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August 26, 2010

George Washington Memorial Parkway HeadquartersTurkey Run ParkMcLean, 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 theburdened 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

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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