Linda Canzanelli, Superintendent                                                 October 31, 2001

Biscayne National Park

9700 SW 328 Street
Homestead, FL 33033-5634

 

RE: General Management Plan – Comments on Newsletter 2

 

Dear Ms. Canzanelli:

 

Please accept this letter as the comments of the Marine Council on the information contained in the General Management Plan Newsletter 2, Fall 2001. First and foremost we would like to emphasize that the comments provided in our original letter to you on this subject still stand. We as an organization were disappointed that more of our concerns were not dealt with in a straightforward manner in the most recent document.

 

As we have stated before, the Marine Council is a community-based advocacy group supporting marine interests in Miami-Dade County. The organization is over 45 years old and has members representing all areas of the marine community. The Marine Council and its members have always supported the protection of our marine resources and were some of the early supporters of the establishment of the BNP. We do however, feel that in some cases undue emphasis has and potentially may be placed on the boater/fisherman in the form of rules, regulation, or restrictions. Our comments in the original letter, as well as these comments, are centered on the general premise that:

 

Boaters and fisherman must continue to have access to and be able to use the BNP.

 

Our comments follow, in no particular order of importance.

 

 

  1. As a whole we felt the document was very vaguely worded allowing for widely different interpretations of the proposed resource conditions, visitor experience and management action and facilities. This only leads to polarization in the ultimate implementation of the plan. Both proponents and opponents can twist what they thought was meant to be accomplished. The use of the overlay concept is misleading. In our opinion it only suggests additional regulatory restrictions.

 

  1. We feel that the impacts from boating and fishing are over emphasized as regulation targets, when issues like canal discharges have much greater impact, in our opinion, than all of the boating activity.

 

  1. We do not understand how the management areas were decided upon. The lack of understanding of their proposed locations is troubling. To ask the general public to draw on a map with a scale of approximately 1” equal to 2 miles is outrageous. No management restrictions should be imposed without scientific justification presented at public hearings and workshops and rule development.

 

  1. The document continues to make reference to “carrying capacity”, “viewshed boundary”, but NO information is provided about their extent or methodology for creating, implementing, etc. We remain strongly opposed to the concept of carrying capacity as a management tool. We don’t think anyone could accurately define the inputs, relationships or results. Viewshed is again the Park’s attempt to expand its jurisdiction beyond the Park’s boundary. This again is a philosophy we strongly object to. One must remember this is an urban area and in our opinion an “Urban National Park” and should be recognized as such.

 

  1. Not all commercial activities in the park should require a permit

 

  1. Commercial and sport fishing activity should be dealt with separately in the plan and not grouped together.

 

  1. Any management concept must deal with the ability to maintain the existing channels for navigation. The concept of navigation corridors implies severe restrictions on boating activities in other areas and should be removed from the plan.

 

  1. No mention of Marinas is included in the document. Why?

 

  1. What is the status and relationship of other documents identified in the management plan, such as the fisheries plan & soundscape management plan? Information on the development of these documents should be presented at the same time as the general management plan.

 

In conclusion The Marine Council remains very skeptical of the general plan development process. Information provided to date has been vague, confusing and misleading. Additional technical and scientific backup must be provided to justify most of the use restrictions proposed. Boaters appear to be at the brunt of most of the regulation efforts. Finally, BNP must recognize it’s place in an urban setting.

 

 

We look forward to an on-going working relationship with you and your staff as the BNP management plan is developed. We would request that the individuals on the attached list be placed on your mailing list to receive updates and meeting notices. If you have any questions please contact us at 305-856-0206. Thank you.

 

 

 

Sincerely;

 

 

 

Phil Everingham, President

The Marine Council

 

 

 

Cc:      Senator Bob Graham

            Representative Ileana Ros-Lehtinen

 

           


Phil Everingham

Merrill-Stevens Dry Dock

1270 N.W. 11th Street

Miami, Florida 33125                  

 

Carl Straw

Professional Marine Assoc.

1323 S.E. 17 Street, Suite 613

Ft. Lauderdale, Florida 33316

 

Carl Liederman

Capt. Harry's Fishing Supply
100 NE 11th Street

Miami, FL 33132

 

Ed Swakon

EAS Engineering, Inc.

55 Almeria Ave.

Coral Gables, FL 33134

 

Nancy Morgan, Executive Director

The Marine Council

PO Box 432463

Miami, Florida 33243