Assabet River NWR Final CCP - U.S. Fish and Wildlife Service

Appendix C: Responses to Substantive Comments
for unauthorized access. In other cases, the requests are for new trails that would provide
access to new areas.
Refuge staff will develop a system for evaluating such requests. This review system will
provide refuge staff with the necessary tools to evaluate the need for and effects of
recommended trails.
Non-wildlife Dependent Public Uses
Dog Walking
A large number of commentors assert that given the popularity and demand for areas to
walk dogs, and the fact that parts of the refuge have been used responsibly for decades by
dog-walkers, FWS should continue to allow dog walking and should authorize it at
Assabet River NWR. Some commentors express support for a ban of dogs from the refuge;
they cited safety concerns, conflicts between dog walkers and bird watchers, and owners
that do not clean up after their dogs.
All of the refuges in the Eastern Massachusetts National Wildlife Refuge Complex were
created with purposes related to protecting, managing, and conserving native wildlife. The
1997 Refuge Improvement Act establishes the mission of the Refuge System as “to
preserve a national network of lands and waters for the conservation and management of
fish, wildlife, and plant resources of the United States for the benefit of present and future
generations.” The Refuge Improvement Act further stipulates that all activities occurring
on refuges must be compatible with wildlife conservation and the specific purposes for
which a refuge was established. This is an important distinction from other public lands
and recreation areas; refuges have a narrow management focus and are not multi-purpose
lands. Six public uses were identified by the Refuge Improvement Act as the priorities for
receiving enhanced consideration on refuges. Dog walking is not one of the six priority
public uses, nor are dogs (except hunting, seeing or hearing dogs) necessary to support the
safe, practical, and effective conduct of the priority public use programs we would be
implementing on the refuge.
Dogs running off leash and piles of dog waste left on trails or tossed in the bushes are
consistent problems, not isolated incidences. Several circumstances prompted the
elimination of this activity on the refuges, including
• Dogs can intimidate other refuge visitors, and deprive them of the peace that
refuges provide. Visitation to the National Wildlife Refuges is expanding,
potentially aggravating user conflicts;
• Dog feces left on trails are an unhealthy and unsightly nuisance to refuge visitors
and impact refuge vegetation. The presence of dog feces on public trails is one of
the most common complaints we receive;
• Dogs, whether leashed or unleashed, conflict with refuge efforts to provide
recreational opportunities for a diversity of visitors, including those limited to
handicapped accessible trails, and the many school groups which visit the refuges
for environmental education;
• Dog walking has resulted in user conflicts with persons engaged in priority public
uses (bird watching, photography, see below);
Comprehencive Conservation Plan - 163 -