The following  comments were submitted to the National Park Service regarding their plan for C&O National Historic Park fees.

I am commenting as a bicycle user of the C&O Canal Towpath and as a blogger with the objective of promoting bicycle touring. I toured the full length of the C&O Canal Towpath in August, 2014, from Cumberland to Georgetown and enjoyed it very much. I agree with the fees-for-use proposed with the three following comments.

First, the Park Pass implementation needs to be easier to understand than as stated in the Park Service proposal: the structure of the fees seems complicated. For example, there are two stated rates, one that covers the Park from the District of Columbia Line to Seneca Creek and another that covers Seneca Creek to Cumberland. This is confusing for a Park user who intends to travel the full length of the towpath. A clearer approach would be to have a single rate from DC to Cumberland, which can be the sum of the rates for the separate legs.

The National Park Service implementation should have a Park Pass that includes all attractions such as the Harpers Ferry and Great Falls sites and others. Inclusions such as this add to the perceived value of the pass for cyclists. As a user, the Great Falls Park in particular doesn’t appear to be a separate park. As I rode the towpath, I saw signs for Great Falls, which is just off the towpath. I don’t know how that attraction cannot be included in the C&O Park Pass. Antietam and Harpers Ferry are truly separate features, but including access to them as a part of the Park Pass fee would be a definite positive for a cyclist.

Second, the Hiker-Biker Campsite Rate is a charge that helps to offset the costs of maintaining the campsites, including regular servicing of the chemical toilets. My recommendation is to decrease the fee for cyclists and hikers to $10 so that it is perceived as a good value when compared with the Drive-In Campgrounds Single Site Rate of $20 per night. The $10 rate is also more comparable with similar campsites that I have used on the Great Allegheny Passage.

My rationale is that when someone drives and parks a motor vehicle at a Drive-In Campground, they will stress the campsite more than a cyclist who will travel light and keep the bicycle near the tent. Besides occupying a parking spot, a drive-in user will tend to bring more gear to the campground, generating additional wear on the grounds. All users also have the responsibility of carrying away any trash generated at the campsite, but cyclists must pack trash with their personal effects and carry it until a suitable dump is found. My opinion is that a cyclist using a remote hiker-biker campsite will be tend to be more responsible if there is a perceived recognition that there is a difference between a cyclist and a drive-in camper.

As a comparison, the Husky Haven Campground on the GAP in Rockwood, PA, charges $10 per night for a primitive campsite. The campsite has a chemical toilet, fire rings with fire wood provided, picnic tables, and trash cans. Hot showers are available for campers a short bicycle ride from the campground and use of them is included in the fee.

Another comparison is the River’s Edge Campground on the GAP near Connellsville, PA. When I camped there in 2014 I paid $20, which included on-site showers, toilets, picnic tables, trash cans, and potable water, all within a short walk from my tent. This campground also has a store and a swimming pool available to guests.

Third and finally, I support the National Park Service fee-for-use approach for the C&O National Historic Park, but I have concerns about the collection and management of the fees. The access to this Park is not controlled and there are generally no obvious entry and exit points where the Park Pass fees can be collected and passes issued. I have a similar concern for the Hiker-Biker Campsite Rate. The “honor system” may work somewhat, but the collection boxes would be subject to vandalism and theft.

The Park Pass and fee-for-use may be interpreted in a negative way by local people along the trail who may use the Park on a daily basis. It is used by local walkers, runners, and cyclists near towns and trail heads. The Park Annual Pass may address this concern, but locals may not like the approach since they have used the Park free of charge to date. If the purpose of the Park Pass is clear, there would be fewer objections. The Park passes through many communities and messaging to potential users along the path is difficult.

There is a good chance that there will be significant use by people who will not pay the fees, undermining the integrity of the system. The implementation should consider methods to minimize this. One thing to consider is to make it clearer that this is a National Park. I personally didn’t know until I talked with some of the maintenance personnel more than half way through the trip. I thought they were volunteers and they made it clear they were not. Other than the signage at some of the historic sites, there is little to indicate that this is a National Park. A lot of positive messaging can be accomplished with better signage.