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A. RECOMMENDATION
We urge the USFWS to utilize the current proposal that has been developed by the Florida Fish and Wildlife Conservation Commission (FWC) (as shown on June 2002 – map3) with the following two modifications:
MODIFICATION #1 – Change that portion of the
Peace River
(shown in red on attachment A) east of the I-75 bridge from the proposed slow speed year round to 25 mph year round.
MODIFICATION #2 – Change that portion of Hunters Creek (shown in yellow on attachment A) from the proposed slow speed year round to slow speed April through September and 25 mph November through March.
B. GENERAL COMMENTS
· Two years ago, manatee groups filed lawsuits against the State of
Florida
and the U.S. Fish and Wildlife Service claiming that both had not done enough to protect manatees and that such inaction was “causing manatees to sink further toward extinction.” The state and federal agencies and the manatee groups entered into settlement agreements to resolve the lawsuits. Since then substantial biological information has been made public. The best available scientific evidence indicates that statewide manatee populations have been steadily increasing over the last 25 years, not declining.
Thus, the original premise of the lawsuits, that manatees are declining to extinction, is clearly false.
· We suggest that the USFWS can, and should, take into consideration the status of manatee populations in a region when the agency considers what kind of regulations may be necessary. The level of regulation should be less restrictive in regions where populations are expanding versus areas where they may be stable or even declining.
· Manatee populations in the
Peace River
area are not declining. In fact, FWC staff presented aerial survey data for the
Peace River
which shows dramatic increases in abundance. Average sightings per flight increased from 3.7 manatees per flight in the late 1980’s, to 14.5 in the early 1990’s, to 22 per flight in 1998-1999 - a 600% increase over the last 10 years.
C. COMMENTS - PEACE RIVER AREA EAST I-75 – MODIFICATION #1
· The area east of the I-75 bridge where we are recommending changes from slow year round to 25 mph year round has had only one watercraft mortality in the last 30 years. Please see the mortality map prepared by the Florida FWC (Attachment B). We simply do not believe that one mortality in 30 years justifies establishing a year round slow speed zone over a 4 1⁄2 - 5 square mile area.
· The current federal and state proposals will dramatically change boat traffic patterns in the area east of I-75. Do you really want to do that? Under the “If it’s not broke don’t fix it” concept, why should boating traffic patterns be changed so dramatically when current usage has resulted in only one watercraft mortality over a 30 year period. The area currently has no speed zones at all. The 25 mph – year round will provide significant additional protection over the current situation.
· The current proposal will force all boats that wish to go more than 5 mph into a single channel and create bottlenecks and conflicts between big and small boats.
D. COMMENTS - HUNTERS CREEK – MODIFICATION #2
· The current proposal creates a two-mile long, year round slow speed zone in Hunters Creek. Such major restrictions are unjustified and unnecessary on a waterbody which has had only one manatee watercraft mortality in 30 years. That mortality was located right at the intersection with the
Peace River
, not up in
Hunter
Creek
. A seasonal zone (see area marked in yellow on Attachment A) which would allow 25 mph from November to March with slow speed the remainder of the year would provide additional manatee protection will still allow reasonable access for recreational fishing during winter months when there are fewer manatees in the area.
E. COMMENTS –
PEACE
RIVER
BETWEEN
U.S.
41 & I-75
· We are extremely concerned and strongly opposed to the current USFWS proposals to make the entire river, shoreline to shoreline – slow speed year round – with only the marked channel exempt. This stretch of river is nearly 3 miles long and 2 miles wide. There is no need to impose such draconian restrictions. Aerial surveys do not even indicate that manatees frequent the middle portions of the river. The 1,000 ft. shoreline buffer proposed by the FWC will provide substantial protection.
F. CONCLUDING COMMENT
· The Florida Fish and Wildlife Conservation Commission is working with all interest groups to try to craft regulations which will provide manatee protection benefits while still allowing reasonable boating access. All scientific evidence indicates that manatee populations are expanding not declining. There is no emergency and there is no reason for the USFWS to impose its proposed draconian measures for the
Peace River
when the FWC is on the verge of approving more reasonable measures which would provide substantial new manatee protection zones and maintain reasonable access for boating and fishing.
We believe that there is ample justification for the USFWS to modify its current
Peace River
proposal when consideration is given for the expanded protection zones being adopted by FWC in the immediate area. These proposals include
Turtle
Bay
and an expansion of the Lemon Bay/Placida zone. The total protection areas established by the FWC are larger than the areas proposed by the USFWS.
The additional FWC protection zones, coupled with fact that in each of the areas for our recommended changes there has been only one watercraft mortality in 30 years, should lead to the conclusion that the FWC proposal and what we are recommending certainly provides no less manatee protection, and possibly provides more, than the USFWS’s current
Peace River
proposal. We urge the USFWS to adopt the current FWC proposal with the two CCA modifications.
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