Holgate Letter - 8/18/1999

U.S. Fish & Wildlife Service
Division of Realty
300 Westgate Center Drive
Hadley, MA 01035-9589

Attention: Alison Whitlock

The Jersey Coast Anglers Association supports the Action Alternative proposals for both the Edwin B. Forsythe (EBF) and the Cape May (CPY) refuges contained in the Jersey Coast Refuges Draft Comprehensive Conservation Plans. We do not support the No Action Alternatives proposed. It is our opinion, however, that the plans for both EBF and CPY fall far short of the goals and policies stated in the National Wildlife Refuge System Improvement Act of 1997. We are proposing changes in the Jersey Coast Refuges plans to make the plans more compatible with the Act.

The reason we can support Action Alternative for EBF is that we believe that the State of New Jersey retains control of the Mean High Water Mark land. This makes your suggested change of motor vehicle use no longer an option. The Holgate issue points out long standing criticisms of Federal Refuge planners when it comes to the use of National Wildlife Refuges by the public. Instead of following the guidelines and policies of the National Wildlife Refuge Improvement Act of 1997 regarding compatible wildlife-related public uses, this plan simply prohibits a compatible wildlife-related public use (in this case beach buggies at Holgate). This particular issue was successfully mitigated years ago and the current solution is generally accepted by all user groups including environmental groups. Federal planners have arbitrarily proposed a total closure with no reason given.

The above use of vehicles allows for access by people with disabilities. Many of the members of the JCAA who have beach vehicles use them so they can surf fish. There are no wheelchair ramps at EBF and beach vehicles provide access for our disabled Veterans and others with mobility problems.

The partial closure system, which was established 10 years ago to deal with problems related to the Endangered Species Act at Holgate, has proven to be very successful. It is generally accepted by all user groups and should be continued. In any event the area used most frequently by beach buggies is riparian land located below the high tide line and should come under the jurisdiction of the State of New Jersey rather than the Federal Government.

When complete, the two refuges will contain approximately 70,000 acres of New Jersey’s extremely valuable, and increasingly scarce, publicly owned open space. This is New Jersey, the nation’s most densely populated state, where open space is always at a premium and where there is an ever increasing demand for wildlife related recreational opportunity. In this regard it is imperative that every opportunity be taken now to provide for compatible wildlife-dependent public recreational use of the EBF & CPY Refuges based upon the policies outlined in the National Wildlife Improvement Act of 1997.

As presently written, the Jersey Coast Refuge plans are far too restrictive as it relates to compatible wildlife-dependent public recreational use. We would like to suggest a different philosophical approach by the refuge planners relative to public recreational use, allowing compatible wildlife-dependent public recreational use wherever possible together with minimal restrictions on the public only where necessary. This would be a change from the present approach, which emphasizes maximum protections with a minimum of compatible use by the public. This approach would be a big step forward in enabling the Plan to comply fully with the policy goals of the National Wildlife Refuge System Improvement Act of 1997.

At-large use at EBF and CPY by the public for such compatible wildlife-dependent uses as bird watching, upland game hunting, fishing, waterfowl hunting, trapping, environmental education, wildlife observation and wildlife photography should be permitted wherever possible. Public at-large uses of both refuges for the above activities could be greatly expanded with no negative impact on the refuges conservation missions and minimal impact on refuge managerial requirements.

Properties acquired for the National Wildlife Refuges should remain open to traditional compatible wildlife-related public recreational activities pending completion of refuge management plans, unless demonstrated negative impacts of these uses are present. The over-restrictive policy of immediately closing all acquired areas to any public use until management plans are complete has in the past resulted in refuge areas being closed for years to the public. This should not be the policy for the Jersey Coast refuges.

Wildlife Refuge Plans should be designed to provide the maximum use by the public within guidelines that protect the refuges. We believe our proposals are compatible with this philosophy and should be considered before any Federal Plans are developed or implemented.

Sincerely,