Public Comments - May 2021

Updates to the Superintendent’s Compendium: Park Hours and Prohibition of Organized, Competitive Recreational Events at Gettysburg National Military Park and Eisenhower National Historic Site

National Park Service Response to Public Comments
May 2021

 

I. Introduction
Between January 19, 2021 and February 17, 2021, the National Park Service (NPS) made available for public comment proposed changes to the Superintendent’s Compendium for Gettysburg National Military Park and Eisenhower National Historic Park. The Superintendent's Compendium is the summary of park specific rules implemented under Title 36 Code of Federal Regulations (36 CFR). The regulations contained in 36 CFR are the basic mechanism used by the National Park Service to preserve and protect the natural and cultural resources of the park and to protect visitors and property within the park. The Compendium is updated at least annually and serves as public notice related to designations, closures, permit requirements and other restrictions adopted under the Superintendent's discretionary authority. The Superintendent's Compendium does not repeat regulations found in 36 CFR and other United States Code and CFR Titles, which are enforced without further elaboration at the park level.

Community feedback was specifically sought related to proposed changes in the park’s hours and the prohibition of organized, competitive recreational events. The public comment period was announced on social media, on the park website, and via a press release. The public was invited to obtain the NPS written determination supporting changes to park hours and organized, competitive recreational events for review and to provide comment through the NPS Planning, Environment & Public Comment (PEPC) website. This report describes how the NPS considered public comments and provides responses to the substantive comments.

II. Methodology
During the public comment period, 230 pieces of written correspondence were received electronically via the webform provided through the PEPC system. Each piece of correspondence was read, and specific comments within each correspondence were identified. Comments were classified as substantive or non-substantive. A total of 116 substantive comments were derived from the correspondence received (46 related to park hours and 70 related to organized, competitive recreational events). A substantive comment is defined in the NPS National Environmental Policy Act Handbook (2015) as one that does one or more of the following (Section 4.6):

  • Question, with a reasonable basis, the accuracy of information presented;
  • Question, with reasonable basis, the adequacy of the environmental analysis;
  • Present reasonable alternatives other than those presented; and/or
  • Cause changes or revisions in the proposal.

As further stated in the Handbook, substantive comments “raise, debate, or question a point of fact or policy.” Comments in favor of or against the proposed action or alternatives, or comments that only agree or disagree with NPS policy, are not considered substantive.” While all comments were read and considered and will be used to help create the compendium, only those determined to be substantive were analyzed for creation of concern statements for response from the NPS, described below. Comments related to other parts of the compendium that NPS was not specifically soliciting input on were documented separately and will be considered during future updates.

All substantive comments were grouped by similar themes, and those groups were summarized with a concern statemnt. Following each concern statement are one or more “representative quotes” which are comments taken directly from the correspondence to illustrate the issue, concern, or idea expressed by the comments grouped under that concern statement. A formal response statement is provided that addresses each concern statement. Of the 230 correspondences, 154 (67%) came from commenters in the state of Pennsylvania, while the remaining correspondences came from 25 other states. (Table 1) Although all correspondences were identified in PEPC as being associated with an unaffiliated individual, several correspondences were self-identified as representing a specific agency/ organization including: County of Adams, Healthy Adams County, Inc., Healthy Adams Bicycle/ Pedestrian, Inc., Destination Gettysburg, Mediation Services of Adams County, YWCA Gettysburg, and 2L Race Services.

 
Table 1. Correspondence distribution by state.

State Percentage Number of Correspondence
PA 67.0% 154
MD 7.4% 17
VA 4.3% 10
OH 3.5% 8
NY 3.0% 7
WV 1.7% 4
MA 1.3% 3
NJ 1.3% 3
SC 0.9% 2
NC 0.9% 2
MI 0.9% 2
CT 0.9% 2
TX 0.9% 2
DC 0.9% 2
VT 0.4% 1
FL 0.4% 1
NV 0.4% 1
LA 0.4% 1
IN 0.4% 1
CO 0.4% 1
IA 0.4% 1
IL 0.4% 1
KS 0.4% 1
NH 0.4% 1
WI 0.4% 1
MN 0.4% 1
Total 230
 

III. Changes Resulting from Public Comment
The following changes will be made as a result of public comment:

  1. The description of number of hours the public may access Gettysburg National Military Park, Gettysburg National Cemetery, and Eisenhower National Historic Site will be corrected in the written determination document. (See Concern Statement 01)

  2. Sunrise will be defined as ½ hour prior to sunrise and sunset will be defined as ½ hour after sunset in the Superintendent’s Compendium. (See Concern Statement 01)

  3. The term “neighborhood electric vehicles” in the Superintendent’s Compendium at 36 CFR §1.5(a)(2) will be more clearly defined. (See Concern Statement 08)

No change was made to the determination that organized; competitive recreational events represent an inappropriate visitor use on park roadways within Gettysburg National Military Park.

IV. Comment Analysis and Response

Concern Statement 01
The NPS estimated the change in park hours would reduce public access to the park by 3.5 to 6 hours per day, depending on time of year. This is a major decrease in access that will disproportionately affect local residents as well as limit the ability of the public to engage in traditional activities such as viewing sunrise and sunset, photography, and engaging in recreational activities during cooler and quieter times of the day.

Representative Quotes:

  • Using the verbiage of the park will open 30 minutes prior to sunrise and close 30 minutes after sunset in accordance with (insert source here) would put an official time on the books, state what source becomes the official time keeper, afford sunrise and sunset viewers and photographers the opportunity to partake in their activities, as well as having a standard enforcement action across the board that can be uniformly and fairly carried out.

  • Gettysburg is known for its breathtaking sunrises and sunsets. Many people enjoy photographing the battlefield, me included. In fact, over the years I have given tours to people whose main reason for coming to the park is for the photography. Many of the iconic photos of Gettysburg were taken after the sun set of before it rose. The most spectacular sunset photos can occur up to thirty minutes after the sun goes down. Your proposed regulations would make many of the best photos impossible to get.

  • The proposed new hours of sunrise to sunset would eliminate recreational activity taking place just before and after the sunrise and sunset period. Now more than ever we need to be expanding healthy lifestyle opportunities that align with the mission of National Parks.

  • Visiting the park in the hours just before sunrise or sunset could in fact be a profound experience for those interested in the cultural resources and in imagining the landscape as the site of 19th century battle. Unlike the daytime hours - especially in peak visitation seasons where it can be difficult to block out the buses, cars, tour groups, and monuments that distract from the otherwise preserved landscape - darker hours offer an opportunity to focus on the natural features and to see a uniquely somber vision of the battlefield.

Response Statement:
The following bullet in the written determination provided to the public by the NPS included an inaccurate calculation in the difference in public access based on the proposed change in park hours that is now corrected.

Original Text

  • This action will reduce the number of hours the public can visit the grounds at Gettysburg National Military Park from between -3.5 (winter) and -6 hours (summer) but it also will extend the amount of time that visitors may access and enjoy the Gettysburg National Cemetery and Annex (+6 hours in summer, no change in winter) and Eisenhower National Historic Site (+7 hours in summer and +1.5 hours in winter).

Corrected Text

  • This action will reduce the number of hours the public can visit the grounds at Gettysburg National Military Park from between -0:58 (summer) and -3:39 (winter) hours but it also will extend the amount of time that visitors may access and enjoy the Gettysburg National Cemetery and Annex in the summer (+1:22 hours in summer, -0:26 hours in winter) and Eisenhower National Historic Site at all times of year (+7:02 hours in summer and +1:21 hours in winter).

In addition to the correction above, after consideration of public comments, the NPS will define sunrise to sunset as 30 minutes before sunrise and 30 minutes after sunset. NPS believes it can both accomplish its stated goals as well as provide continued opportunities for visitor use (observing sunrise/sunset, photography, etc.) with this slightly expanded definition. This action will result in a change in the number of hours the public can visit the grounds at Gettysburg National Military Park from 0 hours (summer) to -2:39 hours (winter) and increase the hours visitors may access the Gettysburg National Cemetery (+0:34 hours winter to +2:22 hours summer) and Eisenhower National Historic Site (+2:21 hours winter to +8:02 hours summer) year round.

Please note that the change in hours is presented based on the difference between the longest day of the year (June 21, summer) and shortest day of the year (December 21, winter). (Attachment 1)

Visitors can plan their visit and obtain a listing of sunrise and sunset times by day in Gettysburg, PA at: https://sunrise-sunset.org/us/gettysburg-pa


Concern Statement 02
Other locations within the NPS allow organized race events and this decision seems inconsistent with what other parks allow.

Representative Quotes:

  • A troubling aspect of this proposed policy is that different Parks, in different regions, have historically and contemporarily allowed an array of varied activities.
  • A quick survey of some major battlefield sites that allow races include Antietam (Freedoms Run Half and Full Marathon), Valley Forge (Valley Forge Half and Full Marathon), Shiloh (Rotary Run in the Park), and Chickamauga (Chickamauga Full and Half Marathon).

  • I would also like to mention that 11 times in the past 14 years, my wife and I have both run a 5 mile race in Valley Forge National Park. This 5 mile race is held 100% within the VFNP from start to finish. The Valley Forge Park Race also requires some road closures within the Park as well as busing of Participants and fans into the Park from a remote site. Why would this Revolutionary Run be allowed to continue in VFNP if the more senior WYCA 5K is not allowed in Gettysburg NP?

Response Statement:
An "appropriate use" as defined by NPS Management Policies (2006) is one that is suitable, proper, or fitting for a particular park, or to a particular location within a park. Not all uses are appropriate or allowable in units of the national park system, and what is appropriate may vary from one park to another and from one location to another within a park. The consideration of whether a particular use is appropriate is made based on the specific resources, visitor experiences, and legislation and management documents present in individual park units. Therefore, an activity that may be considered appropriate at Chickamauga & Chattanooga National Military Park may not be considered appropriate at Gettysburg National Military Park.
As described in NPS Policy, "Appropriate visitor enjoyment is often associated with the inspirational qualities of the parks. As a general matter, preferred forms of enjoyment are those that are uniquely suited to the spuerlative natural and cultural resources found in the parks and the (1) foster an understanding of and appreciation for park resources and values, or (2) promote enjoyment through a direct association with, interaction with, or relation to park resources...When proposed park uses and the protection of park resources and values come into conflict, the protection of resources and values must be predominant." (NPS 2006, p. 13) The park General Management Plan (1999), specific to recreational activities, also states that “these opportunities must be consistent with the park's purpose and significance and not harmful to resources or park visitors.” Organized, competitive recreational events, which are timed activities, do not meet this management standard at Gettysburg National Military Park. The NPS will continue to embrace appropriate uses of the park that are consistent with its purpose and protective of its resources and visitor experience including a variety of other non-competitive, organized events managed through the special use permit system.


Concern Statement 03
Some race events that involve responsible race organizers and do not require unusual resources, manpower or road closure should continue to be allowed.Representative Quotes:

  • ...we would hope that event that do not require unusual resources, manpower, or road closures be left on the table for the benefit of both the Park and our community. An example of such an event would be a bike ride, walking or running event, that would begin and end at the Gettysburg Rec Park, with participants leaving the Rec Park in a staggered manner, that would not entail any unusual Park resources or closures.
  • I was very surprised that you allowed seven races in 2019. I think that is quite a disruption to the focus of the park… But before writing off races completely, maybe you could consider choosing those events that can guarantee the respect that you require.

  • While many "races" are not done properly and cause more harm than good to the parks and certain areas, there are other "races" that are done properly and do more good than harm. All races are a burden on the course and area that is used. The race needs to be mindful that the positive aspects of the event and burden outweigh the negative impact. I don't think that all events should be allowed, but also don't feel that all races should be banned.

  • I strongly urge you to consider allowing vetted, responsible race directors host races on NPS property.

Response Statement:
The park “will always consider allowing activities that are appropriate to the park, although conditions may preclude certain activities or require that limitations be placed on them. Park superintendents must continually monitor all park uses to prevent unanticipated and unacceptable impacts. If unanticipated and unacceptable impacts emerge, the superintendent must engage in a thoughtful, deliberate process to further manage or constrain the use, or discontinue it.” (NPS 2006, p. 13) In the absence of a thoughtful, deliberative, park-specific evaluation of whether organized, competitive recreational events are an appropriate use at Gettysburg, issuing a permit for an organized, competitive recreational event has established the precedent for subsequent requests; expanding from 1 organized, competitive race 30 years ago to 5 organized, competitive races in 2019, with new requests for similar events each year. This park-specific evaluation and written determination is not based on the number or amount of resources required by NPS to manage these events but on the individual and cumulative impacts of multiple organized, competitive recreational events on park resources, visitor experience, and visitor safety at Gettysburg National Military Park.


Concern Statement 04
Gettysburg National Military Park is important to the Gettysburg community whose members host a variety of special events in the park. The same justification described for prohibiting organized, competitive race events may be used to preclude non-competitive events that use park roadways or ban all forms of recreational use.

Representative Quotes:

  • While HABPI does not conduct any races, we do host an annual recreational bike ride as a fundraiser for our organization. This event, which has been held the past five years, begins and ends at the Gettysburg Area Rec Park. Specifically we are concerned that, while this event is not a race, our ability to obtain a special event permit might be impacted using some of the same reasoning for not wanting races.

  • I belong to a local bicycle group (Healthy Adams Bicycle Pedestrian Inc.) Unbelievable that we would not be "allowed" to have a bicycle ride through our own battlefield…

  • The GNMP, as such a large and integral part of the Gettysburg community, should be willing to make some modest accommodation that would allow local organizations to conduct a limited number of races and organized rides on Park roads.

  • I ran the Spirit of Gettysburg 5k 25 years ago and hope to do so again in 2021. As recently as two hours ago I was out running on the park and checking monuments and learning about the park. Running on the park is part of the historical experience for many of us and does no harm to cultural or natural resources. Banning organized runs is unnecessary and could lead to eventual banning of all running or other forms of "recreational use."

  • While running, you get a sense of the scale of the battlefield that reminds you of how the soldiers must have felt as the scrambled from battle to battle, carried supplies, or brought up munitions. While the driving tour is certainly informative, for me it pales in comparison to experiencing the park on foot.

Response Statement:
The NPS considers the Gettysburg community to be critical in our ability to be successful both individually and jointly whether it is in telling the whole story of the Battle of Gettysburg, keeping visitors safe through collaborative law enforcement, or promoting visitation to the area and economic viability of the community. We fully support use of the park for events that contribute to the welfare of the local community and at the same time are an appropriate use of the park. The determination that organized, competitive recreational events are an inappropriate use does not apply to non-competitive events or other recreational activities outside those already prohibited in the Superintendent’s Compendium at 36 CFR §1.5(a)(2). The only location in the park where all recreational activities are prohibited is within the Gettysburg National Cemetery and Annex.

Non-competitive events as currently administered are considered to have a meaningful association with the park and foster a better understanding of and appreciation for park resources. As an appropriate use, the impacts of these events and other activities requiring a permit (See Superintendent’s Compendium at 36 CFR §1.6(f)) are managed through the Special Use Permit system.

Local community members and other visitors, while traversing park roadways on foot or bicycle in a non-competitive environment, are able to take the time to understand and appreciate the historic and commemorative landscape, stop or step off the roadway to allow buses and vehicles to pass safely, do not ring cowbells or shout encouragement, and do not interfere with the ability of other visitors to experience and enjoy the history of the hallowed grounds and solemnity of the park. The NPS looks forward to working collaboratively with the community to support special events that: (1) are appropriate to the purpose for which the park was established; (2) are inspirational, educational, or healthful, and otherwise appropriate to the park environment; (3) will foster an understanding of and appreciation for park resources and values, or will promote enjoyment through a direct association with, interaction with, or relation to park resources; and (4) can be sustained without causing unacceptable impacts to park resources or values. (NPS 2006, p. 99)

Lastly, appropriate recreational activities are referred to as “other important resources and values” (OIRV) in the park Foundation Document (NPS 2016). This designation represents their importance for the purpose of planning and recognizes the role the park plays as open space for the local community. As described in the Foundation Document: “Historic avenues, walking trails, and horse trails in the park provide outstanding opportunities for appropriate recreational activities. These and other methods of visitor use provide alternate ways for individuals to experience and appreciate the land within the park. Recreational activity must be done in a way in which commemoration and solemnity of the battlefield and Soldiers’ National Cemetery are respected.” Gettysburg National Military Park will continue to serve the community as an open space where appropriate recreational activities are welcome.


Concern Statement 05
Race events in the park contribute to visitation and economic sustainability within the Gettysburg community.

Representative Quotes:

  • We would also like to make the obvious point that these events do promote visitation to the Park and the community.
  • It would be an understatement to proffer that right now the Park Visitor Center and the community need visitation to Adams County to be economically viable.

  • To be honest, I would have never come to see Gettysburg National Battlefield except for the marathon. After all, it's just an old battlefield. To be able to see the course during the race is a memory I will not forget.

  • Races bring many people to the park, not just the runners, but family members who can learn up close about the many treasures the park has to offer to its visitors.

  • The National Park Service (NPS), as a policy has attempted to increase visitation and revenues at National Parks and thus this proposed actions would be contrary to current operating policy.

Response Statement:
Visitation to GNMP is approximately 1,000,000 annually. The total number of organized, competitive race participants represents less than ¼ of 1% of total park visitation (not including spectators). However, these organized, competitive recreational events occur during periods of high visitation. When combined with non-competitive events, which are considered an appropriate park use, they result in use of park roadways for special events on up to 100% of weekends between April and October. Additionally, the nature of organized, competitive recreational events, as described in the published determination, results in unacceptable impacts on park resources, visitor experience, and visitor safety.

The NPS does not have a Servicewide policy to increase visitation and revenues at parks but does seek to ensure that everyone has the opportunity to connect to parks in a meaningful way and to promote financial sustainability. As stated in NPS policy, the “Service will continually adjust to changing patterns of visitation and an increasingly multiracial, multiethnic, and multicultural society to ensure that the national park system remains high among societal concerns and relevant to future generations.” (NPS 2006, p. 92)

Adams County provides numerous alternative routes that would be more appropriate for hosting organized, competitive recreational events and still promote visitation to the Gettysburg area and support the economic viability of local businesses. Alternate routes include state and local roadways through the park where organized, competitive recreational events can be held safely with support from local law enforcement and the community. Alternate routes include Emmitsburg Road through the park which is already designated PA Bike Route J and a potential route for the future Grand History Trail through Adams County. The Feasibility Study for the Grand History Trail (GARA 2020) describes a network of state and municipal roadways outside the park “with low traffic volumes and many that can be characterized as ‘country walking roads’”. In previous years, many of these alternate routes have hosted the same organized, competitive recreational events that now occur in the park. The NPS is committed to continuing to support organized, competitive recreational events in partnership with the community held on state and local roadways through the park and along the park boundaries.


Concern Statement 06
The park should be supporting non-traditional interpretive visitor experiences such as race events that also support the community.

Representative Quotes:

  • With a changing society, we request that non-traditional interpretative experiences should be considered by the National Park Service and adapted to benefit the Park, the visitor and the community.

  • Our parks are a treasure and we should use any means possible to introduce people to the parks.

Response Statement:
Enjoyment of park resources and values by the people of the United States is part of the fundamental purpose of all parks. (NPS 2006) Gettysburg National Military Park supports the development of meaningful and innovative experiences that connect park visitors to all resources in sustainable, accessible, and creative ways. We are committed to providing opportunities for forms of enjoyment that are uniquely suited and appropriate to the superlative natural and cultural resources found in the park.

Visitors today experience the park on horseback, in carriages, on buses, segways, neighborhood electric vehicles if they are legal on state roadways, e-bikes, and more traditionally on foot, bicycle, and via private vehicle. In 2020, the ability of visitors to experience the park from the comfort of their homes through digital connections also significantly increased. What all these experiences have in common is a focus on historical interpretation of the Battle of Gettysburg and the Commemorative Landscape which is consistent with the purpose and significance of the park. They also foster an understanding of and appreciation for park resources and values and allow visitors to enjoy the park through a direct association and interaction with park resources. Alternatively, organized, competitive recreational events are an intensive recreational activity rather than an interpretive experience. As stated in NPS Policy, there are “many forms of recreation enjoyed by the public do not require a national park setting and are more appropriate to other venues.” (NPS 2006, p. 99) While we recognize the inspirational value of holding an organized, competitive recreational event on the hallowed ground of Gettysburg National Military Park, this activity is considered an inappropriate visitor use. It is the conclusion of Gettysburg National Military Park that organized, competitive recreational events on park roadways are a form of recreation enjoyed by the public that is more appropriate to other venues including state and locally owned roadways through and around the park.


Concern Statement 07
The park should be supporting activities that provide a physical, mental and educational outlet for visitors during the Covid-19 pandemic and contribute to environmental sustainability. Public access for these types of activities should not be restricted.Representative Quotes:

  • Right now more than ever strategic use of the Park, provides a physical, mental and educational outlet for a COVID weary society that is desperate for activities that combine those three benefits.

  • The Park should be encouraging biking and walking within the Park as a healthy way to reduce car traffic and its resulting air pollution, and as a way to draw new visitors to the Park who increasingly want alternative means of experiencing destinations like the Park other than by car.

  • I encourage you not to adopt any policies that restrict access to the park. Again, these parks are for we, the people, by we, the people, paid for by we, the people.

  • Link: https://www.nps.gov/subjects/healthandsafety/healthy-parks-healthy-people-resources.htm The link above describes multiple National Park Service Health Initiatives that provide documentation and research to illustrate:

    • Public access to green spaces has immeasurable benefits to mental, physical and emotional health.
    • The NPS has gone to great lengths and great expense at the national level to establish these plans and guidebooks that encourage the public to enjoy, recreate and exercise in the national parks and urges public/private partnerships.
    • National Military Parks are one specific type of NPS park and have a special mission - to protect resources and interpret the military and cultural history. This mission is an additional mission of NMP's but cannot take precedence over the NPS broader mission and the imperatives of keeping as much public access to these parks as is possible while promoting health in our population.

Response Statement:
The NPS continues to support and encourage appropriate visitor activities and events that are inspirational, educational, or healthful and can be sustained without unacceptable impacts. Passive recreational use of the park by dog walkers, hikers, bikers, birders and joggers has increased over time,particularly over the last year during the Covid-19 pandemic. We recognize and support the need for the American public to get outdoors in our National Parks for their physical, mental, and intellectual well-being.

Appropriate recreational activities are referred to as “other important resources and values” (OIRV) in the park Foundation Document (NPS 2016). This designation represents their importance for the purpose of planning and recognizes the role the park plays as open space for the local community. As described in the Foundation Document: “Historic avenues, walking trails, and horse trails in the park provide outstanding opportunities for appropriate recreational activities. These and other methods of visitor use provide alternate ways for individuals to experience and appreciate the land within the park. Recreational activity must be done in a way in which commemoration and solemnity of the battlefield and Soldiers’ National Cemetery are respected.” Additionally, the Superintendent’s Compendium at 36 CFR §1.5(a)(2) specifically states that activities described by commenters such as walking, jogging, and bicycling are not prohibited. The determination that organized, competitive recreational events are an inappropriate use will not interfere in any way with the ability of the visiting public to experience the park on foot, bicycle, horseback, etc. including participation in organized non-competitive events that provide a physical, mental and educational outlet for participants. Public access to park roadways and other areas for the purposes of engaging in healthy activities such as jogging and cycling is unchanged as a result of this determination. The NPS will continue to serve the community as an open space where appropriate recreational activities are welcome.

NPS initiatives that support use of parks for activities contributing to healthy living do not take precedence over law, regulation and NPS policy guiding resource protection, appropriate use of the parks, special use permits, or the NPS mission to “preserve unimpaired the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations.” Our desire and support for access to parks for recreational activities that promote public health should not be interpreted to mean that any recreational activity or special park use that members of the public consider “healthy” is appropriate or can be allowed. Special events are considered a privilege and special use permits for such events are issued under the authority of 54 U.S.C. § 100101. Regulations guiding issuance of permits for special park uses are found at 36 C.F.R. § 2.50. Further guidance is found in Directors Order #53: Special Park Uses and Reference Manual #53, Special Park Uses (available at https://npspolicy.nps.gov/index.cfm). Regulation and policy both require that special use permits only be issued if there is “a meaningful association between the park area and the events, and the observance contributes to visitor understanding of the significance of the park area.” As described in both 36 C.F.R. § 2.50 and Directors Order #53, permits for special park uses that cause unacceptable impacts to park resources or values, are contrary to park purposes, unreasonably impair the atmosphere of peace and tranquility, interfere with interpretive or other activities, create an unsafe environment for other visitors, or conflict with other existing uses shall be denied.


Concern Statement 08
There are other activities that occur on the Battlefield that have negative impacts similar to those described for organized, competitive race events but they are not being prohibited.

Representative Quotes:

  • The argument that the field is intended for solemn reflection is one I certainly am sympathetic to. And when anyone - runners include - violate that sacred obligation, it irks me…But there are many groups beyond runners that do that….What about the middle schoolers that scream off the top of the Pa. Monument? Or the streams and streams of motorcycles that make solemn reflection impossible at times?

  • School trips with buses full of schoolkids produce at least as much congestion, noise, and litter, if not more, not to mention RVs, charter bus tours, and crowds of re-enactors. Will you ban these too?

  • If the NPS problem is with too many people gathering in one area at one time, shouldn't that be the goal of encouraging people to come to *our* national parks? Why not cancel the July 1-2-3 battlefield days when thousands more people come to the town than for the races?

  • According to the Changes document, the proposed change is to add prohibiting race events to the Recreational and Sporting Activities policy. Interestingly, I found that the policy prohibits "...motorized scooters, neighborhood electric vehicles, golf carts, pocket motorcycles,..." Vehicles such as these are used for a multitude of educational tours. According to this policy, the only recreational vehicle should be your car or a horse and buggy. Use of vehicles such as the segways, scoot-coupes, and double decker bus tours cause more environmental and aesthetic damage to the park than a pack of runners at 7:00 am.

Response Statement:
The park acknowledges that during normal visitation some groups and individuals may engage in behaviors that can interfere with the interpretive or contemplative experience of other visitors. However, the middle school children, visitors to the park during “Battle Anniversary” on July 1-3, motorists/buses/RVs on park avenues, and visitors touring the park on segways are present in the park for the purpose of understanding the meaning and relevance of park resources. These activities support the mission goals of the park including: (1) The public understands and appreciates the significant events associated with the Gettysburg Campaign and its impact upon the development of the nation, and (2) Visitors safely enjoy high quality educational experiences accessible to all segments of the population. (NPS 1999) This is core to the mission of the NPS and the purpose of Gettysburg National Military Park.

Select commercial operations that provide visitor services/tours consistent with the mission and purpose of Gettysburg National Military Park and have minimal impact on park resources are authorized and regulated through a Commercial Use Authorization (54 U.S.C. § 101925). For clarity, the park does not allow the use of "...motorized scooters, neighborhood electric vehicles [that are not street legal in accordance with PA State Law], golf carts, or pocket motorcycles,..” by authorized tour providers or others. The NPS agrees that the language in the Superintendent’s Compendium regarding “neighborhood electric vehicles” is confusing and requires clarification. This will be addressed in the next update to the compendium.

Any problems that arise as a result of normal visitation or the activities of commercial entities authorized by the park through a CUA are addressed through the park law enforcement program. The law enforcement program is an important tool in carrying out the NPS mission and park purpose. The objectives of the NPS law enforcement program are (1) the prevention, detection, and investigation of criminal activities through resource education, public safety efforts, and deterrence; (2) the protection of the natural and cultural resources; and (3) providing for the protection, safety, and security of park visitors, employees, concessioners, and public and private property. (NPS 2006)


Concern Statement 09
Permit conditions are sufficient to address many of the potential negative impacts of organized, competitive race events.

Representative Quotes:

  • There are improvements that can be worked with the race organizers, such as a cup-free races (e.g. https://vacationraces.com/programs-and-initiatives/cup-free-racing/). Silent areas can be implemented so that cheering is not occurring in sensitive regions of the park. I am positive race organizers and racers will work with the park to an agreement that allows them to continue racing inside the park.

  • Adams County has no county parks and few recreational areas, so the Gettysburg National Military Park has served many purposes for locals and visitors beyond its primary purpose. I have run marathons in all 50 states, but none as special as Gettysburg. I think that community runs (not a "race" for most) can complement the educational purpose of the Battlefield with little impact on visitors with some simple rules.

  • I feel that with a little bit of scheduling; such as only allowing races to be held early in the morning (as they normally are) and not having them on the GNMP roads during the height of the tourism season (when races are not normally held, due to the heat),there's no reason not to allow races to use the lands of the USA.

Response Statement:

Only those activities in parks that are considered “appropriate” are managed through the Special Use Permit system. An “appropriate use” is defined by NPS Management Policies (2006) as one that is suitable, proper, or fitting for a particular park, or to a particular location within a park. Not all uses are appropriate or allowable in units of the national park system, and what is appropriate may vary from one park to another and from one location to another within a park. The consideration of whether a particular use is appropriate is made based on the specific resources, visitor experiences, legislation and management documents in individual park units. “Appropriate visitor enjoyment is often associated with the inspirational qualities of the parks. As a general matter, preferred forms of enjoyment are those that are uniquely suited to the superlative natural and cultural resources found in the parks and that (1) foster an understanding of and appreciation for park resources and values, or (2) promote enjoyment through a direct association with, interaction with, or relation to park resources…When proposed park uses and the protection of park resources and values come into conflict, the protection of resources and values must be predominant.” (NPS 2006, p. 13) The park General Management Plan (1999), specific to recreational activities, also states that “these opportunities must be consistent with the park's purpose and significance and not harmful to resources or park visitors.” Organized, competitive recreational events do not meet this management standard at Gettysburg. The NPS will continue to embrace appropriate uses of the park that are consistent with its purpose and protective of its resources and visitor experience including a variety of other non-competitive, organized events managed through the special use permit system.

Concern Statement 10
Use of other roadways through Gettysburg will result in race events that are unsafe and/or will not allow race participants to experience the Battlefield.Representative Quotes:

  • Runners are tourists too, and they will come back with their families when the race is over. Where do you expect people to run around Gettysburg? Route 30?

  • The race would not be the same without the run through a portion of the park.

  • As the battlefield surrounds the town itself, it is simply not possible to hold any sort of race or organized bike ride or other activity without using NPS roads.

  • Banning all races decreases recreational use of safer park roadways and limits the ability to have races in this town at all, due to the connected nature of our roadways with park land.

Response Statement:
Adams County provides numerous alternative routes that would be more appropriate for hosting organized, competitive recreational events and still promote visitation to the Gettysburg area and support the economic viability of local businesses. Alternate routes include state and local roadways through the park where these events can be held safely with support from local law enforcement and the community. Alternate routes include Emmitsburg Road through the park which is already designated PA Bike Route J and a potential route for the future Grand History Trail through Adams County. The Feasibility Study for the Grand History Trail (GARA 2020) describes a network of state and municipal roadways outside the park “with low traffic volumes and many that can be characterized as ‘country walking roads’”. In previous years, many of these alternate routes have hosted the same organized, competitive recreational events that now occur in the park. Use of these roadways provides access to improved roads, allows event participants to continue to benefit from and get inspiration from the scenic beauty and history of Gettysburg and at the same time promotes resource protection, visitor experience, and visitor safety on park roadways. The NPS is committed to continuing to support organized, competitive recreational events in partnership with the community held on state and local roadways through the park and along the park boundaries to ensure a safe and enjoyable experience for participants.


Concern Statement 11
Race events occur only on park roadways and are therefore less damaging/disrespectful than if they were occurring off-road.Representative Quotes:

  • I firmly believe that allowing races to occur through the roads of the park is not a sign of disrespect, but rather, a beautiful way to commemorate the battle fought there. Besides, running races are only occurring on the roads of the battlefields, not galavanting through the grass disrespectfully where the war was fought.

Response Statement:
The purpose, location, and features of the “roads of the battlefield” have significant meaning as elements of a designed landscape. As described in the written determination provided to the public, the park avenues and the monuments, tablets, memorials, and statues that line them mark the lines of the battle of both armies and the positions of regiments and units. Although the battle was fought across the landscape, the lines of battle were often where the fighting raged the hottest. The commemorative avenues are also designated as the primary means of visitor access to sites within the park. As interpretive elements, the monumentation and avenues describe the battle, help visitors visualize the positions of troops, and serve as a reminder of the pain, grief, and pride that survivors felt after the battle. They are a remarkable record of both the battle and of the emotions of survivors. (NPS 1999) While off-road events of any kind would likely result in different types of damage (e.g. soil compaction, loss of vegetation) there may be nowhere in the park that contributes more to the special sense of place at Gettysburg or elicits feelings associated with solemnity and hallowed ground than along the commemorative system of avenues.


Concern Statement 12
The statement that race participants are focused on winning or beating a personal best time is inaccurate.

Representative Quotes:

  • The document said that race participants are only interested in "winning" or beating a personal best. I guess the person who wrote that hasn't run much. I run one or two races every month and NEVER give one thought to winning anything and hardly notice my time. I do it for the social aspect and for the experience. It is an amazing way to enjoy a unique place.

  • In your section of "Relationship to "Races"" - you mention that the fundamental purpose is to compete to win. While there may be elite athletes at races looking to win, the majority of racers are there for the challenge and to celebrate the often months of training that led up to the race. They choose the Gettysburg race because of the opportunity to experience the park as they take on a personal challenge that pushes their mental and physical comfort level. Could the race happen elsewhere? Sure - but I would not be signing up.

  • Most of us are serious runners who are trying to achieve a certain time. Nobody is going to be stopping to vandalize the park.

  • Races provide motivation for runners to train. And as they train, they gain the benefits I've described. By hosting races, you are contributing to the well-being of your community in ways you may not fully appreciate.

Response Statement:
The NPS acknowledges that there are many motivations for individuals to be involved in an organized, competitive recreational event and reference to winning and beating a previous time is not intended to diminish other personal motivations for participating in such events. However, the presence of timing these events makes them fundamentally, races. As described under Concern Statement 07, visitors to Gettysburg National Military Park will continue to be able to run, bike and engage in other appropriate recreational activities within the park. They will continue to be able to train, challenge themselves, and have social interaction whether as an individual or through participation in non-competitive events in the park. We continue to welcome these activities. However, the culminating event of an organized, competitive recreational event is considered an inappropriate visitor use. As stated in NPS Policy, there are “many forms of recreation enjoyed by the public do not require a national park setting and are more appropriate to other venues.” (NPS 2006, p. 99) It is the conclusion of Gettysburg National Military Park that organized, competitive recreational events on park roadways are a form of recreation enjoyed by the public that is more appropriate to other venues including state and locally owned roadways through and around the park.


V. References

Gettysburg Area Recreation Authority. 2020. A Feasibility Study for the Grand History Trail. Adams County, Gettysburg Area Recreation Authority. 41p.

NPS. 2015. National Park Service NEPA Handbook. U.S. Dept of the Interior, National Park Service. 96p. Available online at https://www.nps.gov/subjects/nepa/upload/NPS_NEPAHandbook_Final_508.pdf

NPS. 2010. Director’s Order #53: Special Park Uses. U.S. Dept of the Interior, National Park Service. 24p. Available online at https://www.nps.gov/subjects/policy/upload/DO_53_2-23-2010.pdf

NPS. 2006. Management Policies 2006. U.S. Dept of the Interior, National Park Service. 180p. Available on-line at https://www.nps.gov/policy/MP_2006.pdf

NPS. 1999. Final General Management Plan and Environmental Impact Statement, Gettysburg National Military Park. Vol. 1. U.S. Dept of the Interior, National Park Service, Gettysburg National Military Park. 478 p.NPS. 2016. Foundation Document, Gettysburg National Military Park, Pennsylvania. U.S. Dept of the Interior, National Park Service. GETT 305/133302. 78p.


Attachment 1. Calculation of Change in Park Hours

The information presented represents the change between the existing hours at each NPS site and the proposed change in park hours to sunrise to sunset, defined as ½ hour before sunrise to ½ hour after sunset. Currently the existing hours NPS sites are open to the public are as follows:

Gettysburg National Military Park
Park grounds and roadways are open between April 1 and October 31 from 6:00am to 10:00pm and accessible to park visitors for a total of 16 hours. Between November 1 and March 31 park grounds and roadways are open from 6:00am to 7:00pm and accessible to park visitors for a total of 13 hours.

Gettysburg National Cemetery and Annex
Cemetery grounds are open from 7:00am to Sunset and accessible to visitors for a total of 9:47 hours (December 21, winter) to 13:40 hours (June 21, summer).

Eisenhower National Historic Site
The grounds at Eisenhower National Historic Site are open from 9:00am to 5:00pm and accessible to visitors 8 hours per day year-round.

 
Date 1/2 Hour Before Sunrise Timea 1/2 Hour After Sunset Timea Hours Open Change in Hours Openb
Gettysburg NMP
June 21 5:08 am 9:10 pm 16:02 +0.02
December 21 6:56 am 5:17 pm 10:21 -2:39
Gettysburg Nat. Cemetery
June 21 5:08 am 9:10 pm 16:02 +2:22
December 21 6:56 am 5:17 pm 10:21 +0:34
Eisenhower NHS
June 21 5:08 am 9:10 pm 16:02 +8:02
December 21 6:56 am 5:17 pm 10:21 +2:21


a Based on sunrise and sunset times provided at https://sunrise-sunset.org/us/gettysburg-pa
b Represents change between the existing number of hours each site is currently open and the number of hours each site will be open/accessible to park visitors based on the proposed change in hours.

Last updated: May 3, 2021

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