NATIONAL PARK SERVICE 

CHAPTER 6.0 CONSULTATION AND COORDINATION 

 

 

6.1 PLANNING PROCESS AND PUBLIC INVOLVEMENT 

The process to prepare a GMP/EIS for Great Falls Park began in September 2002. The NPS 

assembled an internal team to develop a preliminary list of issues that needed to be addressed in 

the GMP/EIS. Public scoping was conducted between December 2002 and February 2003. The 

park published a newsletter (Newsletter 1, dated January 2002) where it sought input on the 

concerns and issues that needed to be addressed in the GMP/EIS. This newsletter was sent to 

area residents and governmental agencies, and made available to park visitors. As part of the 

public scoping process, the park also held a public open house on January 28th, 2003. 

Following the scoping process, the planning team explored several alternative scenarios to 

manage the park. A second public consultation process was undertaken in the Fall/Winter of 

2003 where the park presented three alternatives for evaluation in a second newsletter 

(Newsletter 2, dated November 2003). These alternatives were revised and consolidated, 

subsequent to more than 190 public and agency comments that were received, as well as 

additional review by the internal planning team. 

The park prepared a Draft GMP/EIS which was distributed to applicable review agencies, 

organizations and interested citizens in June 2005. In addition, the park conducted an open 

house on September 17th, 2005 to receive comments on the draft plan. Another newsletter 

(Newsletter 3) was published in October 2005 to clarify some concerns that were raised at the 

open house and to correct some inconsistencies in the draft plan. The park received more than 

200 comments during the public comment period that ended on December 15th

, 2005. 

Following a review of the comments that were received, the park has revised the two 

alternatives, as presented in the Final GMP/EIS. Also, the park has prepared responses to the 

substantive issues that were raised in the public and agency comments. These are provided in 

the following section (Section 6.2 Responses to Substantive Comments Received on the Draft 

GMP/EIS). 

At the conclusion of the planning process, the NPS will make its determination on the GMP/EIS 

pursuant to NEPA and issue a Record of Decision (ROD). 
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GREAT FALLS PARK, VIRGINIA y FINAL GMP/EIS 6.2

6.2 RESPONSES TO SUBSTANTIVE COMMENTS RECEIVED ON DRAFT GMP/EIS 

 

Written comments were received on the Draft GMP/EIS from a variety of public agencies, 

organizations, and individuals during the public comment period that began on August 15th

 2005 

and ended on December 15th 2oo5. Oral comments were received at the public open house, held 

on September 17th 2005 at Great Falls Park. All comments received or postmarked during the 

public comment period were reviewed and analyzed. 

The park has prepared responses to all substantive issues and concerns that were raised in the 

comments received. These issues and concerns are categorized by general topics, and described 

in greater detail through representative quotes from the comments that were received. 

Complete comments from public agencies and community organizations are included at the end 

of this chapter (under Section 6.3) 

 

 

6.2.1 Alternatives 

 

Issue 6.2.1.1: Support for Alternative A presented in the Draft GMP/EIS, with concerns. 

Representative Quote: I approve of the “Alternative A” approach, providing for 

no changes to the current climbing access availability at Great Falls (I approve of 

restrictions at the sites known at Gorky Park, MicroDome, and Flat Iron). I feel 

that the draft, as written, is unfair to climbers, did not provide for appropriate 

independent study of the site, and used outdated information. 

Response: As described under Section 2.1.2 (Alternative A - Continue Current Management 

Practices) of the Final GMP/EIS, climbing activities in the park would continue 

similar to current conditions, with no restrictions at the Gorky Park, Microdome 

and Flat Iron climbing areas. 

Issue 6.2.1.2: Support for Alternative B presented in the Draft GMP/EIS, with concerns. 

 

Representative Quote: I strongly urge you and the National Park Service to work 

with Friends of Great Falls (FOGF) to revise Plan B so that it will be more 

palatable to the climbing community, while continuing to observe the 

preservation concerns of park management 

 

Representative Quote: I believe that Alternative B would be more justified and 

scientifically sound if it presented the intent to further study the interactions of 

all park users and these sensitive resources and to initiate more focused actions 

where there is more evidence to support them, rather than generalized policies 

such as Parkwide permitting. 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative) of the 

Final GMP/EIS, the NPS will prepare a Climbing Management Plan (CMP) to 

manage climbing activities, and a Trails Management Plan (TMP) to manage 

hiking, mountain biking, and horseback riding activities throughout the park. 

Both of these plans will be prepared with extensive coordination and input from 
CONSULTATION & COORDINATION 

6.3 NATIONAL PARK SERVICE 

the public including, the local rock climbing, horseback riding, hiking and 

mountain biking communities, as well as park neighbors. 

The NPS has initiated a study to assess the potential impacts of climbing on cliff 

habitat and rare plant species. Similarly, the NPS is planning to conduct a study to 

evaluate the impacts of trail activities on sensitive natural and cultural resources. 

Both of these studies would provide scientific information to guide the 

management policies that would be adopted as part of the CMP and TMP. 

Issue 6.2.1.3: Range of management alternatives proposed for evaluation in the Draft 

GMP/EIS. 

Representative Quote: Preparing a GMP/EIS with only one action alternative and 

a clearly unacceptable "no action" alternative does not suggest much thought was 

devoted to developing a range of reasonable alternatives that provide differing 

alternatives regarding the Park's management. 

 

Response: Several additional management alternatives were developed for the park, but 

were eliminated due to either public feedback, significant potential impacts on 

park resources identified early in the environmental review of the project, or 

operational concerns. These include three alternatives for the future use and 

management of Great Falls Park that were presented for public evaluation in the 

Alternatives Newsletter (Newsletter #2) that was released for public review in 

November 2003. The alternatives that were developed during the preparation of 

the General Management Plan for the park are briefly described under Section 

2.4 (Alternatives Considered but Eliminated) of the Final GMP/EIS. 

 

Issue 6.2.1.4 Modify Management Prescriptions. 

 

Representative Quote: In the FEIS, include continued provision of unique 

recreational experiences, especially to specialized recreation activities such as 

kayaking and rock climbing, in the management prescription for the Mather 

Gorge Zone. NPS officials have publicly stated that visitor safety is not the 

number one concern; nor is there any instance of demonstrated resource 

damage. Therefore, providing unique and challenging recreation opportunities 

should be included in the stated management prescription for this zone. 

 

Response: As described under Section 2.3.3 (Mather Gorge Zone) of the Final GMP/EIS, the 

NPS would continue to provide unique and challenging recreation opportunities 

in this zone. As stated in the document, "The Mather Gorge Zone would provide 

visitors with opportunities to view the Potomac River, as well as to pursue 

recreational activities such as rock climbing, hiking, boating and fishing in 

designated areas." 

 
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GREAT FALLS PARK, VIRGINIA y FINAL GMP/EIS 6.4

6.2.2 Affected Environment 

 

Issue 6.2.2.1: Need for corrections and additions to text regarding natural resources. 

 

Representative Quote: Plan does not clearly reference the sources of the names, 

the taxonomic concepts, and the conservation ranks of the rare communities. 

The meaning of the "G" and "S" ranks are not explained (the criteria are different 

for communities than for species), and, from the explanation given to climbers at 

the October 24th meeting, it is apparent that there is confusion among National 

Park Service staff about who recognizes the taxonomic units and defines global 

ranks. The community names listed in the Plan are colloquial, sometimes they 

match those listed for equivalent concepts that can be found on Natureserve's 

Explorer website (http://www.natureserve.org/explorer/); sometimes they do 

not. I assume that both the source of the taxonomic concepts themselves and the 

state and global ranks are opinions of either the conservation organization, 

NatureServe or the Virginia Natural Heritage Program, but it is impossible to 

understand this from the document, as the Plan cites neither the source of the 

names or ranks nor the equivalent Latin names (as was done for the species). 

 

Representative Quote: NPS uses the phrase "regionally rare" to bolster its 

argument for protecting certain plant species. Without being clearly defined, the 

phrase has no meaning and cannot be used in and of itself as a supporting 

argument. In the document, NPS needs to explain the phrase, including what 

body made the designation and the geographic boundaries that are used. For 

example, does the "region" include the other side of the gorge in Maryland, or 

does it only refer to Virginia. In the document, NPS should also state that none of 

the plants in question are listed as either "Threatened" or "endangered" as 

defined by the Endangered Species Act. 

 

Response: The Final GMP/EIS has been updated and provides this information under 

Section 3.3.3 (Biological Resources) and Appendix E (Rare, Threatened and 

Endangered Species Status and Description of Ranking). 

 

Issue 6.2.2.2: Missing source information. 

 

Representative Quote: The source of the maps of the rare communities is not 

cited. 

 

Response: The Final GMP/EIS has been updated and provides this information below each 

map in the document. 

 

Issue 6.2.2.3: Need information on federally listed threatened or endangered species in 

the park, if any. 

 

Representative Quote: In the FEIS, clearly state whether any federally listed 

threatened and endangered species are known to reside in the Park; provide a 

listing of any all such species, and describe their status in terns of recovery. 

Otherwise, state none are found. 
CONSULTATION & COORDINATION 

6.5 NATIONAL PARK SERVICE 

Response: There are no federally listed threatened or endangered species located at Great 

Falls Park. This is stated in the updated Section 3.3.3 (Biological Resources) of the 

Final GMP/EIS. 

Issue 6.2.2.4: Development of strategies to manage invasive plant species. 

 

Representative Quote: p. 2.15 (Resource Condition or Character) Nowhere in this 

document is the impact and management of invasive introduced species 

adequately addressed. Currently, the natural vegetation over much of Great Falls 

Park is being overrun by invasive exotic plants, including (but not limited to) 

Japanese stilt-grass (Microstegium vimineum), Chinese wisteria (Wisteria 

sinensis), garlic-mustard (Alliaria petiolata), Japanese honeysuckle (Lonicera 

japonica), bush-honeysuckle (Lonicera maackii), vinca (Vinca minor), and many 

others. The spread of these exotics is often compounded by other activities 

including excessive herbivory of native species by white-tailed deer, horseback 

riding, disturbance of soils by visitors, and Park management and construction 

activities. Managing invasive species will be absolutely critical to "preserving 

natural resources and settings." Without a commitment to such management, the 

viability of many natural communities in the Park will be heavily compromised in 

the near future. Although a cooperative project with The Nature Conservancy for 

spot control of invasives in critical areas is currently underway, much more will 

be needed in the future. If this is not the correct place in the document to address 

this issue, it should be spelled out in no uncertain terms elsewhere. 

 

Response: The Park acknowledges the importance of preserving the viability of natural 

communities found at Great Falls Park through exotic invasive plant 

management. Natural Resource Management staff will continue to work with 

the National Capital Region’s Exotic Plant Management Team (EPMT), The 

Nature Conservancy and volunteer groups to target invasive plant infestations 

and coordinating activities to control them. The cooperative project with The 

Nature Conservancy, however, is dependent on future funding. Great Falls Park 

also follows guidance included in a plan entitled, A 5-Year Plan for Invasive 

Exotic Plant Treatments Along the George Washington Memorial Parkway 2004-

2008. 

Issue 6.2.2.5: Validity of Taxonomy. 

Representative Quote: Of the three plant species of concern named at the public 

meeting in September, one species, Amelanchier nantucketensis, is of 

questionable taxonomy, “suspected of being an apomictic species or a stabilized 

hybrid, perhaps same as plants previously called Amelanchier stolonifera var. 

micropetala”; (Natureserve, 2005). Its status is correspondingly listed as 

questionable. While the status of another species, Solidago simplexvar. racemosa, 

is listed as S1 (five or fewer populations in the state of Virginia), the number if 

individuals comprising the population found in the Gorge appears to be in the 

thousands. I would hope that even if data will not be made public, the effect of 

recreational activities on the plant population as a whole would be the focus of 

any impact study. 
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GREAT FALLS PARK, VIRGINIA y FINAL GMP/EIS 6.6

Response: The status of Amelanchier nantucketensis cited on Natureserve seems to be 

following what is cited in Gleason and Cronquist (1991) Manual of Vascular 

Plants of Northeastern United States and Adjacent Canada. However this is not 

the current (though unpublished) thinking of plant taxonomists dealing with 

Amelanchier species who believe that A. nantucketensis warrants status as a 

distinct species. NPS management polices call for protection of all state listed 

species (individuals, not populations) regardless of their abundance within a 

park. To take a view contrary to this could allow for destruction of large portions 

of a population, provided some plants remain. This would not be consistent with 

NPS management policies. 

Issue 6.2.2.6: Need for Clarification 

Representative Quote: The third sentence in the fist paragraph on page 3.36 

contradicts the third sentence, second paragraph on page 3.34, with regard to the 

“viability” of terrace communities in Great Falls Park. One sentence states these 

communities have “good viability” and one sentence states these communities 

have “fair viability”. Which is correct? Recommendation: In the FEIS, clearly 

describe what the viability of the terrace communities has been determined to be, 

and include a discussion of the methodology used to determine this. 

Response: The comment on page 3.36 of the Draft GMP/EIS erroneously identified terrace 

communities “to have only fair viability”. That portion of the study was 

discussing upland forest habitat and not terrace communities. The text has been 

corrected in the Final GMP/EIS and identifies the following: 

• “Overall, terrace communities in the Gorge are considered to have good 

viability based on good size, good landscape context and the fair 

condition of resources (Nature Conservancy 2001).” (Page 3.34) 

• “Overall, upland forest habitat in the Gorge are considered to have only 

fair viability based on the fair condition of resources, fair landscape 

context and poor size (Nature Conservancy 2001).” (Page 3.37) 

6.2.3 Supporting Data for Impact Analysis 

 

Issue 6.2.3.1: Need for scientific data to support decisions and impacts identified for 

changes to climbing activities under Alternative B (Preferred Alternative). 

 

Representative Quote: Closures of any climbing areas in Great Falls Park must be 

based on scientific proof and it must be demonstrated that climbers are causing 

the destruction of the natural environment in these areas. As it is currently 

worded, the draft plan does not provide a sound, scientific justification for the 

closure of these three climbing areas. In addition, the National Park Service 

should explore all options to protect natural resources before closing a climbing 

area. I believe that in many cases, it is possible to protect natural resources by 

measures other than closing a climbing area. 

 
CONSULTATION & COORDINATION 

6.7 NATIONAL PARK SERVICE 

Representative Quote: Botanical studies conducted in 1993 and 1994 are out-ofdate and only represent a snapshot conducted at a certain point in time. To 

support the climbing restrictions and adequately address the impact of climbing 

on plant populations, a more recent study should have been conducted over a 

several year period. This type of timeseries approach is really the only way to 

control for the effect of other variables that could be impinging upon plants in 

specific climbing areas. Cross-sectional studies conducted over a limited period 

are not adequate for evaluating the impact of climbing on specific areas. 

Representative Quote: Simply stating that a plant is “regionally rare” does not 

automatically justify restricting human access to an area simply because said 

species is, or may be found there. 

 

Response: As identified under Section 2.1.2 (Alternative B - Preferred Alternative), the NPS 

has initiated a study ("Assessment of Climbing Impacts on Cliff Habitat and Rare 

Plant Species at Great Falls Park, Virginia and C&O Canal National Historical 

Park, Maryland") that will include developing and applying objective methods 

for assessing trampling-related impacts from visitors along trails, at cliff-top and 

cliff-base vistas, at recreation sites, and from climbers on the cliff-face. Rare 

vascular plants and many non-vascular plants (e.g. lichens, mosses, liverworts) 

will also be surveyed in the vicinity of cliffs, as these areas have been omitted in 

most previous surveys. If impacts to rare plants or rare plant communities are 

detected, they will be documented and investigated, and recreation management 

practices designed to avoid or minimize associated resource impacts will be 

identified. This study has a tentative completion date of 2009. Under Alternative 

B (Preferred Alternative), the NPS would prepare a Climbing Management Plan 

(CMP) that will be based on the information gathered for this study. 

 

Issue 6.2.3.2: Need for scientific data to support decisions and impacts identified for 

changes to horseback riding or mountain biking activities under Alternative 

B (Preferred Alternative) 

 

Representative Quote: The Management Plan implies that horses are damaging 

resources within the Park, but does not provide enough specifics for us to 

address the issue. We believe most trail erosion is caused by heavy rain - not 

horses or bikes. 

 

Representative Quote: No scientific studies show that mountain bikers cause 

more wear to trails than other users. 

 

Response: As identified under Section 2.1.2 (Alternative B – Preferred Alternative), the NPS 

will conduct a scientific evaluation of sensitive natural and cultural resources 

impacts resulting from trail activities. If impacts are detected, they will be 

documented and investigated, and recreation management practices designed to 

avoid or minimize associated resource impacts will be identified. Under 

Alternative B, the park would prepare a TMP that will be based on the 

information gathered for this study. The purpose of the TMP would be to ensure 

that horseback riding, hiking, and mountain biking activities, as well as access to 
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GREAT FALLS PARK, VIRGINIA y FINAL GMP/EIS 6.8

key areas for other activities such as climbing or interpretation, continue on 

designated trails in the park, but in a manner that is consistent with the NPS’s 

responsibility of protecting park resources. The TMP will recommend best 

practices, especially in areas where trails are located within or adjacent to 

sensitive resources and would discuss the need for management strategies. 

 

 

6.2.4 Environmental Consequences 

 

INTERPRETATION

Issue 6.2.4.1: Provide visitors education about sensitive plants. 

 

Representative Quote: I would like to see a proposal in the management plan to 

develop signage in the park that would educate visitors on the unique natural 

habitats of the park – particularly the bedrock terrace, the bedrock floodplain, 

and the swamp. Although there is signage about the cultural and historical 

aspects of the park such as the old Patowmack Canal, there is currently no 

signage about the rare natural communities and the need to protect them. 

Representative Quote: Educate the climbers. Instead of making it virtually 

impossible to climb at Mather Gorge, have signs with photos at the tops of cliffs 

showing and naming the "sensitive" plants. Give climbers a sense of their own 

responsibility in protecting these species. 

Representative Quote: Particularly when the park is closing trails to protect these 

rare communities, it is very important to educate visitors about why these areas 

need to have limited access. The signage on the boardwalk trail to Olmsted Island 

across the river at Great Falls, MD would be a good model for signage at Great 

Falls Park. Signage should be placed near the natural communities but not at 

them as even small construction projects disturb the habitat and visitors reading 

the signs would likely compact the nearby soil. 

 

Response: Earlier in 2006, the NPS installed 14 new interpretive trailside exhibits that 

interpret the significance of the Potomac Gorge, as well as the relationship of the 

gorge with the Chesapeake Bay watershed. In addition, under Alternative B - 

Preferred Alternative (as discussed in Section 2.1.2 of the Final GMP/EIS), NPS 

would expand the interpretive programs at the park with additional educational 

materials and exhibits. These materials and exhibits would be located at the 

visitor center and on-site at some of the resource areas. The interpretive 

programs would be aimed at enhancing a visitor’s experience and understanding 

of the cultural and natural features that contribute to the park’s significance. 

These features include the Patowmack Canal, Matildaville, the Potomac Gorge, 

the Potomac River watershed, and the linkage to the area’s American Indian 

heritage. The programs would also focus on promoting safety and providing 

guidance on how to recreate in a manner that minimizes impacts on the park’s 

resources. 

 
CONSULTATION & COORDINATION 

6.9 NATIONAL PARK SERVICE 

NATURAL RESOURCES

 

Issue 6.2.4.2: Need for identification of the amount of clearing required to locate US Park 

Police horses off of Jackson Lane. 

 

Representative Quote: The construction and use of a new on-site Park Police 

horse facility is likely to promote the invasion and spread of non-native plant 

species. If the facility must be moved on-site, it should be constructed in already 

cleared areas, avoiding the loss of additional Forestland, and the contractors 

should use best management practices to minimize surrounding forest habitat 

disturbance and prevent the spread of invasive species. 

 

Representative Quote: Page 4.16 states that, "The area off Jackson Lane is mostly 

wooded with some clear areas. Developing stables and a paddock area for horses 

may require clearing some of the existing vegetation in this area and could result 

in a minor adverse impact." The DEIS does not specify the approximate acreage 

of clearing needed nor does it delineate the vegetation that may be impacted. 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative) in the 

Final GMP/EIS, NPS would undertake further studies before finalizing a decision 

to locate USPP horses at this site. These studies would identify whether any 

clearing of vegetation would be required to locate stables and a paddock area, 

and would include additional environmental documentation and a survey for 

potential archaeological resources. 

Issue 6.2.4.3: Provide for protection of Threatened and Endangered Species. 

 

Representative Quote: Difficult Run has been designated as a Threatened and 

Endangered Species Water, due to the presence of wood turtles, which are listed 

by the Commonwealth as a threatened species. Other streams in the vicinity of 

the Park also support this species. Wood turtles are found primarily in and near 

clear brooks and streams in deciduous woodlands. Although highly terrestrial, 

they typically remain in moist areas. As with any long-lived and slow-reproducing 

species, the loss of a single wood turtle can have devastating effects on the species 

population. It is a violation of Virginia law, according to the Department of Game 

and Inland Fisheries, to harm a wood turtle or to keep it for personal possession. 

The Department of Game and Inland Fisheries recommends the following 

[Wood Turtle Conservation Measures]: [a] Provision of an undisturbed riparian 

buffer of at least 300 feet in width be restored and/or preserved along Difficult 

Run and other perennial streams that are known to support, or to have potential 

to support, wood turtle populations; [b] Provision of undisturbed buffers 100 feet 

wide along intermittent streams; [c] Incorporation of wood turtle conservation 

into the Park's environmental education programs, including use of appropriate 

signs to inform Park visitors about the wood turtle, including the status of wood 

turtle conservation and legal status in Virginia. 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative), the NPS 

would prepare a TMP. The purpose of the TMP would be to ensure that 
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GREAT FALLS PARK, VIRGINIA y FINAL GMP/EIS 6.10

horseback riding, hiking, and mountain biking activities, as well as access to key 

areas for other activities such as climbing or interpretation, continue on 

designated trails in the park, but in a manner that is consistent with NPS’s 

responsibility of protecting park resources. . An evaluation of sensitive natural 

and cultural resources (including threatened and endangered species) impacts 

resulting from trail activities will be conducted as part of the TMP. 

Currently, the Difficult Run Trail runs parallel to Difficult Run and is located less 

than 100 feet from the stream. During preparation of the TMP, the NPS would 

examine the impacts of the trail, and its use for hiking, biking, and horseback 

riding, on wood turtles. If impacts are determined, the NPS would explore 

options for minimizing impacts, including rerouting the trail if necessary. 

 

Issue 6.2.4.4: Impacts of flooding on natural resources. 

 

Representative Quote: In the FEIS, include an assessment of the impacts to 

natural resources, especially impacts to sensitive plant species, caused by annual 

flooding of the Potomac River. Contrast and quantify these impacts to those 

impacts thought to be caused by human activities. 

Response: As described under Section 3.3.3 (Biological Resources), the Potomac River’s 

periodic flooding is one of the primary contributing factors towards the 

biological diversity present in the Potomac Gorge. Areas that flood relatively 

frequently are dominated by riparian communities and species associated with 

floodplains; areas on higher elevations that flood relatively less frequently are 

dominated by terrace communities consisting of upland species; and, upland 

forest blocks are located in areas that rarely or never experience flooding. 

Therefore, periodic flooding generally benefits the existing natural resources in 

the park. 

 Impacts resulting from human activities will be discussed in the CMP that the 

NPS will prepare based on the ongoing study ("Assessment of Climbing Impacts 

on Cliff Habitat and Rare Plant Species at Great Falls Park, Virginia and C&O 

Canal National Historical Park, Maryland"). The study will include developing 

and applying objective methods for assessing trampling-related impacts from 

visitors along trails, at cliff-top and cliff-base vistas, at recreation sites, and from 

climbers on the cliff-face. If impacts to rare plants or rare plant communities are 

detected, they will be documented and investigated, and recreation management 

practices designed to avoid or minimize associated resource impacts will be 

identified. 

RECREATIONAL ACTIVITIES - CLIMBING

 

Issue 6.2.4.5: Concerns with managing climbing activities in the park. 

 

Representative Quote: I urge that the final GMP/EIS defer all specific decisions 

on whether anchors or permits should be included in a CMP to the CMP process 

itself. 
CONSULTATION & COORDINATION 

6.11 NATIONAL PARK SERVICE 

Representative Quote: The following changes are needed to Alternative B: all 

current climbing areas shall be labeled "Designated Climbing Sites". The NPS 

and FOGF shall collaboratively study and jointly decide on the following issues 

and the concomitant details of how, what, where, when, etc. [regarding] access to 

Designated Climbing Sites, need for permanent anchors, [and] need for permits. 

 

Representative Quote: Should a CMP be proposed in the revised GMP as part of 

Alternative B or an equivalent, it must be prepared collaboratively with the local 

climbing community, including FOGF. The details of the process -procedural, 

legal - that will be followed to prepare a CMP need to be included in the 

GMP/EIS or through a Memorandum of Understanding. 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative) of the 

Final GMP/EIS, the NPS would continue to provide climbing opportunities in 

Great Falls Park and would prepare a CMP under Alternative B. The park will 

prepare the CMP as a collaborative effort with the public and the climbing 

community, with the intention of continuing climbing as a traditional visitor use, 

but in a manner that is consistent with NPS’s responsibility of protecting park 

resources, as required by its Management Policies. In general, the CMP is 

anticipated to: (a) examine climbing routes on a case-by-case basis and 

recommend whether the climbing areas should be expanded, kept the same, or 

reduced; (b) examine access to the climbing areas from adjacent trails and, in 

areas where access is off undesignated trails, work with the public to develop 

strategies where access is maintained; (c) recommend best practices, especially in 

areas within or adjacent to sensitive resources. These practices could include the 

limited use of fixed anchors or an access pass for specific areas if necessary to 

avoid sensitive resources; and (d) potentially close specific areas on a temporary, 

periodic, or permanent basis, if necessary for resource protection. 

NPS would also adopt temporary measures on a trial basis until the CMP is 

prepared. The park is concerned with potential impacts from foot traffic on the 

globally rare Central Appalachian/ Piedmont riverside prairie located between 

the southern end of Overlook #3 and the Sand Box climbing area. To avoid 

potential damage to this resource, the park would: (a) designate a trail to access 

Gorky Park, Microdome and Flat Iron climbing routes located in this area; (b) 

allow access to this area with an access pass; (c) formalize an existing 

undesignated trail used commonly by climbers as the only access route to the 

Sand Box climbing area; and (d) install a fence along the River Trail to preclude 

visitors from entering the area other than at the designated trail head. 

 

Issue 6.2.4.6: Temporary closure of climbing areas. 

Representative Quote: To the extent that any plants need temporary protection 

for re-growth, the NPS should work with climbing organizations to work on a 

plan that is precisely tailored to temporarily restrict climbing in certain specific 

locations and certain specific times. Climbers are responsible stewards of the 

environment and would respect any valid temporary and narrowly tailored 

action to avoid damage to specific, documented damage to natural resources.
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GREAT FALLS PARK, VIRGINIA y FINAL GMP/EIS 6.12

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative) of the 

Final GMP/EIS and above under Response to Issue 6.2.4.5, the park would 

implement the following measures on a trial basis. To address the park's concern 

with potential impacts from foot traffic on the globally rare Central Appalachian/ 

Piedmont riverside prairie located between the southern end of Overlook #3 and 

the Sand Box climbing area: (a) the park would designate a trail to access three 

climbing routes (Gorky Park, Microdome and Flat Iron) located in this area; (b) 

climbers would be allowed to access this area with an access pass. The purpose of 

the pass would be to discourage casual visitors from entering this area, as well as 

for the park staff to provide visitors with educational information about 

appropriate recreational practices in the area. NPS anticipates that this access 

pass would be issued seasonally, in unlimited quantities, and free-of-charge; (c) 

the park would formalize an existing undesignated trail used commonly by 

climbers as the only access route to the Sand Box climbing area. Visitors seeking 

to access the Sand Box area would be required to enter and exit using the 

designated route; and (d) the park would install a fence along the River Trail to 

preclude visitors from entering the area other than at the designated trail head. In 

addition, the park would use signage to inform visitors that an access pass is 

required to use the trail, as well as identify the level of difficulty of the trail, and 

whether it was open for access due to river conditions. 

Issue 6.2.4.7: Use of Trails. 

 

Representative Quote: We believe that improved signage on trails and an 

improved trail system will eliminate any concerns that horses will damage the 

Park's historical assets. Our group is ready to meet with Park staff to devise 

appropriate solutions to any specific problems that the Park believes are created 

by horses. 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative) of the 

Final GMP/EIS, the park would prepare a TMP as a collaborative effort with the 

public including, the local horseback riding, hiking, mountain biking, and rock 

climbing communities, as well as park neighbors. The purpose of the TMP would 

be to ensure that horseback riding, hiking and mountain biking activities, as well 

as access to key areas for other activities such as climbing or interpretation, 

continue on designated trails in the park, but in a manner that is consistent with 

NPS’s responsibility of protecting park resources. An evaluation of sensitive 

natural and cultural resources impacts resulting from trail activities will be 

conducted as part of the TMP. Opportunities for horseback riding on designated 

trails would remain available; however, the park would consider redesigning, 

realigning, or closing portions or entire trails where the TMP identifies adverse 

impacts to a sensitive natural or cultural resource. 

 

Issue 6.2.4.8: Use of anchors for climbing activities. 

 

Representative Quote: The GMP/EIS also proposes the installation of permanent 

anchors. The reasons for this policy are not given, and there are no details as to 

how a permanent anchor scheme would operate. Questions: - What is the 
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6.13 NATIONAL PARK SERVICE 

principal rationale for anchors? Are anchors for protection of trees/other 

resources or for 'safety'? - What type of anchors? (Bolts, chains?) How many 

anchors, what spacing, what areas? - If bolts, would they be located at edge of cliff 

(safety concern) or back from edge? - Are climbers to be required to use the 

permanent anchors only - e.g. no use of anchors constructed with rock climbing 

hardware, and/or no use of trees (including protective wraps around trees)? - 

Will available routes be limited to one or two directly under the permanent 

anchors, with routes to the side not permitted, if anchors are not installed above 

all routes? - Would anchors be shared by different climbers? - Would commercial 

groups have preferential use of anchors? - Who takes responsibility for proper 

installation and maintenance of anchors? 

 

Representative Quote: Am opposed to the use of artificial anchors to determine 

or regulate climbing areas or the number of climbers. Artificial anchors, if used at 

all, should be assessed on a case-by-case basis, and such evaluations should be 

made in conjunction with the NPS and representatives of the climbing 

community, such as the Friends of Great Falls. 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative) of the 

Final GMP/EIS, the park will prepare a CMP as a collaborative effort with the 

public and the climbing community, to ensure that climbing continues in the park 

as a traditional visitor use, but in a manner that is consistent with the NPS’s 

responsibility of protecting park resources. During the preparation of the CMP, 

the NPS will explore and recommend best practices, especially in areas within or 

adjacent to sensitive resources in the park. These practices could include the 

limited use of fixed anchors for specific areas if necessary to avoid sensitive 

resources. 

 

Issue 6.2.4.9: Need for permits. 

 

Representative Quote: The proposed GMP/EIS does not contain sufficient detail 

to fully evaluate the impact it could have on climbing at Great Falls. In particular, 

the proposal to require permits to climb at Great Falls is not spelled out in 

sufficient detail to provide the climbing community with the ability to determine 

how it will effect us. 

 

Representative Quote: The GMP/EIS proposes that under the preferred 

alternative permits would be needed for rock climbing. In the GMP/EIS, the 

reasons for needing a permit system are not given, and there are no details as to 

how a permit system would operate. It is consequently difficult to comment on 

either the rationale or mechanics of a permit system. Questions - Are permits 

intended to simply reduce climber numbers, or is there a perceived safety aspect 

as well? - If there is a safety aspect, how will increased safety be implemented? 

What tests would be used to issue permits? Who would implement the tests? 

How often? Where? - If permits are intended for access control, i.e., as a quota, 

how would this quota be determined? Would permits be for a day or a shorter 

period? Would permits be for individual routes? Would permits be reissued 

during the day if someone leaves? - How will permits be issued/checked? Will 
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there be a fee, in addition to the usual entry charge? What resources does the 

NPS have to implementing a permit system, both administratively and in terms of 

enforcement? For example, would there by rangers at the top of the cliffs? - 

There seems to be the possibility of permit capture by commercial groups which 

will eliminate recreational access. Would commercial groups be 

included/excluded from any permitting system/quotas? 

 

Representative Quote: Oppose permits for individuals, but support them for 

groups. In fact, I would like to see group permitting enforced more, as there are 

COUNTLESS times that I find groups at climbing sites during the summer who 

are not permitted. These groups (often church groups or community groups) 

have not reviewed the application procedures or documented that they have 

appropriate staff and safety protocols, yet they climb anyway. 

 

Representative Quote: The GFCA is opposed to the permitting of any specific 

user group. Part of the challenge of this park is to balance the protection of 

natural and cultural resources with recreational opportunities. We suggest that 

special outreach materials be developed which would contain tips on good 

stewardship for each user group. 

 

Representative Quote: How will permits protect sensitive plants? What is the 

purpose of permits? Is the idea that permits with a fee would discourage climbers 

from using Great Falls, and that fewer people would mean less damage to plants? 

If that is the case, has the NPS undertaken any studies to determine the 

relationship between the damage to these plants and the numbers of climbers? Is 

the idea that fee permits would compensate the NPS for relocating rare plants? If 

there will be no fee for permits, what effect are they intended to have? Has the 

Great Falls NPS consulted with any other national park areas on the use of 

permits? If so, what input did the Great Falls NPS receive? 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative) in the 

Final GMP/EIS, and above in response to Issue 6.2.4.5, the NPS will implement 

the following measures on a trial basis. To address the concern with potential 

impacts from foot traffic on the globally rare Central Appalachian/ Piedmont 

riverside prairie located between the southern end of Overlook #3 and the Sand 

Box climbing area, the park would designate a trail to access three climbing 

routes (Gorky Park, Microdome and Flat Iron) located in this area. Climbers 

would be allowed to access this area with an access pass. The purpose of the pass 

would be to discourage casual visitors from entering this area, as well as for the 

park staff to provide visitors with educational information about appropriate 

recreational practices in the area. NPS anticipates that this access pass would be 

issued seasonally, in unlimited quantities, and free-of-charge. The management 

of access to this area through an access pass would be implemented on a trial 

basis and would be reexamined during the preparation of the CMP. 

 
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6.15 NATIONAL PARK SERVICE 

Issue 6.2.4.10: Closure of climbing areas due to concerns with trail access. 

 

Representative Quote: The NPS should, with the FOGF, reroute paths that are 

destructive in order to minimize impact. Both groups are responsible for creating 

and implementing a solution to the problem. It is not acceptable to simply restrict 

access to climbing areas by closing existing paths without creating a replacement. 

 

Representative Quote: Cliff closures are an extreme measure. There are 

alternative access paths to Gorky Park, Microdome and the Flat Irons. A better 

approach would be to mark sensitive sites with designated climbing access paths. 

The Park Service can work with local clubs and the Friends of Great Falls to 

identify and mark these trails. 

 

Response: As discussed under Section 2.1.2 (Alternative B - Preferred Alternative), the park 

is concerned with potential impacts from foot traffic on the globally rare Central 

Appalachian/ Piedmont riverside prairie located between the southern end of 

Overlook #3 and the Sand Box climbing area. 

To avoid potential damage to this resource, the park would adopt several 

temporary measures until a CMP is prepared. These include the following: 

• The park would designate a trail to access three climbing routes (Gorky 

Park, Microdome, and Flat Iron) located in this area. 

• Visitors seeking to engage in climbing would be allowed into this area 

with an access pass. The purpose of the pass would be to discourage 

casual visitors from entering this area, as well as for the park staff to 

provide visitors with educational information about appropriate 

recreational practices in the area. NPS anticipates that this access pass 

would be issued seasonally, in unlimited quantities, and free-of-charge. 

• The park would formalize an existing undesignated trail used commonly 

by climbers as the only access route to the Sand Box climbing area. 

Visitors seeking to access the Sand Box area would be required to enter 

and exit using the designated route. 

• The park would install a fence along the River Trail to preclude visitors 

from entering the area other than at the designated trail head. In addition, 

the park would use signage to inform visitors that an ‘access pass’ is 

required to use the trail, as well as identify the level of difficulty of the 

trail, and whether it was open for access due to river conditions. 

RECREATIONAL ACTIVITIES – HIKING / MOUNTAIN BIKING / HORSEBACK RIDING 

 

Issue 6.2.4.11: Impact of trails on sensitive resources. 

 

Representative Quote: The Plan may also propose to educate visitors through 

increased interpretive programs regarding benefits of preserving wetlands. EPA 

suggests that raised walkways be considered, where feasible, to prevent visitor 

impact to wetlands. 

 
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Representative Quote: We caution against any new activities, including trail 

development, along Difficult Run. Difficult Run has been designated a 

Threatened and Endangered Species Water due to the presence of State 

Threatened wood turtles. 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative), the NPS 

would prepare a TMP. The purpose of the TMP would be to ensure that 

horseback riding, hiking and mountain biking activities, as well as access to key 

areas for other activities such as climbing or interpretation, continue on 

designated trails in the park, but in a manner that is consistent with NPS’s 

responsibility of protecting park resources. An evaluation of sensitive natural and 

cultural resources impacts resulting from trail activities will be conducted as part 

of the TMP. 

During preparation of the TMP, the NPS would examine the impacts of hiking, 

biking, and horseback riding along the Difficult Run Trail on wood turtles. If 

impacts are determined, the NPS would explore options, including rerouting the 

trail, or redesigning portions of it as a raised walkway to minimize impacts. 

Also, as described under Section 2.1.2 (Alternative B – Preferred Alternative) of 

the Final GMP/EIS, interpretive programs in the park would be expanded and 

designed to enhance a visitor’s experience and understanding of the cultural and 

natural features that contribute to the park’s significance. These features include, 

amongst others, the presence of the park within the Potomac River watershed. 

Within this context, the park would explore adding information that highlights 

the benefits of preserving wetlands. 

 

Issue 6.2.4.12: Consider realignment and reconstruction of horseback riding trails in 

sensitive areas instead of closing them. 

 

Representative Quote: We also applaud the exploration of removal of horse 

trails, particularly around Mine Run. For many years, we have been concerned 

about the trampling of rare plants and their habitat along Mine Run near Clay 

Pond. We hope an agreement can be reached with the horseback-riding 

community that will result in alternative trails away from areas with sensitive 

natural and cultural resources. 

 

Representative Quote: The proposed closure of the Mine Run and Matildaville 

trails are examples of trails that make a ride in the park unique and interesting to 

everyone (horsemen included). The primary users of the Matildaville Trail are 

walkers and joggers, not horseback riders. If other users are allowed to continue 

using it, and only riders are prohibited I think you will soon find that you still 

have the same environmental damage you now experience. I say this because the 

primary ingredient to the problem is that the trail has little or no drainage in 

certain key areas. Its continued use by the non-riding public will still result in 

erosion and damage to the environment. What might enable this trail to remain 

viable for all groups would be the establishment of a "raised bed" in those key 

areas that tend to become a bog after the heavy rains of Spring or Fall. When I say 
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6.17 NATIONAL PARK SERVICE 

raised bed, I have in mind something like what gardeners do when they build a 

"raised flower bed". Specifically! This would be a path that has pressure-treated 

boards on each side that retain a stone and crushed stone base covered by several 

inches of stone dust on top. This will raise the elevation of the path anywhere 

from 6 to as much as 12 inches above the surrounding soil in these difficult areas. 

This technique has worked well in other applications and should provide a good 

firm dry surface for all users. It would only need to be employed in those low 

lying areas of the trail where adequate drainage is not naturally available. 

 

Representative Quote: (There is no) credible evidence that wear on the trails 

from horse travel in particular contributes to the disturbance of relics that are still 

buried, or to sensitive vegetation. If there is any concern about wear and tear 

from traffic in general, this should be addressed by realigning those sensitive 

parts of the trail for all traffic, rather than singling out equestrians as unwelcome 

users. 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative), the park 

would prepare a TMP, in partnership with the public including the local 

horseback riding, hiking, mountain biking, and rock climbing communities, as 

well as park neighbors. The purpose of the TMP would be to ensure that 

horseback riding, hiking and mountain biking activities, as well as access to key 

areas for other activities such as climbing or interpretation, continue on 

designated trails in the park, but in a manner that is consistent with NPS’s 

responsibility of protecting park resources. An evaluation of sensitive natural and 

cultural resources impacts, including the area adjacent to Mine Run and Clay 

Pond, resulting from trail activities will be conducted as part of the TMP. Based 

on the study, the TMP would recommend whether the designated trail system 

should be expanded, realigned, kept the same, or closed in segments where 

resource impacts are identified. The TMP would also recommend best practices, 

especially in areas where trails are located within or adjacent to sensitive 

resources, such as near Mine Run or Clay Pond. Such practices could include 

requiring an access pass for specific areas or uses if necessary, fencing off areas to 

avoid sensitive resources, or reconstructing portions of the trail using techniques 

such as boardwalks to minimize impacts. 

 

Issue 6.2.4.13: Criteria for determining closure of routes. 

 

Representative Quote: There is no stated mechanism for developing clear 

criteria/decision process for closing certain climbing areas. 

 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative), the NPS 

will prepare a CMP. The CMP will be prepared in partnership with the public 

and the climbing community, and would be aimed to ensure that climbing 

continues in the park as a traditional visitor use, but in a manner that is consistent 

with NPS’s responsibility of protecting park resources. NPS has recently initiated 

a study to assess the impacts that climbing may have on cliff habitat and rare plant 

species. This study would provide an assessment of impacts related to climbing. 

The CMP would be based on the information gathered for this study and would 
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GREAT FALLS PARK, VIRGINIA y FINAL GMP/EIS 6.18

determine appropriate strategies to manage climbing activities. In general, the 

CMP could recommend potentially closing specific areas on a temporary, 

periodic, or permanent basis, if necessary for resource protection. The CMP 

would also describe the process that would be undertaken if such closure is 

recommended. 

 

Issue 6.2.4.14: Connections with regional trails. 

 

Representative Quote: The Northern Virginia Regional Commission staff has 

reviewed the application described above. Staff would like to note that the 

existing system of formal and social trails currently serves to provide park access 

for wide range of users. For example, a social trail provides an important link 

between the Fairfax County Stream Valley equestrian/hiking trail along Difficult 

Run and the Ridge Trail, making possible a circuit hike that includes the scenic 

Difficult Run Trail in Great Falls Park. Staff recommends that the General 

Management Plan ensure that the internal trail system components of the plan 

coincide with existing and future plans for the Fairfax County trail network. In 

addition, the plan should provide for collaboration and cooperation with local 

government officials to identify a suitable alignment for the Potomac Scenic 

National Heritage Trail. 

Response: As described under Section 2.1.2 (Alternative B - Preferred Alternative) of the 

Final GMP/EIS, the proposed Cross County Trail (CCT), Potomac Heritage 

National Scenic Trail (PHNST), and the Georgetown Pike Trail (GPT) would be 

connected to existing trails within the park. These existing trails within the park 

would be identified by their original names, as well as the name(s) of the regional 

trails that would connect to them. For example, the existing Difficult Run trail 

within the park would also be named the CCT to indicate that the trail functions 

both as the Difficult Run Trail and as a route for the CCT. Potential routes for the 

regional trails through the park are illustrated in Figure 2.2 on page 2.14 of the 

FEIS. 

During the preparation of the TMP, the NPS would coordinate with Fairfax 

County to identify a preferred route for the PHNST. 

Issue 6.2.4.15: Adoption of a temporary trail closure policy in response to weather 

conditions. 

 

Representative Quote: A good bit of erosion occurred in June/July when we had 

the heavy rains. Many of the main trails have major gullies as a result of the rain - 

this is not as the result of horses or bikes. It may be better to institute a policy that 

says no bike or horseback riding within X number of days after a rain. I know that 

gets difficult to determine, but I think the horse community would be more than 

willing to go along with more a flexible policy then having to get permits. 

 

Representative Quote: (There is no) credible evidence that wear on the trails 

from horse travel in particular contributes to the disturbance of relics that are still 

buried, or to sensitive vegetation. If there is any concern about wear and tear 
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6.19 NATIONAL PARK SERVICE 

from traffic in general, this should be addressed by realigning those sensitive 

parts of the trail for all traffic, rather than singling out equestrians as unwelcome 

users. 

 

Response: At this time, no permits or access passes are recommended for horseback riding. 

However, as described under Section 2.1.2 (Alternative B - Preferred Alternative) 

of the Final GMP/EIS, the NPS will prepare a Trail Management Plan (TMP), the 

purpose of which would be to ensure that horseback riding, hiking and mountain 

biking activities continue on designated trails in the park, but in a manner that is 

consistent with NPS’s responsibility of protecting park resources. 

An evaluation of sensitive natural and cultural resources impacts resulting from 

trail activities will be conducted as part of the TMP. Based on the impacts that are 

identified by the study, the park would explore measures including closing 

specific trails on a temporary, periodic, or permanent basis, if necessary for 

resource protection. The TMP would also recommend best practices, especially 

in areas where trails are located within or adjacent to sensitive resources. Such 

practices could include requiring an access pass for specific areas or uses if 

necessary on a temporary or permanent basis, or fencing off areas to avoid 

sensitive resources. The park will prepare the TMP with input from the public 

including the local horseback riding community. 

Issue 6.2.4.16: Consider closure of undesignated (social) trails on a case-by-case basis. 

 

Representative Quote: The trail runs from Riverbend Road, at a point about 1000 

feet from its intersection with Georgetown Pike and joins the Ridge Trail near 

Old Dominion Drive. I believe the route of the trail was originally called "The 

Old Country Road". The trail is clearly shown on the large map posted in the 

museum section upstairs in the building at Great Falls Park. Currently, hikers and 

riders walk alongside the old roadbed. A copy of a photo taken of the map is 

attached with the trail circled. The trail is not shown in the Draft General 

Management Plan on page 3-9 (figure 3-2), which shows existing trails. As the 

trail is a least as old, if not older, than any of the trails shown, I point out this 

omission since it is clearly shown on your own museum map. If the Interior 

Department closes this historic trail into the park, it would mean that equestrians 

and hikers alike would have no way of accessing the park from my property, nor, 

for that matter, from any other location north of Georgetown Pike. Equestrians, 

in particular, would have to load their horses onto trailers and drive them to the 

park. This makes no sense from an overall environmental point of view and 

would tie up a lot of parking spaces at the park. It is hard to see how this would 

serve any positive environmental purpose. 

 

Representative Quote: Existing trails, social trails too, need to remain in service. 

As visitors increase in number we need to spread them out rather than 

concentrating them on fewer trails. 

 

Representative Quote: I feel that closure or development of social trails should be 

on a case-by case basis. Some social trails may benefit the park by being 
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GREAT FALLS PARK, VIRGINIA y FINAL GMP/EIS 6.20

designated and maintained. Development of trails may include the reduction of 

impacts to vegetation, the wildlife habitat, and water resources. 

 

Response: In accordance with the recommendations in the Final GMP/EIS, the park would 

eliminate some of the existing undesignated (social) trails to reduce habitat 

fragmentation, and to protect sensitive resources. As described under Section 

2.1.2 (Alternative B - Preferred Alternative), the NPS would prepare a TMP to 

ensure that horseback riding, hiking and mountain biking activities, as well as 

access to key areas for other activities such as climbing or interpretation, 

continue on designated trails in the park, but in a manner that is consistent with 

NPS’s responsibility of protecting park resources. The TMP would focus on 

reducing the number of undesignated trails in the park, and adopting practices to 

avoid the creation of new undesignated trails. During the preparation of the 

TMP, the park will examine the designated and undesignated trails on a case-bycase basis to determine their impacts on sensitive natural and cultural resources 

and identify which trails should be eliminated, relocated, or left as is. The TMP 

would designate those existing undesignated trails, that provide access to key 

areas without impacting sensitive resources. 

 

Issue 6.2.4.17: Horses and bikes access to the Potomac Heritage National Scenic Trail. 

Representative Quote: Mountain bikers and equestrians use the carriage roads 

that link Great Falls to other areas. We believe the new management plan needs 

to implicitly state that the Potomac National Heritage Trail be designated as bike 

and horse "friendly" ensuring these users will be able to traverse this section of 

the heritage trail, even following reroutes and fortifications of the canal zone. 

Response: The proposed PHNST would be connected to existing trails within the park. The 

potential route for the trail through the park is illustrated on Figure 2.2 on page 

2.14 of the Final GMP/EIS. As proposed, the PHNST would overlap with the 

Difficult Run Trail, Ridge Trail, and the Old Carriage Road Trail, all of which 

currently allow access for mountain biking and horseback riding. 

 

Issue 6.2.4.18: Consideration of a separate bike and hiking lane along the entrance road. 

 

Representative Quote: Concerning general trails, the NPS should strive to 

connect trails with trails outside the park so that enhanced hiking and biking 

opportunities would be available. Bicycle and hiking access to the park should be 

encouraged to help alleviate traffic and parking problems. Currently, it is quite 

difficult to get into the park by bicycle. A separate bike lane and hiking trail 

should be added to the entrance road as well as adding access from other nearby 

parks. 

 

Response: As described under Section 2.4.7 (Construct a New Trail Parallel to Old 

Dominion Drive and Georgetown Pike), the park had explored the option of 

constructing a bicycle/pedestrian trail parallel to the entrance road. One of the 

reasons for eliminating this option from further consideration was the potential 

impacts of such a trail on the park's natural resources. Preliminary analysis 
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6.21 NATIONAL PARK SERVICE 

conducted indicated that a proposed trail along Old Dominion Drive (between 

Georgetown Pike and the entrance station) would be approximately 4,700 feet 

long, of which approximately 600 feet would be in the form of a boardwalk. 

Assuming that this trail would be eight feet wide, parallel on the east side of Old 

Dominion Drive, and built for the use of bikes and pedestrians (since horses 

would not use the boardwalk portion), it has the potential to result in the 

following impacts: 

• Require the removal of 37,600 SF of vegetation (4,700 feet x 8 feet). A 

considerable amount of trees along Old Dominion Drive would need to 

be removed to establish this trail. 

• Approximately 75 percent of this trail would be on land with more than 12 

percent slope 

 

Issue 6.2.4.19: Restriction of pets to specific areas of the park. 

 

Representative Quote: Pets should be limited to particular areas, or kept away 

from specified areas. The Department of Conservation and Recreation 

recommends measures such as a leash law and restrictions intended to avoid user 

conflicts. 

 

Response: NPS regulations require pets to be on leash in all national parks (36 CFR Section 

2.15). In addition, dogs are required to be on leash in all public areas of Virginia 

(except dog parks). This information is posted near the entrance station, bulletin 

board, and park information cards that are given out to the visitors. 

RECREATION – BOATING

Issue 6.2.4.20: Access to the Potomac River 

 

 Representative Quote: The Department of Conservation and Recreation 

recommends portage opportunities for kayak and canoe users.

Response: As described under Section 2.1.2 (Alternative B – Preferred Alternative), access to 

the Potomac River for whitewater boating and kayaking would remain available 

from Fisherman’s Eddy (located between Overlooks 2 and 3), and AA Gorge. 

6.2.5 Funding for Improvements 

Issue 6.2.5.1: Funding for trail improvements. 

 

Representative Quote: We urge that the park staff explore the possibility of 

getting additional funding for River Bend Road and the Georgetown Pike Trails 

by working with Great Falls Trail Blazers as they pursue funding for local trails. 

 

Response: The park is very interested in obtaining additional funding for Riverbend Road 

and Georgetown Pike Trails and would be interested in coordinating application 
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GREAT FALLS PARK, VIRGINIA y FINAL GMP/EIS 6.22

for funding with the Trail Blazers. The Trail Blazers should contact the Site 

Manager to coordinate this effort. 

 

6.2.6 Community Involvement 

 

Issue 6.2.6.1: Collaboration with community and local organizations to develop the 

Climbing Management Plan and the Trails Management Plan. 

 

Representative Quote: Great Falls Park is heavily utilized by climbers, 

equestrians, hikers, boaters, and others. Many of these users are conservationminded and would like to see the Park's natural areas protected while preserving 

access to recreational resources .....Perhaps through education and partnership, a 

plan can be developed that would reduce impact to sensitive plant species, while 

retaining adequate access to popular climbing locations. We urge you to consider 

holding public discussion forums focused on various user groups to encourage 

education about sensitive resources and an open discussion about how to protect 

these resources. 

 

Representative Quote: Policy decisions concerning rock climbing should not be 

made unilaterally by the NPS. Instead such policies should be developed through 

consensus between the NPS and the rock climbing community. 

 

Representative Quote: Commission staff recommends that the Plan be developed 

to: ensure that the internal trail system components in the Park coincide with 

existing and future plans for the Fairfax County trail network; and provide for 

collaboration and cooperation with local government officials to identify a 

suitable alignment for the Potomac Scenic National Heritage Trail. 

 

Response: To continue engaging the public in its decision-making, the NPS would routinely 

conduct meetings, publish newsletters, and post updates on its website, under 

either alternative. These meetings, newsletters, and web postings would provide 

an update on actions recommended in the Final GMP/EIS and would be utilized 

to solicit individual opinions on specific issues. 

The Federal Advisory Committee Act (FACA) provides agencies with guidelines 

on seeking public input. Consistent with the FACA guidelines, the NPS will meet 

with individuals and groups or organizations involved in rock climbing to obtain 

input during the development of the CMP under Alternative B. Similarly, NPS 

will meet with individuals and groups, including park neighbors, during the 

development of the TMP under Alternative B. 
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6.23 NATIONAL PARK SERVICE 

6.3 COMMENTS FROM PUBLIC AGENCIES AND COMMUNITY 

ORGANIZATIONS 

The following pages provide copies of correspondence received from public agencies and 

community organizations in response to the Draft GMP/EIS.
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CONSULTATION & COORDINATION 6.45 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.46
CONSULTATION & COORDINATION 6.47 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.48
CONSULTATION & COORDINATION 6.49 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.50
CONSULTATION & COORDINATION 6.51 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.52
CONSULTATION & COORDINATION 6.53 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.54
CONSULTATION & COORDINATION 6.55 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.56
CONSULTATION & COORDINATION 6.57 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.58
CONSULTATION & COORDINATION 6.59 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.60
CONSULTATION & COORDINATION 6.61 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.62
CONSULTATION & COORDINATION 6.63 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.64
CONSULTATION & COORDINATION 6.65 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.66
CONSULTATION & COORDINATION 6.67 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.68
CONSULTATION & COORDINATION 6.69 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.70
CONSULTATION & COORDINATION 6.71 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.72
CONSULTATION & COORDINATION 6.73 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.74
CONSULTATION & COORDINATION 6.75 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.76
CONSULTATION & COORDINATION 6.77 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.78
CONSULTATION & COORDINATION 6.79 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.80
CONSULTATION & COORDINATION 6.81 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.82
CONSULTATION & COORDINATION 6.83 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.84
CONSULTATION & COORDINATION 6.85 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.86
CONSULTATION & COORDINATION 6.87 NATIONAL PARK SERVICE
CHAPTER 6 GREAT FALLS PARK, VIRGINIA . FINAL GMP/EIS 6.88