Tuesday, February 19, 2013

MHC comments on WSSC regulations on use of WSSC horseback riding trails

Comments of the Maryland Horse Council on the WSSC Budget Hearings
February 19, 1013

The Maryland Horse Council is the umbrella organization representing all of Maryland’s equestrian businesses, farms and enthusiasts, many of whom have enjoyed riding on the WSSC Rocky Gorge trails for decades. We are submitting these remarks relating to the conformance of the WSSC’s new regulations for public access and use of the land surrounding the reservoirs with the legal requirement placed in WSSC’s budget that any new regulations reflect sound science and best industry practices.
First, we applaud WSSC for modifying its original proposal and deleting any requirement that dropped manure be packed out from trail routes, for reinstating use of the equestrian trails (we assume this will be ALL previously available trails) instead of the severely degraded access road/fire break, as well as reinstating free access for seniors.
However, a number of concerns remain. Specifically:
  1. the fees for access from private property seem to have no justification. WSSC’s own regulations allege that these fees “are applied as partial reimbursement to the WSSC for its expenses in maintaining facilities . . ..” It is clear that WSSC has NO expenses in allowing these access points. Indeed, access from private property should SAVE WSSC money, since the need for additional services at “authorized access points,” e.g., pavement of access driveways and parking areas, trash collection facilities, restrooms, etc. will be obviated. AND, direct mounted access to the trails means that trailers and their towing vehicles will not potentially be dropping oil, transmission fluid, antifreeze and other chemicals onto the parking areas, which could wash into the reservoir. Furthermore, pushing enforcement of the requirement for trail access permits on to boarding facilities is unfair. How is the owner of a boarding facility able to monitor the activities of one of its clients who inadvertently strays onto WSSC lands? As yet, there are no “black boxes” for horses. Yet a facility could lose the ability to access the WSSC land for all of its clients, because some one rider made a mistake. These facilities already provide WSSC significant revenue by encouraging their clients who use the trails to purchase permits. An additional fee on the facilities is “double dipping” with no economic justification.
  2. It seems odd and not logically justifiable to close the trails entirely in winter, and yet require that riders at other times of the year check the website to see if trails are open, based on conditions. If WSSC really intends to maintain the website on a daily basis, there is no reason to close trails for months on end in winter. On those days when the ground is frozen solid, trail riding should be permissible and posted as such on its website.
  3. The requirement that "unauthorized"cutting or clearing of brush or trees is prohibited needs to be clarified that routine trail clearing (i.e., cutting of branches that overhang trails and cause hazards to horses and riders, as well as downed trees that block trails) is permitted. There seems to be no sound budgetary logic in prohibiting this volunteer labor force that has served WSSC well for many years. If this volunteer service is not allowed, and if WSSC does not provide its own trail clearing service, within only a couple of years these trails will be obliterated for anyone who wants to use them.
Finally, we would strongly urge:
(1) There seems no reason to not re-open riding on the relatively flat Access Road of the Tridelphia, which was allowed in earlier decades and WSSC's documents show resulted in no detectable damage.
(2) Institution of a volunteer force (like the successful volunteer mounted patrols of numerous area parks and police departments that many TROT members are on), that could facilitate patrolling of WSSC's now un-patrolled lands, which many neighbors are requesting, without the expense of a patrol force that WSSC says it can not afford.
  1. Although EA's GIS mapping does not show any perceptible section of the equestrian trail close to the water, hopefully WSSC will follow EA's suggestion to accept the free offer from the Prince George's Soil Conservation District experts, to assess the trail and determine if any sections should be re-routed, and let TROT do it.

Respectfully submitted,
Jane Seigler
Vice President
MD Horse Council

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