We are a member of the local Marine Industries Asociation of South Florida. I just received this email from them, and as the subject will have an effect on any of us with an interest of any kind in Florida boating, whether it is our business, a related business or as a boater I thouhgt I would post it here.
December 11, 2002
To: Marc Berman
Dear MIASF Member:
It is important that you read this letter and accompanying memo.
Your Marine Industries Association of South Florida has made significant
investments in the development of a new public awareness campaign "Our
Waterways, Our Future." You've read about the campaign in Tide-ings and many
of you have seen the television commercials and have read the articles in
the local press resulting from our media contacts. We believe our moderate
proactive approach will help turn the tide of public opinion and encourage
greater cooperation between environmental groups, government, industry and
boaters toward reasonable solutions to the manatee controversy.
Your board of directors and staff however cannot do it alone. We need the
support of all industry members and boaters. We need you to be at the public
hearings on Thursday to help us voice our concerns about the threat of
additional regulation of recreational boating and marine facilities. The
proposed new regulations are likely to restrict development of boat ramps,
marinas, docks and other watercraft access facilities and further regulate
operation of boats on our waterways.
Each of you has an opportunity to influence the outcome of this critical
debate over access to our waterways. Tomorrow evening, Thursday December
12,U.S. Fish and Wildlife Service will present a proposal for new rulings
that will affect marine industry and boaters throughout Florida, including
you. They will then receive comments from the public about their proposal.
We need you to attend this hearing and share your opinions on the proposed
regulations. If you prefer not to speak, we still need you to be there to
show your support and our solidarity as an industry. Please make a point to
be present tomorrow evening,Thursday December 12, from 6-9pm at the
Renaissance Hotel, 1617 SE 17th Street, Fort Lauderdale.
If you are unable to attend, then send a friend, or you can also express
your concerns by sending your written comments to USFWS, Attn: Field
Supervisor, Jacksonville Field Office, U.S.Fish and Wildlife Service, 6620
Southpoint Drive South, Suite 310, Jacksonville, FL 32216. Your comments
must be received before January 10, 2003.
Inform your customers and employees and encourage them to write their
representatives and the USFWS as well. Anyone who cares about the future of
our industry and recreational boating needs to act. We need your support on
this critical issue.
Scott Miser Dale Weatherstone
President,MIASF Secretary/Treasurer, MIASF
Chair, Our Waterways, Our Future
To: MIASF Membership
From: Frank Herhold, Executive Director
Re: U.S. Fish & Wildlife Service Public Hearing December 12 at 6 p.m.
"Incidental Take" Proposed Regulations
With this memo, you are urged to attend the Thursday, December 12 hearing
with as many colleagues as possible, to assure the voices in favor of
waterway access are heard by the USFWS. It is extremely important you find
the time in your busy holiday and year-end schedule for this important
The U.S. Fish & Wildlife Service proposes to place a five-year moratorium on
permits for marinas, docks and other facilities and require Letters of
Authorization for boat operation in Southwest Florida because manatee death
rates are high. Miami-Dade, Broward and Palm Beach counties are part of the
USFWS "Atlantic" manatee stock and the service's intentions are less clear,
but potentially equally ominous.
USFWS has determined "Incidental Take" regulations apply to manatees
accidentally killed in Florida and that incidental take must have a
"negligible impact" on survival of the species. USFWS has the authority to
require waterway users to obtain Letters of Authorization for virtually any
activity that potentially affects the habitat. USFWS's scope includes:
* Authorization to regulate watercraft operation;
* Authorization to construct boat ramps, marinas and docks;
* Fund construction of watercraft access facilities;
* Operate facilities that provide watercraft access to waters; and
* Operate government-owned watercraft in Florida waters where manatees live.
"Take" is defined in the Marine Mammal Protection Act (Act) as "harass,
harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect any
threatened or endangered species. Harm may include significant habitat
modification where it actually kills or injures a listed species through
impairment of essential behavior (e.g., nesting or reproduction). Where
incidental take exceeds USFWS limits, the agency is announcing its intention
to place additional restrictions on waterway access.
The USFWC actions could be effective as early as May 2003. Florida's manatee
population has now been divided into four "stocks." Currently, our
stock--the entire Florida Atlantic coast-is close to exceeding its "take"
limits. Potential economic losses to the area and its marine industry are
inestimable. The USFWS is seeking comments on the proposed incidental take
regulations and the accompanying environmental impact statement.
MIASF members are urged to attend the one opportunity we will have in our
area to express our concerns and offer constructive comments regarding this
impending legislation. The USFWS has scheduled South Florida's public
hearing for Thursday, December 12 from 6 p.m. - 9 p.m. at the Fort
Lauderdale Renaissance Hotel, 1617 SE 17 Street. Even if you do not intend
to speak, it is important our industry is well represented. More than 3,000
people attended the first public hearing on December 2 in Fort Myers. If
you decide to speak (there is a 2 1/2 minute limit), there are several key
points MIASF recommends you make:
* The public 60-day comment period of Nov. 5, 2002 to January 10, 2003 is
entirely too short. USFWS should petition the court for an extension to at
least six months.
* Incidental take is a concept applicable to mammals trapped in commercial
fishing nets and has no applicability in the case of manatees. The true
number of manatees is not known. The actual cause and location of death is
often not possible to determine. And the definition of negligible impact is
highly subjective and arbitrary. Moreover, unlike county manatee protection
plans and Florida's Fish and Wildlife Conservation Commission regulations,
incidental take does not address root causes of manatee mortality.
* The environmental impact statement is superficial, statistical in nature
rather than field proven and too incomplete to base the sweeping assumptions
of the USFWS's proposals.
* The definition of four manatee stocks is highly arbitrary and penalizes
counties like Collier with published and accepted manatee protection plans
for proximity to counties such as Lee County with higher manatee populations
and less defined regulations.
* Since manatees are highly mobile, USFWS should consider survival ratios on
a statewide basis rather than on a four-region basis.
* Manatee mortality should be evaluated in terms of a percentage of the
known population (as counted in aerial surveys) rather than the current
"head count" ... as the manatee population continues to increase (currently
3,276 as of the 2000 aerial survey) boat-related mortality may naturally be
expected to trend up.
* Greater emphasis needs to be placed upon education and public awareness
campaigns such as MIASF's new "Our Waterways, Our Future" campaign.
* Resources from public and private sources must be directed towards very
promising marine mammal avoidance technology research
* Funding for enhanced law enforcement needs to be authorized. Consider the
cost of additional law enforcement officers on the water vs. the enormous
revenue loss to the State and local economies as marine industry, real
estate and tourism industries begin to experience the effects of new
* Family recreational boating and Florida's $14.3 billion marine industry
must be considered when evaluating the proposed regulations. Look no
further than the ill-fated luxury tax to see how easily a lifestyle and a
vital economic engine can be devastated
It is suggested for maximum effectiveness that your comments be delivered in
writing as well. Please furnish MIASF with a copy of any written comments.
We must stand together as a statewide industry and ensure that USFWS is made
aware of the concerns of "the Yachting Capital of the World."
Please call the MIASF office if you have any questions or for further
details. You may review the USFWS Proposed Regulation and Request for
Public Comment at http://northflorida.fws.gov
Peace & grace be to this place.
........ God bless the troops, always! :)
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