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 establ