Dear Mr. Fry

As the National Park Service develops the scope of the Cumberland Island Transportation Management Plan to permit reasonable access to historical sites on the northern end of the island, as required by Public Law 108-447, please carefully consider the following recommendations in order to minimize impact on the environment, flora and fauna, in particular within the Wilderness areas and those areas immediately adjacent to Wilderness, so that the island’s character, spirit and primitive nature can be preserved to the fullest extent possible for future generations.

The guidelines below for the Transportation Management Plan are necessary to prevent abuse and to ensure minimal impact on the natural and historical resources of Cumberland Island.

1) Route
a) Origin/return: Sea Camp or Dungeness. There are already sufficient existing facilities.
b) Route: Travel on Main Road to wharf ruins, turn right, stop at historic sites, ending at hotel at High Point. Return by same. No traveling across the dunes or along the beach.
c) Prohibited areas: dunes, wilderness, beach, areas north of wharf ruins.

2) Visitor access
a) Guided tours only to Historic Districts.
b) Stops: No unsupervised or extended stops that would allow tour participants to wander into prohibited areas. [See 1c) above]
c) No one-way drop-off trips; round-trip guided tours only.
d) All tours by all concessionaires must abide by same guidelines.
e) No motorized side trips to Plum Orchard. Existing tours via ferry and foot are sufficient. Legislation mandates tours to the Historic District, not to Plum Orchard.

3) Mode
a) Electric or hybrid motorized vehicles only (electric preferred).
b) Smallest and quietest vehicle available. Recommend that the Park Service lease vehicles until tour demand is established to avoid unnecessary monetary outlays.
c) Speed limit recommended at 10-15 mph, compatible with current condition of road, to reduce noise, protect the road and avoid dangerous encounters with pedestrians and wildlife.

4) Support facilities
a) No additional facilities should be constructed. Maintain, upgrade or equip existing structures as needed to ensure health, safety and sanitation. Existing structures may be used for tours and for vehicle maintenance and storage.
b) No new visitor center anywhere on the Island. Additions at St. Mary’s visitor center only.
c) Interpretive signs and structures are really unnecessary with guided tours, but if considered, must be limited to within the boundaries of the historic districts. Please consider carefully the impact that additional structures may have, and minimize such. This should be one of the lowest priorities, if considered.
d) Create tour brochure to hand out, with multiple language inserts as necessary. A basic edition can be produced for no charge, a more expansive, glossy edition for sale.

5) Tour operations
a) Tours offered by Greyfield Inn to the northern Historic District shall be included in the count of the legally required trips to be offered daily.
b) The National Park Service should be the only concessionaire to offer these tours, with the exception of Greyfield Inn, who may continue to offer tours, in accordance with permit issued by the National Park Service, following all guidelines as other tours, including no beach driving.
c) Tour fees should cover the complete cost of the tours, including personnel, structures, vehicles, etc. If a “reasonable fee” does not cover total costs, the remainder must be covered by additional, separate funding from the Federal Government designated for this purpose, so as to not take funds away from other Park Service functions.
d) Tour costs must also include funding designated to enable the National Park Service to provide proper oversight of the tours and ensure compliance with all rules and regulations. Fines from violations may be applied to these funds.

I urge you to carefully consider any deviation from the above recommendations and the impact which the choices in the Transportation Management Plan will have for hundreds of years to come. The best action alternative is really No Action. However, since Public Law 108-447 does not appear to permit this alternative, please implement the above guidelines to preserve the natural heritage that Cumberland Island provides to all her visitors, present and future.

Please Keep Cumberland Island Wild!
 

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