•  There are a number of changes that affect Cumberland Island’s Wilderness and Potential Wilderness in this plan.

•  No published or public data or metrics exist to evaluate potential degradation or infringement of Wilderness values at Cumberland Island National Seashore.

Bicycles and E-Bikes: Allowing bikes and e-bikes to use the Main Road certainly contrasts with the purpose and design of the Wilderness Act; however, opening administrative roads to bikes and e-bikes in designated Wilderness is an explicit violation of the Wilderness Act and a deliberate act to undermine Wilderness protections.

CUIS management should not be proceeding with any pre-decisional planning processes that considers ebike use until the NPS completes a proper rulemaking NEPA process. (see Pub. Emps. for Environmental Responsibility v. National Park Serv., Civil Action No. 19-3629 (RC), 2022 U.S. Dist. LEXIS 93204 (D.D.C. May 24, 2022)

•  The proposed plan appears to include opening all NPS administrative roads and additional trails to bikes and e-bikes.

•  This plan allows motorized boat access to Wilderness and Potential Wilderness campsites (Brick Hill, Toonahowie). 

•  While public roads are open to bicycles and e-bikes per NPS policy, no environmental analysis has been provided on e-bike use within or adjacent to the Wilderness on Cumberland Island.

The 1984 General Management Plan specifies Wilderness access Stafford; the proposed plan offers access directly by ferry to Plum Orchard. 

The Visitor Use Management Plans fails to meet NEPA requirements by providing only a no-action alternative and second alternative. 

• It included no incremental alternatives and only provided its preferred alternative, choosing to dismiss from further consideration many options that have widespread public and scientific support.

Additionally:

• The proposed plan lacks sufficient data in every aspect: research and monitoring, adaptive management techniques, implementation, operational impacts, risk analysis for the public. 

• There is no data included (or publicly available) to indicate what necessitated an increase in visitor capacity. 

• This plan does not include critical baseline information (such as how many days per year the Seashore reaches its capacity). It is unclear whether or not any environmental assessment considered this information in calculating potential capacity for proper evaluation or implementation. 

In determining whether or how to allow certain types of uses, park managers must first consider the congressional or presidential interest as expressed in the enabling legislation or proclamation. 

Cumberland Island National Seashore was established by the Act of October 23, 1972, 86 stat. 1066, Public Law 92-536, “to provide for public outdoor recreation use and enjoyment of certain significant shoreline lands and waters of the United States, and to preserve related scenic, scientific and historical values”. 

The law further states that “the Seashore shall be permanently preserved in its primitive state, and no development of the project or plan for the convenience of visitors shall be undertaken which would be incompatible with the preservation of the unique flora and fauna or the physiographic conditions now prevailing“.

The Seashore’s 1984 General Management Plan also specifies that “No concessions will be permitted on the island.” (p. 36) 

It is abundantly clear that the proposed plan does not align with the intent of the Seashore nor its management guidelines. 

Additionally:

•  Specific details are NOT provided on relevant use numbers, location, size, or potential environmental impacts from construction and/or operation of ANY of the proposed commercial operations, including an island-based retail store, kayak/canoe rentals, motorized or non-motorized boat tours, etc.

•  It does not incorporate impacts from existing commercial uses (Greyfield Inn and Stafford) for proper public or environmental evaluation.

•  A Visitor Use Management Plan is the appropriate place for the public to weigh in on any policy changes that could affect the visitor experience. 

•  A number of significant changes have already happened at the discretion  of management within the last decade, including, but not limited to:

•  Implementing bicycle rental, thus presenting it as properly authorized to visitors in this plan

•  Installation of large metal bear boxes in developed campsites at Sea  Camp and Stafford 

•  Changes in hammock policy

•  Allowing beach fires by the public

•  Changes in canine access for private boaters

•  Implementation of a cashless policy, a blatantly discriminatory practice

All of these changes have an impact on the visitor experience, and the public should have an opportunity to weigh in on them – proposing them in this plan would have been the appropriate place to evaluate changes for all user groups in a meaningful and equitable fashion. We believe management has selectively chosen to evaluate visitor use changes that promote commercial use of the Seashore.

Throughout the plan, the National Park Service arrives at unsupported conclusions that conflict or contradict their own findings of direct, indirect, and cumulative effects to species. 

It is clear that substantial development, construction of facilities, concessionaires, increased ferries, increased boat traffic, increased motorized access to the island, expanding visitor used, and more than doubling visitation will have significant impacts, especially to rare and imperiled wildlife. 

It is unacceptable to facilitate any increased visitor use within or adjacent to designated Critical Habitat for multiple species. We can also reasonably anticipate the identification of additional threatened and endangered species or critical habitats within the boundaries of Cumberland Island National Seashore, likely overlapping existing and proposed areas of use.

•  The environmental impacts of new and expanded commercial uses have not been evaluated, as required by NEPA, to assess impacts on any listed species.

•  The Environmental Assessment (Appendix C) and Biological Evaluation in (Appendix G) fail to measure and fully analyze these impacts to species and their habitats.

•  The National Park Service failed to complete a full consultation with U.S. Fish and Wildlife Service and National Marine Fisheries Service as required by Section 7(a)(1) of the Endangered Species Act. Its in-house Biological Evaluation fails to meet Section 7 Endangered Species Act requirements.

• The increase in daily visitor numbers (700) reflects only daily passenger ferry delivery. 

• There is no cap on visitation in the proposed plan. 

• The plan also suggests additional charter service, increases in recreational boat access, authorizes new commercial uses, and even a water taxi between St Marys and Fernandina – without adequate supporting details. 

The potential rezoning and residential development of nearly 90 acres (Lumar, LLC) immediately adjacent to Sea Camp on Cumberland Island is not addressed in this plan. 

• This will have a direct impact on recreational boat and vehicle use, and possible impacts on visitor services; the proposed plan lacks sufficient data for evaluation. 

Planned residential and marina developments in adjacent communities (Fernandina, FL and St Marys, GA) will have a direct impact on recreational boat use; the proposed plan lacks sufficient data for evaluation. 

• Long-term mooring permits are now allowed in Georgia waterways (based on increased demand/need); this will have a direct impact on recreational boat use; the proposed plan lacks sufficient data for evaluation. 

Impacts NOT Identified in this Plan

CUIS has recently received funding for (and has already begun) projects within the boundary of the Seashore for projects that are NOT referenced, included, or integrated into this plan for the public to consider in its contextual assessment. These projects include, but are not limited to: 

• Sea Camp Ranger Station Rehabilitation

• Sea Camp Campground Bathroom Renovation 

• Grand Ave/Main Road Grading and Repair 

• Three separate funding installments for renovation of the Grange 

• Shoreline Restoration (grant received)

• Mainland museum renovation

The potential rezoning and residential development of nearly 90 acres (Lumar, LLC) immediately adjacent to Sea Camp on Cumberland Island is not addressed in this plan. 

•  This could have a direct impact on recreational boat and vehicle use, and possible impacts on visitor services; the proposed plan lacks sufficient data for evaluation. 

Planned residential and marina developments in adjacent communities (Fernandina, FL and St Marys, GA) will have a direct impact on recreational boat use; the proposed plan lacks sufficient data for evaluation. 

• Long-term mooring permits are now allowed in Georgia waterways (based on increased demand/need); this will have a direct impact on recreational boat use; the proposed plan lacks sufficient data for evaluation. 

Impacts NOT Identified in this Plan

CUIS has recently received funding for (and has already begun) projects within the boundary of the Seashore for projects that are NOT referenced, included, or integrated into this plan for the public to consider in its contextual assessment. These projects include, but are not limited to: 

• Sea Camp Ranger Station Rehabilitation

• Sea Camp Campground Bathroom Renovation 

• Grand Ave/Main Road Grading and Repair 

• Three separate funding installments for renovation of the Grange 

• Shoreline Restoration (grant received)

• Mainland museum renovation

No funding has yet been secured to support these changes. 

It is well-documented that the NPS is experiencing issues staffing, funding, and housing the types of diverse experts needed to employ adaptive management strategies effectively and accurately across our entire park and Wilderness system — Cumberland Island will be no exception.

Note: CUIS has recently received funding for (and has already begun) projects within the boundary of the Seashore for projects that are NOT referenced, included, or integrated into this plan for the public to consider in its contextual assessment. These projects include, but are not limited to: 

1. Sea Camp Ranger Station Rehabilitation 
2. Sea Camp Campground Bathroom Renovation
3. Grand Ave/Main Road Grading and Repair
4. Three separate funding installments for renovation of the Grange 
5. Shoreline Restoration
6. Mainland museum renovation

Feral horses were excluded from consideration in the proposed Visitor Use Management Plan. We believe the safety implications of more than 700 visitors per day and potential risks associated with the island’s feral horse population should absolutely be evaluated.

The horses’ documented and ongoing degradation of island ecosystems were not considered in conjunction with increased human impact in any environmental analysis.

The proposed plan does not detail how “adaptive visitor management strategies” will realistically be employed by the NPS, nor does it address the unique challenges facing implementation at this unit.

The proposed plan does not include any proposed or established measurement guidelines to employ an adaptive management strategy for evaluation. 

It also does not identify potential effects on CUIS operations, such as: 

• Increased requirements for on-island staff for maintenance, vehicles, ranger patrols, services, resource monitoring, mitigation, interpretation, administrative oversight, and facilities and infrastructure. 

• These operational changes will directly impact every visitor experience, particularly given the limited transportation routes available for staff, volunteers, and visitors. 

• There is no detail on how adaptive management techniques would be employed, or the ways in which that will potentially impact the visitor experience.

It is widely-known and well-documented that the NPS is experiencing issues staffing, funding, and housing the types of diverse experts needed to employ adaptive management strategies effectively and accurately across our entire system — Cumberland Island will be no exception.

There is insufficient monitoring, data, or mitigation details included in this plan to properly minimize and address the increased risks related to the introduction and spread of invasive species within the Seashore, despite the Plan acknowledging that increased visitors, hikers, bikers, and boaters will increase potential spread and/or introduce new species.

•  The proposed Visitor Use Management and Environmental Assessment plan adds more visitors, additional infrastructure, increases waste and withdrawal, and has the potential to negatively affect the water quality available to visitors and wildlife. This plan lacks proper analysis of potential impacts to island resources. 

Insufficient water quality testing in primary visitor access areas, Wilderness, and Potential Wilderness have all been identified as existing Seashore management concerns. More details coming soon.

•  Several rare, imperiled, and federally-listed species depend on the island’s freshwater resources, including the wood stork (Mycteria americana) and gopher tortoise (Gopherus polyphemus). The Carolina gopher frog (Lithobates capito capito) and tricolored bat (Perimyotis subflavus) are also freshwater-dependent species proposed by the U.S. Fish and Wildlife Service for federal Endangered Species Act protections

Wild Cumberland understands that Americans are seeking increasingly more remote and secluded experiences – and places like Cumberland Island National Seashore and Wilderness will face an ever-increasing demand for the unique opportunities it provides for transformation, respite, and rejuvenation. 

There are no details in this plan about ways the Seashore intends to facilitate use or improve access by historically-marginalized groups by increasing visitor numbers. It simply facilitates more access to the same demographic of users.

Without significant changes to current Seashore fee structure, concessionaire fees, and/or other initiatives, the demographics of the park will remain more of the same. 

• The proposed plan acknowledges the likelihood that ferry costs may actually increase as the concessionaire adjusts for increased operating costs. 

• The plan states, “Proposed development in St. Marys and Camden Spaceport may increase visitation to St. Marys and develop the town into a primary tourist destination. As a result, the town may need to develop additional accommodations such as lodging and dining that could provide economic benefit to the gateway community and local stakeholders. At the same time, this increase in development and potential growth of the area may lead to changes in local economics that could increase associated prices of traveling and the ferry prices. Consequently, the socioeconomic barriers to visitation may increase or remain the same.”

• An increased offering of commercial services is not only contrary to the Seashore’s intent, it creates additional barriers for some visitors.

• This plan facilitates increased access by recreational boaters, but they are not the users that have historically been excluded from access to our public lands. 

• We have received numerous questions about how the Seashore would facilitate parking for up to 700 visitors per day and how that might affect visitor access and the local community.

• Provide daily discounted admission for local residents, first-time visitors, families with young children, and college students.

• Increase interpretation staff vs law enforcement staff 

• Allow a portion of reservations to be made more than six (6) months in advance to accommodate planning, travel, and other needs specific to the experience this resource requires. 

• Identify and host inclusive public lands events and programming on park facilities on the mainland. 

• Provide service opportunities and discounted / free admission for participating members of the public or service organizations (trash pickup, etc) 

• Revisit the “no cash accepted” policy instituted by CUIS in July of 2022.

• Partner with local libraries to provide free backpacks for check out, containing park passes, maps, native wildlife brochures, interpretation materials, and binoculars.

• Establish an official “Friends” group for the park, who can commit to fundraising for programs that will actively work to increase access for historically-marginalized populations, and facilitate community and stakeholder involvement both on and offsite. Note: Cumberland Island National Seashore is only one of two National Seashores without an official “Friends” group.

• Prioritize initiatives to offset some of the costs of outdoor recreation for low-income visitors, including equipment costs, entrance fees, and travel costs. This group would work in cooperation with the NPS to fund projects and programs that protect, preserve, and enhance Cumberland Island National Seashore. It would also help to source volunteers and advance educational programs and research projects. 

There are no details in this plan about ways the Seashore intends to facilitate use or improve access by historically-marginalized groups by increasing visitor numbers. It simply facilitates more access to the same demographic of users.

Without significant changes to current Seashore fee structure, concessionaire fees, and/or other initiatives, the demographics of the park will remain more of the same. 

• The proposed plan acknowledges the likelihood that ferry costs may actually increase as the concessionaire adjusts for increased operating costs. 

• The plan states, “Proposed development in St. Marys and Camden Spaceport may increase visitation to St. Marys and develop the town into a primary tourist destination. As a result, the town may need to develop additional accommodations such as lodging and dining that could provide economic benefit to the gateway community and local stakeholders. At the same time, this increase in development and potential growth of the area may lead to changes in local economics that could increase associated prices of traveling and the ferry prices. Consequently, the socioeconomic barriers to visitation may increase or remain the same.”

• An increased offering of commercial services is not only contrary to the Seashore’s intent, it creates additional barriers for some visitors.

• This plan facilitates increased access by recreational boaters, but they are not the users that have historically been excluded from access to our public lands. 

• We have received numerous questions about how the Seashore would facilitate parking for up to 700 visitors per day and how that might affect visitor access and the local community.

Wild Cumberland believes there are numerous management strategies that could, and should, be considered in conjunction with any proposed Visitor Use Management Plan, including:

• Provide access to the NPS Visitor Center in St Marys before and after ferry hours; this has been a consistent visitor request for decades.

• Develop a robust education/outreach program targeted to recreational boaters and anglers. These users are unable to go through proper park interpretation based on their means of travel and originate from more than one state at all times. 

• Facilitate Citizen Science opportunities that engage the community and stakeholders in a way that is meaningful to resource protection. 

• Ensure there is a park ranger present on every boat transporting visitors to and from the island. 

• Consider an overall reduction in on-island vehicular speed limits due to an increase in vehicular (South End Shuttle and residential), foot, and bike traffic to ensure wildlife protection and visitor safety. 

• Facilitate the ability for a concessionaire to establish and run a store on the mainland with extended hours to meet the demand of increased recreational boaters and an extended ferry schedule. 

• Position the Sweetwater Lakes Wilderness campsite slightly further north, near Cedar Dock, to reduce adverse impacts and degradation to delicate freshwater wetlands and numerous resident and migratory species.

• Provide a timeline for the development, approval, and implementation of an Air Transportation Management Plan, because measures to address commercial use of public airspace, infringement upon Wilderness character, and/or impacts on the visitor experience are not addressed in this plan. Low-flying aircraft were identified as an issue the park needed to actively address in its original 1984 General Management Plan; to date, no data is being tracked that would facilitate the development of this plan.