National Park Service

ORV PROPOSED RULE (RIN 1024-AD85) 

 

Virginia Coastal Access Now (VCAN) is our 501C3 non-profit group that represents the public, recreational anglers, and environmental advocates working to maintain and enhance the public’s access to Virginia’s beaches and waterways within the Commonwealth of Virginia’s coastal zone. VCAN was formed as a result of the continued loss of public access to Virginia’s coast.  With a membership of 300 plus, interest and participation in Access issues on North Carolina’s coast have become inevitable.  Many of our members are longtime visitors to the Cape Hatteras National Seashore Recreational Area.  We appreciate the opportunity to comment on the ORV PROPOSED RULE (RIN 1024-AD85).

 

Comments regarding this rulemaking process

 

Before making comment on aspects of the proposed rule, VCAN believes this entire public rulemaking process has been rife with flaws.  These flaws include but are not limited to:

·         a failed Negotiated Rulemaking (Reg/Neg) process that was unable to reach any consensus;

·         abandonment of the National Environmental Policy Act (NEPA) vetted Interim Management Strategy (IMS);

·         a consent decree that has instituted new/current rules with no public input;

·         questionable “best available” science used to justify these rules;

·         these new/current rules and the questionable “best available” science being used as the basis for all action alternatives in the Draft Environmental Impact Statement (DEIS);

·         public comment period on DEIS alternatives being conducted while the socio-economic analysis is incomplete and unfinished;

·         incomplete impact assessment of Traditional Cultural Properties;

·         cost/benefit analysis mentioned in the proposed rule is not available to the public;

·         and the use of an informal name on all official documents instead of Cape Hatteras National Seashore Recreational Area (CHNSRA).