On October 11 DCR issued a communication encouraging all who care about the Fells to read and review and provide comments on the draft Resource Management Plan. The Friends of the Fells agrees. The best way to understand how DCR intends to manage the Fells is by looking directly at the details of each of the proposals found in the draft Fells RMP.
Here we respond to the DCR Questions and Clarifications section of the October 11 bulletin by printing actual text from the Fells DCR draft Resource Management Plan itself.
DCR: “Why does the RMP recommend closing 22 miles of trails at the Fells?”
Closing redundant, unauthorized, illegal, user-created trails to protect sensitive natural and cultural resources and reduce visitor confusion is essential, and this is a small start. Oddly, DCR’s RMP only recommend closing 9 miles of the 22 miles of illegal trails. The RMP should focus on closing illegal trails and should not be proposing to close existing legal trails like the Dark Hollow Pond Trail which simply need minor remediation, while simultaneously creating as many as three dedicated mountain bike trails in this Dark Hollow Pond section:
“6.9.2 Designate the 1-3 official trails within the Dark Hollow area for mountain bike use to provide enhanced mountain biking opportunities (RMP G4.10). This is also part of a strategy to provide a positive use to an area with unwanted activity (RMP G5.10).” [RMP, Appendix p. A-108 – also see map found on Appendix p. A-63 showing closed Dark Hollow Pond Trail]
Not only that, but the RMP states that budget shortfalls limits the ability to provide support for trail closures. Without such support – and enforcement – trail closures are quickly re-opened in the Fells.
G1.7. Fill DCR Middlesex Fells Reservation Forest and Park Supervisor II and Laborer I positions to provide support for trail closures. Resources level 3 – funding is currently unavailable, but may become so in more than five years. [RMP, p. 68]
G2.1. Close targeted redundant, confusing, fall-line and poor-condition trails in Zone 1 areas. Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 68]
DCR: “Does the RMP recommend expanding recreation or development at the DCR Middlesex Fells?”
DCR’s response is ‘no’ but the bulletin admits that its expansion of mountain biking and off leash dog recreation in the Fells “might be characterized as expansions.” DCR then claims that impacts from these will be minimized due to recommendations for expanded enforcement and protection. But the actual text of the draft Fells RMP shows that due to lack of funding, increased enforcement and DCR personnel for resource protection in the Fells are merely empty promises.
G1.10. Enforce dog-owners properly picking up and disposing of dog waste. Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 68]
G1.12. Implement additional recommendations to protect water supplies, wetlands and vernal pools as detailed in Appendix N, Trail System Plan. Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 68]
G2.3. Enforce prohibition on off-trail recreation (unless specifically permitted). Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 68]
G2.10. Fill the Natural Resource Specialist position to provide support for habitat management, trail closures and species protection. Resources level 3 – funding is currently unavailable, but may become so in more than five years.”[RMP, p. 69]
G3.1. Increase staff awareness and protection of cultural resources through participation in workshops and training offered by the DCR‟s Office of Cultural Resources. Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]
G3.1. Increase staff awareness and protection of cultural resources through participation in workshops and training offered by the DCR‟s Office of Cultural Resources. Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]
G3. 2. Conduct an archaeological survey of the reservation to evaluate the significance of known and potential archaeological and historic sites. Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]
G3.3. Development of a Cultural Resource Protection Plan based on the above survey. Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]
G3.4. Develop a seasonal monitoring program to address human and natural impacts to these archaeological resources. Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]
G4.7. Enforce leash regulations outside of official designated areas and circumstances, and enforce a 3-dog per person limit. Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 70]
G4.12. Enforce no biking on / in pedestrian only trails and areas. Resources level 2 – funding is currently unavailable, but may become so in the near future;[RMP, p. 70]
G5.3. Provide two additional long-term seasonal rangers for the Fells District. Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 70]
DCR: Does the RMP recommend allowing dogs off-leash on trails in the Fells?
DCR’s response is ‘no’ saying there is no “recommendation” for off-leash dogs on trails, but the Fells RMP does outline clear options for authorizing and permitting additional loose dog access to Fells trails, including permitting professional dog walking. The only requirement for implementing these options for allowing dogs off-leash on trails is an undefined commitment of a dog owner stakeholder group, as sections of RMP confirm:
“The team identified the need for strict enforcement of a 3-dog limit per person and that commercial dog walking should require permits.”
“In evaluating options for recreation with dogs at the Fells, the RMP team considered the following:
• Options for providing a single designated off- leash trail, or set of trails, for dogs under voice control
• Options for designating “courtesy hours,” when dogs would be allowed off-leash under voice control on trails at certain times, but would require leashes at all other times (i.e., dawn to 9 a.m.)
• Options for creating a certified dog program that would be managed by a third party and that would allow dogs who could demonstrate that they could follow required behaviors and be under full voice control to be off-leash in the Fells” [RMP, p. 63]
“6.10.2 Consider development of a “certified dog” program that would allow dogs under full voice control of their owners on an additional set of trails in the Fells (RMP G4.6).” [RMP, Appendix – A-108]
“The team agreed that, with respect to both a designated off-leash area at the Sheepfold and any potential future off-leash opportunities, a significant commitment and potential capital investment from a stakeholder group, such as FellsDog, would be a necessary component.” [RMP, p. 63]
DCR: “Does the RMP recommend any provisions for increased enforcement, fines or management presence in the Middlesex Fells?”
DCR says ‘yes’ but in truth it isn’t just the lack of funding for DCR enforcement and management personnel that renders DCR impotent to protect resources and visitors. While the RMP states that there will be “Citations or increased fines for violations of rules and regulations” nowhere in the document is it admitted that DCR lacks the legal ability to enforce payment of fines for infractions of park rules and regulations. The RMP states that “the Massachusetts State Police which has primary law enforcement on state-owned lands” (RMP, p. 44), but the State Police do not patrol interior trails in the Fells.
DCR essentially throws in the towel when it comes to enforcement capability. Admitting decades of minimal enforcement of regulations in the Fells, the RMP then declares that in the face of non-compliance the easiest thing to do is just to change the rules:
“Enforcement of these rules and regulations at the reservation has been minimal. Resources for enforcement are limited and the lack of obvious consequences to breaking rules for oneself or others fosters an attitude of non-compliance in the Fells… However, one common-sense element of a larger compliance strategy is to better align recreational demands with rules and legal opportunities as a way to encourage greater self-compliance.” [RMP, p. 59]
“DCR has also been reluctant to strictly enforce leash regulations given the public demand for legal off-leash recreational opportunities.” [RMP, p. 64]
DCR: “Does the RMP recommend that most trails in the Fells will be open to mountain bike use and only two short trails will be pedestrian only?”
While the DCR Fells RMP may not “recommend” opening more than an additional 13 miles of hiking trails to bike use, the RMP actually provides a blue print for permitting considerable additional bike access. With the lack of enforcement detailed above, this will encourage an expansion of illegal bike use throughout the Fells.
- Increasing bike access to hiking trails includes converting the Reservoir Trail in the Winchester section of the Fells to bike use. [RMP, p. 60]
- Creating a new Flynn Rink to Quarter Mile Pond bike access trail. [RMP, p. 60]
- Designating “All or some” of the Rock Circuit Trail for bike use : “6.9.3 Consider designating single-track trails and areas in the eastern Fells as multi-use, including all or some of the Rock Circuit Trail, to provide more advanced mountain biking opportunities on sustainable surfaces and disperse biking from the western Fells (RMP G4.11).” ).” [RMP, Appendix – A-108]
- Creating 1-3 new “official” bike trails in Dark Hollow Pond area: “6.9.2 Designate the 1-3 official trails within the Dark Hollow area for mountain bike use to provide enhanced mountain biking.” [RMP, Appendix – A-108]
- And converting “additional trails” in the Eastern Fells: “the team recommended designating some additional single-track trails in the eastern Fells in the future.” [RMP, p. 60]
DCR: What is the purpose of avoiding activities around, or a survey of, all “level, well-drained areas around ponds or wetlands?”
While it appears DCR is proposing protective policies for wetlands and Vernal Pools in the Fells, in truth DCR lacks the ability to prevent off-leash dogs from an all too common activity; “However, off-leash dogs have been observed entering vernal pools at the Fells. This has the potential to disturb or dislodge amphibian egg masses within the pool during breeding season…” [RMP, p. 61]
Without Fells ranger staff the agency cannot make good on the promise found in the RMP to “Close trail segments that go through or are eroding into vernal pools.” [RMP, p. ix]
In addition, only half of the 129 Vernal Pools in the Fells are protected with Zone 1 status. Additional areas of Zone 1 are required to protect large clusters of Vernal Pools in the Long Pond area and
the southeastern portion of the Fells. [RMP, p. 10]
DCR: Will changes be made to the draft plan before it is approved?
Despite the promise of responsiveness contained in the DCR bulletin, past practice regarding last year’s DCR Fells Trails Plan shows that the agency’s response to comments has mainly been to staunchly defend what has been presented in the DCR draft proposals.
Thorough review of the draft DCR Fells Resource Management Plan reveals its core problem. It plans to deliver increased loose dog and bike access in the Fells Reservation, while basing the great majority its resource and visitor protection measures on unfunded promises, at a time when DCR’s budget is slashed to its lowest level in history.
DCR has it exactly backwards. Resource protection and public safety should come first. Conservation is the agency’s primary responsibility. It absolutely makes no sense for DCR to increase potentially harmful access to already impacted Fells resources when the agency has not demonstrated capacity for remediation and enforcement, yet this is exactly what the draft Fells RMP proposes.
Last year the Sierra Club stated in a letter to DCR, “DCR must take actions to protect the resource and the safety of visitors prior to expansion of use or designation of any further trails as “multi-use” at the Fells.”
And Mass Audubon also wrote, “DCR should not take on extensive new trails or expanded uses at the Fells until it can manage the existing trails and uses. After sensitive area damage has been contained and addressed, DCR could consider implementing recreational enhancements consistent with the RMP, with cooperation of all user groups.”
Write Today: Please write DCR today.
Convey to the agency that protection of nature and provisions for safety of the general public must come before expansion of recreation access and uses.
The Fells Resource Management Plan must be revised. Tell DCR that they must:
- Create effective programs to repair and protect Fells resources before any expansion of recreational access.
- Provide and implement a funded plan for effective Fells enforcement staffing and trail-use management.
- Protect all sensitive natural areas in the Fells, including Vernal Pools throughout the Reservation.
Email DCR: rmp.comments@state.ma.us
or mail to: Fells RMP Comments, 136 Damon Rd., Northampton, MA 01060
The entire DCR Fells RMP may be viewed here:
http://www.mass.gov/dcr/stewardship/rmp/downloads/midfells/rmp-midfellls.pdf
Thank You!
Friends of the Middlesex Fells Reservation 235 West Foster Street, Melrose, MA 02176
