The NRC says dogs are damaging to conservation lands…
There is little evidence that dogs damage conservation lands and no direct evidence that Concord’s lands have been negatively impacted by off-leash dogs. The studies cited by the NRC are inconclusive and are not based on credible or defensible data. The NRC’s only effort to collect data was to send two rangers (summer employees, with no experience or background) to various trail heads at randomly selected town properties. Their anecdotal observations were that there is no problem with dogs, except at White Pond where erosion is a problem. Whether erosion is dog induced is unlikely and needs to be investigated in a more rigorous manner.
The NRC says there is an increased number of dog related incidents on conservation lands…
Police records indicate otherwise. The numbers of dog related incidents since 2012 has declined significantly from 141 in 2012 to just 84 in 2016. 2017 is estimated at 80. Further more, the definition of “incidents” is wide ranging and suggests that there needs to be closer scrutiny as what “incidents” actually relate to off-leash activities.
The NRC says they are restricting people and dogs to leashes in Punkatasset to be in line with neighboring properties and that Punkatasset is a nature preserve…
The Punkatasset deed calls for recreation and allows for grazing of animals. It does NOT specify it as a nature preserve. Allowing abutter’s to dictate policy is dangerous and against the very spirit of what was intended for the general, responsible use of conservation land by Concord town citizens. It is not clear whether there has been any investigation as to the true motives of the abutters complaints which appear to be more focused on the fact that they don’t want to deal with the traffic that conservation land brings verses specifically related to whether dogs are on leashes or not.
The NRC says that dogs must be kept off of all agricultural land for compliance with Food Safety Act…
The fact sheet provided by the US FDA on the final FSMA rules says “As was stated in the supplemental rules, famers are NOT required to exclude animals from outdoor growing areas, destroy animal habitat, or clear borders around growing or drainage areas. Nothing in the rule should be interpreted as requiring or encouraging such actions.”
The NRC has not tried less restrictive measures to solve their non-existent problem based on no credible evidence…
We request a moratorium on these proposed regulations to allow the NRC to collect sound, unbiased data, and to work with responsible dog owners to educate the public.
The NRC says only 12% of lands will be affected by their proposed regulations…
This will have a town-wide impact and should be voted on at Town Meeting. As citizens of Concord we are all owners of town conservation land and are being disenfranchised without cause. The NRC’s proposals will affect usage at other areas by pushing us off lands we all paid for, crowding us into smaller and smaller areas.
While appearing to follow an open meeting format, it is abundantly clear that the NRC began this process with a predetermined outcome in mind which is very disappointing. They have not listened to the over 1000 concerned citizen participants or rigorously debated the facts based on actual evidence and data, which is not in the spirit or intention of governing councils endorsed by the Concord town government. By ignoring the thoughtful and well researched input from the hundreds of citizens who have spoken, written and attended meetings, they have alienated and disenfranchised this very large, vibrant community who perhaps appreciate, and moreover RESPECTS these lands and the opportunity to enjoy them the most.
A simple question for the NRC… Why wasn’t this relatively mundane matter resolved with better awareness, education and improved facilities by working together?