If anyone is interested in using the comments of the NY State Ornithological Assoc. in preparing their own submission, they are pasted in below. I believe NY City Audubon also has suggestions for comments on their website.
Andy Mason, Conservation Chair NYSOA ***************************************************** Suzanne McCarthy September 30, 2013 Acting Superintendent Gateway National Recreation Area Dear Superintendent McCarthy: I am writing on behalf of our organization with comments on the draft general management plan for the Gateway National Recreation Area. The NY State Ornithological Assoc. is the umbrella group for bird clubs and a number of Audubon chapters in NY State. We represent 46 member organizations and 700 individual members. Gateway National Recreation Area is well-known and supported by our member clubs and individual members, and is one of the locations most visited by the birding community in New York. Our organization has held field trips to various locations in the area, including visits from the NY State Young Birders Club which we sponsor. We have long been involved with management of natural resources, particularly birds, on federal lands in New York State. Within the past year and a half we have submitted comments on management plans for Wallkill National Wildlife Refuge and Montezuma National Wildlife Refuge. As with Gateway, we emphasize protection of avian resources in balance with access and recreation. We are concerned that the preferred Alternative B of the pending draft management plan includes actions that would negatively impact important bird habitat and birds in the Gateway area, and threaten the long-term well-being of these resources for the future. This alternative recognizes the potential for visitor use to degrade habitats and affect wildlife with resulting impacts that could violate the Endangered Species Act. Clearly this is an unacceptable scenario. No governmental agency should engage in management activities that could conflict with the ESA or other important environmental protections. We oppose planned recreation activities for Big Egg Marsh, Canarsie Pol, and Hoffman and Swinburne Islands. Numerous species of waterbirds and shorebirds depend on these areas for nesting and feeding. Increased human presence and activity can bring nest abandonment and predation with reduced production in these very important breeding areas. These locations are not appropriate for recreation and should receive a high level of protection. Alternative B envisions removal of grasslands that are important for a number of state and federally listed species. This habitat type has already experienced major losses regionally, with a corresponding decline in grassland birds. Rare plant species would also be negatively impacted by this development. In particular, the Floyd Bennett Field grasslands hold potential for increased breeding of grassland birds with proper management. Grasshopper Sparrows—a species recognized as of great conservation need has nested there in the past. Other grassland bird species could also utilize this area and are threatened by development and increased recreation activities. Grasslands should receive a high priority for protection in the plan. Development of Plumb Beach that would result from adoption of Alternative B threatens horseshoe crabs—an at risk species, and important food source for rapidly declining Red Knots, as well as other shorebirds. This area is an important stopover and refueling site for these birds that likely have few alternative feeding sites. The management plan should consider the threats and importance of Plumb Beach and include protective actions rather than development. The declining and environmentally important marshes of the Jamaica Bay NWR should likewise receive higher levels of protection than envisioned under alternative B. These areas should be classified as sensitive resource subzones, reflecting their critical place in the overall ecosystem of the Gateway area. Marshes and other wetlands in urban settings are among the most threatened natural areas, and their importance as wildlife habitat, for storm protection and improving water quality cannot be overstated. The Jamaica Bay NWR should be reserved for passive recreation only, in consideration of its purpose as a wildlife refuge. Activities such as biking, kayaking and other boating, fishing, etc. are inappropriate for this area. On balance it is the view of our organization that Alternative C, identified as “ . . . least damaging to the biological and physical environment and best at protecting and enhancing natural and cultural resources.” should replace Alternative B as the preferred alternative. Alternative C will provide Gateway with a management course that will allow future generations to benefit from the special qualities and opportunities it has provided since its establishment. We call on the National Park Service to place protection of the irreplaceable natural resources of the Gateway National Recreation Area as its highest priority. Sincerely, Andrew Mason, Conservation Chair -- NYSbirds-L List Info: http://www.NortheastBirding.com/NYSbirdsWELCOME http://www.NortheastBirding.com/NYSbirdsRULES http://www.NortheastBirding.com/NYSbirdsSubscribeConfigurationLeave.htm ARCHIVES: 1) http://www.mail-archive.com/nysbirds-l@cornell.edu/maillist.html 2) http://www.surfbirds.com/birdingmail/Group/NYSBirds-L 3) http://birdingonthe.net/mailinglists/NYSB.html Please submit your observations to eBird: http://ebird.org/content/ebird/ --
