A Florida conservation group wants National Park Service Director Jon Jarvis to reject the preferred off-road vehicle plan for the Addition lands in Big Cypress National Preserve. In a lengthy letter the South Florida Wildlands Association urges the director to "take a step that will truly fulfill the lofty language of the Organic Act of 1916" by setting aside more of the landscape for wilderness designation.
The voluminous letter, running nearly 10,000 words, outlines a range of problems the wildlands association believes the ORV plan will create. Among those issues are impacts to the endangered Florida panthers that live within the national preserve, perceived "unfairness" in the amount of ORV trails that would be allowed within the Addition lands, and unreasonable impacts to natural resources in the 147,000 acres spread across the preserve's northeastern corner.
The Addition lands came to Big Cypress in 1996 as part of a land swap. At the time the Addition was placed off-limits to ORV travel and hunting until a management plan could be developed. When Superintendent Pedro Ramos released the final version of his preferred ORV plan in November, it called for up to 130 miles of ORV trails, and as many as 650 ORV permits annually. Along the way to developing that plan, his critics allege that the superintendent and his staff went around Director Jarvis' wishes and denied wilderness eligibility for 40,000 acres in the Addition section.
Superintendent Ramos, however, counters that everything was conducted above-board and that the reduction in acreage worthy for wilderness designation stemmed from his staff's review of more than 17,000 comments on the draft ORV plan.
But in his letter sent this week to Director Jarvis, Superintendent Ramos, and Southeast Regional Director David Vela, Matthew Schwartz of the wildlands association argues that "there are significant issues pertaining to policy, science, and law which NPS has failed to consider in the writing and publication of this plan. We request that NPS reconsider the signing of Record of Decision for this plan in light of these deficiencies."
While Superintendent Ramos said part of the rationale for his decision on the plan stems from the designation of Big Cypress as a "national preserve," and not a "national park," two park system classifications that carry different management duties, Mr. Schwartz contends that those distinctions don't matter when it comes down to the basic mandate given the Park Service by the National Park Organic Act of 1916.
"In my years of work on this issue for the Sierra Club and now with South Florida Wildlands Association, I have been frequently criticized by some members of the general public, but also by NPS staff, for not taking into consideration the distinction between a ‘park’ and a ‘preserve’ with regard to management decisions by NPS in BCNP," writes Mr. Schwartz, the wildlands association's executive director.
He went on to note that the off-road management plan adopted for the rest of Big Cypress notes that the preserve is to be managed "in a manner that will ensure its ‘natural and ecological integrity in perpetuity.’"
"The (enabling) legislation (of Big Cypress) further states the management of the area should be in accordance ‘with the provisions of the Act of August 25, 1916 (NPS Organic Act),'" he writes. "Thus, the natural and ecological integrity of the preserve is the fundamental value that Congress directed the National Park Service to protect."
Other items cited in the letter include:
* "The plan to open 130 miles of primary ORV trails (and a still unspecified number of secondary trails) in the Addition is inherently unfair. ... most of the BCNP is already open to motorized recreation for up to 2000 permitted ORV owners."
"This plan hardly provides for the 'equitable allocation and use of facilities' of the preserve. Nor does it seek to 'avoid conflict among visitor use activities.' Instead it brings the preserve from ‘mostly motorized’ to almost ‘completely motorized’—at the expense of the current users of the Addition who do not utilize motor vehicles and seek a different type of experience."
* A 2007 visitor use study of the preserve conducted by the University of Idaho "indicated that the most common visitor group activities were viewing wildlife (69%), taking a scenic drive (66%) driving through the Preserve to reach another destination (52%), and bird-watching (48%). Hiking and photography/painting/ drawing were also popular activities, at 39%. A smaller portion of visitors participated in more traditional forms of outdoor recreation, including picnicking (20%), camping (18%), airboating (18%), and fishing (15%). Only 9% of the visitors surveyed planned to canoe or kayak, and only 4% planned to hunt. About 7% of visitors interviewed had plans to drive off road vehicles within the Preserve. Around 6% of visitors participated in ‘other’ types of activities, which may include biking and horseback riding."
That study, Mr. Schwartz points out, also noted that "in terms of activities that visitors would like available in the Addition, hiking, camping, wildlife viewing, fishing, canoeing, bird watching, biking, and hiking were the most frequently mentioned."
* The preferred plan would exacerbate user conflicts by designating ORV routes over trails currently used by hikers.
* "We would also like to point out that the completely untapped potential of the Addition Lands as a place to educate south Florida’s school children on their region’s natural heritage (with families or in cooperation with area schools) appears never to have been explored or even considered by NPS in their analysis."
* Mr. Schwartz also cites a report on the preserve produced by the U.S. Geological Survey in 2001 that negatively portrayed ORV use in Big Cypress.
ORV use in Big Cypress National Preserve (BICY) has impacted wildlife populations and habitats through modifications to water flow patterns (direction and velocity) and water quality, soil displacement and compaction, direct vegetation damage, disturbance to foraging individuals, and, ultimately, overall suitability of habitats for wildlife.
* The preferred plan would adversely impact Florida panthers by increasing human presence in the panthers' habitat and increased hunting pressures on their prey, contends the wildlands association.
"Whether the panther ‘can handle’ the anticipated impacts is very much up in the air and should immediately trigger application of the NPS’s ‘precautionary principle,'" writes Mr. Schwartz. "As stated in the current DOI Management Policies for the NPS: In cases of uncertainty as to the impacts of activities on park natural resources, the protection of natural resources will predominate."
* Rich botanical resources also would be imperiled by the proposed ORV plan.
"Dr. Jim Burch, supervisory botanist of the BCNP, has referred to Big Cypress as quite likely the most biodiverse land in the continental United States (personal communication, 2007)," Mr. Schwartz wrote. "The abstract of a well-known botanical study of the preserve published in 2003 in the Journal of the Torrey Botanical Society, Plants of the Big Cypress National Preserve, reports the following:
"A new survey of the Big Cypress National Preserve shows that the vascular flora consists of 145 families and 851 species. Of these, 72 are listed by the State of Florida as endangered or threatened plants, while many others are on the margins of their ranges. The survey also shows 158 species of exotic plants within the Preserve, some of which imperil native species by competing with them. Finally, we compare the flora of the Big Cypress National Preserve with those of the nearby Fakahatchee Strand State Preserve and the Everglades National Park. Although Big Cypress is less than half the size of Everglades National Park, it has 90% of the native species richness."
* " ... the enabling legislation required that the Addition be objectively evaluated for wilderness characteristics and that the NPS report those findings to the President for his approval and eventual transmittal to congress. Two early attempts at carrying out this mandate found well over 100,000 acres of wilderness eligible lands in the 146,000 acre Addition. The wilderness study actually released to the public in 2009 found 111,000 acres of wilderness eligible land. However in April of this year, with no notice to the general public, a re-evaluation of wilderness eligible lands took place which dropped approximately 40,000 acres of the Addition from wilderness eligibility....
"The Addition Lands are a national treasure," Mr. Schwartz concludes. "Added to the 582,000 acres of the original preserve by The Big Cypress National Preserve Addition Act of 1988, the Senate report accompanying this legislation referred to the Addition as 'one of the few remaining large parcels of pristine land left in Florida' and noted 'its environmental importance and beauty is unquestioned.' On the House side, the Addition was referred to as an area of “unique wild beauty,” and as 'habitat for a wide variety of plants and animals, including the Florida panther, the bald eagle, native orchids and many other species…'
"This is an opportunity for NPS administration to take a step that will truly fulfill the lofty language of the Organic Act of 1916. The reasons for steering clear of the current preferred alternative are abundantly clear. At a time when restoration of the Greater Everglades has become a national priority, this is not a time to turn back the clock on natural resource protection," he writes.