ORV Letter to Members

1

Problem

Night driving ban (9:00 pm to 6:00 am). Table pp. 100

Needed Modifications

a. Allow driving on back road anytime.
b. Allow access to beach near open ramps but limit speed and range to a few hundred yards in each direction from the ramp entrance.
c. Allow parking, fishing and sleeping anywhere on open beach areas in accordance with current regulations. Vehicle movement permitted to evade flood tides or other emergencies.

Rationale

Night driving does not need to be banned because of the option to use the back road. There is no scientific evidence presented that passing vehicles off the beach with headlights on or ephemeral lighting affects turtle or bird nesting outcomes.

2

Problem

30′ overall vehicle length limit, trailer length limits. pp. 60

Needed Modification

Allow length limit currently imposed by ferry concessionaire = 40′.

Rationale

The limit on vehicle length is arbitrary. With an improved back road, congestion issues and maneuverability will be facilitated.

3

Problem

Driver education certificate and annual renewal. pp. 56

Needed Modifications

a. Allow on-line and multi-location issuance (CALO and Ferry Offices)
b. Allow multi-year certificate renewal coincident with driver license renewal

Rationale

An annual certificate is a waste of NPS resources and unnecessary. The NC Dept. of Motor Vehicles has determined that driver, passenger and pedestrian safety is adequately secured by multi-year operator licenses.

4

Problem

Vehicle permit limit of a) 3000 for South Core and 2500 for North Core and b) cost. pp. 63

Needed Modifications

a. Single permit allows access to both islands.
b. We recommend no permit limits. CALO has built-in and natural barriers keeping vehicle numbers on the islands to reasonable limits. Limiting permits will pose many logistical issues that create more problems than solutions. Permits should be available on-line, by phone, mail, at Harkers Island or at the islands.
c. The NPS is proposing $80 for 10 day and $150 for annual vehicle permits. We think this is high and recommend $50 for the short term permit (10 days). NPS should consider waiving the permit fee in cases of financial hardship and other special situations.

Rationale

a. Many visitors use both North and South Core and 2 permits could be a financial burden.
b. Realistically, the Park can’t have more operating vehicles than a combination of ferry service capacity and ORV’s in LT parking. Limiting permits does not correlate with the number of vehicles on the beach at any given time. A superior control method already exists: controlling beach access in sensitive areas with ramp to ramp closures. The annual DIFF fishing tournament represents the usage highpoint and there is not an

5

Problem

Cost of Alternative C is borne by ORV permit holders, not other Park users.

Needed Modification

The Park Service projects $454,500 in increased costs for Alternative C, but these are not all attributable to ORV users, therefore pedestrian users should share in them. We recommend a $5 to $10 fee for non-ORV park users per visit. The public should have complete visibility on expenditures and revenues related to Alt. C.

Rationale

Shelters, trash collection, resource protection, interpretation and education, pedestrian facilities and maintenance, and predator control are not costs exclusively attributable to ORV users. Other Park users should bear some of the increased costs that the NPS wants ORV users alone to bear.

6

Problem

Seasonal reduction in long term parking spaces (from 150 to 90 during the summer season), moving parking lot to the north end of the Great Island cabins and away from dock. pp. 60

Needed Modification

Recommend no reduction in number of spaces. Possible division of current lot into two lots, new one behind ranger station to shield parking from cabins.

Rationale

The seeming reason for moving the Great Island LT parking lot is aesthetic, not managerial or environmental. The lot needs to remain proximate to the ferry dock. Moving the LT lot as proposed, creates a hardship for people with physical or mobility issues when retrieving vehicles.

7

Problem

Creation of new (1.9 miles) pedestrian-only area in front of Great Island cabins and Codd Creek (.8 miles at ramp 35a and b) from Memorial Day through Labor Day and expansion of lighthouse pedestrian only area by .7 miles from ramp 41a to ramp 42b year round for a total permanent closure of 1.4 miles. pp. 62

Needed Modifications

a. The Great Island cabin area does not have adequate road space to permit all vehicular traffic as well pedestrian foot traffic to safely use the back road.
b. Beach driving is necessary for safe travel past the cabins and for beach access for elderly and disabled so they can readily access restroom and bath facilities.

c. Keep ramps at Great Island cabins and 41a open.

Rationale

a. There is no room on the ocean side of the cabins to widen the road to accommodate the increased traffic caused by the pedestrian-only beach closure, without cutting into the dune area.
b. Grandma may have some difficulty hoofing from the cabin to the beach area, then to

8

Problem

Ban on high performance sport models and 2 stroke ATV’s and UTV’s phased in over 5 years. pp. 59

Needed Modification

No ban

Rationale

So long as these vehicles are operating in accordance with the Park rules, they pose no special or unique environmental threat.

9

Problem

Ramp Spacing pp. 58 & 59

Needed Modification

The Alt C plan calls for up to 5 additional ramps on South Core Banks. While this is a positive step, we need to have as many as 9 new ramps to deal with the likelihood of increasing ramp to ramp closures due to American Oyster Catcher (AMOY) nesting, turtle nesting and plovers. Or, a less permanent solution is the creation of access at temporary ramps where feasible.

Rationale

Ramps, once opened, require minimal maintenance and will allow greater beach access given the current spacing of approximately 1 mile. Adding 8 new ramps to the existing proposal is a one-time cost but could add up to 4 miles of additional miles of open beach during nesting periods. We think a proper spacing of ramps is 1⁄2 mile given the required breeding buffers for listed species.

10

Problem

The cost to implement Alt C is $454,500 above the “no action plan” with the largest increase ($180,000) allocated toward enforcement. pp 526

Needed Modification

Shift spending from enforcement to resource management.

Rationale

With higher budgets for education, including the driver certificate, the number of enforcement officers should not need a disproportionate increase. “Adaptive Management” is dependent upon accurate species monitoring and data collection. The enforcement money is better spent on improved and clearer markers, signage, and resource protection to achieve “Indicator Species” goals and protect endangered species with predator excluders, monitoring and relocation as needed. In addition, CALO has lost monitoring manpower with no participation from NCSU for 2014. Adequate numbers of properly trained monitors are the key to accurately measure goals under Adaptive Management. Findings by NCSU on AMOY nesting conclude that uncertainties about the causes of nesting failures can be reduced by improved monitoring, leading to improved decisions.

Needed Modifications

a. Recommend selecting a basket of indicator species where performance is measured as a whole against goals to determine NPS actions. This methodology better reflects the NPS wildlife protection mandate.
b. For consistency, all Indicators should have a 10 % cushion below the goal before a minor impact is triggered. The indicator target for “nest survival” exceeds the 12 year median. (see link to DIFF website on “Indicator Species”)

c. Step 1 should include the same exculpatory language concerning “hurricanes, or other strong storms, predators, or other natural conditions not tied to impacts from visitor use” as step 2.

Rationale

a. Putting all eggs in one measurement basket has statistical risks that a composite of measurements does not. It is accepted that species populations rise and fall cyclically, and is not necessarily the result of human causality.
b. The indicator target exceeds the 12 year median making the goal a stretch. Furthermore, a minor impact should not be triggered unless the indicator falls some margin below the target. We recommend 10% so that minor deviations do not trigger an impact level.

c. Step 1 should provide the same flexibility in management actions as step 2, if indicators are triggered due to natural conditions unrelated to visitor use.