Official Sierra Club Missouri Chapter Comments on the Ozark National Scenic Riverways Management Plan

July 29 2009
Superintendent Ozark National Scenic Riverways
P.O. Box 490
Van Buren MO 63965

Thank you for the opportunity to comment on the General Management Plan/Wilderness Study for the Ozark National Scenic Riverways. The ONSR is a valued natural treasure which provides many management challenges. We hope our comments will help in the preparation of a management plan that rises to those challenges.

We are providing input on behalf of the Sierra Club. The Sierra Club is a national conservation organization founded in 1892 and dedicated to the preservation, protection and enjoyment of our natural resources. The Sierra Club has a membership of nearly 650,000 with approximately 8000 in Missouri. We value the OSNR for the resource it provides to all citizens, including of course Missourians for which it holds special significance.

As the NPS works with public input to develop a management plan, we hope that the primary purposes of the National Park System and the OSNR in particular are kept foremost in mind as stated in the 1916 Organic Act:
The service thus established shall promote and regulate the use of the Federal areas known as national parks, monuments, and reservations hereinafter specified by such means and measures as conform to the fundamental purpose of the said parks, monuments, and reservations, which purpose is to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations. (U.S.C., title 16, sec. 1.)
 And as stated specifically in the 1964 act creating the ONSR:

For the purpose of conserving and interpreting unique scenic and other natural values and objects of historic interest, including preservation of portions of the Current River and the Jacks Fork River in Missouri as free-flowing streams, preservation of springs and caves, management of wildlife, and provisions for use and enjoyment of the outdoor recreation resources….


We know that the NPS is dedicated to these principles. But many of the current conditions in the ONSR reflect a failure to apply them rigorously to on the ground day to day management. Cumulatively those shortcomings have taken a toll. At the same time we note that the NPS has taken meaningful steps to address some contemporary issues, such as the Park’s efforts to deal with rowdy behavior on the river.

We hope that through the development of a new management plan the NPS and the public reaffirm that the future of the ONSR will be managed in accordance with its original principles. Through that effort the best options for protection of the natural resource and best opportunities for enjoyment of those resources will emerge. It is in that spirit that we offer our observations and recommendations in the following areas.

WATER QUALITY
The Current and Jacks Fork rivers are also listed as Outstanding National Resource Waters. That status along with designation as part of the country’s Natural Scenic Riverways system should insure that high water quality in these waters is maintained and protected. Families who swim, inner tube, canoe or boat in these rivers deserve to know that the waters are clean enough for recreation. Unfortunately that has not always been the case. In fact a portion of the Jacks Fork has been classified as an “impaired waterbody” through a mechanism of the Clean Water Act.

The ONSR management plan needs to include aggressive steps to restore and protect water quality. This should be acknowledged as a fundamental and critical goal. Management cannot be considered a success unless water quality standards are met.

At the same time not all factors impacting water quality are under direct control of the NPS. But significant sources of poor quality are. Studies have indicated that horses contribute significantly to river contamination.

The new management plan should take steps to provide for the following options:
1. Move riding trails further from the river and minimize stream crossings.
2. Limit the number of horses on the river. Even with limited stream crossings and trail adjustments, large trails rides may be more than the system can handle.
3. Include a commitment to water quality testing to measure outcomes of policy changes

In summary, the new management plan needs to include a clear commitment to greatly reducing the impact on water quality from equestrian use. The plan needs to clearly give the NPS authority to take measures as outlined above to achieve that goal. Equestrian recreation is appropriate on the ONSR, but it must be conducted in a manner that does not harm the stream environment or create a health hazard for other recreationists.

As with all management activities, the NPS should include input from the public on details regarding achievement of this goal, so that the ONSR can boast of both high water quality and opportunities for equestrian recreation.

Equestrian recreation is not the only activity on the ONSR that impacts water quality, but it is the most significant source within the NPS jurisdiction. Other activities such as controlling off road vehicle use, motor boating and sheer numbers of canoeists also have an impact. We encourage the NPS to keep water quality objectives in mind when managing any facet of the ONSR.

ROADS, TRAILS AND ACCESS POINTS
A well managed system of roads, trails and river access points is important to providing safe and satisfying recreation opportunities along the river. Originally the ONSR was envisioned to include 18-20 access points. It now holds 25 official access points but up to as many as 100 if unauthorized access points are included. Those unauthorized access points are many times linked with an unauthorized road or trail. Unauthorized access points contribute to stream bank erosion, and impair stream habitats. In addition they provide a point of entry for off road vehicle use.

It is important that these unauthorized access points be closed. The access point system should be evaluated for spacing (longer and shorter runs) and for safety. Some current unauthorized access points, where linked with an authorized road, may be candidates for inclusion in the system of legitimated points. But inclusion should be considered only after careful evaluation of the need, placement, ecological impacts and maintenance requirements. The present, out of control, situation must change and the number of access points be significantly reduced.

The same evaluation needs to be applied to unauthorized roads and trails. Trail expansion or relocation needs to develop through a process of environmental evaluation and public input. So called “user designated” trails or roads should have no place in the ONSR.

The new management plan should directly address the issue of unauthorized access points, roads and trails and include a commitment and schedule to achieve the above objectives. The original vision for the ONSR of natural flowing streams, with a largely uninterrupted natural riverbank should guide the plan.

OFF ROAD VEHICLES
The use of off road vehicles of all types unfortunately mars the visit of many recreationists along the ONSR. Their presence off road in campgrounds, on gravel bars, on river banks and in the river is all too often part of the ONSR experience. Off road vehicles also contribute to erosion, water pollution and disturbance of stream and riparian habitats. Off road vehicle use is a contributor to the problem of unauthorized roads, trails and access points. It is widespread and well known that the ONSR is an easy place for illegal off road riding. This is an unacceptable situation. Resolving it should be a priority in the management plan.

The NPS needs to enforce its own current prohibition against off road riding in the ONSR. The management plan needs to outline how the NPS will to do this, what resources it needs to do so and what support it needs from the public for this critical objective.

MOTORBOATS
Developing a sound policy regarding the use of motorized watercraft and HP on the Current and Jacks Fork is an integral part of any long term management plan for the ONSR. Without further changes the future is likely to result in unsustainable numbers of motorboats on the rivers. The Current and Jacks Fork are, in many places, narrow, winding and shallow. Increased number of motorboats will only lead to user conflicts and adverse impacts on stream health. Thus we recommend at least the restrictions recommended in Alternative A. As another alternative we recommend that the NPS consider a year round ban on all recreational motor boating above Two Rivers, a 10 HP limit between Two Rivers and Van Buren and a 25 HP limit below Van Buren.

Whatever options are evaluated, giving consideration to appropriate pollution and noise controls will provide options for recreational motor boating, while minimizing impacts to other recreationists and to stream health.

WILDERNESS
We support the designation of Big Springs Wilderness via and act of US Congress as in Alternative A. The Big Spring tract has excellent wilderness values. Its addition to the ONSR would help create a protected wild area which would add value to the system now and over time. As a Wilderness, the area would still be open to hiking and horseback riding. Its protection would ensure a wild stretch of the lower Current for river travelers to enjoy. It would provide reliable wildlife habitat.

EASEMENTS
Scenic easements are valuable voluntary agreements which benefit both private landowners and the public. However, if some of these agreements are not respected and enforced, it is a loss for the public and for other private landowners who abide by their agreements in good faith. Serious questions have been raised about lack of enforcement of some easements along the ONSR. The NPS needs to address this matter and take measures to ensure the public and all easement holders in the area, that these agreements will be honored.

CAPACITY ISSUES
A plan that is designed to cover up to 20 years needs to look not just at current problems and how to address them, but also anticipate future needs. One of those issues facing the ONSR is the sheer number of recreationists enjoying the rivers. While our comments have specifically mentioned present problems related to recreationists who enjoy equestrian and motor boating, other pursuits such as hiking, canoeing and tubing, can in enough numbers, mar the human and natural environment of ONSR. The management zone concept as presented by the NPS can address capacity issues to some extent. However, we recommend that the new management plan consider providing the NPS options for limiting the number of recreationists, if future conditions require it. The details of any such policies would need to be worked out with public input. But the NPS, and of the public, may need to be willing to accept restrictions on the number of users in order to ensure that a quality ONSR will be available for others well in the future.

Of course unauthorized activities such as off road vehicles need to be controlled as a present source of damage and a future threat.

ECOLOGICAL INTEGRITY AND CLIMATE CHANGE
All points already raised are linked to the ecological health of the ONSR. In addition to the challenges faced by increased number of recreationists, the ONSR will be impacted by climate change. During the next 20 years the Ozarks may see significant changes in temperature and precipitation. We encourage the NPS to work with other agencies in the state to ensure that the ONSR contributes to the region’s ability to adjust to climate change. As a healthy riparian zone with adjacent lands largely protected from development, the ONSR can provide a useful wildlife corridor for the region.

In summary, Alternative A provides the best option for the long term health of the ONSR. It provides the best opportunity for low impact recreation that is appropriate to the purpose of the ONSR and is the most sustainable course for long term future of the area.  We have recommended a few areas in which Alternative A could be improved.

We appreciate the NPS’ outreach efforts to gain input into this process. As the input process continues, we encourage the NPS to continue that outreach and takes steps to further its reach. The public “open house” events are useful, but should be expanded to other larger metropolitan areas, such as Kansas City and Springfield, which were overlooked in the most recent schedule.

Thank you for consideration of our comments.

Caroline Pufalt
on behalf of the MO Chapter of the Sierra Club
7164 Manchester Ave, St Louis MO 63143