Mr Thomas Bonneti July 11, 2014 U.S. Fish and Wildlife Service 300 Westgate Center Drive Hadley,MA 01035 RE; Chincoteague NWR CCP Dear Mr. Bonetti, Please allow me to thank you for an opportunity to comment on this issue. But first let me to say a Special Thanks for allowing my family and me to spend the best decade of my life(1978-the late 80s) at this wonderful area known as The Hook. It truly was the experience of a lifetime. During that time I spent approximately 20+ hours there weekly and am quite knowledgeable of the area and the happenings over the years. I was present with perhaps the best DOI person I have ever had the pleasure to know and the most knowledgeable person of the area. His name is Mel Olsen and was the NPS Southern District Chief Ranger. I was standing next to him in July of 1984 on the peak of a dune watching the incoming tide. He told me that he didnt think we were going to make it. Within minutes the Ocean breached the dunes and the beginning of the washover area was born. Has anyone from FWS asked for his input into this CCP? Over the ensuing years a great many changes have occurred. First was restricting areas of the Hook area to nesting areas. Next came closure of the Hook entirely from March 15th to September 1st annually. I have no problem with protecting an Endangered Species as long as it is completed in thoughtful process. In fact I would greatly support such an action. I would like to commend FWS for their compilation of this CCP as it must have taken an extensive labor, intensive time consuming process. I staunchly support Alternative B with a few caveats. First of which is the time constraints for closure of the OSV zone. Closure should not be time specific, but with the time nests have fledged. This time seems to go from 25-33 days. After a great amount time spent researching Ocean front areas from Maine to North Carolina, almost ALL AREAS are reopened after nests have fledged. FWS seems to have adopted a close the areas available for fishing access until Sept 1st( I have seen dates ranging in the CCP from August 31st, Sept 1st or now proposing Sep.15th.) This flies in face of one FWS primary objectives of providing Fishing access if compatible with the resource. I have been told by FWS officials that extending the date of closure to Sept 15th is because of a study that says all migratory birds have left the area. While I am in opposition to this time extension of Sept 15th, it is because the beginning of the PRIME FISHING TIME while it begins usually on or about Sept 1st or earlier This prime fishing time actually occurs when finger mullet appear in the surf. Closure of fishing availability (OSV or walk on) should be based on the time the birds have fledged rather than something time specific. If a nest has fledged, the area should be opened immediately to the next nest in conflict. This area can and should remain open until a conflict with another nest closer than 200 hundred meters is encountered. This can be accomplished with minimal labor while allowing FWS to meet one of its PRIMARY OBJECTIVES of allowing fishing in these areas when compatible with the resource. The opening of !/2 mile south of the re-located to OSV use it a noble gesture, I would request that the area be open should be extended south the of Overwash area and be subject to closures if the presence of nesting plovers if encountered. If these nests are fledged the area should be re-opened immediately. The OSV limit should remain at 18. Vehicle limits presently in use were done under NO STUDY,but the opinion of The Assateague Mobile Sportfishermens Association and agreed to by at the NPS Supt Tom Norris in the mid 60s. During a recent closure on the Md end of Assateague only 1.1 kilometers of beach were open. The vehicle limit was still 145 since the vehicle limit was established by AMSA and agreed to by NPS. I really find this practice questionable. Surely,a vehicle limit of18 would still leave nearly150 between vehicles even if nesting sites were found in the area south of the new OSV area. While I am not sure why the residents of Chincoteague were mostly in favor of Alternative A, I imagine they felt somewhat left out of the input decision.(Looking through the CCP I know they were invited to participate early on in this planning process). I think perhaps they thought they should be included in the integral planning of each aspect of the process. I think perhaps a good line of communication could correct this situation. One last thing in this process, in conversation with FWS officials I was informed that to the best of their knowledge NO CONSIDERATION was given to opening the area North of the proposed re-located beach to OSV access. While I can tell you that opening the area north could kill two bird(poor choice of words) with one stone. It could allow FWS to close the HOOK area permanently while at the same time allowing FWS to conform to Objective6.2 Fishing and OSV Use. According to a CNWR Plover nesting report dated June 27,2014 there was only 1 nest present in the Wild Beach and it was abandoned. Again this is not my first choice as I stated earlier I am Hooked on the Hook I will enclose in my written response an EXELLENT article about how NPS is going about protecting the Plover on the Md end of Assateague. Im sure FWS could accomplish the same results and at the same time accomplish one of its primary objective of promoting Fishing when compatible with the resource. Again let me thank you for the opportunity to comment. This comment really is not for me as Ive had my time on the HOOK, but for my children and grandchildren hoping they may enjoy this magnificent area as well. This comment will be sent in and is from a long time member of AMSA. Please get involved and send in your comments also.
Posted on: Mon, 14 Jul 2014 02:05:52 +0000
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