BasicPatrick
01-04-2016, 10:01 PM
MBBA ACTION ALERT
1/4/16
The Cape Cod National Seashore is currently accepting public comment on a proposed Comprehensive Shorebird Management Plan. This comment period opened on November 9th, 2015 and will end on January 11, 2016 at 11:59PM. The Massachusetts Beach Buggy Association has spent a great deal of time & resources working with a consulting firm in order to analyze this very complicated 274-page document. MBBA will continue to review the Seashore’s proposal and will be submitting detailed comments by January 11th. We have released this ACTION ALERT urging members, friends, affiliated organizations and the public at large to take a few minutes and submit individual comments as soon as possible.
There are TWO ways to submit comments:
1) To submit comment via email:
Open the web site: www.parkplanning.nps.gov
On this page you will find a list of "Projects with Documents Open for Comment.
Click on the "Cape Cod National Seashore" "Comprehensive Shorebird Management Plan".
Click on the words "Open for Comment"
Click on the words "Comprehensive Shorebird Management Planned Environmental
Assessment"
Click on the Words "Comment Now"
Fill out the digital form and either type in or cut and paste your comments.
2) To submit comments via US Mail:
Mr. George Price, Superintendent,
Cape Cod National Seashore,
99 Marconi Site Road,
Wellfleet MA 02667.
What should you say in your comments? In our view, the proposed plan is so vaguely written that even though it appears to promote access via flexible management, we feel it simply gives the Park Service a "blank check” to impose more restrictions on the public's access & ability to recreate within the Cape Cod National Seashore. MBBA urges like-minded commenters to consider incorporating the following guidance into their personal comments. We prefer commenters write in their own words, however feel free to cut and paste if you prefer.
Suggested guidance for comments:
1) The alternatives proposed will cause significant impact to wildlife populations, park resources and traditional visitor experience. This level of impact is not adequately captured in the "EA" (Environment Assessment). While we acknowledge NPS held a one-night open house on the plan, there has been no detailed public presentation to both year round and summer residents. To conduct a public comment period over the holidays for a plan that proposes NPS shoot, trap and poison animals with no public hearing can be seen as nothing else but an attempt to avoid public scrutiny of a very controversial subject matter. NPS should find that the potential impact of these alternatives rises to a level that requires a comprehensive "EIS" (Environmental Impact Statement) rule making process, which includes formal public hearings, a more detailed analysis of impacts and allows for more transparent public input.
2) Alternative A is presented as the legally required Status Quo option. In most sections, the language used differs in content and meaning from the language in the existing CFR (Code of Federal Regulations). In the section that details size of the SCV (Self Contained Vehicle) areas, Alternative A makes changes to the methodology used to determine the size of these areas. We suggest Alternative A be re-written and status quo language be taken directly from the existing CFR. If NPS is actually proposing changes to the SCV area language, it should do so in a separate alternative with clear explanation so that the public can fully understand and make comment.
3) The plan proposes multiple actions which allow CCNS personnel a great deal of flexibility when it comes to personal judgment regarding placement of symbolic fencing, the size of buffer zones and decisions on whether to open, modify or completely close access to various areas. The alternatives do not provide enough detail for the public to evaluate this type of flexibility and how the specific alternatives will impact current access. We feel that each of these sections should contain detailed procedures that include measurable metrics based on best available science. These procedures should be explained using language that is easy to understand by both NPS and stakeholders.
4) Alternative B allows NPS to relax protection of up to 5 nests near income generating parking lots, lifeguarded beaches and "Pole Road". This reduction in shorebird protection would be allowed in exchange for increased protection and restricted access to other areas of the park in which recreational activities are currently allowed after July 1. For example, Alternative B would allow for traditional spring restrictions in Hatches Harbor be extended to as late as October 15 if certain species are simply present. We do not feel the benefit of this flexible management is worth the risk of losing the ability to fish, swim and kayak in Hatches Harbor, Nauset Marsh and from increased closed areas from expanded protection of "resting" shorebirds.
5) Generally, MBBA is opposed to using lethal predator control as a method to increase shorebird populations within CCNS. We question how birds that have eaten poison but fly away will be counted in terms of the proposed 50 animals this plan allows NPS to kill each year. Much more detail and discussion should be provided to the public with regard to the predator control programs prior to final decision making. We notice that a recent reduction in the use of exclosures appears to coincide with the similarly recent dramatic decline in fledge rate. We would like to see use of exclosures returned to the frequency of use when fledge rates were as high as 1.44. Finally, the Purpose and Need section lays blame for increased numbers of predators on the human caused factors of "Bird Feeders, Garbage left on beaches & Road kill". This plan proposes no actions to reduce bird
feeders or road kill within or near the park nor does it propose methods to prevent human garbage from being deposited on the beach twice per day during the rise and fall of the tide.
Once you have submitted comments, please call at least one friend and get them to make comment as well. Democracy works when people voice their opinion.
Your opinions matter!
Sincerely: MBBA Political Action Committee
1/4/16
The Cape Cod National Seashore is currently accepting public comment on a proposed Comprehensive Shorebird Management Plan. This comment period opened on November 9th, 2015 and will end on January 11, 2016 at 11:59PM. The Massachusetts Beach Buggy Association has spent a great deal of time & resources working with a consulting firm in order to analyze this very complicated 274-page document. MBBA will continue to review the Seashore’s proposal and will be submitting detailed comments by January 11th. We have released this ACTION ALERT urging members, friends, affiliated organizations and the public at large to take a few minutes and submit individual comments as soon as possible.
There are TWO ways to submit comments:
1) To submit comment via email:
Open the web site: www.parkplanning.nps.gov
On this page you will find a list of "Projects with Documents Open for Comment.
Click on the "Cape Cod National Seashore" "Comprehensive Shorebird Management Plan".
Click on the words "Open for Comment"
Click on the words "Comprehensive Shorebird Management Planned Environmental
Assessment"
Click on the Words "Comment Now"
Fill out the digital form and either type in or cut and paste your comments.
2) To submit comments via US Mail:
Mr. George Price, Superintendent,
Cape Cod National Seashore,
99 Marconi Site Road,
Wellfleet MA 02667.
What should you say in your comments? In our view, the proposed plan is so vaguely written that even though it appears to promote access via flexible management, we feel it simply gives the Park Service a "blank check” to impose more restrictions on the public's access & ability to recreate within the Cape Cod National Seashore. MBBA urges like-minded commenters to consider incorporating the following guidance into their personal comments. We prefer commenters write in their own words, however feel free to cut and paste if you prefer.
Suggested guidance for comments:
1) The alternatives proposed will cause significant impact to wildlife populations, park resources and traditional visitor experience. This level of impact is not adequately captured in the "EA" (Environment Assessment). While we acknowledge NPS held a one-night open house on the plan, there has been no detailed public presentation to both year round and summer residents. To conduct a public comment period over the holidays for a plan that proposes NPS shoot, trap and poison animals with no public hearing can be seen as nothing else but an attempt to avoid public scrutiny of a very controversial subject matter. NPS should find that the potential impact of these alternatives rises to a level that requires a comprehensive "EIS" (Environmental Impact Statement) rule making process, which includes formal public hearings, a more detailed analysis of impacts and allows for more transparent public input.
2) Alternative A is presented as the legally required Status Quo option. In most sections, the language used differs in content and meaning from the language in the existing CFR (Code of Federal Regulations). In the section that details size of the SCV (Self Contained Vehicle) areas, Alternative A makes changes to the methodology used to determine the size of these areas. We suggest Alternative A be re-written and status quo language be taken directly from the existing CFR. If NPS is actually proposing changes to the SCV area language, it should do so in a separate alternative with clear explanation so that the public can fully understand and make comment.
3) The plan proposes multiple actions which allow CCNS personnel a great deal of flexibility when it comes to personal judgment regarding placement of symbolic fencing, the size of buffer zones and decisions on whether to open, modify or completely close access to various areas. The alternatives do not provide enough detail for the public to evaluate this type of flexibility and how the specific alternatives will impact current access. We feel that each of these sections should contain detailed procedures that include measurable metrics based on best available science. These procedures should be explained using language that is easy to understand by both NPS and stakeholders.
4) Alternative B allows NPS to relax protection of up to 5 nests near income generating parking lots, lifeguarded beaches and "Pole Road". This reduction in shorebird protection would be allowed in exchange for increased protection and restricted access to other areas of the park in which recreational activities are currently allowed after July 1. For example, Alternative B would allow for traditional spring restrictions in Hatches Harbor be extended to as late as October 15 if certain species are simply present. We do not feel the benefit of this flexible management is worth the risk of losing the ability to fish, swim and kayak in Hatches Harbor, Nauset Marsh and from increased closed areas from expanded protection of "resting" shorebirds.
5) Generally, MBBA is opposed to using lethal predator control as a method to increase shorebird populations within CCNS. We question how birds that have eaten poison but fly away will be counted in terms of the proposed 50 animals this plan allows NPS to kill each year. Much more detail and discussion should be provided to the public with regard to the predator control programs prior to final decision making. We notice that a recent reduction in the use of exclosures appears to coincide with the similarly recent dramatic decline in fledge rate. We would like to see use of exclosures returned to the frequency of use when fledge rates were as high as 1.44. Finally, the Purpose and Need section lays blame for increased numbers of predators on the human caused factors of "Bird Feeders, Garbage left on beaches & Road kill". This plan proposes no actions to reduce bird
feeders or road kill within or near the park nor does it propose methods to prevent human garbage from being deposited on the beach twice per day during the rise and fall of the tide.
Once you have submitted comments, please call at least one friend and get them to make comment as well. Democracy works when people voice their opinion.
Your opinions matter!
Sincerely: MBBA Political Action Committee