January 29, 2022
Ms. Tracy Swartout, Superintendent
Blue Ridge Parkway
199 Hemphill Knob Rd
Asheville, NC 28803
Dear Superintendent Swartout:
I am writing to you on behalf of over 2,100 members of the Coalition to Protect America’s National Parks (Coalition), a non-profit organization composed of retired, former, or current employees of the National Park Service (NPS). The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. As a group we collectively represent nearly 40,000 years of experience managing and protecting America’s most precious and important natural and historic resources. Among our members are former NPS directors, regional directors, superintendents, environmental and resource specialists, NEPA practitioners, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.
As described on the park’s PEPC website for this project:
The IRONMAN Group has requested a Special Use Permit (SUP) to allow a portion of the cycling segment of the Carillion Clinic IRONMAN 70.3 Ironman Virginia’s Blue Ridge triathlon to take place on the Parkway. The IRONMAN Group has requested a full, two-lane motor road closure from mid-afternoon June 4, 2022 through mid-afternoon June 5, 2022 to ensure the safety of riders, motorists, and event staff; as well as to provide safe and expeditious movement of event support and emergency vehicles. The proposed closure would be approximately 21 miles from VA-43 at parkway milepost 91.0 to VA-24/Washington Avenue at Parkway milepost 112.2. Per Virginia Department of Transportation (VDOT) representatives, VA-43 from Buchanan to the Parkway will be fully closed during the event.
Our primary concerns with the proposed SUP are the following:
1. If NPS issues the SUP as requested for an event during a typically busy weekend in June, numerous park visitors would be unable to visit the 21-mile section of the Parkway that would be closed by the event – The Blue Ridge Parkway is one of the most heavily visited units of the National Park System; and June is typically one of the most heavily visited months at the Parkway. As a result, the proposed race has the potential to negatively impact hundreds if not thousands of park visitors who would be denied access to this portion of the Parkway during a 24-hour period. See NPS Visitor Use statistics at: irma.nps.gov/stats/BLRI
2. The proposed event conflicts with applicable NPS regulations and management policies – These include the following:
A. 36 CFR § 2.50 Special events, which states, in part:
(a) Sports events, pageants, regattas, public spectator attractions, entertainments, ceremonies, and similar events are allowed: Provided, however, there is a meaningful association between the park area and the events, and the observance contributes to visitor understanding of the significance of the park area, and a permit therefor has been issued by the superintendent. A permit shall be denied if such activities would:
(1) Cause injury or damage to park resources; or
(2) Be contrary to the purposes for which the natural, historic, development and special use zones were established; or unreasonably impair the atmosphere of peace and tranquility maintained in wilderness, natural, historic, or commemorative zones.
(3) Unreasonably interfere with interpretive, visitor service, or other program activities, or with the administrative activities of the National Park Service; or
(4) Substantially impair the operation of public use facilities or services of National Park Service concessioners or contractors; or
(5) Present a clear and present danger to the public health and safety; or
(6) Result in significant conflict with other existing uses.
B. NPS Management Policies 2006, Section 8.6.2.1 Special Events, General, which states, in part:
The Park Service will not permit the staging of an event in an area that is open to the public, or the closure of an area that is open to the public, when the event
• is conducted primarily for the material or financial benefit of a for-profit entity; or
• awards participants an appearance fee or prizes of more than nominal value; or
• requires in-park advertising or publicity (unless the event is co-sponsored by the Service); or
• charges a separate public admission fee.
In this case, the IRONMAN Group is a for-profit entity. See https://www.ironman.com/about-ironman-group. The individual entry fee for the race is $399 per person until January 30, 2022; then the fee will increase. See https://www.ironman.com/im703-virginia-blue-ridge-register. Permitting this for-profit event and closing a portion of the Parkway during the event is in clear conflict with the above section of the CFR.
3. Permitting this event would establish a harmful precedent for the Parkway as well as for other National Park Systems Areas – Permitting this event at the Blue Ridge Parkway would be in direct conflict with the purpose of the park that speaks to visitor enjoyment of the Parkway and the scenic views; and would establish a harmful precedent for future events. Although the NPS has previously permitted organized bicycle rides, not competitive races, at the Parkway, approval of those events did not result in road closures. Participants were required to ride in single file; and other park visitors were not excluded from traveling the entirety of the Parkway during the event.
Similar permit requests for competitive bicycle races at other parks have been denied by the NPS. For example, in 2011 NPS Director Jonathan Jarvis denied a request to route a professional bicycle race through Colorado National Monument. The request had previously been denied in late 2010 by Superintendent Joan Anzelmo; however, Colorado elected officials appealed that decision to Director Jarvis, who subsequently affirmed the denial. See https://archive.nytimes.com/www.nytimes.com/gwire/2011/03/25/25greenwire-pro-cycling-race-barred-from-colorado-national-50222.html.
In closing, for the reasons stated above, we believe the proposed IRONMAN Group race on a portion of the Blue Ridge Parkway in an inappropriate use that should not be permitted by the NPS. We appreciate the opportunity to comment on this important issue.
Sincerely,
Michael B. Murray, Chair
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013
cc: Cassius Cash, Acting Regional Director, National Park Service