DEPARTMENT OF ENVIRONMENTAL PROTECTION

DIVISION OF RECREATION AND PARKS

OFFICE OF PARK PLANNING

ELLIE SCHILLER HOMOSASSA

SPRINGS WILDLIFE STATE PARK

PUBLIC COMMENTS

From: David BrownTo: FLStateParkPlanningSubject: Homosassa Springs Wildlife ParkDate: Saturday, July 27, 2019 2:01:44 PM

I would like to suggest that we raise admission price by $1 for the upcoming year. This should not result in anyreduction in attendance as the raise is demimus to the general public. It was mentioned that the attendance is313,000 annually. This should generate approximately $300,000 in annual additional revenue. I would furtherpropose that all these monies go directly to the park for a period of five years to pay for all the park improvements. Total generated would be approximately $1,500,000. At the end of five years, the additional revenue would go tothe state. This would positively impact the park and have no negative impact on the State of Florida.

Thank you.David Brown

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Florida Office P.O. Box 7566 | St. Petersburg, Florida 33734 Telephone: 727.823.3888 www.defenders.org

National Headquarters | 1130 17th Street, N.W. | Washington, D.C. | tel 202.682.9400 | fax 202.682.1331| www.defenders.org

August 7, 2019 Zachary Phifer Park Manager Ellie Schiller Homosassa Springs Wildlife State Park Division of Recreation and Parks Florida Department of Environmental Protection 4150 South Suncoast Boulevard Homosassa, Florida 34446 Submitted electronically via email Re: Ellie Schiller Homosassa Springs Wildlife State Park July 2019 Draft Unit Management Plan Dear Mr. Phifer, Defenders of Wildlife (Defenders) appreciates the opportunity to provide comments to the Division of Recreation and Parks of the Florida Department of Environmental Protection (“Parks Division” of “FDEP”) on the Ellie Schiller Homosassa Springs Wildlife State Park July 2019 Draft Unit Management Plan (“Draft UMP”). Founded in 1947, Defenders of Wildlife is a national non-profit conservation organization focused on conserving and restoring native species and their habitats across the country. Based in Washington, DC, the organization also maintains six regional field offices and represents more than 1.8 million members and supporters in the United States and around the world, including nearly 130,000 in Florida. Accordingly, Defenders hereby submits these comments on behalf of thousands of Floridians dedicated to the conservation of native species and their habitats. Defenders respectfully requests that the Parks Division incorporates the following items into the Final Unit Management Plan for Ellie Schiller Homosassa Springs Wildlife State Park (“Final UMP” for the “Park”): 1) periodic review of and, when warranted, extension of the winter period when wild manatees are allowed access to the main spring boil; 2) a mandate that all proposed construction activities are performed outside of the winter period when wild manatees take refuge in the main spring boil; 3) hurricane preparation and mitigation measures to protect the wild and captive manatees that utilize the Park; 4) reconsideration of the Park’s provision of veterinary care for manatees; and 5) a mandate that muck and invasive plant removal activities, as well as experimental plantings of native submerged aquatic vegetation (SAV), are to be conducted sustainably and in a manner that is minimally disruptive to wild manatees and supportive of water quality protection. Defenders appreciates that the Parks Division opens the barrier fence to the main spring boil from November 15th to the end of March every year so that wild manatees are able to access the warm waters therein (Draft UMP at 55). Due to seasonal temperature fluctuations occurring with climate change and manatees’ propensity to cold stress (see: Edwards, Potential impacts of climate change on

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warmwater megafauna: the Florida manatee example, J. Climate Change, 2013), Defenders recommends that the Final UMP should mandate that the amount of time that this barrier fence remains open must be increased, when necessary, in consultation with pertinent agencies and stakeholders (e.g. the Florida Fish and Wildlife Conservation Commission (“FWC”), USFWS, and relevant wildlife protection organizations that monitor manatee activity) to account for actual length, temperature, and wild manatee usage of the Park. This will ensure that wild manatees are able to access this crucial warm water habitat for as long as needed, taking into account winter weather that may be longer and/or cooler than in years past. Of additional relevance to winter manatee congregation, Defenders posits that the Final UMP should require that the several renovation and/or construction activities outlined on pages 82 – 90 of the Draft UMP be completed outside of the winter period when wild manatees take refuge in the main spring boil (adjusted when necessary, as discussed above) in order to minimize noise, debris, pollution, vehicle presence, and other potential disruption to the manatees. Access to winter warm water refugia is an issue of ever-increasing importance to the survival of the Florida Manatee (see: Laist et. al, Winter Habitat Preferences for Florida Manatees and Vulnerability to Cold, PLoS ONE 8(3), 2013), and, as the Draft UMP notes, Homosassa Springs and the spring run are important winter refuge for “more than 100 manatees.” (see: Draft UMP at 1.) Accordingly, Defenders urges the Parks Division to avoid any wintertime construction and renovation activity, especially activity occurring in or near the water (e.g. “Fishbowl” renovation), to avoid any disruption whatsoever to this important wild manatee refuge. Defenders acknowledges and appreciates that FWC promulgates manatee safety guidelines to recipients of permits, such as those for in-water construction work (FWC, Standard Manatee Conditions for In-Water Work, 2011), and encourages the Parks Division to consider the magnitude of manatee congregation at this site and accordingly keep all construction activity to months outside of the sensitive winter months. Another climate change impact of crucial importance to manatees is likely increased frequency and severity of storm systems, e.g. hurricanes and tropical storms (see: Edwards, 2013); therefore, Defenders encourages the Parks Division to delineate relevant preparation and mitigation procedures and projects in the Final UMP. Defenders appreciates that the Parks Division acknowledges sea level rise as a Special Management Consideration in the Draft UMP (see: page 68) and encourages the Parks Division to incorporate existing data about this and other climate change impacts to outline specific policies, procedures, and goals in the Final UMP (the term “climate change” is absent from the Draft UMP, and Defenders respectfully notes that this is not reflective of the actual climate sensitivity of the Park and its ecosystem). An incident report from October 2017 highlights a pertinent example of need for storm preparation: following Hurricane Irma, “higher than normal flood waters” made the Park’s hippopotamus enclosure accessible via metal spillway grates to a manatee in rehabilitation named Gleewood, who was found on her back on the beach in the hippopotamus enclosure. (see: Parks Division, Summary Report for Incident on 10-7-17, accessed from The Citrus Chronicle.) Defenders appreciates that the Park took swift, remedial action for this particular incident and — as rising water levels are a highly foreseeable impact of future severe storm systems — strongly encourages the Park to define specific processes, procedures, and projects in the Final UMP to prevent further incidents connected to sea level rise and other consequences of hurricanes. Defenders additionally requests that the Parks Division reconsiders its primary provider of veterinary care for its resident and rehabilitation manatees. The Draft UMP states that: “Assistance with manatee care is provided by Dr. Ray Ball,” and continues to note his involvement in the Park’s

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Manatee Rescue, Rehabilitation, and Release Program, set up by USFWS. (see: Draft UMP at 54.) Defenders has concerns due to Dr. Ball being the subject of a recent veterinary panel review and USFWS investigation for veterinary malpractice. (Carly Zervis, Report: Decision to feed hay to manatees at Homosassa park may have contributed to death of Lorelei, The Citrus Chronicle, December 14, 2018; Craig Pittman, Vet for Tampa zoo accused of killing manatees through malpractice, The Tampa Bay Times, November 1, 2018.) Some of the practices for which Dr. Ball was investigated included, but are not limited to: feeding of hay to manatees, improperly conducted “chest taps” (in which needles are stuck into a manatee’s chest to determine the size of a puncture in a lung), in-field amputations of manatees’ flippers without treatment for infection or pain and subsequent release with exposed bones; and use of experimental drugs and/or experimental methods of administering drugs. (id.) The Citrus Chronicle article notes that while Dr. Ray Ball was permitted to return to ZooTampa and care for animals, his oversight role for manatee care was revoked and transferred to a different veterinarian. Defenders thus questions whether Dr. Ball should be permitted to oversee veterinary care for the Park’s manatees, a federally-listed threatened species, and accordingly encourages the Parks Division to similarly transfer responsibility to a different veterinarian and establish safeguards in the Final UMP to ensure that resident and rehab manatees receive optimum veterinary care. As a final matter, Defenders encourages the Parks Division to include mandates in the Final UMP to ensure that any potential sediment removal, experimental plantings of native SAV, and aquatic invasive plant removal are to be conducted sustainably and in a manner that is minimally disruptive to wild manatees and supportive of water quality protection. The Draft UMP notes in its objective to “restore natural hydrological conditions and function to approximately 4.35 acres of Spring Run” that the Parks Division will “evaluate the feasibility of conducting experimental SAV plantings in the spring and spring-run stream.” (Draft UMP at 38.) The Draft UMP also states that, in 2006, over 12,000 cubic yards of unnatural sediments were removed from Homosassa Spring “to benefit all aquatic organisms, including manatees.” Defenders generally appreciates the restorative intent of these efforts. However, if there are to be any further, similar sediment removal activities, including in support of SAV plantings, Defenders encourages the Parks Division to avoid ecologically disruptive dredging activities to the greatest extent possible. Additionally, Defenders encourages the Parks Division to give serious consideration to water quality in selecting methods for the Exotic Species Management Program, especially in determining the appropriateness of herbicide. (Draft UMP at 61). When aquatic vegetation is controlled by herbicide, the plants will often die, settling to the bottom of water bodies and decomposing, robbing the water of necessary oxygen; accordingly, Defenders encourages the Parks Division to consider water quality in invasive plant removal methods. In sum, Defenders respectfully requests that the Parks Division incorporates the following items in the final UMP: 1) a mechanism to extend the winter period when wild manatees are allowed access to the main spring boil; 2) a mandate that all proposed construction activities are performed outside of the winter period when wild manatees take refuge in the main spring boil; 3) hurricane preparation and mitigation measures to protect the wild and captive manatees that utilize the Park; 4) revised veterinary care direction and oversight; and 5) a mandate that muck and invasive plant removal activities, as well as experimental plantings of native submerged aquatic vegetation (SAV) are to be conducted sustainably, particularly without highly disruptive dredging activities.

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Please feel free to contact the undersigned with any questions. Thank you for your consideration. Sincerely, Elizabeth Leigh Neville, Esq. Manatee Advocate Defenders of Wildlife