Anyone who has birded the Assateague Island National Seashore knows that it is a fantastic place to bird year round. One of the great spots to bird is the Bayside Point area which is phenomenal during migration. During spring and fall, tens of thousands of migrants are utilizing the woodland area between the parking area and camping loops and a recent plan by the National Park Service is threatening to destroy much of the woodland area for expanded parking. Many of us feel that the opinion of the NPS Environmental Assessment is deeply flawed and that removing these woods would cause significant environmental impacts to migrant birds.
The birding community CAN make a difference by voicing our concerns and sharing the data collected by citizen scientists and submitted to eBird. THE DEADLINE FOR COMMENTS IS WEDNESDAY SEPTEMBER 25th! You can write your own response, but if you aren’t sure what to say, Mark Hoffman sent out a sample email that you can edit to your liking and submit. It is below.
The full Environmental Assessment is available at:
The link for comments is:
And letters can also be addressed to:
Deborah Darden, Superintendent
Assateague Island National Seashore
Attn: Bayside Picnic and South Ocean Beach Parking Areas Removal and Relocation EA
7206 National Seashore Lane Berlin, MD 21811
Below is a sample email that Mark Hoffman composed that you can use as inspiration for your comments to the NPS.
Dear Ms. Darden:
Thank you for the opportunity to comment on the Bayside Picnic and South Ocean Beach Parking Areas Removal and Relocation EA (EA). My comments follow in the list below, and are limited to the assessment of the impact of changes to the Bayside Picnic area.
1) The EA is inconsistent with requirements of the National Environmental Policy Act (NEPA) due to the inadequate assessment of the impact of the parking lot relocation on migratory bird habitat.
The National Environmental Policy Act (NEPA) [42 U.S.C. 4321 et seq.] requires a federal agencies conduct a through evaluation and assessment of proposed actions that have significant environmental impacts. The EA is woefully inadequate in assessing impact of the parking lot relocation to migratory bird habitat. The woodland/shrub-scrub habitat at the Point is home to one of the largest concentrations of migratory landbirds in the mid-Atlantic states. The parking lot relocation would destroy or fragment 50% of this tiny area. As detailed below, and contrary to the assertions in the EA, this small area of critical habitat is not equal to or interchangeable, with other habitat areas on the Bayside Peninsula or Assateague. Impacts to migratory bird habitat are not even considered a “Retained Impact Topic” and received only cursory review in the EA (pages 11-12).
As pointed out in multiple comments sent to the NPS during the scoping process, the woodland/shrub-scrub habitat at Bayside Point is the site of a unique concentration of migratory birds during spring and fall migration. Due to the geographical configuration of the peninsula, migratory birds concentrate in very large numbers in the woodland/shrub-scrub habitat between the end of the camping loops and the existing Bayside Picnic Area parking lot (the exact area proposed to be altered by the parking lot relocation), because of its proximity to the mainland. For the most part, these concentrations consist of birds that have migrated long distances along the coast or over the ocean during the preceding night. They may be physiologically stressed and are searching for immediate shelter, protection from predators, and food, and are driven to congregate at the closest point of land to the mainland. On a typical flight day morning, hundreds or thousands of migrants will concentrate in the woodland/shrub-scrub habitat at Bayside Point, feeding and resting, and waiting for ideal conditions to cross the bay. Years of observations by birders and avian researchers have indicated that this concentration of birds is unique to the Bayside Point area and not found anywhere else on Assateague Island. Hence, the habitat at the Bayside Point provides a unique value to migratory birds fundamentally different from the habitat elsewhere on the peninsula.
2) The Bayside area has been the site of extensive avian monitoring demonstrating the significance of the woodland/shrub-scrub habitat at Bayside Point, however, these data are not considered in the EA.
Since 1990, the Maryland birding community has been monitoring migrant use of the Bayside area – and in particular the area of the proposed action. These observations provide a detailed assessment of avian use of the Bayside Point area and can help evaluate the scope of the impacts. Much of this information is available through the data repository eBird (www.ebird.org), sponsored by the Cornell Laboratory of Ornithology, or in data which has been previously provided to the NPS. A summary of the peak counts of migratory bird species at Bayside Point is provided below.
SPECIES NAME – DATE – NUMBER – COMMENTS
Yellow-bellied Sapsucker – 10/23/2005 – 20
Red-bellied Woodpecker – 10/5/2011 – 89 – eBird MD high count
Northern Flicker – 10/5/2011 – 800 – eBird MD high count
Eastern Kingbird – 8/23/2009 – 37
Philadelphia Vireo – 9/7/2006 – 4
Red-eyed Vireo – 9/8/2006 – 14
Red-breasted Nuthatch – 9/29/2007 – 108 – eBird MD high count
Brown Creeper – 10/13/2012 – 12
Golden-crowned Kinglet – 10/19/2009 – 50
Ruby-crowned Kinglet – 10/19/2009 – 15
Swainson’s Thrush – 10/12/2003 – 40
Hermit Thrush – 11/3/2006 – 25
American Robin – 11/6/2009 – 2,305
Gray Catbird – 8/17/2008 – 50
Brown Thrasher – 8/18/2008 – 20
Cedar Waxwing – 10/5/2011 – 300
Northern Waterthrush – 9/21/2006 – 9 – eBird MD high count
Black-and-white Warbler – 9/12/2009 – 14
Prothonotary Warbler – 9/8/2006 – 2
American Redstart – 9/14/1996 – 200 – eBird MD high count
Cape May Warbler – 9/29/2007 – 156 – eBird MD high count
Wilson’s Warbler – 9/21/2006 – 4
Northern Parula – 10/15/2011 – 13
Magnolia Warbler – 5/15/2010 – 125 – eBird MD high count
Bay-breasted Warbler – 5/15/2010 – 7
Blackburnian Warbler – 5/15/2010 – 19
Yellow Warbler – 8/9/2011 – 25
Chestnut-sided Warbler – 9/7/2006 – 2
Blackpoll Warbler – 5/15/2010 – 43
Black-throated Blue Warbler – 9/29/2007 – 41 – eBird MD high count
Palm Warbler – 10/16/2003 – 20
Yellow-rumped Warbler – 10/5/2011 – 1,000
Prairie Warbler – 9/4/2006 – 10
Black-throated Green Warbler – 9/29/2007 – 19
Yellow-breasted Chat – 5/13/1991 – 4
Scarlet Tanager – 9/21/2006 – 8
Rose-breasted Grosbeak – 9/21/2006 – 12
Blue Grosbeak – 5/15/2010 – 14
Indigo Bunting – 9/30/1994 – 100
Dickcissel – 10/12/2003 – 6
Bobolink – 9/10/2011 – 450
Orchard Oriole – 8/18/2008 – 10
Baltimore Oriole – 9/12/2009 – 125 – eBird MD high count
Purple Finch – 11/8/2003 – 8
As indicated above, for nine of these migratory species, the counts at the Bayside Point area represent the highest number of that species ever recorded in Maryland at a single location. Hence, it is incorrect to infer that destroying and fragmenting 50% of the woodland/shrub-scrub habitat there will have no impacts to migratory birds.
3) The selected alternative (B) is inconsistent with the fundamental goals of the project (page 7).
The EA (page 7) states one goal of the project is to “Maintain the current level of use and parking capacity for visitors at the Bayside Picnic … area.” Alternative B of the proposal related to Bayside would increase the number of parking spaces (from 63 to 87). The user facilities at Bayside Point are very limited (restrooms, 10–12 picnic tables [as stated in the EA, but in reality there are fewer picnic tables here], 6 grills, canoe launch). If the goal is to maintain the current level of use, it is not necessary to provide parking for 87 vehicles, including 12 oversized vehicles. Moreover, Alternative B would significantly increase the visitor capacity of the Bayside Picnic area (page 29): 8–10 picnic tables, a picnic pavilion, and 4–9 grills would be added to the public resources available.
Hence, Alternative B would almost double the visitor resources/footprint at the Bayside Point area – while the stated goal of the project is simply to maintain current amenities. This increase in visitor facilities is inconsistent with the stated desire (page 7) to limit the “footprint” of facilities on the Island. And, as stated above, another goal of the project (page 7) is to “Minimize harm to sensitive natural or cultural resources when removing and relocating the parking areas.” Given the substantial impacts on migratory bird habitat as detailed above, Alternative B is inconsistent with this objective as well.
4) Removal of a portion of the existing parking lot and restoration of habitat would not replace the value of the habitat lost in building the new parking lot.
Alternative B includes the removal of the northwest portion of the existing parking lot and allowing natural processes to revegetate a portion of this area. However, the area to be replaced by the new parking lot consists of many mature trees that provide high-energy fruit for migrants, including black cherry, red cedar, and numerous fruiting vines and shrubs. It would take decades for the revegetated area to reach the tree size and habitat condition of the areas to be destroyed by the alternative B. Additionally, a large portion of this area would be needed to support the increase in infrastructure identified on page 29, and as detailed in item #3.
5) Alternatives that would have lesser impact to migratory bird habitat were not fully considered.
The EA presents two options: (A) maintain the current parking area, or (B) create a new parking area by destroying two acres of woodland – shrub scrub habitat with a significant increase to the physical infrastructure. Additional alternatives must be considered, such as a reduction in size of the existing parking lot to address sustainability concerns, while limiting further impacts to natural habitat.
Indeed, an alternative that would be more appropriate to the stated goals of the plan and the mission of the National Park Service would be to preserve this important stopover habitat for migratory birds, develop strategies for protecting it from further destruction, and create an interpretive program to educate the public about its significance.
6) Additional time and opportunity for public input and comment on the proposed alternatives needs to be provided.
NPS has not scheduled any public meetings related to these proposals to seek public input. Assateague Island is a resource of national significance, and many of the individuals with extensive knowledge of the importance of the migratory bird habitat are not local residents. Timelines for public comment have been short.
In summary, the EA is inadequate in addressing the impacts of Alternative B related to the Bayside parking area, and Alternative B is contrary to the stated goals of the project plan and a core value of the National Park Service – to protect the very rare natural resources of this national treasure.