CaptnKirk

I was sent this by Biloxigeek...he's been keeping up on the happenings of the Gulf Islands National Seashore. Thanks bro! Here's what was said...

The email Biloxi sent...

....and the response from Mr. Eubanks...

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BiloxiGeek

Ok, the way I read the response I got was that "new regulations" most likely means we're going to get access to the islands back. Maybe with some speed and/or distance rules on wakes and whatnot, but at least it's a run I can plan on making this summer.

What do you all think? Am I being over optimistic reading that email?

__________________
Mississippi Gulf Coast Personal Watercraft Club
http://www.mgcpwc.com/
/- Sinners can repent, but stupid is forever. -/

J.Donaldson

My experience with GINS/Jerry Eubanks/NPS regs, going back to 1998, is to be pessimistic, not optimistic.

GINS has never had a PWC problem, meaning a high level of use, or accidents or enviro degradation.

The NPS rule back in '98/99 was that the parks including GINS would have to be studied to remain open - or would close automatically. GINS and Mr. Eubanks NEVER undertook the study, they simply stalled. And this is despite media attention in Pensacola and Mississippi State legislators writing them asking for them to complete the studies and allow action. Hence my feeling that the "glass is half empty"

If the rules come out as overly restrictive, it will be time to turn up the heat on GINS and the NPS as much as possible, using every resource and means of communication.

In the mean time, we suffer with Eubanks' stalling.

BiloxiGeek

Not sure where you're getting your info. They did their study, maybe it took them awhile but it was done.

http://www.nps.gov/applications/park...March-2004.pdf

http://www.nps.gov/guis/extended/guis%20pwc.pdf

__________________
Mississippi Gulf Coast Personal Watercraft Club
http://www.mgcpwc.com/
/- Sinners can repent, but stupid is forever. -/

J.Donaldson

Study/rule whatever. They have been stalling; Katrina, Ivan, Rita aside. This has been in process for almost 8 years and closed for 5 1/2 years - not the sign of anyone in a hurry to admit PWC.

J.Donaldson

Biloxi,
I also get the sense that you have read the study. I too looked at the study and made comments. Following is one of my letters that did not get a response from Supt. Eubanks:

February 12, 2003


Dear Superintendent Eubanks:

I am a park visitor who enjoys Personal Watercraft use and a variety of other recreational activities on the nation's public lands and waters. I ask that you please allow PWC use at Gulf Island National Seashore at the earliest opportunity. This is the only possible management alternative that allows all visitors to access the Seashore and to enjoy its natural qualities.

PWC operators have as much a right to enjoy access to public waters as any other type of recreational vessel. The presence of PWC, seeking recreational experiences in a safe in responsible fashion, will have no more impact or safety related concerns than other powered vessels.

The concerns about noisy, polluting, high-speed nature of PWC are typically based on out-of-date information and stereotypes perpetuated by anti-recreation groups. The PWC manufactured in the past three to four years have sound levels up to 70% less that models from a decade or more ago. NPS should collect timely and accurate data for themselves before accepting statements supplied by anti-access groups.

Most waterways across the nation are becoming more and more crowded. It is critical that the National Park Service develops stewardship policies that promote safe and suitable access for the activities for all the recreation users who want to enjoy the public recreational waterways .

The safety record of PWC is another issue used to distort or sensationalize PWC use. Before bowing to the misstatements and half truths of the lock-out fanatics, the NPS has an obligation to talk to recognized boating safety authorities, the very folks who collect and analyze boating safety data. Boating accident information related to the waters of GINS should be the criteria for analyzing safety issues, not overblown hyperbole of special interest groups.

Frequently, the NPS and other resource management agencies are asked to embark on some regulatory scheme on the basis of comparison with other jurisdictions; i.e. because ABC prohibited PWC, GINS should also prohibit PWC. Such comparisons make no allowance for the conditions of each venue, nor any allowance for changing times. Such comparisons are relying on a “cookie-cutter” approach dictated by bureaucrats in distant regional offices or headquarters. As you know, the regulatory environment for NPS units has been a constantly evolving process. The call for banning activities based on the shrill cries of misanthropic lock-out factions of special interest groups is not currently in favor.

Please do not turn your back on the vast numbers of the public who operate PWC, such as the more than 50 million Americans who enjoyed a PWC experience as some point. Any legitimate environmental assessment will confirm that balanced use and reasonable access for all responsible recreational activities is an appropriate management strategy.


Sincerely,


John Donaldson
3 Hutton Center Drive #880
Santa Ana, Ca. 92707

J.Donaldson

Yet more observations. The following is my correspondance to NPS mailed in May of '04 as comments on the Environmental Assessment (EA). If you read the NPS EA and then look at my comments, you will find that if anything, I was subdued with my questioning of the credibility, accuracy and objectivness of the NPS in preparing the EA.

Also you should note that I did not receive a reply from Supt. Eubanks on these comments either.

May 17, 2004
Jerry A. Eubanks
Superintendent
Gulf Islands National Seashore
Park Headquarters
1801 Gulf Breeze Parkway
Gulf Breeze, FL 32563-5000


I strongly urge the National Park Service (NPS) to reject Alternative B, designate Alternative A as the preferred alternative, and allow the resumption of PWC use in the Gulf Islands National Seashore (GUIS) as soon as possible.

According to the NPS’s Environmental Assessment (EA), Alternative B is preferable because it ensures “safe, healthful, productive, and aesthetically and culturally pleasing surroundings,” while “attain[ing] the widest range of beneficial uses of the environment without degradation, risk of health or safety, or other undesirable and unintended consequences.” The NPS emphasizes that Alternative B will reduce visitor conflicts and enhance boating safety.

These conclusions are based on a substantial amount of conjecture, speculation, unfounded assumptions, and otherwise undocumented and immaterial observations. The inclusion of this unscientific rhetoric in the EA creates an aura of prejudice and is not up to the standards of objectivity one should expect in taxpayer funded reports.

For example, while the NPS properly finds that PWC emissions will not impair nor significantly impact park resources, the EA does not recognize nor make any estimate of the impact of technological improvements already in widespread use by PWC. Thereby, EA relies on outdated emissions data and overstates the potential impacts of PWC on air and water resources and potentially on human health. These are prejudicial and seemingly deliberately misleading omissions in the EA.

Alternative A does not suffer from these flaws. Instead, it sets forth a more balanced strategy for managing PWC use in the Gulf Islands NS. Alternative A best accomplishes the park’s mission and regulatory goals and is consistent with Florida law because it imposes limitations on all motorized vessels, not just PWC. Enforcing Alternative A likely will be more appealing to local law enforcement upon whom the NPS relies to some extent. It will also ensure safe, fair and environmentally-sound management of park resources, thereby enjoying better voluntary compliance by PWC operating visitors.

Emissions

One of the areas in the EA that particularly disturbs me is the NPS’ citation to the Kado Study. PWC opponents, including some who litigated against any PWC use, have attempted in the past to use this study to polarize the opinions of those unfamiliar with the relative levels and impact of PAH emissions from PWC. This EA appears to perpetuate that prejudicial impression.

Every form of combustion creates PAH emissions of some sort, basically in proportion to the amount of fuel consumed. It has been estimated that the wildfires in the Western US (including those in National Parks) in the past three years created more PAH than if every internal combustion engine in the US were to run continuously for a year. Yet the EA has a lengthy discussion about PWC PAH impacts under the water quality section, seemingly implying that PWC are somehow a unique problem. The EA offers not one hint of context or relative contribution for the estimated PWC PAH.

The changing engine technology in PWC, to four-stroke and direct injected two-stroke engines is occurring much faster than the EA assumes. Sales of these newer models have rapidly surpassed the sale of conventional carbureted two-stroke PWC. The estimated amounts of unburned fuel released into the park’s waters will therefore decline substantially more rapidly than projected in the EA. Because the EA has not properly accounted for the pace at which the PWC are converting to cleaner-running engine technologies that meet various standards, the EA predictably overstates the potential water quality impacts of PWC use. Considering the NPS estimate on only ½ to 4% of overall boat use represented by PWC, relative PWC pollutant loads are miniscule. Further the PWC contribution will decline as a percent of the total if the NPS were to consider the more rapid retirement of old technology PWC vs. outboard engines.

Another example of the EA making unfounded and unsupportable assumptions is the observation that PWC will be responsible for a disproportionate share of emissions in the short- and long-terms. The EA states that, in 2002, PWC operating in the park would, had they been permitted for the entire year, have contributed approximately 30% of cumulative emissions, even though PWC would have comprised somewhere between 0.5 and 4% of the vessels in the park. Then in yet a more astounding leap of logic the EA projects that in 2012, that PWC will be the source of 50% of the cumulative boating emissions. These arbitrary projections are, in my opinion, a crystal clear example of bias against PWC.

There is no explanation or data to support these figures nor is there any collection of field data that would permit a reasonable presumption of accuracy of this projection. In fact, the presumption that the 2012 PWC emissions will constitute half of the boating emissions also conflicts with the EA’s PWC use forecasts. The NPS assumes that, in 2012, 501 PWC will operate in park waters for a total of 1,906 hours on peak days. In contrast, in 2012, 9,502 motorized boats will use park waters for a total of 16,693 hours on peak days. Based on these speculative numbers, PWC will represent just over 5% of all vessels on park waters and approximately 11.5% of total boating hours. The net effect is that the EA significantly inflates potential PWC impact levels.

These numbers dramatically call into question how PWC, meeting the same emission standards as other recreational boats and with a more rapid turnover of their fleet to new technology will be responsible for 50% of the boating emissions. The fact is that PWC emissions are declining at an even quicker pace than the NPS presumes. The inescapable logic is that PWC will be responsible for a decreasing percentage of overall future emissions. The EA is clearly wrong in this section, revealing a troubling bias against PWC.

Correcting the flawed speculations and misleading assumption will lead to lower (and more accurate) estimates of future PWC emissions. These estimates would then much more clearly support the EA’s conclusion that PWC use will not impair or significantly impact human health or aquatic resources.

Sound

The EA notes that park staff received “complaints” about PWC noise. However, the EA does not include any complaint data, relying instead solely on anecdotal accounts. I have seen other NPS reports and documents where the exact number of complaints about the most trivial park activities are fully documented. The lack of specifics in this instance, suggests to me that “noise” issues are a matter of perception, and an answer in search of a question.

The EA suggests that PWC noise is more prevalent than other sounds because PWC are highly maneuverable. I personally cannot think of one possible link between maneuverability and sound. This would imply that if PWC were more maneuverable than any other vessel, they would be louder. Yet that is patently inaccurate.

Based on this odd linkage of characteristics, and the park’s alleged history of noise complaints, the NPS states that PWC use under Alternatives A and B will have sound impacts ranging from negligible to moderate adversity depending on the location, time of day and season.

The EA’s “findings” are unfounded and overstate the potential sound impacts of PWC use. The Gulf Islands NS is one of the most heavily visited units in the national park system, receiving nearly five million visitors each year. Between these millions of visitors, the military overflights from adjacent Air Force and Naval bases, commercial air traffic, commercial shipping, and thousands of other recreational boats, the material contribution of PWC noise is likely to be imperceptible.

So, the NPS then tries to suggest that PWC noise is more intrusive than other human-generated sounds because “PWC continually leave the water, which magnifies noise. Without the muffling effect of water, the engine noise is typically 15 dBA louder and the smacking of the craft against the water surface results in a loud ‘whoop’ or series of them.” according to the EA. The EA has no data support these statements, does not cite any empirical studies nor provides an explanation it arrived at this 15 dBA figure. In fact there is no evidence that the NPS conducted any testing at the Gulf Islands NS, or in other units, which produced an increase of this intensity. Thus, the statement-as-fact that PWC noise is 15 dBA louder when the craft leave the water is unsupportable and as likely as not to be flat wrong.

There is another challenge to credibility in this “noise” related hypothesis. While it may be true that PWC can leave the water on occasion as can all motorized vessels, the NPS speculates about the craft becoming airborne. It is my strong impression that the majority of PWC do not leave the water with the frequency assumed or suggested in this section of the EA. Three-passenger PWC which are frequently carrying a passenger, are quite uncomfortable for both passenger and operators if they leave the water frequently. Thus the EA’s statement that PWC “continually” leave the water appears to be based on a misperception of PWC users.

There is no question that the impact of sound is highly subjective. For example, retired military aviators living near the above mentioned air bases may will enjoy the reminders of their previously exploits represented by the roar of military jets. Others may be less enthusiastic about such sounds.

The fact that NPS receives some complaints about PWC noise is not unexpected. Should NPS regulate all activities that create sound, there would be neither visitors nor any human activity within earshot of NPS units.

Finally one must consider what state and local efforts are being made to reduce boat noise. There is a Model Noise Act suggested by the National Marine Manufacturers Association. It would prohibit the operation of any motorboat, including PWC, in such a manner as to exceed a noise level of 75 decibels measured as specified in SAE J1970 from any point on the shoreline.

Disturbance of manatees, birds and seagrass

The EA again contains no data or evidence to support the “finding,” that PWC could have minor to moderate adverse impacts on park wildlife and habitats. There is nothing in the history of PWC use in the park or in scientific literature to collaborate this statement.

In yet another example of prejudicial, misleading statements, the EA states that, over the past decade, 30% of manatee deaths resulted from collisions with watercraft without a single mention none of these deaths or collisions involved PWC. This could easily lead one to presume that somehow PWC were responsible. In fact, in official correspondence from the State of Florida to a member of the U.S. Congress, it is clearly stated that in Florida waters where manatees are more common, there are “no verified records that implicate a personal watercraft caused the death or injury of a manatee.”

The EA cites no data or proof linking PWC use to manatee deaths or injuries, or for that matter, to the death or injury of other animals in the park. The absence of such evidence is unsurprising: PWC as the EA already noted, are more maneuverable than other vessels, and thus better able to avoid collisions. Further PWC do not have exposed propellers, which could strike submerged or diving animals. Once again, this EA in what appears to me to be a thinly veiled attempt to justify unnecessary PWC regulations, is a discredit to the National Park Service for its lack of objectivity, inclusiveness and cleaving to facts.

In discussing bird impacts, there are published studies that demonstratePWC are, in fact, no more disruptive than other forms of boating activity. Since 1995, Dr. James Rodgers of the Florida Fish and Wildlife Conservation Commission has been conducting scientific studies of the effects of human disturbances on wildlife. In fact I have had first hand experience with Dr. Rodgers in helping him secure equipment for his unconditional use is his research.

From my reading of Dr. Rodgers’ work, he says that any human interaction with wildlife will likely cause some disturbance. Further his studies have shown that PWC are no more likely to disturb wildlife than any other form of human interaction. In fact in several cases, PWC pose less of a disturbance than other vessel types. I find it again predicable that the EA fails to reference the majority of Dr. Rodgers’ research. I can only imagine that his research would not be consistent with the other so called studies cited in the EA.

For example there are the “observations” of park staff. Such observations are not conducted by trained personnel nor on any objective basis from what can be read in the EA, yet they are quoted as a part of the foundation for a regulatory scheme.
Further there are the citations to a so-called “study” conducted well over a decade ago in the Everglades National Park by Skip Snow. A short review of this report destroys the contention in the EA that the Everglades Report is a scientific or empirical study.

Mr. Snow’s report is more correctly described as a speculative discussion of the potential future impacts of PWC use in the park, which Mr. Snow rightly notes early in his document. The EA bizarrely claims Snow proved that PWC use “resulted in damage to vegetation, adversely impacted shorebirds, and disturbed the life cycles of other wildlife.” The EA’s mere suggestion that the Everglades Report was in any way based on factual findings again calls to question the credibility of the overall EA.

I am going to pass over the discussion of potential for damage to sea grasses. The literature is filled with discussions of sea grass damage throughout Florida and elsewhere caused by prop-scarring. With no propellers and no under-hull protrusions, the most unfamiliar of observers would know that PWC were not a factor in the thousands of acres of sea grasses impacted by recreational boating activity. The NPS and the EA fail to make note of this obvious fact.

The EA, in yet another remarkable leap of logic, concludes that PWC use could result in minor adverse impacts on the park’s cultural resources from possible illegal collection and vandalism. With five million visitors, only 1000 of which are PWC users based on park staff input, how could there be the slightest suggestion that PWC would be materially involved in “looting and vandalism of cultural resources.” One PWC per 5000 park visitors. One can only wonder at the store of ill-will harbored in the minds of those who prepared and approved this document.


Alternative A is the more balanced approach to regulating PWC use within the Gulf Islands NS. This alternative treats PWC like all other motorized vessels. I support Alternative A, which should be designated as the preferred alternative.


PWC have been banned from Gulf Islands NS for over two years due to reasons of inertia, and apparently subjectively negative opinions by staff or management or both.

Despite what I have pointed out as clearly biased “findings”, inaccurate and misleading statements in the EA, the NPS still acknowledges that PWC pose a lesser impact on park resources than other forms of motorized boating. If an objective and complete review of fact were available, they would clearly unmask mischaracterizations, inaccuracies, and deliberately prejudicial statements made in the EA.



The NPS should more carefully cloak themselves in the mantle of objectivity, and dismiss the shrill cries of misanthropic lock-out fanatical elements of special interest recreation groups who call for the arbitrary restriction or ban of PWC. These groups will use issues like PWC regulation as membership development tactics, and line items on resumes for grant applications. Their agendas relative to improving the NPS via PWC regulations is as flimsy as mist in the midday Florida sun. As the EA and my comments indicate, there is no reason to exclude the safe and responsible use of PWC throughout GUIS.

Sincerely,


John Donaldson
3 Hutton Center Dr. #880
Santa Ana, Ca. 92707

impulse922

As much fun as i think it would be to ride out to Ship Island, I don't think I'd like it too much when I went out ther to fish/enjoy the island, to me it would just be irritating, becuase there would be bunches of teens out there making a fool of themselves on the pwc their mommies and daddies bought them.

BiloxiGeek

I agree. But how would that be different from riding the rivers, along the coast, or the back bay? If they're being idiots I got no problem calling the sheriff and/or Coast Guard on my cell or VHF.

__________________
Mississippi Gulf Coast Personal Watercraft Club
http://www.mgcpwc.com/
/- Sinners can repent, but stupid is forever. -/

J.Donaldson

Impulse,
Not meaning the following in any personal fashion but let's look at your statement in the context of NIMBY - not in my back yard. Your statement is the exact justification that anti PWC people use EVERYWHERE in the country. I am a responsible person but those outsiders who come to my lake, river, beach should be restricted or banned.

I have been to Ship Island twice on weekends and the only PWC I saw were those in the group I was in. Consider also the Gulf Islands Nat. Seashore (GINS) includes those barrier islands at the mouth of Pensacola harbor, where on busy summer weekends hundreds if not thousands of recreational boats gather. What is the justification for a ban there? Too much boat traffic - so let's whittle that down by eliminating PWC? The NPS doesn't even have a patrol boat, so they rely on the Florida Marine Patrol or the US Coast Guard. How much sense does it make to ask the CG to enforce a ban that is based on one person's (Supt. Eubanks) prejudices? Does that improve homeland security or boating safety?

Finally, GINS has never had ANY boating restrictions prior to their current PWC ban. That raises a couple of questions. First, what possible justification did they have to completely ban PWC. Second, did they try any alternative measures before instituting a ban?

The answers?

1) None but they could speculate that they would eventually be overrun with PWC so better to ban now. [Read their PWC environment impact doc]

2) They went from no boating rules at all to a total PWC ban without a single effort at managing any issues. The reason being - THEY DIDN'T HAVE ANY ISSUES to manage.