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August 26, 2010 George Washington Memorial Parkway Headquarters Turkey Run Park McLean, VA 22101 Dear Superintendent

Marshall: I am writing in response to the Record of Determination Reconfirming and Restating Bicycles are not allowed on the roadways of the Clara Barton and George Washington Memorial Parkways (ROD). The logic of this ROD is deeply flawed and leads to a conclusion that unfairly prevents cyclists from accessing a portion of the National Park that is made accessible to other transportation visitors. The making of this discriminatory determination, without the input of the public or the burdened community, is wholly inappropriate and furthers concerns about the Park Services relationship with the regions cycling community. The ROD states that bicycling on the parkway roadways is unsafe and not feasible. No evidence is provided to support these conclusions. Bicycles operate regularly 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 the inability of bicyclists and motorists to share the public space on these Parkways as they do throughout the region. And, although parallel drain grates can be unsafe for bicyclists, the banning of cyclists from roadways to avoid minor repairs to drainage coverings is a disproportionate response. Further, the conclusion that bicyclists have an available and safe alternative wholly ignores 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 Theodore Roosevelt Island, and the C&O Canal Towpath that NPS proposes as an alternative to the paved Clara Barton Parkway is a dirt and gravel patha surface that is impossible or unsafe for many bicycles. An equivalent would be if motorists were directed to an alternative road that was navigable only by a 4-wheel drive vehicle with high clearance. And even if these trails were deemed reasonable alternatives to the Parkways during some periods, they clearly are not during winter periods following snowfallwhen NPS makes no effort to keep them passable for bicyclists. NPS cannot rely on the presence of these trails as an available alternative when they refuse to maintain them as such. In sum, this ROD does not provide a fair analysis of the question of bicyclist access to the Parkways, but rather a rationale for complete abdication of NPS

responsibility to make public land accessible to cyclists in a fair manner. Less restrictive measures have been found throughout the region and the world to enable bicyclists and motorists to share space. The assertion by NPS that similar approaches cannot work on these two roadways is indefensible, and the determination here fails to withstand either legal or logical scrutiny.

Thus, I would like to request a meeting at your earliest convenience to discuss options for addressing the question of cyclist access to the Clara Barton and George Washington Memorial Parkways in a manner that satisfies the demands of logic and law and is informed by the sorts of facts and experience that are provided through the input of the affected public. Sincerely,

Shane Farthing, Executive Director

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