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ORIGINAL: 2260 P> r~ tr\ »— I i g r— ~^ From: Stasz, Jeff [[email protected]] Sent: Tuesday, April 30,2002 8:41 PM ;J> : Vu; / To: '[email protected] ^"i:'tf v;-Jri;;i$S!C;ii Thank you for meeting with American Whitewater's representatives on multiple occasions regarding proposed modifications to the State Parks Regulations (Annex A, Title 17, Part 1, Subpart B, Chapter 11). American Whitewater's members are particularly interested in the portions of the proposed rule regarding Whitewater recreation opportunities (§11.220 and §11.219). While we support the proposed regulation changes, including the decision to eliminate quota provisions in §11.75(a)(3) because "they are matters of internal Department policy and do not require regulations", we have two outstanding concerns that we would like to see addressed. Specifically, we would like to work with the Bureau of State Parks to substanttvely address concerns regarding restrictions on waterfall running at Ohiopyle State Park and Whitewater launch and take-out sites across the Pennsylvania State Parks system. Waterfall running. In regard to Whitewater boating, we would like to see the proposed regulation modified to permit waterfall running in Ohiopyle State Park. Short of this, we would like the regulation changed to allow this activity with permission from the Park Superintendent. At present, draft regulation §11.2200(3) states "Waterfall running. Waterfall running is prohibited without written permission of the Department." Our preference is to see this regulation modified to state "Waterfall running. Waterfall running is permitted." If that is not acceptable, then, at a minimum, we propose changing the regulation to state, "Waterfall running. Waterfall running is permitted subject to restriction as determined by the Park Superintendent." Both solutions are consistent with the 500+ letters that American Whitewater members and other paddlers have written to the Department and Governor on this matter. Related to this, §11.220© (1) Lower Youghiogheny River should be changed to read "Lower Youghiogheny River. The Lower Youghiogheny River is the section of the Youghiogheny River between Ohiopyle Borough and the northern most point of the park...". Canoe and kayak launching. As described in Ed Gertler's guidebook "Keystone Canoeing," there are numerous Whitewater sections in state parks that are not addressed or described under regulation. Under the current phrasing most park superintendents are likely to interpret this omission to mean that boating is not permitted on these Whitewater sections. We would like to see this situation changed to allow Park Superintendents the discretion to evaluate boating on a river-by-river basis. Draft regulation §11.219 Boating applies to the use of watercraft other than Whitewater boating. Subsection §11.219(f)(1), prohibits "Launching or removing watercraft at a location that is not designated by the Department as a launching site, without written permission of the Department. Draft regulation §11.220 Whitewater Boating then addresses Whitewater recreation in Ohiopyle, Lehigh Gorge, and McConnells Mill State Park. Thus the status of boating on non-specified Whitewater rivers in the state parks is murky. We recommend amending §11.220 to state "(a) General requirements. A person engaging in Whitewater boating at any state park, including Ohiopyle State Park, Lehigh Gorge State Park, or McConnells Mill State Park shall comply with the following requirements:"; this phrasing would ensure that each participant is adequately equipped for safety, and subject to the watercraft prohibitions regarding motors. In addition, we recommend explicitly acknowledging in a new subsection "(f) Other parks. Whitewater boating will be permitted unless clearly posted otherwise. The decision to prohibit Whitewater boating in a Park will be made by the Park Superintendent." Finally, we would like to express concern that American Whitewater was not sent copies of the public notice regarding the draft regulations comment period though we had met and discussed this issue multiple times with the Department and had been notified at all other stages of the planning process. Page Iof2 ORIGINAL: 2260 1 ' :r n Smith, Gary (DCNR) From: JMac221 @ aoi.com Sent: Tuesday, April 30, 2002 10:13 PM To: [email protected] Subject: Ohiopyle Falls, memory April 30, 2002 Gary Smith, Division Chief PA DCNR, Bureau of State Parks Rachel Carson State Office Building PO Box 8551 Harrisburg, PA 17105-8551 717-783-3307 Dear Mr. Smith, Three of my adult children and I paddle the waterways of PA and other states. I was fortunate to paddle the Ohiopyle falls with one of my children. It is a fantastic memory that we will never forget. I would like,, and my children would like to see more access to running the water fall at Ohiopyle. I am in favor of the AWA position stated below. Sincerely, Jeff Macklin 221 North First Street Jeannette, PA 15644 [email protected] Note that Whitewater boating remains legal in Ralph Stover State Park (the Tohickon) too. Also, there are some easy water state parks such as Oil Creek, Tyler, and Leonard Harrison (the famous Pine Creek Canyon) which are developed for boating. Dear Mr. Smith, Thank you for meeting with American Whitewater's representatives on multiple occasions regarding proposed modifications to the State Parks Regulations (Annex A, Title 17, Part 1, Subpart B, Chapter 11). American Whitewater's members are particularly interested in the portions of the proposed rule regarding Whitewater recreation opportunities (§11.220 and §11.219).While we support the proposed regulation changes, including the decision to eliminate quota provisions in §11.75(a)(3) because "they are matters of internal Department policy and do not require regulations?', we have two outstanding concerns that we would like to see addressed.Specifically, we would like to work with the Bureau of State Parks to substantively address concerns regarding restrictions on waterfall running at Ohiopyle State Park and Whitewater launch and take-out sites across the Pennsylvania State Parks system.Waterfall running. In regard to Whitewater boating, we would like to see the proposed regulation modified to permit waterfall running in Ohiopyle State Park. Short of this, we would like the regulation changed to allow this activity with permission from the Park Superintendent. At present, draft regulation §11.220(c)(3) states "Waterfall running. Waterfall running is prohibited without written permission of the Department." Our preference is to see this regulation modified to state "Waterfall running. Waterfall running is permitted." If that is not acceptable, then, at a minimum, we propose changing the regulation to state, "Waterfall running. Waterfall running is permitted subject to restriction as determined by the Park Superintendent." Both solutions are consistent with the 500+ letters that American Whitewater members and other paddlers have written to the Department and Governor on this matter.Related to this, §11.220(c) (1) Lower Youghiogheny River should be changed to read "Lower Youghiogheny River. The Lower Youghiogheny River is the section of the Youghiogheny River between Ohiopyle Borough and the northern most point of the park...".Canoe and kayak launching. As described in Ed Gertler's guidebook "Keystone Canoeing," there are numerous Whitewater sections in state parks that are not addressed or described under regulation. Under the current phrasing most park superintendents are likely to interpret this omission to mean that boating is not permitted on these Whitewater sections. We would like to see this situation changed to allow Park Superintendents the discretion to evaluate boating on a river-by-river basis.Draft regulation §11.219 Boating applies to the use of watercraft other than Whitewater boating. Subsection §11.219(f)(1), prohibits "Launching or removing watercraft at a location that is not 5/1/02 Page 2 of 2 designated by the Department as a launching site, without written permission of the Department. Draft regulation §11.220 Whitewater Boating then addresses Whitewater recreation in Ohiopyle, Lehigh Gorge, and McConnells Mill State Park. Thus the status of boating on non-specified Whitewater rivers in the state parks is murky.We recommend amending §11 =220 to state "(a) General requirements. A person engaging in Whitewater boating at any state park, including Ohiopyle State Park, Lehigh Gorge State Park, or McConnells Mill State Park shall comply with the following requirements:"; this phrasing would ensure that each participant is adequately equipped for safety, and subject to the watercraft prohibitions regarding motors.In addition, we recommend explicitly acknowledging in a new subsection "(f) Other parks. Whitewater boating will be permitted unless clearly posted otherwise. The decision to prohibit Whitewater boating in a Park will be made by the Park Superintendent." Finally, we would like to express concern that American Whitewater was not sent copies of the public notice regarding the draft regulations comment period though we had met and discussed this issue multiple times with the Department and had been notified at all other stages of the planning process. Sincerely, Jeff Macklin 221 North First Street Jeannette, PA 15644 Jason D. Robertson Access Director, American Whitewater Barry Tuscano President, American Whitewater Pennsylvania Resident Charlie Walbridge Board, American Whitewater Safety Committee 5/1/02 ORIGINAL: 2260 From: tlna meyers [[email protected]] Sent: Monday, April 29, 2002 2:24 PM To: Garyksmith ©state.pa.us iiiiVi^W cdnVilSSlbfr* Subject: Whitewater I am just writing to let you know that I fully support American Whitewater in all of their work and their proposal. Thank you, Christine Meyers Chat with friends online, try MSN Messenger: http://messenger.msn.com Page 1 of 1 ORIGINAL: 2260 c r'r: ! ' ' "~ H Smith, Gary (DCNR) 12——: , ...jmu^^-m-^Bd- From: scot kelley [[email protected]] Sent: Monday, April 29, 2002 8:10 PM ji -v - - c SSION To: [email protected] Cc: [email protected] Subject: Ohiopyle falls I would like to express my strong interest in making Ohiopyle falls on the Lower Yough runnable.
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