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TYhis was sent to me. I cannot reveal the source. Ian

******* has developed what I consider to be a very good response for the BIG Cypress National Preserve mineral management plan. I encourage each of you to cut and copy this document into your own letter and mail it to Mr. Donahue.

Thanks ****

Mail to Superintendent John J Donahue, Big Cypress National Preserve, HCR 61, BOX 110, Ochopee, FL., 34141 by July 27, 2001

Big Cypress National Preserve
Oil and Gas Management Man Comments

1. No, I do not agree with the goals and objectives of this plan. I would add the following goals/objectives:

A. Ensure the rights of mineral owners are protected as per Executive Order 12630 (Government Actions and Interference with Constitutionally Protected Property Rights) and the enabling legislation for both the Preserve and the Addition Lands of the Preserve.

B. Ensure the Oil/Gas plan complements our National Energy Policy whose purpose is to establish our nation's independence from foreign oil cartels. Energy is a national security issue. We have the strongest military in the
world and yet OPEC could bring our country down to its knees with anther and more extensive version of the Arab Oil Embargo of the 1970's. We had the Gulf War over oil! Let's produce our own. We have plenty of it.

C. Ensure the new plan meets the recently issued Executive Orders 13211 and 13212. These EO's require federal agencies to take actions to expedite energy-related projects. The Draft Plan should explain how NPS will minimize regulations and expedite the planning/permitting process as required by these EO's.

2. No, the planning team did not adequately cover the resources and values that could be affected by this plan. NPS should examine and address the following issues in the Draft Plan:

A. Visitor Use. The continuing reduction of recreational use opportunities in the Preserve.

1. The implementation of the Recreational ORV Management Plan that resulted in additional unit closures and significant reductions in backcountry access and use for hunting, fishing, camping, wildlife viewing, frogging, bird watching, sight-seeing, etc.

2. The arbitrary and capricious fishing closure at HP.Williams park.

3. The unlawful prohibition of hunting in the Addition Lands.

4. The closure of public primitive campgrounds for most of the year due to a lack of funds.

5. The closure of wells for drinking water along the Florida National Scenic Trail.

6. Continuing efforts by NPS to further restrict hunting activities by eliminating transferability of hunting permits and the banning of handguns as legal hunting weapons.

7. The fencing of 175, the removal of bridges over Turner River canal and the closure of other access points in order to severely limit human access to the Preserve backcountry.

Therefore, expanded oil/gas geophysical operations should have minimal impact on visitor use in the backcountry.

B. Cultural Resources. The Draft Plan should evaluate the impact of NPS removing historic structures such as fences, fence posts and others in the name of restoration. Fewer cultural resources will lessen geophysical
operational issues in the Preserve.

C. Socio-economics. The Draft Plan should examine and consider the cost of prohibitive rules, Regulations, Requirements imposed on mineral rights owners.

D. Water Resources. The Draft Plan should provide a comparison with other Big Cypress sheet flow impediments such as I-75, Tamiami Trail, Loop Road, Turner River road and the canal system associated with the above roads. Any sheet flow impact from oil/gas geophysical operations should be minimal when compared to the real sheet flow impediments in the Preserve, those water management practices outside the Preserve and being built into CERP.

3. No, the Special Management Areas and Special Management Concerns are not complete. Old growth pinelands should not be listed as an SMA. These pinelands can sustain geophysical operations with minimal environmental
impact These areas should be reviewed on a site by site basis to ensure die protection of the existing red cockaded
woodpecker colonies. These birds are nesting and expanding in all parts of Florida's public lands, including State Forest.

I believe the Bald Eagle is no longer on the Endangered Specie List Therefore, this species should not be treated as a species of Special Management Concern.

My suggestions for alternative management strategies: There should be one or two additional alternatives that address expanding ml/gas operations in the Preserve. Raising/eliminating the 10% cap on geophysical operations, reducing regulations, crediting the plan/permit timetables (per Executive Onto) are issues to be addressed in these
alternatives. I would also eliminate your Preliminary Alternative number

4.NPS has no authority to purchase the private mineral rights in the Preserve. Is this alternative an attempt by NPS to circumvent the intent of Congress through the enabling legislation for the Preserve?

I strongly protest this alternative as it is contrary to Presidential Executive Orders as well as the enabling legislation. I also oppose the use of my tax dollars to buy these expensive mineral rights, especially when our country faces much more important budgetary issues such as finding education, saving Social Security, Medicare and providing
prescription drugs for seniors!

5. Additional comments:
A. I fully support Oil/Gas geophysical exploration and production in the BCNP that is conducted in an environmentally sound manner using the latest in technological methodologies.

B. NPS has had over 26 years to conduct studies on almost every issue impacting the Preserve. Therefore, recommendations/alternatives in the Draft Plan should be based on science and facts and not arbitrary
restrictions/regulations unofficially designed to hinder, obstruct, delay, or stop lawful oil and gas operations.

C. The 10% cap on oil/gas geophysical operations is purely arbitrary and completely lacking in science. This cap constitutes a taking of mineral rights by NPS. The Draft Plan should increase or eliminate the cap requirement or else explain the science or facts behind it.

D. The NPS should use all applicable (local, state and federal) scientific studies when evaluating alternatives and ecological impacts. For example: the extensive 1986 Duever study found oil/gas operations in the Preserve had
"minimal environmental Impact" Also, studies conducted by David Maehr have shown the Florida Panther to be highly tolerant of human presence. Florida Panthers are currently found in record numbers in the Preserve, especially at Raccoon Point and Bear Island.
It is interesting to note that if the Panther wore as sensitive to human disturbance as the NPS and the environmental community would have you believe, then we wouldn't have any panther s left in the Preserve! These poor cats are intentionally chased all spring by biologists on Swamp Buggies using packs of hounds to tree, dart and collar or re-collar them. Then, the researchers continue to harass the cats from the ground or by air
surveillance the remainder of the year while the cat has to lug around these uncomfortable collars. If this intentional harassment doesn't make them leave the Preserve, then I don't see how other non-harassing activities are going to bother them.
Additionally considering that 55% of all panthers live north of the Big Cypress National Preserve because the habitat is more suitable to the Panther's liking and that these lands have are used more intensely by man with machines one really has to wonder why the NPS continues to try and convince people they must remove sportsmen from the Big Cypress National Preserve.
A visit to Raccoon Point-oil field in the Corn Dance unit of the Preserve will show that the oil company can keep a clean, tidy, organized operation. Deer and other wildlife are seen within a few yards of operating oil
equipment. Wildlife, whether endangered or not, is only very minimally impacted by oil/gas operations in the Preserve.
Further evidence that the panther is able to live with man, be they sportsmen, ORV operators or oilmen, can be found in the Bear Island Unit of the Preserve. Oil has been removed for more than 35 years from this part of
the Preserve. The panther population continues to be very stable and healthy. Cattlemen and sportsmen have used this same area continuously for more than 60 years and the panther continues to live and reproduce in this part of the Preserve as it does in the rest of the Preserve. There is no evidence that the panther is being disturbed by oilmen or sportsmen. There are some with negative opinions about this relationship but no evidence. In fact the opposite exist because of the real world facts concerning the panther living in Bear Island, Raccoon Point and on agriculture lands out side of the Preserve.

E. I also fully support the following NPS statement relating to oil/gas impact on recreational ORV trails on page 46 (General ORV Regulations) of the 1991 BCNP General Management Plan:
** If a new mineral access road or pipeline displaced an established ORV trail, a new or alternate ORV trail to the affected area would be provided,."

The above statement should be made part of the Draft Plan.

F. Input from the Florida Fish and Wildlife Conservation Commission should be considered and utilized in the development of the draft plan. Further the NPS must start following the Amended Big Cypress National
Preserve enabling act and truly "consult and cooperate" with the Florida Fish, Wildlife and Conservation Commission and all other State agencies in the management of the Preserve. The NPS must stop merely notifying the State of actions it is going to take.


cc: The Honorable George W. Bush, President of The United States Of
The Honorable Gale Norton, Secretary of The Department of Interior
The Honorable Spencer Abraham, Secretary of The Dept. Of Energy
The Honorable Fran Mainella, Director, National Park Service
Dr Alan Egbert, Director, Florida Fish, Wildlife and Conservation Commission
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