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Nps ROD Response

Nps ROD Response

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Published by tonalblue

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Published by: tonalblue on Aug 26, 2011
Copyright:Attribution Non-commercial


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August 26, 2010George Washington Memorial Parkway Headquarters Turkey Run ParkMcLean, VA 22101Dear Superintendent Marshall:I am writing in response to the “Record of Determination Reconfirming andRestating Bicycles are not allowed on the roadways of the Clara Barton and GeorgeWashington Memorial Parkways” (“ROD”). The logic of this ROD is deeply flawedand leads to a conclusion that unfairly prevents cyclists from accessing a portion of the National Park that is made accessible to other transportation “visitors.” Themaking of this discriminatory determination, without the input of the public or theburdened community, is wholly inappropriate and furthers concerns about the ParkService’s relationship with the region’s cycling community. The ROD states that bicycling on the parkway roadways is “unsafe and notfeasible.” No evidence is provided to support these conclusions. Bicycles operateregularly and safely, on curving roadways with travel lanes of 9 ft. and 11 ft.,throughout the region safely on a daily basis, and NPS provides no evidence of theinability of bicyclists and motorists to share the public space on these Parkways asthey do throughout the region. And, although parallel drain grates can be unsafefor bicyclists, the banning of cyclists from roadways to avoid minor repairs todrainage coverings is a disproportionate response.Further, the conclusion that bicyclists have an available and safe alternative whollyignores the difference in character, quality, and treatment of these “alternatives.”Separate facilities do exist, but they are far from equal. Apart from issues of crowding and speed limits, there is no alternative to the trail north of TheodoreRoosevelt Island, and the C&O Canal Towpath that NPS proposes as an alternativeto the paved Clara Barton Parkway is a dirt and gravel path—a surface that isimpossible or unsafe for many bicycles. An equivalent would be if motorists weredirected to an alternative road that was navigable only by a 4-wheel drive vehiclewith high clearance. And even if these trails were deemed reasonable alternativesto the Parkways during some periods, they clearly are not during winter periodsfollowing snowfall—when NPS makes no effort to keep them passable for bicyclists.NPS cannot rely on the presence of these trails as an available alternative whenthey refuse to maintain them as such.In sum, this ROD does not provide a fair analysis of the question of bicyclist accessto the Parkways, but rather a rationale for complete abdication of NPS’

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