corridors are not only a matter of convenience, but are necessary for boating safety and seagrass protection. Without these access corridors, the PTZs in the Preferred Alternative are de facto exclusionary zones.

Some of the areas within the proposed PTZs are deep enough to allow for normal operation and, depending on the tide, may be too deep for reasonable poling. Examples include: the area between Sid Key and Jim Foote, which provide more than adequate depth for normal vessel operation, as does the area south of Camp Key, east of Pelican and north of Jim Foote. These areas should allow for combustion engine operation. Additionally, many of the areas within proposed PTZs have over two (2) feet of draft, depending upon the tide; these areas will easily and safely accommodate “idle” transit too. In terrestrial parks users are afforded access through the "wilderness" through trails and paths that have been cut from the wilderness and are maintained by the US Park Service- CCA urges the Park to employ a similar philosophy in establishing and marking access corridors and channels into the proposed PTZs.

CCA recommends the Park incrementally establish these PTZs, starting with the areas around Flamingo, which according to the Parks' Vessel Density Analysis experiences the highest usage, and progressing outward as funds become available to mark access corridors and the PTZs. This incremental approach will allow the Park, with the consultation of the Park’s users, to evaluate and assess the PTZs and their effectiveness. Before additional PTZs are put in place, the Park’s users, including angling and boating groups, should be consulted. Incremental implementation will also allow the Park to meet its budgetary constraints. The PTZs should also consider seasonal variations in water depth, variations which can allow for additional access into those areas and bights so affected. For example, the waters of Garfield Bight experience a significant seasonal variation and the Park should consult with the Park’s recreational and professional users to delineate those areas.

While the proposed shoreline zones arguably enhance the experience of anglers and paddlers, many of these areas provide deeper water and have been historically used as channels, these areas are depicted on CCA’s graphic and should be maintained for access and boating safety reasons. These suggested channels include access to Slagle Ditch, House Ditch and East Cape as well as the area along and immediately west of the campground and around islands such as Palm Key. The continued use of these historic corridors, channels, passes and cuts are also necessary due to the type of vessels that are most frequently used to traverse the Bay. These boats are best described as shallow draft boats, many of which sacrifice weight to be able to draw as little water as possible. The use of these shallow draft skiffs has become more prevalent and it is expected that this trend will continue. This means that many more of today's boats are able to get on flat without disrupting the grasses than was the case a mere ten years ago. These boats are also able to trim up their engines so as to allow idle or slow speed operation without disrupting the bottom. These boats are ecologically friendly, but they also experience more difficulty in moderate winds and the sea conditions found on the open waters of the Bay.

The Preferred Alternative unreasonably removes historically used navigation channels. These access corridors or channels include those in Rabbit Key Basin up to Cluett Key, Tin Can to Palm Key, Clive Key west to Rocky Channel, Palm Key leading into Palm Lake as well as the channels/runoffs of Nine Mile Bank, Cluett Key, Rabbit Key and the areas between Barnes and Buchanan. The Snake Bight PTZ should be modified to allow better access through Snake Bight Channel, Christian Point and the natural deep water tidal runoffs along Snake Bight channel. Each of these proposed channels should be marked, indicated as corridors by buoys/stakes and arrows or, if there are concerns regarding navigation, they should be indicated “as local knowledge required”.

CCA supports boater education through programs such as Eco-Mariner, a program that CCA endorsed. CCA is concerned that mandatory education or the establishment of a permit could lead to the imposition of multiple educational and permitting requirements given the several federally and state operated parks, refuges and sanctuaries. Initially the Park should support a boater education program that is readily accessible to the prospective users and internet based.

With regard to the Gulf areas of the Park, the imposition of a PTZ along the western portion of Gopher Creek is not warranted and, when combined with the existing idle speed zone along the eastern portion of Gopher Creek, essentially turns Gopher Creek into a no boating zone. The Cross Bays/Hurdles Creek area should not be restricted as they provide historic access and passage during rough weather. The proposal for Wood River constitutes an exclusionary zone and is not warranted.