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	<title>FELLS BIKING PROBLEM</title>
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	<description>DCR WRONG - BIKES TEARING UP PARK</description>
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		<title>Beware of Biking Proposal At Fells</title>
		<link>http://fellsforever.org/2011/11/10/beware_bike_proposal_at_fell/</link>
		<comments>http://fellsforever.org/2011/11/10/beware_bike_proposal_at_fell/#comments</comments>
		<pubDate>Thu, 10 Nov 2011 06:50:16 +0000</pubDate>
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		<description><![CDATA[Beware of Biking Proposal At Fells Melrose Free Press Posted Nov 08, 2011 @ 08:59 PM To the editor: Twenty-year-old restrictions against mountain biking at the Middlesex Fells, put into place because of alarm over serious mountain biking-related trail damage, would be mostly eliminated if no changes are made to a draft DCR Resource Management [...]]]></description>
				<content:encoded><![CDATA[<p>Beware of Biking Proposal At Fells</p>
<div><a href="http://www.wickedlocal.com/melrose">Melrose Free Press</a></div>
<div title="2011-11-08T20:59:44Z">Posted Nov 08, 2011 @ 08:59 PM</div>
<div>
<div>To the editor: Twenty-year-old restrictions against mountain biking at the Middlesex Fells, put into place because of alarm over serious mountain biking-related trail damage, would be mostly eliminated if no changes are made to a draft DCR Resource Management Plan presented by the DCR on Sept 14. Changes proposed by the DCR in the plan include the creation of three new bike-only trails in the Dark Hollow area; the conversion of the Reservoir Trail, and other trails in the Eastern Fells, to bike access trails; and the creation of new trail from the Flynn Rink to Quarter Mile pond. And bikers will also still have full access to all fire roads and the mountain bike loop. These are major changes. They go against the judgment of every previous DCR/MDC park administration of the last 20 years. They will impact not only the Middlesex Fells, but other DCR properties as well. Furthermore, there is evidence that these changes will be used to justify biking elsewhere. This may be why bikers have packed every RMP planning meeting during the last year, vastly outnumbering every other user group. Changes of this magnitude need to be properly justified, and yet this has NOT been done in the RMP, which selectively cites “available ecological literature” and questionable DCR observations at the Fells to justify a new view that “the magnitude of impacts from biking is similar that of hiking and the two uses should be treated similarly.” However the available “ecological literature” is sparse. Gary Sprung, former president of the International Mountain Bike Association wrote: “as of 2003, only two empirical studies have scientifically compared the erosion impacts of bicycling with other forms of trail travel.” And little research has been done since. The very first study cited by the DCR was 18 years old and funded by the International Mountain Bike Association and it doesn’t say what the DCR claims it did. The second study was conducted down a hillside so steep hikers sometimes slipped and slid completely out of the study area. A third study cited was a survey of bike trail widths in remote areas of New Mexico and Arizona and not a comparative study at all. The fourth found similar impact on flat roads, but more impact from bikes on hillsides and wetland area. And this is being used to justify biking in the Middlesex Fells? The studies cited by the DCR are irrelevant. You can read more about them on my website fellsforever.org. “Close review of these studies shows that they lack relevance for decision-making regarding trail use in the Middlesex Fells Reservation (MFR),” writes Dr. Richard Eilbert, a recently retired Harvard educated physicist who examined the studies. “The locations and conditions studied bear little resemblance to site factors found in the MFR.” I don’t believe this major bike policy change has been properly justified by the DCR, and therefore plans for new bike trails at the Middlesex Fells as described in the draft RMP should not be included in the final plan. — <strong>Steve Gyurina, West Wyoming Ave, Melrose</strong></div>
</div>
<p>Read more: <a href="http://www.wickedlocal.com/melrose/news/opinions/letters/x1439480846/Letter-Beware-of-biking-proposal-at-Fells#ixzz1dHZ5bXnK">Letter: Beware of biking proposal at Fells &#8211; Melrose, Massachusetts &#8211; Melrose Free Press</a> <a href="http://www.wickedlocal.com/melrose/news/opinions/letters/x1439480846/Letter-Beware-of-biking-proposal-at-Fells#ixzz1dHZ5bXnK">http://www.wickedlocal.com/melrose/news/opinions/letters/x1439480846/Letter-Beware-of-biking-proposal-at-Fells#ixzz1dHZ5bXnK</a></p>
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		<title>Friends of the Fells looks at DCR October 11 RMP Update</title>
		<link>http://fellsforever.org/2011/11/05/rmp-update/</link>
		<comments>http://fellsforever.org/2011/11/05/rmp-update/#comments</comments>
		<pubDate>Sat, 05 Nov 2011 14:51:07 +0000</pubDate>
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		<description><![CDATA[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 [...]]]></description>
				<content:encoded><![CDATA[<p>On October 11 DCR issued a communication encouraging all who care about the Fells to <strong>read and review</strong> and provide comments on the draft Resource Management Plan.  <strong>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 <a href="http://www.mass.gov/dcr/stewardship/rmp/downloads/midfells/rmp-midfellls.pdf" rel="" class="mtli_attachment mtli_pdf">Fells RMP</a>.</strong></p>
<p>Here we respond to the DCR <strong>Questions and Clarifications </strong>section of the October 11 bulletin by printing <strong>actual text</strong> from the Fells DCR draft Resource Management Plan itself.</p>
<p align="center"><strong><em>DCR: “Why does the RMP recommend closing 22 miles of trails at the Fells?”</em></strong></p>
<p>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 <strong>should</strong> focus on closing illegal trails and should <strong>not</strong> be proposing to close existing <strong><em>legal</em></strong> trails like the Dark Hollow Pond Trail which simply need minor remediation, while simultaneously <em>creating</em> as many as <em>three</em> dedicated mountain bike trails in this Dark Hollow Pond section:</p>
<p>“<strong>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).” </strong>[RMP, Appendix p. A-108 – also see <strong>map</strong> found on Appendix p. A-63 showing closed Dark Hollow Pond Trail]</p>
<p>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.</p>
<p><strong>G1.7. Fill DCR Middlesex Fells Reservation Forest and Park Supervisor II and Laborer I positions to provide support for trail closures</strong>.  Resources level 3 – funding is currently unavailable, but may become so in more than five years.  [RMP, p. 68]</p>
<p><strong> </strong></p>
<p><strong>G2.1. Close targeted redundant, confusing, fall-line and poor-condition trails in Zone 1 areas. </strong>Resources level 2 –funding is currently unavailable, but may become so in the near future; [RMP, p. 68]</p>
<p>&nbsp;</p>
<p align="center"><strong><em>DCR: “Does the RMP recommend expanding recreation or development at the DCR Middlesex Fells?”</em></strong></p>
<p>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<em> </em>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.<em> </em></p>
<p><strong>G1.10. Enforce dog-owners properly picking up and disposing of dog waste.  </strong>Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 68]</p>
<p><strong> </strong></p>
<p><strong>G1.12. Implement additional recommendations to protect water supplies, wetlands and vernal pools as detailed in Appendix N, Trail System Plan. </strong>Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 68]</p>
<p><strong> </strong></p>
<p><strong>G2.3. Enforce prohibition on off-trail recreation (unless specifically permitted). </strong>Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 68]</p>
<p><strong> </strong></p>
<p><strong>G2.10. Fill the Natural Resource Specialist position to provide support for habitat management, trail closures and species protection.  </strong>Resources level 3 – funding is currently unavailable, but may become so in more than five years.”[RMP,  p. 69]</p>
<p><strong> </strong></p>
<p><strong>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.  </strong>Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]</p>
<p><strong> </strong></p>
<p><strong>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. </strong>Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]</p>
<p><strong> </strong></p>
<p><strong>G3. 2. Conduct an archaeological survey of the reservation to evaluate the significance of known and potential archaeological and historic sites</strong>. Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]</p>
<p><strong> </strong></p>
<p><strong>G3.3. Development of a Cultural Resource Protection Plan based on the above survey. </strong>Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]<strong></strong></p>
<p><strong> </strong></p>
<p><strong>G3.4. Develop a seasonal monitoring program to address human and natural impacts to these archaeological resources. </strong>Resources level 3 – funding is currently unavailable, but may become so in more than five years.” [RMP, p. 69]</p>
<p>&nbsp;</p>
<p><strong>G4.7. Enforce leash regulations outside of official designated areas and circumstances, and enforce a 3-dog per person limit. </strong>Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 70]</p>
<p><strong> </strong></p>
<p><strong>G4.12. Enforce no biking on / in pedestrian only trails and areas.</strong> Resources level 2 – funding is currently unavailable, but may become so in the near future;[RMP, p. 70]<strong></strong></p>
<p>&nbsp;</p>
<p><strong>G5.3. Provide two additional long-term seasonal rangers for the Fells District.</strong>  Resources level 2 – funding is currently unavailable, but may become so in the near future; [RMP, p. 70]</p>
<p><strong> </strong></p>
<p align="center"><strong><em>DCR: Does the RMP recommend allowing dogs off-leash on trails in the Fells?</em></strong></p>
<p>DCR’s response is ‘no’ saying there is no “recommendation” for off-leash dogs on trails, <strong>but</strong> the Fells RMP <strong>does</strong> outline clear options for authorizing and permitting additional loose dog access to Fells trails, <strong><em>including permitting professional dog walking</em></strong>. The<em>only</em> requirement for implementing these options for allowing dogs off-leash on trails is an <em>undefined</em> commitment of a dog owner stakeholder group, as sections of RMP confirm:</p>
<p><strong>“The team identified the need for strict enforcement of a 3-dog limit per person and that commercial dog walking should require permits.”</strong></p>
<p><strong>“In evaluating options for recreation with dogs at the Fells, the RMP team considered the following:</strong></p>
<p><strong>• Options for providing a single designated off- leash trail, or set of trails, for dogs under voice control</strong></p>
<p><strong>• 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.)</strong></p>
<p><strong>• 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”  </strong>[RMP, p. 63]<strong></strong></p>
<p><strong>“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).”  </strong>[RMP, Appendix – A-108]</p>
<p><strong>“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.”  </strong>[RMP, p. 63]</p>
<p align="center"><strong><em> </em></strong></p>
<p align="center"><strong><em>DCR:  “Does the RMP recommend any provisions for increased enforcement, fines or management presence in the Middlesex Fells?”</em></strong></p>
<p>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 “<em>Citations or increased fines for violations of rules and regulations”</em> 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 <strong>“the Massachusetts State Police which has primary law enforcement on state-owned lands” </strong>(RMP, p. 44), but the State Police do not patrol interior trails in the Fells.</p>
<p>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:</p>
<p>&nbsp;</p>
<p><strong>“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…</strong><strong> 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.”  </strong>[RMP, p. 59]</p>
<p><strong> </strong></p>
<p><strong>“DCR has also been reluctant to strictly enforce leash regulations given the public demand for legal off-leash recreational opportunities.”  </strong>[RMP, p. 64]</p>
<p>&nbsp;</p>
<p align="center"><strong><em> 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?”</em></strong></p>
<p>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.</p>
<ul>
<li><strong>Increasing bike access to hiking trails includes converting the</strong> <strong>Reservoir Trail in the Winchester section of the Fells to bike use</strong>. [RMP, p. 60]<strong></strong></li>
<li><strong>Creating a new Flynn Rink to Quarter Mile Pond bike access trail. </strong>[RMP, p. 60]<strong></strong></li>
<li><strong>Designating &#8220;All or some&#8221; of the Rock Circuit Trail for bike use</strong> <strong>: “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).”  ).”  </strong>[RMP, Appendix – A-108]<strong></strong></li>
<li><strong>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.” </strong>[RMP, Appendix – A-108]<strong></strong></li>
<li><strong>And converting &#8220;additional trails&#8221; in the Eastern Fells: “the team recommended designating some additional single-track trails in the eastern Fells in the future.”  </strong>[RMP, p. 60]</li>
</ul>
<p>&nbsp;</p>
<p align="center"><strong><em>DCR: What is the purpose of avoiding activities around, or a survey of, all “level, well-drained areas around ponds or wetlands?”</em></strong></p>
<p>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;  <strong>“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…”  </strong>[RMP, p. 61]<strong> </strong></p>
<p><strong> </strong></p>
<p>Without Fells ranger staff the agency cannot make good on the promise found in the RMP to <strong>“Close trail segments that go through or are eroding into vernal pools.”  </strong>[RMP, p. ix]</p>
<p><strong> </strong></p>
<p>In addition, only half of the 129 Vernal Pools in the Fells are protected with Zone 1 status. <strong>Additional areas of Zone 1 are required to protect large clusters of Vernal Pools in the Long Pond area and</strong></p>
<p><strong>the southeastern portion of the Fells.</strong> [RMP, p. 10]</p>
<p>&nbsp;</p>
<p align="center"><strong><em>DCR: Will changes be made to the draft plan before it is approved?</em></strong></p>
<p>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.</p>
<p>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.</p>
<p>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.</p>
<p>Last year the Sierra Club stated in a letter to DCR, <strong><em>“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.”</em> </strong></p>
<p>And Mass Audubon also wrote, <strong><em>“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.”</em></strong></p>
<p><strong>Write Today</strong>:  Please write DCR today.</p>
<p><strong>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.</strong></p>
<p>The Fells Resource Management Plan must be revised.  Tell DCR that they must:</p>
<ul>
<li><strong>Create effective programs to repair and protect Fells resources <em>before</em> any expansion of recreational access.</strong></li>
<li><strong>Provide and implement a <em>funded</em> plan for effective Fells enforcement staffing and trail-use management.</strong>
<ul>
<li><strong>Protect all sensitive natural areas in the Fells, including Vernal Pools throughout the Reservation.</strong><strong></strong></li>
<li><strong> </strong></li>
</ul>
</li>
</ul>
<p>Email DCR: <a href="mailto:rmp.comments@state.ma.us">rmp.comments@state.ma.us</a></p>
<p>or mail to: Fells RMP Comments, 136 Damon Rd., Northampton, MA 01060</p>
<p>The entire DCR Fells RMP may be viewed here:</p>
<p>http://www.mass.gov/dcr/stewardship/rmp/downloads/midfells/rmp-midfellls.pdf</p>
<p>&nbsp;</p>
<p align="center">Thank You!</p>
<p align="center">Friends of the Middlesex Fells Reservation   235 West Foster Street, Melrose, MA 02176</p>
<p>&nbsp;</p>
<p>&nbsp;</p>
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		<title>Friends of the Fells opinion piece published in Melrose Free Press, Oct 27th, 2011</title>
		<link>http://fellsforever.org/2011/11/05/friends-fells-opinion-piece-published-melrose-free-press-oct-27th-2011/</link>
		<comments>http://fellsforever.org/2011/11/05/friends-fells-opinion-piece-published-melrose-free-press-oct-27th-2011/#comments</comments>
		<pubDate>Sat, 05 Nov 2011 00:25:23 +0000</pubDate>
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		<description><![CDATA[Friends of the Fells opinion piece published in Melrose Free Press, Oct 27th, 2011 DCR must put conservation first in the Fells With funding slashed to the lowest point in its history the Department of Conservation and Recreation (DCR) declares in its draft Fells Resource Management Plan (RMP) released on September 14th that it will not [...]]]></description>
				<content:encoded><![CDATA[<p>Friends of the Fells opinion piece published in Melrose Free Press, Oct 27th, 2011</p>
<p><strong>DCR must put conservation first in the Fells</strong></p>
<p>With funding slashed to the lowest point in its history the Department of Conservation and Recreation (DCR) declares in its draft Fells Resource Management Plan (RMP) released on September 14<sup>th</sup> that it will not be able to fulfill important ranger and other Fells staff positions. For example, we learn that funding will not be available for “at least five years” for a Natural Resources Specialist position needed for support of habitat management, trail closures and species protection.  And funding for numerous other Fells staff positions for monitoring and enforcing regulations is “currently unavailable, but may become so in the near future.”</p>
<p>In recent years severe budget cuts to state agencies has diminished staffing for Fells management so that today not even a single DCR ranger is assigned specifically to the Fells.</p>
<p>The result of this has been that the Fells shows increasing signs of impacts to its natural resources, user conflicts have risen, and visitors’ sense of tranquility and safety has been diminished.</p>
<p>There were hopes that a DCR Resource Management Plan would address important issues to help restore the Fells Reservation to its historic role, continuing to provide city dwellers a nearby natural oasis to escape the noise and confusion of city life.  Surely the quality of visitor experiences should be predicated on well-protected resources.</p>
<p>But hopes turned to disappointment when DCR released its draft Fells Resource Management Plan on September 14.  Instead of effective plans for conservation of Fells natural resources and enforcement of regulations, the agency proposes opening more trails to bike riding and promoting more options for dogs to be allowed loose on hiking trails.</p>
<p>Despite DCR’s motto, <em>It’s Your Nature! </em>nature in the Fells will have less of a chance if the new management plans are allowed to go into effect.  And visitors would be increasingly challenged to find quiet, un-impacted places to visit.</p>
<p>For example, the Dark Hollow Pond Trail, which passes through some of the most biodiverse nature in the Fells, would be entirely closed and <em>replaced</em> by 1 &#8211; 3 bikes-only trails. Hiking trails in the Fells targeted to be converted to mountain bike use include the entire Reservoir Trail, &#8220;all or some&#8221; of the Rock Circuit Trail, and &#8220;additional trails&#8221; in the Eastern Fells.</p>
<p>In these proposals DCR has brushed aside comments received last year, such as this one, “<em>my family and I frequently hike throughout the Fells, and numerous times I have had to quickly push my young daughters (aged 4 &amp; 6) from the trail because of approaching mountain bikes.</em>”  Another Fells visitor wrote, “<em>I cannot tell you how many times I&#8217;ve almost been run over by a mountain biker bent on cycling through what used to be a quiet nature reserve for children and families, school groups and seniors&#8230; The Middlesex Fells is desperately needed by its local citizens, who range in age from infants in backpacks and strollers, to older visitors who cannot always hear the cyclists approaching, let alone dodge them</em><em>.“</em></p>
<p>Concerns about increasing incidents of off-leash dog encounters have been overridden by DCR planners to satisfy the wishes of vocal dog owner groups.  Already the Sheepfold has been converted into an off-leash dog park, and the Fells RMP suggests that off-leash dog access could also be permitted on multiple hiking trails, “under voice control,” and that DCR would consider permitting commercial dog walkers to legally bring groups of dogs into the Fells Reservation. For more details visit <a href="http://www.fells.org/">www.fells.org</a></p>
<p>It isn’t just people on trails who are affected by off-leash dogs.  DCR writes that “<em>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,” </em>yet the agency’s policy changes would permit more dogs loose in the Fells with no effective means for enforcement to protect people and natural features.</p>
<p>The Friends of the Fells agrees with Mass Audubon, which in a letter sent last year to the DCR Commissioner stated<strong> </strong>“<em>DCR should not take on extensive new trails or expanded uses at the Fells until it can manage the existing trails and uses.”</em></p>
<p>DCR has it exactly backwards. Resource protection and public safety should come first. A resource management plan should first demonstrate ability to protect resources.  Conservation is the agency’s primary responsibility.</p>
<p>You can help!  The comment period on the proposed Fells Resource Management Plan closes on November 14<sup>th</sup>.  Please send an email or letter today to DCR to request that Fells Resource Management Plan must be revised.</p>
<p>Tell DCR it is imperative they:</p>
<p><strong> </strong><strong>• Implement effective programs to repair and protect Fells resources <em>before</em> considering expansion of recreational access.</strong></p>
<p><strong>• Provide and <em>implement</em> a <em>funded</em> plan for effective Fells enforcement staffing and trail-use management.</strong></p>
<p><strong>• Protect all sensitive natural areas in the Fells, including Vernal Pools, throughout the Reservation.</strong></p>
<p><strong>Email DCR</strong>: <a href="mailto:rmp.comments@state.ma.us">rmp.comments@state.ma.us</a></p>
<p><strong>or mail</strong> <strong>to: Fells RMP Comments, 136 Damon Rd., Northampton, MA 01060</strong></p>
<p><strong>The DCR Fells RMP may be viewed here: </strong><a href="http://cts.vresp.com/c/?FriendsoftheMiddlese/1b6743e91b/809bb08081/01c74a86b1">http://www.mass.gov/dcr/stewardship/rmp/downloads/midfells/rmp-midfellls.pdf</a></p>
<p><strong>Thank You!</strong></p>
<p><strong>Mike Ryan, </strong></p>
<p><strong></strong><strong>Melrose,<br />
</strong><strong>Executive Director<br />
</strong><strong>Friends of the Fells</strong></p>
<p>&nbsp;</p>
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		<title>NEMBA : We believe there is no place for unsupported conjecture in this RMP.</title>
		<link>http://fellsforever.org/2011/11/02/nemba-happy-rmp/</link>
		<comments>http://fellsforever.org/2011/11/02/nemba-happy-rmp/#comments</comments>
		<pubDate>Wed, 02 Nov 2011 17:03:45 +0000</pubDate>
		<dc:creator>admin</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://fellsforever.org/?p=3353</guid>
		<description><![CDATA[NEMBA : &#8220;We believe there is no place for unsupported conjecture in this RMP.&#8221; I agree with NEMBA. And so does this expert: &#8220;The DCR cites a number of published studies analyzing the impact of hikers, bikers and other trail users.  Close review of these studies shows that they lack relevance for decision-making regarding trail use [...]]]></description>
				<content:encoded><![CDATA[<h5>NEMBA : &#8220;We believe there is no place for unsupported conjecture in this RMP.&#8221;</h5>
<h5>I agree with NEMBA. And so does <span style="text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;"><a title="DCR Bike Studies Lack Relevance for Decision-Making" href="http://fellsforever.org/studies-info/expert_review/" target="_blank">this expert</a>:</span></span></span></h5>
<h5>&#8220;The DCR cites a number of published studies analyzing the impact of hikers, bikers and other trail users.  <strong>Close review of these studies shows that they lack relevance for decision-making regarding trail use in the Middlesex Fells Reservation (MFR)&#8221; </strong></h5>
<p>If the studies cited by the DCR do not support DCR claims there should be no place for them in the RMP.</p>
<h5></h5>
<p>&nbsp;</p>
<p><strong>&#8220;GB NEMBA  comment on the Fells Draft RMP</strong></p>
<p><em>The Greater Boston Chapter of the New England Mountain Bike Association is pleased to submit comments about the Draft Resource Management Plan (RMP) for the Middlesex Fells. This plan is the most detailed, researched and well-studied of any RMP created by the Department of Conservation and Recreation thus far, and we commend DCR for incorporating highly sophisticated trail management practices and the latest in conservation science into the draft RMP. As this RMP is an exercise in compromise, all involved, credible stakeholders must understand that balance should carry the day. Ultimately, in all cases DCR has made the argument that sensitive resources will get a high level of protection. The Fells Draft RMP goes to great lengths to enhance protection of the Fells&#8217; natural resources. The level of conservation detail and resource protection far exceeds expected standards and is unprecedented in any DCR RMP.</em></p>
<p><em>The Fells RMP process has been highly politicized, and the final draft is being misrepresented by the anti-mountain bicycling group, the Friends of the Fells. We urge DCR not to waiver in its core mission to balance recreation and conservation due to the extremist pressure being applied by this group. DCR is a sophisticated land management agency entrusted by the citizens of the Commonwealth to steward the Fells according to its management guidelines, and we trust that the agency will set forth policies grounded in sound practice and science that will both protect the Fells and provide sustainable recreation opportunities for its users.&#8221;</em></p>
<h5>(The Friends of the Fells have been involved in many projects at the Fells concerned with conservation and preservation just like hundreds of other Friends groups across the country. They are not a anti-mountain bike group as NEMBA implies. This is more another example of fear mongering that has been so common in NEMBA&#8217;s letters. The Friends are hardly extremist. Concerns about mountain biking are widespread. On the west coast there have been battles raging for more than thirty years. Biking is not allowed any longer on Lincoln, Mass land trust properties because of concerns about negative environmental impact. Just a few of the more than 100 Trustees of the Reservation properties allow biking. Bikes are banned there, and the Friends are extremists?</h5>
<h5>Preservation and Conservation trumps recreation. I have no problem with biking in a situation where no damage to resources occurs, or where issues of safety on shared use trail have been resolved. I have no problem with mountain biking if  cyclists stick to legal trails and there are laws in place that make it possible to enforce protective regulation. I have no problem with biking if other users can also have a pleasant experience at the park without fear of speeding bikes. I would have no problem with bikes if there were plenty of money to repair all the trails that have so badly damaged one the years, not closed with sticks and tree limbs, but actually restored.</h5>
<h5>The DCR SHOULD set forth policies &#8220;grounded in sound practice (whatever that is) and science.&#8221;  I asked Dr. Richard Eilbert who has a Ph.D. from Harvard and has spent his career dealing with complex scientific problems, is the holder of numerous patents, and has published numerous papers, what the thought of the DCR science mentioned by NEMBA. His response:</h5>
<h5>&#8220;The DCR cites a number of published studies analyzing the impact of hikers, bikers and other trail users.  Close review of these studies shows that they lack relevance for decision-making regarding trail use in the Middlesex Fells Reservation (MFR).&#8221; <span style="text-decoration: underline;"><span class="Apple-style-span" style="font-size: 13px; color: #0000ff; text-decoration: underline;"><a title="DCR Bike Studies Lack Relevance for Decision-Making" href="http://fellsforever.org/studies-info/expert_review/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">Read more here.</span></a></span></span></h5>
<p><em>&#8220;While NEMBA agrees with most of the recommendations contained in the RMP, we wish to highlight a few areas that we believe need improvement. Our central concerns are the following:</em></p>
<p><em>1. The RMP only allows for a minimal increase in multi-use trails, and those that are mentioned might not be opened to multi-use for many years, if ever. We urge DCR to expand the quantity of multi-use trails and to reclassify these trails now rather than in the future.&#8221;</em></p>
<h5>(Anybody else feeling a bit of pressure? If the science cited by the DCR is irrelevant, that means there is no justification for any kind of trail expansion at the Middlesex Fells. )</h5>
<p><em>&#8220;2. While we understand DCR is attempting to mediate potential user conflict by offering single-use trail opportunities, single-use trails should be the exception and not the norm, as is the case throughout most of DCR&#8217;s properties. Single-use trail systems isolate users and inhibit the formation of a collaborative trails community; given the limited trail resources, single-use trail systems are an inefficient means to provide recreational opportunities to all trail users.&#8221;</em></p>
<h5>(Bikers and hikers have always been at odds. The two user groups have very different priorities. The creation of many new biking trails throughout the Fells is not going to improve relations or collaboration between these two groups. Given limited resource, this is no time to be handing over trails to cyclists. It is impossible to enforce regulations, ticketing is impossible, trails can&#8217;t be monitored, there are no Rangers, funding of trail conversion is absent, bikers regularly violate park rules and have been doing so for years. Last year, on opening day of the Fells NEMBA even took a large group of cyclists on an <span style="text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;"><a title="NEMBA VIDEO – 2010 FISHER ILLEGAL TRAIL RIDE at the FELLS" href="http://fellsforever.org/fells_photos/nemba_fisher_ignore_rules/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">illegal ride through Dark Hollow</span></a></span>,</span> then after that on a <a title="NEMBA VIDEO – 2010 FISHER ILLEGAL TRAIL RIDE at the FELLS" href="http://fellsforever.org/fells_photos/nemba_fisher_ignore_rules/" target="_blank"><span style="color: #0000ff;">&#8220;<span style="text-decoration: underline;">HAMMER RIDE</span></span>&#8221; </a>on another hiking only trail. A views of group that calls their own property <span style="text-decoration: underline; color: #0000ff;"><a title="Vietnam – Videos Shot on Nemba-Owned Land" href="http://fellsforever.org/fells_photos/vietnam-nemba-owned-land/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">VIETNAM</span></a></span> must be taken with a large grain of salt. )</h5>
<p><em>&#8220;3. The creation of new trails (especially in the Dark Hollow Pond area), sensible trail re-routes to the existing trail system, and the conversion of underutilized double-track fire roads into singletrack trails need to be fast-tracked.&#8221;</em></p>
<h5>(Fast-tracked? Now I&#8217;m really feeling the pressure. Why do these major expansions need to be fast  tracked? If they aren&#8217;t&#8217; fast tracked then what? What is the justification for all of these new trails? Recreation? Are we sure that biking impacts are the same as hiking? NO. And there is every indication in the Fells that biking impacts are enormously greater than hiking. Until there is a study of this park and the impact of biking here, an the environmental impact of bikes on these trails, biking should not be expanded.)</h5>
<p><em>&#8220;Because the RMP only proposes a minimal expansion of mountain biking, those opportunities need to be enacted as soon as possible. If trail access lags behind trail restrictions, enforcement becomes an issue as terrain is so limited, and social conflicts are likely to increase.&#8221;</em></p>
<h5>(This is a<strong> threat</strong> pure and simple. So if bikers don&#8217;t get more trails they are going  to use hiking trails and and enforcement will be an issue. Why would enforcement become an issue? If bikers stay on legal trail there would be no enforcement issue? NEMBA is saying if you don&#8217;t do what we say there will be problems. Am I wrong or right? Isn&#8217;t&#8217; this a THREAT?)</h5>
<p><em>&#8220;We understand that the concept of &#8220;new&#8221; trails can be highly sensitive &#8211; particularly at the Fells. In almost all instances, trails at the Fells have never been sited or routed following best practices resulting in many instances where the trails just cannot be sustainable.DCR and the involved stakeholders should use this as an opportunity to correct these deficiencies for the long-term health of the Fells: by constructing new trails or trail re-routes if necessary.&#8221;</em></p>
<h5>(There are more than a hundred miles of trails in the Fells. Why not repair those trails? Why construct new trails or reroute existing trails? This is absurd. It is impossible to make every trail in the Fells sustainable and NEMBA knows that. Besides, even if they were, most riders would avoid those trails and they wouldn&#8217;t be enjoyable to other trail users. <span style="text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;"><a title="Vietnam – Videos Shot on Nemba-Owned Land" href="http://fellsforever.org/fells_photos/vietnam-nemba-owned-land/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">Look at the trails that NEMBA likes.</span></a>)</span></span></h5>
<p><em>&#8220;We believe that the RMP, and DCR&#8217;s Trail Guidelines, lay out all the planning protective steps required to do this sustainably for the Fells. Lastly, trail plans should be submitted as soon as the RMP is ratified and a schedule of meetings and trailwork completion dates (including an ongoing planning calendar) decided within 60 days of RMP ratification.&#8221;</em></p>
<h5>(Here&#8217;s more ram it through as soon as possible stuff. This park will be around for centuries. There is no reason to ram anything through. This is an important issue. It needs to be carefully thought through. You can&#8217;t make major policy changes that go against what the management of this park has done for the last twenty years. The current restrictions against bikes exist because of bike erosion and trail damage issues from twenty years ago when biking was unrestricted at the park. And now suddenly, twenty years later, when there are far more mountain bikes, bikes are being declared no more harmful than hiking? And the case is closed? There can be no debate on this? The science mentioned by the DCR can&#8217;t be questioned? )</h5>
<p><em>&#8220;4. Funding. Several of the specific high-priority goals in the RMP recommendations (G1.7 for example) require funding that DCR may not have at the current time. It will be important for DCR to clearly communicate how those goals will be met with their current funding situation as well as important for all committed stakeholders and partners to strongly advocate for increases to DCR&#8217;s funding at the state level to rectify financial challenges that DCR faces agency-wide.&#8221;</em></p>
<h5>(Funding is a huge issue. See <span style="text-decoration: underline; color: #0000ff;"><a title="Friends of the Fells looks at DCR October 11 RMP Update" href="http://fellsforever.org/articles_on_mountain_biking/resource_management_plan_examined_by_friends_of_fells/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">Mike Ryan&#8217;s letter. </span></a></span> With no funding then why should the DCR ram anything through? )</h5>
<p><em>&#8220;5. The RMP fluctuates between being providing general criteria in some areas and making very specific decisions in others. The RMP should be a general blueprint that sets guidelines and parameters that will help DCR&#8217;s Planning and Operations groups make actual on-the-ground implementation decisions when acting on recommendations in the RMP. Making specific decisions now, in the RMP, will have the effect of it becoming impossible to ever make changes if circumstances ever warrant. For example, instead of making the Skyline Trail pedestrian only, the RMP might instead give guidelines of: 1. The Fells will have a mix of multi- and solitary use trails. 2. 60-80% of all trails in the Fells should be multi-use. 3. 60-80% of singletrack trails should be multi-use. 4. DCR Planning and Operations will have the sole discretion in determining how these get implemented. This would result in a much more flexible, forward looking plan for trail use at the Fells.&#8221;</em></p>
<h5>(More pressure from NEMBA. This time regarding the Skyline trail. Convert that too! I&#8217;m sorry but I find this sickening. The arrogance of this organization is beyond the pale. If any group deserves to be thrown out of the Fells it is NEMBA. It threatens, it accuses, it lies about what other people say, the science it holds up to support biking is full of holes. What justification is there for bikes anyway? Just because lots of people like to bike doesn&#8217;t mean we should hand over the park to them without reason. And I&#8217;m not seeing many valid reasons, frankly. All I&#8217;m seeing are studies a PhD from Harvard is calling irrelevant,<span style="text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;"> <a title="Trail widening at the Fells" href="http://fellsforever.org/fells_photos/trail-widening-at-the-fells/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">trails that horribly eroded</span></a></span></span>, <span style="text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;"><a title="NEMBA VIDEO – 2010 FISHER ILLEGAL TRAIL RIDE at the FELLS" href="http://fellsforever.org/fells_photos/nemba_fisher_ignore_rules/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">rampant illegal use</span></a></span></span>, a <span style="text-decoration: underline; color: #0000ff;"><a title="Illegal Trail Use Negates DCR Impact Conclusion" href="http://fellsforever.org/studies-info/dcr-compares-bike-trails-to-hiking-trails/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">culture of non-compliance</span></a>,</span> <span style="text-decoration: underline; color: #0000ff;"><a href="http://www.fellsbiker.com" target="_blank"><span style="color: #0000ff; text-decoration: underline;">websites that encourage illegal use</span></a></span>, <span style="text-decoration: underline; color: #0000ff;"><a title="Illegal Trail Use Negates DCR Impact Conclusion" href="http://fellsforever.org/studies-info/dcr-compares-bike-trails-to-hiking-trails/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">illegal trail reviews</span></a></span>, threats, pressure. Am I the only one who finds this objectionable?  And this is the reason the park should be handed over?)</h5>
<p><em>&#8220;6. The RMP should provide an operational chart of where decision making powers reside for implementing components of the RMP. There should be no ambiguity who has ultimate decision making authority when it comes to approvals for trail work or projects in the Fells.&#8221;</em></p>
<h5>(Here NEMBA is asking for the creation of a position of power that can&#8217;t be questioned at the Fells. In a democracy or state government things don&#8217;t work that way, nor should they. The local manager of the Fells needs to answer to his/her higher ups. Sure this would make it possible for NEMBA to implement their agenda quickly if the person in power were on their side, as seems to be the case in the Fells currently, but the DCR commissioner should have a say, and the general public too.)</h5>
<p><strong>&#8220;These overarching principles guide the more detailed comments below.</strong></p>
<p><em>Goal 1: Protecting Water Resources</em><br />
<em> NEMBA strongly supports this goal. Water resources are critical to healthy ecosystems and the Fells is no exception. However, this is made more complex within the Fells with the adjoined properties of Winchester Water Authority and MWRA.</em></p>
<p><em>G1.1, G1.3, G1.4, G1.8, G1.10, G1.11, G1.12 &#8211; No specific comments &#8211; NEMBA supports the goals.</em></p>
<p><em>G1.2 NEMBA Generally supports this goal. However, we strongly believe that DCR needs to begin an initiative to work with MWRA and WWA to relax and rationalize the restrictions currently in place for roads and trails that transect MWRA and WWA property.&#8221;</em></p>
<h5>(incredible)</h5>
<p><em>&#8220;DCR&#8217;s data shows that no water quality impacts have been found and the water quality impact of users on the well-established dirt/gravel fire roads is next to nothing. This is supported by WWA&#8217;s own data: in their 2010 Drinking Water Report the data shows that the measured level of water turbidity which is directly correlated to soil runoff from erosive processes is 5 times lower than the minimum threshold for this indicator.</em></p>
<p><em>Further, other primary water supply reservoirs in Massachusetts (Quabbin, Fresh Pond) successfully allow recreation in and around without impact on water quality or safety. We believe that this is an area that DCR should be leading discussions with the MWRA and WWA towards a future goal of allowing limited recreation access on these properties contained within the Fells.</em></p>
<p><em>G1.5 We strongly support closing or re-routing trails that go through or are too close to vernal pools. However, we do believe that should there be a need to provide a trail opportunity for users to experience the beauty of an example of a Fells vernal pool, modern trail engineering practices can provide sustainable, low impact methods to achieve this.&#8221;</em></p>
<h5>(More trails, bridges, who is going to pay for this? and what about trails leading up to these areas?)</h5>
<p><em>&#8220;G1.6 Closing or rerouting trails impacting wetland areas should be the first choice. Modern trail engineering practices and structures should be used to re-mediate trails that cannot be closed or re-routed.</em></p>
<p><em>G1.7 This goal is of special concern. These two staff positions are listed as high priority to fill. However, it is not clear how DCR plans to do this under its current budget constraints.&#8221;</em></p>
<h5>(Exactly, so nothing should happen before then.)</h5>
<p><em>&#8220;G1.9 NEMBA strongly supports the change in winter trail closure to the month of March. However, we do not support the current language that bans and singles out mountain bikes explicitly. DCR has demonstrated in the RMP that soft trails are at risk from all types of users and the language should be changed to reflect this. The current language is effectively granting permission for foot traffic to use the trails in March if they are soft. Boots are just as damaging in soft conditions and much more likely to try and go around soft areas, causing trail widening and trampling of adjacent vegetation. NEMBA educates riders to &#8220;take the mud&#8221; and ride the center of any soft areas to prevent trail creep &#8211; most foot traffic does not do this. These wet areas are also signs of poor trail design/routing that should be identified and properly corrected. A fairer and more sustainable mud season closure policy would limit park traffic to forest roads in March, and close all single track trails to all users.&#8221;</em></p>
<p><span class="Apple-style-span" style="font-size: 11px; font-weight: bold;">(Close all trails in the park to all user for the month of March? No comment needed.)</span></p>
<p><em>&#8220;Goal 2. Protect and enhance habitats for rare species, natural communities and native plants and animals</em><br />
<em> NEMBA strongly supports this goal.</em></p>
<p><em>G2.2, G2.3, G2.4, G2.5, G2.8, G2.9, G2.10, G2.11, G2.12 &#8211; No specific comments &#8211; NEMBA supports the goals.</em></p>
<p><em>G2.1 NEMBA volunteers our trail engineering expertise to help meet goal G2.1.</em></p>
<p><em>G2.6 NEMBA strongly supports this goal.</em></p>
<p><em>G2.7 NEMBA advocates for relocation or closure of trails near sensitive resources instead of adding trail edge definition elements. Often these elements create secondary trail drainage issues and are unnecessary if the trail is designed properly in the first place. If the trail must remain in the same location, modern trail engineering techniques should be used to mitigate impact on adjacent sensitive resources.&#8221;</em></p>
<p><em>&#8220;Goal 3. Preserve the cultural resources of the reservation</em></p>
<p><em> NEMBA strongly supports this goal.</em></p>
<p><em>G3.1 &#8211; G3.16 &#8211; No specific comments &#8211; NEMBA supports the goals.</em></p>
<p><em>Goal 4. Provide for and enhance diverse recreational opportunities</em></p>
<p><em> NEMBA strongly supports this goal.</em></p>
<p><em>G4.2, G4.3, G4.4, G4.5, G4.6, G4.7, G4.15, G4.16, G4.17, G4.18 &#8211; No specific comments &#8211; NEMBA supports the goals.</em></p>
<p><em>G4.1 NEMBA supports this goal. We have previously applied for, and received funding via the RTP grant program on DCR&#8217;s behalf, for the all-persons trail from Flynn Rink. The implementation of this grant from RTP funding for implementing the all-persons trail leaving from Flynn Rink has been stalled by objections from Friends of the Fells and it puts our credibility at risk if we must return the grant money unused.</em></p>
<p><em>G4.8 NEMBA disagrees with the practice of creating single-use trails in general. While they can be useful in extreme cases, we believe that at the Fells they will only serve to further the &#8220;us vs. them&#8221; entitlement that has been so pervasive for decades.&#8221;</em></p>
<h5>(So NEMBA now wants a multi-use trail at Dark Hollow?)</h5>
<p><em>&#8220;The majority of DCR&#8217;s trail inventory across the state are multi-use. This promotes positive trail user communities and results in less enforcement requirements. Calls for enforcement at the Fells are not borne out by DCR&#8217;s data. 80% of trail user conflicts are reported to be &#8220;social values based&#8221; rather than actual conflict on the trail. This means that the vast majority of trail interactions at the Fells are already positive. The only group of users unable to share the trails are a small, angry group of anti-mountain bike extremists operating as the Friends of the Fells. They do not represent the majority of trail users or interactions in the Fells.&#8221;</em></p>
<h5> (The Friends of the Fells are<a title="Fells Users Express Bike Concerns" href="http://fellsforever.org/studies-info/dcr_letter/"><span style="text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;"><strong> not alone in their concerns about biking</strong></span></span>. </a> Dozens of letter have been written to the DCR during this process. And since only only a fraction of any population takes time to write letters, the number of other people concerned about biking is probably much larger. <a title="Mtb/Hiker Conflicts in Marin County, CA" href="http://fellsforever.org/articles_on_mountain_biking/mtbhiker-conflicts-in-marin-county-ca/" target="_blank"><span style="text-decoration: underline; color: #0000ff;">Biking is a problem all over this country</span>.</a> and many <a title="Mountain Biking Problems in other parks" href="http://fellsforever.org/studies-info/history-of-failure-from-the-los-angeles-majority-report/" target="_blank"><span style="text-decoration: underline; color: #0000ff;">trails have been closed to bikes</span>. </a> The Friends are not extremists, just people who care enough to speak up when they see an obvious problem. )</h5>
<p><em>&#8220;We also believe that this begins the process of locking out in perpetuity these trails from becoming shared use. While DCR has stated that the RMP should be a living document, we believe that the reality will be that once a trail becomes designated as single use, it will never, ever be considered for multi-use designation again.</em></p>
<p><em>If DCR follows through with designating Virginia Wood as pedestrian only, it is essential that a multi-use access corridor be preserved for transiting through it. Failure to do this will effectively prevent anyone on a bike who resides in those neighboring communities from easy access to the Fells without having to travel on busy roadways. DCR would be creating a serious safety issue and hardship as a result.&#8221;</em></p>
<h5>(This is simply a lie. Trails through Virginia Woods are not used to get to the Fells. There is a sidewalk for that purpose that leads from the Grimbsy&#8217;s restaurant. Just another reason to question NEMBA&#8217;s whole campaign)</h5>
<p><em>&#8220;G4.9 NEMBA strongly supports this goal. In accordance with DCR listing it as &#8220;High&#8221; priority, designation of the Reservoir trail as multi-use should happen without delay. Further, examination of trail issues on the Reservoir trail and their appropriate remediation&#8217;s should take high priority as well. The Reservoir trail should be come a showpiece trail in the Fells for multi-use and excellence in sustainable trail maintenance.&#8221;</em></p>
<p>(How that is going to happen I&#8217;d like to see. <span style="text-decoration: underline;"><span style="color: #0000ff;"><a title="Photos/Video" href="http://fellsforever.org/fells_photos/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">This trail is a mess. </span></a></span></span></p>
<p><em>&#8220;G4.10 NEMBA strongly supports this goal. There should be 3 official trails designated as multi-use through Dark Hollow Pond. Since one of the overall goals with a DCR-approved renovation and rationalization of the Dark Hollow Pond trail system should be to increase positive use, the language in this goal should be changed to read &#8220;multi-use&#8221; and not &#8220;mountain bike use&#8221;. This is especially important with the significant natural features in DHP that all users can enjoy &#8211; and hopefully displace the illicit MSM activities that make this an area to be avoided.&#8221;</em></p>
<h5>(Here NEMBA is backing off of earlier demands for a biking only trail at Dark Hollow but three new trails in one of the ecologically diverse areas in the Fells is far too many. New trails are the most damaging of all. New trails are the same as illegally created ones, they damage the park. There are far too many new trails already. Furthermore, those NEMBA knows those trails will only be used by bikers. And the terrain there is so extreme it would be almost impossible to create a multi use trail that was sustainable. Anybody who has walked this trail would know this. Bikers don&#8217;t even like multi-user trails, they are too sanitized. They prefer the trails at Dark Hollow as they are. And bikes don&#8217;t belong there anyway. <span style="text-decoration: underline; color: #0000ff;"><a title="Dark Hollow Nature Trail – to be replaced by 3 biking-only trails" href="http://fellsforever.org/studies-info/dark-hollow-nature-trail/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">This is a nature trail. )</span></a></span></h5>
<p><em>&#8220;The Dark Hollow Pond trails should also be showcases for excellence in sustainable trail design and shared-use for the Fells.</em></p>
<p><em>G4.11 NEMBA strongly supports this goal. The Eastern Fells can provide a variety of challenging, sustainable single-track opportunities if trails are designated as multi-use. We believe that the priority should be changed to &#8220;High&#8221; from the current designation of &#8220;Medium.&#8221; The Eastern Fells is under-utilized and much of the challenging singletrack is on rock surfaces which support extremely sustainable trails. As DCR notes, this will serve to help disperse use across the Fells which can be a significant factor in reducing perceived trail conflicts.&#8221;</em></p>
<h5>(More calls for expansion of trail. More trails in the Eastern Fells will just draw more riders generally to the Fells which will not lessen impact on the park. The trails in that park are in better shape that the western Fells. Bikers just want trails that are not eroded. That the trails in the eastern Fells are in better shape is a testament to the impact of bikes in the western Fells. Why are trails in such good condition in the Eastern Fells? Because it is underutilized by bikes! If the  western Fells were underutilized by bikes. naybe then it would be in better condition as well)</h5>
<p><em>&#8216;G4.12 NEMBA supports appropriate enforcement of trail policies at the Fells. We are concerned that the mountain bike community is being singled out as a community of rule-breakers however when as DCR has previously stated, all types of users ignore rules at the Fells. The solution, as DCR has noted as well, are policies that make sense, are equitable, and promote self-enforcement. DCR should not heed the strident calls of a small group of exclusionary, anti-mountain bike fells users that believe extreme enforcement is the only solution at the Fells. Will DCR be targeting off-trail hikers seeking solitude as aggressively as goal G4.12?&#8217;</em></p>
<h5>(Extreme enforcement? Currently there is no enforcement. DCR rangers can not ask for your ID, so it ticketing is impossible. You are not required to pay your ticket if you get one. There are no rangers to issue tickets even if they had real ticketing power. The Fells is like the the old Wild West. Anything goes there now. Asking for a way to enforce existing rules is not extreme, it is quite reasonable. Here NEMBA is over the top again with its fear mongering. The friends are not talking about SWAT teams in the Fells. Nor am I. The rules of the Fells are mean to protect and preserver park resources. All parks have rules. And if a park is a good park it has a staff that can effectively enforce those rules. The DCR doesn&#8217;t have staff in the the Fells. Park rangers are rarely seen there. They can&#8217;t enforce any rule.  Self-enforcement is a joke. Bikers are too large a group to self-enforce. And NEMBA <a title="NEMBA VIDEO – 2010 FISHER ILLEGAL TRAIL RIDE at the FELLS" href="http://fellsforever.org/fells_photos/nemba_fisher_ignore_rules/" target="_blank"><span style="text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;">has set a terrible example</span></span>.</a> I say stop the name calling, drop this self-enforcement line, and get funding for DCR rangers, a change in rules so rangers can issue tickets and drop any plans for trail expansion till rampant illegal use that currently occurs in the Fells can be controlled. This is no time to he increasing problems. There are enough problems with bikes as it is.)</h5>
<p><em>&#8220;G4.13 NEMBA supports this goal. This RMP provides an opportunity for a fresh look at the Fells trail system and any necessary corrective closures of redundant and inappropriately sited trails should be seen as strong positive steps for the Fells.</em></p>
<p><em>G4.14 NEMBA strongly supports this goal. Every effort should be made to separate overlaps of these trails. We concur with the priority of this goal as &#8220;High.&#8221; However, we believe that since much of the actual work can be done with skilled volunteer effort, the Resources ranking of &#8220;2&#8243; is not precisely accurate &#8211; it should be either &#8220;1&#8243; or &#8220;1-2&#8243;.</em></p>
<p><em><strong>Goal 5: Enhance compliance with rules and regulations to protect resources and enhance recreational experiences</strong></em></p>
<p><em>NEMBA supports DCR&#8217;s efforts at enhancing compliance with rules and regulations at the Fells. <a title="NEMBA VIDEO – 2010 FISHER ILLEGAL TRAIL RIDE at the FELLS" href="http://fellsforever.org/fells_photos/nemba_fisher_ignore_rules/" target="_blank"><span style="text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;">We work to educate our constituents to follow the rules in effect and to practice good trail etiquette</span></span>.</a> Further, unauthorized trail work should be enforced to the same degree as unauthorized trail use, if not more so. The punishment should fit the crime, e.g. if a ranger or trooper writes a $50 ticket to an off-leash dog owner, or to a rider on a closed trail, the unauthorized trail builder should get a $500 ticket. Unauthorized trail use is misuse of a resource, whereas unauthorized trail work is vandalism of a resource.&#8221;</em></p>
<h5><span style="text-decoration: underline;"><span style="color: #0000ff; text-decoration: underline;">(I<a title="Illegal Trail Use Negates DCR Impact Conclusion" href="http://fellsforever.org/studies-info/dcr-compares-bike-trails-to-hiking-trails/" target="_blank"><span style="color: #0000ff; text-decoration: underline;">llegal trail use is also vandalism of a resource</span></a>.</span></span> It has horribly impacted the park. There is no mention of this)</h5>
<p><em>&#8220;G5.1, G5.2, G5.4, G5.5 G5.6, G5.7, G5.8, G5.10, G5.11 &#8211; No specific comments &#8211; NEMBA supports the goals.</em></p>
<p><em>G5.3 NEMBA supports this goal but we reiterate the question of how this will be funded.</em></p>
<p><em>G5.9 NEMBA supports this goal. See our comments for G4.10.</em></p>
<p><em><strong>Goal 6: Interpret the natural and cultural resources of the Fells</strong></em></p>
<p><em> G6.1 &#8211; G6.3- No specific comments &#8211; NEMBA supports the goals and DCR&#8217;s efforts at interpreting and helping to connect Fells visitors to the rich heritage contained within the Fells.</em></p>
<p><em><strong>Goal 7: Work with diverse partners and volunteers to achieve these management goals.</strong></em></p>
<p><em>G7.1 NEMBA supports this goal. We will be happy to enter in to a formal Memorandum of Understanding and Stewardship Agreement with DCR. However, we believe these formal contracts should be limited to organizations who have clearly demonstrated an ability to operate in compliance with DCR&#8217;s policies and a willingness to participate in a positive, collaborative fashion.</em></p>
<p><em>G7.2 NEMBA supports this goal. We educate our members in following rules in effect and observing good trail etiquette; we post these guidelines publicly on our website.</em></p>
<p><em>G7.3 NEMBA supports this goal. NEMBA has a very strong history of partnership and collaboration with DCR, other stakeholders, and dozens, if not hundreds of Friends Groups and similar organizations across New England. NEMBA will work with DCR to help raise and/or lobby for funds to support completion of components of the RMP.&#8221;</em></p>
<h5>(I&#8217;d like to see that list)</h5>
<p><em>&#8220;<strong>Changes to the body of the RMP</strong></em><br />
<em> Consider removing the section on page 59, Section 4.4 beginning with &#8220;In identifying specific trails and areas&#8230;&#8221; and listing bulleted experiences for mountain bikers, as distinct from pedestrians, for the following reasons:</em></p>
<p><em>Mountain bikers do not seek mountain biking-only trails</em><br />
<em> Aside from pedestrian only trails, all bulleted points in both lists could conceivably apply to all stake</em>holder groups.<br />
This is further supported by the &#8220;Possibly Compatible Interests&#8221; listed on page 30, Section 2.6.&#8221;</p>
<h5> (But any trail used by bikes soon becomes a biking only trail. And any trail that can be used by both hiker and bikers must be transformed into something that is no longer enjoyable for hikers. Trails in the Fells are narrow and run over steep and rocky terrain. It is unreasonable to expect that all of these trails can or should be converted to sanitized trails that can withstand biker impacts. Even if such trails could be constructed, it would only allow bikers to go faster on them which would frighten off other users.)</h5>
<p><strong>&#8220;&#8221;Consider removing the following speculative &#8211; not supported by any data or research &#8211; statements from pg. 56, section 4.4:</strong></p>
<p><strong>&#8220;Threats from recreational trail uses are not documented, but because of greater average speeds that bikes can travel, and the racers&#8217; tendency to bask in open areas on rocks or trails, we speculate that this species may be somewhat more susceptible to disturbance, trampling or occasional injury by recreational mountain bikers.&#8221;</strong></p>
<p><strong>&#8220;Although not documented, one can speculate that because of greater average speeds and continuous tire contact, mountain bikes may be more likely to trample tiger beetles than feet.&#8221;</strong></p>
<p><strong>Conjecture about greater impacts on reptile species and tiger beetles only provides grease to the speculative, slippery-slope arguments that have curtailed multi-use access in the past. These statements fly against all the other parts of the RMP that are supported by actual data and science. We believe there is no place for unsupported conjecture in this RMP.&#8221;"</strong></p>
<h2>( There certainly is no place for unsupported conjecture in this RMP. The DCR conjecture that biking impact and hiking are the same is unsupported. The studies cited are irrelevant at the Fells. There is therefore no scientific justification for mountain biking at the Fells, and certainly no justification for countless more trails even if they are shared use. The DCR needs to drop this whole plan and focus on existing problems like enforcement ability, staffing and repair of existing trail damage. This will improve the situation at the Fells, turning the park into a mountain bike mecca will only make things far worse.)</h2>
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		<title>No Means Yes in October 12th DCR Update</title>
		<link>http://fellsforever.org/2011/11/01/october-12th-dcr-update/</link>
		<comments>http://fellsforever.org/2011/11/01/october-12th-dcr-update/#comments</comments>
		<pubDate>Tue, 01 Nov 2011 04:01:44 +0000</pubDate>
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		<description><![CDATA[On October 12th the DCR issued an update to the draft Resource Management plan in which they answered  questions that had been raised about the plan. What follows is a question about biking and the DCR&#8217;s answer. &#160; &#8220;Does the RMP recommend expanding recreation or development at the DCR Middlesex Fells? No, the majority of the [...]]]></description>
				<content:encoded><![CDATA[<p>On October 12th the DCR issued an update to the draft Resource Management plan in which they answered  questions that had been raised about the plan. What follows is a question about biking and the DCR&#8217;s answer.</p>
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<p><strong>&#8220;Does the RMP recommend expanding recreation or development at the DCR Middlesex Fells? </strong></p>
<p><strong>No,</strong> the majority of the RMP’s recommendations actually seek to curb existing levels of recreation at the Fells, enforce rules, and better protect natural and cultural resources. Six (6) recommendations in Section 5 of the RMP specifically discuss reducing recreational access and closing trails. Eleven (11) recommendations discuss expanded enforcement of rules and regulations.  Ten (10) recommendations propose measures to better protect natural and cultural resources.  And nine (9) recommendations propose repairing degraded existing infrastructure.  <strong>Only six (6) recommendations propose some limited and specific changes to existing pedestrian, mountain biking and off-leash dog recreation at the Fells that might be characterized as expansions.&#8221;</strong></p>
<p><strong> What follows are the (6) recommendations cited on page 60 of the Fells RMP</strong></p>
<p>&#8220;The team agreed that the goal should be to enhance the mountain biking and pedestrian experiences at the Fells and not necessarily to expand the volume of either use. The goal should also be to decrease mountain biking on trails designated for pedestrians only; and encourage positive trail etiquette, join projects and respect for other users in an effort to reduce potential conflicts.</p>
<p>The team specifically noted the importance of clear maps, signs and other user information. The team noted that <strong>the introduction of positive uses, such as official mountain biking in the Dark Hollow area between the Sheepfold and Bear Hill,</strong> could help dissipate unwanted uses that contribute to the degradation of natural resources.</p>
<p>The team identified<strong> the Reservoir Trail as an appropriate shared-use loop trail</strong> with generally good sight lines, moderate grades, scenic views and some rock features that will be appropriate for intermediate to advanced riders and hikers. The team also recommended<strong> a new all-persons (accessible) trail connection from the Flynn Rink to Quarter Mile Pond</strong>. Finally, the team recommended designating <strong>some additional single-track trails in the eastern Fells in the future (including portions of the Rock Circuit Trail) as multi-use</strong> to provide longer, more challenging loop trail that will help disperse mountain bikers away from the more popular western Fells and provide more rock features, resistant rock surfaces and scenic views.&#8221;</p>
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<h5><strong>Comments on the DCR Update &#8211; Steve Gyurina</strong></h5>
<p>The DCR is not being truthful when it says that it will not be expanding recreation or development at the Fells. The creation of a biking-only trail at Dark Hollow is a major project in one of the most ecologically diverse areas in the entire Middlesex Fells Reservation. <a title="Dark Hollow Nature Trail – to be replaced by 3 biking-only trails" href="http://fellsforever.org/studies-info/dark-hollow-nature-trail/">12 unique plant communities exist in this area of the Fells</a> and this biking-only trail and the creation of any new trail in this area vastly negates any closure of trails in the same area since closed trails are soon opened up.</p>
<p>The Reservoir Trail is a major route for pedestrians that makes a large circle around the western Fells. Bikes have used this trail illegally for years. If they are allowed legal use it will become a biker-only trail, hikers tend to avoid any trail that is heavily used by bikers. And many bikers don&#8217;t like sanitized trails, so if too much work is done to this trail to accommodate bikers and hikers &#8211; widening and hardening &#8211; it will ruin the experience of hiking and it will drive bikers to more interesting trails.</p>
<p>A new trail connection to Quarter Mile pond makes no sense. Quarter Mile Pond is a stone&#8217;s throw from the Flynn Rink This would only be a shortcut into the Fells through a delicate wetland/pond area that has already been heavily eroded. Cyclists can easily follow the sidewalk down a short distance north on Woodland Road and turn left into the Fells. There is no reason to create a new trail through this area for the convenience of cyclists.</p>
<p>Building new trails in the Eastern Fells is yet another example of expansion that will negatively impact the Fells. There are plenty of trails in the Fells, there is not need to build new trails for cyclists.</p>
<p>Most people simply don&#8217;t realize what will likely happen if the DCR opens all of these trails up to mountain biking. It will become a mecca for cyclists. With no way to enforce regulations, and miles of new legal trails to draw cyclists into areas they don&#8217;t currently go the whole character of the Fells will forever be changed.  This is an absurdly bad idea.</p>
<p>To see what NEMBA likes to do on their own land <a title="Vietnam – Videos Shot on Nemba-Owned Land" href="http://fellsforever.org/fells_photos/vietnam-nemba-owned-land/" target="_blank">look here.</a> To see what bikers do at nearby <a title="Lynn Woods Videos" href="http://fellsforever.org/fells_photos/lynn-woods-videos/" target="_blank">Lynn Woods look here.</a> To see the amazing capabilities of modern mountain bikes <a title="Mountain Biking Videos" href="http://fellsforever.org/fells_photos/bikevideos/" target="_blank">look at these videos.</a> To see what a law-abiding group NEMBA is, and to help you judge how they would do on all of these new trails if, like now, enforcement is impossible,<a title="NEMBA VIDEO – 2010 FISHER ILLEGAL TRAIL RIDE at the FELLS" href="http://fellsforever.org/fells_photos/nemba_fisher_ignore_rules/" target="_blank"> look at this video.</a> To see  other examples of illegal trail use, trail reviews of closed trails and a website dedicated to illegal trail riding,<a title="Illegal Trail Use Negates DCR Impact Conclusion" href="http://fellsforever.org/studies-info/dcr-compares-bike-trails-to-hiking-trails/" target="_blank"> then visit this page. </a></p>
<p>Trails that allow bikers to ride the way they like to ride a<a title="Trail widening at the Fells" href="http://fellsforever.org/fells_photos/trail-widening-at-the-fells/" target="_blank">re ugly trails</a>. You can find these trails all over the Fells. This is no time to be building more trails to supplement to old ruined trail. The DCR needs to <a title="Mass AUDUBON – Fix Existing Problems First" href="http://fellsforever.org/studies-info/mass-audubon-bike-trails/" target="_blank">fix current problems</a> before adding more new trails. <a title="Review of DCR-cited Studies on Impact of Biking on Trails" href="http://fellsforever.org/studies-info/expert_review/" target="_blank">Science does not support the DCR&#8217;s conclusion that hiking and biking impacts are similar</a>, Bikers in real life do not ride like they do in the <a title="Mountain Bike Studies Debunked" href="http://fellsforever.org/studies-info/dcr-bike_studies/" target="_blank">controlled study site</a>s one reads about in the DCR studies. Just watch any of the videos that you can link to from this page and tell me honestly that biking and hiking impacts are the same. Take a look <a title="Reservoir Trail: Pine Forest" href="http://fellsforever.org/fells_photos/before_after_on_reservoir_trail_middlesex_fells/" target="_blank">at photographs</a> on this site and tell me biking impacts are the same as hiking. The absurdity of this claim is sickening, and yet that is exactly what the DCR has done.</p>
<p>Are we to stand idly by and do nothing about this?  It simply isn&#8217;t right for any user group to get this kind of unbridled access to the Fells at a time when DCR funding is the lowest it has ever been, at a time when it is impossible is enforce regulations because rangers can&#8217;t ask for your ID and there is no penalty for not paying tickets. Science is not behind biking despite bikers claims. The only reason bikers have gotten their demands into the RMP is because they have shown up enormous numbers at public meeting and written thousands of letters. But so what? What if motorcyclists, dirt bikers, snowmobiles started to using the Fells and mobbed public meetings, wrote thousands of letters and did all the things bikers have done for the past two decades, does it make sense to reward them too? What if they too claimed their sport was harmless, as bikers have done, because  an industry-funded study proves that going down a hill on a motorcycle is no more damaging to trails than a mountain bike doing the same thing? These are the kinds of studies being cited by the DCR. Selling out is too kind a word.</p>
<p>What is especially disturbing about this update is the way the DCR has essentially lied about what it is doing. They say NO we&#8217;re not going to expand recreation when in fact  they are expanding it enormously. Why?  It is deceptive, it quiets the crowds, it keeps the public unaware of what they are doing until it is too late and nothing can be done. I&#8217;m sorry but I think this is terribly wrong.</p>
<p>The saddest part of this sellout will be the consequences it will have on the Fells. It is important to understand that at one time the Middlesex Fells was declared the most popular mountain bike park in the entire country by a major mountain biking magazine. This popularity drew mountain bikers far and wide. Races were common, every trail was used and abused by bikers. The MCD (former DCR) put into place current restrictions against bikes because of the damage they did to this park. NEMBA was formed as a result of those restrictions. They convinced the MDC that it made sense to have a separate trail for bikes, and the MDC agreed. That is how the mountain bike loop was created. In exchange NEMBA promised to stay off of all other trails in the park. Of course not every biker is a NEMBA member, and even if they were, <a title="NEMBA VIDEO – 2010 FISHER ILLEGAL TRAIL RIDE at the FELLS" href="http://fellsforever.org/fells_photos/nemba_fisher_ignore_rules/" target="_blank">NEMBA members break park rules</a> too. That is the reason, I believe, this park is such a mess.</p>
<p>NEMBA claims they want better access but what they want is new and better trails. The old trails are so eroded that they are dangerous to ride on. New trails are called &#8220;virgin&#8221; single track. That is what cyclists want, not sanitized or eroded trails.</p>
<p>I don&#8217;t believe for a second that trail damage will lessen if bikes are dispersed like the DCR claims. If more trails are opened to bikes, this will simply draw more bikes to the Fells. This will do nothing to lessen impact.</p>
<p>DCR needs to demonstrate that it can enforce existing regulations before it invites increased use. It needs to demonstrate it can restore trails instead of hoping that blocking off trails with piles of sticks will last when this is seldom effective.</p>
<p>More than anything else though, those who have been pushed out of the Fells by bikers need to reclaim this park. The Fells is a beautiful place and it  does not have to be a mountain bike park if enough people say we&#8217;ve had enough.</p>
<p>The things I love about a beautiful park are missing now at the Fells. I cringe when I look at trails or see a group of cyclists barreling down on me. This should be a park where we can feel comfortable taking our kids. Our children&#8217;s shouldn&#8217;t be stumbling over exposed roots or falling on rocks. Moss should cover trails in the Fells not dirt. Walks should be pleasant. I should be able to stop along the edge of a trail, have a sandwich, hang out with friends, sit on a log or rock, relax. I should be able to see beautiful things in the Fells not dirty, dusty, ugly, eroded trails.  I should feel excited about having a place nearby where I can take photographs of beautiful flowers I see, or scenery. <a title="Mountain Biking Videos" href="http://fellsforever.org/fells_photos/bikevideos/" target="_blank">Bikers flying off cliffs</a> or <a title="Vietnam – Videos Shot on Nemba-Owned Land" href="http://fellsforever.org/fells_photos/vietnam-nemba-owned-land/" target="_blank">barreling down a trails at high</a> speed should be the last thing on my mind. If I were a school teacher I should be able to take my kids out into the Fells to learn about nature, without fear that my group will be disturbed by speeding wheeled intruders.</p>
<p>I don&#8217;t have any problem with bikers doing what they want on their own property, however I sincerely believe what bikers love so much is completely incompatible with the vast majority of other park users. It simply isn&#8217;t fair that this public park must be ruined to accommodate thrill seekers and speed demons. Go to <a title="Vietnam – Videos Shot on Nemba-Owned Land" href="http://fellsforever.org/fells_photos/vietnam-nemba-owned-land/" target="_blank">NEMBA&#8217;s Vietnam</a> if that is your thing, but don&#8217;t do it in the  Fells.</p>
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		<title>Mass Audubon &#8211; Fix Existing Problems First</title>
		<link>http://fellsforever.org/2011/10/31/mass-audubon-rmp/</link>
		<comments>http://fellsforever.org/2011/10/31/mass-audubon-rmp/#comments</comments>
		<pubDate>Mon, 31 Oct 2011 04:01:37 +0000</pubDate>
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		<description><![CDATA[&#160; Advocacy Department Six Beacon Street, Suite 1025 p Boston, Massachusetts 02108 tel617.962.5187 fax617.523.4183emailjclarke@massaudubon.org March 31, 2011 Middlesex Fells RMP Comments c/o MA Office of Public Collaboration University of Massachusetts Boston 100 Morrissey Blvd., M-1-627 Boston, MA 02125 Via Email: MiddlesexFellsRMP@umb.edu Re: Resource Management Plan (RMP) for the Middlesex Fells Reservation Dear Middlesex Fells RMP Team: On [...]]]></description>
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<p>Advocacy Department</p>
<p>Six Beacon Street, Suite 1025 p Boston, Massachusetts 02108 tel617.962.5187 fax617.523.4183emailjclarke@massaudubon.org</p>
<p>March 31, 2011</p>
<p>Middlesex Fells RMP Comments c/o MA Office of Public Collaboration University of Massachusetts Boston 100 Morrissey Blvd., M-1-627 Boston, MA 02125</p>
<p>Via Email: MiddlesexFellsRMP@umb.edu Re: Resource Management Plan (RMP) for the Middlesex Fells Reservation</p>
<p>Dear Middlesex Fells RMP Team:</p>
<p>On behalf of Mass Audubon, I submit the following comments as you begin drafting the Resource Management Plan (RMP) for the Middlesex Fells Reservation. We are grateful that the Department of Conservation and Recreation (DCR) has initiated the process to prepare an RMP for the Fells, and has conducted a series of public engagement workshops as part of this process. We also appreciate DCR’s inclusion of Mass Audubon in the workshop on Flora and Fauna. Although we were not able to have staff present at all the workshops, we have reviewed the presentations and comments posted on the DCR website.</p>
<p>DCR works hard to fulfill its dual mission of land stewardship and recreational opportunities across hundreds of thousands of acres of state land. These challenges are becoming ever greater as the agency’s budget has declined precipitously over the past several years. The need for Massachusetts residents and visitors to have access to safe and enjoyable outdoor recreational experiences is increasing while resources for DCR to maintain trails and facilities, provide interpretive services, and conduct enforcement against improper uses are declining. The conflicts between resource conservation and recreation and among different user groups at the Fells are just one example of the challenges DCR faces statewide.</p>
<p>DCR has recognized that cooperation and partnership with recreational groups, nonprofit organizations, and individual volunteers is essential in order to fulfill its mission and meet these challenges. At the Fells, DCR is making a concerted effort to bring various stakeholders together to build shared understanding and foster cooperation. Based on the comments submitted to date and the available information regarding such things as trail establishment and user conflicts, it is clear that the issues at the Fells are both real and difficult to resolve.</p>
<p><strong>Given DCR’s limited budget and resources, and the existing degraded conditions and conflicts in the Fells, the RMP priority recommendations should focus on reducing existing impact, restoring degraded resources, and targeted enforcement to improve compliance with park rules</strong>.Cooperative projects with several user groups working together under DCR’s guidance to close unauthorized trails in sensitive areas should be a priority both for resource stewardship and as a means to bring people together and foster greater cooperation. This process offers an opportunity for groups and individuals to work together and cooperatively with DCR and move the Fells in a positive direction where both user experiences and the condition of the resources can be improved. If this approach is successful at the Fells, it can be a model for DCR to apply in other locations. We hope that is the outcome.</p>
<p><strong>Middlesex Fells Reservation</strong><strong></strong></p>
<p>As noted in Mass Audubon’s previous comments, the Middlesex Fells is important in terms of its ecology, history, and public values. Established in 1894, the Fells is one of the first large reservations established in the commonwealth, and is part of the legacy of Charles Eliot and other visionaries who founded the state parks system that has served as a model around the world.</p>
<p>[T]he Middlesex Fells, a great tract of wild land, unfit for the general purposes of cultivation, but pre-eminently fitted for a great natural park, for which purpose it ought to be set apart forever.1</p>
<p>The Fells presently covers some 2,575 acres and harbors a wealth of natural resources including a diversity of habitat types and plants, over 100 vernal pools, and at least 8 state-listed rare species. Two of these species are state listed as endangered, the highest level of conservation concern with the greatest risk of being eliminated entirely from the state. One of these two species is so sensitive that the NHESP does not release the name of the species to the public.</p>
<p>The Commonwealth’s BioMap2: Conserving the Biodiversity of Massachusetts in a Changing World (Massachusetts Department of Fish and Game and The Nature Conservancy, 2010) maps most of the Fells (except the northeast section from Virginia Woods northward) as Core Habitat. This includes habitats for rare, vulnerable, or uncommon species of plants and wildlife, Priority Natural Communities (PNC), high quality wetland and vernal pool habitats, and intact forest ecosystems. The western section of the Fells (west of Route 93) is mapped in BioMap2 as Critical Natural Landscape, a designation applied to the largest intact landscape blocks in each of eight ecoregions across the state. This area is also mapped as uplands that buffer important wetland or aquatic habitats. The entire Middlesex Fells Reservation is also an Important Bird Area (IBA), as designated by Mass Audubon http://www.massaudubon.org/Birds_and_Birding/IBAs/site_summary.php?getsite=47. An IBA provides essential habitat to one or more species of breeding, wintering, and/or migrating birds. The Fells IBA is an important migratory stopover or seasonal concentration site for migratory land birds (e.g. warblers).</p>
<p>The Reservation is also a popular recreational area, with thousands of people visiting year round. There are approximately 122 miles of woods, roads, and trails on the property. Some have existed for 100 years or more, including the “carriage roads” which are in many instances wide enough for emergency service vehicles to pass over a compacted, relatively level surface. There are also networks of trails developed without authorization by the state. Several trails, such as the Skyline Trail, traverse high points, passing up and down steep, rocky, and sensitive soils while offering the visitor scenic vistas and access to quiet valleys.</p>
<p><strong>This confluence of natural setting and the surrounding large urban population, combined with inadequate DCR resources to fully enforce rules as well as maintain trails and signage has led to significant damage and stresses on the natural resources of the Fells. According to the draft Fells Trails Plan, DCR has identified and mapped 497 trail damage points. DCR has also documented many instances of trails in or in close proximity to sensitive natural resources, including Priority Habitat for state-listed rare species, vernal pools and other wetlands, and potential PNC.</strong></p>
<p><strong>Management Principles and Goals</strong><strong></strong></p>
<p>The draft management principles and goals proposed for the Fells RMP address both the conservation and recreation aspects of DCR’s mission and provide a framework for the plan. The Management Principle is stated as: Through the creative use of state management resources, partnerships and volunteer stewardship, achieve a sustainable balance between the conservation of the cultural and ecological resources at the Middlesex Fells Reservation and the provision of quality recreational opportunities. This is a good guiding statement, although it is important that “balance” between conservation and recreation not be interpreted to allow significant degradation of sensitive resources. <strong>The goal should be to provide for recreation in a manner that will protect resources not only now but also for future generations.</strong> The location and condition of trails, and management of uses to designated routes, is vital to achieving the overall goal.</p>
<p><strong>Recommendations for RMP Priorities</strong><strong></strong></p>
<p>Information compiled to date including but not limited to the draft Trails Plan and associated documents, data from NHESP, historical reports, and studies by qualified volunteers such as the survey of flora, provide an extensive base of information upon which to base the RMP. There is ample documentation of important natural and cultural resources on the property as well as extensive trail damage, proliferation of unofficial trails, impacts to soils and vegetation, invasive species, and conflicts among user groups. Based on this information, Mass Audubon recommends the RMP recommendations for management actions prioritize the following steps:</p>
<ol>
<li><strong>Halt illegal uses and illicit activities;</strong></li>
<li><strong>Close unauthorized trails and increase enforcement to protect the public’s health and safety as well as the natural resources of the reservation;</strong></li>
<li><strong>Repair and restore damage to natural resources associated with unauthorized activities;</strong></li>
<li><strong>Repair and restore damage to trails and surrounding natural resources associated with authorized and legal activities as part of a long-term and routine recreation and conservation maintenance program; and</strong></li>
<li><strong>Limit any new or expanded uses and trails to those which can both be accommodated without significant new impacts to resources or exacerbating user conflicts, and where adequate oversight is available to ensure they do not detract from the above priorities or create new problems.</strong></li>
</ol>
<p>Sensitive Areas Remediation: DCR has previously proposed numerous positive recommendations for: closing redundant trails (duplicative trails through a single area); improving signage, maps, and user education; protecting sensitive resources; and reducing user conflicts. <strong>Given DCR’s budgetary and staffing constraints, it is important that the RMP establish clear priorities for specific locations where resource damage is most severe and work with volunteer user groups to implement effective actions to halt damage and close or stabilize these areas. Cooperative projects involving multiple user groups to undertake restoration measures can also be a means of bringing people together and defusing some of the tensions that have developed at the Fells. Once a trail repair or closure project has been implemented with volunteers, the individuals who contributed to that project will also be motivated to monitor the results and communicate with other park users about the importance of the restoration work.</strong></p>
<p><strong>Resource Information and Application to Management Priorities:</strong> The RMP should include maps of sensitive areas and overlaying of that information with the trails network. It should include guidelines such as appropriate setbacks to vernal pools and other resources. This information should be applied to identify priorities for trail closures or other actions to reduce or eliminate ongoing impacts to sensitive features.</p>
<p>The RMP is important in making decisions about future trail configurations and uses because it includes mapping of appropriate use zones according to the Land Stewardship Zoning Guidelines, including any appropriate overlay zones for sensitive areas. Given the numerous sensitive features of the Fells, it is important that the property be mapped according to these guidelines. The RMP should provide a map of a future trail network that minimizes conflicts between sensitive areas and trails while maintaining a functional trail system for all approved uses. The future trail map also needs to be consistent with the Massachusetts Endangered Species Act (MESA) and Wetlands Protection Act.</p>
<p>The RMP should include plans for invasive species control, especially where invasive plants may affect rare or uncommon species or habitats.</p>
<p>Some information may not be able to be fully verified during the RMP process – for example it is unclear if all vernal pools can be certified or potential PNC2 field-verified and mapped as part of this process. Nevertheless, to the extent there is credible preliminary information e.g. Potential Vernal Pool maps from NHESP or preliminary PNC data from trained botanists, DCR should apply a precautionary principle in not allowing any new trails or activities in those areas until further investigations can be completed. Any work within Priority Habitat of state-listed species protected under the MESA or in or near wetlands protected under the Wetlands Protection Act requires permitting, and DCR has a duty to protect these resources as a core part of its mission.</p>
<p>Rare Species: According to the MESA regulations at 321 CMR 10.05, state agencies have special duties in planning for management of rare species habitats on state property. These requirements go above and beyond what is required of private property owners under MESA:</p>
<p>All state agencies shall utilize their authorities in furtherance of the purposes of MESA and 321 CMR 10.00: review, evaluate and determine the impact on Endangered, Threatened and Special Concern species or their habitats of all works, projects or activities conducted by them; and use all practicable means and measures to avoid or minimize damage to such species or their habitats&#8230;.</p>
<p>Management Policies. Unless specifically required otherwise by statute, localities on state owned lands that provide habitat for state listed species shall be managed for the benefit of such listed species. Said agencies shall give management priority to the protection, conservation, and restoration of Endangered, Threatened, and Special Concern species occurring on state owned lands. All practicable means and measures shall be taken to resolve conflicts between the protection, conservation, and restoration of state listed species on state owned lands and other uses of such lands in favor of the listed species. [emphasis added]</p>
<p>Planning Procedures. State agencies shall submit to NHESP any draft management plans they prepare for state owned lands on which state listed species are known to occur. NHESP shall review such draft plans and provide comments and recommendations to the state agency concerning the protection, conservation, and restoration of the listed species on the land subject to the plan. Such review and recommendations shall be repeated at least once every five years or every time the land management plan is updated, whichever is sooner.</p>
<p>321 CMR 10.05</p>
<p>NHESP noted in a letter attached to the draft Trails Plan that even the existence or routine maintenance of current trails at the Fells may impact state-listed species on the property. Also, any rerouting of trails in Priority Habitat requires review under the MESA.</p>
<p>The Trails Plan included general language regarding commitments to protect sensitive areas including rare species habitats and vernal pools. The RMP should provide more specific language regarding the habitat needs and measures that will be taken to protect the rare species found at the Fells.</p>
<p><strong>Implementation</strong><strong></strong></p>
<p><strong>DCR should begin working immediately to increase enforcement, education, signage, and cooperation with and among user groups. However, we recognize the reduced and modest resources available to DCR.</strong> Cooperative enforcement with the State Police should be undertaken to address illicit activities that threaten public health and safety.</p>
<p>To reduce conflicts between user groups, it would be beneficial to plan trail closure and remediation work days in a way that encourages different user groups to work together and cooperate. Starting with a few priority projects, DCR could then build on those successes to achieve further progress in curtailing existing and ongoing damage and unauthorized activities. Ongoing evaluation and adjustments will be needed.</p>
<p><strong>Conclusion</strong><strong></strong></p>
<p><strong>As DCR continues to face severe budgetary and staffing constraints for the foreseeable future, it is important to focus limited resources on ensuring public safety, halting and repairing resource damage, and managing approved uses</strong>. Volunteers play an increasingly important role in assisting DCR, and we encourage DCR to work with all user groups to cooperatively address a prioritized list of urgent needs.</p>
<p>Thank you for your attention to these comments. Mass Audubon looks forward to continuing to work with DCR to make the Fells a truly rich and enjoyable conservation opportunity and recreational experience for this and future generations.</p>
<p>Sincerely,</p>
<p>John J. Clarke Director of Public Policy and Government Relations</p>
<p>cc: DCR Commissioner Edward Lambert DCR Stewardship Council</p>
<p>Appalachian Mountain Club Environmental League of Massachusetts FellsDOG Forest and Parks Friends Network Friends of the Middlesex Fells New England Mountain Bike Association Sierra Club The Trustees of Reservations</p>
<p>Mass Audubon works to protect the nature of Massachusetts for people and wildlife. Together with more than 100,000 members, we care for 34,000 acres of conservation land, provide educational programs for 225,000 children and adults annually, and advocate for sound environmental policies at local, state, and federal levels. Mass Audubon&#8217;s mission and actions have expanded since our beginning in 1896 when our founders set out to stop the slaughter of birds for use on women&#8217;s fashions. Today we are the largest conservation organization in New England. Our statewide network of wildlife sanctuaries, in 90 Massachusetts communities, welcomes visitors of all ages and serves as the base for our work. To support these important efforts, call 800-AUDUBON (283-8266) or visit www.massaudubon.org.</p>
<p>&nbsp;</p>
<p>1 Davenport, George E., A Lecture on the Middlesex Fells, Medford, 1893</p>
<p>2 A natural community is an assemblage of plants and animals that occur together in recognized groupings, such as red maple swamp or oak-hickory forest. Uncommon and exemplary natural communities are recognized by the NHESP as being of particular biological and conservation significance and are inventoried in the NHESP database as PNC. http://www.mass.gov/dfwele/dfw/nhesp/natural_communities/natural_communities.</p>
<p>&nbsp;</p>
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		<title>Places in Need: Mountain Bike Damage on the Pacific Crest Trail</title>
		<link>http://fellsforever.org/2011/10/29/places-mountain-bike-damage/</link>
		<comments>http://fellsforever.org/2011/10/29/places-mountain-bike-damage/#comments</comments>
		<pubDate>Sat, 29 Oct 2011 01:17:53 +0000</pubDate>
		<dc:creator>admin</dc:creator>
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		<guid isPermaLink="false">http://fellsforever.org/?p=3119</guid>
		<description><![CDATA[&#160; The photo shown here depict damage to the Pacific Crest Trail (PCT) caused by the illegal use of the trail by mountain bike riders. From the Big Bear to Tehachapi Mountains in southern California, to the Donner Summer and the Sierra Buttes north of Lake Tahoe, to Castle Crags and beyond, mountain bikes on [...]]]></description>
				<content:encoded><![CDATA[<p><a href="http://www.pcta.org/images/trail-threats/mtn-bike-dmg-large.jpg" target="_blank"><img id="imgMtnBikeDmg" class="alignright" src="http://www.pcta.org/images/trail-threats/mtn-bike-dmg.jpg" alt="Mountain Bike Damage on the trail" width="150" height="200" /></a></p>
<p>&nbsp;</p>
<p>The photo shown here depict damage to the Pacific Crest Trail (PCT) caused by the<strong> illegal use of the trail by mountain bike riders.</strong> From the Big Bear to Tehachapi Mountains in southern California, to the Donner Summer and the Sierra Buttes north of Lake Tahoe, to Castle Crags and beyond, mountain bikes on the trail are causing damage and creating a number of “PCT Places in Need.”</p>
<p>Mountain bike riders represent a large (and growing) number of outdoor recreationists. <strong>For example, the International Mountain Bike Association (IMBA) has 32,000 individual members, more than 450 bicycle clubs members, and more than 130 corporate partners.</strong> But regardless of the number of mountain bikers looking for trails to ride on, the status of the PCT remains the same: under U.S. Government regulation, <strong>bikes are prohibited on the PCT</strong>. The Pacific Crest Trail Association (PCTA) has long had a policy supporting this prohibition and continues to press for enforcement of it. Unfortunately, however, U.S. regulations and regulators have not, thus far, been able to curb the illegal use of the PCT by mountain bikers. The resulting trail damage and user conflicts can’t be taken lightly. To complicate matters, bikes are permitted on many trails that lead to the PCT, resulting in bikers reaching the PCT on such trails and then proceeding along the PCT to pick up another feeder trail. Given <strong>land management agency staffing and budget issues, policing and enforcement is sorely lacking.</strong></p>
<p>There are a number of reasons why mountain bikes represent a problem for PCT users and the trail’s future. One we often hear about is safety – the speed at which a mountain bike can travel along the trail, and especially around blind curves, make collisions with hikers or with equestrians a dangerous possibility. Additionally, stock may be easily frightened of bikes and “spook,” potentially causing injury to riders, themselves, and others. But while safety is a significant concern in regards to bikes and the PCT, in this article we’d like to focus on trail damage and trail maintenance issues.</p>
<h5>Simply put, the PCT was not designed or constructed for mountain bikes and is thus easily and seriously degraded by mountain bike use – especially when those bikes are ridden on wet or muddy trail. Riding bikes on wet trails can cause deep furrows and erosion. It typically occurs when riders skid back tires when braking on downhill, apply heavy torque to tires when riding uphill, or simply ride through mud. The damage caused by a mountain biker is much greater than that caused by a hiker or horse because, with a bike, the soil is impacted continuously along the trail, while a hiker&#8217;s or horse’s feet hit the soil only at intervals. The continuous troughs created in trail tread by bikes collect water runoff from the entire hillside above the trail and then act as drainage ditches, creating serious erosion which the PCT was not constructed to withstand. Water that might drain off the trail under pedestrian and equestrian use now runs down it in wheel ruts, eventually removing all the soil and turning the trail into a streambed. In extreme cases, no amount of “trail maintenance” can restore the trail and new trail becomes necessary.</h5>
<p>If you see mountain bikers on the PCT, kindly remind them that they are on the Pacific Crest National Scenic Trail and that by U.S. Government regulation bikes are not allowed on the PCT.</p>
<p>Avoid confrontations. If you engage bikers in conversation try to ascertain where they are from and which trailheads they used to get into the backcountry and onto the trail, as this will help in education and signage. Ask also where they plan to get off the trail. Taking a picture and documenting the location can help agency personnel to enforce the bike closure. Forward all of this information to your local ranger district or other applicable land management unit, or to the PCTA. The concerns of thousands of hikers and equestrians who use the PCT can help to remind legislators and those in charge of backcountry regulation enforcement that PCTA members and PCT supporters continue to believe that mountain bikes do not belong on the Pacific Crest National Scenic Trail.</p>
<p>“I can’t stress enough the importance of responsible trail users reporting illegal uses of the PCT,” says PCTA Regional Representative for N. Calif./S. Ore., Ian Nelson, “It is crucial that we hear from concerned users so that we and our agency partners can strategize as to how to curb the illegal use.”</p>
<p>&nbsp;</p>
<p>The photo shown here depict damage to the Pacific Crest Trail (PCT) caused by the illegal use of the trail by mountain bike riders. From the Big Bear to Tehachapi Mountains in southern California, to the Donner Summer and the Sierra Buttes north of Lake Tahoe, to Castle Crags and beyond, mountain bikes on the trail are causing damage and creating a number of “PCT Places in Need.”</p>
<p>Mountain bike riders represent a large (and growing) number of outdoor recreationists. For example, the International Mountain Bike Association (IMBA) has 32,000 individual members, more than 450 bicycle clubs members, and more than 130 corporate partners. But regardless of the number of mountain bikers looking for trails to ride on, the status of the PCT remains the same: under U.S. Government regulation, bikes are prohibited on the PCT. The Pacific Crest Trail Association (PCTA) has long had a policy supporting this prohibition and continues to press for enforcement of it. Unfortunately, however, U.S. regulations and regulators have not, thus far, been able to curb the illegal use of the PCT by mountain bikers. The resulting trail damage and user conflicts can’t be taken lightly. To complicate matters, bikes are permitted on many trails that lead to the PCT, resulting in bikers reaching the PCT on such trails and then proceeding along the PCT to pick up another feeder trail. Given land management agency staffing and budget issues, policing and enforcement is sorely lacking.</p>
<p>There are a number of reasons why mountain bikes represent a problem for PCT users and the trail’s future. One we often hear about is safety – the speed at which a mountain bike can travel along the trail, and especially around blind curves, make collisions with hikers or with equestrians a dangerous possibility. Additionally, stock may be easily frightened of bikes and “spook,” potentially causing injury to riders, themselves, and others. But while safety is a significant concern in regards to bikes and the PCT, in this article we’d like to focus on trail damage and trail maintenance issues.</p>
<p>Simply put, the PCT was not designed or constructed for mountain bikes and is thus easily and seriously degraded by mountain bike use – especially when those bikes are ridden on wet or muddy trail. Riding bikes on wet trails can cause deep furrows and erosion. It typically occurs when riders skid back tires when braking on downhill, apply heavy torque to tires when riding uphill, or simply ride through mud. The damage caused by a mountain biker is much greater than that caused by a hiker or horse because, with a bike, the soil is impacted continuously along the trail, while a hiker&#8217;s or horse’s feet hit the soil only at intervals. The continuous troughs created in trail tread by bikes collect water runoff from the entire hillside above the trail and then act as drainage ditches, creating serious erosion which the PCT was not constructed to withstand. Water that might drain off the trail under pedestrian and equestrian use now runs down it in wheel ruts, eventually removing all the soil and turning the trail into a streambed. In extreme cases, no amount of “trail maintenance” can restore the trail and new trail becomes necessary.</p>
<p>If you see mountain bikers on the PCT, kindly remind them that they are on the Pacific Crest National Scenic Trail and that by U.S. Government regulation bikes are not allowed on the PCT.</p>
<p>Avoid confrontations. If you engage bikers in conversation try to ascertain where they are from and which trailheads they used to get into the backcountry and onto the trail, as this will help in education and signage. Ask also where they plan to get off the trail. Taking a picture and documenting the location can help agency personnel to enforce the bike closure. Forward all of this information to your local ranger district or other applicable land management unit, or to the PCTA. The concerns of thousands of hikers and equestrians who use the PCT can help to remind legislators and those in charge of backcountry regulation enforcement that PCTA members and PCT supporters continue to believe that mountain bikes do not belong on the Pacific Crest National Scenic Trail.</p>
<p>“I can’t stress enough the importance of responsible trail users reporting illegal uses of the PCT,” says PCTA Regional Representative for N. Calif./S. Ore., Ian Nelson, “It is crucial that we hear from concerned users so that we and our agency partners can strategize as to how to curb the illegal use.”</p>
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		<title>DCR must put conservation first in the Fells</title>
		<link>http://fellsforever.org/2011/10/28/dcr-put-conservation-fells/</link>
		<comments>http://fellsforever.org/2011/10/28/dcr-put-conservation-fells/#comments</comments>
		<pubDate>Fri, 28 Oct 2011 01:50:37 +0000</pubDate>
		<dc:creator>admin</dc:creator>
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		<guid isPermaLink="false">http://fellsforever.org/?p=3019</guid>
		<description><![CDATA[Op-ed published in the Melrose Free Press October 27, 2011 DCR must put conservation first in the Fells With funding slashed to the lowest point in its history the Department of Conservation and Recreation (DCR) declares in its draft Fells Resource Management Plan (RMP) released on September 14th that it will not be able to [...]]]></description>
				<content:encoded><![CDATA[<p>Op-ed published in the Melrose Free Press October 27, 2011</p>
<p><strong>DCR must put conservation first in the Fells</strong></p>
<p>With funding slashed to the lowest point in its history the Department of Conservation and Recreation (DCR) declares in its draft Fells Resource Management Plan (RMP) released on September 14<sup>th</sup> that it will not be able to fulfill important ranger and other Fells staff positions. For example, we learn that funding will not be available for “at least five years” for a Natural Resources Specialist position needed for support of habitat management, trail closures and species protection.  And funding for numerous other Fells staff positions for monitoring and enforcing regulations is “currently unavailable, but may become so in the near future.”</p>
<p>In recent years severe budget cuts to state agencies has diminished staffing for Fells management so that today not even a single DCR ranger is assigned specifically to the Fells.</p>
<p>The result of this has been that the Fells shows increasing signs of impacts to its natural resources, user conflicts have risen, and visitors’ sense of tranquility and safety has been diminished.</p>
<p>There were hopes that a DCR Resource Management Plan would address important issues to help restore the Fells Reservation to its historic role, continuing to provide city dwellers a nearby natural oasis to escape the noise and confusion of city life.  Surely the quality of visitor experiences should be predicated on well-protected resources.</p>
<p>But hopes turned to disappointment when DCR released its draft Fells Resource Management Plan on September 14.  Instead of effective plans for conservation of Fells natural resources and enforcement of regulations, the agency proposes opening more trails to bike riding and promoting more options for dogs to be allowed loose on hiking trails.</p>
<p>Despite DCR’s motto, <em>It’s Your Nature! </em>nature in the Fells will have less of a chance if the new management plans are allowed to go into effect.  And visitors would be increasingly challenged to find quiet, un-impacted places to visit.</p>
<p>For example, the Dark Hollow Pond Trail, which passes through some of the most biodiverse nature in the Fells, would be entirely closed and <em>replaced</em> by 1 &#8211; 3 bikes-only trails. Hiking trails in the Fells targeted to be converted to mountain bike use include the entire Reservoir Trail, &#8220;all or some&#8221; of the Rock Circuit Trail, and &#8220;additional trails&#8221; in the Eastern Fells.</p>
<p>In these proposals DCR has brushed aside comments received last year, such as this one, “<em>my family and I frequently hike throughout the Fells, and numerous times I have had to quickly push my young daughters (aged 4 &amp; 6) from the trail because of approaching mountain bikes.</em>”  Another Fells visitor wrote, “<em>I cannot tell you how many times I&#8217;ve almost been run over by a mountain biker bent on cycling through what used to be a quiet nature reserve for children and families, school groups and seniors&#8230; The Middlesex Fells is desperately needed by its local citizens, who range in age from infants in backpacks and strollers, to older visitors who cannot always hear the cyclists approaching, let alone dodge them</em><em>.“</em></p>
<p>Concerns about increasing incidents of off-leash dog encounters have been overridden by DCR planners to satisfy the wishes of vocal dog owner groups.  Already the Sheepfold has been converted into an off-leash dog park, and the Fells RMP suggests that off-leash dog access could also be permitted on multiple hiking trails, “under voice control,” and that DCR would consider permitting commercial dog walkers to legally bring groups of dogs into the Fells Reservation. For more details visit <a href="http://www.fells.org/">www.fells.org</a></p>
<p>It isn’t just people on trails who are affected by off-leash dogs.  DCR writes that “<em>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,” </em>yet the agency’s policy changes would permit more dogs loose in the Fells with no effective means for enforcement to protect people and natural features.</p>
<p>The Friends of the Fells agrees with Mass Audubon, which in a letter sent last year to the DCR Commissioner stated<strong> </strong>“<em>DCR should not take on extensive new trails or expanded uses at the Fells until it can manage the existing trails and uses.” </em></p>
<p>DCR has it exactly backwards. Resource protection and public safety should come first. A resource management plan should first demonstrate ability to protect resources.  Conservation is the agency’s primary responsibility.</p>
<p>You can help!  The comment period on the proposed Fells Resource Management Plan closes on November 14<sup>th</sup>.  Please send an email or letter today to DCR to request that Fells Resource Management Plan must be revised.</p>
<p>Tell DCR it is imperative they:</p>
<p><strong> </strong></p>
<p><strong>• Implement effective programs to repair and protect Fells resources <em>before</em> considering expansion of recreational access. </strong></p>
<p><strong>• Provide and <em>implement</em> a <em>funded</em> plan for effective Fells enforcement staffing and trail-use management. </strong></p>
<p><strong>• Protect all sensitive natural areas in the Fells, including Vernal Pools, throughout the Reservation.</strong></p>
<p>&nbsp;</p>
<p><strong>Email DCR</strong>: <a href="mailto:rmp.comments@state.ma.us">rmp.comments@state.ma.us</a></p>
<p><strong>or mail</strong> <strong>to: Fells RMP Comments, 136 Damon Rd., Northampton, MA 01060 </strong></p>
<p>&nbsp;</p>
<p><strong>The DCR Fells RMP may be viewed here: </strong><a href="http://cts.vresp.com/c/?FriendsoftheMiddlese/1b6743e91b/809bb08081/01c74a86b1">http://www.mass.gov/dcr/stewardship/rmp/downloads/midfells/rmp-midfellls.pdf</a></p>
<p>&nbsp;</p>
<p><strong>Thank You! </strong></p>
<p>&nbsp;</p>
<p><strong>Mike Ryan</strong></p>
<p><strong>Melrose </strong></p>
<p><strong>Executive Director</strong></p>
<p><strong>Friends of the Fells </strong></p>
<p>&nbsp;</p>
<p>&nbsp;</p>
<p>&nbsp;</p>
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		<title>SIERRA CLUB AND OFF ROAD USE OF BICYCLES</title>
		<link>http://fellsforever.org/2011/10/28/sierra-club-road-bicycles/</link>
		<comments>http://fellsforever.org/2011/10/28/sierra-club-road-bicycles/#comments</comments>
		<pubDate>Fri, 28 Oct 2011 01:46:49 +0000</pubDate>
		<dc:creator>admin</dc:creator>
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		<description><![CDATA[From Sierra Club Massachusetts letter to DCR 11/19/2010 SIERRA CLUB AND OFF ROAD USE OF BICYCLES Although the Club has stated in written communications and at public meetings numerous times that we are not intrinsically opposed to off road use of bicycles where determined to be appropriate, our policy has been misquoted, misrepresented, and distorted [...]]]></description>
				<content:encoded><![CDATA[<p><strong>From Sierra Club Massachusetts letter to DCR 11/19/2010</strong></p>
<p><strong>SIERRA CLUB AND OFF ROAD USE OF BICYCLES</strong></p>
<p>Although the Club has stated in written communications and at public meetings numerous times that we are not intrinsically opposed to off road use of bicycles where determined to be appropriate, our policy has been misquoted, misrepresented, and distorted by user groups not affiliated with our organization. Therefore, we will clarify that policy here.</p>
<p>Sierra Club Policy on Off Road Use of Bicycles state <strong>the use should not be allowed where it would cause the following measurable effects. </strong>This list is not all-inclusive.</p>
<p>1. Significant soil erosion or significant damage to streams or fish habitat.</p>
<p>2. Rutting, impairment of trail drainage, breakdown of trail shoulders, and other forms of damage not correctable using U.S. Forest Service trail maintenance standards.</p>
<p>3. Significant disturbance of plants, animals, or their habitat.</p>
<p>4. Danger to the safety of bicyclists or other users because of bicycle speed, steep grades, steep terrain, sharp curves, slippery or unstable trail surfaces, or limited visibility. Significant displacement or annoyance of other non-motorized users.</p>
<p>5. Damage to archaeological, scientific, historical, or other significant resources, including rare natural features of interest for scientific study.</p>
<p>Without conducting a comprehensive Resource Management Plan, DCR simply can not claim an ability to assess these items, especially “damage to resources” (item 6).</p>
<p><strong>Therefore, all mountain bike usage at the Middlesex Fells, as approved by DCR as the land manager, is currently in direct violation of Sierra Club policy.</strong></p>
<p>Furthermore, DCR has failed to:</p>
<p>1. Promulgate effective implementing regulations where impacts are sufficiently low that vehicle use is appropriate.</p>
<p>2. Monitor trails and areas designated for vehicular use to detect environmental damage or user interference inconsistent with the above criteria.</p>
<p>Where this occurs, <strong>Sierra Club policy clearly states that the trail or area must be closed to vehicles including off road bicycles unless and until effective corrective regulations are established and enforced. Failure to conduct an RMP which addresses all management and resource protection concerns raised in the Club’s policy will necessitate a request to the land manager that all trails be closed to off road bicycle use at the Fells and similar properties.</strong></p>
<p>The Massachusetts Chapter has not yet called for closure of all bike trails at the Fells. As an alternative, we have requested an expedited and comprehensive RMP process in order to achieve a balance where some usage can continue without unacceptable degradation to the resource, as appropriate and determined through the RMP process.</p>
<p>Continued trail usage at the Fells after completion of an RMP would include establishment of</p>
<p>• Identifying the impacts being monitored, including impacts to water quality, soils, wildlife, flora, and other users (accidents, injuries, enjoyment of the trail). Sierra Club Comments Middlesex Fells Trail System Plan (corrected 11/19/2010)</p>
<p>• Establishing quantitative and qualitative measurement scales for impacts.</p>
<p>• Establishing impact thresholds which, if reached, trigger correction or closure of trails.</p>
<p>• Establishing a schedule for monitoring activities.</p>
<p>• Establishing a written reporting system.</p>
<p>• Training personnel to follow the monitoring program (reliable trained persons user groups may be used to supplement monitoring by staff.)</p>
<p>• Specifying baseline inventories to allow for monitoring of trends.</p>
<p>• Securing the resources to carry out the monitoring/enforcement plan.</p>
<p>• Full enforcement of regulations from regular patrolling combined with effective education and an active monitoring program.</p>
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		<title>Forest Service might close illegal mountain bike trail near Aspen</title>
		<link>http://fellsforever.org/2011/10/27/forest-service-close-illegal-mountain-bike-trail-aspen/</link>
		<comments>http://fellsforever.org/2011/10/27/forest-service-close-illegal-mountain-bike-trail-aspen/#comments</comments>
		<pubDate>Thu, 27 Oct 2011 21:22:33 +0000</pubDate>
		<dc:creator>admin</dc:creator>
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		<guid isPermaLink="false">http://fellsforever.org/?p=3003</guid>
		<description><![CDATA[Forest Service might close illegal mountain bike trail near Aspen Cameras possible after Wilderness Workshop pointed out construction of Balcony Trail on Smuggler http://www.aspentimes.com/article/20100922/NEWS/100929950 Scott Condon The Aspen Times Aspen, CO Colorado ASPEN — A “bandit trail” on Smuggler Mountain that&#8217;s growing in popularity among mountain bikers could be closed as early as next month, [...]]]></description>
				<content:encoded><![CDATA[<div>Forest Service might close illegal mountain bike trail near Aspen</div>
<div>Cameras possible after Wilderness Workshop pointed out construction of Balcony Trail on Smuggler</div>
<div><a href="http://www.aspentimes.com/article/20100922/NEWS/100929950">http://www.aspentimes.com/article/20100922/NEWS/100929950</a></div>
<div><a href="mailto:scondon@aspentimes.com">Scott Condon</a><br />
The Aspen Times<br />
Aspen, CO Colorado</div>
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<div>ASPEN — A “bandit trail” on Smuggler Mountain that&#8217;s growing in popularity among mountain bikers could be closed as early as next month, according to the Aspen Ranger District of the U.S. Forest Service.The Balcony Trail was illegally constructed over the past two years in the White River National Forest without prior discussion with the Forest Service, said Martha Moran, recreation specialist with the Aspen office.<strong>“We were thinking of signing it and using cameras and closing it off,</strong>” Moran said. The cameras would be used to try to identify anyone using the closed trail.No plan will be finalized until after the Aspen staff meets with the law enforcement branch of the national forest to prioritize how enforcement officers will spend their limited time, Moran said. There is a chance the Forest Service will also investigate who constructed the trail and pursue enforcement action, she said.</p>
<p>The Balcony Trail has become a skirmish connected to the Hidden Gems Wilderness proposal. In a presentation to the Pitkin County commissioners on Tuesday, Gems proponent Sloan Shoemaker said the illegal trail is an example of why more Wilderness is necessary. <strong>If greater protections aren&#8217;t added, demands for new routes by mountain bikers, dirt bikers and other users of motorized vehicles will lead to further fragmentation of public lands,</strong> said Shoemaker, executive director of Wilderness Workshop.</p>
<p>After the commissioners&#8217; meeting, he said that Wilderness Workshop staff members scouted the trail this summer to gather GPS coordinates and map the route. The information was recently turned over to the Forest Service, and a Wilderness Workshop member accompanied a forest ranger to the trail.</p>
<p>The Balcony Trail is in an area that conservation groups want added as Wilderness as part of the Hidden Gems proposal. The trail, on the south side of Smuggler Mountain, is a single-track route that climbs from a prominent spot on the mountain.</p>
<p><strong>Wilderness Workshop&#8217;s primary concern is that the trail “is just friggin&#8217; illegal,”</strong> Shoemaker said. The trail goes through lands that are severe winter range for elk and a calving area in spring. It is also foraging area for bears and habitat for countless other species of wildlife, according to Shoemaker.</p>
<p>While mountain biking might not affect habitat in the winter, the general use threatens to degrade its value as habitat, he said.</p>
<p>Shoemaker was disappointed that the trail was allegedly cut by mountain bikers over the same period that Hidden Gems organizers were negotiating with cyclists over lands to be designated as Wilderness.</p>
<p><strong>“This community is out of control,</strong>” Shoemaker said. “<strong>This community needs to do some soul-searching.”</strong></p>
<p>He later amended his comment to target a certain segment of the mountain biking community. He said he wasn&#8217;t making a blanket statement about all mountain bikers.</p>
<p>Shoemaker alleged that <strong>the people who built the trail tried to obscure its entry/exit for an undetermined time and keep secret the illegal use of public land as a private benefit.</strong></p>
<p>“It backfired on them, and it&#8217;s going to get shut down,” he said.</p>
<p>Moran said trail construction must go through a thorough Forest Service review process under the National Environmental Policy Act, or NEPA. Issues such as the need for the trail and its affects on the environment would be assessed, she said. If approved, the trail would be properly engineered so it is sustainable and has minimal effect on the surrounding environment. That process requires time, she said.</p>
<p>Numerous trails were illegally constructed in the 1990s on the slopes flanking the Hunter Creek Valley, including Smuggler Mountain, but the vast majority of them were legalized by the Forest Service as part of its forest plan, a management guide for the forest and in a draft of a travel management plan.</p>
<p>But the timing doesn&#8217;t work to legalize the Balcony Trail anytime soon. No Forest Service plan is in the works to accommodate the trail.</p>
<p><a href="mailto:scondon@aspentimes.com">scondon@aspentimes.com</a></p>
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