Public Decisions about Public Land

The Goal of Park Planning

The Maryland Park Service started the process of revising the 1998 Trail Management Plan in October 2014. The process, led by Trail Manager Dan Hudson, includes several stakeholder meetings and a public review of the draft Trail Plan.

This official planning process with public participation is what the Sierra Club was requesting for the Park. Although the Trail Management Plan is not as comprehensive as a new Master Plan would be (see below), it would still address many of the projects that are proposed in the PHG Management Plan.

However, although the Sierra Club and the PHG, Inc. are included as stakeholders in the planning process, the PHG proposals are not being considered by the Park Service. In email correspondence ( Rob Dyke re phg trail plans.docx) the Park Manager, Rob Dyke, stated: 

None of the plans in their [PHG's] plan have gone through review nor do they need to in order for the [MHAA] approval process to continue.  None of those plans would have any impact on our planning process for hikers in December.

PHG will not get funding for anything in PVSP that has not gone through our review process.  They will ask for funding for specific plans, AFTER they have gone through our review process. The plan is PHGs plan.  Not the Park Services plan.  We did not write their plan, they did.  We looked at the plan, found nothing that was alarming, saw that their were merits in them getting the status, and gave our approval for the plan in general. 

This means that the public hearings to solicit testimony on the PHG's Management Plan are completely meaningless: the projects mentioned are not even being considered by the Park Service. So the public has NO idea what we are approving PHG to do. There will be no more public hearings after certification. As a private organization, PHG has no obligation to share their plans with the public. What's more, PHG, Inc. already refused to sign a Memorandum of Understanding that would have obliged them to seek the advice of environmental organizations regarding any proposals for the Patapsco Valley State Park (see response from PHG President Slater:  Slater re MOU.docx). If they wouldn't agree to this before certification, they would have little motivation to agree to it afterwards. 

The PHG Management Plan includes this paragraph: 

7.6 Patapsco Valley State Park

The current 5,346 acres of the Patapsco Valley State Park located within the heritage area are governed by the land use designations of the MD DNR as set forth in the Code of Maryland Regulations In accordance with these general provisions, the park area classifications, uses, and development activities are determined by the current Patapsco Valley State Park Master Plan and subsequent and more detailed plans for individual areas. The planning staffs of MD DNR’s Land Acquisition and Planning Group and Integrated Policy and Review Unit are involved in all long-range planning, management, and development projects within the park. The Maryland Park Service oversees the implementation of these activities. 
This is completely inadequate for oversight of development proposals in the Park because the "Patapsco Valley State Park Master Plan and subsequent and more detailed plans" don't exist. The last version of the Master Plan was published in 1981 and is considered obsolete. The latest version of the Trail Management Plan is currently being written. What's more, the Land Acquisition and Planning Group is under the direction of John Wilson, who is also the DNR representative on the MHAA Board. 

The PHG Management Plan includes a provision to fund and help write a new Master Plan for the Park. This is a serious conflict of interest if the PHG is also the managing entity of a Heritage Area that includes the Park. The PHG, Inc. can apply for $100,000 per year in matching funds for its own administration (not for use in the Park). Other grants must also have matching funds, which DNR can't supply. MHAA has about $1.7 million dollars in grant funds left after awarding administrative grants; those funds are to be divided among the 13 Heritage Areas. If the DNR needs $100,000 for a new Master Plan, the chance of getting it from MHAA is negligible.
According to the PHG Management Plan, all grant proposals must be approved by PHG, Inc., making this private organization the gatekeeper for any Park funding through the MHAA. 

The Master Plans for the Maryland State Parks

Most of the Master Plans for the Maryland State Parks are out of date due to budget constraints. The PVSP plan is 33 years old. 

The master plan for a Maryland state park is the result of a systematic process which includes thorough site analysis. assessments of the regional setting, and environmental sensitivity, appraisal of alternatives, public participation, and cost evaluation in formulating the various proposals advanced.
1981 Master Plan for Patapsco Valley State Park 
( PVSP Master Plan 1981.pdf)
The Sierra Club position is that the crucial element is "public participation", especially through the Citizens Advisory Committee. 
The citizens advisory committee works with the principal park planner in drafting a master plan that will be harmonious with the needs and preferences of the local and regional population. Committee members influence the general scheme of a park by voicing their own concerns and by relaying the viewpoints of the public regarding the development issues being discussed.
The 1981 Master Plan was "considered relevant for approximately twenty years". After that, the same process of site analysis, opinion surveys, and public hearings would be required for any subsequent plans. The paticipants in the planning process should include all the stakeholders: experts from the Department of Natural Resources, representatives of special interest groups, and members of the general public.
A Shared Vision 
That process has not yet taken place. Heritage tourism is only one of the recreational opportunities in the Park. The Heritage Areas Program didn't exist in 1981, so the decision to include the Park in a Heritage Area was never considered in the overall vision for the Park. Specific projects, such as building trails and overlooks, can only be considered with respect to the overall plan, and should require a public review as well.

No single special-interest group should have exclusive privileges in deciding the future of the State Park, or any specific construction projects in the Park; it seems like a violation of the public trust for the Park Service to plan and collaborate in private (see the letter from the Park Service to the Howard County Council: Nita Settina re Patapsco Heritage Greenway.pdf).

Balancing the disparate uses of the Park (while preserving it) is the job of the Department of Natural Resources. All the advocates for the Park should be equal stakeholders. The Sierra Club position is that the Patapsco Heritage Greenway, Inc. would not be an equal stakeholder in Park planning if acting as the "managing entity" for the Park at the same time. The expectation is that PHG, Inc. would fund the Master Plan as well (see the Baltimore Sun article, in which the PHG, Inc. president explains, "You can't do one without the other.") 

If certified as "managing entity" of a Heritage Area including Park property, PHG, Inc. would be able to fund and carry out construction projects in the State Park without public review. According to the Howard County Council (see work session video of July 22, 2014 at ), DNR will approve the PHG, Inc. plans through the Maryland Heritage Areas Authority directly. This was confirmed by the Attorney General’s office ( PHA Memo Attorney General.doc): no public review is required.

To construct paths and overlooks in the Park while financing and working on the Master Plan for the Park at the same time, seems like an egregious conflict of interest.

All the other activities of a Heritage Area, from marketing to environmental stewardship to "telling the story", can be accomplished without including the Park in the Area. Including the Park in the Area, before the Master Plan is written, allows construction to begin on projects before they are approved by the public. That is, in fact, the ONLY reason to include the Park from the beginning, rather than adding it to the Heritage Area after writing a new Master Plan.

The Sierra Club position is that the Park's Master Plan, and any potential construction projects for the Park, must first be approved by the public. Share our position with decision-makers, especially at the Park Service: email