Make Plans for Environmental Protection and Conservation Before Construction
The draft Management Plan for the proposed Patapsco Valley Heritage Area includes numerous construction projects in the State Park, but no detailed measures for environmental protection.
It's not sufficient to propose, for example, to "develop an ecologically sensitive loop trail". Specific instructions are needed, such as these (from he PVSP 1998 Trail Management Plan ( PVSPTrailMngt00000630.pdf):
- Rolling dips shall be used where possible to minimize erosion.
- Stream crossings shall be avoided when possible.
- Stream crossings shall be located where wetland corridors are at the most narrow point and where approach slopes are as flat as possible.
- Water Bars with 3" top width should be utilized at close spacing for steep slopes (25' spacing on 25% slope), gradually decreasing in number as slope decreases (200' spacing on 10% slope).
The 1998 Trail Management Plan will be updated through a public process starting in October 2014.
The Master Plan for the PVSP (see PVSP Master Plan 1981.pdf) became obsolete in 2001, and also needs to be updated. The Department of Natural Resources (DNR) needs to specify the regulations that will govern clearing vegetation, creation of new pavement and other impervious surfaces, stormwater management, erosion control, herbicide use, and many other environmental impacts of new development in the Park. The DNR should conduct resource surveys in the Park and make decisions about accommodating increased visitor numbers.
It is premature to fund and build tourist attractions in the State Park before the resource inventories and development planning have been completed by DNR with public input. Share the Sierra Club position with decision-makers.
Tourist Attractions or Conservation?
The Heritage Area designation is meant to preserve and protect natural resources. The PHG, Inc. draft Management Plan has numerous detailed proposals for Patapsco Valley State Park, intended to increase visitor numbers and open the Park to nearby communities through trails into the Park. There is no assessment of the environmental impact of these proposals.
The PHG, Inc. plan states only that PHG, Inc. will promote “various natural resource protection and conservation activities”; wiill seek to “stay abreast of ongoing research”, support partner activities, and serve as a resource on where the partners can find guidance (Section 8, Objective 1.5). This sounds as if conservation work will be done, not by PHG, but by PHG’s as-yet-unnamed partners.
The plan doesn’t conserve any part of the environment from tourism development. Instead the plan proposes the opposite: adding more land to “existing parks for which public access is possible”. Other land acquisition is planned for property of "historical interest", not ecological value.
The plan includes “continuing the natural resource conservation programs and environmental education programs” that PHG has been conducting since the last attempt at Certification as a Heritage Area, in 2001. These volunteer activities include trash clean-ups and removal of invasive plant species in PVSP.
The PHG, Inc. can continue environmental stewardship efforts and support for environmental groups even if the State Park is not included in the boundaries of the Heritage Area. Because the State Park has no current Master Plan with detailed development and environmental guidelines, and because the PHG, Inc. draft Management Plan doesn't contain any either, the Heritage Area should exclude the State land until these plans are created with public input.