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Master
Recreation Plan
SAFER’s Public
Comments to the Master Recreation Plan PDT
Two of our members, Al Ovies and Rick
Persson, attended the Decomp PDT meeting on February 4, 2003. They
both spoke up during the meeting’s public comment period. We have
received, via email, your summary of this meeting, and their
comments are included in the summary. We thank you for their
inclusion. Mr. Persson also attended the Master Recreation Plan (MRP)
meeting on February 6, 2003. We have not yet received any
correspondence from MRP. However, due to the nature of the meetings
and time restrictions, our representatives’ comments did not fully
develop SAFER’s position on the issues discussed at the meetings.
We’d like to take this opportunity to expand on their thoughts.
The
Master Recreation Plan (MRP)
Mr. Persson gave us a report of the
MRP meeting at our recent monthly meeting, and we were disheartened
to hear what he had to say. At this point, we are skeptical that the
MRP, as currently structured, will contribute in any meaningful way
towards the realization of our organization’s goals. These goals, as
you are well aware, focus on the prevention of the backfilling of
the Water Conservation Area 3A (WCA 3A) canals.
We were hopeful that Dennis Duke’s announcement at the public
meeting held on January 15, 2002, of the creation of a recreational
committee, was a signal that the Corps of Engineers was approaching
the subject of recreational access in general, and of bass fishing
in the Everglades canals in particular, from a fresh, new
perspective. We expected your agencies to bring interested outside
parties into some semblance of a partnership with the USACE and
SWFMD in the Restoration effort. In November of 2002, the U.S.
Institute for Environmental Conflict Resolution, at the behest of
the sponsoring agencies of the Modified Water Deliveries to
Everglades National Park (MWD), published a report entitled
“Assessment of Opportunities for Multi-Stakeholder Collaboration.”
Their assessment is equally applicable here. It warned:
“By involving stakeholders in the
decision making about collaboration and in the design for such a
process, the [Institute] believes there would be an enhanced
likelihood that the [collaboration] process will ultimately result
in a plan that achieves the sponsoring agencies’ shared goals of
interagency agreement, broad public support, less litigation and
greater trust.” (Institute
Assessment, pg. 48)
Other concerned stakeholders summed
it up, when they testified, “would prefer to participate fully,
not as in CERP teams, where the agencies participate and other
affected parties are allowed to just observe and comment at the
end…Just offering the opportunity for public comment does not
provide sufficient or meaningful participation.” (Institute
Assessment, pg. E-5) Unfortunately, this is where we find ourselves
with respect to MRP.
Despite our inability to fully
participate in the process that could destroy one of the state’s
best fisheries, there are several, more compelling, reasons that
mitigate against MRP in our contention that this is not the answer
to the problems created for bass fishermen by Decomp’s willingness
to backfill the WCA 3A canals.
In the decade long struggle to implement MWD, and more recently
Decomp, the creation of the MRP, “a program-level effort,”
seems almost like an afterthought, an attempt by the Corps at issue
management. This is hinted at by MRP in the committee’s Program
Management Plan (PgMP) of January 27, 2003. It states:
Although a master recreation plan was
not specifically identified in the Restudy, the Corps and SFWMD have
agreed to conduct this planning effort…The CERP/MRP will
interface with all CERP-related project activities, feasibility
studies, critical projects and pilot projects. Many other projects
are underway in South Florida that are not a part of CERP and will
add to the body of knowledge required to complete the CERP MRP.
(MRP/PgMP, pg 3, 5)
Our misgivings stem from three points that we would like to discuss
in more detail. (1) MRP addresses future CERP projects, not projects
in progress, such as MWD and Decomp; (2) MRP doesn’t address the
issue of bass fishing in the WCA 3A canals; and (3) MRP looks at
recreation in CERP’s post-construction phase.
1.
MRP Addresses Future CERP Projects
MWD, the precursor to Decomp, is getting ready to move out of the
planning stages and into implementation. As you know, the
construction phases of this program have been on hold as a result of
litigation filed in federal court by the residents of the 8.5 Square
Mile Area. The judgment in favor of the residents was the result of
the exploitation by their lawyers of a technicality in the language
of the law. The federal magistrate ruled that the federal government
wasn’t authorized to purchase the land in the 8.5 SMA without the
participation of its CERP partner, the State of Florida. The Miami
Herald reports in its February 15, 2003 edition, that both houses of
Congress had moved to approve a change in the language to allow the
COE to begin the purchase of the necessary homesteads. No doubt,
there will be another protracted round of appeals. Nonetheless it
appears that CERP agencies are getting closer to activity.
With the removal of this roadblock, Decomp will also start to move
forward. At the recent Decomp PDT meeting, limited Project
Implementation Reports (PIR) were “re-initiated” and reports from
the different agencies clearly indicate that the work of developing
performance measures, data collection and model development is well
under way. SFWMD alone has spent over $320,000 in advancing Decomp’s
goals. With a “No Plan Formulation” rule in effect, participating
agencies are using every budgetary trick they can think of to move
Decomp’s goals forward. Mr. Ovies, in his report to our members,
stated that he felt that the Decomp PDT was literally “champing at
the bits” to get started.
With all this going on, SAFER is not confident that MRP can “bridge
the gap,” so to speak. Their PgMP states this dilemma clearly:
“The master recreation planning process will take three years. Many
of the CERP Projects are in the PIR phase and will have conducted
recreational analysis prior to completion of a master recreation
plan…It is assumed that the related CERP projects currently
completing recreation analysis will provide the information stated
in this report in a timely basis.” (MRP PgMP, pg. 8-9)
SAFER has little faith in the value of the relatively little
recreational analysis that has been done with regards to Decomp and
MWD. We make this statement with the understanding that recreation,
to the members of SAFER, refers exclusively to bass fishing in the
WCA 3A canals.
2. MRP
Doesn’t Address Bass Fishing in WCA 3A
And therein lies the heart of the problem. If MRP has a major
drawback, it’s the PgMP’s reluctance to address the issue of bass
fishing. Instead, the Summary of Agency Responsibilities
states broadly, “The MRP will take a system-wide approach…The
CERP Master Recreation Plan deals in concepts, and program wide
policies. Projects will develop the actual details of design.” (MRP
PgMP, pg. 6-7) While MRP is painting the canvas with broad strokes,
SAFER wants to see the details brushed in. We want to see the grass,
for which the Everglades is famous, blowing in the breeze. We want
to envision a sleek bass boat on the water, several anglers casting
expertly for a largemouth bass. We want to gasp when a big bass
slams a lure on the surface, and exult when our skill and equipment
tame the fish’s power and cunning. Alas, this is a work of art that
we fear very few on this team will see or feel.
SAFER believes that one of the impediments to the success of this
project is that the U.S. Fish and Wildlife Service seems to be
guided solely by its legal responsibilities to the enforcement of
the Endangered Species Act. This has contributed heavily to the
perception of the USFWS as an agency driven by single species
management philosophy. In its report, the Institute describes the
situation pointedly: “The agencies [ENP and USFWS] are perceived
as being single-mission agencies, not concerned with or required to
find a solution that balances the needs of all the interests.”
(Institute Assessment, pg. 25) One stakeholder warned the panel,
“The process will never work unless these agencies consider other
entities’ interests.”
(Institue Assessment, pg.
E-6) SAFER believes that only
a balanced approach to restoration will lead to success. Restoration
balanced by recreational fishing, that’s our creed at SAFER.
Contrary to what their name implies,
the USFWS certainly isn’t driven by a need to protect the interests
of fisherman across this country. This, despite the fact that the
Federal Water Project Recreation Act of 1965, (WPRA) “Requires
that full consideration be given to opportunities for recreation and
fish and wildlife enhancement.” (MRP PgMP, pg. 9) We invite the
members of the MRP/USFWS to join us at our annual tournament at
Holiday Park, on May 25, 2003. We want to hear from them why their
agency isn’t the first one in line to protect this magnificent
fishery located a stone’s throw from the city limits, right in the
heart of the Everglades. USFWS needs to pay closer attention to what
the Florida Fish and Wildlife Conservation Commission (FWC) is
saying. Their message is clear: restoration and recreational fishing
can exist side by side in peaceful harmony in the Restoration
process. The WPRA urges, “the non-Federal administration of
recreation and enhancement areas be encouraged.” (MRP PgMP, pg.
9) SAFER believes that FWC has the interests of all South Florida
anglers and urges that they play a major role in your deliberations.
3.
MRP Looks at Recreation in CERP’s Post-construction Phase
MRP’s inability to directly involve
itself in the details of other projects’ design, consigns it to
merely looking at recreation in the aftermath of construction on MWD
and Decomp. The Program Scope, according to the PgMP, is “to
identify, evaluate, and address recreational opportunities within
CERP with consideration of impacts to existing recreational
opportunities that may result from CERP implementation.” (MRP
PgMP, pg. 6)
The picture this plan paints does not bode well for the future of
bass fishing in the Everglades. Stating that the Water Resources Act
of 1990 will be a
“consideration
in implementation,” the MRP
quotes:
"If the recreation uses are
adversely impacted, they may be restored or alternatives provided
for comparable recreational use. Costs incurred shall be allocated
to recreation and shall be payable by the beneficiaries of the
recreation." (MRP PgMP,
pg. 8)
The
MRP needs to move beyond the realm of discussion of restoring the
adverse affects of construction, or replacing the Everglades canal
fisheries. This is a fishery that has developed over the decades,
and just now is reaching full maturity. Proximity to the marshes,
and the decades long practice of tournament fishermen who are
dedicated to “catch and release,” has produced a fishery second to
none. It is simply not replaceable! We sincerely hope
that someone on this committee isn’t thinking of moving us somewhere
else in the system, then saying that our concerns were accommodated.
In identifying the goals and objectives of the MRP, the management
plan states that, “Public outreach efforts, performed early in
this phase by the USACE and SFWMD, will ensure that public concerns
related to these problems are identified for review and
consideration…” (pg. 17) We have done that. We have spoken at
public meetings and at PDT workshops. We have given our views to the
Institute of Environmental Conflict Resolution, and they have
published them in their “Assessment of Opportunities.” We have been
in touch with many of the media, and have tried to get our message
out. And we have used opportunities such as this, to have our views
presented directly to the project managers at USACE and SFWMD.
Our message has been the same
throughout, and the Institute’s comments are applicable:
“Recreational interest’s main concern is retaining the recreational
benefits present in the C&SF Project. In particular they object to
the filling of the canals, such as the L-67C canal, that provide a
recreational fishing resource and economic benefits for the region.”
(pg. 23) Despite our misgivings about MRP, SAFER plans to stay
active in the process, attending the public meetings and speaking
our piece at the appropriate time.
We will also continue to press to have the nature of this planning
group changed so that interested shareholders, such as SAFER, will
have a greater impact on the recreational issues of CERP. Only by
allowing meaningful participation will MRP be able to overcome what
the Institute calls a “long history of polarized adversarial
relationships.” The Assessment continues, “The level of
frustration, resentment, mistrust, and in some cases outright
hostility…creates a significant challenge for anyone attempting to
engage the diverse stakeholder interests to work together
constructively.” (Institute Assessment, pg. 30)
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