Personal comments of Jono Miller re:
Myakka River State Park Draft Unit Management Plan
March 14, 2017 version firstname.lastname@example.org
There is a lot that should be included in the plan that is simply missing.
Missing UMP Trend Content: I don’t see how it can be possible to plan for the next decade without retrospective analysis of the last decade (or in this case, the last 13 years since the UMP update is late). There is no trend analysis of recent historic park data. This includes no analysis of needed park staffing levels. The park had the same employee FTE (Full Time Equivalents) in 2013 as it did in 2004, even though attendance doubled from 260,000 to 520,000. That's not sustainable (even fewer FTEs now). Table 7 (Page 1 of 5) shows $16,000 over ten years for administrative support, but there is no increase shown in park staff. I’ve requested from Park Manager Steve Giguere the following data: For the last ten years, by year: Burn targets versus Actual acres burned, Park attendance, Park staffing levels (FTE), Volunteer numbers, Volunteer hours, Cost of contracted services, Park Income, and cost to operate park. These and other relevant data should be included, ideally in graphic form near the front of the UMP.
Missing UMP Carrying Capacity Analysis: No transparency on how a park carrying capacity of 4,002 users per day was generated. That is roughly four times the daily average. How does the park function (or not function) during peak load days? Show your work. Who is driving the demand to increase visitation by over 50%? ( Page 121) more visitors. UMP calls for increasing recreational carrying capacity by 660 users per day in some places and 220 in others. Since the current daily average is around 1,000, this would be a major increase with no comparable increase in support staff.
Missing UMP Scenic Consideration: No guidelines regarding aesthetic experience for visitors on Park Drive or paddling on the Wild & Scenic River. More than 13 miles of the State-designated Wild and Scenic River flow through the Park, but there are no aspirational goals for the paddling user experience or acknowledgement of the river values listed in the adopted management plan. Instead a variety of new facilities visible from the River are being proposed: Upper Myakka Lake Viewing Platform, vessel launch area (for staff) in the Wilderness Area, & pedestrian boardwalks. And what about that hideous dumpster in plain view of the river at the Upper Lake? That really should be relocated.
In addition to missing information there is a lot of problematic wording.
Implications of Single Use Determination (Page 1) The current designation of the Park states At Myakka River State Park, public outdoor recreation and conservation is the designated single use of the property. The new draft would change that to read: Myakka River State Park is designated single-use in accordance with 253.034(2)a F.S. to provide public outdoor recreation and other park-related uses. Consequently the relevant section of 253.034 is not a, but b. which reads, in part, Single use ” means management for one particular purpose to the exclusion of all other purposes, except that the using entity shall have the option of including in its management program compatible secondary purposes which will not detract from or interfere with the primary management purpose”. So secondary purposes are optional for single use.
Section 5 states “Plans for managed areas larger than 1,000 acres shall contain an analysis of the multiple-use potential of the property which includes the potential of the property to generate revenues to enhance the management of the property”. So It does not say some revenue sources have to be found --- only that the analysis be done.
Compatible Secondary Management Purposes (Page 7) “For this park, it was determined that timber harvesting, fuel and stump harvesting, and palm or palmetto frond harvesting could be accommodated in a manner that would be compatible and not interfere with the primary purpose of resource-based outdoor recreation and conservation. These compatible secondary management purposes are addressed in the Resource Management Component of the plan.”
The revealing use of the passive voice (“it was determined”) serves to shift attention from who was making the determination, based on what analysis, to the decision. I discuss stumping and frond harvesting later, so let’s focus on the timber.
“An area of small offsite pine trees was identified with potential for removal in when the pines mature to a marketable size in ten years.”DRP, aided by the Florida Forest Service, is advocating a management practice that reveals the pretzel logic involved in rationalizing waiting. In Myakka River State Park North Florida Slash Pine is an invasive exotic species. It is axiomatic that the first rule with any invasive species is to prevent it from reproducing – kill it before it spreads. If this were any other invasive exotic: water hyacinth, old world climbing fern, cogon grass, etc. the main focus after initial control would be follow-up to snuff out any remnants that could produce viable propagules.
But because this happens to involve pine trees, the sound management practice gets stood on its head, leading to a “determination” to wait eight to ten years in order for the seedling pines to become more merchantable (and more fecund) – thus revealing that DRP is deliberately advocating that revenue generation take precedence over sound management. This is precisely the practice that is feared. If it were a single instance, it might be written off as an anomaly.
But this is actually the third instance of revenue generation (or in-kind services) being given priority over sound management in Myakka River State Park. The specter of cattle leasing in the Myakka Prairie unit in 2015 was the first inkling that DRP had embarked on a new pecuniary approach to our Parks. This unwarranted, unappealing directive from Tallahassee was remarkably difficult to counter, despite that fact that local cattlemen saw it made no sense.
Then there is the inexplicable and unattributed “determination” that harvesting palm fronds was somehow congruent with reaching sound management objectives. I discuss this elsewhere, but the proposed practice should be viewed as prima facie evidence that revenue generation was taking precedence over sound management.
As shown on the following page, the second or third generation pines of Zone 01-B are the progeny of pines that have already left the park, and for which the state has already been paid. Elvis has left the building. The current practice of benign neglect has resulted in an ongoing coniferous calamity – perpetuating pines that should be eliminated. Sound management dictates that DRP and FFS stop the revolving door of allowing NFSP to reach reproductive age in Management Unit 01-B.
So the Myakka UMP could say: We looked at stumps and the impacts of stumping outweigh benefits, and we looked at the sale of palm fronds (see attached Palm or Palmetto Frond Harvesting), and that made even less sense. We then looked at the meager area of North Florida Slash Pines, and, taking into account the risk of seed dispersal while waiting another 8-10 years until the trees are merchantable, we decided the potential marginal income was outweighed by the risk of these trees spreading. Therefore, we did the required analysis and, for Myakka Park, which has already removed the vast majority of any restoration-related vegetation with any noticeable street value, concluded that there were no practicable revenue sources associated with restoration efforts.
Stumping According to the former Conservation Chair for the Manatee Sarasota Group of the sierra Club, Bill Lewis “The pine stumps are a non-renewable natural and cultural resource which provide significant wildlife value. The adverse impacts of the stumping operations have long term adverse ecological consequences. At both Jonathan Dickinson and Lake Kissimmee State Parks the harvest of stumps was proposed and denied due to the harmful effects.”
See stumping photos on following page.
Inconsistent Activities (Page 7) “Uses such as, water resource development projects, water supply projects, stormwater management projects, linear facilities and sustainable agriculture and forestry (other than those forest management activities specifically identified in this plan) are not consistent with this plan or the management purposes of the park.” This is welcomed language. Use of lead shot is not consistent with FPS goal of conserving natural values because of the devastating effects on wildlife that consume shotgun pellets. Please add hunting to the enumerated activities that are not consistent.
Secondary Use Confusion (Page 7) Statutory language related to “Secondary uses” is very problematic. Selling vegetation left over from legitimate management/restoration activities should not be considered a use any more than selling an annual pass is a use, or patching the Park Drive is a use. The Division of Recreation and Parks manages the park, it doesn’t use it. It is the public that uses the park. That’s why we have terms like day use, or user fee. Camping is a use. Paddling is a use. Birdwatching is a use. Getting rid of North Florida Slash Pine is not a use – it is a form of management. When the park contracts to get rid of stuff it either pays (take away the garbage) or is paid (former removal of NFSP). But having the garbage hauled off is not a use.
Invasive Species – Dry Prairie (Page 30) Draft UMP proposes allowing 6% coverage of invasive species in globally imperiled dry prairie habitat. That could be as much as 847 acres! Current "coverage" is less than a combined 5 acres. Why backslide and how was this number reached? Reduce the percentage to less than .5%
Palm or Palmetto Frond Harvesting
Jono Miller • email@example.com
On page 1 of the Advisory Group Draft Unit Management Plan for Myakka River State Park it states that “The purpose of Myakka River State Park is to preserve the natural beauty, wildlife, and historical features of the property, to serve as an important link in the chain of protected lands in the southern portion of the state, and to provide outstanding outdoor recreation and natural resource interpretation for the benefit of the people of Florida.”
On page 7 there is an unattributed “determination” that palm or palmetto frond harvesting “could be accommodated in a manner that would be compatible and not interfere with the primary purposes of resource-based outdoor recreation and conservation.” The page 7 references are the only mentions of palm fronds in the entire 248-page document. No justification is provided for frond harvest. There is no documentation of market demand and no analysis of known or projected impacts. In the absence of any evidence the reader is left to accept the premise that frond harvest is a benign, compatible activity, which is problematic because the Florida Park Service apparently has no contemporary experience with frond harvest.
Sabal palmetto (cabbage palm) green frond harvesting is undertaken for two purposes: religious events (typically associated with Palm Sunday) and as thatch for chickee roof construction. Serenoa repens (saw palmetto) leaves are harvested to supply only two bakeries (La Segunda and Faedo) in Ybor City with strips of leaves that are baked into the loaves of Cuban bread and which are typically removed prior to sale.
Before assessing impacts it is important to note that there are no known management benefit resulting from frond removal. It does not advance any management goal of the park and therefore apparently is being proposed solely as a possible income source, although no data is provided to support the contention that the financial benefits outweigh the impacts. Frond removal weakens the tree, reduces its role as a wildlife habitat and food, wreaks damage on the landscape, and compromises the natural aesthetic of the tree.
In order to assess the potential impacts of frond harvesting four parameters need to be considered: impacts to the target species, collateral impacts to other species and the landscape, any effects on park user experience, and impacts on other frond harvesting operations.
Target Species Impact Harvesting fronds is functionally equivalent to pruning a palm. The harvester removes 15 to 20 green fronds, typically leaving less than six. Since Sabal palmetto is estimated to produce 14 leaves a year, such harvesting sets the tree back one year. The State of Florida (through IFAS) has published an information sheet related to palm pruning: Pruning Palms. Presumably DEP DRP respects relies upon the technical authority and expertise of IFAS in such matters. Here is what that document says, in part: “Pruning, or more importantly, excessive pruning, can affect palms in a number of ways. If palms are overpruned, the reduction in canopy size results in reduced photosynthetic capacity. In the short term, some studies have shown that overpruning can result in greater leaf production rates, but the resulting leaves were smaller in size than those on unpruned palms (Endress et al. 2004; Mendoza et al. 1987; Oyama and Mendoza 1990). If this practice is repeated frequently, the palm may also develop a smaller trunk diameter (Fig. 7).”
In addition to IFAS, Manatee County, the Florida Association of Native Nurseries, The Florida Native Plant Society and the Central Florida Palm Cycad Society also argue against cutting healthy green fronds.
Collateral Impacts There are several wildlife species impacted by palm frond harvesting. Sabal palm harvesting involves removing both dead and green fronds. The dead fronds are important foraging sites for Downy Woodpeckers, Picoides pubescens. Northern Yellow Bats, Lasiurus intermedius, do not use bat houses, but rather rely on Sabal palm skirts and oaks with Spanish Moss. According to Bats of Florida, “To provide habitat for yellow bats, older oaks and taller sabal palms should be preserved. In areas where older tree growth exists, the palm skirts should be left in their natural untrimmed state . . .” In addition to those animals directly depending on cabbage palms, other species can be negatively impacted. Having accompanied a cabbage palm harvesting crew I can attest that frond harvesting crews have been documented killing venomous Pygmy Rattlesnakes (Sistrurus miliarius) they encounter as a precautionary measure.
Park User Experience Two types of users are affected, frond collectors themselves and park visitors. Harvesting fronds is challenging work: There is the heat, the aforementioned pygmy rattlers, poison ivy, invasive fire ants, the two types of wasps (Guinea Polistes exclamans and (Great) Black Sphex pensylvanicus) that nest on the underside of the palm fronds, and the bull ants and scorpions living in the palms. Even if liability issues are covered, park staff may be needed to provide assistance related to injuries, or stuck vehicles. Even a modest chickee requires thousands of palms fronds. Collecting and transporting the fronds typically involves hauling a large trailer capable of holding the thousands of fronds to sites less than one hundred feet from where the fronds were cut and bundled. That’s relatively easy in the open prairies of South Florida, but will involve major impacts in the Myakka landscape. Thus recreational users of the park will be confronted with new woods roads as well as the stark visual aspect of overpruned palms. And from a park management point of view, allowing commercial harvest of palm fronds may erode the authority of park staff to enforce prohibitions on plant collecting when visitors see others carting off vast quantities of native vegetation.
Economic Impacts The claim that frond harvest makes sense presupposes an economic demand for fronds. No information was provided documenting any demand not currently being met by ranches and reservations. Green Sabal palmetto leaves only have value in vast quantities. If small quantities of cabbage palm leaves were valuable, every landscape crew would be segregating their pruned cabbage palm leaves and turning them in for cash payments. That simply doesn’t happen.
Opening State Parks to palm harvest has the potential of competing with private ranching operations. If the DRP price point is too high, no one will bid on frond collection. However, if the price is lower the state will be inappropriately undercutting a revenue stream for the Florida ranching community.
Finally, the cabbage palms of Myakka River State Park with their unpruned, natural, spherical canopies serve to reassure urban dwellers that our state tree does not need to be pruned, regardless of what their landscape crew suggests. Pruning palms in the park will raise the specter that pruning is an appropriate activity even though “Palms do not require pruning as we associate the term with branching broadleaf trees.”
In summary palm frond harvest will not preserve the natural beauty and wildlife of the state and will compromise the quality of outdoor recreation for park visitors. In light of the demonstrable negative impacts and the absence of any justification this proposed use should be removed from the UMP.
New Interpretive Center (Page 121) Building a new interpretative center at the Upper Myakka Lake concession area which is frequently a parking nightmare. The proposed strategy to solve clogged parking at the Upper Lake is a massive new parking area near the entrance and a shuttle system to take visitors to the Upper Lake Concession Area. No tram system is shown in the Implementation schedule spreadsheet. To make matters worse, in order to utilize this area it would need to be brought up to the same height of the drive/parking area. Water stands after each rainfall in summer months and when the river is out of its banks but not overtopping the drive. Fill would kill oaks in the area and there is certainly not enough room for more pavilions and a visitor center (structures that would necessitate removing more of the oak hammock). More analysis is needed before advocating a new interpretive center at the Upper Lake Concession Area.
Eco-Lodge and Conference Center (Pages 125, 126) Proposing a new Eco-Lodge and Conference Center intruding into the Wilderness Area with no business plan (and shown as a $4 million dollar project). You have the same situation in the youth area/STOP Camp as in the Lake Picnic Area. This is a low-lying area of very small size that becomes inundated after summer rains and water stands off and on for as much as 3 months. This project would obviously impact the State Wilderness Area and there is no pro forma analysis to even begin to analyze whether this makes any sense. Rather than a fantasy $4 million project, this proposal should be reframed as a needed discussion on the future of the STOP camp.
New or Wider fire lines (Page 90) I lack expertise to comment authoritatively on the fire line proposal, but more knowledgeable people have challenged this approach and I was dismayed to see large oaks “truncated” during the Christmas Bird Count. This proposal deserves a second look.
Increasing Park Revenue The only proposals for increasing park revenue are from sale of the public’s natural resources. DRP appears to have gone to some effort to comply with the multiple use requirement in Chapter 253. 034 when it comes to the potential revenue that may be gained from extractive, consumptive uses, but failed to undertake comparable analysis identifying the revenue increasing potential of new non-consumptive recreational activities. The various ways the Park can make money by losing natural resources probably should have been balanced by ways the park can make money through recreational opportunity based on protecting and interpreting natural resources.
Optimum Boundaries (Pages 128-130) To begin with, the vicinity map that follows page 2 fails to show the protected Myakka Conservancy property north of the park, as well as the Triangle Ranch, also north of the Park, which is now 95% protected by SWFWMD conservation easement.
Optimum boundaries that include lands already otherwise protected through conservation easement, including the O-Bar-O Ranch and roughly half the land north of the park “Panhandle” and a section east of the panhandle. Why aren’t other contiguous areas of native habitat included?
The desire to not enumerate specific parcel IDs is understandable, but why not list the various criteria that may contribute to warranting inclusion:
• Habitat connectivity to other protected lands
• Potential to add habitats currently underrepresented in the park
• Further protection of the Myakka River corridor
• Simplify boundary configuration
• Reduce visual intrusion in the Park
• Facilitate hydrologic restoration
I do want to put forward two ideas to improve the park experience. Since no one was allowed to hear them on Thursday night and I was directed to confine my Friday comments to positions taken by the Myakka River Management Coordinating Council, no one has reacted to these ideas.
Potential “Paddle-In” Primitive Campsite on Upper Myakka Lake
Myakka River State Park offers both fantastic paddling opportunities and great primitive camping experiences, but not both combined. Creating a campsite along the narrow parts of the river would create significant visual intrusion, but a campsite on the north shore of Upper Myakka Lake need not be visually intrusive. This approximately nine-acre site (outlined in yellow) is currently seldom visited. A straight (and straightforward) one-mile paddle from the Upper Lake put-in to the opposite shore would bring canoe or kayak paddlers to a magnificent oak hammock with open understory, ideal for camping (when it is not too wet). I believe the addition of a paddle-in primitive campsite would prove to be a popular, reserved-months-in-advance opportunity that would appeal to paddlers of all skill-levels. (see attached illustration)
Potential New One-Way Park Drive Segment
There are several problems with the existing park drive: 1) It does not introduce visitors to the globally imperiled Dry Prairie habitat, 2) It forces bicyclists, pedestrians, and runners along the lakefront into close juxtaposition with motor vehicles, and, due to its width, 3) it fails to convey the experience of driving through a hammock because so few sections feature a closed canopy. Taking a page from Highlands Hammock State Park, a new one-way drive segment approximately 1.75 miles in length would convert a portion of the present northbound Park Drive along the lakeshore lane into a southbound lane for vehicles, leaving the present southbound (lake-fronting) lane for bikes and pedestrians. The new nine foot wide drive would take advantage of the already-impacted18-acre abandoned field for parking and provide for either a dry prairie observation structure or possibly a new interpretive center. (see attached illustration)
Finally, the public process was sorely lacking.
No Public Involvement at the Front End: No “scoping” with local stakeholders before undertaking UMP update. DEP staff takes at least three years to draft and gives the local public 15 days before the meeting to evaluate 249 pages. Proper planning should start with stakeholders, not end with the stakeholders.
Not a Hearing: Although advertised as a hearing, the Thursday evening event is really an “Open House” that prevents citizens from hearing everyone else’s ideas.
Why are real hearings better than the chaotic “Open House” format?
The central premise of a hearing is being heard. People want to be heard. You can’t spelling hearing without “hear”. When people are not heard they are unhappy. Ironically, not only were people thwarted by the process, but the acoustics dictated that the court reporter couldn’t hear and had to move outside. In a hearing, everyone is getting identical information from the speakers – everyone is exposed to the same input. Having a shared starting point is a big advantage in any contentious issue. At this meeting NO two people received the same information. In a hearing, everyone is hearing the concerns of the public. The potential for working towards a compromise or consensus has its roots in understanding and appreciating the concerns/needs of the other side.
Quotes from Facebook and paraphrasings from Friday’s meeting:
"I have rarely seen such a dysfunctional and undemocratic "public hearing." DEP is a sham. They have no credibility and must be opposed by principle.""
"A tie for the worst public meeting I ever attended. The other was the DEP meeting on Big Pass." (paraphrased)
"The process was designed to squelch public opinion." (paraphrased)
“Public hearing” and “Open house” an oxymoron. (paraphrased)
“As someone fairly new to the process, it was both disappointing to watch and very clear that concerns were to be put in a box and ignored.”
“It was poorly run and offered no answers to our questions, only the same rhetoric repeated over and over”
“there was NO PUBLIC COMMENT allowed . they gave a presentation ,then there where DEP staff at large maps for private discussion . Good luck with that with the crowd and noise it was next to impossible to talk .”
 Section 2(a) specifically includes recreation as one component of multiple use, and Section 5 (for properties over 1,000 acres) requires "an analysis of the multiple-use potential of the property which includes the potential of the property to generate revenues to enhance the management of the property." So, taken at face value, any increase in revenue attributable to improved recreational opportunity (one explicit dimension of multiple use) should accrue to the funds set aside for park management. In other words, DRP appears to have gone to some effort to comply with the multiple use requirement when it comes to the potential revenue that may be gained from extractive, consumptive uses, but failed to undertake comparable analysis identifying the revenue increasing potential of new non-consumptive recreational activities. The various ways the Park can make money by losing natural resources probably should have been balanced by ways the park can make money through recreational opportunity based on protecting resources. The assertion that keeping RV camping fees low for Class A RV rigs (than can cost more than $300,000) when nearby competing private campgrounds charge TWICE what Myakka does as a commitment to keeping parks affordable is risible. Myakka River State Park charge a year-round fee of $26.00 per night, plus tax, plus a non-refundable $6.70 reservation fee, roughly half the summer rate of a nearby private competing campground on the Myakka River (BELOW).
 Bats of Florida
(Marks, 2006) p. 69
 Ornamental Palm Horticulture (Broschat & Merrow) 2000.p 220.