Monday, August 15, 2011

FNPS Position State on Park Development

Letter outlining the official position of the Florida Native Plant Society regarding the development of campgrounds in state parks.

July 18, 2010

Bob Ballard., Chairman
Environmental and Restoration Council
Douglas Building, Room 1021D
3900 Commonwealth Boulevard, M.S. 44
Tallahassee, Florida 32399-3000

SUBJECT: ARC Review of Proposal to Develop Campgrounds at 56 State Parks

Dear Chairman Ballard:

The Florida Native Plant Society (Society) was pleased by the recent decision to forgo development of a family campground at Honeymoon Island State Park.  Although camping is a compatible recreational activity in many of our State Parks and provides an outstanding way for the public to enjoy these special lands, any decisions about the expansion of public uses or development of additional facilities must be carefully weighed against the potential for such uses or development to degrade the natural resources the State Parks are mandated to protect.

The Society believes the combination of relatively small size (less than 500 acres of upland habitat), extremely high public visitation rates, and presence of rare and sensitive natural habitats render Honeymoon Island unsuitable for campground development.  We are also concerned about the ability of the other 3 parks currently under consideration to withstand the impacts that would result from campground development.

The decision by Governor Scott and Secretary Vinyard to end the expedited review of these proposals was an important step towards ensuring that a comprehensive assessment of potential environmental impacts and public concerns will precede any final decisions. The facilities required to accommodate family camping, as described by your staff’s site-specific proposals, are extensive and reflect the intensity of this form of camping activity.  We ask the Acquisition and Restoration Council (ARC) to adopt a posture on this issue that places resource protection concerns above acquiescence to pressure to open any parks to campground development that would compromise protection of either the natural resources or the recreational experience of current users.

We are also concerned by ARC’s apparent position that any such facilities could be developed and managed by private interests who will certainly place a higher priority on profits than on resource protection.  During these difficult economic times, the state might well be looking for ways to generate revenue; however, our State Parks are a public treasure held in trust by DEP for the future enjoyment of all Floridians. They should not be perceived as cash cows, nor be expected to earn a profit.  It is difficult to conceive of an approach to allowing private development and management of campgrounds in our State Parks that would be supported by the Society.  Who better to develop and manage such facilities than the DEP staff who share our love of these magnificent parks and have demonstrated a superlative ability to be good stewards?

We would also like to document some of our concerns specific to the proposed development of family campgrounds at Fanning Springs, De Leon Springs and Wakulla Springs.  The spring and spring run systems that serve as the centerpieces of those State Parks have already been seriously degraded by declines in water quality.  Nitrate levels exceeding 1mg/liter have been documented in the spring discharge emanating from all three parks.  These nutrient levels exceed historic background levels by 100-fold and more, and are responsible for declining conditions in the plant communities and habitat conditions of the spring runs and downstream waterbodies.   Although Fanning Springs and Wakulla Springs are served by sewage treatment systems, De Leon Springs is not.  Non-point inputs from campgrounds would serve as another potential input of pollutants.  We ask that ARC show a greater interest in the implementation of actions that would improve water quality within these systems than in recreational development that could lead to further degradation.

Like Honeymoon Island, Fanning Springs (198 acres) and De Leon Springs (606 acres) are relatively small parks.  The campgrounds proposed for those sites would require conversion of approximately 10 percent of the total park land area in order to accommodate one of the most intensive recreational uses that can be accommodated by a State Park.  The scale of the campgrounds, relative to the land area of the parks, would certainly overwhelm their natural character and degrade the recreational experience of other users.

Most of the proposed development appears directed towards sections of the parks that were altered by previous human activities, e.g., logging at Wakulla Springs that pre-dated establishment of the park, and we concede that altered sites are preferable to undisturbed sites for the development of park facilities.  However, we also assert that a higher priority should be placed on restoring, rather than developing, altered sites within State Parks. If the State of Florida won’t pursue a management strategy in our State Parks that places resource protection and restoration above recreational development, then where will such conservation take place?

Again, the Society appreciates the recent decision to end the expedited review of campground proposals for the State Parks and we hope that decision reflects a more circumspect attitude towards the development of family campgrounds.  We ask you to consider the concerns we have enumerated above and look forward to reviewing any additional proposals for such facilities.  Please let me know if the Society can be of any additional assistance.

Respectfully,

Steven Woodmansee, President
Florida Native Plant Society

Cc:    Governor Rick Scott
     Secretary Herschel T. Vinyard, Jr, FDEP
    Jim Farr, Staff Director and Environmental Manager, FDEP ARC
    Al Gregory, Office of Park Planning, FDEP

Florida Native Plant Society
Post Office Box 278, Melbourne, FL  32902
Telephone:  786.488.3101

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