My name is Kari Martin. My husband and I own and operate the ferry service to Long Point, CALO, on North Core Banks. My family has owned and operated the ferry service for over 60 years including owning land on the seashore. We leave from our private land and return to our private land while transporting pedestrians and their effects to CALO. Below you will find my comments on the approaching EIS/ORV Plan. If you need further information, please feel free to contact me at the above number. I will be awaiting your response to my remarks. Thank you in advance for your time in this matter. My comments regarding the ORV/EIS Management Plan at Cape Lookout National Seashore (CALO) in Carteret County are listed below. The Mission statement of Cape Lookout National Seashore states that the seashore was established by Public Law 89-366 (March 10, 1966) “to preserve for public use and enjoyment an area in the State of North Carolina possessing outstanding natural and recreational values…” On Page iv, Purpose and Significance of …. To restrict or prohibit Off Road Vehicles (ORVs) would violate the enabling legislation that would diminish or prohibit the use and enjoyment of the park by a significant and historic proportion of the park visitors. The use of ORVs is historic and predates the founding of the seashore, but has become an increasingly targeted and regulated form of recreation and visitation. Vehicle Permits (pg ix) should not even be considered. When people make plans to visit CALO, they have to make ferry arrangements to get their vehicles and/or effects transported to the island. They already pay a fee for this arrangement. This park is NOT like Cape Hatteras National Seashore with a major highway right beside it and you can take any open ramp off the main highway onto the seashore. When the visitor makes plans to visit CALO, the visitor has to want to go to CALO. There are plans involved with visiting this national seashore. BUT, if you have to make an entrance/vehicle fee, it should be economically feasible for the average American to obtain. Remember this is OUR Park. The entrance/vehicle fee should cost no more than what the average cost is for a Driver’s License. If you require an astronomically high entrance/vehicle fee, the visitation will go down drastically, not to mention the affect it would have on the vehicle ferries along with revenue inside of Carteret County. Carteret County is supposed to be known for its tourism, with this high fee, the tourism will diminish drastically. This structure stated in the ORV/EIS Plan was not thought out clearly by anyone who understands this park. It seems like it was just manufactured like the fee structure at Cape Hatteras National Seashore, which CALO is totally different from. Cape Lookout National Seashore provides outstanding visitor recreational opportunities to fish, hunt, beachcomb, hike, swim and camp in a remote coastal environment. This fee structure needs to be worked on by users of the park, not just NPS employees who don’t even use the park as a visitor. This is simply unacceptable for the visitors of CALO; we should not have to simply accept Cape Hatteras’ fee structure. Rather than accepting the cost structure enacted at Cape Hatteras National Seashore, CALO should recognize its uniqueness and enact a fee structure that best fits the visitation patterns of the park. Another issue at hand is why would the service from a different seashore than the one you are trying to change, Cape Hatteras, be exempt from the driving regulations? This shows partiality and is not fair to the visitors of the park from the county that the park is located in. Why should these visitors have special treatment? Do they spend tax dollars in this county? This is about as ridiculous as the permit fee structure. Again, you need to relook at this issue using common sense. Where is the documentation or evidence that night time driving on CALO hurts the wildlife? Decisions and possible restrictions should be and need to be based on supported fact and not unsupported argument. Again, this is another issue at Cape Hatteras National Seashore that you people, have added to the ORV/EIS Plan for CALO. Remember, you cannot drive off a major highway at any access point; you have to make ferry arrangements to get to the island and from the island. While beaches in Florida and other states have lights directly on the beach from houses and cars driving on the beach, the success rate of turtles are high. In a recent study funded by the U.S. Marine Corps in cooperation with the National Park Service, and other agencies state nocturnal predators is a main cause of a nest failure, not ORV or human activity. Again, where is the documentation for this restriction imposed upon the visitor of CALO? On page 60, it discusses the vehicle length and operator requirements, it seems to me that the operators of ORVs, especially Overhead Campers, know more about what their vehicles than you or I. To say you can only have a vehicle that is under 30 feet is preposterous and then on top of that you add that every ORV user should have a tire gauge, shovel, etc. Don’t you think they already know this? This, again, seems like it is directly from Cape Hatteras National Seashore where you can just drive off the highway onto the beach on any open ramp, whereas, if you visit CALO, you have to make ferry reservations to even get to and from the seashore. If any of the ORV users get stuck, NPS has never helped so this issue shouldn’t matter, but then on the other hand, many ORV users have helped NPS when their vehicle got stuck. This needs to be cleared up and rewritten to be clearer so that visitors with Overhead Campers can have an input with this issue. If the ferry operators don’t have an issue with the vehicle length, neither should CALO. Where is the data that supports the idea that to travel on the beach or back road should be or has to be done with a vehicle 30 feet or under? If you have evidence to support this issue then you need to make it public. Despite documented research on Piping Plovers (Page 170) and observation of Piping Plovers activity within the seashore, the accompanying data fails to take into account the full range of factors that is all present perhaps insurmountable obstacles to the revitalization of the species across its range. Where is the data from USFWS that supports the stated goal of 2,000 pairs being obtainable or sustainable? Again, in a study funded by the U.S. Marine Corps and National Park Service, Matthew Hillman stated, “CALO is unique in that relatively few measures, historically or presently, have been implemented to control erosion and protect human development. Therefore, human impacts on water bird habitat are less PERVASIVE at CALO than in many other regions of the U.S. Atlantic coastline.” (10) In another study done by the same agencies, Tracy Borneman stated, “I did not find human activity affected oystercatcher nest attendance.” (26) Borneman also states, “Although I found oystercatchers were often off their nests during vehicle and pedestrian events, I found MINIMAL evidence that human activity affected the total number of times oystercatchers left their nests in a day, suggesting oystercatchers move to and from their nests frequently during the day REGARDLESS of HUMAN ACTIVITY.” (26) A solution to this problem is for NPS to hire more “Resource” personnel and equipment so they can monitor Middle Core as they do both North and South Core Banks. When the NPS counts the nests on Middle Core, but do nothing to increase the survival rate of these chicks, for example, put wire cages so predators can’t get to them, these numbers make it look like the visitor is not respecting what you are doing to keep this and any other endangered species alive. If you look at the number of tickets per the number of users to the park, it shows that an over whelming number of visitors are in compliance with the monitoring of ALL the species that are endangered, protected, concerns of Interest, and just plain everyday animals. Of course, lets don’t forget that Piping Plovers, as well as all protected species, are wild animals that have and will continue to be impact by the environment as a whole and their viability will continue to be influenced and in a large measure governed by the entirety of the environment in which they must live, despite any resources or the efforts of these who work toward their continued survival. As stated on Page 197, Human activity, “…many violations occur every year at the seashore.” This statement is misleading and cannot be supported by the provided data. In YOUR report, you state that for 2012 the visitation was “approximately 480,000” (Pg. 235) and the number of vehicles that was transported to the seashore was 4,156 (Pg. 238). During the time the seashore was open from March 16th through December 31 (approximately 291 days) only 17 citations (8 pedestrians and 9 vehicles) were issued for the entire birding closure areas. WOW, so that claim is really not what you tout in the report, the visitors need to be commended for obeying the law. Kudos to the visitors of CALO, the Superintendent should be commended for the work of his people that enforce and educate the visitors. Yet again in the most recent report, Hillman alleges, “Additionally, NPS beach management practices, namely the 50-m buffer between the colony edge and symbolic fencing to exclude pedestrians and vehicles, appeared to adequately protect colonial water birds from any demographic effects of human recreation.” (29) Once more, this seashore is NOT as accessible by a highway as is Cape Hatteras National Seashore. Most of the visitors want the experience with a natural environment therefore they RESPECT what the NPS is doing with the survival rates of the endangered and threatened species. All through the ORV/EIS Plan there is no evidence that would lead me and others to believe that further restrictions on ORV operations is warranted or will lead to a greater Piping Plover fledge rate. During the most productive year, 2011, the Piping Plover fledge rate of .90 was achieved which falls well below the “Recovery plan goal of 1.5 chicks per year” (Pg. 173). As you stated in the ORV/EIS Plan, “the cause of high chick mortality continues to be unknown…” (Pg. 182); which easily leads anyone with common sense to realize that this could be attributed to any number of NATURAL factors instead of the presence of an ORV. Hillman states, “The main drivers of nest and chick survival at CALO were flooding and mammalian predation in 2010 and 2011.” (21) Not human activity including driving an off road vehicle. Borneman states in her report, “Nest survival, chick survival, and productivity in study season were comparable or higher than overall levels in North Carolina from 1995-2012” (68) Borneman also states, “Predations was by far the GREATEST cause of nest failure (41.96% of total nests). Environmental elements, such as wind and storm overwash were responsible for failure of 10.71% of nests and 7.14% of nests were abandoned.” (68) Hillman also states “The greatest threats to colonial waterbirds at CALO were predation and flooding …. Predators, primarily raccoons and to a lesser extent feral cats, gull-billed terns,, common terns, ruddy turnstones, ghost crabs and great horned owls, were the main cause of nest failure..” (28) Hillman also states, “There was no EVIDENCE that overflights or HUMAN RECREATION contributed to nest failures wither directly or indirectly, particularly as nocturnal predators were the primary driver of nest failure and >90% of all known depredation events occurred at night when the Core MOA was inactive, non-Core MOA overflights were rare, and FEW RECREATIONISTS were observed.” Borneman also states, “I believe the current LOW levels of pedestrian activity at North Core Banks have MINIMAL reproductive consequences for nesting American Oystercatchers.” (72) With all this being stated in reports funded by the U.S. Marine Corps along with the National Park, this just goes to show that ORVs are not what is detrimental to the birds or turtles but, other wildlife! Are you going to stop or put on number on them next? Throughout the ORV/EIS Plan, ambiguous phrases such as “could impact, the potential to, could result, may cause, has the potential, potential impacts’ among others, are used as justification for enacting further restrictions, limiting access or banning ORVs from CALO. The words are just that, words, where is the evidence presented to support the argument that the operator of an ORV on the seashore is unfavorable to the environment? As I stated above, these two studies are the latest and most current reports on CALO’s bird population. This seems to me that whoever came up with this ORV/EIS Plan is targeting one user group, ORV operators, only because of the threatened actions of special interest groups and to value the opinions of those groups, who have probably never stepped foot on CALO, versus the opinions of park visitors is violating our trust in the National Park Service. Sincerely, Kari Martin Owner Morris Marina Ferry Cc: Sen Kay Hagan Sen Richard Burr Congr Walter Jones Sec of Interior Director of NPS Works Cited Hillman, Matthew Dean.2012. Evaluating the Impacts of Military and Civilian Overflights and Human Recreation on Least Terns, Common Terns, Gull-billed Terns, and Black Skimmers at Cape Lookout National Seashore, North Carolina. Borneman, Tracy Elizabeth. 2013. Effects of Human Activity on American Oystercatchers (Haematopus palliatus) Breeding at Cape Lookout National Seashore, North Carolina
Posted on: Thu, 17 Jul 2014 12:18:55 +0000
Trending Topics
Recently Viewed Topics
© 2015