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' natural resources. The level of conservation detail and resource protection far exceeds expected standards and is unprecedented in any DCR RMP.

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.

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:

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.

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'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.

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. 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. We understand that the concept of "new" trails can be highly sensitive - 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. We believe that the RMP, and DCR'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.

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's funding at the state level to rectify financial challenges that DCR faces agency-wide.

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'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.

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.

These overarching principles guide the more detailed comments below.

Goal 1: Protecting Water Resources
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.

G1.1, G1.3, G1.4, G1.8, G1.10, G1.11, G1.12 - No specific comments - NEMBA supports the goals.

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. DCR'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'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.

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.

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.

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.

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.

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 "take the mud" and ride the center of any soft areas to prevent trail creep - 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.

Goal 2. Protect and enhance habitats for rare species, natural communities and native plants and animals
NEMBA strongly supports this goal.

G2.2, G2.3, G2.4, G2.5, G2.8, G2.9, G2.10, G2.11, G2.12 - No specific comments - NEMBA supports the goals.

G2.1 NEMBA volunteers our trail engineering expertise to help meet goal G2.1.

G2.6 NEMBA strongly supports this goal.

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.

Goal 3. Preserve the cultural resources of the reservation
NEMBA strongly supports this goal.

G3.1 - G3.16 - No specific comments - NEMBA supports the goals.

Goal 4. Provide for and enhance diverse recreational opportunities
NEMBA strongly supports this goal.

G4.2, G4.3, G4.4, G4.5, G4.6, G4.7, G4.15, G4.16, G4.17, G4.18 - No specific comments - NEMBA supports the goals.

G4.1 NEMBA supports this goal. We have previously applied for, and received funding via the RTP grant program on DCR'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.

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 "us vs. them" entitlement that has been so pervasive for decades. The majority of DCR'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's data. 80% of trail user conflicts are reported to be "social values based" 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.

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.

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.

G4.9 NEMBA strongly supports this goal. In accordance with DCR listing it as "High" 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'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.

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 "multi-use" and not "mountain bike use". This is especially important with the significant natural features in DHP that all users can enjoy - and hopefully displace the illicit MSM activities that make this an area to be avoided.

The Dark Hollow Pond trails should also be showcases for excellence in sustainable trail design and shared-use for the Fells.

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 "High" from the current designation of "Medium." 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.

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?

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.

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 "High." However, we believe that since much of the actual work can be done with skilled volunteer effort, the Resources ranking of "2" is not precisely accurate - it should be either "1" or "1-2".

Goal 5: Enhance compliance with rules and regulations to protect resources and enhance recreational experiences
NEMBA supports DCR's efforts at enhancing compliance with rules and regulations at the Fells. We work to educate our constituents to follow the rules in effect and to practice good trail etiquette. 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.

G5.1, G5.2, G5.4, G5.5 G5.6, G5.7, G5.8, G5.10, G5.11 - No specific comments - NEMBA supports the goals.

G5.3 NEMBA supports this goal but we reiterate the question of how this will be funded.

G5.9 NEMBA supports this goal. See our comments for G4.10.

 

Goal 6: Interpret the natural and cultural resources of the Fells
G6.1 - G6.3- No specific comments - NEMBA supports the goals and DCR's efforts at interpreting and helping to connect Fells visitors to the rich heritage contained within the Fells.

 

Goal 7: Work with diverse partners and volunteers to achieve these management goals.

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's policies and a willingness to participate in a positive, collaborative fashion.

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.

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.

 

Changes to the body of the RMP

Consider removing the section on page 59, Section 4.4 beginning with "In identifying specific trails and areas..." and listing bulleted experiences for mountain bikers, as distinct from pedestrians, for the following reasons:

Mountain bikers do not seek mountain biking-only trails
Aside from pedestrian only trails, all bulleted points in both lists could conceivably apply to all stakeholder groups.
This is further supported by the "Possibly Compatible Interests" listed on page 30, Section 2.6.

 

Consider removing the following speculative - not supported by any data or research - statements from pg. 56, section 4.4:

"Threats from recreational trail uses are not documented, but because of greater average speeds that bikes can travel, and the racers' 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."

"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."

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.