Georgia Audubon Comments Regarding Cumberland Island National Seashore Proposed Visitor Use Management Plan

​December 27, 2022
 
Superintendent Gary Ingram
Cumberland Island National Seashore
101 Wheeler Street
St. Marys, Georgia 31558
 
Submitted via online portal
 
Re: Cumberland Island National Seashore Proposed Visitor Use Management Plan & Environmental Assessment (2022)
 
Dear Superintendent Ingram and the Planning Team:
 
Thank you for the opportunity to comment on the Visitor Use Management Plan for Cumberland Island National Seashore and Wilderness. We are writing to you to share our concerns about the proposed Visitor Use Management Plan (VUMP) for Cumberland Island and its potentially devastating impacts for birds.
 
Georgia Audubon’s mission is to build places where birds and people thrive. We fulfill our mission through education, conservation, and community engagement. With over 2,400 chapter members and more than 5,000 National Audubon Society members across the state, Georgia Audubon represents a broad constituency united by a desire to protect birds and other wildlife. Our constituents include coastal residents, frequent visitors, and concerned citizens who understand the significance of the natural beaches, salt marshes, and maritime forest to the more than 250 species of birds that winter, breed, migrate through, or live year-round on Cumberland Island and surrounding areas. Georgia Audubon is submitting the following comments on behalf of members from across Georgia.
 
Cumberland Island is home to pristine maritime forests, undeveloped beaches, and extensive salt marshes, and supports a rich biodiversity of wildlife and plants. These habitats are crucial to birds because of their natural and pristine state. Cumberland is a hotspot for migratory birds; being Georgia’s southernmost barrier island, it is tremendously important stopover for thousands of birds, like the Blackpoll Warbler, Red Knot, and Peregrine Falcon, where they first make landfall after endless hours of flight or fuel up before their long open water journey back to South America. 
 
Cumberland Island is also an important breeding ground in the spring and summer for many species of birds, including the threatened Least Tern and Wilson’s Plover. During the winter, Cumberland provides exceptional wintering grounds for thousands of shorebirds, sparrows, and Bald Eagles.
 
Georgia Audubon is asking the National Park Service to conduct a comprehensive Environmental Impact Statement to gain a full understanding of how both state- and federally-listed species will be impacted by the proposed increased use of Cumberland Island. The assessment in the current plan is incomplete and fails to capture the harms and potential adverse effects to state- and federally-listed bird species.
 
Our specific concerns with the FAA Environmental Impact Statement (EIS) as they relate to avian life are as follows:
 

• The Piping Plover is a federally-listed threatened shorebird that depends on the undeveloped beaches of Cumberland Island for foraging and roosting habitat during the winter and in migration. The northern, eastern, and southern shore of Cumberland Island— including 1,500 inland feet of dune and interdune habitat—has been designated critical habitat for the piping plover. The VUMP proposes construction of a motorized access dock and development, including two pavilions, in habitat that is critical for Piping Plovers. In addition, proposed  increases in visitation, use of bicycles and e-bikes, hiking trails, and motorized access that will be difficult to monitor and control will likely lead to SUBSTANTIAL disturbance of critical Piping Plover roosting and foraging habitat. The VUMP states that the Plan “may affect but is not likely to adversely affect” Piping Plovers. However, this finding is inconsistent with the VUMP’s own findings and not supported by evidence. The Plan’s proposed construction and development will result in take of federally listed Piping Plovers and adversely modify their designated critical habitat.
• Red Knots are a federally listed threatened species that complete one of the world’s longest distance migrations, traveling up to 19,000 miles round trip between wintering grounds and their summer habitat. Cumberland Island is a critical stop for these birds to rest and refuel on their long-distance journeys each year. Without adequate food resources, Red Knots will die and fail to complete their migration to the breeding grounds. The proposed motorized access dock and development as well as the dock and campsite at Beech Creek will substantially increase visitation at the South end of Cumberland Island. The increased visitation and access via bicycles, e-bikes and motorized vehicles will adversely affect Red Knot populations. A vague environmental protection zone in no way offsets the impacts of the proposed developments and increased motorized access to the south end. Similarly, a dog-free zone near the south end motorboat dock and development will not compensate for the massive increases in motorized boat access and human use of the south end. The Plan’s proposed construction and development will result in take of federally listed Red Knots and adversely modify the habitat on which they depend for their long migrations.
• The status of many nesting species (Willets, Wilson's Plovers, Least Tern, Killdeer, Gull-billed Tern) remains undetermined after a resurgence in coyote predation on the island. The VUMP fails to address the current status of vulnerable or threatened bird species or to address potential impacts of increased foot traffic and recreation.
• Increased foot traffic and recreational activities on South End Beach would likely have adverse impacts on beach-nesting birds. The "vessel landing zone" on South End Beach would result in a loss of beach-nesting habitat as well as an increase in foot traffic and increased potential for unregulated recreational activities that would have further impact beyond this zone.  Additionally, the monitoring that would be required to enforce the closure area on South End Beach designated in this plan would be difficult to enforce due to remote access.
• An increase in visitation to Nightingale beach would disturb beach-nesting birds. A correlated increase in trash would have a high probability of attracting more scavengers to nesting habitat.
• In addition, Georgia Audubon is concerned about potential disturbance by the increased visitation, motorized access, and proposed new trails and facilities on a number of other species, including Wood Storks, Bald Eagles, Least Terns, American Oystercatchers, and Wilson’s Plovers.
• The provisions in the VUMP will significantly increase visitors to the island, especially to the south end, and does not set any cap on visitation. Also, private and commercial use will increase with two new marinas, one in St. Mary’s and a second in Fernandina, along with a corresponding increase in recreational boat use and cruise ship traffic. The VUMP does not assess impact from increased visitation that exceeds their estimated numbers.
• The proposed VUMP fails to adequately address impacts to avian life as required by the National Environmental Policy Act (NEPA) and the Endangered Species Act. Georgia Audubon strongly encourages the National Park Service to conduct a full Environmental Impact Statement before moving forward with any portion of the proposed Visitor Use Management Plan.

 
Thank you for your consideration, and please do not hesitate to reach out to me by email at Jared.Teutch@georgiaaudubon.org or by phone at 678-973-2437 with any questions or comments.
 
Sincerely,

Jared Teutsch
Executive Director