PO Box 273, Yonkers, NY 10707
A Project of Cetacean Society International
June 21, 2003
Acting Superintendent Billy Garrett
Gateway National Recreation Area
210 New York Ave
Staten Island, NY 10305
RE: Comments on Personal Watercraft Use Environmental Assessment
Dear Superintendent Garrett:
The New York Whale and Dolphin Action League is deeply concerned with the National Park Service's (NPS) Environmental Assessment (EA) for personal watercraft (PWC) use in Gateway National Recreation Area (NRA). Allowing PWC use within the NRA will remove full protection of the park resources.
At this time, 45 states have regulations on the use of PWC because of wildlife impact, incompatibility issues, water and air pollution and public safety.
From Page 17 of the Gateway NRA Personal Watercraft Use Environmental Assessment: "Gateway is home to hundreds of species of plants and animals that are identified as 'of concern' by the states of New York and New Jersey;" and "Gateway encompasses the largest collection of natural systems, wildlife habitats, historic resources, and recreational opportunities in the New York City/New Jersey metropolitan area. Gateway includes numerous sites of critical natural . . . importance to the health of local ecosystems; to the life of migratory and native species."1
Studies have consistently shown that PWC interfere with nesting and breeding and thus reproductive success of native wildlife, including threatened and endangered species, where they are in use. In Barnegat Bay, New Jersey, it was found that 15 Common Tern colonies experienced frequent intrusions by PWC. These colonies suffered a reduced reproductive success as compared to colonies that nested in areas with no PWC access.2 One jetski operator was observed deliberately flushing out nesting ospreys eleven times in a one-hour period. It has been repeatedly proven that PWC operators cannot be relied upon to follow safe nautical laws, or be respectful of the wildlife that is so abundant within our marshes and wetlands.
These "thrillcraft," which are built for speed, are able to travel at high speeds (up to 100 mph!) in very shallow waters, going places where many motorboats cannot. Their presence in previously inaccessible areas is destructive to ecosystems and to the survival of marine and estuary species.
In fact, jetskis represent the antithesis of respect for the environment. PWC dump up to one third of their fuel directly in the water unburned, making them perhaps the single most polluting transportation vessel of all vehicles either on water or land.
A study by the Dept. of Biology at Saint Olaf College in Northfield, Minnesota found that "Two stroke outboard engines produce large quantities of combustion emissions per liter of fuel consumed." The study exposed killifish (Medaka), Oryzias latipes, embryos to water contaminated with outboard motor emissions (OME) to determine the environmental risk of exposure. "Time for larval development, incidence of larval abnormalities, and larval mortality all increased, and length of hatched larvae decreased, with exposure to increasing concentrations of OME-contaminated water. Chemical analysis using solid phase extraction, followed by gas chromatography, indicated high concentrations of polycyclic aromatic hydrocarbons (PAHs) in the OME water. Application of these results to hypothetical lakes suggests significant risks to fish development in the case of high OME input rates to small lakes."3 PAHs are known carcinogens and mutagens, and are common constituents of combustion emissions, which can cause changes in growth, reproduction and behavioral patterns in a broad variety of marine organisms.
In June, 1999, two experiments were conducted at Lake Tahoe, California, to assess the impact of ambient levels of motorized watercraft emissions on zooplankton and fish larvae. "Chemical analysis revealed good correlation between peak boating activity and PAH concentrations in the lake (range 5-70 ng total PAH/L). A significant effect on fish growth was observed in the UV (ultraviolet) treatment of NS (nearshore) site water during Experiment 1 (46% decrease). There was significant mortality of zooplankton observed at all sites during both experiments in the UV treatments. Dose response relationships were observed between integrated PAH dose and mortality of zooplankton in UV treatments, and between PAH and reproduction in the no-UV treatments, indicating both phototoxicity and direct toxicity on zooplankton. Results from these experiments provided evidence that ambient levels of exhaust components from motorized watercraft caused photoactivated toxicity to fish and zooplankton as well as direct (i.e., no-UV) toxicity to zooplankton."4
Furthermore, noise from jetskis is disturbing to shore visitors or beach-goers often seeking a peaceful interaction with nature. PWC motors easily reach 100+ decibels, a deafening noise that ruins the quality of visitor experience and forces wildlife to flee from their habitat. In areas where PWC are present, birdwatchers are unable to cite species, and marine scientists and ecologists are unable to accurately manage populations that are hiding from the noise or forced to flee from their habitat. This may be considered a violation of the rights of public use of the natural resources.
The National Park Service's recreation visitor counts for 2001 and 2002 showed that parks that prohibited personal watercraft experienced an average of six percent increase in visitation. During the same time period, parks that continued to allow PWC experienced a 9% drop in visitation. Such parks must employ an increased number of personnel to enforce boating safety rules and guard public health while steady complaints from visitors about the jetskis often overwhelm officials. There is clearly an economic benefit to local communities from prohibiting jetskis from their park waters.
Jetskis are dirty, highly destructive of quality park experiences and values and or visitors' contemplative enjoyment. Furthermore, as a "thrillcraft" they are highly dangerous.
A study from the American Canoe Association found that jetskis are involved in 55% of all boating collisions but they account for only 6.2% of all vessels. The study found that "Jetski use is disproportionately responsible for more boating accidents, more high-speed collisions, more cases of reckless operation, more incidents of harassment, more harm to wildlife and more complaints of disturbance due to noise, air and water pollution than any other vessel type," and that "80% of all jetski accidents result from causes that place others at risk, such as careless or reckless operation and excessive speed."5
Four years ago I was seriously injured while riding a passenger on a jetski. Ironically, it was the first time I had ever been on a jetski. The injury occurred while the driver failed to slow the vehicle while jumping the wake of a passing vessel in a very busy area of Barnegat Bay. The impact crushed one of my vertebrae, broke four ribs and left me with permanent nerve damage. To my horror and amazement I discovered that on that particular weekend alone there were four deaths in the metropolitan New York, New Jersey area resulting from operating jetskis on the water. The number of serious life-threatening injuries on these craft is staggering.
Analysis of 1997 boating accident report data from the National Transportation Safety Board showed that there is a high risk of injury associated with PWC, and that 84 percent of PWC operators received no boating instruction whatsoever.6 Operating high-impact "thrillcraft" does not instill the values that would encourage concern for proper safety procedures, respect for the environment, wildlife and others' well-being and quality of life to impressionable youth or adults. Areas that allow PWC use are obligated to increase boating rule enforcement personnel, even as visitor numbers decrease.
It can easily be demonstrated that PWC pollute the air and water, create law enforcement problems, threaten public safety, endanger wildlife, destroy natural soundscapes, and diminish opportunities for more contemplative forms of recreation. Considering the known environmental degradation associated with PWC, the health hazards, and the fact that these craft appeal to a few thrill-seeking enthusiasts at the expense of the majority of the shore-going public, it is appalling that the NPA would even consider allowing PWC in the Gateway National Recreation Area. Yet the NPS's preferred EA alternative permits PWC use on much of the park's waters despite the fact that the document reasons that park resources would be best protected by the no-action PWC-ban alternative.
The NY Whale and Dolphin Action League finds this unacceptable. Compliance with the National Environmental Policy Act, (NEPA) and the Federal Endangered Species Act (ESA) will be achieved only if PWC are barred from these ecologically diverse and sensitive areas comprising the Gateway National Recreation Area. For this reason we encourage the NPS to take the action that would ban all PWC from operation throughout the NRA. Any other course of action makes no sense and will be greeted by challenges from this and many other environmental organizations.
PWC use is regulated within Gateway NRA through the Organic Act of the NPS. Legal decisions have consistently found that the Park Service is required by federal law to leave the resources and wildlife of the park system unimpaired and without degradation for the well-being and use of future generations. Given the damage PWC cause the environment, wildlife and public, we strongly urge the NPS to adopt the "no-action alternative" of its EA that will prohibit PWC from the Gateway NRA.
Taffy Lee Williams, Director
Chair, City of Yonkers, Citizens' Conservation Advisory Committee
cc Assemblyman Mike Spano
Assemblyman Tom DiNapoli, NYS Assembly Environmental Committee Chair
Assemblyman Steve Englebright
Senator Carl Marcellino, NYS Senate Environmental Committee Chair
American Canoe Association
Williams Rossiter, President, Cetacean Society International
John Stouffer, Legislative Director, Sierra Club
Assemblyman Scott Stringer
1. U.S. Department of the Interior, National Park Service. Gateway National Recreation Area, New York/New Jersey. Personal Watercraft Use Environmental Assessment. 2003.
2. Burger, Joanna. 1998. "Effects of Motorboats and Personal Watercraft on Flight Behavior over a Colony of Common Terns." Rutgers University, NJ: Nelson Biological Laboratories.
3. Koehler, M., Hardy, J. 1999. Effects of Outboard Motor Emissions on Early Development of the Killifish Oryzias latipes. Northwest Science, Vol. 73, No. 4.
4. Oris, J.T., A.C. Hatch, J.E. Weinstein, R.H. Findlay, P.J. McGinn, S.A. Diamond, R. Garrett, W. Jackson, G.A. Burton, and B. Allen. 1998. "Toxicity of Ambient Levels of Motorized Watercraft Emissions to Fish and Zooplankton in Lake Tahoe, California/Nevada, USA." Poster number 3E-P005, Eighth Annual Meeting of the European Society of Environmental Toxicology and Chemistry. April 1998, University of Bordeaux, France.
5. American Canoe Association. Hostile Waters, The Impacts of Personal Watercraft Use on Waterway Recreation. 2002.
6. National Transportation Safety Board. Personal Watercraft Safety. Safety Study NTSB/SS- 98/01. PB98-917002 Notation 7002. May, 1998.
Organizations Supporting a Ban on PWC in the Gateway National Recreation Area:
Hudson Basin River Watch
New York Whale and Dolphin Action League
City Of Yonkers Citizen's Conservation Advisory Committee
The New York Whale and Dolphin Action League
PO Box 273, Yonkers, NY 10707 USA
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A Project of Cetacean Society International
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