GBCC Input to PWR (long)

Below is text just submitted, on behalf of the Club, to the Fish and Wildlife Service regarding the Comprehensive Conservation Plan for the Patuxent Research Refuge.

The Greater Baltimore Canoe Club, established in 1976, is a non-profit corporation formed to promote, encourage participation in, and provide opportunities for responsible recreational canoeing and kayaking.

The Patuxent Research Refuge is crossed by the Patuxent River and its tributary, the Little Patuxent River. The Patuxent River is the longest river located entirely within Maryland, and for many members of the GBCC, as well as the public, could offer a nearby place to enjoy paddling through the protected Refuge. Paddling through the refuge provides a low-impact opportunity to observe wildlife, photograph nature, and learn about the local ecosystem. These activities are included among those identified for priority uses of the National Wildlife Refuges.

The flow of the Patuxent River through the Patuxent Research Refuge is greatly influenced by the water management practices of the Washington Suburban Sanitary Commission, which controls the outflow from Duckett Dam. Releases from the dam moderate the natural flow. Perhaps due to the usual low outflow from this dam, timber jams have accumulated in the river to the extent it is attractive as a paddling venue to only the most determined paddlers.

There are few artificial restrictions of the flow of the Little Patuxent River through the Refuge. Perhaps for that reason, there are far fewer timber jams in the Little Patuxent as it passes through the Refuge. The Little Patuxent will be very attractive as a paddling venue to many paddlers.

Paddling either the Patuxent or the Little Patuxent through the Refuge should be permitted. GBCC recommends that the Refuge adopt policies to permit paddling of either river, but in particular to encourage paddling of the Little Patuxent. The GBCC realizes there are challenges to opening the rivers and finding volunteers to work with the Refuge toward developing safe alternatives for paddling the rivers that are compatible with the priority uses for National Wildlife Refuges. Alternatives include:

1. Unrestricted access
2. Permitted access on specific dates
3. Guided access

Any of these alternatives could be implemented without facility modification or with modification ranging from access trails to launching facilities.

Alternative 3 might have the benefit of reducing any perceived burden of policing the waterway. Parties could be permitted in a group with a volunteer guide who could report back that the group had come out. GBCC views this as unnecessary but will work with PWR to implement a guided-group alternative if PWR decides it is necessary.

A water trail has been developed for the Patuxent system. Along with opening up the river through the Refuge, PWR should seek inclusion in the water trail.

GBCC notes that in the 1990s the Army released several reports on "Unexploded Ordnance" (UXO) in PWR. Reports on surveys conducted after the completion of contracts to remove UXO found that the risk of encountering an exposed UXO "indeterminate", i.e., the risk exists but cannot be estimated. Further, the report stated the Army has never recorded a case of injury from accidentally stepping on UXO. Accidents either resulted from tampering with the UXO after removal, or encountering UXO during digging. Risk of UXO is acceptable to allow hunting in the Refuge and hunters walk through the Refuge. Given that paddlers would be floating through, their risk of encountering UXO will be dramatically less than hunters. GBCC believes that, at most, risk of encountering UXO warrants a permit process so the paddler can be educated and acknowledge the risk. Permitting could also impose a requirement to report the location of any UXO encountered while paddling.

Beyond opening the River to paddlers, GBCC suggests PWR engage in a more systematic and organized dialogue with its residential and other property owner neighbors, to see if they might consider adding voluntary conservation easements to their land in order to create an expanded buffer around the Refuge. GBCC notes there are organizations such as the Patuxent Riverkeeper, Maryland Environmental Trust and others that will be eager to assist the Refuge in obtaining conservation easements provided PWR ratify the activity through their planning process. Voluntary conservation easements adjoining the Refuge will enhance PWR’s mission of protecting wildlife and will have only the cost of negotiating the easements.

GBCC looks forward to the Comprehensive Conservation Plan process and results. Our proposal to open the Patuxent River and Little Patuxent River to paddling promotes the mission priorities of the National Wildlife Refuge System, and can be implemented with the Refuge’s current resources. All that is really required is to rewrite the rules and permitting guidelines. Similarly, expanding the area available for wildlife conservation with voluntary easements enhances the NWRS mission, and would have little marginal cost. The GBCC will be happy to make a representative available to discuss and advise regarding these recommendations.