Chesapeake and Ohio Canal The Making of a Park

After the National Park Service abandoned its plan to build a parkway along the canal in 1956, it was again faced with deciding how to develop and otherwise treat the canal property above Seneca. Every park was supposed to have a master plan for development and use. The Service completed such a plan for the Chesapeake and Ohio Canal National Monument in 1964, but the unsettled status of the national historical park proposal limited its value. A hasty replanning effort accompanied the park proposal's revival in 1969, but there was strong opposition to the resulting development plan once the park bill had passed. A new effort followed, culminating in the mid-1970s in a general plan enjoying broad support.

In the spring of 1956 George Thompson, a recreation planner in the Service's Philadelphia regional office, surveyed the canal and prepared recommendations for land acquisition and recreational developments along it. The Philadelphia office assumed administrative oversight of the canal above Seneca from National Capital Parks in September 1958, and in April 1959 Assistant Regional Director George A. Palmer, William R. Failor, a planner with that office, and Edwin M. ("Mac") Dale, superintendent of what was then called the C & O Canal National Historical Park Project, reconnoitered the canal from Cumberland to Harpers Ferry. Their purpose was to review Thompson's recommendations for acquisition and locate areas for immediate development.

Failor stressed the need for a comprehensive study of existing non-recreational canal uses, which predominated nearly everywhere beyond Harpers Ferry, before general development planning. He recommended disposing of the canal above North Branch because it passed through "a hodge podge of uses with no zoning protection." Palmer was opposed to any such disposal of canal property, viewing it as a bad precedent. [1] (As has been seen, that controversy would continue.)

Dale's maintenance force was then clearing vegetation and other obstructions from the towpath and portions of the canal bed. Palmer commented that another season of work would probably make it possible to drive the entire towpath without a break except at certain aqueducts. But he was unhappy with the lack of aesthetic sensitivity displayed in some instances. "One of the saddest looking sections of the Canal is that cleared by National Capital Parks in 1957," he wrote the regional director. "The Canal and towpath were stripped clean and the sprouts are now coming up to five or six feet. By summer, they will be ten. The result is that this section of the canal doesn't have an abandoned look, it has a neglected look. The sections cleared by Superintendent Dale are better, because he did leave some selected trees along the towpath. I believe we should go even further in planning for clearings by leaving clumps of trees, breaking the monotony by varying the degree of thinning, and generally presenting a more pleasing appearance than just raw canal." [2]

Palmer wanted to stop further clearing until it had been determined through master planning which sections of the canal would be developed and how. He also wanted to leave evidence of flood devastation: "Just below Lock 33 at Harpers Ferry, I would not touch the ruins of the Canal because here, more than at any other point, the destruction illustrates . . . one of the principal reasons for its eventual closing." [3]

The master plan for the national monument was prepared by the Park Service's Eastern Office of Design and Construction in Philadelphia and approved by Acting Director Jackson E. Price on August 28, 1964. It outlined the many problems caused by the lack of adequate boundary data, adverse neighboring development, and encroachments. The park could not be effectively administered, it declared, without a clearly defined boundary extended for resource protection and development of administrative and visitor facilities. It called for extensive recreational developments and proposed rewatering many stretches of the canal, including the 13-mile stretch from Lock 71 in Oldtown through the Paw Paw Tunnel to Lock 62. [4]

Much of the proposed development was carried forward into the 1968 Potomac National River plan, which John M. Kauffmann "split lengthwise" in 1969 for the boundary map and development outline accompanying the successful national historical park legislation (page 97). Proposed development in the first year after enactment included a major visitor center complex at North Branch and canal restoration, boat ramps, and other amenities at North Branch and Brunswick. The second year would see a visitor center, marina, and campsites at Praether's Neck, new visitor facilities at Hancock, Williamsport, and Edwards Ferry, and restoration of several aqueducts, locks, and lockhouses. Restoration of historic features and development of new facilities, including more boat ramps, campgrounds, picnic areas, and comfort stations, would continue at the same level during the next three years. [5]

As noted previously, some conservation groups expressed displeasure with the extent of proposed development during the hearings on the park legislation in 1970, and Congress cut the authorized development appropriation from $47 million to $17 million. This was not necessarily meant to curtail the Park Service's plans, but it would require the Service to return to Congress for an increase in the development ceiling after the $17 million had been appropriated and spent. Following enactment of the legislation in January 1971, Kauffmann proceeded to incorporate his development outline in a new master plan for the expanded park. The ambitious plan called for 25 boat launch facilities accessible by automobile, 31 group camps with a total capacity of 6,000, and nearly 3,000 picnic sites. These and other developments were designed for a day-use visitor capacity of 53,500.

Copies of the master plan "were, somehow, obtained by the private sector and circulated to the public without the authorization of the National Park Service," in Dick Stanton's words. Quite apart from the plan's content, the impression of secrecy did not bode well for its acceptance. Justice William O. Douglas wrote Anthony Wayne Smith, president of the National Parks and Conservation Association: "I understand the Park Service has decided on three parking lots being located between the Canal and the River—and that all their plans are secret!! That is par for the Park Service. We should start hollering!" [6]

"We are already hollering," Smith replied, enclosing a copy of a letter he had sent Assistant Secretary of the Interior Nathaniel P. Reed: "The procedures being followed by the National Park Service with respect to the old C & O Canal are an outrage and violate all the purposes for which the protectors of the Canal have been fighting for over 17 years. We are simply not going to put up with this kind of thing by the National Park Service and the Department of the Interior. . . . I think you have an obligation to see that this nonsense is stopped." [7]

The Chesapeake and Ohio Canal National Historical Park Commission had been viewed by the Service as the appropriate forum for public involvement in the master plan. Unfortunately, the commission was not organized until nearly a year after enactment of the park legislation. Kauffmann spoke on the plan at its first meeting on December 20, 1971. "We have to, first, recognize the limitations of the park," he said. "It is long and narrow and full of fragile resources. It is going to be a very difficult task to administer this, to develop it wisely and properly for the type of uses which you can expect in this urbanized region in the future." [8] His plan proposed a variety of conditions: the canal would be rewatered for as much as half its length, left naturally overgrown in other areas, and maintained in grass near communities to present a town park appearance.

The first large proposed development upriver from the already developed section below Seneca was at Edwards Ferry. Here the plan called for a marina building and dock for a hundred boats. Reaction from commission members was negative. Grant Conway of Montgomery County complained about the noise and pollution from power boats and existing efforts to accommodate them: "The Park Service has already put so many ramps in the river that people can't hear themselves talk in their yards near the river." Kauffmann argued that the proposed marinas were intended to concentrate power boating in limited areas rather than to increase it, but the critics were unpersuaded. [9]

Conway and Rome F. Schwagel of Washington County also expressed concern about the planned extent of rewatering, which would require much tree removal and other disturbance of naturally regenerated areas. NCP Director Russell E. Dickenson defended the rewatering on historical grounds, but no commission members voiced support. The commission did agree on the importance of stabilizing the aqueducts to maintain the continuity of the towpath, a concern heightened by the partial collapse of the Seneca Aqueduct three months before. The members voted unanimously for a motion by Justice Douglas, attending as "special adviser to the commission," that aqueduct restoration receive priority. [10]

After the meeting Assistant Secretary Reed, who had been present, relayed his reaction to Kauffmann: "My reading of the Advisory Board meeting was that the priority is to protect the Canal and the locks. Repair the damage and last and least construct visitor facilities. . . . Unless I am wrong, the Canal should not be developed for heavy use mass recreation. Bicycling, walking, canoeing, limited, low development, low density camping are the features the Advisory Board wants. Unless your Master Plan reflects this objective, there will be years of strife ahead." [11]

A fresh start was called for. Kauffmann moved on to other assignments, and John G. Parsons, a dynamic young landscape architect and planner at NCP headquarters, was charged with developing a new park plan "acceptable to the National Park Service, the Commission, and the public," as Dick Stanton later wrote. [12]

During May and June 1972 the Service held five public information meetings, in Washington and each of the four Maryland counties containing the park, to discuss the planning effort and obtain public comment. Parsons and his colleagues distributed a draft "study plan" for the park, and one of them remained available for two days after each meeting. A total of some 1,500 people attended, and about fifty took advantage of the opportunities for further discussion.

The National Parks and Conservation Association was among those commenting on the study plan. NPCA supported its proposal to provide only walk-in camping but found too much development emphasis remaining elsewhere. It opposed the plan's call for a new developed area at Watts Branch in Potomac, expansion of parking to accommodate 150 cars at Violettes Lock, marina services at Edwards Ferry, and a footbridge across the Potomac at Harpers Ferry. [13]

At a meeting of the park commission that July, Carl Linden and Alan Franklin of the C & O Canal Association presented their group's position on park development. They wanted nothing that would encourage or support recreational activities not directly related to the canal, including drive-in campgrounds, picnic grounds, and walk-in campgrounds accessible from parking areas like that at Antietam Creek. "It should be a park developed for those who are willing to walk into it," Franklin said. Harry Rinker, president of the Pennsylvania Canal Society, disagreed. He saw the park as the national canal park, catering not just to area residents but to people coming from afar by car. He wanted more vehicle access and development for those visitors, who might lack the time or ability to hike long distances. [14]

Partly in response to such differing demands, Parsons developed a zoning concept for the park. At a commission meeting that September he unveiled his plan to divide the park into five categories, ranging from major interpretive zones to primitive zones. The former would be the most developed and accessible; the latter would be the most untouched and remote. In addition to reflecting the park's diversity, the zones would be used to control visitor use. In major interpretive zones, sufficient parking would be provided to allow as many as three hundred people per mile; in primitive zones, the target maximum was 25 per mile. [15]

The zoning concept was incorporated in a "Preliminary Draft Master Plan," which won the commission's endorsement in January 1973. The draft was widely circulated. There were more public meetings and more public input. The Washington Post editorialized on the Park Service planning effort following the twentieth anniversary Justice Douglas Hike in April 1974: "As Justice Douglas has often said, the traditional strategy has been, 'First save the canal from the parkway, then save it from the Park Service.' This may be easier than it used to seem, for the National Park Service has been listening to public sentiment and has apparently abandoned earlier plans to 'improve' the park by adding large marinas, plug-in campgrounds and other intrusive facilities. In concert with the Maryland congressional delegation, the Park Service is now focusing on obtaining sufficient money for repairs and restoration." [16]

The Chesapeake & Ohio Canal National Historical Park General Plan was endorsed by the park commission in July 1975 and officially approved by NCP Director Manus J. (Jack) Fish, Jr., in January 1976. It began by defining the park's management objectives: to "preserve the atmosphere of past times and enduring natural beauty and safeguard historic remains and natural features," to "impart to visitors an understanding and appreciation of an historic way of life blended into the natural setting of the Potomac Valley," and to "develop the potential of the park's recreation resources for safe yet stimulating enjoyment by the visitors within limits compatible with the other two management objectives." [17]

The general plan divided the park into 32 sections, each assigned to one of the five zones. Six sections totaling 10.4 miles—at Georgetown, Great Falls, Seneca, Williamsport, Four Locks, and North Branch—were assigned to Zone A, the National Interpretive Zone. Here the emphasis would be on historical restoration and interpretation, with vehicular access and facilities to accommodate the largest numbers of visitors. Zone B, the Cultural Interpretive Zone, applied to ten segments totaling 23.4 miles. They would also focus on cultural resources, but with less development. Zone C, the Short-Term Recreation Zone, was "designed to serve the general towpath user seeking a leisurely stroll of 2 to 6 hours in a natural setting." Six segments totaling 39.1 miles were so classified. Zone D, the Short-Term Remote Zone, was the category for seven segments totaling 61.8 miles, each intended to provide "an undisturbed day in a natural setting." Zone E, the Long-Term Remote Zone, applied to three segments totaling 49.6 miles, the longest being a 29.5-mile stretch from Hancock through the lower Paw Paw Bends to Lock 62. These would serve "those who seek a near wilderness involvement with the environment." [18] The idea of controlling visitor use by setting explicit carrying capacities for the various zones did not find its way into the plan.

A chart depicted the kinds of facilities that would be suitable in the various zones. Boat concessions could go in Zones B and C, for example, while hiker-biker campgrounds would be appropriate in Zones C, D, and E. The existing drive-in campgrounds at McCoys Ferry, Little Orleans, and Spring Gap were to be phased out "when private enterprise meets the demand." (They were still present 15 years later.) Twenty-four miles of the canal, comprising the 13 Zone A and B segments outside the already-watered 22 miles below Seneca, were proposed for rewatering; where engineering studies found this infeasible, the bed would be cleared of natural vegetation, sodded, and mowed.

The park commission's influence was apparent in the plan's strong statement about development priorities: "It is imperative that higher priority be given to the stabilization and restoration of historic structures than to new development. If this is not done, the danger of losing these fragile, limited, nonrenewable resources, for which the park has been established, becomes apparent. . . . No new visitor use facilities will be constructed until emergency flood rehabilitation and aqueduct stabilization work has been funded and further research on stabilization and restoration of the cultural resources has occurred." [19]

A chapter titled "Sectional Concepts" addressed each of the 23 sections with suggestions for its treatment. It was prefaced with the caveat that "the concepts here may change significantly and will not be implemented until a sectional development plan for the entire section is completed." These plans, to be undertaken with "complete public involvement," would dictate all development beyond the restoration work then in progress after tropical storm Agnes. The Great Falls section was slated for initial attention. [20]

The Great Falls section was the most heavily used area of the canal, outside Georgetown. It was made so by its location in the Washington metropolitan area and its many attractions: the falls themselves, canal barge trips running through the uppermost of five closely spaced locks, the historic Great Falls Tavern, the picturesque Widewater section of the canal, the rugged Billy Goat Trail along the river's Mather Gorge, the river's suitability for whitewater canoeing and kayaking, and the scenic quality of the area as a whole. The National Capital Team of the Park Service's Denver Service Center began work in 1978 on the area's development concept plan or DCP, as the sectional development plans were titled. The planners held two public hearings in the vicinity in late 1979 and produced a draft in mid-1980.

The draft identified a range of problems, including inadequate facilities to meet recreational demands; inadequate interpretation of the canal and tavern, the nearby Maryland Gold Mine, and the historic Washington Aqueduct running beneath the area; conflicts between hikers and bikers on the congested towpath; an interrupted stretch of the towpath at the head of Widewater; a lack of access to view the falls after Agnes swept away a set of bridges to Olmsted Island in 1972; poor circulation patterns; inadequate office space in the tavern, rest room facilities, and food concession service; and a run-down hiker-biker campground at Swains Lock. After presenting five alternative programs for addressing these and other concerns, it described a preferred course of action.

Under the recommended plan, a dock for the canal barge would be built below Lock 20, which would remain operational for the barge trips. Access and circulation would remain essentially unaltered. The parking lots at Swains Lock and opposite Old Anglers Inn (below Widewater) would be paved and striped but not expanded. A twenty-car parking area would be added near the Maryland Gold Mine. To limit crowding, overflow parking would not be allowed. Cyclists would be required to walk their bicycles between Widewater and the Great Falls Tavern during peak visitation periods. The towpath at the head of Widewater would ultimately be restored; meanwhile, a wooden walkway begun there would be completed. The bridges to Olmsted Island would be replaced. The campground at Swains would be retained. The lockhouse at Lock 16 would be rehabilitated to house seasonal park employees. Administrative offices on the second floor of the tavern would be moved to a historic stone house nearby that had been built and used by the Corps of Engineers; two adjacent modern houses would be razed upon their expected transfer from the Corps to the Park Service. [21]

The towpath by Widewater, periodically scoured and washed out by floods, had been a bone of contention for several years. At the House hearing on the park bill in 1970, conservation group representatives criticized work then underway to reconstruct part of it; the Park Service appeared to them to be building a road rather than a path. [22] In the spring of 1976, in conjunction with towpath repair work necessitated by the 1972 tropical storm Agnes, the park began to construct a 270-foot-long wooden bridge over a rocky stretch below Lock 15. Edwin F. Wesely, a commission member from Montgomery County, considered the bridge intrusive and unnecessary and sounded the alarm among the conservation community.

Most other commission members and conservationists had less quarrel with the structure itself than with the Service's failure to consult the park commission and other interested parties before proceeding with it. (Because the park was in the National Register of Historic Places, the Service was required to consult the District of Columbia's or Maryland's state historic preservation officer and the federal Advisory Council on Historic Preservation on all projects affecting it.) The Service suspended construction of the bridge and brought the issue before the commission that May. There John Parsons confessed the error of the 1970 work while defending the present project: "We were doing an insensitive, lousy fill job at Widewater, and I'm glad that the conservationists stopped us. . . . I think we've heeded that advice, and we have built something with a great deal of sensitivity to the resources." Superintendent William R. Failor argued that the bridge was necessary to maintain the continuity of the towpath and did not constitute the kind of new development requiring a sectional development plan or DCP. But the Service agreed to go no further with it until could be fully addressed in such a planning effort. [23]

When the commission reviewed the draft DCP in October 1980, the proposal to complete the bridge over the rocks again came under criticism, as did several other ingredients of the plan. Four commission members formed a committee to review the draft and propose revisions. The committee recommended against completing the bridge, favoring instead "a staggered path effect which would reflect the natural terrain" pending ultimate restoration of the towpath to its historic condition. It opposed the new parking area or any other development on the gold mine tract. It urged some treatment other than asphalt and striping for the parking areas at Swains Lock and Old Anglers Inn to maintain their rural character. It advocated retaining the modern Corps of Engineers houses as employee residences. The commission endorsed its committee's recommendations that December. [24]

Superintendent Dick Stanton shared a draft "record of decision" on the DCP with the commission in April 1981. It appeared to incorporate most of the commission's views. Only the exterior of the lockhouse at Lock 16 would be restored; employees would be housed in the modern residences if they were transferred to the Park Service. The parking area at Old Anglers Inn would be paved and striped to increase its efficiency; nothing was said about that at Swains. The forty-car parking area nearest the Great Falls Tavern would be removed to provide a more appropriate setting for the tavern. The existing pullout for cars near the intersection of Falls Road and MacArthur Boulevard would be slightly improved to provide better access to trails in the Gold Mine Tract and "present a more park-like entrance portal." The "staggered path effect" would be tried at Widewater; if it proved satisfactory, the Service would consider removing the bridge and extending the new treatment the entire distance. [25]

Regional Director Jack Fish approved the DCP that summer, but Stanton told the commission that no money would be available to implement it anytime soon. A decade later, nothing had been done about the parking areas or the rocky stretch at Widewater. The park requested $325,000 in 1989 to restore 875 feet of towpath there, but the project lacked sufficient priority for funding. [26] The Service did acquire and occupy the Corps houses and a garage building, freeing space in the tavern, and it partially restored the exterior of the Lock 16 lockhouse. It built a dock for the canal barge below Lock 20, and it proceeded with plans to replace the bridges to the falls overlook on Olmsted Island. The change most evident to Great Falls visitors by the end of 1990 was the inauguration of a $3-per-car fee that November. Collected at the entrance to the parking area, it was expected to help control public use and lessen overcrowding.

The next development concept planning effort addressed the last ten miles of the canal running though North Branch and Cumberland. Terry Langlois, a Denver Service Center planner who had worked on the Great Falls DCP, began the Cumberland/North Branch DCP in 1979 and presented three alternatives to the park commission in July 1980. The commission members from Allegany County and local officials favored the alternative leading to the greatest development, estimated to cost more than $10 million; unlike those from wealthy Montgomery County, they were eager to attract more visitors to lift their depressed economy. At the commission's request, Cumberland and Allegany County appointed a study team headed by commission member John D. Millar to make recommendation to the planners. In April 1981 Millar reported "overwhelming support" for rewatering from Spring Gap to a waste weir a mile below the terminus, a distance of more than ten miles. [27]

The Park Service planning team concluded that the rewatering and other improvements favored by the community could not feasibly be accomplished within ten years (the general rule guiding what went into a DCP). Obtaining sufficient water, relocating the roads and storm drains crossing the canal, and funding the work involved posed major problems. While proposing engineering feasibility studies of rewatering, the planners gave first priority to restoration of the Evitts Creek Aqueduct. They also favored exterior restoration of the lockhouse at Lock 72, removal of a road and bridge crossing the canal at Lock 74, adaptive use of the Lock 75 lockhouse at North Branch as a ranger office and visitor contact facility, and redevelopment of the former Western Maryland Railway station at the terminus by the city of Cumberland to house a visitor information exhibit on the canal. [28]

The Cumberland/North Branch DCP as approved and published in October 1982 reflected these views. Under continued pressure from the community, however, it was revised in May 1983 to express greater support for rewatering in the near term. "As a minimum, the canal would be rewatered between Locks 72 and 75 (1.2 miles) and between Evitts Creek Aqueduct and Candoc (1.34 miles)," it declared. "Lock 75 would be an appropriate location for a floating barge. Other areas that prove to be feasible would be rewatered." [29]

The Park Service opened an information center in the Cumberland railroad station in May 1985. It performed some stabilization work on the Evitts Creek Aqueduct, and with funds obtained through the efforts of Rep. Beverly B. Byron in 1989, it installed dikes and flooded a section of the canal in Cumberland to test its water-holding ability. But the greatest chance of achieving the extensive and permanent rewatering sought by the community appeared to lie in a new proposal for yet another canal parkway (page 176).

The Williamsport section of the canal was next to receive development planning attention. The planners began work there in late 1980 and completed its DCP in August 1982. The DCP prescribed actions to be undertaken in two phases. Phase I actions included stabilizing the Conococheague Aqueduct, restoring an old trolley power station for use as a visitor contact and management facility, restoring the exterior of the Cushwa Warehouse and outlining the former canal turning basin next to it in stone, restoring Lock 44 and its lockhouse, conducting an engineering feasibility study of rewatering, and rewatering the canal from Lock 44 to the Conococheague Aqueduct. The historic Bollman Bridge over the canal would be closed to motor vehicles and only vehicles carrying disabled persons would be allowed to reach the river on Potomac Street, with the result that Riverfront Park would be inaccessible by car to all but the disabled. In Phase II, the canal would be rewatered east of Lock 44, if feasible, to permit locking through a barge; the turning basin would be restored and rewatered; and the existing boat ramp in Riverfront Park would be removed. [30]

The park commission approved the Williamsport DCP but expressed concern that the Bollman Bridge not be closed until an alternate route was available. Community opposition to the actions affecting Riverfront Park mounted, and in December 1982 the commission requested removal of any reference to closing the bridge and relocating the boat ramp. The Service heeded the commission's advice in a revised edition of the DCP, issued in May 1983. [31]

The Phase I rewatering was successfully completed in the mid-1980s. Thanks to Beverly Byron and Sen. Barbara A. Mikulski, the Service's 1991 appropriation earmarked $2.3 million for rewatering in Williamsport, Hancock, and Brunswick. Williamsport's share of the money would be used to begin Phase II, including excavation and restoration of the turning basin, continued rewatering past Lock 44 to a Potomac Edison access road, and restoration of the lock to operating condition. [32]

Work on a DCP for the Brunswick section got underway in 1981. The Service's major problem there was the use of the towpath for vehicular access to a town-operated campground and a sewage treatment plant between the canal and river. Between the canal and the town center lay a large Chessie System railroad yard. The Service initially sought, without success, to have this traffic rerouted along railroad property. [33]

A draft of the DCP, circulated in August 1982, called for the Brunswick section to be rezoned from B to A if the town and the railroad developed "a high quality living museum of the railroad era." Under Phase I of the proposed development, towpath traffic west of Maple Avenue would be eliminated except for a crossing to the state-owned boat ramp under the U.S. Route 17 highway bridge, Lock 30 would be stabilized, and the lock gates would be restored. Under Phase II, a new road crossing the canal at Maple Avenue and running parallel with it east to the sewage treatment plant and campground would allow removal of the remaining towpath traffic. The boat ramp under U.S. 17 would be eliminated and its function shifted to the campground ramp. The canal would be rewatered if engineering studies demonstrated the feasibility of doing so.

The park commission asked that the proposals to rezone the section and eliminate the boat ramp be stricken; thus revised, the DCP was published in February 1983. It was amended in April 1988 to incorporate a description of the Brunswick Waterfront Project, a product of the Brunswick Revitalization Committee in cooperation with the Park Service and the park commission. The addition specified the responsibilities of the town and the Service for upgrading the area over a three-year period; the town was to provide signing and publicity and take steps to enhance the approach to the park. [34]

During the summer of 1989 the park raised part of the canal berm at Brunswick and tapped the town's water supply to fill the canal there. Brunswick agreed to turn its water intake system over to the park when a planned replacement system became operational. [35]

The Service undertook a DCP for the Georgetown section in 1985-86. The planning effort there was complicated by redevelopment proposals for the Georgetown waterfront, most of which lay outside the park boundary. The park commission endorsed a DCP draft in May 1986. It was subsequently approved by outside review bodies, and the D.C. Council adopted a resolution recommending that city-owned waterfront lands be transferred to the Service. With no new development proposed for the great majority of the park, there was little pressure or need for development concept planning elsewhere.