Discussion: Public Comment on Massachusetts' Middlesex Fells

I figure I'll try and put to use the AP groupthink. Today I plan to draft a letter from NEOC to Mass Department of Conservation and Recreation and welcome your ideas.

Mass DCR is requesting input (PDF) on its draft trail system plan (PDF). More information. Public comment ends November 19th.

In this document, there are some (to me) concerning statements about not allowing off-trail use (unless permitted), and some interesting things about mapping sensitive areas, and various collaborating organizations mentioned, but not NEOC.

To help write the NEOC letter, I want references for studies about impact of orienteering on the woods.

And any suggestions for wording or points to make.

Here is my off-the-cuff outline:


Thanks for the opportunity to comment on the draft trails/Fells plan.

NEOC is a 501c3 organization dedicated to education and providing opportunities for everyone to orienteer. Orienteering is a map navigation sport.

NEOC has been putting on meets and classes for people of all ages and abilities in the Fells for many years. This public land is a key resource for orienteering with its unique location close to the urban center of Boston.

[Good things about orienteering]

Orienteering is an off-trail activity.

Orienteering, managed appropriately, is not damaging to the woods. There have beens studies of the effect of orienteering on the woods. [cite them.] In choosing our time of year to hold meets, and the routes of the courses, we avoid negative impact on ecology.

We ask:

* That orienteering be explicitly recognized as an appropriate and supported use of the Fells.

* For a meeting with the DCR to discuss how NEOC could collaborate with the DCR and contribute to stewardship and appropriate use of the Fells.

* For a meeting to increase our knowledge of ecologically sensitive places and times so that we can further improve our event planning

And, please note, that you are all encouraged to write your own letters to DCR too!

I was under impression that CSU had paid for the newest Fells map... should they be in the loop somehow?

Given the current state of things, I would hypothesize it'd be best to not write anything nor bring anything up. Orienteering continues to be allowed if permitted; end of story. No point in creating a record, thereby possibly bringing attention to us from some overzealous, misunderstanding entity. And given the nature of the park, it'd be quite hard for them to "prohibit" off-trail activity. Are they going to post a cop next to, you know, the meeting area?

Yes, I struggle with the question of whether to hide or whether to enter the fray. But in the end I think that having good relationships with, and educating, the land managers is the best approach. There are factions adamantly opposed to off-trail use, and they are definitely making their opinions known.

Cross posted from my log:


some links:
USOF Land Use policy - authored by Terry Farrah and adopted 2006.
Orienteering and the environment - blog post by Ben Rattray, 1/7/2010
Attackpoint thraed - Environment and Orienteering - starts from Rattray's post.
List of scientific studies from O Australia. Looks like a gold mine.
The 2007 case study in ACT (PDF)
IOF review of research into ecological impact of orienteering (PDF)
From the British O site

And, this: A thesis entitled Orienteering in North America: A geographic perspective by Wynia-Machacek. Abstract:

This thesis explores the sport of orienteering. Literature on the popularity of the sport and the impact of orienteering on the environment is reviewed. A questionnaire was submitted to all clubs in North America with a four-part objective. The purpose was to determine what steps clubs are taking to recruit new members and whether clubs are fostering a relationship with local schools. Information was collected in an effort to identify how a club perceives their impact on the environment and what steps clubs take to minimize their environmental damage. Specific detailed information was requested as to why land managers have denied access to clubs.

The findings indicate that 52 percent of clubs are or have experienced some form of land denial, although some of these denials were only temporary in nature. Club size and year established did not appear to be a factor in being denied access. The findings also showed that the majority of clubs are not actively putting effort into increasing membership. Therefore, continued effort to increase participation would not necessarily determine if a club would be subject to future problems in ensuring use of land.

My concern is that those adamantly opposed are apriori irrational, and no amount of scientific evidence is appropriate to convince them. The best amount for them may be zero. The land managers themselves have either been infiltrated/coopted by the zealots, in which case see above, or they haven't, in which case it should be easy to continue dealing with them just like we have been.

What works in this case may not be scientific evidence, but the parks' eventual running out of resources if the enforcement policy is overly expansive. Resources is something all land managers understand.

Also, I'm not sure if a letter from CSU would differ much from a letter written by NEOC/Barb. We have the same desires and concerns which is to say that we want to put on events on the Pine Hill map and we are relying on continued access to our newest map to grow our club.

I think many contests are decided by those who show up and if we state our case properly then the sane people at the DCR will be able to use our letter(s) as a reason to allow off-trail use. It seems to imply that off-trail use is currently prohibited and also posted as such.... I've never slowed down long enough to read those signs I guess :)

I do believe that apart from a concern about ecological damage and new trail creation there is also a feeling that this measure might be able to cut down on the use of the area just north of the sheepfold for 'cruising' as they euphemistically put it. Section 2.9 of the draft lays it out clearly.

I would be happy to write a similar letter and post it, or to write a joint letter from both clubs.

IF you decide to submit comments, I have a few suggestions based on my experience working within government.

Make your letter short and to the point. Government officials dealing with public comment have time to read about 10 percent of the materials that people think they absolutely must read. Brevity is appreciated.

Explain what you want before you go into the details. Ross' summary is a good example ("we want to put on events on the Pine Hill map and we are relying on continued access to our newest map to grow our club.") Think about your 12-second message.

If you have a history of using the area, you should mention it. If you can say something about the area hosting orienteering events regularly since 1975 (or whenever), you should include that.

I wouldn't include references to studies unless the studies are about orienteering in the specific park. Government officials are used to seeing letters full of references to various studies to support just about any position. Studies from stakeholders representing a specific interest just aren't very compelling or useful. You won't convince someone who has already made up their mind that any off-trail use is unacceptable. People who haven't made up their mind won't be convinced by a collection of studies picked by a stakeholder.

Follow-up with a phone call. Make sure they've got the letter. If they've had a chance to look at it, ask if they have any questions or if they think any additional information would be useful. When you speak to a person, you could tell them you've found some studies of environmental impact and ask if they'd like to see them. It is very useful to have contact with a person at the staff level. Don't pester them, but if you can develop a reasonable relationship, it is a good thing.

If both NEOC and CSU want to express their opinions, it would be better to send them as two separate letters. But, they shouldn't be form letters.

It should go without saying, but don't lie and don't be dismissive of opposing points of view.

That's helpful advice, thanks!

National forests everywhere in the USA are developing travel management plans, and that includes mapping the existing trail networks and deciding which trails are good and which are not.

I agree about keeping any letter very short and to the point. The question you need to answer before writing the letter is this: is your club's special use permit at risk? Yes and no require totally different letters. I would simply decide the permit is not at risk and write accordingly. In which case, your key points are that every year the club brings N hundred visitors to the park (M visitor hours or days), and the club looks forward to continuing to work with park staff to protect sensitive areas and enhance the visitor experience for all visitors. That is a single paragraph.

Include an attachment that shows how your club is uniquely qualified to help park staff enhance the visitor experience. Get your club's course designers and course setters to take a close look at the draft trails map and indicate where they would like trails added or removed. Trail connectivity is all the latest thing in public land management. Some club members know the terrain better than anyone except a park ranger. Think about enhancing the trail user experience. Trail alignment and shape (the difference between a boring run and an asthetically exquisite one), problem areas (erosion, permanent muck, shortcutting), destinations (overlooks, meadows, interesting rocks, water, fall foliage, spring flowers, etc.). For beginner courses, you need trail loops of reasonable length in terrain that is appealing and has a good density and variety of mappable features. Remember: don't tell, show. This attachment needs to be very explicit and detailed, and maybe accompanied by a marked up map. Use OCAD or Purple Pen or the like to put numbered circles on the draft map and refer to them in the text.

Finally, don't confuse management plans for trails with management plans for off-trail recreation. Those are distinctly different issues.

Sorry to interlope but I figured you deserve a heads-up since you are putting a lot of great thought into your response. There is a pitched battle going on right now between conservation and recreational groups. The conservation groups are trying to block any improvements to equitable access and also trying to apply the highly restrictive Forest Vision Patch designation TO THE ENTIRE PARK.

Find out more at http://www.gbnemba.org/

Support the recreation-friendly Trails Plan here:
http://www.gbnemba.org/fellscomments

There is a pitched battle going on right now between conservation and recreational groups.

It rarely pays to engage in battle on ground chosen by the opposition. Mass DCR has requested input on a draft trail system plan. Address that request, and do not feed trolls.

Good, thanks!

Update:

On Wednesday evening 6:30-8:30, there will be a meeting in Medford - this is one of a series of DCR meetings to get public input related to the Fells Resource Management Plan, and this is the one meeting in the series most relevant to orienteering. I encourage those in the area to attend and represent the interests of orienteering at this meeting? I probably can't make it because I'm teaching a workshop on orienteering that day.

My biggest concern is the potential for banning off-trail use. My biggest hope is to get more support for orienteering from the DCR.

Here is the info:

Recreation
Co-hosted by Appalachian Mountain Club
• Wednesday, March 2, 2011
• 6:30 p.m. to 8:30 p.m.
• McGlynn School Cafeteria, 3002 Mystic Valley Parkway, Medford
• This workshop will engage the public in further discussing recreational uses and
needs at the Middlesex Fells.