How can the namesake river of Rock Creek Park be overlooked in the Park's new management plan?

Rock Creek National Park is collecting comments on its new General Management Plan. The focus of the Plan is clearly on transportation issues affecting commuters. As a result, the Plan neglects the health and water quality of the Creek as well as the recreation opportunities that the creek provides.

Please lend your voice in support of American Whitewater and write to the Park Service to ask for the Plan to be modified to: (1) explicitly authorize canoeing and kayaking, and (2) include a planning mechanism for improving water quality throughout the Park and restoring the creek for fish health and viability, as well as for public health.

American Whitewater submitted our comments on April 22, 2003. Our letter is attached below. We encourage you to write a letter too and send it to the Park. A sample is attached below to help speed you along.

Rock Creek Park is truly a gem in our nation's capital. It offers visitors an opportunity to reflect and soothe their spirits through the beauty of nature. Fresh air, majestic trees, wild animals, and the ebb and flow of Rock Creek emanate the delicate aura of the forest. -NPS General Management Plan

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American Whitewater's Comments

Adrienne Coleman, Superintendent
3545 Williamsburg Lane NW
Washington, D.C. 20008-1207
202-282-1063


Dear Superintendent Coleman

I am writing on behalf of American Whitewater, a national non-profit organization that represents river recreationists. We have communicated with you, your staff, and your predecessors several times in the past regarding canoe and kayak access to Rock Creek.

We are concerned that the Draft General Management Plan for Rock Creek Park and the Rock Creek and Potomac Parkway does not appear to include any management statements regarding recreational use of Rock Creek through Rock Creek Park.

As the Plan is intended to provide comprehensive guidance on management actions, recreation, environmental conditions, and visitor use of the Park, it is surprising that the Draft EIS omits any reference to either the public's or Park's interest in managing the waters of Rock Creek. This is of concern for several reasons:

First, because American Whitewater asked in 1999 and 2000, and received verbal assurances, that the topic would be addressed in this management plan.

Second, because there is a documented history of institutional forgetfulness among the Park Police regarding historic agreements over the Superintendent's policy to allow canoeing and kayaking.

Third, because the continuing issues of water quality and sanitation are not addressed in the planning document. The namesake creek for the Park, Rock Creek, is regularly subjected to sewage overflows and urban runoff. It is a tragedy of the first order that the primary river in our Nation's Capitol is not better protected and that the Park Service is not doing more to recognize the problem and improve sanitation such that other recreation activities such as fishing and wading may be permitted in the Park.

Rock Creek is a unique urban sanctuary for recreationists and nature lovers within the city. It offers people the chance to hike, jog, bike, rollerblade, tour, and picnic on a daily basis. It also offers limited opportunities for cross country skiing, canoeing, kayaking, climbing and even ice-skating depending on the weather and season.

Unlike other regional tributaries to the Potomac, such as Difficult Run in Virginia, the whitewater on Rock Creek is of moderate difficulty. The creek is not particularly dangerous, and most of the rapids on the creek are rated Class I-II on the international scale of difficulty, with a couple of Class III drops located immediately downstream of the Rock Creek Ranger Station. Depending on water level, the waterfall created by the dam at Pierce Mill ranges from Class III-V. The creek is generally runnable in the immediate hours after a thundershower or for 1-3 days after an extended rainstorm.

I personally have enjoyed paddling the creek at both low and high levels, and have paddled the creek on multiple occasions when Beech Drive was closed due to flooding. The relative dangers were not appreciably different at the two levels and no rapid exceeded Class III with the exception of the waterfall at Pierce Mill. I found that the primary difference in the two levels was that there was less urban debris at the higher flows, and I didn't have to scratch the bottom of my boat on shallower segments.

In terms of safety, most boaters use lifejackets, helmets, and floatation when boating whitewater rivers. Boaters also tend to carry safety throw ropes, safety knives, safety whistles, and first aid kits. While the use of this equipment does not guarantee boater safety, it helps to mitigate the risk of the sport. Regardless, whitewater canoeing and kayaking are relatively safe and are comparable in risk to mountain biking.

There is a long tradition of boating on Rock Creek. While float permits were required for several years, the permit restriction was lifted in 1986. Since then American Whitewater estimates that a few thousand boaters have floated through Rock Creek without incident. For further information on the history of boating in the Park I encourage you to begin by reviewing Superintendent Ellard's 1987 letter to Ron Knipling [L30(NCR-ROCR)] in which Ellard states that "There is no longer a requirement for a boating permit..."

According to the published notes by Lt. Berberich of a Rock Creek Park Staff meeting in on April 27, 1993, "Kayaking is permitted on Rock Creek- no permit needed. USPP requested that a warning sign be placed along the creek to warn of Pierce Mill Falls ahead. Park stated that they would look at it." Lt. Kass forwarded this document to American Whitewater in March 2002, including the handwritten statement that "The current superintendent has continued this policy".

I have attached a timeline that American Whitewater has reconstructed of the major management points affecting river access on Rock Creek. This timeline clearly demonstrates that kayaking and canoeing are long established uses in the park and have been recognized as appropriate activities within Rock Creek. The document shows that canoeing and kayaking have enjoyed the support of many Park Superintendents over the past 30 years; but it also shows that there is a major problem of institutional forgetfulness about these activities within the Park.

As Ed Gertler wrote in 1997, "Because of the regular turnover in management and subsequent disruption in institutional memory, we are always concerned that our privileges might be disrupted by new management personnel who are unfamiliar with our activity and our good record as responsible users."

Boating Timeline

1970 Ed Gertler, Conservation Co-chair of the Canoe Cruisers Association, canoed on Rock Creek. Ed recalls that canoeing was already an established use in the Park before he first floated this creek.

1978 Ed Gertler met with Superintendent James Redmond and drafted a river use permit. Superintendent Redmond adopted the boating permit for Rock Creek Park.

May 10, 1978 Superintendent Redmond writes (A9031-NCR-ROCR) to Ed Gertler detailing the basic elements of the river use permit.

1980's Boating use continued with periodic interference by Park Police who were not aware of Superintendent Redmond decision to authorize canoeing and kayaking on Rock Creek.

February 13, 1987 Superintendent Ellard wrote (L30-NCR-ROCR) to Mr. Ron Knipling and stated that "Due to changes in the United States Code of Federal Regulations which took effect on November 17, 1986, a canoe permit is no longer required in the National Capital Region of the National Park Service… Prior to November 17, 1986, the National Capital Region of the National Park Service was regulated by CFR 36; Part 50. To facilitate a consistent interpretation of laws concerning all National Park Service areas across the nation, we now use Part 7, CFR. There is no longer a requirement for a boating permit in this section."

1989 Ed Gertler asked Superintendent Swain if the permit system was still in effect. Superintendent Swain was unaware of the permit, but after reviewing applicable regulations stated that: a) he saw no reason to perpetuate such unnecessary paperwork, and b) that boating on Rock Creek should continue without permits.

1993 Boaters were again harassed intermittently by Park Police.

April 27, 1993 Lt. Berberich's prepared notes for a Rock Creek Park Staff meeting state in item #3 that "Kayaking is permitted on Rock Creek- no permit needed. USPP requested that a warning sign be placed along the creek to warn of Pierce Mill Falls ahead. Park stated that they would look at it."

May 22, 1993 Ed Gertler wrote to Superintendent Shields and asked for a clarification on boating policy in Rock Creek.

June, 1993 Superintendent Shields responded in writing and stated that "I have coordinated our response and the National Park Service's position with the Park Police regarding paddle-type craft on the creek. There is no prohibition of kayaks and canoes on any section of Rock Creek that is under the jurisdiction of the National Park Service… We do recognize that boating is a compatible recreation activity in the park that should not be complicated or restrictive by a permit system unless future uses warrant… I hope that our position is clear on this issue."

July 7, 1993 Ed Gertler thanks Superintendent Shields in a letter, and states that he will pass on the information to local clubs and boaters.

July 24, 1997 Ed Gertler writes to Superintendent Coleman to request that boating be recognized as a compatible use of the park in future planning documents. Ed Gertler requests that "Because of the regular turnover in management and subsequent disruption in institutional memory, we are always concerned that our privileges might be disrupted by new management personnel who are unfamiliar with our activity and our good record as responsible users." Ed Gertler has no record of a response.

September 17, 1999 Two canoers, Ron Knipling and Mark Halle, were asked to leave the river by Lieutenant Kass. The river was at a low/moderate level. An incident report was filed.

October 1999 Two kayakers, Martin Radigan and a friend, were asked to leave the river by an unidentified officer. According to Lieutenant Kass no incident report was filed.

October 18, 1999 Ronald Knipling, the president of the Blue Ridge Voyageurs Canoe Club, wrote to Superintendent Coleman about his encounter with Lieutenant Kass on September 17th, and asked for a resolution "in favor of unfettered access."

October 26, 1999 Ron Knipling contacted American Whitewater, and American Whitewater's Access Director Jason Robertson wrote to Superintendent Coleman regarding continued support for boater access to Rock Creek.

December 8, 1999 In response to a phone conversation with Assistant Superintendent Cindy Cox, American Whitewater faxed a letter to Assistant Superintendent Cox discussing the appropriateness of boating in Rock Creek. This fax included a copy of the October 26, 1999 letter to Superintendent Coleman.

January 17th, 2000 In a phone conversation between American Whitewater and Lieutenant Kass, the Lieutenant explained that after reviewing Park records and speaking with Assistant Superintendent Cox, the current park administration would respect the former park supervisor's decisions and continue allowing unrestricted river access. The Park police would not restrict boater access to Rock Creek regardless of river level.

January 17th, 2000 American Whitewater's Access Director , Jason Robertson, wrote to Assistant Superintendent Cox and Superintendent Coleman describing the content of the morning's conversation with Lieutenant Kass and requested written confirmation of the boating policy. Based on discussions with Lieutenant Kass, it was American Whitewater's understanding that the Park Police would continue supporting the boating rights and privileges that the public has enjoyed for the last 13 years. In other words, experienced whitewater canoers and kayakers would continue being permitted to float the Class III (IV) creek, regardless of water level and that no special permits or permissions would be required. American Whitewater requested that future planning documents explicitly reflect that canoeing and kayaking recreation are permitted.

February 19, 2000 Nick Lipkowski, an American Whitewater employee and member, was asked to leave the river by Officer Timothy McMorrow (Badge # 475) because he believed that boating was not permitted. A second officer walked up during the conversation between Mr. Lipkowski and Officer McMorrow. This other officer reportedly commented that even if boating were allowed, the park police wouldn't allow boaters on the river because it was too high. However, the river hydrograph indicates that the creek was at a minimum level for boating on the day of this incident and was not too high by any stretch of the imagination. This incident highlights the need for a clear policy statement on boating on the river, as well as a need for a formal education process for Park personnel on the public right to kayak and canoe Rock Creek. A policy statement is essential for securing our member's ability to enjoy the river as they have for more than 30 years, and avoiding the perennial public problems of addressing this use when new park staff are hired.

March 2002 Lt. Kass forwarded Lt. Berberich's April 27, 1993 document to American Whitewater and included the signed and handwritten statement that "The current superintendent has continued this policy".

Rock Creek is one of the foremost urban parks in America. It has effectively addressed use and recreation in an urban setting for decades. The continued tradition of allowing boater access is essential to many visitors' enjoyment of the Park. It would be a tragedy for us to lose this opportunity through a misunderstanding of the visitor experience and management regulations.

In regard to water quality, in May 2001, Washington, DC's Health Commissioner, Dr. Ivan Walks, issued the warning that, "We are not recommending that people use Rock Creek and enter Rock Creek because of standing high bacteria levels..." Dr. Walks added that the bacteria levels in Rock Creek are too high for human contact, and had been for the last year. It is not acceptable that the largest river in the Nation's capitol is one of only a handful of rivers across the country for which there is a health warning. The Park must develop a planning mechanism for improving water quality throughout the Park and restoring the creek for fish health and viability, as well as public health.

American Whitewater encourages you to continue the tradition of working in partnership with the boating community and respect former Superintendent Ellard's sentiments by continuing to allow floating in Rock Creek National Park. We strongly encourage the Park to explicitly allow canoeing and kayaking in Rock Creek National Park within the General Management Plan.

Please call me at 301-589-9453 if you have any questions or would like clarification on any of the matters detailed above.

Sincerely,

Jason D. Robertson
Access Director
American Whitewater


CC: Mac Thornton, Spokesman, Canoe Cruisers
Ron Knipling, President, Blue Ridge Voyageurs
Martin Radigan, Co-founder, Potomac River Safety Group
Ed Gertler, Author, Maryland and Delaware Canoe Trails

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SAMPLE LETTER

Send your comments to the address below or log on the Park's website at http://planning.nps.gov/parkweb/comments.cfm?RecordID=135 and file your comments electronically.

National Park Service, Rock Creek Park
Adrienne Coleman, Superintendent
3545 Williamsburg Lane NW
Washington, D.C. 20008-1207
202-282-1063


Dear Superintendent Coleman

I support American Whitewater and agree that the General Management Plan for Rock Creek National Park is woefully inadequate in addressing management of Rock Creek.

The Plan should specifically authorize canoeing and kayaking in recognition that these activities are a traditional use of the Park and have been for at least 35 years.

The namesake river, Rock Creek, is regularly subjected to sewage overflows and urban runoff. It is a tragedy of the first order that the primary river in our Nation's Capitol is not better protected and that the Park Service is not doing more to recognize the problem and improve sanitation such that other recreation activities such as fishing and wading may be permitted in the Park.

The Plan should specifically address the continuing issues of water quality and sanitation. The Park must develop a planning mechanism for improving water quality throughout the Park and restoring the creek for fish health and viability, as well as public health.

Sincerely,

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Photos from www.nps.gov/rocr/