The Delaware Chapter of the Sierra Club finds value in the approach adopted by the U.S. Fish and Wildlife Service for the future management of the Prime Hook Natural Wildlife Refuge.  The CCP provides an assessment of ecological conditions within the Refuge and its watershed.  An extensive amount of research was compiled in the CCP in excess of one thousand pages, including archaeological uses dating back to the Paleo-Indian Period, vegetation communities, habitat and biological resources.  The CCP also presents a historic description of the Refuge as a built landscape.  A history of farming, impoundments and drainage ditches modified the landscape prior to its acquisition by the U.S. Fish and Wildlife Service.  The Service intentionally increased some of these manipulations and allowed others to continue.

However, we have concerns about the assumptions that inform this document and some of the alternatives under consideration.

We support planning for climate change.

Climate change is the largest threat that our natural heritage has ever faced. The effects of climate disruption are already being felt on even our most pristine landscapes. Setting aside areas where development is restricted is no longer enough — we must now actively work to create resilient habitats where plants, animals, and people are able to survive and thrive on a warmer planet. 

The threats of climate change and sea level rise are being felt locally in Delaware.  The CCP illustrates, in a time-series of aerial photographs dating back to 1937, a history of dune overwash and changes to the barrier island beach.  Furthermore, the shoreline at Prime Hook NWF has retreated 500 feet between 1926 and 2011.  Sea level rise is only part of the coastal dynamics at Prime Hook, but it is expected to get worse.  The Prime Hook NWF presents the first major challenge in addressing sea level rise for wildlife habitat management in Delaware.  We understand the need for such planning and commend the U.S. Fish and Wildlife Service for taking steps to plan for climate change to meet the future needs of wildlife habitat in Delaware.

We support a long-view to environmental planning.

The key to wildlife and native plant conservation is the continued existence of diverse natural ecosystems and the preservation of native biodiversity. The Sierra Club is committed to maintaining the world's remaining natural ecosystems, and, where feasible, to the restoration and rehabilitation of degraded ecosystems. Wildlife, plants, and their ecosystems have value in their own right, as well as value to humans and to the health of the biosphere.

Habitat simplification, fragmentation, degradation, and elimination pose the greatest threats to natural ecosystems and biodiversity and must be counteracted by reasonable and effective measures for the long-term preservation of intact ecosystems.  Such measures should be incorporated into decisions made by all levels of government.  We must develop and implement wildlife and native plant conservation measures that protect ecosystems and our wildlife heritage.

The Sierra Club advocates a consistent public policy to preserve and restore the hydrologic, biologic, and aesthetic values of wetlands as public assets.  We place highest priority on the protection of natural wetlands.  Because our goal is to reverse, not merely slow, the trend of vegetated wetlands destruction and degradation, we also support restoration of degraded wetlands.  Wetlands protection should be promoted further by increased public understanding and enjoyment of wetland values through compatible uses.

We understand that the purpose of the CCP is for the management of the refuge within its designated mission and purpose over a period of the next fifteen years.  However, given the scale of sea level rise that the CCP seeks to address, fifteen years is an inadequate time frame to consider the long-term wildlife and habitat needs.  We encourage the U.S. Fish and Wildlife Service to look beyond the immediate concerns presented in the CCP and consider a long-term strategy to habitat and wildlife protection.

For example, the CCP should include a strategy for acquiring additional lands in the refuge for protection as wildlife habitat to replace land and habitat lost to sea level rise in the coming decades.  As the eastern portions of the refuge are flooded by sea level rise, the Service should prepare for facilitating a natural transition of ecosystem communities and a plan for a landward transgression of protected forests and wetlands.

We support the preservation of native ecosystem diversity and endangered species.

Within natural ecosystems, natural diversity and abundance of wildlife and plants should be ensured by means that involve a minimum of overt human interference.  Ecosystems modified by human activities should be managed to ensure optimum native diversity and numbers of wildlife and plants to natural historic levels where feasible, with emphasis on restoration and rehabilitation of degraded ecosystems to a more natural condition.

Because of species' value to ecosystems and to humans and for their intrinsic values, every effort should be made to prevent the extinction of species due to human activities. The Sierra Club vigorously supports strong and vibrant recovery programs that protect wildlife, plants, and natural ecosystems.

We support the Service’s proposal to restore areas of the Refuge to a more natural salt marsh, which will allow natural sediment accretion to occur.  Doing so has the potential to create a more sustainable habitat that is better-equipped to adapt to rising sea levels in the future. 

We support proactively restoring forest in the Refuge as habitat for endangered species, including the Delmarva Fox Squirrel as provided in Alternative B.  Promoting a diversity of native forest types within the refuge would provide valuable habitat for endangered and other native species. 

Promoting native habitat is especially important where wetland migration will occur, and is needed to ensure that natural habitat is established.  Without intentional management of native wetlands, unmanaged areas will likely be dominated with invasive species.

We support chemical-free mosquito control.

The Sierra Club advocates for alternatives to mosquito and other pest control systems which fill, contaminate, or otherwise significantly impede wetland functions, or interrupt the aquatic food chain.  We support the elimination in the use of adulticides in the CCP, and we encourage the Service to discontinue the use of all pesticides for mosquito control.  Natural pesticide management measures, including the restoration of native habitats that include mosquitos’ natural predators, are encouraged.