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Cambridge Response to the DCR Parks and Forests Report to categorize our publicly owned Parks, Reserves and Forests.
Response to DCR Landscape Design Plan from Friends of Alewife Reservation
August 13 and 26, 2011
added to website October 25, 2011

There is no recognition of urban wilds or the urgent need to protect the dwindling natural resources within our urban communities throughout Mass. The following by Cambridge resident, Marilyn Wellons gives a strong and effective argument for protection of Mass. "urban wilds".

Following the response by Marilyn Wellons there is a response by Ellen Mass.

While FAR has given support to the restoration of wetlands and marshes by destroying urban wild vegetation of about 10 acres from 130, we believe it will enhance our urban wild in the long run. The present phase of excavation is very painful for FAR and followers. Most of our concerns and advocacy are directed towards building and impervious surface development. We consistently and vocally oppose development in the urban wild rare forest and reserve area.

Ellen Mass

FROM: Marilyn Wellons
DATE: 8/26/2011 4:44:37 PM
SUBJECT: DCR Landscape Designations FINAL DRAFT
re: Landscape Designations for DCR Parks & Forests: Selection Criteria and Management Guidelines FINAL DRAFT May 2011

Dear DCR Designation Comments:

As a user of urban wilds on the Charles River, I have read this document hoping for acknowledgement of their importance and guidelines for their protection. While the draft indicates a significant rethinking of the agency's stewardship of Forests and Reserves, it unfortunately confirms the status quo for Parklands.

The discrepancy leads me to believe violation of the agency's stewardship at the Zimmer woods precipitated this critical review and reorganization for forestry and reservations. Even so, it's puzzling that major violations of the public trust on state parklands have not, it seems, precipitated an analogous rethink for them.

Urban wilds, an increasingly important resource for city dwellers and focus for research, are absent from the document. It is in my opinion a fatal error to omit these important contributors to the ecology of cities. The draft's minor, passing references to "biodiversity" are inadequate to its task, especially when the presumption is that "non-native invasives" derogate from biodiversity. Recent research indicates this is not the case (Peter Del Tredici, "The Ecology of an Urban Wild," Silva, Fall/Winter 2011-2012, p. 4).

I'm most familiar with the Charles River lower basin. It seems likely that DCR management of other urban parks is similar, but without firsthand knowledge my comments draw primarily on time spent along the Charles.

The Arnold Arboretum's project at Bussey Brook Meadow has an initial definition of urban wilds: "areas not maintained to a [prescribed] horticultural standard and lacking amenities other than unpaved pathways" (Del Tredici, Silva). DCR parklands are full of such places. The agency should celebrate their services, given pro bono.

Landscape Designations should identify urban wilds within the Land Stewardship Zones and elsewhere in the document.

The draft's understanding of and references to "non-native invasives" need serious revision. (See Stephen Jay Gould, "An Evolutionary Perspective on Strengths Fallacies, and Confusions in the Concept of Native Plants," Arnoldia Vol. 58, No. 1; the comments in Vol. 58, No. 3, pp. 25-32; and Gert Groening and Joachim Wolschke-Buhlman, "The Native Plant Enthusiasm: Ecological Panacea or Xenophobia?" Vol. 61, No. 4; and Del Tredici, Wild Urban Plants of the Northeast, 2010.)

Given the DCR's policy against urban wilds' "non-native invasive species," it might be fair to include them as rare and endangered, hence in the proposed LSZ 1, the "most protective" category. "[S]pecial management approaches and practices to protect and preserve their special features and values" would be continued neglect. This would save the DCR sporadic, expensive, radical, and ultimately unsuccessful attempts to "restore" urban wilds to what is "ecologically and evolutionarily impossible" to quote Del Tredici again (Wild Urban Plants of the Northeast, 2010, p. 16). Magazine Beach, 2004-present, is a prime example; these "non-native invasives," special as they are, are not going away.

(Controlled burns at pine barrens are one thing. Like attempts to eradicate "non-native invasives" on the Charles, they try to hold back inexorable natural processes. The Miles Standish Forest's pine barrens are not, however, long gone and impossible to restore to some period of their natural history, as are the tidal flats of the undammed Charles River. As long as the state is willing to pay for burns in the pine barrens, it can probably preserve a rare and endangered ecosystem.

To try to eradicate false indigo on the Charles or phragmites on the Mystic, however, is an expensive indulgence of ignorant fantasy. Such efforts are blind to the beauty and value of what is there, e.g., false indigo for habitat and erosion control, phragmites for habitat and uptake of pollutants. In addition to funding DCR client consultants and contractors, these efforts serve the latent function of helping insure the DCR's survival. They are not in my opinion examples of good ecological or financial stewardship.)

Current DCR policies implicitly rank urban wilds in LSZ 3, "already developed landscapes or areas that may be suitable for future development as intensive use areas." Thus at the goose meadow in Cambridge the agency has worked (illegally) for years to develop it, first as part of the BU campus and, soon, as a maintenance area following its three years as the DCRdesignated construction site for BU Bridge repairs.

Even at Herter West, with its vernal pool, snakes, rabbits, hawks, and songbirds, the Master Plan proposes to "strengthen [its] habitat value" by "regrading the area to address its drainage problem" with "a significant amount of fill . . . to give a better shape to the land" and with paved paths (Charles River Master Plan, section 8S, pp. 139-41). Without official recognition of DCR's urban wilds, and with Harvard's plans for abutting properties in Allston, this proposed crime against the environment may actually take place when money is available. (Herter West is also the site of illegal cutting and clearing, done under the auspices of the Charles River Conservancy.)

If urban wilds were protected, and if public recreation clearly included engagement with the natural world, LSZ 2 might be suitable: "typical yet important natural and cultural resources. . . . the keystone to DCR's management responsibilities, because the protected landscape provides a buffer for sensitive resources, recharge for surface and groundwater, and large areas where typical public recreation activities can be managed at sustainable levels." But the draft is silent on these points.

Instead it confirms the Charles River parklands as ripe for further development and recreation as primarily strenuous physical activity, Appendix 3 notwithstanding. The guidelines propose that "all management activities in Parklands should focus on maintaining or improving the recreational experiences of visitors" (p. 21). The "ecological services" the land provides are the setting for such activities.

With a nod to environmental education, there is little if any understanding of engagement with the natural world itself.

Observation, study, taking inspiration from it is absent from the draft. On this point, please note the parklands' designer, Charles Eliot, whose biographer reports that "[i]n contrast to Olmsted's retreat into a private contemplation of nature, Eliot compared scenery or landscape to other advantages of urban culture, especially books and art" ( Urban wilds provide just this opportunity for profound recreation.

The draft's understanding of parkland and recreation reinforces the Charles River Master Plan. As it suggests, Master Plans "may be developed for a complex capital project" (p. 7), and this has been the case on the Charles. The agency has been at the service of major institutions like Harvard, Boston University, and MIT, eager to help them incorporate the park into their campuses, willing to destroy urban wilds in the process. It invokes the Master Plan to justify every development.

In December, 2001, Herb Nolan, DCR's consultant for the Master Plan, told a meeting that most people "like the river as it is. We wish they were a little less happy with it" (3 December, 2001, my notes). Opportunities for the exploration and enjoyment of urban wilds are high on the list of what people like here. As long as landscape architects dominate the agency's planning function, DCR personnel who actually understand this issue will lose their bureaucratic battles over what constitutes proper stewardship, and the public will lose these assets.

It's not possible to discuss the draft completely in this format. I send my comments on in hopes review of the Final Draft with allow for recognition and protection of urban wilds in the parklands designation.

Yours sincerely,
Marilyn Wellons
Cambridge, MA 02139

FROM: Ellen Mass
DATE: 8/13/2011 11:50:35 AM
SUBJECT: Friends of Alewife Reservation Response Plan

Tim Rayworth
Internal Working Group for the Landscape Designation Process
MA Department on Conservation and Recreation

Dear Tim Rayworth,

DCR designations of Reserves, Parklands, Reserves, have put the Alewife Reservation of DCR between a rock and a hard place, but I will, this week, respond to what you have as final draft of the DCR "Landscape Designations for Parks and Forests".

My regret is that we at Alewife have been at a disadvantage because of the tremendous confusion, battles and misery over the cutting up of the Alewife Reservation with minimal assistance from DCR to communicate and follow up with loyal community representatives who have long promoted DCR as a vital state agency and conservation protector of our natural lands and historic places.

We have spoken to Senior Planning to little avail, but will continue to try to work closely and productively with you all despite failure in the past to accomplish plans and goals at Alewife with key members of the Alewife community.

We'll continue to put many hours of volunteer time into proving our Reservation is worthy of consideration. We just ended our 5th annual Alewife Ecology Camp supported by the city and grants and the DCR rangers.

As you know, one of the biggest environmental storm water projects of the state of Mass. and possibly beyond is presently taking place at Alewife, between Belmont, Cambridge and Arlington and one of the biggest developers in the country is working behind the scenes in all of this difficulty, and his development system is challenging the public state agency in charge (you) and the communities and municipalities to uphold and enforce our state environmental standards and our FEMA requirements for that area. We know that your designations have put us in a general parkland category, where development is given great leeway.

Much legislation has been put through, and we have tried to designate it as specially protected land (?) processed under former state Legislator Anne Paulsen. And Rep. Rep. Brownsberger has passed 2 bills through House and Senate which give you some of the most valuable land in the Commonwealth (on a T stop) by buying it together with the towns and city. However, DCR was not interested which did not encourage the Governor to sign and has hindered our efforts, and which goes against your Final Draft in your purposes and intent to protect such valuable land and forest area.

I regret the need to stand clear on these egregious mistakes, but it is not too late, and that is why I must respond before your 26th deadline, despite health and other obstacles for me, personally.

Thank you for sending this and extending the deadline for groups like ours.

Ellen Mass
Friends of Alewife Reservation
Cambridge, MA 02138